DRC-2019-003761 - 0901a06880a29650

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com ENERGY FUELS
April 18, 2019
SENT VIA OVERNIGRT 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
D RC-2019- 00377I
Div of Waste Manastrfx111
and Radiation Contrtol
APR 2 4 2019
•Re: Application by Energy Fuels Resources (USA) Inc. ("EFRI") for an amendment to
State of Utah Radioactive Materials License No. 1900479 for the VVhite Mesa Uranium Mill
(the "Mill") to authorize processing of NPM Silmet OU ("Silmet") alternate feed material
(the "Uranium Material")
Dear Mr. Howard:
We are pleased to enclose with this letter 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 uraniurn and disposal of the
resulting tailings in the Mill's tailings impoundments as 1 le.(2) byproduct material.
Silmet is licensed to store up to 615 metric tons of uranium material on site at their facility in
Estonia. Based on current production rates, Silmet anticipates that limit will be reached by late
2019. EFRI plans to enter into an agreement with Silmet to allow shipment of the uranium material
to the Mill as soon as reasonably possible. Please contact us as to the anticipated timeframe
required for DWMRC to review this application.
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
David Frydenlund
Mark Chalmers Paul Goranson
Logan Shinnway
Terry Slade
Scott Bakken
April 18, 2019
SENT VIA OVERNIGHT DELIVERY
Mr. Ty L. Howard
Director
Di vision 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 NPM Silmet OU ("Silmet") alternate feed material
(the "Uranium Material")
Dear Mr. Howard:
We are pleased to enclose with this letter 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.
Silmet is licensed to store up to 615 metric tons of uranium material on site at their facility in
Estonia. Based on current production rates, Silmet anticipates that limit will be reached by late
2019. EFRI plans to enter into an agreement with Silmet to allow shipment of the uranium material
to the Mill as soon as reasonably possible. Please contact us as to the anticipated timeframe
required for DWMRC to review this application.
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
cc: David Frydenlund
Mark Chalmers
Paul Goranson
Logan Shumway
Terry Slade
Scott Bakken
REQUEST TO AMEND
RADIOACTIVE MATERIALS LICENSE
ENERGY FUELS RESOURCES (USA) INC.
WHITE MESA URANIUM MILL
SAN JUAN COUNTY, UTAH
AND
ENVIRONMENTAL REPORT
for
Processing of
Alternate Feed Material
from
NPM Silmet OU
Prepared for:
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, UT 84114-4880
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600,
Lakewood, CO 80228
April 18, 2019
Energy Fuels Resources (USA) Inc.
TABLE OF CONTENTS
1.0 INTRODUCTION .............................................................................................................. 1
1.1 WHITE MESA MILL ........................................................................................................... 1
1.2 PROPOSED ACTION ............................................................................................................ 1
1.3 PURPOSE OF ACTION .......................................................... ················ ............................... 1
1.4 AMENDMENT APPLICATION AND ENVIRONMENTAL REPORT ............................................. 2
2.0 MATERIAL COMPOSITION AND VOLUME ............................................................. 2
2.1 GENERAL .......................................................................................................................... 2
2.2 HISTORICAL SUMMARY OF SOURCES ................................................................................ 4
2.3 QUANTITY OF MATERIAL .................................................................................................. 5
2.4 RADIOCHEMICAL DATA ..................................................................................................... 6
2.5 PHYSICAL AND CHEMICAL DATA ...................................................................................... 6
2.6 COMPARISON TO OTHER ORES AND ALTERNATE FEED MATERIALS LICENSED FOR
PROCESSING AT THE MILL ............................................................................................................ 6
2.6.1 Ores and Alternate Feed Materials With Similar Radiological Characteristics ......... 6
2.6.2 Ores and Alternate Feed Materials With Similar Chemical/Metal Characteristics .... 8
3.0 REGULATORY CONSIDERATIONS ........................................................................... 8
3.1 ALTERNATE FEED GUIDANCE ............................................................................................ 8
3.2 URANIUM MATERIAL QUALIFIES AS "ORE" ...................................................................... 8
3.3 URANIUM MATERIAL NOT SUBJECT TO RCRA ................................................................. 8
3.3.1 General ......................................................................................................................... 8
3.3.2 EFRIIUDEQ Listed Hazardous Waste Protocol .......................................................... 9
3.3.3 Application of the Listed Hazardous Waste Protocol ................................................ 10
3.3.4 Radioactive Material Profile Record ......................................................................... 11
3.3.5 Conclusion .................................................................................................................. 12
3.4 URANIUM MATERIAL IS PROCESSED PRIMARILY FOR ITS SOURCE MATERIAL CONTENT 12
3.5 OTHER LICENSING CONSIDERATIONS .............................................................................. 12
4.0 AFFECTED ENVIRONMENT ...................................................................................... 13
4.1 GENERAL ........................................................................................................................ 13
4.2 TRANSPORTATION CONSIDERATIONS .............................................................................. 16
4.2.1 Packaging and Mode ofTransportation ..................................................................... 16
4.2.2 Transportation Impacts .............................................................................................. 17
4.2.3 Transportation Accidents ........................................................................................... 19
4.3 STORAGE ......................................................................................................................... 19
4.3.1 Manner of Storage ...................................................................................................... 19
4.3.2 Environmental Impacts Associated With Storage ...................................................... 19
4.4 PROCESS .......................................................................................................................... 19
4.4.1 Mill Accidents and Emergency Response ................................................................... 20
4.5 COMPATIBILITYWITHEFRIMILL TAILINGS ................................................................... 21
4.5.1 Physical Compatibility ............................................................................................... 21
4.5.2 Capacity and Throughput ........................................................................................... 23
Request to Amend Radioactive Materials License
Energy Fuels Resources (USA) Inc.
4.5.3 Mill Tailings Closure and Reclamation ...................................................................... 23
4.6 GROUNDWATER·············································································································· 23
4.7 SURFACE WATER ············································································································ 24
4.8 AIRBORNE RADIOLOGICAL IMPACTS ............................................................................... 25
4.9 RADON AND GAMMA IMPACTS ........................................................................................ 25
4.10 SAFETY MEASURES .................................................................... ····· ................................ 25
4.10.1 General ................................................................................................................... 25
4.10.2 Radiation Safety ...................................................................................................... 25
4.10.3 Occupational Safety ................................................................................................ 26
4.10.4 Vehicle Scan ............................................................................................................ 27
4.11 LONG TERM IMPACTS ...................................................................................................... 27
4.12 0THER0PERATIONALCONSIDERATI0NS ........................................................................ 27
4.13 ADDED ADVANTAGE OF RECYCLING ............................................................................... 27
4.14 CONSIDERATION OF ALTERNATIVES ................................................................................ 27
5.0 CERTIFICATION ........................................................................................................... 29
ATTACHMENTS
Attachment 1 NPM Silmet OU' s (Silmet) Sillamae, Estonia Facility Information
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 Constituents in Silmet Uranium Material to Determine the
Potential Presence of RCRA Characteristic or RCRA Listed Hazardous Waste
Attachment 5 Review of Chemical Constituents in Silmet Uranium Material to Determine
Worker Safety and Environmental Issues and Chemical Compatibility at the EFRI
White Mesa Mill
Attachment 6 Cross Index to DWMRC 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 lle.(2)
byproduct material. The Uranium Material is similar to the alternate feed materials the Mill is
currently licensed to receive from the Cabot and Fansteel Metals Recovery, Inc. ("FMRI")
facilities, which are also residues from tantalum and niobium processing facilities.
1.2 Proposed Action
This is a request for an amendment to State of Utah Radioactive Materials License ("RML") No.
UT 1900479 to authorize receipt and processing of certain uranium containing materials. These
materials are residuals resulting from purification of columbite and tantalite mineral ores
processed via an acid leach process for recovery of columbium ("niobium") and tantalum
conducted in NPM Silmet OU's ("Silmet's") tantalum and niobium production plant (the
"Facility") in Sillamae, Estonia. 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 0.05% uranium on both a wet and dry basis. The
Uranium Material is the uranium-containing residue (or "tailings") from the Facility which has
been dried and calcined to oxidize the residual minerals and remove water content (reduce
volume), then cooled and packaged in closed drums for off-site recovery or disposal.
Because the Uranium Material contains elevated levels of naturally-occurring radionuclides, its
collection and storage has been regulated by the Republic of Estonia under Silmet's
Radioactivity License 14 010. License 14 010 limits the quantity of residue collected and stored
on site at the Facility to 615.5 metric tonnes. To date, the Facility has accumulated and stored
600 metric tonnes (660 tons) of material, in over 2,000 drums. Because the Facility has
approached its licensed storage limit, Silmet has temporarily suspended the niobium and
tantalum recovery operations which produce the Uranium Material.
Silmet's Radioactivity License 14 010, authorized on January 30, 2014, expired on January 31,
2019. The Ministry of Environment of the Republic of Estonia has required that Silmet
demonstrate they have arranged with an off-site facility appropriately licensed for recovery or
disposal of the Uranium Material, prior to renewal of Silmet's license and resumption of
niobium/tantalum recovery operations. Silmet is seeking to remove the material off-site, as soon
as practicable, for reprocessing or disposal. No facility within the Republic of Estonia is
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Energy Fuels Resources (USA) Inc.
currently licensed for either the direct disposal or the reprocessing of the Uranium Material.
Although the Estonian government is planning to build a disposal facility, it is not expected to be
completed for a number of years. Silmet would like to recycle the Uranium Material for the
recovery of uranium if possible. No facility within the Republic of Estonia is capable of
reprocessing and recovery of any component of the Uranium Material at this time. In order to
recycle the Uranium Material, Silmet desires to send the material to the White Mesa Mill, which
has a long history of successfully processing such types of alternate feed materials for the
recovery of uranium.
EFRI has been requested by Silmet to make this application to process the Uranium Material as
an alternate feed material at the Mill for the recovery of uranium 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 Silmet to meet the requirement of the Estonian Ministry of Environment to confirm
a licensed off-site destination for the Uranium Material, and to resume operations at the
Facility.
Reprocessing at the Mill will afford Silmet a cost-effective and productive mechanism for
managing the Uranium 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 ("ER") 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 Facility currently operates a niobium and tantalum, production plant located in the Republic
of Estonia.
The Republic of Estonia1 is a country in Northern Europe. It is bordered to the north by the Gulf
of Finland with Finland on the other side, to the west by the Baltic Sea with Sweden on the other
11 This summary information about Estonia is drawn from Wikipedia.
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side, to the south by Latvia (343 km), and to the east by Lake Peipus and Russia (338.6 km).
The territory of Estonia consists of a mainland and 2,222 islands in the Baltic Sea, covering a
total area of 45,227 km2 (17,462 sq mi), water 2,839 km2 (1,096 sq mi), land area 42,388 km2
(16,366 sq mi), and is influenced by a humid continental climate. The official language of the
country, Estonian, is the second most spoken Finnie language.
The territory of Estonia has been inhabited since at least 9,000 B.C. Ancient Estonians were
some of the last European pagans to be Christianized, following the Livonian Crusade in the 13th
century. After centuries of successive rule by Germans, Danes, Swedes, Poles and Russians, a
distinct Estonian national identity began to emerge in the 19th and early 20th centuries. This
culminated in independence from Russia in 1920 after a brief War of Independence at the end of
World War I. Initially democratic, after the Great Depression Estonia was governed by
authoritarian rule since 1934. During World War II (1939-1945), Estonia was repeatedly
contested and occupied by the Soviet Union and Germany, ultimately being incorporated into the
former as the Estonian Soviet Socialist Republic. After the loss of its de facto independence,
Estonia's de jure state continuity was preserved by diplomatic representatives and the
government-in-exile. In 1987 the peaceful "Singing Revolution" began against Soviet rule,
resulting in the restoration of de facto independence on 20 August 1991.
The sovereign state of Estonia is a democratic unitary parliamentary republic divided into fifteen
counties. Its capital and largest city is Tallinn. With a population of 1.3 million, it is one of the
least-populous member states of the European Union since joining in 2004, the economic
monetary Eurozone, Organization for Economic Co-operation and Development, Schengen Area,
and of the Western military alliance of the North Atlantic Treaty Organization (NATO). It is a
developed country with an advanced, high-income economy that has been among the fastest-
growing in the European Union. Estonia ranks very high in the Human Development Index, and
performs favorably in measurements of economic freedom, civil liberties, education, and press
freedom (third in the world in 2012 and 2007). Estonian citizens are provided with universal
health care, free education, and the longest-paid maternity leave in the Organization for
Economic Cooperation and Development. One of the world's most digitally advanced societies,
in 2005 Estonia became the first state to hold elections over the Internet, and in 2014 the first
state to provide e-residency.
The Facility is located on a property which formerly contained a shale oil production plant from
1927 to 1940. A uranium production pilot plant was constructed on the site in 1944, following
the commencement of the Soviet Union's occupation of Estonia. A separate portion of the
Facility produced uranium oxides from local shale ores from 1944 through 1952. The Facility
subsequently began receiving other uranium-containing ores in 1952, and continued to produce
uranium oxides, including reactor-grade enriched uranium products from 1982-1988, in this
separate portion of the Facility, until uranium production ceased in 1990. In 1970, concurrent
with the uranium operations, the plant began receiving loparite ores and began the recovery of
niobium and tantalum in one process area, and rare earths from loparite ores in a separate process
area, both of which were separate and independent from the uranium processing and enrichment
areas. After 1990, the plant no longer received loparite ores, and began to process columbite and
tantalite ore residue concentrates for niobium and tantalum production. Processing of columbite
and tanatalite ores occurs in the same separate portion of the Facility used to process the loparite
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ores. Niobium and tantalum recovery continues to the present time. The Uranium Material was
produced specifically from operations since 2000 in the plant area and process operation which
recovers niobium and tantalum, as discussed in Section 2.3, below.
Prior to 2000, all tailings and wastes from the uranium processing and enrichment activities, as
well as tailings from the loparite ore processing and columbite and tantalite ore residue
concentrates, were disposed of in a radioactive tailings pond near the Facility. That pond was
taken out of service in 1999 and decommissioned by a third party between 1999 and 2009. From
1999 onward, because the pond was no longer available, the residues from the ongoing
columbite and tantalite ore residue processing operations were filtered into filter cake, calcined
to remove the remaining moisture, and packaged in 55-gallon metal drums lined with triple-
walled polyethylene bag liners and stored as Uranium Material. The currently accumulated
Uranium Material is comprised of the drums of material that had accumulated through this
process and have been stored at the Facility since 1999. As the columbite and tantalite ore
residue processing operations continue to be active, Uranium Material is expected to continue to
be produced in this same fashion at the rate of approximately 80 tons/yr. indefinitely. This
license amendment application covers the currently accumulated Uranium Material as well as the
Uranium Material that is expected to continue to be produced going forward.
The Uranium Material does not include residuals from oil shale production, from uranium
production or enrichment, rare earth recovery, or from other previous operations at the Facility.
It does not include any material from the former radioactive tailings pond or from the
decommissioning of the former pond which has been conducted by entities other than Silmet.
The Uranium Material is comprised only of residuals from the current Silmet niobium and
tantalum recovery unit, which were directly calcined, dried, and drummed after generation in a
closed process, independent of other historic activities at the Facility. No other processing
activities, other than the current niobium and tantalum recovery operations, have occurred at the
site since 2000.
2.2 Historical Summary of Sources
The Uranium Material consists of the residuals from niobium and tantalum recovery from
columbite and tantalite ore concentrates. It does not include residuals from oil shale production,
from uranium production or enrichment, rare earth recovery, or from other previous operations
at the Facility. It does not include materials from the former radioactive materials pond at the
Facility.
Columbite and tantalite-containing mineral ore concentrates were processed via acid-leaching to
separate the insoluble impurities, including uranium and some thorium, from niobium and
tantalum. The ores were crushed and milled, then dissolved in hydrofluoric and sulfuric acid,
and removed in solution phase. The insolubles, containing uranium and thorium, were removed
from solution. The precipitate was filtered, and the filter cake was transferred to the calcining
unit, in the same building. The filter cake was calcined and dried in electric rotary kilns, cooled
in rotary coolers and placed into metal drums lined with triple-walled polyethylene bags.
The process which generated the Uranium Material is isolated from the remainder of site
operations. Columbite and tantalite ores are processed in a separate milling area, for which the
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Energy Fuels Resources (USA) Inc.
feed, grinding and discharge steps are controlled by hermetically sealed equipment, primarily for
the management of radioactive dusts. Acid leaching, washing, filtration, electric rotary
calcining, rotary cooling and packaging are all conducted in automated closed systems. Hence,
the Uranium Material is isolated from other materials on site from feed source through drum
packaging.
The process which produced the Uranium Material is comparable to the process which produced
other alternate feed materials previously licensed for receipt and processing at the Mill. The
table below compares the source of Silmet Uranium Material to the sources of previously
licensed alternate feeds.
Alternate Feed Niobium Tantalum
Source Production Production
Cabot X X
Fansteel X X
Silmet X X
EFRI has been requested by Silmet 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.. By providing Silmet with the option of
processing the Uranium Material at the Mill, Silmet will be given the option of 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
Silmet has requested that EFRI recycle the uranium material and has asked that EFRI submit this
Amendment Request. Silmet estimates that the total volume of Uranium Material accumulated
to date is approximately 600 metric tonnes (660 tons). The material has been dried and calcined,
therefore this value is essentially a dry weight quantity, and chemical and radiochemical data
discussed in this application and attachments are on a dry weight basis. Based on Silmet's prior
Radioactivity License, the Facility is permitted to accumulate an average of 72.5 metric tonnes
(80 tons) per year of Uranium Material. This application anticipates that the Mill could
potentially receive the accumulated material plus Uranium Material annually for a total of at
least 1,325 metric tonnes (1,460 tons) assuming at least 10 years of annual Uranium Material
production. It has been EFRI' s experience with other alternate feed materials from comparable
sources that the initial estimate may increase by as much as 50 percent or more by the time of
receipt, due to factors such as under-estimation of numbers of containers and other variables.
Therefore, in order to allow for these factors and the potential to receive annual increments of
Uranium Material for greater than 10 years, this Request for Amendment is for approval of
approximately 2,200 tons dry weight of Uranium Material, to ensure that all the Uranium
Material for a reasonable period of time is covered by this Amendment.
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2.4 Radiochemical Data
As noted, the process history demonstrates that the Uranium Material results from the recovery
of niobium and tantalum from columbite and tantalite ore concentrates. Silmet has estimated
that the current Uranium Material has a uranium content ranging from 0.14 to 0.35 dry weight
percent natural uranium or 0.17 to 0.41 dry weight percent U30s. The uranium content may be
expected to average approximately 0.23 dry weight percent natural uranium or 0.27 dry weight
percent U30s. As discussed in section 1.3 above, the Uranium Material has been dried and
calcined, hence all available data is on a dry weight basis. As noted in the Radioactive Materials
Profile Record ("RMPR") and on the Table below, the Thorium-232 content will likely range
from 542 to 2,160 picocuries per gram dry weight basis ("pCi/g-dry"). A more detailed
radiological characterization of the Uranium Materials (see Section 2.6.1, below) is contained in
the RMPR (Attachment 2). The radionuclide activity concentration of the Uranium Material is
comparable to Colorado Plateau ores and alternate feed materials which the Mill is currently
licensed to receive (see Section 2.6.1, below).
2.5 Physical and Chemical Data
Physically, the Uranium Material consists of dry, calcined, powdered solids, 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 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 feeds, at levels generally
comparable to or higher than those reported in the Uranium Materials.
2.6 Comparison to Other Ores and Alternate Feed Materials Licensed for
Processing at the Mill
2.6.1 Ores and Alternate Feed Materials With Similar Radiological Characteristics
With an average uranium content of approximately 0.17 to 0.41 percent U30s, the Uranium
Material is comparable to a high-grade Colorado Plateau ore. Colorado Plateau ores typically
average from approximately 0.18 percent to 0.3 percent U30s.
The estimated average content of total natural thorium (Th-232) ("Th-nat") of approximately
2,200 pCi/g-dry is higher than normally encountered with natural ores but well within the range
of previously licensed alternate feed materials at the Mill.
For example, the average concentrations of Th-nat in the Sequoyah Fuels alternate feed material
averaged 2,385 pCi/g Th-232, and many other alternate feed materials have had elevated
concentrations of Th-nat. The Uranium Material will be handled at the Mill under the Mill's
radiation safety program in a manner appropriate for such materials.
The table below compares the radionuclide content of the Uranium Material and that of other
alternate feed materials and natural uranium ores previously approved for processing at the Mill.
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Range of Uranium Previously Licensed Material Alternate Feed Radionuclide Radionuclide Radionuclide Activity Source for Alternate
Activity Concentrations Feed Information
Concentration
(pCi/g dry) (pCi/g dry)
2,000 avg; 10,400 max W.R.Grace Application
April 2000
Ra-226 445 max CaF2 annual feed analysis
Average 1332 2018
1650 pCi/g Typical Arizona Strip
Natural Uranium Ores
2,000 avg.; 3,222 max W.R.Grace Application
527 to 1,790 April 2000
Th-228 Sequoyah Fuels
Average 1,033 1,110 max Application
August 2013
75.5 mg/kg (1,555,000 Nevada Test Site Cotter
pCi/g) avg., 143 mg/kg Concentrate Application
(2,330,000 pCi/g) max. March 1997
Th-230 507 to 1,300 8,000 avg.; 31,500 max W.R.Grace Application
Average 900 April 2000
46,300 pCi/g Sequoyah Fuels annual
alternate feed sample
Sequoyah Fuels
542 to 2,160 2,385 avg.; 4,990 max Application
Th-232 August 2013
Average 1,200 1,190 avg. Heritage RMPR, undated
Unat 1,400 mg/kg to 3,500 686,000 mg/kg max Mill lab monthly assays
mg/kg of Cameco UF4
Note: Values are in pCi/g unless otherwise stated.
Energy Fuels Resources (USA) Inc.
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 feeds,
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 lle.(2) byproduct material, the feed material must qualify as "ore". NRC
has established the following definition of ore: Ore is a natural or native matter that may be
mined and treated for the extraction of any of its constituents or any other matter from which
source material is extracted in a licensed uranium or thorium mill. The Uranium Material is an
"other matter" which will be processed primarily for its source material content in a licensed
uranium mill, and therefore qualifies as "ore" under this definition. Further, the uranium
concentration of the Uranium Material is greater than 0.05 percent on both a wet and dry basis,
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 Resource
Conservation and Recovery Act ("RCRA") authorized State regulations), it would be subject to
EPA (or State) regulation under RCRA. However, the Guidance provides that if the licensee can
show that the proposed feed material does not consist of a listed hazardous waste, this issue is
resolved. NRC guidance further states that feed material exhibiting only a characteristic of
hazardous waste (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
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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 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 contemplated 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
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;
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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 constituents 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.
The Uranium Material is produced solely as a residual from the processing of columbite and
tantalite ore concentrates for recovery of tantalum and niobium, a known process under the
control of the generator. No other wastes from the niobium/tantalum process, and no residuals
from any other process at the Facility enter the rotary kilns, the rotary coolers or the collection
drums where the Uranium Material is generated and packaged.
NPM Silmet OU Radiation Activity License 14 010, approved on January 30, 2014, authorized
Silmet to collect and store up to a licensed limit of 615.5 metric tonnes of calcined Uranium
Material generated from the tantalum/niobium circuit. Silmet's Radiation Activity License
expired on January 30, 2019. The quantity collected on site prior to expiration of the Radiation
Activity License, 600 metric tonnes, approached the licensed limit.
Although the license limit has not been reached, Silmet and the Ministry of Environment of the
Republic of Estonia have agreed that Silmet will cease further production of niobium/tantalum,
and therefore cease production of Uranium Material, and that renewal of the Radioactivity
License will be delayed until such time as Silmet demonstrates they have confirmed an
appropriately-licensed off-site destination for the material. Silmet has suspended
niobium/tantalum processing, the only source of the Uranium Material, pending renewal of the
Radioactivity License.
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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 an affidavit declaring that the Uranium Material is not and does not contain
RCRA listed hazardous waste. This determination is consistent with Boxes 1 and 2
and Decision Diamonds 1 and 2 in the EFRI/UDEQ Protocol Diagram;
b) 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.
c) Analysis by a Utah approved laboratory, process history, and review of mineralogy
literature confirms that all of the metal and inorganic constituents in the material are
consistent with those expected to result from columbite and tantalite ores and the
niobium and tantalum recovery process described by the generator;
d) No volatile or semi-volatile organic compounds were detected in any of the analyses
performed by the certified analytical laboratory.
3. The Uranium Material does not exhibit any of the RCRA characteristics of ignitability,
corrosivity, reactivity, or toxicity for any constituent.
3.3.4 Radioactive Material Profile Record
Furthermore, in order for EFRI to characterize the Uranium Material, Silmet has completed
EFRl'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 Code of Federal Regulations
("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).
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3.3.S 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 Silmet, 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), 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 EFRl'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.
3.5 Other Licensing Considerations
As stated above, according to the Alternate Feed Guidance, for the tailings and wastes from the
proposed processing to qualify as 1 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 uranium mill, and therefore qualifies as "ore" under this definition. Further, because 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 under 10 CFR 40.4.
Upon issuance of a license amendment authorizing the Mill to receive and process the Uranium
Material as an alternate feed material, the Uranium Material may be imported into the United
States as "source material" under 10 CFR 110.20(a), because it is covered by the NRC general
license described in 10 CFR 110.27(a), and because the Uranium Material:
• is not in the form of irradiated fuel, as contemplated by 10 CFR l 10.27(b ); and
• is not a radioactive waste, as contemplated by 10 CFR 110.27(c). As an approved
alternate feed material ore, the Uranium Material will not be a radioactive waste as
defined in 10 CFR 110.2 because (A) the Uranium Material will be processed for its
source material content and will therefore be imported solely for the purposes of
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recycling and not for waste management or disposal, and (B) there is a market for the
recycled uranium.
In its November 1998 approval of Amendment 9 to the Mill's Source Material License SUA-
1358, White Mesa Uranium Mill -Approval to Process Materials from Cameco Corporation's
Facilities in Ontario, Canada," which are alternate feed materials from Canada, the NRC came to
the same conclusion in the same circumstances:
"Finally, import of radioactive materials from Canada required a license from
NRC. As discussed above, the staff has determined that these uranium-bearing
materials from Cameco's Blind River and Port Hope facilities will be processed
for their source-material content. Therefore, with the staff's approval of IUC's
request to process these materials, IUC also is authorized to import them under
the general license at 10 CFR 110.27."
Because the import of the Uranium Material into the United States is covered by the general
license in 10 CFR Part 110.27(a), a specific import license is not required.
It should also be noted that Estonia is a member of the Nuclear Suppliers Group as stipulated
under 10 CFR 110.30 and is not considered an "embargoed destination" or "restricted
destination" by the NRC under 10 CFR 110.28 and 110.29, respectively.
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 system. 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 Sequoyah Fuels
Corporation ("SFC") Alternate Feed Material prepared by DWMRC, and
• The Technical Evaluation and Environmental Assessment Report prepared in connection
with the 2018 Radioactive. Materials License Renewal for the Mill, prepared by
DWMRC.
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The Uranium Material will also be processed as an alternate feed 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;
g) potential airborne radiologic impacts;
h) potential radon and gamma impacts; and
i) worker health and safety issues.
These potential pathways will be discussed in the following sections of this document. The
findings below will demonstrate that, because all the constituents in the Uranium Material have
either been reported to be, or can be assumed to be, already present in the Mill's tailings system
or were reported in other licensed alternate 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,
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• 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,
• 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
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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
The drummed Uranium Material from the Facility accumulated to date will be loaded into closed
cargo containers, such as Container Express ("Conex"), Sea Box, Intermodal Containers
("IMCs") or the equivalent and transported by truck to a port of departure in Estonia. The
containers will be transferred to a container ship and will be transported by sea from Estonia to a
Port of arrival (such as Houston, Texas) in one seaborne shipment. The closed cargo containers
will be transferred either to:
• intermodal rail cars at the port of entry and transported by rail to one of the existing rail
transfer yards in Utah (e.g., Green River), followed by transfer to intermodal truck
tractors from the railhead to the Mill, or
• multi-unit truck tractors at the port of entry and transported by truck over public
highways from the port of entry to the Mill.
The Uranium Material will be shipped as Radioactive LSA I (low specific activity) Hazardous
Material as defined by U.S. Department of Transportation ("DOT") regulations. Silmet 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).
Silmet will ship a total of approximately 50 IMCs or the equivalent to transfer all the material
currently on site in Estonia. If the Facility continues to ship material produced for the next 10
years, Silmet will ship an additional 6 containers per year, or a total of approximately 110
containers, over that time period. Once a shipment reaches the Port of arrival, the entire
consignment of containers might potentially be transferred directly to rail cars or to individual
truck tractors without interim-term storage at dockside or at the terminal. In the maximum
theoretical case for Uranium Material accumulated to date, if 50 truck chassis were available for
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container pickup at the Pmt, and were continuously loaded and released from dockside at one per
hour, or if the rail shipment was transferred to IM Cs at the rail terminal in Utah at the rate of one
container per hour, the entire initial shipment of 50 containers could conceivably travel SR 191
over a period of slightly more than two days. Subsequent future shipments of annual Uranium
Material would be expected to be transported periodically in similar or smaller-sized batches.
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 Facility for the port of departure
from Estonia. The containers and trucks will be decontaminated again, as necessary, prior to
leaving the Mill site.
In the maximum theoretical case, for the Uranium Material accumulated to date, the Mill may
potentially receive the trucks over a period of two to three days, stage the trucks on site as they
are received, and release them over a period of one week or more as each truck and container is
scanned, decontaminated as needed, for release.
Alternatively, the shipper may be requested to transport the initial shipment to the Mill at a
preferred frequency of no more than 10 containers per day. This rate would allow the Mill to
receive, scan, decontaminate and release each truck as it arrives, with no staging on the Mill site
required.
4.2.2 Transportation Impact
For the following reasons, it is not expected that transportation impacts associated with the
movement of the Uranium Material by cargo ship and 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 ("mrem/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 Silmet prior to departure from the Facility 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 covered exclusive use box-style trailers or IMCs, in a similar fashion to
other conventional ores and 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
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Report for the Mill, p. 5-34). In contrast, the entire quantity of Uranium Material accumulated to
date is expected to be transported in a total of approximately 50 truckloads of 20-ton containers.
Whether the material shipments are received over a week or, in the worst case, condensed into a
period of two days, the maximum additional truck traffic generated will be no greater than 25
trucks per day or approximately one truck per hour over two days.
In future years, the entire annual production of Uranium Material could potentially be
transported to the Mill in six 20-ton containers, once per year.
In addition, based on a licensed yellowcake capacity of 4,380 tons U308 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 accumulated to date is expected to be transported in
approximately 11 drums or a fraction of one truckload. In future years, the entire volume of
yellowcake produced may be transported in one drum per year. 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 from all other sources would, in total, exceed a small fraction of the truck
transportation associated with licensed capacity.
After leaving the port of arrival, the shipments will travel west via one of several routes to the
Mill. Potential routes considered include:
• Rail shipment to one of the existing rail transfer yards in southeastern Utah or western
Colorado, followed by transfer of the containers to intermodal trucks, and transport by
truck the remainder of the trip to the Mill. These potential transfer locations would result
in truck travel for a short distance on Interstate Highway 70 to Utah State Highway
("SH") 191, and south along SH 191 to the Mill.
• Interstate Highway 45 to Interstate Highway 35 to Interstate Highway 40, followed by
US and State Highways to the Four Corners area, to SH 191 and north on SH 191 to the
Mill.
• Interstate Highway 10 to Interstate Highway 25 to Interstate Highway 40, followed by
US and State Highways to the Four Corners area, to SH 191 and north on SH 191 to the
Mill.
(ii) Comparison to Existing Truck Traffic on US Highway 191
Whether the shipments from the port of entry arrive by rail and truck or directly by truck, the
multi-unit trucks will travel over Utah Highway 191 either north or south of the Mill, to reach the
Mill.
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In the most conservative case, based on information from the Utah Department of Transportation
("UDOT") analysis reports, 319 multi-unit trucks traveled daily on segments of US Highway 191
south of the Mill. Based on the 2017 UDOT truck traffic information, the maximum of 25
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 8 percent
for no longer than two to three days. Alternatively, at a lower truck frequency of 10 per day, the
increased traffic load of 3 percent may last no longer than a week. 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,
even in the most conservative case.
In theoretical future years, the incremental increase of six trucks per year, transported in one day,
would produce an increased traffic load of less than 2 percent for one day.
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 Colorado Plateau 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 transport above previously licensed activities. Existing
accident response and spill response procedures are therefore sufficient for management of
potential transportation accidents or spills of the Uranium Material.
4.3 Storage
4.3.1 Manner of Storage
Trucks arriving at the Mill site will be received according to existing Mill procedures. The 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 metal
drums with triple-walled polyethylene bag liners 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 ores and 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 Uranium Material is in a dry, powdered state, the drum contents will
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be managed, as required, to minimize dust generation upon emptying. Dust management may
include emptying the drums within an enclosure with water sprays, wetting the drum contents
before emptying, or emptying the drums submerged, as determined to be appropriate based on
the material condition after receipt. In either case, 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 tailings 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. Because the Uranium Material contains elevated
concentrations of Th-232, relative to conventional ores (but within the concentrations of other
approved and processed alternate feed materials) the Mill's existing high-thorium content SOP
will also be utilized or modified for the specific alternate feed material as applicable.
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. The Technical Memorandum provides, in Tables 4-1
and 4-2, 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 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 Colorado Plateau 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 resp~nse and spill response procedures are therefore sufficient for management of
potential accidents or spills of the Uranium Material on the Mill site.
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Energy Fuels Resources (USA) Inc.
4.5 Compatibility with EFRI Mill Tailings
4.5.1 Physical Compatibility
The Uranium Material will be received as dried powdered solids from rotary calcining at the
Silmet Facility. 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. For purposes of comparison, calculations of concentration
changes in the tailings management system have been prepared both for Cell 3 and 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 management system, it is estimated that for the main processing
circuit, the additional load to the tailings management system is minimal (Attachment 5, Tables
4-1 and 4-2). It is expected that the percent increase to the system will be an average of 4 to 5
percent averaged over all components. Based on the calculations in Table 5, lead concentrations
may theoretically increase up to 87% compared to the currently estimated concentration of lead
in Cell 4A. It should be noted, however, that the existing concentrations of lead in Cell 4A are
low and that the maximum lead content of 4,100 mg/kg in the Uranium Material is substantially
lower than the elevated lead levels of previously approved alternate feeds such as Molycorp and
others, which have ranged up to 236,000 mg/kg, and the quantity of Uranium Material is far
lower than the quantities of those alternate feed materials.
As can be seen from Tables 4-1 and 4-2, the constituents in the Uranium Material are estimated
to raise the current concentration in Cell 4A by no more than a few mg/L, and for many
constituents, due to the low levels in the Uranium Material, the resulting concentration in tailings
is expected to go down, in some cases significantly.
Based on Table 4-1 lead concentrations may increase by 14.9 mg/L compared to current
concentrations in Cell 4A or by 3.4 mg/Lover the life of Cell 4A, when represented by Cell 3 in
Table 4-2. Again, it should be noted, that the level in the Uranium Material is 100 times lower
than that of other alternate feed materials previously approved and processed at the Mill, such as
the Molycorp Mountain Pass drummed material.
Based on Table 4-1 barium concentrations may increase by 1.6 mg/L compared to current
concentrations in Cell 4A or by 0.4 mg/L over the life of Cell 4A, when represented by Cell 3 in
Table 4-2.
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 4B, placed into service in February 2011, currently
serves as an evaporation pond and receives only solutions at this time. Cell 4A has primary and
secondary high-density polyethylene ("HDPE") flexible membrane liners, a geosynthetic clay
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Energy Fuels Resources (USA) Inc.
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 management
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 feeds 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 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 management system beyond those
produced by the Mill's processing of natural ores or previously approved alternate feed
materials.
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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
of processing a similar amount of natural ore. The Facility, as described above, may be expected
to ship a total of approximately 2,200 tons of Uranium Material to the Mill. 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, Final Environmental Statements ("FESs"), 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 is not impacting groundwater, the receipt and
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Energy Fuels Resources (USA) Inc.
processmg 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
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 ("BAT") 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 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 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 metal drums with triple-walled
polyethylene bag liners 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 dry, with an average moisture content estimated to be
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less than 1 %. The drums 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. In addition,
standard procedures at the Mill for dust suppression will be employed if necessary. There will
therefore be no new or incremental risk of discharge to surface waters resulting from the receipt
and processing of Uranium Material at the Mill or the disposition of the resulting tailings.
Finally, as the chemical and radiological make-up of the Uranium Material are sufficiently
similar to natural ores and other alternate feed materials and resulting tailings, that the existing
surface water monitoring program at the Mill will be adequate to detect any potential impacts to
surface water. As a result, there will be no incremental impacts over and above previously
licensed activities.
4.8 Airborne Radiological Impacts
The chemical and radiological make-up of the Uranium Material will not be significantly
different from natural ores 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 2.6.1 above, the uranium content and radioactivity levels of the Uranium
Material is comparable to high grade Colorado Plateau ores and previously approved alternate
feed materials. Therefore Rn-220 emanations from the Uranium Material will be comparable to
emanations from the same quantity of Colorado Plateau ores. The gamma emanations from the
Uranium Material will be elevated somewhat compared to Colorado Plateau ores, due to the
elevated Th-228, but within the range of higher-grade conventional ores and other alternate feed
materials. Overall, the Uranium Material will therefore pose a comparable or 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, including the Mill's High Thorium
Content SOP as applicable, 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 RML, and applicable State Regulations, is adequate to ensure the protection of the
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Energy Fuels Resources (USA) Inc.
worker and environment and is consistent with the principle of maintammg 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
Gamma radiation levels associated with the Uranium Material are within levels of gamma
radiation associated with other ores and alternate feed materials processed or licensed for
processing at the Mill in the past. Gamma exposure to workers will be managed in accordance
with existing Mill SOPs, including the Mill's High Thorium Content SOP as applicable.
c) Radon
Radon levels associated with the Uranium Material are within levels of radon associated with
other ores and alternate feed materials processed or licensed for processing at the Mill in the
past. Radon exposures to workers will be managed in accordance with existing Mill standard
operating procedures.
d) Control of Airborne Contamination
The Uranium Material is a fine-grained powder with an average moisture content estimated to be
less than 1 %. While stored on the ore pad, the uranium material will remain within the metal
drums with triple-walled polyethylene bag liners 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 Derived Air Concentration ("DAC") to be used
in any analysis of airborne particulate exposure to workers will be developed specifically for the
Uranium Material, based on applicable regulations and Mill procedures, in order to take into
account the specific radionuclide make-up of the Uranium Material. The Mill has safely received
and processed alternate feed materials with 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).
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4.10.4 Vehicle Scan
As stated in Section 4.2 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 Equipmem 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.
4.11 Long Term Impacts
The Uranium Material is comprised of similar chemical and radiological components as already
exist in the Mill's tailings management system. 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
Silmet 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.
Silmet 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, Silmet 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 Silmet for disposal/processing options in
connection with removal of uranium material from storage at the Facility to maintain compliance
with the Facility's license conditions. 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
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Materials. Given that removal of the Uranium Material to an offsite facility is required to meet
the Facility's license conditions, the only options are as to which offsite facility the Uranium
Materials will ultimately be sent for reprocessing or disposal. Silmet 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 1s
utilized, the value of the recoverable uranium in the Uranium Material would not be realized.
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5.0 CERTIFICATION
This applicat'on and Environmental Report has been submitted as of April 18, 2019 by
By:_-H-H'-1---1--------
David , ·yde 1 und
Chief Financial fficer, General Counsel and Corporate Sectretary
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ATTACHMENT 1
NPM Silmet OU Facility Information
• necf
Performance Materials
HISTORICAL OVERVIEW OF THE SITE -NPM SILMET OU
General overview
1927-1940
1944
1946-1952
1952-1970
1970
1982-1988
1988-1990
1990-1997
1997
1999-2009
A. Nobel established Shale Oil production factory, which was destroyed
during Second World War
Soviet Union occupied Estonia and restoration of facilities started, with the
aim to produce Uranium from local Shale ore
The Pilot production of the Uranium from local Shale ore
Different Uranium containing ores processing to produce Uranium oxide
Started the Loparite ore processing to produce Nb, Ta and Rare Earth
Concentrates
Production of the reactor grade enriched uranium products
Soviet occupation in Estonia ended and uranium production stopped.
Facility reorganization as State owned company
Private Company for Nb, Ta and REE production
The decomissioning process of the radioactive tailings pond.
Regulated quantites of the collection and storage of the NORM residues in NPM
Silmet 00
NPM Silmet 00 Radiation Activity License 14 010 (valid from 30.01.2014 to 30.01.2019)
regulates the quantity of the NORM residue collected and stored on the site in period 2014-
2019 is 362,5 Mt. NPM Silmet 00 has already collected and stored 255 Mt NORM residues
during previous periods (2009-2014) after closing Sillamae radioactive tailings pond at 2009.
NPM Silmet 00 has licensed limit to collect and storage altogether 615,5 Mt of NORM
residues.
NPM Silmet 00 actual quantity of collected and storaged NORM residue will be 535,33 Mt in
the end of 2018.
Graph 1. NORM residue quantities in period 2009-2019.
NPM SILMET 00
Kesk 2
40231 Sillamae, Estonia
Reg hr. 10294959
www.neomaterials.com
[phone] PHONE
100
80
60
40
20
0
NORM Residue collected and storaged in 2009-
2019
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
-Lubatud -tegelik
2
Jane Paju
Director of Technology
NPM Silmet 00
• necf
Performance Materials
TECHNOLOGICAL PROCESS DESCRIPTION FOR PRODUCTION OF NORM
CONTAINING RESIDUE
General description of the process
Columbite and tantalite -NORM (U 238 and Th 232) containing mineral ore concentrates are
processed via leaching process to separate the insoluble impurities including NORM (U238
and Th232) and Nb, Ta. The process includes the following operations:
Crushing and milling of the mineral ores Columbite and Tantalite;
Dissolution of the mineral ores, columbite and tantalite in acid solutions (HF, H2S04);
Precipitation of insolubles from slurry and their filtration -Filter cake = NORM
containing residue;
Washing of the filter cake with water
Filtration of the NORM containing residue
Calcination, cooling and packing of the NORM containing residue
Figure 1. The principal flowchart of the NORM containing residue process
TANTALITE, COLUMBITE
Mineral or concentrates
Crushing and Milling
i
Dissolution i ~----_..
Raw material
NPM SILMET 00
Kesk 2
40231 Sillamae, Estonia
Reg nr. 10294959
Filtration and washing
i
NORM containing residues
Drying and Calcination
+
Cooling and packing of NORM containing residues
www.neomaterials.com
[phone] PHONE
Nb and Ta
containing
2
Raw Materials
NPM Silmet 00 is using several types of mineral ores -Columbite and Tanatlite, which are
characterized by different rare metals Nb and Ta content, but also different impurities profile
included content of naturally occuring radioactive materials U 238 and Th 232 and their decay
products. Typical characteristics of Columbite and Tantalite are in Table 1.
Columbite and Tantalite are dark coarse mineral materials, what will be crushed and milled by
vibrating mills. Raw materials are transported to NPM Silmet 00 in 50 kg plastic bags or 200
liter metal drums.
Table 1
Element Columbite Tantalite
1 Ta205, % 4 30
2 Nb205, % 40 20
3 Th02, % 0,5 0,2
4 U203, % 0 1 0,2
5 LOO,% 0, 1 0, 1
Crushing and milling of raw material
Columbite and tantalite are crushed and milled in isolated area -milling unit, because of the
formation of the radioactive dust, which is the must hazardous factor of the entire process.
Raw materials are loaded by hermetic feeder screws into vibrating mills, where material is
milled until to required particle size, removed from mills by hermetical discharge systems and
packed into metal drums. Milling unit has isolated ventilation system with filter systems, dust
particles from the filtered air is removed by cyclons and recycled in the process with raw
material.
Dissolution of raw material and filtration of the solutions.
Milled columbite and tantalite is transported into dissolution unit (located in the same territory,
but separate building). Drums with the milled columbite and tantalite are placed on the top of
automatic feeder systems, where material is loaded into dissolution reactors into hydrofluoric
acid solution. Raw material is dissolved at temperature 80-85°C in hydrofluoric acid and
sulphuric acid is added to precipitate out the impurities. The slurry is filtrated to remove the
insoluble impurities including U and Th. After filtration the filtercake is washed with water
several times to remove all Nb and Ta from the cake. Wet NORM containing cake is packed
into 1 Mt plastic bags (Big-bags) and transported into calcination unit (locating in the same
building).
Calcination of the NORM containing cake
NORM containing cake (NORM Residue) is loaded from big-bags into electric rotary kilns via
feeder systems, and calcined at temperature 550-600 °C 1 hour. Calcined NORM residue is
moving from rotary kiln into rotary coolers where material is cooled down and packed into 200
I metal drums what is insulated with triple wall PE bags. Quality Control Department with
Governmental Lab Okosil AS, are taking samples from every drum for gamma spectrometry
analyze and all drums are measured for dose speed. The LOT is completed from 9 drums and
transported into warehouse, photos 1,2,3.
Photos 1, 2: Packed NORM residues.
Photo 3. NORM residue warehouse
3
Jane paju
Director of Technology
NPM Silmet 00
ATTACHMENT 2
Radioactive Material Profile Record and Affidavit
RADIOACTIVE MATERIAL PROFILE RECORD
Name and Title of Person Completing Form: JANE PAJU, DIRECTOR OF TECHNOLOGY
Original Submission: yes; Revision# I; Date of Revision: 03 January 2019
Generator Name: NPM SILMET OU Generator/Feed Stream#: columbite/tantalite Volume of Feed Material: 600 metric tons
Contractor Name: _______ _,. Feed Stream Name: ________ _, Delivery Date:----------
Check all appropriate boxes:
Licensed: Yes
NORM/NARM X; LLRW_; MW_; MW Treated_; MWNeedingTrtmt_; DOE_; lie. (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 fonn, contact Energy Fuels Resources (USA)
Inc.'s ("EFRI's") Manager of Compliance and Licensing at 303.389.4132. MATERIALS CANNOT BE ACCEPTED AT EFRl'S
WHITE MESA MILL UNLESS THIS FORM IS COMPLETED. If a category does not apply, please indicate. This form must be
updated annually.
I. GENERATOR INFORMATION
EPA ID# EPA Hazardous Waste Number(s) (if applicable) __________ _
Mailing Address: KESK 2, SILLAMAE, ESTONIA, EU
Fax: Phone:---------------------------------
Location of Material (City, ST): KESK 2, SILLAMAE, ESTONIA, EU
Generator Contact: Jane Paju Title: Director of Technology
Mailing Address (if different from above): [e-mail]
Phone: [phone] Fax: ----------------
B. MATERIAL PHYSICAL PROPERTIES (Should you have any questions while completing this section, contact EFRl's Manager
of Compliance and Licensing at 303.389.4132.)
I. PHYSICAL DA TA (Indicate percentage of material that will pass through the following
grid sizes, e.g., 12" 100%, 4" 96%, I" 74%, 1/4" 50%, l/40" 30%, l/200" .5%)
2. DESCRIPTION: Color _x_ Brown/Multi_ Odor
Liquid_ Solid_ Sludge __ Powder/Dust_x_
3. DENSITY RANGE: (Indicate dimensions) 0.9 -1.2 S.G.
4. GENERAL CHARACTERISTICS (% OF EACH)
Odorless_x_
lb. /ft3 lb. /yd3 l/200" 61.72%
GRADATION OF
MATERIAL:
12" 100%
4" 100%
I" 100%
1/4" 100%
1/40" 99.83%
Process Residue (concentrated and calcined NORM containing filter cake after ore (columbite/tantalite) leaching) -
100%
Other constituents and approximate% contribution of each:
Generator or Contractor Initials:
Page I of 11
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: %
High Moisture Content: %
Average Moisture Content: below 1 %
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).
C. RADIOLOGICAL EVALUATION
I. 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 Atlachment C. 1).
Isotooe Concentration Ran2e lnCi/2) Avera2e (oCi/e:)
Pb 210
U Nat (238)
Th 228
Th 230
Th 232
Rad226
Rad 228
U234
U 235
ND -Analyte not detected.
(Please Circle)
904
1105
1033
902
I 199
1332
1394
Others (Please Specirv)
979
45
2. Y ® Is the radioactivity contained in the feed material Low-Level Radioactive Waste as defined in the Low-Level
Radioactive Waste Policy Amendments Act of 1985 or in DOE Order 5820.2A. Chapter III? lfyes, check "LLRW"
block on line 3 of page I.
3. Y @ 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 __ ; Special Nuclear Material __ ; By-Product __ ; Norm __ ; NARM __ ;
LICENSING AGENCY: LICENSE NUMBER:---------
0. CHEMICAL AND HAZARDOUS CHARACTERISTICS
1. DESCRIPTlON AND HISTORY OF MATERIAL
Please attach a description of the material to this profile (as Attachment D. l a through/). 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 used in or commingled with the material.
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.
Generator or Contractor Initials: ./LL
Page 2 of 11
Radioactive Material Profile Record
Please describe the history, and include the following:
(Please Circle)
Was this material mixed, treated, neutralized, solidified, commingled, dried, or otherwise processed at any time
after generation?
Has this material been transported or otherwise removed from the location or site where it was originally generated?
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?
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* Nickel -Total* X
"Derived-From" HW Barium -TCLP* Selenium -Total* X
Characteristic Cadmium -TCLP* Silver -Total* X
Reactive -CN X Chromium -TCLP* Thallium -Total* X
Reactive Sulfide X Lead-TCLP* Tin-Total* X
Ignitable X Mercury -TCLP* Uranium -Total* X
Corrosive X Selenium -TCLP* Vanadium -Total* X
Toxic (as detennined bv TCLP analvsis) Silver -TCLP* Zinc -Total* X
Oreanics Arsenic -Total* X Miscellaneous
voes X Barium -Total* X Exolosives X
SVOCs X Beryllium -Total* X Pyrophorics X
Pesticides X Cadmium -Total* X Infectious X
Herbicides X Chromium -Total* X Chelating Agents X
Dioxins X Cobalt -Total* X Residue from WWT Plant X
PCBs X Copper -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 f or these constituents regardless of generator knowledge of process or materials.
Generator or Contractor Initials: ,
Page 3 of 11
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 LABO RA TORY ANALYSIS, CHECK WITH EFRI
REGARDING UTAH LABORATORY CERTIFICATIONS.) Please summarize results on the blank spaces provided.
Analyte TCLP Range or MHimum
Arsenic 0.0125
Barium ND
Bervllium
Cadmium 0.0198
Chromium 0.257
Cobalt
Cooner
Iron
Lead 1.114
Manganese
Mercurv ND
Molybdenum
Nickel
Selenium ND
Silver ND
Thallium
Tin
Uranium
Vanadium
Zinc
Fluoride
Nitrate
Nitrite
Sulfate
Sulfide
ND= Not Detected NA = Not Analyzed
Additional Required Analytical Information:
pH (liquids only): NIA
(me/L\
Paint Filter Liquids Test (Please Circle): Pass 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)
4.9
435
1.8
3.5
89
3.8
85 .2
8766.7
4093
1458
0.2
2.3
51.5
ND
3.5
1.3
88
2306
7.4
88.2
4933
0.2
NA
6051
NA
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) Inc., Attn: Sample Control, 6425 S. Highway 191, P.O. Box 809, Blanding, UT 84511
Phone: ( 435) 678-2221
Generator or Contractor Initials:
Page 4 of 11
Radioactive Material Profile Record
5. LABORATORY CERTIFICATION INFORMATION. Please indicate below which of the following categories applies to
your laboratory data.
a. All radiologic data used to support the data in item C. l. must be from a certified laboratory.
X UT AH 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
GENERA TOR'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 tenns 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
GENERA TOR'S CERTIFICATION: I also certify that where necessary those representative samples were or shall be provided to
EFRI and to qualified laboratories for the analytical results reported herein. I also certify that the information provided on this form
is complete, true and correct and is accurately supported and documented by any laboratory testing as required by 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 IO 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 26 l .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 behalf of itself, and as agent for the Generator, on behalf of the Generator. By signing this certification, the
Contractor is signing on its own behalf and on behalf of the Generator.
Generator's or Contractor's Signature:-..~""'"""""-""'----"--·-~-----
(Sign for the above certifications).
Print Name of Individual Signing above: Randal Reid
Generator or Contractor Initials:
Page 5 of 11
Title: attorney-in-fact Date: 08 February 2019
List of Documentation Required With the Submission of This RMPR
Attachment B.6 -Description of Physical Attributes of the Material
Attachment C. l -Radiological Analysis -Data Packages (including all pertinent Quality Control Data)
Attachment D.1 a through f-Material generation process history and description
Attachment 0.2 -Analytical data (including all pertinent Quality Control Data) for all yes answers
Attachment 0.3 -Analytical Data (including all pertinent Quality Control Data) for total and TCLP metals and anions
Page 6 of 11
Radioactive Material Profile Record
Attachment B.6
Description of Physical Attributes of the Material
(see Material Information Safety Sheet, dated 08/02/2013 -attached)
Generator or Contractor Initials:
Page 7 of 11
r Molx_corp •
Present Material Safety Information Sheet is only informative as described material is
not the object of the Regulation (EC) No.1907/2006 (REACH Regulation) or Regulation
(EC) No.1272/2008 (CLP Regulation).
Radioactive substances and mixtures are regulated by EC Directive No. 96/29/Euratom
of 13 May 1996.
Created on August 02, 2013
MSIS (Material Safety Information Sheet)
LMF (Insoluble Mineral Fraction)
1. IDENTIFICATION OF THE SUBSTANCE AND OF THE COMPANY
1.1 Product identifier
Trade name: LMF (Insoluble Mineral Fraction)
Other names: LMF, Tantalum containing cake, Uranium containing cake
Chemical name: NIA
INDEX number as listed in Annex VI NIA
of CLP:
ID number of the C&L inventory: NIA
CAS number: NIA
REACH registration no(s): NIA
1.2 Relevant identified uses of the substance or mixture and uses advised against
Uses: LMF (Insoluble Mineral Fraction) is used as raw material
of production of Light Rare Earth Elements, Ta, Zr, Sn and
also U and Th for Energy solutions.
Uses advised against: NIA
1.3 Details of the supplier of the safety data sheet
Manufacturer: AS MOL YCORP SILMET
Kesk Str.2; 40231; Si llamae; ES TONIA
Tel.: [phone]
URL website: www.molycorp.com
Email: [e-mail]
Person responsible for the Safety Jane Paju
Data Sheet (with e-mail address) [e-mail]
1.4 Emergency telephone number
Emergency phone number:
MOL YCORP SILMET AS
Kesk 2 [phone] PHONE
40231 Si/lamiie, Estonia [phone] FAX
Reg. nr. 10294959
2. HAZARDS ID ENT/FICA TION
2.1 Other hazards
Other hazards: Contains traces of naturally occurring radionuclides
(NORM) U-238, Th-232, Ra-226 and Ra-228.
Total Activity (by U and Th) -below 191 Bq/g
3. COMPOSITION/INFO.RMA TION ON INGREDIENTS
Substances
This material is intennediate which contains insoluble mixed metal oxides on fluorides.
Chemical name CASno. EC no. Classification Cone.%
information (max)
Niobium Pentoxide (Nb205) 1313-96-215-213-Not classified according 2,3
8 6 ~LP
Tantalum Pentoxide (Ta20s) 1314-61-215-238-Not classified according 5,0
0 2 CLP
Silicon Dioxide (Si02) 7631-86-231-545-Not classified according 11,0
9 4 CLP
Zirconium Dioxide (Zr02) 1314-23-215-227-Not classified according 23,0
4 2 CLP
Dialuminium Trioxide (Al203) 1344-28-215-691-Not classified according 9,0
1 6 CLP
Cerium Dioxide 1306-38-215-150-Not classified according 1,5
3 4 CLP
Di lanthanum Trioxide 1312-81-215-200-Not classified according 0,5
8 5 CLP
Dineodymium Trioxide 1313-97-215-214-Not classified according 0,5
9 1 CLP
Diyttrium Trioxide 1314-36-215-233-Not classified according 1, 7
9 5 CLP
Diytterbium trioxide 1314-37-215-234-Not classified according 0,7
0 0 CLP
Iron Oxide (Fe203) 1309-37-215-168-Not classified according 8,5
1 2 CLP
Titanium Dioxide (Ti02) 13463-236-675-Not classified according 2,5
67-7 5 CLP
Tin Dioxide (Sn02) 18232-242-159-Not classified according 40,0
10-5 0 CLP
Tungsten Trioxide (W03) 1314-35-215-231-Not classified according 0,1
8 4 CLP
Uranium Oxide (U30s) 1344-59-215-702-Radioactive substance 0,8
8 4 regulated by EC Directive
96/29/Euratom
Thorium Oxide (Th02) 1314-20-215-225-Radioactive substance 2,4
I I '"egulated by EC Directive
1)6/29/Eu ratom
Fluoride content Bonded with metals 13,0
4. FIRST-AID MEASURES
4.1 Description of first aid measures
Eye contact: Hold eyelids apart and flush affected eye(s) with plenty of
clean water (at least for 10 minutes)
Skin contact: Flush with plenty of water and mild soap.
Ingestion: Seek for medical attention
Inhalation: Seek for medical attention.
4.2 Most important symptoms and effects
Acute effects Dust may cause irritation of eyes and respiratory organs
Delayed effects Can be harmful in case of prolonged contact due to
radioactive properties particularly when swallowed or
inhaled.
4.3 Indication of any immediate medical attention and special treatment needed
Note to physician: Radioactive substances
5. FIRE-FIGHTING MEASURES
5.1 Extinguishing media
Suitable: Use extinguishing agent suitable for type of surrounding
fire
Not suitable: Not known
5.2 Special hazards arising from the substance or mixture
Not known
5.3 Advice for firefighters
Wear appropriate protective equipment. Move undamaged containers from immediate hazard area
if it can be done with minimal risk. Dust could bear radioactive particles.
6. ACCIDENTAL RELEASE MEASURES
6.1 Personal precautions, protective equipment and emergency procedures
A void creating dusty conditions and prevent wind dispersal. A void contact with eyes, skin, and
clothing. Use suitable protective equipment.
6.2 Environmental precautions
Prevent the material from contact with soil, entering surface water or sanitary sewer system. Do
not discharge directly to a water source. If accidental spillage or washings enter drains or
watercourses contact local authority.
6.3 Methods and material/or containment and cleaning up
Vacuum or sweep up and place into suitable labelled containers for recovery or disposal. Clean up
affected area with a large amount of water.
6.4 Reference to other sections
See section 8 for personal protective equipment and section 13 for waste disposal.
7. HANDLING AND STORAGE
7.1 Precautions/or safe handling
Technical measures/ Precautions: Use with adequate ventilation. Local exhaust ventilation
should be provided. Avoid contact with eyes, skin and
clothing. Avoid creating dusty conditions and prevent
wind dispersal.
General occupation hygiene: Do not eat, drink or smoke in work areas. Wash hands
after use. Remove contaminated clothing and protective
equipment before entering eating areas.
7.2 Conditions for safe storage, including any incompatibilities
Technical measures/ Storage Material is to be stored in area marked for radioactive
conditions: material storage.
Keep in the original container. Keep container tightly
closed in a cool, dry, well-ventilated place.
Packaging materials:
Stainless steel (304). Synthetic material.
Incompatible products: Not known
8. EXPOSURE CONTROLS I PERSONAL PROTECTION
8.1 Control parameters
Regulated occupational exposure Effective dose: 100 mSv/5 years for workers (not
limit values: exceeding 50 mSv in single year).
8.2 Exposure controls
Appropriate engineering controls: Use of adequate ventilation is good industrial practice. In
addition, an eyewash facility and a safety shower for
facilities storing or utilizing this material is good industrial
practice.
Environmental exposure controls; Dispose of rinse water in accordance with local and
national rej:!;ulations.
Individual protection measures, such as personal protective equipment
(}eneral remark: Only person wearing personal dosimeter can work with
this material.
Respiratory protection: Respiratory protection if high airborne concentrations
prevail
Hand protection: Protective gloves, impermeable to the dust
Eye protection: Chemical goggles or face shield are recommended to
prevent potential eye contact.
Skin and body protection: Working clothes
Hygiene measures: Wash hands, forearms and face thoroughly after handling
chemical products, before eating, smoking and using the
lavatory and at the end of the working period. Appropriate
techniques should be used to remove potentially
contaminated clothing. Wash contaminated clothing before
reusing.
9. PHYSICAL AND CHEMICAL PROPERTIES
9. I Information on basic physical and cl,emical properties
Appearance: Beige or yellow clumpy powder material.
Odour: Odourless
Melting/Freezing temperature: NIA
Boiling temperature: NIA
Flash-point: NIA
Flammability: Non flammable (based on molecular structure).
Explosive properties: NIA
Oxidizing properties: NIA
Vapour pressure: NIA
Relative density (D4 (20)): 5-6 glcm~
Solubility in water: negligible
Partition coefficient n-octanol/water: NIA
Viscosity: Not applicable to solids
Specific conductivity: No data
Auto ignition temperature: NIA
Surface tension: Not surface active (based on molecular structure)
9.2 Other information
JO. STABILITY AND REACTIVITY
10.1 Reactivity
Stable under recommended storage and handling conditions (see section 7, handling and storage).
10.2 Chemical stability
Stable under recommended storage and handling conditions (see section 7, handling and storage).
10.3 Possibility of hazardous reactions
NIA
10.4 Conditions to avoid
None known
10.5 Incompatible materials
None known
10.6 Hazardous decomposition products
None known
11. TOXICOLOGICAL INFORMATION
I 1.1 Information on toxicological effects
ACUTE TOXICITY Oxides and fluorides contained in LMF are not toxic, but
material is radioactive and could cause health risk due to
radioactive properties.
OTHER In case of prolonged eye contact or repeated inhalation or
ingestion material can present a hazard due to radioactive
properties.
12. ECOLOGICAL INFORMATION
Avoid contamination and distribution in the environment due to radionuclide properties.
13. DISPOSAL CONSIDERATIONS
Waste from residues; Special disposal in accordance with local and state
regulations due to radioactivity.
Container: Containers should be cleaned by appropriate method, in
accordance with local and national regulations. Do not
remove label until container is thoroughly cleaned.
Empty containers should be decontaminated before reuse.
14. TRANSPORT INFORMATION
UN Number: 2912
Proper shipping name: Radioactive material, low specific activity LSA-1
Transport hazard classes: ADR/RJD: 7 (LSA I)
IMO: 7 (LSA I)
lCAO/IATA: 7 (LSA I)
Authorized carrier for class 7 required!
Packaging group: I type IP-I (II yellow, Tl =O, I)
Special precautions: HAZARDOUS MATERIAL, DANGEROUS GOOD,
RADIOACTIVE!
15. REGULATORY INFORMATION
15. 1 Safety, health and RADIOACTIVE
environmental regulation/legislation National regulation observation recommended!
specific for the substance or mixture: Radioactive substances and mixtures are regulated by EC
Directive No. 96/29/Euratom of 13 Ma~ 1996.
15 .2 Chemical safety assessment: This substance is not regulated by REACH. In accordance
with REACH Article 14, a Chemical Safety Assessment
has not been carried out for this substance.
16. OTHER INFORMATION
The information provided in this safety data sheet is correct to the best of our knowledge,
information, and belief at the date of its publication. The information given is designed only as
guidance for safe handling, use, processing, storage, transportation, disposal, and release and is not
to be considered a warranty or quality specification. The information relates only to the specific
material designated and may not be valid for such material used in combination with any other
materials or in any proceed, unless specified in the text.
Classification in accordance with Regulation 1272/2008, as listed in Annex VI:
Radioactive substances and mixtures, as such are not regulated by the Regulation 1272/2008
Version: 2
Creation date: 13.05.2013
Revision date: 12.08.2016
Printing date: 12.08.2016
Release info: This version replaces all previous documents
Created/Revised by: Jane Paju [e-mail])
2. HAZARDS IDENTIFICATION
2.1 Other hazards
Other hazards: Contains traces of naturally occurring radionuclides
(NORM) U-238, Th-232, Ra-226 and Ra-228.
Total Activity (by U and Th) -below 191 Bq/~
3. COMPOSITION/INFORMATION ON INGREDIENTS
Substances
This material is intennediate which contains insoluble mixed metal oxides on fluorides.
Chemical name CAS no. EC no. Classification Cone.%
information (max)
Niobium Pentoxide (Nb20s) 1313-96-215-213-Not classified according 2,3
8 6 SLP
Tantalum Pentoxide (Ta20s) 1314-61-215-238-Not classified according 5,0
0 2 CLP
Silicon Dioxide (Si02) 7631-86-231-545-Not classified according 11,0
9 4 CLP
Zirconium Dioxide (Zr02) 1314-23-215-227-Not classified according 23,0
4 2 CLP
Dialuminium Trioxide (A'203) 1344-28-215-691-Not classified according 9,0
I 6 CLP
Cerium Dioxide 1306-38-215-150-Not classified according 1,5
3 4 CLP
Dilanthanum Trioxide 1312-81-215-200-Not classified according 0,5
8 5 CLP
Dineodymium Trioxide 1313-97-215-214-Not classified according 0,5
9 1 CLP
Diyttrium Trioxide 1314-36-215-233-Not classified according 1,7
9 5 CLP
Diytterbium trioxide 1314-37-215-234-Not classified according 0,7
0 0 CLP
Iron Oxide (Fe203) 1309-37-215-168-Not classified according 8,5
1 2 CLP
Titanium Dioxide (Ti02) 13463-236-675-Not classified according 2,5
67-7 5 CLP
Tin Dioxide (Sn02) 18232-242-159-Not classified according 40,0
10-5 0 CLP
Tungsten Trioxide (W03) 1314-35-215-231-Not classified according 0,1
8 4 CLP
Uranium Oxide (UJ08) 1344-59-215-702-Radioactive substance 0,8
8 4 regulated by EC Directive
~6/29/Euratom
Thorium Oxide (Th02) 1314-20-215-225-Radioactive substance 2,4
1 l egulated by EC Directive
\>6/29/Eu ratom
Fluoride content Bonded with metals 13,0
4. FIRST-AID MEASURES
4.1 Description of first aid measures
Eye contact: Hold eyelids apart and flush affected eye(s) with plenty of
clean water (at least for IO minutes)
Skin contact: Flush with plenty of water and mild soap.
Ingestion: Seek for medical attention
Inhalation: Seek for medical attention.
4.2 Most important symptoms and effects
Acute effects Dust may cause irritation of eyes and respiratory organs
Delayed effects Can be harmful in case of prolonged contact due to
radioactive properties particularly when swallowed or
inhaled.
4.3 Indication of any immediate medical attention and special treatment needed
Note to physician: Radioactive substances
5. FIRE-FIGHTING MEASURES
5.1 Extinguishing media
Suitable: Use extinguishing agent suitable for type of surrounding
fire
Not suitable: Not known
5.2 Special hazards arising from the substance or mixture
Not known
5.3 Advice for firefigl,ters
Wear appropriate protective equipment. Move undamaged containers from immediate hazard area
if it can be done with minimal risk. Dust could bear radioactive particles.
6. ACCIDENTAL RELEASE MEASURES
6.1 Personal precautions, protective equipment and emergency procedures
A void creating dusty conditions and prevent wind dispersal. A void contact with eyes, skin, and
clothing. Use suitable protective equipment.
6.2 Environmental precautions
Prevent the material from contact with soil, entering surface water or sanitary sewer system. Do
not discharge directly to a water source. If accidental spillage or washings enter drains or
watercourses contact local authority.
6.3 Methods and material/or containment and cleaning up
Vacuum or sweep up and place into suitable labelled containers for recovery or disposal. Clean up
affected area with a large amount of water.
6.4 Reference to other sections
See section 8 for personal protective equipment and section 13 for waste disposal.
7. BANDUNG AND STORAGE
7.1 Precautions for safe handling
Technical measures/ Precautions: Use with adequate ventilation. Local exhaust ventilation
should be provided. A void contact with eyes, skin and
clothing. A void creating dusty conditions and prevent
wind dispersal.
General occupation hygiene: Do not eat, drink or smoke in work areas. Wash hands
after use. Remove contaminated clothing and protective
equipment before entering eating areas.
7.2 Conditions for safe storage, including any incompatibilities
Technical measures/ Storage Material is to be stored in area marked for radioactive
conditions: material storage.
Keep in the original container. Keep container tightly
closed in a cool, dry, well-ventilated place.
Packaging materials:
Stainless steel (304). Synthetic material.
Incompatible products: Not known
8. EXPOSURE CONTROLS I PERSONAL PROTECTION
8.1 Control parameters
Regulated occupational exposure Effective dose: 100 mSv/5 years for workers (not
limit values: exceeding 50 mSv in single year).
8.2 Exposure controls
Appropriate engineering controls: Use of adequate ventilation is good industrial practice. In
addition, an eyewash facility and a safety shower for
facilities storing or utilizing this material is good industrial
practice.
Environmental exposure controls: Dispose of rinse water in accordance with local and
national regulations.
Individual protection measures, such as personal protective equipment
General remark: Only person wearing personal dosimeter can work with
this material.
Respiratory protection: Respiratory protection if high airborne concentrations
prevail
Hand protection: Protective gloves, impermeable to the dust
Eye protection: Chemical goggles or face shield are recommended to
prevent potential eye contact.
Skin and body protection: Working clothes
Hygiene measures: Wash hands, forearms and face thoroughly after handling
chemical products, before eating, smoking and using the
lavatory and at the end of the working period. Appropriate
techniques should be used to remove potentially
contaminated clothing. Wash contaminated clothing before
reusing.
9. PHYSICAL AND CHEMICAL PROPERTIES
9.1 Information on basic pl1ysica/ and c/remica/ properties
Appearance: Beige or yellow clumpy powder material.
Odour: Odourless
Melting,'Freezing temperature: NIA
Boiling temperature: NIA
Flash-point: NIA
Flammability: Non flammable (based on molecular structure).
Explosive properties: NIA
Oxidizing properties: NIA
Vapour pressure: NIA
Relative density (D4 (20)): 5-6 g,'cmJ
Solubility in water: negligible
Partition coefficient n-octanol/water: NIA
Viscosity: Not applicable to solids
Specific conductivity: No data
Auto ignition temperature: NIA
Surface tension: Not surface active (based on molecular structure)
9.2 Other information
10. STABILITY AND REACTIVITY
10.1 Reactivity
Stable under recommended storage and handling conditions (see section 7, handling and storage).
10.2 Chemical stability
Stable under recommended storage and handling conditions (see section 7, handling and storage).
10.3 Possibility of hazardous reactions
NIA
10.4 Conditions to avoid
None known
10.5 Incompatible materials
None known
10.6 Hazardous decomposition products
None known
11. TOXICOLOGICAL INFORMATION
I I.I Information on toxicological effects
ACUTE TOXICITY Oxides and fluorides contained in LMF are not toxic, but
material is radioactive and could cause health risk due to
radioactive properties.
OTHER In case of prolonged eye contact or repeated inhalation or
ingestion material can present a hazard due to radioactive
properties.
12. ECOLOGICAL INFORMATION
Avoid contamination and distribution in the environment due to radionuclide properties.
13. DISPOSAL CONSlDERA TIONS
Waste from residues: Special disposal in accordance with local and state
regulations due to radioactivity.
Container: Containers should be cleaned by appropriate method, in
accordance with local and national regulations. Do not
remove label until container is thoroughly cleaned.
Empty containers should be decontaminated before reuse.
14. TRANSPORT INFORMATION
UN Number: 2912
Proper shipping name: Radioactive material, low specific activity LSA-1
Transport hazard classes: ADR/RID: 7 (LSA I)
IMO: 7 (LSA I)
ICAO/IA TA: 7 (LSA I)
Authorized carrier for class 7 required!
Packaging group: I type IP-1 (II yellow, Tl =O, 1)
Special precautions: HAZARDOUS MATERIAL, DANGEROUS GOOD,
RADIOACTIVE!
15. REGULATORY INFORMATION
15. 1 Safety, health and RADIOACTIVE
environmental regulation/legislation National regulation observation recommended!
specific for the substance or mixture: Radioactive substances and mixtures are regulated by EC
Directive No. 96/29/Euratom of 13 Ma~ 1996.
15.2 Chemical safety assessment: This substance is not regulated by REACH. In accordance
with REACH Article 14, a Chemical Safety Assessment
has not been carried out for this substance.
16. OTHER INFORMATION
The information provided in this safety data sheet is correct to the best of our knowledge,
information, and belief at the date of its publication. The information given is designed only as
guidance for safe handling, use, processing, storage, transportation, disposal, and release and is not
to be considered a warranty or quality specification. The information relates only to the specific
material designated and may not be valid for such material used in combination with any other
materials or in any proceed, unless specified in the text.
Classification in accordance with Regulation 1272/2008, as listed in Annex VI:
Radioactive substances and mixtures, as such are not regulated by the Regulation 1272/2008
Version: 2
Creation date: 13.05.2013
Revision date: 12.08.2016
Printing date: 12.08.2016
Release info: This version replaces all previous documents
Created/Revised by: Jane Paju ([e-mail])
Radioactive Material Profile Record
Attachment C.1
Radiological Analysis -Data Packages (including all pertinent Quality Control Data)
(see ALS lab analysis results, dated 07/27/2018 -attached)
Generator or Contractor Initials:
Page 8 of 11
A
Ft. Collins, Colorado
Friday, July 27, 2018
Jane Paju
Neo Performance Materials Silmet 00
Kesk tn 2, 40231
Sillamae, Estonia,
Re: ALS Workorder: 1806204
Project Name: NEO Silmet
Project Number:
Dear Ms. Paju:
LIMS Version: 6.867 Page 1 of 1
Fifteen solid samples were received from Neo Performance Materials Sil met 00, on 6/4/2018. The samples were
scheduled for the following analyses:
Gamma Spectroscopy
lgnitability
lnorganics
Isotopic Thorium
Isotopic Uranium
Lead-210
Metals
The results for these analyses are contained in the enclosed reports.
The data contained in the following report have been reviewed and approved by the personnel listed below. In
addition, ALS certifies that the analyses reported herein are true, complete and correct within the limits of the
methods employed.
Thank you for your confidence in ALS Environmental. Should you have any questions, please call.
Sincerely,
~±:
Jeff R. Kujawa
Proj ect Manager
ADDRESS 225 Commerce Drive, Fort Collins, Colorado, USA 80524 I PHONE [phone] FAX [phone]
ALS GROUP USA, CORP. Part of the ALS Laboratory Group An ALS Limited Company
Enulronm•nt•• JII www dhglobal.com
AICiHT SDLUTIDns Rlc;HT PAR TnER 1 of70
ALS Environmental -Fort Collins is accredited by the following accreditation bodies for
various testing scopes in accordance with requirements of each accreditation body. All
testing is performed under the laboratory management system, which is maintained to
meet these requirement and regulations. Please contact the laboratory or accreditation
body for the current scope testing parameters.
ALS Environmental -Fort Collins
Accreditation Boclv License or Certification Number
AIHA 214884
Alaska (AK) UST-086
Arizona (AZ) AZ0742
California (CA) 06251CA
Colorado (CO) C001099
Florida (FL) E87914
Idaho (ID) C001099
Kansas (KS) E-10381
Kentuckv (KY) 90137
PJ-LA (DoD ELAP/ISO 170250) 95377
Maryland (MD) 285
Missouri (MO) 175
Nebraska(NE) NE-OS-24-13
Nevada (NV) C0000782008A
New York (NY) 12036
North Dakota (ND) R-057
Oklahoma (OK) 1301
Pennsvlvania (PA) 68-03116
Tennessee (TN) 2976
Texas (TX) T104704241
Utah (UT) C001099
WashinQton (WA) C1280
2 of70
1806204
lgnitability:
The samples were analyzed based on SW-846, 3rd Edition method 101 O and the current revision of
SOP 629.
All acceptance criteria were met.
Metals:
The samples were analyzed following SW-846, 3rd Edition procedures. Analysis by Trace ICP
followed method 601 OB and the current revision of SOP 834. Analysis by ICPMS followed method
6020A and the current revision of SOP 827. Mercury analysis by CVAA followed method 7470A
(leachate), 7471A (solid) and the current revision of SOP 812.
All acceptance criteria were met.
lnorganics:
The samples were analyzed following SW-846 and EMSL procedures for the current revisions
of the following SOPs and methods:
Analyte
Ammonia as N
Nitrate/nitrite as N
pH
Chloride
Fluoride
Sulfate
All acceptance criteria were met.
Gamma Spectroscopy:
Method
350.1
353.2 Revision 2.0
90450
300.0 Revision 2.1
300.0 Revision 2.1
300.0 Revision 2.1
SOP#
1129
1127
1126
1113
1113
1113
The samples were analyzed for the presence of gamma emitting radionuclides according to the
current revision of SOP 713.
These samples were prepared according to the current revision of SOP 739. The samples were
sealed in steel cans and stored for at least 21 days prior to analysis.
All acceptance criteria were met.
-\~00;,.,~;: 225 Commerce Drive, Fort Collins Colorado 80524 USA ''-' ,·,c +l 970 490 1511 ,: :, +l 970 490 l 52~ of 70
·.•, ;r;:;,,,·, ,J:C.\ =:·,.e r· Part of the ALS Group An ALS Limited Company
Isotopic Uranium:
The samples were analyzed for the presence of isotopic uranium according to the current
revision of SOP 714.
U-234 activity is reported in the associated method blank above the minimum detectable
concentration value. The measured blank activity is below the requested MDC. Results are
acceptable according to the current revision of SOP 715, and are submitted without further
qualification.
All remaining acceptance criteria were met.
Isotopic Thorium:
The samples were analyzed for the presence of isotopic thorium according to the current
revision of SOP 714.
A
Due to a laboratory spill, sample 1806204-15DUP has a chemical recovery of 10.9%, below the 30%
lower control limit. The duplicate error ratio (DER) values for the sample/duplicate pair for Th-228,
Th-230, and Th-232 are in control. Please refer to NCR #14714 for further information.
All remaining acceptance criteria were met.
Lead-210:
The samples were analyzed for the presence of 210Pb according to the current revisions of SOP
704.
All acceptance criteria were met.
. i='C•,' ~ ;_, 22 5 Commerce Drive, Fort Collins Colorado 805 24 USA ?H ','I::: + l 970 490 1 51 1 > ·\, + 1 970 490 1 52ij of 70
'-'-' ::;:L:,•;F · ,, \ ,~r;,{" Part of the ALS Group An ALS Limited Company
ALS --Fort Collins
Sample Number(s) Cross-Reference Table
OrderNum: 1806204
Client Name: Neo Performance Materials Silmet 00
Client Project Name: NEO Silmet
Client Project Number:
Client PO Number:
Client Sample Lab Sample COC Number Matrix
Number Number
LOT20 1806204-1 SOLID
LOT21 1806204-2 SOLID
LOT22 1806204-3 SOLID
LOT31 1806204-4 SOLID
LOT 32 1806204-5 SOLID
LOT34 1806204-6 SOLID
LOT35 1806204-7 SOLID
LOT 58 1806204-8 SOLID
LOT60 1806204-9 SOLID
LOT64 1806204-10 SOLID
LOT69 1806204-11 SOLID
LOT76 1806204-12 SOLID
LOT84 1806204-13 SOLID
LOT85 1806204-14 SOLID
LOT 86 1806204-15 SOLID
LOT20 1806204-16 LEACHAT
LOT 21 1806204-17 LEACHAT
LOT22 1806204-18 LEACHAT
LOT 31 1806204-19 LEACHAT
LOT32 1806204-20 LEACHAT
LOT34 1806204-21 LEACHAT
LOT35 1806204-22 LEACHAT
LOT58 1806204-23 LEACHAT
LOT60 1806204-24 LEACHAT
LOT64 1806204-25 LEACHAT
LOT69 1806204-26 LEACHAT
LOT76 1806204-27 LEACHAT
LOT84 1806204-28 LEACHAT
LOT85 1806204-29 LEACHAT
LOT 86 1806204-30 LEACHAT
Date
Collected
10-Apr-18
10-Apr-18
1 O-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
10-Apr-18
Time
Collected
Page 1 of 1 ALS --Fort Collins Date Printed: Friday, July 27, 2016
LIM$ Version: 6 B67
5 of70
I
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3
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1
~
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11
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Kesk l, 40231, Sillamlle
Tel. [phone]
AS OKOSIL KESKK01'~ALABOR
Akreditccritud katselaboratoorium
EN JSO/JEC J702S Reg.or. L 091
FJks 39 29152, e-mAII: sckrctar@.ecosll.ee
17577 7 SS E rn ZZEl9F 7177W i7 7 HIP 1 rr::t ... -~ 77 s ·lli2 a .,. .. Ts
MEASUREMENT PROTOCOL .N'!, 195/18
Date: 10.04.2018
Customer: NPM Silmet 00, Kesk 2, 40231 Sillamae
FESPTEZ nrr:w· T I
Sheet !(I)
Order: NORM samples analysis, LOT 20,21,22,30,31,32,34,35,58,59,60,64,65,68,69,76,84,85,86
Target: Determination of radionuclide content: U-238, Th-232, Ra-226, Ra-228
Measurement method:
Measurement of the content ofradionuc.Jides on a gamma spectrometric unit using the Genie -2000
spectroscopy system*
Appliance:
Digital Spectrum Analyzer DSA-1000, sin 00001181, Canberra Ind.Inc.
Germanium detector Model GR2520. Serial number: b 96517
Sample Geometry-Marinelly, 500 ml
Reference Materials
MBSS2, RGU-1, RGTh-1
Measurement results:
The content of ratlionuclidcs in the l'IOR:\-1 samples, Bq/g.
Samples Weiizh. g
LOT20 500
LOT21 500
LOT22 500
LOT3I 500
LOT32 500
LOT34 500
LOT35 500
LOT58 500
LOT60 500
LOT64 500
LOT69 500
LOT 76 500
LOT84 500
LOT85 500
LOT86 500
• The mclhod i~ not accredited
Dina Shestakova ~
Sillamae department director
U-238 Th-232 Ra-226
37 29 38
59 27 60
46 45 I 51
37 34 33
36 35 36
46 49 36
45 49 30
62 68 46
80 81 60
73 73 57
91 82 57
87 95 60
73 81 57
80 72 67 .
73 71 I 68
Ra-228
30
28
47
35
35
50
49
68
74
73
81
95
81
72
73
PrOll'COI data relate only to lhc "it.:ms lt:dicated in th: Protocoi.
Prolocol playbuck i$ o.llowed only in ~pc~i1ic pnrls oflh~ written pem:ission of AS Okosii
••;.
6 of70
A ALS Em'ironmental -Fort Collins
CONDITION OF SAMPLE UPON RECEIPT FORM
Client: _.N..._t-_O ________ _ Workorder No: I~ i) lo ) 0 L-J
Project Manager: ---------------Initials: C.~ Date: (p.,)1 .... /f'
I Does this project require any special handling in addition to standard ALS procedures? YES ' Cl:!Q)
1. Are custody seals on shipping containers intact? NOfil_ (yE§")' NO ------·
3. Are Custody seals on sample containers intact? (.1iON1;/ YES NO -~ -
4. Is there a COC (Chain-of-Custody) present or other representative documents? (YES) NO
s. Are the COC and bottle labels complete and legible? I (...YE'Y NO --
6 Is the COC in agreement with samples received? (IDs, dates, times, no. of samples, no. @ of containers, matrix, requested analyses, etc.) NO --
7. Were airbills / shipping documents present and/or removable? DROP OFF YES ( N<Y -
s. Are all aqueous samples requiring preservation preserved correctly? (excluding volatiles) (NIA) YES NO
9. Are all aqueous non-preserved samples pH 4-9? (NIA) YES NO
10. Is there sufficient sample for the requested ~alyses? (YE9 NO -
11. Were all samples placed in the proper containers for the requested analyses? (yE~ I NO
12. Are all samples within holding times for the requested analyses? (VEs) NO
13. Were all sample containers received intact? (not broken or leaking, etc.) ~ NO --,---·--
14· Are all samples requiring no headspace (VOC, GRO, RSK/MEE, Rx CN/S, radon) ~ YES NO headspace free? Size of bubble: __ < green pea __ > green pea I
G ' is. Do any water samples contain sediment? Amount YES NO
Amount of sediment: __ dusting moderate __ heavy --·-
16. Were the samples shipped on ice? -YES (NO)
17. Were cooler temperatures measured at 0.1-6.0°C? IR gun i(1RAU YES I 00) used*: #1 #3 #4 ONb)'
Cooler#: I '.)_
Temperature (°C): /Jrr.}, ~~
No. of custody seals on cooler: -m5o I DOT Sul'ff~ External ~LR/hr reading: Accepla.nce
Information
Background ~LR/hr reading: 11...
Were external µR/hr re.,clings s two Innes l>nckgrmmd and within DOT accepuincc criteria? YES/ NO/ NA (lfno. see Fonn 008.)
Additional Information: PROVIDE DETAILS BELOW FOR A NO RESPONSE TO ANY QUESTION ABOVE, EXCEPT# I AND #16.
----------------------
If applicable, was the client contacted? YES/ NO~ Contact: DateiTime: ---------------------
Pro j tt t M,nag" ..... ,.,. /Doi<, 1..1/._ 'l.... C -l't ,Ir
f I[ ·1R Gun #1, VWR SN 170560549
Fonn 201r25.xls ·rR Gun #3, VWR SN 170647571
(0.2/12/2018) ·1R Gun #4, Oakton. SN 2372220101-0002
ALS --Fort Collins
Client: Neo Performance Materials Silmet 00
Project: NEO Silmet
Sample ID: LOT 20
Legal Location:
Collection Date: 4/10/2018
Analyses
Ammonia as N
AMMONIAASN
Gamma Spectroscopy Results
Ra-226
Ra-228
ICPMS Metals
SILVER
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CADMIUM
COBALT
CHROMIUM
COPPER
IRON
POTASSIUM
MAGNESIUM
MANGANESE
MOLYBDENUM
SODIUM
NIOBIUM
NICKEL
LEAD
SELENIUM
TIN
TANTALUM
THORIUM
THALLIUM
URANIUM
VANADIUM
ZINC
ZIRCONIUM
Ion Chromatography
CHLORIDE
FLUORIDE
SULFATE
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229
Th-228
Th-230
Th-232
Result
47
900 (+/-110)
667 (+/-78)
2.2
1400
7.1
320
1.3
2500
4
3.2
34
32
4500
420
400
410
0.74
220
350
26
1700
ND
110
70
5700
0.5
1400
5
48
410
ND
1600
7300
86.7
527 (+/-83)
507 (+/-80)
642 (+/-85)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 92.B
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-1
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
EPA350.1 Prep Date: 71712018
0.99 MG/KG 1
SOP 713 Prep Date: 611812018
M3,G 10 pCi/g NA
M3,G 8 pCi/g NA
M3
M3
M3
SW6020 Prep Date: 711612018
0.048 MG/KG 10
9.6 MG/KG 10
0.19 MG/KG 10
0.48 MG/KG 10
0.048 MG/KG 10
96 MG/KG 10
0.19 MG/KG 10
0.48 MG/KG 10
0.96 MG/KG 10
1.9 MG/KG 10
9.6 MG/KG 10
96 MG/KG 10
9.6 MG/KG 10
0.48 MG/KG 10
0.19 MG/KG 10
96 MG/KG 10
0.96 MG/KG 100
1.9 MG/KG 10
19 MG/KG 1000
0.96 MG/KG 10
0.96 MG/KG 10
0.96 MG/KG 100
1.9 MG/KG 1000
0.0096 MG/KG 10
0.96 MG/KG 1000
0.48 MG/KG 10
9.6 MG/KG 10
0.48 MG/KG 100
EPA300.0 Prep Date: 6118/2018
19
48
96
MG/KG
MG/KG
MG/KG
10
50
10
SOP 714 Prep Date: 712/2018
30-110 %REC DL = NA
4 pCi/g NA
6 pCi/g
1 pCi/g
NA
NA
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL = NA
PrepBy: HMA
717/201813:31
PrepBy:NMP
7/9/2018 07:33
7/9/2018 07:33
PrepBy: JML
7/21/201817:15
7/21/201817:15
7/21/201818:48
7/21/201817:15
7/21/2018 17:15
7/21/2018 17:15
7/21/201817:15
7/21/2018 17:15
7/21/201817:15
7/21/2018 17:15
7/21/201817:15
7/21/2018 17:15
7/21/201817:15
7/21/2018 17:15
7/21/201817:15
7/21/201817:15
7/27/201811:15
7/21/201817:15
7/22/201819:51
7/21/201818:48
7/21/201817:15
7/27/2018 11 :15
7/22/201819:51
7/21/201817:15
7/22/201819:51
7/21/201817:15
7/21/2018 17:15
7/27/2018 11 :15
PrepBy: HMA
6/19/2018 03:30
6/19/2018 03:45
6/19/2018 03:30
PrepBy:SOW
7/14/2018 12:06
7/14/2018 12:06
7/14/2018 12:06
7/14/2016 12:06
PrepBy: SOW
7/16/2018 07:26
ALS --Fort Collins
LIMS Version: 6.867 AR Page 1 Stoi&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Sil met 00
NEOSilmet
Sample ID: LOT20
Legal Location:
Collection Date: 4/10/2018
Analyses Result
U-234 518 (+/-86)
U-235 23.7 (+/-6.1)
U-238 545 (+/-90)
Lead-210 by Liquid Scintilation
Pb-210 480 (+/-120)
Carr: LEAD 93.1
Mercury
MERCURY ND
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 2.68
Report
Qual Limit
M3 2
M3 1.8
M3
SOP 704
M3 0
40-110
SW7471
0.031
EPA353.2
0.096
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
Work Order: 1806204
Lab ID: 1806204-1
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCi/g NA
pCilg NA
pCi/g NA
Date Analyzed
7116/2016 07:28
7/16/2018 07:28
7/16/2016 07:26
Prep Date: 7/17/2018 PrepBy:NCC
pCi/g NA 7/18/201815:44
%REC DL=NA 7/18/201815:44
Prep Date: 7/12/2018 PrepBy: KJM
MG/KG 1 7/13/201811 :21
Prep Date: 6/22/2018 PrepBy:HMA
MG/KG 1 6/2312018 09:18
Prep Date: 6/18/2018 PrepBy:AEJ
pH 1 6/1812018
AR Page 2 2,to(&70
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT21
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 36
Gamma Spectroscopy Results
Ra-226 1140 (+/-130)
Ra-228 636 (+/-75)
ICPMS Metals
SILVER 2.6
ALUMINUM 1800
ARSENIC 7.9
BARIUM 460
BERYLLIUM 2.2
CALCIUM 3600
CADMIUM 0.95
COBALT 1.1
CHROMIUM 24
COPPER 24
IRON 5400
POTASSIUM 310
MAGNESIUM 660
MANGANESE 500
MOLYBDENUM 0.65
SODIUM 420
NIOBIUM 430
NICKEL 16
LEAD 2100
SELENIUM ND
TIN 110
TANTALUM 140
THORIUM 4100
THALLIUM 0.61
URANIUM 1900
VANADIUM 4.2
ZINC 42
ZIRCONIUM 490
Ion Chromatography
CHLORIDE ND
FLUORIDE 1400
SULFATE 8500
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 81,7
Th-228 574 (+/-91)
Th-230 740 (+/-120)
Th-232 611 (+/-96)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 92.1
Report
Qual Limit
EPA350.1
0.99
SOP 713
M3,G 10
M3,G 12
SW6020
0.048
9.5
0.19
0.48
0.048
95
0.19
0.48
0.95
1.9
9.5
95
9.5
0.48
0.19
95
0.95
1.9
19
0.95
0.95
0.95
1.9
0.0095
0.95
0.48
9.5
0.48
EPA300.0
20
49
98
SOP 714
30-110
M3 7
M3 10
M3 2
SOP 714
30-110
ALS --Fort Collins
LIMS Version: 6,867
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: I 806204-2
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/712018 PrepBy:HMA
MG/KG 1 7/7/2016 13:32
Prep Date: 6118/2018 PrepBy: NMP
pCi/g NA 7/9/2016 07:33
pCi/g NA 7/9/2018 07:33
Prep Date: 7/16/2018 PrepBy: JML
MG/KG 10 7/21/201817:18
MGIKG 10 7/21/2018 17:18
MGIKG 10 7/21/2018 18:54
MGIKG 10 7/21/201817:18
MGIKG 10 7/21/201817:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/201817:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/201817:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/2018 17:18
MG/KG 10 7/21/201817:18
MG/KG 10 7/21/2018 17:18
MG/KG 100 7/27/201811 :16
MG/KG 10 7/21/2018 17:18
MG/KG 1000 7/22/2018 19:54
MG/KG 10 7/21/2018 18:54
MG/KG 10 7/21/2018 17:18
MG/KG 100 7/27/2018 11 :16
MG/KG 1000 7/22/2018 19:54
MG/KG 10 7/21/2018 17:18
MG/KG 1000 7/22/201819:54
MG/KG 10 7/21/201817:18
MG/KG 10 7/21/2018 17:18
MG/KG 100 7/27/201811:16
Prep Date: 611812018 PrepBy: HMA
MG/KG 10 6/19/2018 04:00
MG/KG 50 6/19/2018 04:14
MG/KG 10 6/19/2018 04:00
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL= NA 7/14/201812:06
pCl/g NA 7/14/201812:06
pCi/g NA 7/14/201812:06
pCi/g NA 7/14/2018 12:06
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/16/2018 07:28
AR Page 1 Qro{&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT21
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
U-234 700 (+1-120)
U-235 30.7 (+/· 7.4)
U-238 750 (+/· 120)
Lead-210 by Liquid Scintllatlon
Pb-210 660 (+/-160)
Carr: LEAD 93.8
Mercury
MERCURY ND
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 2.72
Report
Qual Limit
M3 0
M3 1.4
M3 0
SOP 704
M3 0
40-110
SW7471
0.033
EPA353.2
0.099
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
'\\'orkOrder: 1806204
Lab ID: 1806204-2
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCi/g NA
pCi/g NA
pCi/g NA
Date Analyzed
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
Prep Date: 7/17/2018 PrepBy: NCC
pCi/g NA 7/18/201816:33
%REC DL= NA 7/18/201816:33
Prep Date: 7/12/2018 PrepBy:KJM
MG/KG 7/13/2018 11 :23
Prep Date: 6/22/2018 PrepBy: HMA
MG/KG 6/23/2018 09:19
Prep Date: 6/18/2018 PrepBy: AEJ
pH 1 6/18/2018
AR Pagel l>to{G'O
ALS --Fort Collins
Client: Neo Performance Materials Silmet 00
Project: NEO Silmet
Sample ID: LOT 22
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 44
Gamma Spectroscopy Results
Ra-226 1070 (+/-130)
Ra-228 940 (+/-110)
ICPMS Metals
SILVER 3.4
ALUMINUM 1300
ARSENIC 6.9
BARIUM 250
BERYLLIUM 0.86
CALCIUM 3000
CADMIUM 1.9
COBALT 2.1
CHROMIUM 20
COPPER 26
IRON 4900
POTASSIUM 300
MAGNESIUM 460
MANGANESE 450
MOLYBDENUM 0.49
SODIUM 240
NIOBIUM 390
NICKEL 9.6
LEAD 2300
SELENIUM ND
TIN 63
TANTALUM 69
THORIUM 6800
THALLIUM 0.44
URANIUM 1600
VANADIUM 4.1
ZINC 29
ZIRCONIUM 720
Ion Chromatography
CHLORIDE ND
FLUORIDE 1200
SULFATE 6500
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 86.4
Th-228 740 (+/-110)
Th-230 650 (+/-100)
Th-232 770 (+/-120)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 89.5
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-3
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
EPA350.1 Prep Date: 7/7/2018
9.8 MG/KG 10
SOP 713 Prep Date: 6/18/2018
M3,G 10 pCi/g NA
MJ.G 10 pCilg NA
SW6020 Prep Date: 7/16/2018
0.05 MG/KG 10
10 MG/KG 10
0.2 MG/KG 10
0.5 MG/KG 10
0.05 MG/KG 10
100 MG/KG 10
0.2 MG/KG 10
0.5 MG/KG 10
1 MG/KG 10
2 MG/KG 10
10 MG/KG 10
100 MG/KG 10
10 MG/KG 10
0.5 MG/KG 10
0.2 MG/KG 10
100 MG/KG 10
1 MG/KG 100
2 MG/KG 10
20 MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
2 MG/KG 1000
0.01 MG/KG 10
1 MG/KG 1000
0.5 MG/KG 10
10 MG/KG 10
0.5 MG/KG 100
EPA300.0 Prep Date: 6/18/2018
9.8 MG/KG 5
20 MG/KG 20
200 MG/KG 20
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL=NA
M3 10 pCi/g NA
M3 10 pCi/g NA
M3 0 pCi/g NA
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL = NA
PrepBy:HMA
717/2018 13:34
PrepBy: NMP
7/9/2018 07:33
7/9/2018 07:33
PrepBy: JML
7/2112018 17:21
7/21/2018 17:21
7/21/201819:00
7/21/201817:21
7/21/2018 17:21
7/21/2018 17:21
7/21/201817:21
7/21/2018 17:21
7/21/2018 17:21
7/21/2018 17:21
7/21/2018 17:21
7/21/2018 17:21
7/21/201817:21
7/21/201817:21
7/21/201817:21
7/21/201817:21
7/27/2018 11 :17
7/21/201817:21
7/22/2018 19:57
7/21/2018 19:00
7/21/201817:21
7/27/201811:17
7/22/2018 19:57
7/21/201817:21
7/22/2018 19:57
7/21/2018 17:21
7/21/2018 17:21
7/27/201811:17
PrepBy:HMA
6/19/2018 04:29
6/30/2018 12:49
6/19/2018 05:15
PrepBy:SDW
7/14/2018 12:06
7/14/2018 12:06
7/14/2018 12:06
7/14/2018 12:06
PrepBy:SDW
7/16/2018 07 :28
ALS --Fort Collins
LIMS Version: 6.867 AR Page llito{&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT22
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
U-234 600 (+/-99)
U-235 28.2 (+/. 7)
U-238 890 (+/-110)
Lead-210 by Liquid Scintilation
Pb-210 650 (+/-160)
Carr: LEAD 92.7
Mercury
MERCURY ND
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 2.96
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-!8
\VorkOrder: 1806204
Lab ID: 1806204-3
Matrix: SOLID
Percent Moisture:
Dilution
Qual Limit Units Factor Date Analyzed
M3 1 pCi/g NA
M3 0.7 pCilg NA
M3 0 pCilg NA
SOP 704 Prep Date: 7/17/2018
M3 0 pCi/g NA
40-110 %REC DL= NA
SW7471 Prep Date: 7/12/2018
0.033 MG/KG 1
EPA353.2 Prep Date: 6/22/2018
0.1 MG/KG 1
SW9045 Prep Date: 6/18/2018
0.1 pH 1
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
PrepBy: NCC
7/18/201817:19
7/18/201817:19
PrepBy: KJM
7/13/201811:26
PrepBy:HMA
6/23/2016 09:20
PrepBy:AEJ
6/16/2018
ALS --Fort Collins
LIMS Version: 6.867 AR Page ilro(OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT31
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 82
Gamma Spectroscopy Results
Ra-226 1020 (+/-120)
Ra-228 950 (+/-110)
ICPMS Metals
SILVER 4.5
ALUMINUM 4300
ARSENIC 9.3
BARIUM 380
BERYLLIUM 0.64
CALCIUM 9400
CADMIUM 28
COBALT 20
CHROMIUM 150
COPPER 860
IRON 11000
POTASSIUM 790
MAGNESIUM 880
MANGANESE 630
MOLYBDENUM 4.1
SODIUM 1500
NIOBIUM 710
NICKEL 100
LEAD 2800
SELENIUM ND
TIN 98
TANTALUM 79
THORIUM 3900
THALLIUM 0.66
URANIUM 1700
VANADIUM 18
ZINC 150
ZIRCONIUM 740
Ion Chromatography
CHLORIDE 110
FLUORIDE 2700
SULFATE 9400
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 87
Th-228
Th-230
Th-232
680 (+1-110)
760 (+1-120)
710 (+/-110)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 93.9
Report
Qual Limit
EPA350.1
10
SOP 713
M3,G 10
M3,G 10
SW6020
0.046
9.1
0.18
0.46
D.046
91
0.18
0.46
0.91
1.8
9.1
91
9.1
0.46
0.18
91
D.91
1.8
18
0.91
0.91
0.91
1.8
0.0091
0.91
0.46
9.1
0.46
EPA300.0
20
49
99
SOP 714
30-110
M3 0
M3 10
SAMPLE SUMMARY REPORT
Date: 27-111/-18
Work Order: 1806204
Lab ID: 1806204-4
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
Prep Date: 7/7/2018
MG/KG 10
Prep Date: 6/18/2018
pCi/g NA
pCl/g NA
Prep Date: 7/16/2018
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 100
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
MG/KG 1000
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
Prep Date: 6/18/2018
MG/KG 10
MG/KG 50
MG/KG 10
Prep Date: 7/2/2018
%REC DL=NA
pCi/g NA
pCi/g NA
Date Analyzed
PrepBy: HMA
7/7/2018 13:36
PrepBy: NMP
7/9/2018 07:33
7/9/2018 07:33
PrepBy: JML
7/21/2018 17:24
7/21/2018 17:24
7/21/2018 19:06
7/21/2018 17:24
7/21/201817:24
7/21/201817:24
7/21/2018 17:24
7/21/201817:24
7/21/201817:24
7/21/201817:24
7/21/2018 17:24
7/21/2018 17:24
7/21/2018 17:24
7/21/2018 17:24
7/21/2018 17:24
7/21/2018 17:24
7/27/2018 11 :19
7/21/201817:24
7/22/2018 20:00
7/21/201819:06
7/21/201817:24
7/27/2018 11 :19
7/22/2018 20:00
7/21/2018 17:24
7/22/2018 20:00
7/2112018 17:24
7121/201817:24
7/27/201811:19
PrepBy: HMA
6/19/2018 05:30
6/30/2018 13:04
6/19/2018 05:30
M3 0 pCilg NA
PrepBy:SOW
7/1412018 12:06
7/14/2018 12:06
7/14/201812:06
7/14/201812:06
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL = NA
ALS --Fort Collins
LIMS Version: 6.867
PrepBy:SOW
7/16/2018 07:28
AR Page H,to{OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT31
Legal Location:
Collection Date: 4/ I0/2018
Analyses Result
U-234 730 (+/-120)
U-235 32.3 (+/-7 .4)
U-238 790 (+/-130)
Lead-21 O by Liquid Scintilation
Pb-210 690 (+/-170)
Carr: LEAD 102
Mercury
MERCURY 0.045
Nitrate/Nitrite as N
NITRATE/NITRITE AS N 0.14
pH
PH 3.61
Report
Qual Limit
M3 0
M3 1.2
M3 0
SOP 704
Y1,M3 0
Y1 40-110
SW7471
0.031
EPA353.2
0.098
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 2 7-Jul-J 8
Work Order: 1806204
Lab ID: 1806204-4
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCl/g NA
pCi/g NA
pCi/g NA
Date Analyzed
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
Prep Date: 7/17/2018 PrepBy: NCC
pCi/g NA 7/18/2018 18:07
%REC DL=NA 7/18/2018 18:07
Prep Date: 7/12/2018 PrepBy: KJM
MG/KG 1 7/13/2018 11 :28
Prep Date: 6/22/2018 PrepBy: HMA
MG/KG 1 6/23/2018 09:20
Prep Date: 6/18/2018 PrepBy:AEJ
pH 1 6/18/2018
AR Page I ito(t'10
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silrnet 00
NEOSilmet
Sample ID: LOT32
Legal Location:
Collection Date: 4/ I 0/2018
Analyses
Ammonia as N
AMMONIAASN
Gamma Spectroscopy Results
Ra-226
Ra-228
ICPMS Metals
SILVER
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CADMIUM
COBALT
CHROMIUM
COPPER
IRON
POTASSIUM
MAGNESIUM
MANGANESE
MOLYBDENUM
SODIUM
NIOBIUM
NICKEL
LEAD
SELENIUM
TIN
TANTALUM
THORIUM
THALLIUM
URANIUM
VANADIUM
ZINC
ZIRCONIUM
Ion Chromatography
CHLORIDE
FLUORIDE
SULFATE
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229
Th-228
Th-230
Th-232
Result
69
930 (+/-110)
860 (+/-100)
4.6
2900
11
490
0.36
4400
1.8
1.9
57
55
6300
1100
450
360
1.5
2300
780
38
2200
ND
92
150
3600
0.44
1500
14
38
710
ND
3200
6700
87.4
599 (+/. 94)
557 (+/. 88)
598 (+/-94)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 80
Report
Qual Limit
EPA350.1
9.9
SOP 713
M3,G 10
M3,G 10
SW6020
0.048
9.5
0.19
0.48
0.048
95
0.19
0.48
0.95
1.9
9.5
95
9.5
0.48
0.19
95
0.95
1.9
19
0.95
0.95
0.95
1.9
0.0095
0.95
0.48
9.5
0.48
EPA300.0
20
49
99
SOP 714
30-110
M3 5
M3 7
M3 2
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-5
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
Prep Date: 7/7/2018
MG/KG 10
Prep Date: 6/18/2018
pCi/g NA
pCi/g NA
Prep Date: 7/16/2018
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 100
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
MG/KG 1000
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
Prep Date: 6/18/2018
MG/KG 10
MG/KG 50
MG/KG 10
Prep Date: 7/2/2018
%REC DL=NA
pCi/g NA
pCi/g NA
pCi/g NA
Date Analyzed
PrepBy:HMA
717/2018 13:39
PrepBy:NMP
7/9/2018 07:33
7/9/2018 07:33
PrepBy: JML
7/21/2018 17:27
7/21/2018 17:27
7/21/201819:12
7/21/201817:27
7/21/201817:27
7/21/2018 17:27
7/21/2018 17:27
7/21/2018 17:27
7/21/201817:27
7/21/201817:27
7/21/2018 17:27
7/21/2018 17:27
7/21/2018 17:27
7/21/2018 17:27
7/21/2018 17:27
7/21/2018 17:27
7/27/2018 11 :20
7/21/2018 17:27
7/22/2018 20:03
7/21/201819:12
7/21/2018 17:27
7/27/2018 11 :20
7/22/2018 20:03
7/21/2018 17:27
7/22/2018 20:03
7/21/201817:27
7/21/2018 17:27
7/27/2018 11 :20
PrepBy: HMA
6/19/2018 05:59
6/30/2018 13:20
6/19/2018 05:59
PrepBy:SDW
7/14/2018 12:06
7/14/2018 12:06
7/14/201812:06
7/14/201812:06
SOP 714 Prep Date: 7/2/2018 PrepBy:SDW
111512018 01 :28 30-110 %REC DL = NA
ALS --Fort Collins
LIMS Version: 6.867 AR Page t 6to(00
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT32
Legal Location:
Collection Date: 4/10/2018
Analyses Result
U-234 640 (+/-110)
U-235 32.7 (+/-8.2)
U-238 730 (+/-120)
Lead-210 by Liquid Scintllation
Pb-210 490 (+/-1201
Carr: LEAD 104
Mercury
MERCURY 0.46
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 3.66
Report
Qual Limit
M3 0
M3 0.8
M3 0
SOP 704
Y1 ,M3 0
Y1 40-110
SW7471
0.032
EPA353.2
0.95
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-5
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCi/g NA
pCi/g NA
pCi/g NA
Date Analyzed
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
Prep Date: 7/17/2018 PrepBy: NCC
pCi/g NA 7/18/2018 18:55
%REC DL=NA 7/18/201818:55
Prep Date: 7/1212018 PrepBy:KJM
MG/KG 1 7/13/201811:30
Prep Date: 6/22/2018 PrepBy: HMA
MG/KG 10 6/23/2018 10:47
Prep Date: 6/18/2018 PrepBy:AEJ
pH 1 6/18/2018
AR Page Ji oto(&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT34
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 140
Gamma Spectroscopy Results
Ra-226 1130 (+/-130)
Ra-228 1360 (+/-160)
ICPMS Metals
SILVER 4.1
ALUMINUM 10000
ARSENIC 1.1
BARIUM 480
BERYLLIUM 4.8
CALCIUM 11000
CADMIUM 0.38
COBALT 1.7
CHROMIUM 180
COPPER 8.6
IRON 19000
POTASSIUM 7200
MAGNESIUM 4200
MANGANESE 3900
MOLYBDENUM 4.1
SODIUM 2700
NIOBIUM 2300
NICKEL 99
LEAD 5900
SELENIUM ND
TIN 88
TANTALUM 440
THORIUM 1900
THALLIUM 5.1
URANIUM 1700
VANADIUM 13
ZINC 180
ZIRCONIUM 4300
Ion Chromatography
CHLORIDE ND
FLUORIDE 17000
SULFATE 17000
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 82.4
1090 (+/-170) Th-228
Th-230
Th-232
780 (+/-120)
1190 (+/. 190)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 BB
Report
Qual Limit
EPA350.1
10
SOP 713
M3 10
M3 10
SW6020
0.049
9.7
0.19
0.49
0.049
97
0.19
0.49
0.97
1.9
9.7
97
9.7
49
0.19
97
9.7
1.9
19
0.97
0.97
0.97
1.9
0.0097
0.97
0.49
9.7
4.9
EPA300.0
40
490
200
SOP 714
30-110
M3 10
M3 10
M3 0
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-6
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
Prep Date: 7/7/2018
MG/KG 10
Prep Date: 6/18/2018
pCi/g NA
pCi/g NA
Prep Date: 7/16/2018
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 100
MG/KG 1000
MG/KG 10
MG/KG 1000
MG/KG 10
MG/KG 10
MG/KG 1000
Prep Date: 6/18/2018
MG/KG 20
MG/KG 500
MG/KG 20
Prep Date: 7/2/2018
%REC DL=NA
pCi/g NA
pCi/g NA
pCi/g NA
Date Analyzed
PrepBy:HMA
717/2018 13:41
PrepBy:NMP
7/9/2018 07:34
7/9/2018 07:34
PrepBy:JML
7/21/201817:29
7/21/2018 17:29
7/21/2016 19:18
7/21/2018 17:29
7/21/2018 17:29
7/21/2018 17:29
7/21/2018 17:29
7/21/2016 17:29
7/21/201817:29
7/21/201817:29
7/21/201817:29
7/21/2018 17:29
7/21/2018 17:29
7/22/2018 20:06
7/21/201617:29
7/21/2018 17:29
7/27/201 B 11 :51
7/21/2018 17:29
7/22/2018 20:06
7/21/201819:18
7/21/201817:29
7/27/2018 11 :21
7/22/2018 20:06
7/21/2018 17:29
7/22/2018 20:06
7/21/201817:29
7/21/2018 17:29
7/27/2018 11 :51
PrepBy: HMA
6/19/2018 06:29
6/30/2018 13:36
6/19/2018 06:29
PrepBy:SDW
7/14/2018 12:06
7/14/2018 12:06
7/14/201812:06
7/14/201812:06
SOP 714 Prep Date: 7/2/2018 PrepBy:SDW
7/16/2018 07:28 30-110 %REC DL = NA
ALS --Fort Collins
LIMS Version: 6.867 AR Page 1 li:t0f&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT34
Legal Location:
Collection Date: 4/10/2018
Analyses Result
U-234 740 (+/. 120)
U-235 37.4 (+/-8.7)
U-238 860 f+/-140)
Lead-210 by Liquid Scintilation
Pb-210 1050 f+/-250)
Carr: LEAD 90_6
Mercury
MERCURY 0.062
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 2.4
Report
Qual Limit
M3 0
M3 1.4
M3 0
SOP 704
M3 0
40-110
SW7471
0.033
EPA353.2
0.95
SW9045
0.1
ALS •· Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
\\lorkOrder: 1806204
Lab ID: 1806204-6
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCi/g NA
pCi/g NA
pCi/g NA
Date Analyzed
7/16/2018 07:28
7116/2018 07:28
7/16/2018 07:28
Prep Date: 7/17/2018 PrepBy: NCC
pCi/g NA 7/18/201819:42
%REC DL=NA 7/18/2018 19:42
Prep Date: 7/12/2018 PrepBy: KJM
MG/KG 1 7/13/201811 :32
Prep Date: 6/22/2018 PrepBy: HMA
MG/KG 10 6/23/2018 10:49
Prep Date: 6/18/2018 PrepBy:AEJ
pH 1 6/16/2018
AR Page ti'Af0{(70
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT35
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
Ammonia as N
AMMONIAASN 150
Gamma Spectroscopy Results
Ra-226 1140 (+/-130)
Ra-228 1410 (+/-170)
ICPMS Metals
SILVER 4.1
ALUMINUM 10000
ARSENIC
BARIUM 480
BERYLLIUM 5.5
CALCIUM 10000
CADMIUM 0.36
COBALT 1.9
CHROMIUM 190
COPPER 7.8
IRON 20000
POTASSIUM 7100
MAGNESIUM 3900
MANGANESE 4000
MOLYBDENUM 3.8
SODIUM 2800
NIOBIUM 2300
NICKEL 120
LEAD 6100
SELENIUM ND
TIN 51
TANTALUM 430
THORIUM 2000
THALLIUM 5.2
URANIUM 1600
VANADIUM 13
ZINC 180
ZIRCONIUM 4000
Ion Chromatography
CHLORIDE ND
FLUORIDE 20000
SULFATE 18000
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 85.2
Th-228 1090 (+/-170)
Th-230 790 (+/-120)
Th-232 1220 (+/-190)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 88.5
Report
Qual Limit
EPA350.1
9.8
SOP 713
M3 10
M3 10
SW6020
0.047
9.4
0.19
0.47
0.047
94
0.19
0.47
0.94
1.9
9.4
94
9.4
47
0.19
94
9.4
1.9
19
0.94
0.94
0.94
1.9
0.0094
0.94
0.47
9.4
4.7
EPA300.0
39
490
200
SOP 714
30-110
M3 0
M3 10
M3 0
SOP 714
30-110
ALS •• Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\\'orkOrder: 1806204
Lab ID: 1806204-7
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy:HMA
MG/KG 10 717/2018 13:45
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 7/9/2018 07:34
pCi/g NA 7/9/2018 07:34
Prep Date: 7/16/2018 PrepBy: JML
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 19:23
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/2018 17:32
MG/KG 10 7/21/201817:32
MG/KG 10 7/21/201817:32
MG/KG 10 7/21/201817:32
MG/KG 10 7/21/2018 17:32
MG/KG 1000 7/22/2018 20:09
MG/KG 10 7/21/201817:32
MG/KG 10 7/21/2018 17:32
MG/KG 1000 7/27/2018 11 :52
MG/KG 10 7/21/2018 17:32
MG/KG 1000 7/22/2018 20:09
MG/KG 10 7/21/2018 19:23
MG/KG 10 7/21/2018 17:32
MG/KG 100 7/27/2016 11 :22
MG/KG 1000 7/22/2018 20:09
MG/KG 10 7/21/2018 17:32
MG/KG 1000 7/22/2018 20:09
MG/KG 10 7/21/201817:32
MG/KG 10 7/21/201817:32
MG/KG 1000 7/27/201811 :52
Prep Date: 6/18/2018 PrepBy:HMA
MG/KG 20 6/19/2018 06:59
MG/KG 500 6/30/2018 13:52
MG/KG 20 6/19/2018 06:59
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/16/2018 07:28
AR Page 1lQ10f§O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Sil met 00
NEO Silmet
Sample ID: LOT35
Legal Location:
Collection Date: 4/10/2018
Analyses Result
U-234 830 (-t/-140)
U-235 42.7 (-t/-9.6)
U-238 970 , .. ,. 160)
Lead-210 by Liquid Scintilation
Pb-210 1260 ,..,_ 300)
Carr: LEAD 73.B
Mercury
MERCURY 0.039
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 2.46
Report
Qual Limit
M3 0
M3 0.7
M3 0
SOP 704
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-7
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor
pCi/g NA
pCi/g NA
pCi/g NA
Prep Date: 7/17/2018
Date Analyzed
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
M3 0 pCi/g NA
PrepBy: NCC
7/18/2018 20 :30
7/18/2018 20:30 40-110
SW7471
0.033
EPA353.2
0.97
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6,867
%REC DL=NA
Prep Date: 7/12/2018
MG/KG 1
Prep Date: 6/22/2018
MG/KG 10
Prep Date: 6/18/2018
pH 1
PrepBy: KJM
7/13/2018 11 :39
PrepBy: HMA
6/23/2018 10:51
PrepBy:AEJ
6/18/2018
AR Page 121,rof&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT 58
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 26
Gamma Spectroscopy Results
Ra-226 1480 (+/-1701
Ra-228 1830 (+/-2101
ICPMS Metals
SILVER 7.6
ALUMINUM 11000
ARSENIC 0.92
BARIUM 550
BERYLLIUM 6.9
CALCIUM 13000
CADMIUM ND
COBALT 1.2
CHROMIUM 100
COPPER 26
IRON 20000
POTASSIUM 670
MAGNESIUM 4100
MANGANESE 1200
MOLYBDENUM 1.6
SODIUM 3300
NIOBIUM 1000
NICKEL 150
LEAD 5700
SELENIUM ND
TIN 69
TANTALUM 210
THORIUM 810
THALLIUM 2.6
URANIUM 2500
VANADIUM 14
ZINC 56
ZIRCONIUM 5100
lgnitability
IGNIT ABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 3900
SULFATE 2600
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 74.1
Th-228 1120 (+/-1701
Th-230 910 (+/-1401
Th-232 1370 (+/-210)
Report
Qual Limit
EPA350.1
1
SOP 713
M3 10
M3 10
SW6020
0.049
9.9
0.2
0.49
0.049
99
0.2
0.49
0.99
2
9.9
99
9.9
0.49
0.2
99
9.9
2
20
0.99
0.99
0.99
2
0.0099
0.99
0.49
9.9
4.9
SW1010
96
EPA300.0
19
97
97
SOP 714
30-110
M3 10
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
\VorkOrder: 1806204
Lab ID: 1806204-8
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy: HMA
MG/KG 1 7/7/2018 13:46
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 11912010 01:34
pCi/g NA 11912010 01:34
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/21/201817:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 19:38
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 112112010 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 1000 7/27/2018 11 :54
MG/KG 10 7/21/201817:47
MG/KG 1000 112212010 20:23
MG/KG 10 7/21/201819:38
MG/KG 10 7/21/2018 17:47
MG/KG 100 112112010 11 :31
MG/KG 1000 7/22/2018 20:23
MG/KG 10 7/21/2018 17:47
MG/KG 1000 7/22/2018 20:23
MG/KG 10 7/21/2018 17:47
MG/KG 10 7/21/2018 17:47
MG/KG 1000 7/27/2018 11 :54
Prep Date: 7/12/2018 PrepBy: JMD
deg C 1 7/12/2018
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 10 6/19/2018 08:18
MG/KG 100 6/30/2018 14:08
MG/KG 10 6/19/2018 08:18
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/201812:06
pCi/g NA 7/14/2018 12:06
AR Page 1J2,f0{00
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT 58
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 85.7
1080 (+/-180) U-234
U-235
U-238
Lead-210 by Liquid Scintilation
Pb-210
Carr: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
52 (+/-11)
1300 (+/-210)
1230 (+/-300)
87.1
ND
ND
2.93
Report
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
Work Order: 1806204
Lab ID: 1806204-8
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL= NA
M3 0 pCi/g NA
M3 2 pCi/g NA
M3 0 pCi/g NA
SOP 704 Prep Date: 7/17/2018
M3 0 pCi/g NA
40-110 %REC DL= NA
SW7471 Prep Date: 7/12/2018
0.033 MG/KG 1
EPA353.2 Prep Date: 6/22/2018
1 MG/KG 10
SW9045 Prep Date: 6/18/2018
0.1 pH 1
PrepBy:SDW
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
PrepBy: NCC
7/18/2018 21:17
7/18/2018 21 :17
PrepBy: KJM
7/13/201811:41
PrepBy: HMA
6/23/201 B 10:53
PrepBy:AEJ
6/18/2018
ALS ·-Fort Collins
LIMS Version: 6.867 AR Page 1ilto{OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet OU
NEO Silmet
Sample ID: LOT60
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 11
Gamma Spectroscopy Results
Ra-226 1520 (+/. 180)
Ra-228 1810 (+/. 210)
ICPMS Metals
SILVER 3.2
ALUMINUM 3400
ARSENIC 1.4
BARIUM 370
BERYLLIUM 1.4
CALCIUM 3500
CADMIUM ND
COBALT ND
CHROMIUM 36
COPPER ND
IRON 7000
POTASSIUM 360
MAGNESIUM 830
MANGANESE 1300
MOLYBDENUM 1
SODIUM 420
NIOBIUM 620
NICKEL 28
LEAD 4600
SELENIUM ND
TIN 84
TANTALUM 75
THORIUM 2100
THALLIUM 0.54
URANIUM 2700
VANADIUM 3.9
ZINC 74
ZIRCONIUM 2200
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 2100
FLUORIDE 2200
SULFATE 2500
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 87.8
Th-228 930 (+/. 140)
Th-230 830 (+/. 130)
Report
Qual Limit
EPA350.1
1
SOP 713
M3,G 10
M3,G 20
SW6020
0.046
9.2
0.18
0.46
0.046
92
0.18
0.46
0.92
1.8
9.2
92
9.2
0.46
0.18
92
9.2
1.8
18
0.92
0.92
0.92
1.8
0.0092
0.92
0.46
9.2
4.6
SW1010
96
EPA300.0
2
9.8
98
98
SOP 714
30-110
M3 10
M3 10
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-!8
\VorkOrder: 1806204
Lab ID: 1806204-9
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy:HMA
MG/KG ?n/2018 13:47
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 7/9/2018 08:21
pCi/g NA 7/9/2018 08:21
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/2018 19:44
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/2018 17:50
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/2018 17:50
MG/KG 1000 7/27/2018 11 :55
MG/KG 10 7/21/2018 17:50
MG/KG 1000 7/22/2018 20:26
MG/KG 10 7/21/2018 19:44
MG/KG 10 7/21/2018 17:50
MG/KG 100 7/27/2018 11 :33
MG/KG 1000 7/22/2018 20:26
MG/KG 10 7/21/201817:50
MG/KG 1000 7/22/2018 20:26
MG/KG 10 7/21/201817:50
MG/KG 10 7/21/2018 17:50
MG/KG 1000 7/27/201811:55
Prep Date: 7/12/2018 PrepBy:JMD
degC 7/12/2018
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 1 6/19/2018 08:33
MG/KG 10 6/19/2018 08:48
MG/KG 100 6/30/2018 14:23
MG/KG 10 6/19/2018 08:48
Prep Date: 7/212018 PrepBy:SDW
%REC DL,.NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/201812:06
AR Page 1J4rtofG'0
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT60
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Th-232 1150 (+/· 180)
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 77.5
U-234 1250 (+/-2101
U-235
U-238
Lead-210 by Liquid Scintilation
Pb-210
Can-: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
64 (+/. 14)
1390 (+/. 230)
960 (+/-230)
BB.7
ND
ND
3.18
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-9
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
M3 0 pCi/g NA
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL = NA
M3 0 pCi/g NA
M3
M3
M3
SOP 704
2 pCi/g
0 pCi/g
NA
NA
Prep Date: 7/17/2018
0 pCi/g NA
40-110 %REC DL=NA
SW7471 Prep Date: 7/12/2018
0.031 MG/KG 1
EPA353.2 Prep Date: 6/22/2018
0.1 MG/KG 1
SW9045 Prep Date: 6/18/2018
0.1 pH 1
7/14/201812:06
PrepBy:SDW
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
PrepBy: NCC
7/18/2018 22:05
7/18/2018 22:05
PrepBy: KJM
7/13/2018 11 :43
PrepBy: HMA
6/23/2018 09:24
PrepBy: AEJ
6/18/2018
ALS •• Fort Collins
LIMS Version: 6 867 AR Page lliJtof&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT64
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 23
Gamma Spectroscopy Results
Ra-226 1570 (+/-180)
Ra-228 1710 (+/. 200)
ICPMS Metals
SILVER 3.9
ALUMINUM 6200
ARSENIC 5.5
BARIUM 540
BERYLLIUM 0.65
CALCIUM 3700
CADMIUM 0.6
COBALT 2.1
CHROMIUM 260
COPPER 34
IRON 7600
POTASSIUM 840
MAGNESIUM 870
MANGANESE 1000
MOLYBDENUM 4.6
SODIUM 13000
NIOBIUM 870
NICKEL 67
LEAD 5400
SELENIUM ND
TIN 100
TANTALUM 180
THORIUM 2200
THALLIUM 0.69
URANIUM 3100
VANADIUM 5.5
ZINC 78
ZIRCONIUM 1700
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 6800
SULFATE 3100
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 83.1
Th-228 1380 (+/-210)
Th-230 1170 (+/. 180)
Th-232 1650 (+/-260)
Report
Qual Limit
EPA350.1
1
SOP 713
M3,G 10
M3,G 20
SW6020
0.049
9.8
0.2
0.49
0.049
98
0.2
0.49
0.98
2
9.8
98
9.8
0.49
0.2
98
9.8
2
20
0.98
0.98
0.98
2
0.0098
0.98
0.49
9.8
4.9
SW1010
96
EPA300.0
20
99
99
SOP 714
30-110
M3 10
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-10
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 71712018 PrepBy: HMA
MG/KG 1 717/2018 13:48
Prep Date: 61181201 B PrepBy: NMP
pCi/g NA 7/9/2018 08:22
pCi/g NA 7/9/2018 08:22
Prep Date: 7116/2018 PrepBy: JML
MG/KG 10 7/21/201817:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/201819:50
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/201817:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/201817:52
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/201817:52
MG/KG 10 7/21/201817:52
MG/KG 10 7/21/201817:52
MG/KG 1000 7/27/2018 11 :56
MG/KG 10 7/21/201817:52
MG/KG 1000 7/22/2018 20:29
MG/KG 10 7/21/201819:50
MG/KG 10 7/21/2018 17:52
MG/KG 100 7/2712016 11 :34
MG/KG 1000 7/2212018 20:29
MG/KG 10 7/21/201817:52
MG/KG 1000 7122/2018 20:29
MG/KG 10 7/21/2018 17:52
MG/KG 10 7/21/201817:52
MG/KG 1000 7127/201811:56
Prep Date: 711212018 PrepBy: JMD
deg C 1 7/12/2016
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 10 6/19/2016 09:02
MG/KG 100 6/3012016 14:39
MG/KG 10 6/1912018 09:02
Prep Date: 71212018 PrepBy:SDW
%REC DL=NA 7/141201812:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/201812:06
pCi/g NA 7/14/2018 12:06
AR Page 1 Jito(OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT64
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 79.2
1340 (+/-220) U-234
U-235
U-238
Lead-210 by Liquid Scintllatlon
Pb-210
Carr: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
68 (+/-14)
1550 (+/. 250)
1160 (+/-2801
91.1
0.88
ND
3.01
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-10
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL=NA
M3 0 pCi/g NA
M3 2 pCi/g NA
M3 0 pCi/g NA
SOP 704 Prep Date: 7/17/2018
M3 0 pCi/g NA
40-110 %REC DL=NA
SW7471 Prep Date: 7/12/2018
0.03 MG/KG 1
EPA353.2 Prep Date: 6/22/2018
1 MG/KG 10
SW9045 Prep Date: 6/18/2018
0.1 pH 1
PrepBy:sow
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
7/1612018 07:28
PrepBy: NCC
7/18/2018 23:40
7/18/2018 23:40
PrepBy: KJM
7/13/201811:45
PrepBy: HMA
6/23/2018 10:55
PrepBy:AEJ
6/18/2018
ALS -Fort Collins
LIMS Version: 6.867 AR Page 2i'oro(OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT69
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
Ammonia as N
AMMONIAASN 78
Gamma Spectroscopy Results
Ra-226 1550 (+/-180)
Ra-228 1480 (+/. 170)
ICPMS Metals
SILVER 2.5
ALUMINUM 3900
ARSENIC 2.5
BARIUM 460
BERYLLIUM 0.41
CALCIUM 2800
CADMIUM 0.38
COBALT 5.9
CHROMIUM 33
COPPER 11
IRON 4900
POTASSIUM 1000
MAGNESIUM 520
MANGANESE 740
MOLYBDENUM 1.8
SODIUM 1600
NIOBIUM 780
NICKEL 18
LEAD 5100
SELENIUM ND
TIN 110
TANTALUM 120
THORIUM 3500
THALLIUM 0.83
URANIUM 3100
VANADIUM 2.2
ZINC 75
ZIRCONIUM 2500
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE 4.2
FLUORIDE 3100
SULFATE 2400
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 85.9
Th-228 1280 (+/-200)
Th-230 1000 (+/. 160)
Th-232 1510 (+/. 230)
Report
Qual Limit
EPA350.1
9.8
SOP 713
M3,G 10
M3,G 20
SW6020
0.05
10
0.2
0.5
0.05
100
0.2
0.5
2
10
100
10
0.5
0.2
100
10
2
20
1
1
1
2
0.01
1
0.5
10
5
SW1010
96
EPA300.0
1.9
97
97
SOP 714
30-110
M3 10
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 2 7-Jul-18
VVorkOrder: 1806204
Lab ID: 1806204-11
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy:HMA
MG/KG 10 7/7/201813:50
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 7/9/2018 08:22
pCi/g NA 7/9/2018 08:22
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/2018 19:56
MG/KG 10 7/21/2018 17:55
MG/KG 10 7121/201817:55
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/2018 17:55
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/201817:55
MG/KG 10 7121/201817:55
MG/KG 1000 7/27/201811 :58
MG/KG 10 7/211201817:55
MG/KG 1000 7/22/2018 20:32
MG/KG 10 7/21/201819:56
MG/KG 10 7/21/201817:55
MG/KG 100 7/27/2018 11 :35
MG/KG 1000 7/22/2018 20:32
MG/KG 10 7/21/2018 17:55
MG/KG 1000 7/22/2018 20:32
MG/KG 10 7/21/201817:55
MG/KG 10 7/21/2018 17:55
MG/KG 1000 7/27/201811:58
Prep Date: 7/12/2018 PrepBy: JMD
degC 1 7/12/2018
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 6/19/2018 09:32
MG/KG 100 6/30/2018 15:28
MG/KG 10 6/19/2018 09:47
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7114/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/201812:06
pCl/g NA 7/14/201812:06
AR Page 2litofOO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT69
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 79.6
U-234 1280 (+/-210)
U-235 64 (+/-13)
U-238 1380 (+/-230)
Lead-21 O by Liquid Scintilation
Pb-210 1110 (+/-270)
Carr: LEAD 90.5
Mercury
MERCURY 0.04
Nitrate/Nitrite as N
NITRATE/NITRITE AS N 0.18
pH
PH 3.2
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-11
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SOP 714 Prep Date: 7/2/2018
30-110 %REC DL = NA
M3 0 pCi/g NA
M3
M3
M3
SOP 704
1 pCi/g
0 pCi/g
0 pCi/g
NA
NA
Prep Date 7/17/2018
NA
40-110 %REC DL= NA
SW7471 Prep Date: 7/12/2018
0.03 MG/KG 1
EPA353.2 Prep Date: 6/22/2018
0.1 MG/KG 1
SW9045 Prep Date: 6/18/2018
0.1 pH 1
PrepBy: SDW
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
PrepBy: NCC
7/19/2018 00:28
7/19/2018 00:28
PrepBy: KJM
7/13/2018 11 :47
PrepBy: HMA
6/23/2018 09:25
PrepBy: AEJ
6/18/2018
ALS •• Fort Collins
LIMS Version: 6.867 AR Page 2%2,tof&'O
ALS --Fort Collins
Client: Neo Performance Materials Sil met 00
Project: NEO Silmet
Sample ID: LOT 76
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
Ammonia as N
AMMONIA AS N 29
Gamma Spectroscopy Results
Ra-226 1360 (+/-160)
Ra-228 2290 (+/-270)
ICPMS Metals
SILVER 2
ALUMINUM 2300
ARSENIC 0.91
BARIUM 490
BERYLLIUM 0.49
CALCIUM 1500
CADMIUM ND
COBALT ND
CHROMIUM 42
COPPER 2.5
IRON 4100
POTASSIUM 820
MAGNESIUM 86
MANGANESE 800
MOLYBDENUM 1.7
SODIUM 350
NIOBIUM 390
NICKEL 28
LEAD 5400
SELENIUM ND
TIN 70
TANTALUM 32
THORIUM 6000
THALLIUM 0.8
URANIUM 3500
VANADIUM 3
ZINC 82
ZIRCONIUM 1000
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 2300
SULFATE 570
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 88.6
Th-228 1790 (+/· 280)
Th-230 1300 (+/-200)
Th-232 2180 (+/-330)
Report
Qual Limit
EPA350.1
0.98
SOP 713
M3,G 10
M3,G 20
SW6020
0.049
9.7
0.19
0.49
0.049
97
0.19
0.49
0.97
1.9
9.7
97
9.7
0.49
0.19
97
9.7
1.9
19
0.97
0.97
0.97
1.9
0.0097
0.97
0.49
9.7
4.9
SW1010
96
EPA300.0
2
99
9.9
SOP 714
30-110
M3 10
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-!8
Work Order: 1806204
Lab ID: 1806204-12
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy: HMA
MG/KG 1 7/7/2018 13:51
Prep Date: 6/18/2018 PrepBy:NMP
pCi/g NA 71912018 08:22
pCi/g NA 719/2018 08:22
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/21/2018 17:58
MG/KG 10 7121/2018 17:58
MG/KG 10 7/21/2018 20:02
MG/KG 10 7/21/2018 17:58
MG/KG 10 7/21/201817:58
MG/KG 10 7/21/2018 17:58
MG/KG 10 7/21/201817:58
MG/KG 10 7/21/2018 17:58
MG/KG 10 7121/2018 17:58
MG/KG 10 7/21/201817:58
MG/KG 10 7121/201817:58
MG/KG 10 7/21/2018 17:58
MG/KG 10 7/21/201817:58
MG/KG 10 7/21/201817:58
MG/KG 10 7/21/201817:58
MG/KG 10 7/21/201817:58
MG/KG 1000 7/27/201811:59
MG/KG 10 7/21/2018 17:58
MG/KG 1000 7/22/2018 20:35
MG/KG 10 7/21/2018 20:02
MG/KG 10 7/21/201817:58
MG/KG 100 7/27/2018 11 :36
MG/KG 1000 7/2212018 20:35
MG/KG 10 7/21/2018 17:58
MG/KG 1000 7/22/2018 20:35
MG/KG 10 7/21/2018 17:58
MG/KG 10 7/21/2018 17:58
MG/KG 1000 7/27/2018 11 :59
Prep Date: 7/12/2018 PrepBy: JMD
deg C 1 7/12/2018
Prep Date: 6/18/2018 PrepBy:HMA
MG/KG 1 6/19/2018 10:02
MG/KG 100 6/30/2018 15:44
MG/KG 1 6/19/2018 10:02
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/14/201812:06
pCilg NA 711412018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
AR Page 2JQ10(&°0
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT76
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 79.6
1380 (+/-230) U-234
U-235
U-238
Lead-210 by Liquid Scintilation
Pb-210
Carr: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
71 (+/-15)
1610 (+/-260)
960 C+I-230)
96.3
0.077
ND
3.76
Report
Qual Limit
SOP 714
30-110
M3 0
M3 1
M3 0
SOP 704
M3 0
40-110
SW7471
0.032
EPA353.2
0.098
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-12
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/16/2018 07:28
pCi/g NA 7/16/2018 07:28
pCi/g NA 7/16/2018 07:28
pCi/g NA 7/16/2018 07:28
Prep Date: 7/17/2018 PrepBy: NCC
pCilg NA 7/19/2018 01 :16
%REC DL=NA 7/19/2018 01 :16
Prep Date: 7/12/2018 PrepBy: KJM
MG/KG 1 7/13/201811:49
Prep Date: 6/22/2018 PrepBy: HMA
MG/KG 6/23/2018 09:26
Prep Date: 6/18/2018 PrepBy: AEJ
pH 1 6/18/2018
AR Page 231-tO(OO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT84
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 16
Gamma Spectroscopy Results
Ra-226 1530 (+/-180)
Ra-228 1970 (+/-230)
ICPMS Metals
SILVER 1.4
ALUMINUM 1700
ARSENIC 0.39
BARIUM 420
BERYLLIUM 0.31
CALCIUM 980
CADMIUM ND
COBALT ND
CHROMIUM 25
COPPER ND
IRON 2700
POTASSIUM 690
MAGNESIUM 170
MANGANESE 480
MOLYBDENUM 1.2
SODIUM 310
NIOBIUM 260
NICKEL 13
LEAD 4700
SELENIUM ND
TIN 72
TANTALUM 16
THORIUM 9200
THALLIUM 0.57
URANIUM 2800
VANADIUM 2.3
ZINC 51
ZIRCONIUM 1000
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 1600
SULFATE 1100
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 81.8
Th-228 1620 (+/-250)
Th-230 1110 (+/-170)
Th-232 1930 (+/-300)
Report
Qual Limit
EPA350.1
0.99
SOP 713
M3,G 10
M3,G 20
SW6020
0.046
9.2
0.18
0.46
0.046
92
0.18
0.46
0.92
1.8
9.2
92
9.2
0.46
0.18
92
9.2
1.8
18
0.92
0.92
0.92
1.8
0.0092
0.92
0.46
9.2
4.6
SW1010
96
EPA300.0
20
49
99
SOP 714
30-110
M3 0
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-13
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy: HMA
MG/KG 7(7/201813:52
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 7/9/2018 08:22
pCi/g NA 7/9/2018 08:22
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/211201818:01
MG/KG 10 7121/2018 18:01
MG/KG 10 7/21/2018 20:08
MG/KG 10 7/21/201818:01
MG/KG 10 7/21/201818:01
MG/KG 10 7/211201818:01
MG/KG 10 7/2112018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/2018 18:01
MG/KG 10 7/21/201818:01
MG/KG 10 7/21/201818:01
MG/KG 1000 712712018 12:00
MG/KG 10 7/21/201818:01
MG/KG 1000 7/22/2018 20:38
MG/KG 10 7/21/2018 20:08
MG/KG 10 7/21/201818:01
MG/KG 100 7/27/201811 :38
MG/KG 1000 7/22/2018 20:36
MG/KG 10 7/21/2018 16:01
MG/KG 1000 7/22/2018 20:36
MGIKG 10 7/21/201818:01
MG/KG 10 7/21/201818:01
MG/KG 1000 7/271201812:00
Prep Date: 7/12/2018 PrepBy:JMD
deg C 1 7/12/2018
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 10 6/19/201810:17
MG/KG 50 6/30/2018 16:00
MG/KG 10 6/19/2018 10:17
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/1412018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/201812:06
pCi/g NA 7/14/2018 12:06
AR Page 23lto(&'O
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT 84
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 85.4
U-234
U-235
U-238
Lead-210 by Liquid Scintilation
Pb-210
Carr: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
1100 (+/-180)
64 (+/-13)
1260 (+/. 210)
930 (+/. 220)
93.3
0.035
ND
3.78
Report
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
Work Order: 1806204
Lab ID: 1806204-13
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SOP 714
30-110
M3 0
M3 1
M3 0
SOP 704
Prep Date: 7/2/2018
%REC DL=NA
pCifg NA
pCi/g NA
pCilg NA
Prep Date: 7/17/2018
PrepBy: SDW
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
7/16/2018 07:28
M3 0 pCilg NA
PrepBy: NCC
7/19/2018 02:03
7/19/2018 02:03 40-110
SW7471
0.031
EPA353.2
0.098
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6,867
%REC DL=NA
Prep Date: 7/12/2018
MG/KG 1
Prep Date: 6/22/2018
MG/KG
Prep Date: 6/18/2018
pH 1
PrepBy: KJM
7/13/201811 :51
PrepBy:HMA
6/23/2018 09:26
PrepBy:AEJ
6/18/2018
AR Page 2iltofOO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet OU
NEOSilmet
Sample ID: LOT85
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIAASN 46
Gamma Spectroscopy Results
Ra-226 1830 (+/-210)
Ra-228 1610 (+/-190)
ICPMS Metals
SILVER 2.3
ALUMINUM 2200
ARSENIC 11
BARIUM 320
BERYLLIUM 0.5
CALCIUM 2000
CADMIUM 0.21
COBALT 1.8
CHROMIUM 45
COPPER 6.7
IRON 7800
POTASSIUM 140
MAGNESIUM 550
MANGANESE 4400
MOLYBDENUM 2.6
SODIUM 1100
NIOBIUM 470
NICKEL 13
LEAD 3900
SELENIUM ND
TIN 96
TANTALUM 49
THORIUM 3700
THALLIUM 0.27
URANIUM 2700
VANADIUM 4.6
ZINC 130
ZIRCONIUM 1500
lgnltablllty
IGNIT ABILITY
Ion Chromatography
CHLORIDE ND
FLUORIDE 2800
SULFATE 2800
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 86.6
Th-228 1080 (+/-170)
Th-230 1170 (+/-180)
Th-232 1310 (+/-200)
Report
Qual Limit
EPA350.1
0.99
SOP 713
M3,G 10
M3,G 10
SW6020
0.05
9.9
0.2
0.5
0.05
99
0.2
0.5
0.99
2
9.9
99
9.9
50
0.2
99
9.9
2
20
0.99
0.99
0.99
2
0.0099
0.99
0.5
9.9
5
SW1010
96
EPA300.0
19
48
480
SOP 714
30-110
M3 0
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-14
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy: HMA
MG/KG 7n/2018 13:52
Prep Date: 6/18/2018 PrepBy: NMP
pCi/g NA 7/9/2018 08:22
pCi/g NA 7/9/2018 08:22
Prep Date: 7/16/2018 PrepBy: JML
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 20:14
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/201818:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/201818:04
MG/KG 1000 7/22/2018 20:41
MG/KG 10 7/21/2018 18:04
MG/KG 10 7/21/2018 18:04
MG/KG 1000 7/27/201812:02
MG/KG 10 7/21/201818:04
MG/KG 1000 7/22/2018 20:41
MG/KG 10 7/21/2018 20:14
MG/KG 10 7/21/2018 18:04
MG/KG 100 7/27/2018 11 :39
MG/KG 1000 7/22/2018 20:41
MG/KG 10 7/21/201818:04
MG/KG 1000 7/22/2018 20:41
MG/KG 10 7/211201818:04
MG/KG 10 7/21/2018 18:04
MG/KG 1000 7/27/2018 12:02
Prep Date: 7/12/2018 PrepBy:JMD
deg C 1 7/12/2018
Prep Date: 6/18/2018 PrepBy: HMA
MG/KG 10 6/19/201810:31
MG/KG 50 6/19/201811:16
MG/KG 50 6/19/201811:16
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/14/201812:06
pCi/g NA 7/14/201812:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
AR Page 2~4,rofOO
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT 85
Legal Location:
Collection Date: 4/ I 0/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232
U-234
U-235
U-238
Lead-210 by Liquid Scintilation
Pb-210
Carr: LEAD
Mercury
MERCURY
Nitrate/Nitrite as N
NITRATE/NITRITE AS N
pH
PH
74.9
1290 (+/· 210)
63 (+/-13)
1440 (+/. 240)
1000 (+/. 240)
96
0.3
ND
3.31
Report
Qual Limit
SOP 714
30-110
M3 0
M3 1
M3 0
SOP 704
M3 0
40-110
SW7471
0.033
EPA353.2
0.098
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6.867
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-14
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/212018 PrepBy:sow
%REC DL=NA 7/1612018 07:28
pCi/g NA 7/16/2018 07:28
pCi/g NA 711612018 07:28
pCi/g NA 7/1612018 07:28
Prep Date: 7117/2018 PrepBy:NCC
pCl/g NA 7/19/2018 02:51
%REC DL= NA 7/19/2018 02:51
Prep Date: 7112/2018 PrepBy: KJM
MG/KG 1 7/13/201811:54
Prep Date: 6122/2018 PrepBy: HMA
MG/KG 1 6/23/2018 09:27
Prep Date: 6/18/2018 PrepBy:AEJ
pH 1 6/18/2018
AR Page 2iS10(00
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEOSilmet
Sample ID: LOT86
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Ammonia as N
AMMONIA AS N 190
Gamma Spectroscopy Results
Ra-226 1820 (+/-210)
Ra-228 1400 (+/-160)
ICPMS Metals
SILVER 5.4
ALUMINUM 4000
ARSENIC 7.4
BARIUM 520
BERYLLIUM 0.47
CALCIUM 2300
CADMIUM 0.56
COBALT 2.7
CHROMIUM 140
COPPER 14
IRON 6300
POTASSIUM 460
MAGNESIUM 560
MANGANESE 1700
MOLYBDENUM 4.8
SODIUM 2900
NIOBIUM 640
NICKEL 48
LEAD 3700
SELENIUM ND
TIN 120
TANTALUM 83
THORIUM 2800
THALLIUM 0.47
URANIUM 2800
VANADIUM 3.9
ZINC 110
ZIRCONIUM 1900
lgnitability
IGNITABILITY
Ion Chromatography
CHLORIDE 5
FLUORIDE 4300
SULFATE 2300
Isotopic Thorium by Alpha Spectroscopy
Tracer: Th-229 83.8
Th-228 1020 (+/-160)
Th-230 1260 (+/. 190)
Th-232 1270 (+/-200)
Report
Qual Limit
EPA350.1
10
SOP 713
M3,G 10
M3,G 10
SW6020
0.046
9.2
0.18
0.46
0.046
92
0.18
0.46
0.92
1.8
9.2
92
9.2
0.46
0.18
92
9.2
1.8
18
0.92
0.92
0.92
1.8
0.0092
0.92
0.46
9.2
4.6
SW1010
96
EPA300.0
1.9
97
97
SOP 714
30-110
M3 0
M3 10
M3 0
ALS --Fort Collins
LIMS Version: 6,867
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
\VorkOrder: 1806204
Lab ID: 1806204-15
Matrix: SOLID
Percent Moisture:
Dilution
Units Factor Date Analyzed
Prep Date: 7/7/2018 PrepBy:HMA
MG/KG 10 717/2018 13:55
Prep Date: 6/18/2018 PrepBy:NMP
pCi/g NA 7/9/2018 08:22
pCi/g NA 7/9/2018 08:22
Prep Date: 7/16/2018 PrepBy:JML
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/201 B 20:20
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/201 B 18:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/2018 18:06
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/2018 18:06
MG/KG 1000 7/27/2018 12:11
MG/KG 10 7/21/2018 18:06
MG/KG 1000 7/22/2018 20:44
MG/KG 10 7/21/2018 20:20
MG/KG 10 7/21/201818:06
MG/KG 100 7/27/2018 11 :40
MG/KG 1000 7/22/2018 20:44
MG/KG 10 7/21/2018 18:06
MG/KG 1000 7/22/2018 20:44
MG/KG 10 7/21/201818:06
MG/KG 10 7/21/201818:06
MG/KG 1000 7/27/201812:11
Prep Date: 7/12/2018 PrepBy:JMD
degC 1 7/12/2018
Prep Date: 6/18/2018 PrepBy:HMA
MG/KG 1 6/19/201811:31
MG/KG 100 6/30/2018 16:15
MG/KG 10 6/19/2018 11 :46
Prep Date: 7/2/2018 PrepBy:SDW
%REC DL=NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
pCi/g NA 7/14/2018 12:06
AR Page 2~iro{&70
ALS --Fort Collins
Client:
Project:
Neo Performance Materials Silmet 00
NEO Silmet
Sample ID: LOT86
Legal Location:
Collection Date: 4/10/2018
Analyses Result
Isotopic Uranium by Alpha Spectroscopy
Tracer: U-232 77.9
U-234 1210 (+/-200)
U-235 62 (+/-13)
U-238 1320 (+/-220)
Lead-210 by Liquid Scintilation
Pb-210 930 (+/-220)
Carr: LEAD 93.B
Mercury
MERCURY 0.13
Nitrate/Nitrite as N
NITRATE/NITRITE AS N ND
pH
PH 3.22
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-15
Matrix: SOLID
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SOP 714
30-110
M3 0
M3 2
M3 0
SOP 704
M3 0
40-110
SW7471
0.032
EPA353.2
0.099
SW9045
0.1
ALS --Fort Collins
LIMS Version: 6,867
Prep Date: 71212018
%REC DL= NA
pCi/g NA
pCi/g NA
pCi/g NA
Prep Date: 711712018
pCi/g NA
%REC DL=NA
Prep Date: 711212018
MG/KG 1
Prep Date: 612212018
MG/KG 1
Prep Date: 6118/2018
pH 1
PrepBy:SDW
7/16/2018 07:29
7/16/2016 07:29
7/16/2016 07:29
7/16/2016 07:29
PrepBy: NCC
7/19/2018 03:39
7/19/201 B 03:39
PrepBy: KJM
7/13/201811:56
PrepBy: HMA
6/23/201 B 09:28
PrepBy:AEJ
6/18/2018
AR Page 3a'o-io(00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEOSi\met
LOT20
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
0.018
0.059
0.39
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
Work Order: 1806204
Lab ID: 1806204-16
Matrix: LEA CHA TE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6. 867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/201813:48
7/12/2018 13:48
7/12/2018 13:48
7/12/201813:48
7/12/201813:48
7/12/2018 13:48
7/12/2018 13:48
PrepBy: KJM
7/13/2018 09:43
AR Page 31Sto(OO
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT21
Collection Date: 4/ I 0/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
0.011
ND
0.0054
0.02
0.4
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-17
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12(2018 14:09
7/12(2018 14:09
7/12/201814:09
7/12/201814:09
7/12/201814:09
7/12(2018 14:09
7/12(201814:09
PrepBy: KJM
7/13/2018 09:45
AR Page 33'Ato{00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEOSilmet
LOT22
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
0.0096
O.D15
0.39
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-18
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1 ,
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/2018 14:12
7/12/2018 14:12
7/12/2018 14:12
7/12/201814:12
7/12/201814:12
7/12/201814:12
7/12/201814:12
PrepBy: KJM
7/13/2018 09:47
AR Page 3~Qf0(00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT31
Collection Date: 4/ I 0/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
0.013
ND
0.085
0.14
0.52
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
\VorkOrder: 1806204
Lab ID: 1806204-19
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MGIL
MGIL
MGIL
MGIL
MGIL
MGIL
MGIL
Prep Date: 7/11/2018
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
71121201814:15
7112/201814:15
7/12/201814:15
7112/201814:15
711212018 14:15
7112/2018 14:15
7112/2018 14:15
PrepBy: KJM
7/1312016 09:49
AR Page 34,l,rof&'O
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEOSilmet
LOT32
Collection Date: 4/ l 0/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
0.0085
0.16
0.56
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
Work Order: 1806204
Lab ID: 1806204-20
Matrix: LEA CHA TE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/201814:18
7/12/201814:18
7/12/201814:18
7/12/201814:18
7/12/201814:18
7/12/2018 14:18
7/12/201614:18
PrepBy: KJM
7/13/2018 09:51
AR Page 3~ltof6"0
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEOSilmet
LOT34
Collection Date: 4/10/20 IS
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
0.012
ND
0.0064
1.2
0.89
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: I S06204
Lab ID: I S06204-2 I
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.05
SW7470
0.002
ALS •• Fort Collins
LIMS Version: 8.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
1
5
Prep Date: 7/1212018
1
PrepBy: AJL2
7/12/2018 14:21
7/12/2018 14:21
7/12/2018 14:21
7/12/2018 14:21
7/12/201814:21
7/12/201814:21
7/12/2018 15:01
PrepBy: KJM
7/13/2018 09:54
AR Page 31Jlto(6'0
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Sil met 00
NEO Silmet
LOT35
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
0.014
ND
0.0057
0.75
0.64
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-22
Matrix: LEA CHA TE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.05
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
5
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/2018 14:24
7/12/2018 14:24
7/12/2018 14:24
7/12/2018 14:24
7/12/2018 14:24
7/12/2018 14:24
7/12/201815:10
PrepBy: KJM
7/13/201 B 09:56
AR Page 3f,10fOO
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT 58
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.095
1.1
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
\VorkOrder: 1806204
Lab ID: 1806204-23
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.05
SW7470
0.002
ALS •• Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
5
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/2018 14:33
7/12/2018 14:33
7/12/2018 14:33
7/12/2018 14:33
7/12/2018 14:33
7/12/2018 14:33
7/12/2018 15:13
PrepBy: KJM
7/13/2018 10:02
AR Page 3fJStof00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT60
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.044
1.1
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-!8
Work Order: 1806204
Lab ID: 1806204-24
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS •• Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/201814:36
7/12/201814:36
7/12/201814:36
7/12/201814:36
7/12/201814:36
7/12/2018 14:36
7/12/201814:36
PrepBy: KJM
7/13/2018 10:04
AR Page 34610{00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT64
Collection Date: 4/ I 0/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.55
1.3
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-25
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 711112018
1
1
1
1
Prep Date: 711212018
PrepBy: AJL2
7/12/2018 14:39
7/12/2018 14:39
7/12/2018 14:39
7/12/2018 14:39
7/12/2018 14:39
7/12/2018 14:39
7/12/2018 14:39
PrepBy: KJM
7/13/201810:06
AR Page 41J7,tof&70
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT69
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.033
0.73
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
Work Order: 1806204
Lab ID: 1806204-26
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
1
1
Prep Date: 7/12/2018
PrepBy: AJL2
7/12/201814:42
7/12/201814:42
7/12/2018 14:42
7/12/201814:42
7/12/2018 14:42
7/12/2018 14:42
7/12/201814:42
PrepBy: KJM
7/13/201810:09
AR Page 44SJO{&'O
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEOSilmet
LOT76
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.11
4.3
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-/8
\VorkOrder: 1806204
Lab ID: 1806204-27
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6,667
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/2018 14:45
7/12/201814:45
7/12/2018 14:45
7/12/201814:45
7/12/2018 14:45
7/12/2018 14:45
7/12/2018 14:45
PrepBy: KJM
7/13/201810:11
AR Page 4f ~f0f&'0
ALS --Fort Collins
Client: Neo Performance Materials Silmet 00
Project: NEO Silmet
Sample ID: LOT 84
Legal Location:
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.063
1.7
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Juf-18
Work Order: 1806204
Lab ID: 1806204-28
Matrix: LEA CHA TE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018 ,
1
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/201814:48
7/12/2018 14:48
7/12/2018 14:48
7/12/201814:48
7/12/2018 14:48
7/12/201814:48
7/12/2018 14:48
PrepBy: KJM
7/13/201810:13
AR Page 4jQto(OO
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT85
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.038
1.7
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Jul-18
VVorkOrder: 1806204
Lab ID: 1806204-29
Matrix: LEA CHA TE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.B67
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
Prep Date: 7/12/2018
PrepBy: AJL2
7/12/2018 14:52
7/12/2018 14:52
7/12/2018 14:52
7/12/2018 14:52
7/12/201814:52
7/12/201814:52
7/12/2018 14:52
PrepBy: KJM
7/13/201810:15
AR Page 4S1to{00
ALS --Fort Collins
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silrnet 00
NEO Silmet
LOT 86
Collection Date: 4/10/2018
Analyses
TCLP ICP Metals
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
TCLP Mercury
MERCURY
Result
ND
ND
ND
0.58
1.2
ND
ND
ND
Report
SAMPLE SUMMARY REPORT
Date: 27-Ju/-18
\\forkOrder: 1806204
Lab ID: I 806204-30
Matrix: LEACHATE
Percent Moisture:
Qual Limit Units
Dilution
Factor Date Analyzed
SW6010
0.01
0.1
0.005
0.01
0.004
0.006
0.01
SW7470
0.002
ALS --Fort Collins
LIMS Version: 6.867
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
Prep Date: 7/11/2018
1
1
1
Prep Date: 7/12/2018
1
PrepBy: AJL2
7/12/2018 14:55
7/12/2018 14:55
7/12/201814:55
7/12/201814:55
7/12/201814:55
7/12/201814:55
7/12/2018 14:55
PrepBy: KJM
7/13/201810:17
AR Page 4Sitol&'O
ALS --Fort Collins SAMPLE SUMMARY REPORT
Client:
Project:
Sample ID:
Legal Location:
Neo Performance Materials Silmet 00
NEO Silmet
LOT86
Collection Date: 4/10/2018
Date: 27-Jul-/8
\VorkOrder: 1806204
Lab ID: 1806204-30
Matrix: LEA CHA TE
Percent Moisture:
Analyses Result
Explanation of Qualifiers
Radiochemistry:
-"Report Limit" is the MDC
U or ND -Result is less than the sample specific MDC.
Y1 -Chemical Yield is in control at 100-110%. Quantitative yield is assumed.
Y2 -Chemical Yield outside default limits,
W -DER is greater than Warning Limit of 1.42
• -Aliquot Basis is 'As Received' while the Report Basis is 'Dry Weight',
# -Aliquot Basis is 'Dry Weight' while the Report Basis is 'As Received'.
G -Sample density differs by more than 15% of LCS density.
Qual
Report
Limit Units
Dilution
Factor
M3 -The requested MDC was not met, but the reported
activity is greater than the reported MDC.
L -LCS Recovery below lower control limit.
H -LCS Recovery above upper control limit.
P -LCS, Matrix Spike Recovery within control limits.
N -Matrix Spike Recovery outside control limits
NC -Not Calculated for duplicate results less than 5 times MDC
B -Analyte concentration greater than MDC.
Date Analyzed
D -DER is greater than Control Limit
M -Requested MDC not met.
B3 -Analyte concentration greater than MDC but less than Requested
MDC.
LT -Result Is less than requested MDC but greater than achieved MDC.
lnorganlcs:
B -Result is less than the requested reporting limit but greater than the instrument method detection limit (MDL),
U or ND -Indicates that the compound was analyzed for but not detected.
E -The reported value is estimated because of the presence of interference An explanatory note may be included in the narrative.
M -Duplicate injection precision was not met.
N -Spiked sample recovery not within control limits. A post spike is analyzed for all ICP analyses when the matrix spike and or spike
duplicate fail and the native sample concentration is less than four times the spike added concentration.
Z -Spiked recovery not within control limits. An explanatory note may be included in the narratiw.
• -Duplicate analysis (relative percent difference) not within control limits.
S -SAR value is estimated as one or more analytes used in the calculation were not detected above the detection limit.
Organics:
U or ND -Indicates that the compound was analyzed for but not detected.
B -Analyte is detected in the associated method blank as well as in the sample. It indicates probable blank contamination and warns the data useL
E -Analyte concentration exceeds the upper level of the calibration range.
J -Estimated value. The result is less than the reporting limit but greater than the instrument method detection limit (MDL).
A -A tentatively identified compound is a suspected aldol-condensation product.
X -The analyte was diluted below an accurate quantitation level.
• -The spike recovery is equal to or outside the control criteria used.
+ -The relative percent difference (RPO) equals or exceeds the control criteria.
G -A pattern resembling gasoline was detected in this sample.
D -A pattern resembling diesel was detected in this sample.
M -A pattern resembling motor oil was detected in this sample.
C -A pattern resembling crude oil was detected In this sample.
4 -A pattern resembling JP-4 was detected in this sample.
5 -A pattern resembling JP-5 was detected in this sample.
H -Indicates that the fuel pattern was in the heavier end of the retention time window for the analyte of interest.
L -Indicates that the fuel pattern was in the lighter end of the retention time window for the analyte of interest.
Z -This flag indicates that a significant fraction of the reported result did not resemble the patterns of any of the following petroleum hydrocarbon products:
-gasoline
-JP-8
-diesel
-mineral spirits
-motor oil
-Stoddard solwnt
-bunker C
ALS --Fort Collins
LIMS Version: 6,867 AR Page 4Slro{&'O
ALS --Fort Collins
Client:
Work Order:
Project:
Neo Performance Materials Sifmet 00
1806204
NEO Silmet
Date: 7/27/2018 4:36:
QC BATCH REPORT
Batch ID: AS180702-7-1 Instrument ID AlphaSpec2 Method: Isotopic Uranium by Alpha Spec
DUP Sample ID: 1806204-15 Units: pCi/g
Client ID: LOT 86 Run ID: AS180702-7UR
SPK Ref
Analyte Result ReportLimit SPKVal Value %REC
U-234 1430 (+/-240) 0
U-235 75 (+/-16)
U-238 1630 (+/-270) 0
Tracer: U-232 160 3 227.7 70.1
LCS Sample ID: AS180702-7 Units: pCilg
Client ID: Run ID: AS180702-7UR
SPK Ref
Analyte Result ReportLimit SPK Val Value %REC
U-234 2.17 (+/-038) 0.01 2.11 103
U-238 2.29 (+/-0.4) 0.01 2.191 105
Tracer: U-232 194 0.03 2.323 83.3
MB Sample ID: AS180702-7 Units: pCi/g
Client ID: Run ID: AS180702-7UR
SPK Ref
Analyte Result ReportLimit SPK Val Value %REC
U-234 0.015 (+/-0.013) 0.013
U-235 ND 0.007
U-238 ND 0.0127
Tracer: U-232 1.86 0.02 2.323 80.1
The following samples were analyzed in this batch: 1806204-1 1806204-2
1806204-4 1806204-5
1806204-7 1806204-8
1806204-10 1806204-11
1806204-13 1806204-14
ALS --Fort Collins
LIMS Version: 6.867
Analysis Date: 7/16/2018 07:29
Prep Date: 71212018 DF: NA
Control Decision DER DER
Limit Le1.el Ref DER Limit Qual
1210 0.7 2.1 M3
62 0.7 2.1 M3
1320 0.9 2.1 M3
30-110 177
Analysis Date: 7/16/2018 07:29
Prep Date: 7/2/2018 OF: NA
Control Decision DER DER
Limit Lewi Ref DER Limit Qual
82-122 p
82-122 p
30-110
Analysis Date: 7/16/2018 07:29
Prep Date: 7/2/2018 OF: NA
Control Decision DER DER
Limit Le1oel Ref DER Limit Qual
B3
u
u
30-110
1806204-3
1806204-6
1806204-9
1806204-12
1806204-15
QC Page: 1 of 16
54 of70
Client:
Work Order:
Neo Performance Materials Silmet 00
1806204
QC BATCH REPORT
Project: NEOSilmet
Batch ID: AS180702-8-1
DUP Sample ID: 1806204-15
Client ID: LOT 86
Analyte
Th-22B
Th-230
Th-232
Tracer: Th-229
LCS
Client ID:
Analyte
Th-230
Sample ID: AS180702-8
Tracer: Th-229
MB
Client ID:
Analyte
Th-228
Th-230
Th-232
Sample ID: AS180702-8
Tracer: Th-229
Instrument ID AlphaSpec2 Method: Isotopic Thorium by Alpha Spec
Units: pCi/g
Run ID: AS180702-8TH
SPK Ref Control
Result Reportlimit SPK Val Value %REC Limit
1120 (+/-220)
1300 (+/-250)
1390 (+1-260)
49.2
40
20
10
1.6
Run ID: AS180702-8TH
451 .2
Result Reportlimit SPK Val
2 52 (+/-0.4) 0.03 2.464
1.84 0.01 2.301
Run ID: AS180702-8TH
10.9 30-110
Units: pCilg
SPK Ref Control
Value %REC Limit
102 85-121
79.9 30-110
Units: pCi/g
SPK Ref Control
Result Reportlimit SPK Val Value %REC Limit
ND 0.026
ND 0.034
ND 0.0079
178 0.01 2.301 77.3 30-110
Analysis Date: 7/14/2018 12:07
Prep Date: 7/2/2018 DF: NA
Decision DER DER
Level Ref DER Limit Qual
1020 0.4 2.1
1260 0.1 2.1
1270 0.3 2.1
377
Analysis Date: 7/14/2018 12:07
Prep Date: 7/2/2018 DF: NA
Decision DER DER
Y2,M3
Y2,M3
Y2,M3
Y2
Level Ref DER Limit Qual
p
Analysis Date: 7114/201812:07
Prep Date: 7/2/2018 DF: NA
Decision DER DER
Level Ref DER Limit Qual
u
u
u
The following samples were analyzed In this batch: 1806204-1 1806204-2 1806204-3
1806204-4 1806204-5
1806204-7 1806204-8
1806204-10 1806204-11
1806204-13 1806204-14
ALS --Fort Collins
LIMS Version: 6.B67
1806204-6
1806204-9
1806204-12
1806204-15
QC Page: 2 of 16
55 of70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: GS180619-1-1 Instrument ID GAMMA
DUP Sample ID: 1806204-4
Client ID: LOT 31 Run ID: GS180619-1A
Analyte Result Reportlimit SPK Val
Ra-226
Ra-228
LCS
Client ID:
Analyte
Am-241
Co-60
Cs-137
LCS
Client ID:
Sample ID: GS180619-1A
Sample ID: GS180619-1
1020 (+/-120) 10
890 (+/-110) 10
Run ID: GS180619-1A
Result Reportlimit SPK Val
467 (+i-57) 14 469.3
200 (+1-24) 1 197.4
182 (+/-21) 179.4
Run ID: GS180619-1A
QC BATCH REPORT
Method: Gamma Spectroscopy Results
Units: pCi/g Analysis Date: 7/9/2018 08:21
Prep Date: 6/18/2018 DF: NA
SPK Ref Control Decision DER DER
Value %REC Limit Level Ref DER Limit Qual
1020 0.02 2.1 M3,G
950 0.4 2.1 M3,G
Units: pCi/g Analysis Date: 7/9/2018 09:11
Prep Date: 6/18/2018 DF: NA
SPK Ref Control Decision DER DER
Value %REC Limit Level Ref DER Limit Qual
99.5 85-115 p
102 85-115 p
102 85-115 p
Units: pCi/g Analysis Date: 7/9/2018 09:11
Prep Date: 6/18/2018 DF: NA
SPK Ref Control Decision DER DER
Analyte Result Reportlimit SPK Val Value %REC Limit Level Ref DER Limit Qual
Ra-226 454 (+/-53) 3 468.3 96.9 85-115 P,M3
Sample ID: GS180619-1 Units: pCi/g Analysis Date: 7/9/2018 08:23 MB
Client ID: Run ID: GS180619-1A Prep Date: 6/18/2018 DF: NA
Analyte Result
Cs-137 ND
Ra-226 ND
Ra-228 ND
The following samples were analyzed In this batch:
SPK Ref Control Decision DER DER
Reportlimit SPKVal Value %REC Limit Level Ref DER Limit Qual
0.109
0.33
0.4
1806204-1 1806204-2
1806204-4 1806204-5
1806204-7 1806204-8
1806204-10 1806204-11
1806204-13 1806204-14
ALS --Fort Collins
LIMS Version: 6.867
u
u
u
1806204-3
1806204-6
1806204-9
1806204-12
1806204-15
QC Page: 3 of 16
56 of 70
Client:
Work Order:
Project:
Neo Performance Materials Sil met 00
1806204
NEO Silmet
Batch ID: Pb180717-1-1 Instrument ID LIQSCINT
LCS
Client ID:
Sample ID: Pb180717-1
Run ID: PB180717-1A
Analyte Result ReportLimit SPK Val
Carr: LEAD
Pb-210
MB
Client ID:
Sample ID: Pb180717-1
839 3 944.4
22 1 (+/-5 4) 0_5 20.66
Run ID: PB180717-1A
QC BATCH REPORT
Method: Lead-210 by Liquid Scintilatio
Units: ug Analysis Date: 7/19/2018 06:50
Prep Date: 7/17/2018 DF: NA
SPK Ref Control Decision DER DER
Value %REC Limit Lewi Ref DER Limit Qual
88.9 40-110
107 70-130 p
Units: ug Analysis Date: 7/19/2018 06:01
Prep Date: 7/17/2018 DF: NA
SPK Ref Control Decision DER DER
Analyte Result Reportlimil SPK Val Value %REC Limit Lewi Ref DER Limit Qual
Carr: LEAD 8496
Pb-210 ND
The following samples were analyzed in this batch:
1000 84_9 40-110
0.55
1806204-2 1806204-3
1806204-5 1806204-6
1806204-8 1806204-9
1806204-11 1806204-12
1806204-1
1806204-4
1806204-7
1806204-10
1806204-13 1806204-14 1806204-15
ALS --Fort Collins
LIMS Version: 6.867
u
QC Page: 4 of 16
57 of70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: HG180712-1-1 Instrument ID CETAC7500
LCS
Client ID:
Sample ID: HG180712-1
Run ID: HG180713-1A1
QC BATCH REPORT
Method: SW7470
Units: MG/L Analysis Date: 7/13/2018 09:12
Prep Date: 7/12/2018 DF: 1
SPK Ref Control Decision RPD RPD
Analyte Result ReportLimit SPK Val Value %REC Limit Lewi Ref RPD Limit Qual
MERCURY 0 00104 0.0002 0.001 104 60-120 20
MB
Client ID:
Sample ID: HG180712-1 Units: MG/L Analysis Date: 7/13/2018 09:10
Run ID: HG180713-1A1
Analyte Result
MERCURY ND
The following samples were analyzed in this batch:
ReportLimit
0.0002
1606204-16 1606204-17
1806204-19 1806204-20
1806204-22 1806204-23
1606204-25 1806204-26
1606204-28 1806204-29
ALS --Fort Collins
LIMS Version: 6.867
Prep Date: 7/12/2018 DF: 1
Qual
1806204-18
1806204-21
1806204-24
1806204-27
1806204-30
QC Page: 5 of 16
58 of 70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEOSilmet
Batch ID: HG180712-3-1 Instrument ID CETAC7500 Method: SW7471
LCS
Client ID:
Sample ID: HG180712-3 Units: MG/KG
Run ID: HG180713-2A1
QC BATCH REPORT
Analysis Date: 7/13/201811:19
Prep Date: 7/12/2018 DF: 1
SPK Ref Control Decision RPD RPO
Analyte
MERCURY
MB
Client ID:
Analyte
MERCURY
Sample ID: HG180712-3
Result Reportlimit SPK Val Value %REC Limit Le~I Ref RPO Limit Qual
0.18 0.0333 0.167 108 80-120 20
Units: MG/KG Analysis Date: 7/13/2018 11 :17
Run ID: HG180713-2A1 Prep Date: 7/12/2018 DF: 1
Result Reportlimit Qual
ND 0.033
The following samples were analyzed In this batch: 1806204-1
1806204-4
1806204-7
1806204-10
1806204-13
1806204-2
1806204-5
1806204-8
1806204-11
1806204-14
1806204-3
1806204-6
1806204-9
1806204-12
1806204-15
ALS --Fort Collins
LIMS Version: 6.867
QC Page: 6 of 16
59 of70
Client:
Work Order:
Neo Performance Materials Silmet 00
1806204
Project: NEO Silmet
Batch ID: IP180711-11-1
LCS Sample ID: IP180711-11
Client ID:
Analyte
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
MB Sample ID: EX180710-4
Client ID:
Analyte
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
MS Sample ID: 1806204-16
Client ID: LOT 20
Analyte
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
SELENIUM
SILVER
Instrument ID ICP6500 Method: SW6010
Units: MG/L
Run ID: IP180712-1A1
SPK Ref
Result Reportlimit SPK Val Value %REC
0 981 0.01 98
1.02 0.1 , 102
0 0524 0.005 0.05 105
0.204 0.01 0.2 102
0.535 0.004 0.5 107
1.97 0.006 2 98
00983 0.01 0.1 98
Units: MG/L
Run ID: IP180712-1A1
Result Reportlimit
ND 0.01
ND 0.1
ND 0.005
ND 0.01
ND 0.004
ND 0.006
ND 0.01
Units: MG/L
Run ID: IP180712-1A1
SPK Ref
Result Reportlimit SPK Val Value %REC
0.01 0.01 100
1.02 0.1 0.1 102
0.0694 0.005 0.05 0.018 103
0.268 0.01 0.2 0.059 104
0.902 0.004 0.5 0.39 103
1.99 0.006 2 0.006 100
0,0926 0.01 0.1 0.01 93
ALS --Fort Collins
LIMS Version: 6.867
QC BATCH REPORT
Analysis Date: 7/12/201813:45
Prep Date: 7/11/2018 DF: 1
Control Decision RPO RPO
Limit Lewi Ref RPO Limit Qual
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
Analysis Date: 7/12/201813:39
Prep Date: 7/11/2018 DF: 1
Qual
Analysis Date: 7/12/201814:03
Prep Date: 711112018 DF: 1
Control Decision RPO RPO
Limit Lewi Ref RPO Limit Qual
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
80-120 20
QC Page: 7 of 16
60 of 70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: IP180711-11-1 Instrument ID ICP6500
MSD Sample ID: 1806204-16
Client ID: LOT 20 Run ID: IP180712-1A1
Analyte Result Reportlimit SPK Val
ARSENIC 1.01 0.01
BARIUM 1 05 0.1
CADMIUM 00706 0.005 0.05
CHROMIUM 0.271 0.01 0.2
LEAD 0.911 0.004 0.5
SELENIUM 2.04 0.006 2
SILVER 0.0954 0.01 0.1
The following samples were analyzed in this batch: 1806204-16
1606204-19
1806204-22
1806204-25
1806204-28
Method: SW6010
Units: MG/L
SPK Ref
Value %REC
0.01 101
0.1 105
0.018 105.4
0.059 106.1
0,39 104.9
0.006 102
0.01 95
1806204-17
1606204-20
1806204-23
1806204-26
1806204-29
ALS --Fort Collins
LIMS Version: 6.867
QC BATCH REPORT
Analysis Date: 7/1212018 14:06
Prep Date: 7/11/2018 DF: 1
Control Decision RPO RPO
Limit Le\el Ref RPO Limit Qual
80-120 20
80-120 1.02 3 20
80-120 0.0694 2 20
80-120 0.268 20
80-120 0.902 20
80-120 1.99 2 20
80-120 0.0926 3 20
1806204-18
1806204-21
1806204-24
1806204-27
1806204-30
QC Page: 8 of 16
61 of70
Client: Neo Performance Materials Silmet 00
Work Order: 1806204
Project: NEO Silmet
Batch ID: IP180716-4-1 Instrument ID ICPMS2 Method: SW6020
LCS Sample ID: IM180716-4 Units: MG/KG
Client ID: Run ID: IM180721-10A2
Analyte Result
ALUMINUM 423
ARSENIC eas
BARIUM 972
BERYLLIUM 4.44
CADMIUM 289
CALCIUM 883
CHROMIUM 464
COBALT 9 57
COPPER 93.4
IRON 483
MAGNESIUM 902
MANGANESE 943
MOLYBDENUM 9.36
NICKEL 47.3
POTASSIUM 448
SELENIUM 9 23
SILVER 0 993
SODIUM 906
THALLIUM 0194
TIN 461
VANADIUM 8.95
ZINC 188
Report Limit
10
0.2
0.5
0.05
0.2
100
1
0.5
2
10
10
0.5
0.2
2
100
1
0.05
100
0.01
0.5
10
SPK Ref
SPK Val Value
500
10
10
5
3
1000
50
10
100
500
1000
10
10
50
500
10
1
1000
0.2
50
10
200
ALS •• Fort Collins
LIMS Version: 6.867
Control
%REC Limit
85 80-120
89 80-120
97 80-120
89 80-120
96 80-120
88 80-120
93 80-120
96 80-120
93 80-120
97 80-120
90 80-120
94 80-120
94 80-120
95 80-120
90 80-120
92 80-120
99 80-120
91 80-120
97 80-120
92 80-120
89 80-120
94 80-120
QC BATCH REPORT
Analysis Date: 7/21/2018 17:06
Prep Date: 7/16/2018 OF: 10
Decision RPO RPD
Lewi Ref RPD Limit Qual
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
QC Page: 9 of 16
62 of70
Client: Neo Performance Materials Silmet 00
Work Order: 1806204
Project: NEO Silmet
Batch ID: IP180716-4-1 Instrument ID ICPMS2 Method: SW6020
LCSD Sample ID: IM180716-4 Units: MG/KG
Client 10: Run ID: IM180721·10A2
Analyte Result ReportLimit
ALUMINUM 430 10
ARSENIC 9_03 0_2
BARIUM 9-76 0.5
BERYLLIUM 456 0.05
CADMIUM 3 0.2
CALCIUM 940 100
CHROMIUM 47_5 1
COBALT 9-75 0.5
COPPER 956 2
IRON 485 10
MAGNESIUM 921 10
MANGANESE 9.77 0.5
MOLYBDENUM 962 0.2
NICKEL 47 8 2
POTASSIUM 461 100
SELENIUM 9 75 1
SILVER 0 993 0.05
SODIUM 931 100
THALLIUM 0197 0.01
TIN 46.6 1
VANADIUM 915 0.5
ZINC 193 10
SPK Ref
SPK Val Value
500
10
10
5
3
1000
50
10
100
500
1000
10
10
50
500
10
1
1000
0.2
50
10
200
ALS --Fort Collins
LIMS Version: 6.867
Control
%REC Limit
66 60-120
90 80-120
98 80-120
91 80-120
100 80-120
94 80-120
95 60-120
97 80-120
96 80-120
97 60-120
92 80-120
98 80-120
96 80-120
96 80-120
92 80-120
98 80-120
99 80-120
93 80-120
99 80-120
93 80-120
92 80-120
96 60-120
QC BATCH REPORT
Analysis Date: 7/21/201817:09
Prep Date: 7/16/2018 OF: 10
Decision RPO RPO
Le\EI Ref RPO Limit Qual
423 2 20
8.66 2 20
9.72 0 20
4.44 2 20
2.89 4 20
863 6 20
46.4 2 20
9.57 2 20
93.4 2 20
483 20
902 2 20
9.43 4 20
9.36 3 20
47.3 20
448 3 20
9.23 5 20
0.993 0 20
906 3 20
0.194 2 20
46.1 1 20
8.95 2 20
166 2 20
QC Page: 10 of 16
63 of70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: IP180716·4·1 Instrument ID ICPMS2
MB
Client ID:
Analyte
Sample ID: IP180716-4
Run ID: IM180721-10A2
Result Reportlimit
ALUMINUM NO 10
ARSENIC ND 0.2
BARIUM ND 0.5
BERYLLIUM ND 0.05
CADMIUM ND 0.2
CALCIUM ND 100
CHROMIUM ND 1
QC BATCH REPORT
Method: SW6020
Units; MG/KG Analysis Date: 7/21/2018 17:03
Prep Date: 7/16/2018 DF: 10
Qual
------------------------------------------------COBALT ND 0.5
COPPER ND 2
IRON ND 10
MAGNESIUM ND 10
MANGANESE ND 0.5
MOLYBDENUM ND 0.2
POTASSIUM ND 100
SELENIUM ND 1
SILVER ND 0.05
SODIUM ND 100
THALLIUM ND 0.01
TIN ND 1
VANADIUM ND 0.5
ZINC ND 10
The following samples were analyzed in this batch: 1806204-1
1806204-4
1806204-7
1806204-10
1806204-1 3
1806204-2
1806204-5
1806204-8
1806204-11
1806204-14
ALS •• Fort Collins
LIMS Version: 6,867
1806204-3
1806204-6
1806204-9
1806204-12
1806204-15
QC Page: 11 of 16
64 of70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: IP180716-4-1 Instrument ID ICPMS2
LCS
Client ID:
Sample ID: IM180716-4
Run ID: IM180722-10A2
Analyte Result Reportlimit SPK Val
LEAD
THORIUM
URANIUM
LCSD
Client ID:
Analyte
LEAD
THORIUM
URANIUM
MB
Client ID:
Analyte
LEAD
THORIUM
URANIUM
Sample ID: IM180716-4
Sample ID: IP180716-4
5 03 0.2 5
0.928 0.02 1
0.958 0.01 1
Run ID: IM180722-10A2
Result Reportlimit SPKVal
516 0.2 5
0.97 0.02
1 01 0.01 1
Run ID: IM180722-10A2
Result Reportlimit
ND 0.2
0.021 0.02
0.015 0.01
The following samples were analyzed in this batch: 1606204-1
1806204-4
1806204-7
1806204-10
1806204-13
QC BATCH REPORT
Method: SW6020
Units: MG/KG Analysis Date: 7/22/2018 19:42
Prep Date: 7/16/2018 OF: 10
SPK Ref Control Decision RPD RPO
Value %REC Limit Le1.el Ref RPO Limit Qual
101 B0-120 20
93 B0-120 20
96 80-120 20
Units: MG/KG Analysis Date: 7/22/2018 19:45
Prep Date: 7/16/2018 DF: 10
SPK Ref Control Decision RPO RPO
Value %REC Limit Lewi Ref RPD Limit Qual
103 B0-120 5.03 3 20
97 80-120 0.928 4 20
101 80-120 0.958 5 20
Units: MG/KG Analysis Date: 7/22/201819:39
Prep Date: 7/16/2018 OF: 10
Qual
1806204-2 1806204-3
1806204-5 1806204-6
1806204-8 1806204-9
1806204-11 1806204-12
1806204-14 1806204-15
ALS --Fort Collins
LIMS Version: 6.867
QC Page: 12 of 16
65 of70
Client:
Work Order:
Project:
Neo Performance Materials Sil met 00
1806204
NEOSilmet
Batch ID: IP180716-4-1 Instrument ID ICPMS2
LCS
Client ID:
Sample ID: IM180716-4
Run ID: IM180727-10A2
Analyte Result Reportlimit SPK Val
NIOBIUM
TANTALUM
ZIRCONIUM
LCSD
Client ID:
Analyte
NIOBIUM
TANTALUM
ZIRCONIUM
MB
Client ID:
Analyte
NIOBIUM
TANTALUM
ZIRCONIUM
Sample ID: IM180716-4
Sample ID: IP180716-4
111 0.1
0.974 0.1
1 09 0.05
Run ID: IM180727-10A2
Result Reportlimit SPKVal
1.09 0.1
0 989 0.1 1
107 0.05 1
Run ID: IM180727-10A2
Result Reportlimit
ND 0.1
ND 0.1
ND 0.05
The following samples were analyzed in this batch: 1806204-1
1806204-4
1806204-7
1806204-10
1806204-13
QC BATCH REPORT
Method: SW6020
Units: MG/KG Analysis Date: 7/27/201811:09
Prep Date: 7/16/2018 OF: 10
SPK Ref Control Decision RPO RPO
Value %REC Limit Le-..el Ref RPO Limit Qual
111 80-120 20
97 80-120 20
109 80-120 20
Units: MG/KG Analysis Date: 7/27/201811:11
Prep Date: 7/16/2018 OF: 10
SPK Ref Control Decision RPO RPO
Value %REC Limit Lewi Ref RPO Limit Qual
109 80-120 1.11 2 20
99 80-120 0.974 2 20
107 80-120 1.09 2 20
Units: MG/KG Analysis Date: 7/27/2018 10:44
Prep Date: 7/16/2018 OF: 10
Qual
1806204-2 1806204-3
1806204-5 1806204-6
1806204-8 1806204-9
1806204-11 1806204-12
1806204-14 1806204-15
ALS •• Fort Collins
LIMS Version: 6.867
QC Page: 13 of 16
66 of70
Client:
Work Order:
Project:
Neo Performance Materials Silmet 00
1806204
NEO Silmet
Batch ID: IC180618-1-1 Instrument ID IC3
LCS
Client ID:
Sample ID: IC180618-1
Run ID: IC180618-1A1
Analyte Result Reportlimlt SPK Val
FLUORIDE
CHLORIDE
SULFATE
LCSD
Client ID:
Analyte
FLUORIDE
CHLORIDE
SULFATE
MB
Client ID:
Analyte
FLUORIDE
CHLORIDE
SULFATE
Sample ID: IC180618-1
Sample ID: IC180618-1
20 4 20
51-4 2 50
202 10 200
Run ID: IC180618-1A1
Result Reportlimit SPKVal
20 3 1 20
506 2 50
202 10 200
Run ID: IC180618-1A1
Result ReportLimit
ND
NO 2
ND 10
The following samples were analyzed in this batch: 1806204-1
1806204-4
1806204-7
1806204-10
1806204-13
QC BATCH REPORT
Method: EPA300.0
Units: MG/KG Analysis Date: 6/19/2018 02:45
Prep Date: 6/18/2018 OF: 1
SPK Ref Control Decision RPD RPO
Value %REC Limit Le1.el Ref RPO Limit Qual
102 85-115 30
103 85-115 30
101 85-115 30
Units: MG/KG Analysis Date: 6/19/2018 03:00
Prep Date: 6/18/2018 OF: 1
SPK Ref Control Decision RPO RPD
Value %REC Limit Lewi Ref RPD Limit Qual
102 85-115 20.4 0 30
101 85-115 51.4 2 30
101 85-115 202 0 30
Units: MG/KG Analysis Date: 6/19/2018 02:31
Prep Date: 6/18/2018 OF: 1
Qual
1806204-2 1806204-3
1806204-5 1806204-6
1806204-8 1806204-9
1806204-11 1806204-12
1806204-14 1806204-15
ALS --Fort Collins
LIMS Version: 6.867
QC Page: 14 of 16
67 of70
Client:
Work Order:
Neo Performance Materials Silmet 00
1806204
QC BATCH REPORT
Project: NEO Silmet
Batch ID: NH180707-2-1 Instrument ID Lachat Method: EPA350.1
LCS Sample ID: NH180707-2 Units: MG/KG Analysis Date: 717/201813:28
Client ID: Run ID: NH180707-2A1 Prep Date: 7/7/2018 DF: 1
SPK Ref Control Decision RPD RPO
Analyte Result Reportlimit SPK Val Value %REC Limit Lewi Ref RPO Limit Qual
AMMONIA AS N 11.2 10 112 85-115 20
LCSD Sample ID: NH180707-2 Units: MG/KG Analysis Date: 717/2018 13:29
Client ID: Run ID: NH180707-2A1 Prep Date: 7/7/2018 DF: 1
SPK Ref Control Decision RPO RPD
Analyte Result Reportlimit SPK Val Value %REC Limit Lewi Ref RPO Limit Qual
AMMONIAASN 112 10 112 85-115 11.2 0 20
MB Sample ID: NH180707-2 Units: MG/KG Analysis Date: 717/2018 13:27
Client ID: Run ID: NH180707-2A1 Prep Date: 717/2018 DF: 1
Analyte Result Reportlimit Qual
AMMONJAASN ND
The following samples were analyzed in this batch: 1806204-1
1806204-4
1806204-7
1806204-10
1806204-13
1806204-2
1806204-5
1806204-8
1806204-11
1806204-14
1806204-3
1806204-6
1806204-9
1806204-12
1806204-15
ALS --Fort Collins
LJMS Version: 6.867
QC Page: 15 of 16
68 of 70
Client:
Work Order:
Neo Performance Materials Silmet 00
1806204
QC BATCH REPORT
Project: NEOSilmet
Batch ID: NN180622-3-1
LCS
Client ID:
Analyte
Sample ID: NN180622-3
NITRATE/NITRITE AS N
LCSD
Client ID:
Analyte
Sample ID: NN180622-3
NITRATE/NITRITE AS N
MB
Client ID:
Analyte
Sample ID: NN180622-3
NITRATE/NITRITE AS N
Instrument ID Lachat Method: EPA353.2
Units: MG/KG Analysis Date: 6/23/2018 09:16
Run ID: NN180623-1A1 Prep Date: 6/22/2018 DF: 1
SPK Ref Control Decision RPO RPO
Result Reportlimit SPK Val Value %REC Limit Level Ref RPO Limit Qual
103 0.1 10 103 80-120 20
Units: MG/KG Analysis Date: 6/23/2018 09:17
Run ID: NN180623-1A1 Prep Date: 6/22/2018 DF: 1
SPK Ref Control Decision RPO RPO
Result ReportLimit SPK Val Value %REC Limit Level Ref RPD Limit Qual
10.1 0.1 10 101 80-120 10.3 2 20
Units: MG/KG Analysis Date: 6/23/2018 09:16
Run ID: NN180S23-1A1 Prep Date: 6/22/2018 DF: 1
Result Reportlimit Qual
ND 0.1
The following samples were analyzed in this batch: 1806204-1 1806204-2 1806204-3
1806204-4 1806204-5
1806204-7 1806204-8
1806204-10 1806204-11
1806204-13 1806204-14
ALS --Fort Collins
LIMS Version: 6.867
1806204-6
1806204-9
1806204-12
1806204-15
QC Page: 16 of 16
69 of70
Ft. Collins, Colorado
Non-Conformance
CONTROLLED
NON-CONFORMANCE REPORT
Initiated By: Steven D. While on 7/12/2018
Event Type: Laboratory lncidenUError
NCR#: 14714
Event Explanation: For sample 1806204-15Dup. Thorium analysis --Low recoveries are expected. The sample cup spilled just before ii was to be poured
through the filter funnel to be planchetted. The sleeve of the lab coat caught lhe sample cup and knocked it over spilling lhe sample on
the counter. What remained in the cup was taken through the rest of the process, but low recoveries are expected.
Action To
Prevent Reccurence: Not Applicable
Corrective Action
Corrective Action:
Department Manager Approval:
Approval Date:
Corrective Action Comments:
Workorder --Procedure
180621JiJ -ilihlS:G>
Associated Batches
John C. Petrovic
7/17/2018
The chemical yield for this sample was below the
30% lower conlrol limit al 10.9%. The DER was in
control for the sample/duplicate al 0.39 (Th-228),
0.14 (Th-230), and 0.34 (Th-232). Narrate low yield
was due to spill.
Workorders Affected
No client contact information.
Approved By
PENDING
------
Approval Date
The samples were originally associated with the following Batch(es): All rework was completed in the following Batch{es):
AS180702-8 created on 7/2/2018 Not Applicable
NCR Approval
Project Manager Approval:
Department Manager Approval:
QA Manager Approval:
Page 1 of 1 Date Printed: Thursday, July 19, 2018
225 Commerce Drive Ft. Collins, Colorado B0524
Phone [phone] Fax [phone] www.elsglobal.com 70 of70
Radioactive Material Profile Record
Attachment D.1 a through f
Material generation process history and description
(see "Technological Process Description for Production of NORM Containing Residue" -attached)
Generator or Contractor Initials:
Page 9 of 11
• necf
Performance Materials
TECHNOLOGICAL PROCESS DESCRIPTION FOR PRODUCTION OF NORM
CONTAINING RESIDUE
General description of the process
Columbite and tantalite -NORM (U 238 and Th 232) containing mineral ore concentrates are
processed via leaching process to separate the insoluble impurities including NORM (U238
and Th232) and Nb, Ta. The process includes the following operations:
Crushing and milling of the mineral ores Columbite and Tantalite;
Dissolution of the mineral ores, columbite and tantalite in acid solutions (HF, H2S04);
Precipitation of insolubles from slurry and their filtration -Filter cake = NORM
containing residue;
Washing of the filter cake with water
Filtration of the NORM containing residue
Calcination, cooling and packing of the NORM containing residue
Figure 1. The principal flowchart of the NORM containing residue process
~----__..
TANTALITE, COLUMBITE
Mineral or concentrates
Crushing and Milling
i
Dissorion
Filtration and washing
i
NORM containing residues
Drying and Calcination
+
Nb and Ta
containing
Cooling and packing of NORM containing residues
Raw material
NPM SILMET 00
Kesk 2
40231 Sillamiie, Estonia
Reg nr 10294959
www.neomaterials.com
,,, ~~ ' ... • , 11,,lJ•
[phone] PHONE
2
Raw Materials
NPM Silmet 00 is using several types of mineral ores -Columbite and Tanatlite, which are
characterized by different rare metals Nb and Ta content, but also different impurities profile
included content of naturally occuring radioactive materials U 238 and Th 232 and their decay
products. Typical characteristics of Columbite and Tantalite are in Table 1.
Columbite and Tantalite are dark coarse mineral materials, what will be crushed and milled by
vibrating mills. Raw materials are transported to NPM Silmet 00 in 50 kg plastic bags or 200
liter metal drums.
Table 1
Element Columbite Tantalite
1 Ta205 % 4 30
2 Nb205, % 40 20
3 Th02. % 0.5 0,2
4 U203 % 0, 1 0,2
5 LOD. % 0.1 0 1
Crushing and milling of raw material
Columbite and tantalite are crushed and milled in isolated area -milling unit, because of the
formation of the radioactive dust, which is the must hazardous factor of the entire process.
Raw materials are loaded by hermetic feeder screws into vibrating mills, where material is
milled until to required particle size, removed from mills by hermetical discharge systems and
packed into metal drums. Milling unit has isolated ventilation system with filter systems, dust
particles from the filtered air is removed by cyclons and recycled in the process with raw
material.
Dissolution of raw material and filtration of the solutions.
Milled columbite and tantalite is transported into dissolution unit (located in the same territory,
but separate building). Drums with the milled columbite and tantalite are placed on the top of
automatic feeder systems, where material is loaded into dissolution reactors into hydrofluoric
acid solution. Raw material is dissolved at temperature 80-85°C in hydrofluoric acid and
sulphuric acid is added to precipitate out the impurities. The slurry is filtrated to remove the
insoluble impurities including U and Th. After filtration the filtercake is washed with water
several times to remove all Nb and Ta from the cake. Wet NORM containing cake is packed
into 1 Mt plastic bags (Big-bags) and transported into calcination unit (locating in the same
building).
Calcination of the NORM containing cake
NORM containing cake (NORM Residue) is loaded from big-bags into electric·rotary kilns via
feeder systems, and calcined at temperature 550-600 °C 1 hour. Calcined NORM residue is
moving from rotary kiln into rotary coolers where material is cooled down and packed into 200
I metal drums what is insulated with triple wall PE bags. Quality Control Department with
Governmental Lab Okosil AS, are taking samples from every drum for gamma spectrometry
analyze and all drums are measured for dose speed. The LOT is completed from 9 drums and
transported into warehouse, photos 1,2,3.
Photo 3. NORM residue warehouse
3
Jane paju
Director of Technology
NPM Silmet 00
Radioactive Material Profile Record
Attachment D.2
Analytical data (including all pertinent Quality Control Data) for all yes answers
(see Attachment C. l -ALS lab analysis results)
Generator or Contractor Initials:
Page 10 of 11
Radioactive Material Profile Record
Attachment D.3
Analytical Data (including all pertinent Quality Control Data) for total and TCLP metals and anions
(see Attachment C.1 -ALS lab analysis results)
Generator or Contractor Initials:
Page 11 of 11
REPUBLIC OF ESTONIA
COUNTY OF IDA-VIR V
CITY OF SILLAMAE
AFFIDAVIT
OF
SIGNEKASK
I, Signe Kask, being duly sworn, depose and state as follows:
GENUINENESS OF THE SIGNATURE
1. I am presently Managing Director of NPM Silmet OU (' Silmet' ). In this capacity I am
responsible for managing the business and operations at Silmet s manufacturing facility
located in Sillamae, Estonia (the Facility ), including its environmental compliance
programs. I am familiar with the operation of Facility equipment and systems, and the
implementation and oversight of decommissioning activities and related, including waste
management. I have personal knowledge of the raw materials used, the production
processes employed, and the waste handling procedures followed at the Facility.
2. Silmet proposes to ship to the White Mesa Mill in Blanding, Utah (which is owned by
EFR White Mesa LLC, a Colorado limited liability company ("White Mesa"), and
operated by an affiliate of White Mesa, Energy Fuels Resources (USA) Inc., a Delaware
corporation) the following materials for processing as alternate feed materials: uranium
and thorium-containing residues ('Residue'). The proposed alternate feed material is
calcined residue resulting from the processing of col um bite and tantalite mineral ore
concentrates at the Facility and contains no RCRA-listed or hazardous materials or
wastes from any other source.
3. The Residue consists of precipitated radionuclides removed from the columbite and
tantalite solutions during the purification process conducted at the Facility. The Residue
contains uranium thorium, and other radionuclide impurities precipitated as a slun-y.
The slurry was passed through a filter press, and the filter cake washed with water. The
washed filter cake was subsequently calcined in a rotary kiln, cooled, and drummed. The
calcined, drummed Residue is to be shipped to the White Mesa Mill.
4. I have reviewed and am familiar with the Utah Hazardous and Solid Waste Regulations
R315-2-10 and R3 l 5-2-11 and the United States Code of Federal Regulations Title 40
Sections 261 .31 through 33 (th,: 'Regulations"). Based on the processing steps
employed at the Facility, the proposed alternate feed materials do not contain any of the
listed wastes enumerated in the Regulations.
5. Based on my knowledge of waste management at the Facility, the proposed alternate feed
materials have not been mixed with wastes from any other source that may have been
defined as or that may have contained listed wastes enumerated in the Regulations.
6. The proposed alternate feed materials:
a. do not contain hazardous wastes from non-specific sources (Utah RCRA F type
wastes) because Silmet: (i) does not operate any processes that produce the types of
wastes listed in Section 261.31 of Title 40 of the Regulations, and (ii) has never
accepted, nor have the proposed alternate feed materials ever been combined with,
wastes from any other source that contain Utah RCRA F type wastes as defined
therein;
b. do not contain hazardous wastes from non-specific sources (Utah RCRA K type
wastes) because Silmet: (i) does not operate any processes that produce the types of
wastes listed in Section 261 .32 of Title 40 of the Regulations, and (ii) has never
accepted, nor have the proposed alternate feed materials ever been combined with,
wastes from any other source that contain Utah RCRA K type wastes as defined
herein; and
c. are not Utah RCRA P or U type wastes because (i) they are not manufactured or
formulated commercially pure grade chemicals, off-specification commercial
chemical products, or manufacturing chemical intermediates, are not residues from
containers that held commercial chemical products or manufacturing chemical
intermediates, and are not residue or contaminated soil, water, or other debris from a
spill cleanup and (ii) Silmet has never accepted, nor have the proposed alternate
feed materials ever been combined with wastes from any other source that contain
Utah RCRA P or U type wastes as defined herein.
In witness whereof I have set my hand on the ). ' day of / a,/!J t1 ~1. 2019.
{ Siglle
Registration number 108 in the Notary Journal of official acts.
In the town of Sillamiie on the twenty-ninth (29th) of January (01) in the year two thousand and
nineteen (2019).
I, the undersigned Sillamae notary Irina Kritsuk, whose office is located at 22 Kesk str., Sillamae,
Jda-Viru county, the Republic of Estonia, do hereby certify the authenticity of the signature made
in my presence by SIGNE KASK, personal code 47107300281, residing at Tutermaa, Harku
parish, Harju county, the Republic of Estonia, who was identified by her identity card
AA1392759.
Upon certifying the authenticity of signatures, the notary did not verify the facts stated by the
applicant in the document.
Notary fee(§ 31 part 12 of Notary Fees Law)
VAT20%
Total
ATTACHMENT 3
EFRI/UDEQ Protocol for Determining Whether Alternate Feed Materials Are
RCRA Listed hazardous Waste
lJc:Yc.-mcr
Di.ir.n~ !l S:i~!,:m, !'h 0.
r:,~1,J(.VC Cu1.:ClOr
Dc:ini, R. Ocwn~
:)1r~~1:1ir
St~1te ()f Ltal1
D i:::PA in V :~ ~ T o:: ::S'· . .":RO '-.YI_\;·:-.\: .. ():'A'..'.": ':'-
D!V :.~ :Ol\ u~· SO~i~> .-\:--,..D l-i.\7.-\i~.UOI_ .. ':-, W:\S~:~
21!8 1-ort:: !460 WW r o lh,x 144SK<l
S~t lnJ.:c City. Utal\ 84 l 14-1&80
(!!Ol l 5 38-6170
(SOI) 538•6715 [:ax
[phone] TDD.
WW\• tkq ,::;(.i!i:.u(.US W<=b
o~cember 7, i 999
M. Lindsay Ford
Parsons, Behle and Latimer
One Utah Center
20 l South 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 ~r. Ford:
On November 22, 1999, we received the final protocol to be used by International Uraniuni
Corporation (TUSA) in determining whether altemate feed materials proposed for processing at
the White Mesa Mill are listed baz.a:rdous 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 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 Verb1ca ::.t
538-6170.
Sincerely,
~~1ri~~~~~e~ry
Utah Solid and Hazardous Waste Control Board
c: Bill Sinclair, Utah Division of Radiation Control
F.ISHW\HWO\OVERSIC'.AIWl'lwhiCcmClo.1.,vpd
(;:~c ~ ·t..,.:1 Cc.:u\&.:t
:!.c 1 ~u·sL'l ~{310 Srrcct
:,m10 i800
1•0,: Office li<l• ~ 5~9~
Sl!I l.2~c City, L:t:Lll
ro:cphoac 801 5J'2.:2l4
r,·.,o,milc 801 !J6-61 l I
Don Verbica
I Par-sons-
Behle & 1 I Latimer i
1
,\ 1•,orcss:0.1.1~
[.;.',I' GnR,o~~TIJ~
November 22, 1999
Utah Divisiou of Solid & Hazardous Waste
288 1':orth 1460 West
Salt Lake City, Utah
Dear Don:
Re: Protocol for Determining Whether Alternate Feed Materials are
Listed Bazardo11.1 Wastes
I am pleased to present the final protocol to be used by [nternational Uranium
(USA) Corporation ("IDSA'') in determining whether alternate feed. materials proposed for
processing at the White Mesa Mill are Listed hazardous wastes. Also attached is a red-lined
version of the protocol reflecting final changes made 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 We 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 unrefutable
information comes to light that indicates the material is a listed hazardous waste. Should
such an eventuality arise, we understand an appropnate response. if any, would need to be
worked out on a case-by-ease basis.
)03107.l
:Jon V t-:-jica
Ct;.ih Division of Solid & Hazardcus \Vaste
:--.:ovember 22, t 999
Page Two
Thank you again for your cooperation on this maner. Please call me if you have
any 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
JOJ!O?.I
Very truly yours,
Parsons Behle & Latimer
~1rAP
M. Lindsay Ford
Protocol tor Determining if Alternate Feed Material is a Listed Hazardous Vv'aste
a ~ S::.rnce 1.-...e~hgotior, I
(e.g .. oblo•n 1"'5!)S,
R~ existir,g ~er.,:;•, (8Stort de:1er1ri:1ottons. 01
o?t,er co·npos·1•:n
J il\'.otmolicn 01 s;:i,,-,.
ping dola rr-:m
9-?rte1aklr(
------:i;·--
o.
II
It ·a: proi,ide to NAC Ol'.d/cr U1o'1:
• SI
• Alrido-.•it tl'f ,'JEA o: 8:r.eiolor
exploiring wh')• r.ol usteo lil'i
Ir ·b, • pr0vioa lo NRC crn:l,'or Utar,;
• Do:umen1o:vi frcm reg1,lalo;y
oufhon~1 -·--·----.-
E"~~:::_,,
~1 t! Si:.1-<<.;r? tn~,,,-319.JJ1:;1'1
PJ-:rt~:rJ , AJ!,~. rlOSe 1ee.::l 11"1,Qle .. .d p·,o~j ~::c
v·n:-F-SSSq or 1/ltlfiP.' ~"~ Ml
c,:,;iw"'Ct'on Sa~ =-Fns: 1:-.cCO\·o'.on .:r
PUJ·'."itl'pt'f'E-f1:
.o.,:i:~•rrce SorrpP.S ,. Up;.-,~ 1ece,_:i1 al ·,•,sr.ne 1.1~;o t.1i I
~ ~ "S...,~,,0~11;:J &Al'KJ~~t;. ibn
;,,,•;,rJ>Jtf flsle,;1lialo·oo..s ,.onstm.eils e Ccr~mu;,nls
l~lef1,r, «:JO~ 2,:>I.As;;P •t,la; lhe tx:,,riCc1 lstrg
tuu:r<lOus •.,rn•,a; o< i" 4\1 CH! 261.JJtel <:I 1rl(F
01 U W:Bles!.
FolP.nh:ily l,;teoWo<res ~ HJ.."0/oou; ...asles ..t!ICl1 o,e
lls!e<:l h~ oo; of rr,,, l~1ed Hc,r:,;;r·oc.,~ C:Jn,~ivan·i
d!?lse<:led h tre 1.1a.211ol (b>f l'.oli e. Conli1rr01on
01 A<:cepor>::~ ~P'.esl OS den:,:oo 1n .:0 CHI
261 .;,cp \Ji (Ji I~ ,3 CFR 261.33/e/ Cf [I(.
GS?Oe1r.J1c..,,r -E:nl#'r ~p::riSbc 10. "lA ,r-e rtvm Y.t"lc:h
t.1ntard ag n)les..
t".'Y.111.:l~.rre,101 "~~ ~ ~c<s. ·nr.J1et o:-d s,ad,-.-,..?111~
L•··,,,..,•;~
YES
m
PtO'llide to NOC ord/or Ufoh:
• 51
, bp·onol'ai ,...ti·,· 110! mec:1
• SAP~!II opp!ccb'~]
, Conlirmallon.,'AccaplOflce
Sorr,;:iing Results 11r oppllco·
blej
YES
NO
NO
II
l-~101
. Polen:nl·r
Li sled Wosles
fl. fconduct ongoing l
Conrirmotion and
Acceptance
Sampling end uss
resui1S ;o roovo~uo1e
Wtlether Maferf::i~ ,.
I. ore listed hazardous
l__'l,OSte:s,.
NO
r Sepo!Ole Liiled
Ha2.a1c,x•s Wosles
Non-h'N 111cm ctr,;<" M::ileld;
NO
H'N
PROTOCOL FOR DETER.:'\,fl)o'l:"JG WHETHER
ALT£R."1"ATE: FEED :V{ATERIALS ARE LISTED HAZARDOUS WA.STES 1
NOVEMBER 16, 1999
1. SOURCE lNVESTIGATlON.
Perform a good faith. investigation (a "Source Investigation" or "Sl")2 regarding whether
any listed hazardous wastes) are located at the site from which alternate feed material"
("Material") originates (th~ 0 Site"). This investigation will be conducted in conformance
with EPA guidance5 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 eff~t, together with (b)
a Material Safety Data Sheet ("MSDS'') for the 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 determining whether alternate feed materials proposed for processing at the
White Mesa Mill are (or contain) listed hazardous wastes. It is based on current Utah and EPA rules and
EPA guidance \lllder the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. §§ 6901 et seq.
This Protocol will he changed as necessary to reflect any pertinent changes to RCRA rules or f.P A
guidance.
2 This investigation will be performed by IDSA, by the entity responsible for the site from which tr.e
Material origmates (the "Generator"). or by a combination of the two.
3 Attachment l to this Protocol provides a summary of the different classifications of RCRA ltsted
hazardous wastes.
4 Alternate feed materials that arc pri.mMY or intermediate products of the generator of the material (e.g..
"green" or "black" salts) are not RCRA "secondary materials" or "solid wastes," as defined in 40 CFR
261, and are not covered by this Protocol.
5 EPA guidance identifies the following sources of site~ and waste-specific information that may.
depending on the circumstances, be considered in such an invcsligation: hu..ardous waste man1fest5,
vouch<.TS, bills of lading, sales and inventory n:cords, material safety data sheets, storage records.
sampling and analysis reports, accident reports, site investigation reports. interviews With
<.mployees/fonner employees and former owners/operators, spill reports, inspection reports and ,ogs.
permits, and enforcement orders. See e.g .. 61 Fed. Reg. I 8805 (April 29, L 996).
243876.l
PtWTOCOL FOR O El Ell..'-11.' l;\"G WHETlf F. R ~LT£RS .\ TE l•HD '.\1." rrn, ..... L.s AR[ LISTE:D H,\lARDOLS \VAST[S
• Where specific information exists about the generation process :md
management of the Yiaterial: (a) an affidavit, certificate, profile record or
similar document from the Generator or Site ~anager, to that effect, together
with (b) an MSDS for the Material, 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 information: site
investigation reports prepared under CERCLA, RCRA or other state or federal
environmental laws or programs (e.g .. an R.I/FS, ROD, RFI/CMS, hazardous
waste inspection report); interviews with persons possessing knowledge about
the Material and/or Site; and review of publicly 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 h.u been accepted for direct
disposal as l le.(2) byproduct material in an NRC-regu.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 to Step 2.
2. SPECIFIC INFORMATION OR AGREEMENT/DETERMINATION BY
RCRA REGULATORY AUTHORITY THAT MATERIAL IS NOT A
LISTED HAZARDOUS WASTE?
a. Determine whether specific information from the Source Investigation exi.sts 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 genetated by a listed waste i.ource 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 the
Material is not a listed hazardous waste, has made a •·contained-out'' detcmrination6 w1th
respect to the Material or bas concluded the Material or Site is not subject to RCRA
6 EPA explains the "contained-out" (also referred to as "contained-in") principle M follo~:
In practice, EPA has applied the contai ncd-1n prmciple to refer to a process where a site-
specific determination ii. made that concentrations of hazardous constituents in any given
(footnote contutued on next page)
243876 I 2
PROTO( 01. F() II. D l::TER~U:'\1:"i G W IIHllER AL l'E R."'0. n: Fr.rn .\.L\.T[R!A!...S Aru:: LtsT [D HA.LA1lDOL::i w .. \:, n:s
If yes to either question, proceed to St<.!p 3.
[f 110 10 borlt questions. proceed to Step 6.
3. PROVIDE INFOR..l\1ATION TO !.'.'RC AND L'TAH.
a. 1f specific information exists to .support a conclusion that the Material is not, and docs
not contain, any listed hazardous waste, TIJSA will provide a description of the Source
Investigation to NRC 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 hazardous waste.
b. Altemati vel y, if the appropriate regulatory authority with RCRA jurisdiction over the
Site agrees in writing with the generator's determination that the Material is not a listed
hazardous waste, makes a contained-out determination 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. illSA may rely on such determination provided
that the State agrees the conclusions of the regulatory authority were reasonable and made
in good faith.
Proceed to Step 4.
4. DOES STATE OF ITTAH 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 IUSA in Step 3 or 16 with reasonable speed and
advise IUSA if it believes IUSA has not properly followed this Protocol in detennining
(footnote continued from previous page)
volume of eovuonmental media an; low enough to determine that the media does not
"contain" hazardous waste. Typically, these so-called .. contained-in" [or "contained·
out") determinations do not mean that no hazardous constituents are present in
environmental media but simply that the concentrations of hazardous constituents
present do not warrant maoag~-ment of tht: mc:dia aa hazardous waste. . ..
EPA has not, to date, issued definitive guidance to establish the concentrations at which
contained-in detenninations may be made. As noted above, decisions that media do not
or no longer contain hu.ardous waste are typjcally made on a case-by-case basis
considering the risks posed by the contaminated media.
63 Fed. Reg. 28619, 28621-22 (May 26, 1998) (Phase IV LDR pre:m1ble).
243876.1 3
PROTOCOi. FOR Dt:n:n.,u:-.1::-.G \\ ... ~Jl::T1!£H ALfUl."i.-\ I£ fH:u :\1.-H£lUAL:i AH£ LISTEU H.UAH.l)<.)l.!; W .. s I LS
that the Material is not listed hazardous waste, specifying the particular areas of
deficiency.
If this Protocol has not been properly followed by IUSA in making its detennination that
the Material is not a listed hazardous waste, then [USA shall redo its analysis in
accordance with this Protocol and, if j u.stified, resubmit the information described in Step
3 or 16 explaining why the Material is not a listed hazardous waste. The State shall
notify lUSA with reasonable speed if the State still believes this Protocol has not been
followed .
.([yes. proceed to Step 5.
If no, proceed to Step I.
5. MATERIAL IS NOT A LISTED HAZARDOUS WASTE.
The Material is not a listed hazardous waste and 110 further sampling or evaluatton is
necessary in the following circumstances:
• Where the Material is determined not to be a listed hazardous waste
based on specific information about the generation/management of the
Material OR 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 conclusions of the regulatory authority were reasonable and
made in good faith) (Step 2); or
• Where the Material is dctcnnined not to be a listed hazardous waste (in
Steps 6 through 11, 13 or 15) and Confumation/Acceptance Sampling
arc determined not to be necessary (under Step 17).
6. IS MATERIAL A PROCESS WASTE K."'IOWN TO BE A LISTED
HAZARDOUS WASTE OR TO BE MIXED WITH A LISTED
HAZARDOUS WASTE?
243876.l
Based on the Source Investigation, determine whether the Material is a process waste
known to be a listed haurdous waste or co be mixed with a listed hv..ardous waste. If the
Material is a process waste and is from a listed hazardous waste source, it is a listed
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 under the RCRA "mixrurc rule ." ff
4
PfW'fO(.OL FOR D£TER.\1l:St:-;G WHETHER AL rER.."-ATE fHD ~l,\ TF,Rl,\T~<; ARF. Lrsn:o H .-\7..ARDQlS W.\STES
the Y!aterial is an Environmental Medium, 7 it cannot be a listed hazardous waste by direc'.
listing or w1der the RCRA "mixture rule ... ~ ff the Material is a process waste but is not
know11 to be from a listed source or to be mixed with a listed waste, or if the Material is
an Environmental Medium, proceed to Steps 7 through 11 to determine whether it is a
listed hazardous waste.
If yes, proceed to Step 12.
If no, proceed to Step 7.
7. DOES MATERIAL CONTAIN ANY POTENTIALLY LISTED
HAZARDOUS CONSTITUENTS?
Based on the Source Investigation (and, if applicable, Confirmation and Acceptance
Sampling). determ.ine'whether the Material contains aoy hazardous constituents listed in
the then most recent version of 40 CFR 261, Appendix VII {which identifies hazardous
constituents for which F-and K-hsted wastes were listed) or 40 CFR 261.33(e) or (f) (the
P and U listed wastes) (collectively "Potentially Listed Haz.ardous Constirucnts"). lf the
Material contains such constituents, a source evaluation is necessary (pursuant to Steps 8
through 11). If the Material does !!Q! contain any Potentially Listed Hazardous
Constituents, it is not a listed hazardous : waste. The Material also is not a listed
hazardous waste it: 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 Confirmation/Acceptance Sampling) and determined not to originate from a
listed S<>urce).
If yes, proceed to Step 8.
If no, proceed to 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 Potentially Listed Hazardous Constituents detected in the Matenal, as
7 The tcnn "Environmental Media" means solls, ground or surface water and sediments.
8 The "mixture rule" applies only to mixtures of listed hazardous wastes and other "solid wastes." Sei,:
40 CFR § 26 t .3(a)(2Xiv). The mixture rule docs, not apply to mixtures of listed wastes and
Environmental Media. because Environmental Media are not ''solid wastes" under RCRA. See 63 Fed.
Reg. 28556, 28621 (May 261 1998).
24Jll7G.I 5
PROTOCOL FOR l>tTF.RMl~1:,,G \VH£i11Efi. ALTER.'-,\ TF; Fuo :\,(,\Tf,RIAU. AR£ LtSTfl) HAZARDOl S w ,\S H.'i
identified. in the then most current version of 40 CFR 261 Appendix VU or 40 CFR
261.3 3( c) or (f) . .., With respect to Potentially Listed Hazardous Constituents identified
through Confirmation and/or Acceptance Sampling, a source evaluation (pursuanL to
Steps 8 through l l) is uecessary only for "new" Potentially Listed Hazardous
Constituents (i.e., constituents other than those that have already been identified by the
Source lnvestigation (or previous Confirmation/ Acceptance Sampling) and determined
not to originate from a listed source).
Proceed 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 rovestigation. determine whether any of the
Potentially Listed Wastes identified in Step 8 are known to have been generated or
managed at the Site. This detem1ination involves identifying whether any of the speclfic
or non-specific sources identified in the K-or F-lists has ever been conducted or located
at the Site, whether any waste from such processes has been managed at the Site, and
whether any of the P-or U-1.istcd commercial chemical products has ever been used,
spilled or managed there. In particular, this determination shouJd be based on the
following EPA criteria:
Solvent Listines {FOOi-FOOS)
Under EPA guidance, .. to determine if solvent constituents contaminating a waste
are RCRA spent solvent F001-F005 wastes, the [site manager] must know if:
• The solvents are spent and ca11not be reused without reclamation or
cleaning.
• The solvents were used excl11sively for their solvent properties.
• The solvents are spent mixtures and blends that contained, before use,
a total of IO percent or more (by volume) of the solvent.s listed in
FOOl, F002, F004, and F005.
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 infonnation oa the use of the solvents and their
characteristics before use, the [wastes] cannot be classified as containing a
9 For example, if the Material contains tetrachloroethylenc, the following would be Potentially Listed
Wastes: FOOi, F002, F024, K019. K020, K150, Kl5I or U210. See 40 CFR 261 App. VU.
2431!7t. I 6
PROiOCOL F()R ()F.Tf.R.'1!'.'ll"-C WHF:THEH ALTl:::R.'i.Hf. FF:F.D MATFRI.A.L.S ARE Lt!)TEO HA.7.AROQl S W ,\SrF.'i
listed spent solvent.";c The person perfonning rhe Source l.nvcStigation
will make a good faith effort to obtain information 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 will be cons1dered in detern1ining
whether those solvents contained 10 percent or more of the solvents listed
in FOOl, F002, F004 or F005.
K-Listed Wastes and F·Llsted Wastes Other Than FOOl·F005
Under EPA guidance, to determine whether K wastes and F wastes other than
F00l-F005 arc RCRA listed wastes, the generator "must know the generation
process information (about each waste contained in the RCRA waste) described in
the listing. For example, for [wastes} to be identified as contairung KOOl wastes
that arc described as 'bottom sediment sludge from the treatment of wastewaters
from wood preserving processes that use creosote and/or pentachlorophcnol, · the
[site manager] must know the manufacturing process that generated the wastes
(treatment of wastewaters from wood preserving process), fccdstocks used in the
process (creosote and pentachJorophcnol), and the process identification of the
wastes (bottom sediment sludge)."11
P-and U-Listed Wastes
EPA guidance provides that "P and U wastes cover only Wlused and unmixed
commercial chemical products, particularly spilled or off-spec products. Not
every waste containing a P Ol" U chemical is a hazardous waste. To determine
whether a [waste] contains a P or U waste, the [site manager] must have direcc
evidence of product use. In particular, the [site manager] should ascertain, if
possible, whether the chemicals are:
+ Discarded (as described 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 Dwing Site Inspections, EP A/540/G-9 l/009, May 199 l
(emphasis added).
l L Management of Invcstigation•Derivcd Wastes Owing Site Inspections. EP A/540/G-91/009, May 1991
(emphasis added).
24JS76.I 7
l'ROTOCOL FOH. DE:n:llMl."il!'iG Wll£1'1l(K ALTER:-.A TF FF F'.n MATF:R(,\L.S ARE; LISTED HAZ . .\.RUOl::, w .;,.::; n:s
• The sole active ingredient ir1 a fonnulat10n.":2
If Potentially Listed Wastes were known to be generated or managed at the Site, furthet
evaluation is necessary to determine whether these wastes were disposed of or
conuningled with the Material (Steps 10 and possibly l l). If Potentially Listed Wastes
were not known to be generated or managed at the Site, then information concerning the
source of Potentially Listed Hazardous Constituents in the Material wiJl be considered
"mtavailable or inconclusive" and, under EPA guidance,u the Material will be assumed
not to be a listed hazardous waste.
12 Management of Investigation-Derived Wastes During Site Inspections, EPA/540/G"91/009, May
1991.
13 EPA guidance consistently provides that, where information concerning the origin of a waste is
unavailable or inconclusive, the waste may be assumed not to be a listed hazardous waste. See e.g.,
Memorandum. from Timothy Fields (Acting Assistant Administrator for Solid Waste & Emergency
Response) to RCRNCERCLA Senior Policy Managers regarding "Management of Remediation Waste
Under RCRA." dated October 14, 1998 (''Where a facility owner/operator mak:cs a good faith effort to
determine if a material is a listed haurdous waste but cannot make such a detennination because
docwncntation regarding a source of contamination, contaminant:, or waste is unavailable or
inconclusive, EPA has stated that one may assume the sow-cc, contaminant, or waste is not hsted
hazardous waste"); NCP Preamble, 55 Fed. Reg. 8758 (March 8, 1990) (Noting that ••it 1s often
necessary to know the origin of the waste to determine whether it is a listed waste and that, if such
docume,itation is lacking, the lead agency may assume it is not a listed waste); Preamble to proposed
Hazardous Waste Identification Rule, 61 Fed. Reg. 1880S (April 29, 1996) {"Facility owner/operators
should make a good faith effort to determine whether media were contaminated by hazardow wastes and
ascertain the dates of placement The Agency believes that by using available sitew and waste-specific
information ... facility owner/operaton; would typically be able to make these determinations. However,
as discussed earlier in the preamble of today's proposal, if information is not available or inconclusive.
facility owner/operators may generally assumf!' that the material contaminating 1/,e "'edia were not
hazardous wastes."); Preamble to LDR Phase IV Rule. 63 Fed. Reg. 28619 (May 26, 1998) ("t\s
discussed in the April 29, 1996 proposal, the Agency continues to believe that, if infonnation is nor
available or inconclusive, it is ge11erally reasonable 10 assume that contaminated .wi/s do not contain
untreated ha:zardo&1.1 was ta ... "); and Memorandum from John H. Skinner (Director, EPA Office of
Solid Waste) to David Wagoner {Director, EPA Air and Waste Management Division, Region Vlf)
rcg;).rding "Soils from Missouri Dio,un S1 tes," dated January 6, 1984 (''The analyses indicate the
presence of a. number of toxic compounds in many of the soil samples talten from various sites.
However. the presence of these to-xicancs in the soil docs not automatically make the soil a RCRA
hazardous waste. The origin of the tox.icants mu.~t be known in order to determine that they arc den ved
from a listed hazardous waste(s). If tlit ~act origin of the 10.iicants is not known. th~ soils cannot be
(footnote continued on next page)
24lB76. l 8
PROTOCOL fOR DETEK;\,'11:',l;'(G \\-'ui,:nu:R AL1'£1l.'i,.,_ H FEED :vt.AT(Rl.ALS AR£ Lcsn:o HALAIWOLS W~TD
If yes. proceed ro Step 10.
If no, procaed to Step 16.
10. WERE LISTED WASTES KNOWN TO BE DISPOSED OF OR
COMMINGLED WITH MATERIAL?
If listed wastes identified in Step 9 were known to be generated at the Site, detemtine
whether they were known to be disposed of or commingled with the Material?
if yes, proceed to Step 12.
Ifno, proceed to Step 11.
11. ARE THERE ONE OR MORE POTENTIAL NON-LISTED SOURCES OF
LISTED HAZARDOUS WASTE CONSTITUENTS?
In a situation where Potentially Listed Wa.sta. were known to have been
generated/managed at the Site, but the wastes were not known to have been disposed. of
or commingled with the Material, detennine whether there are potential non-listed
sources of Potentially Listed Hazardous Constituents in the Material. If not, unless the
State agrees otherwise; the constituents will be asswned to be from listed sources
(proceed to Step 12). If so, the Material will be assumed not to be a listed haz.ardous
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 considered
to be from the listed source(s) ~ based on the relative proximity of the Material to the
listed and non-listed source(s) and/or information concerning waste management 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 I 6.
If no. proceed to Step 12.
12. MATERIAL IS A LISTED HAZARDOCS WASTE.
The Material is a listed hazardous waste under the following circumstances;
(footnote continued from previous pagt.:)
considered RCRA hazardous wastes unless they exhibit one ·or more of the characteristics of ha.7.ardou,;
waste ... ").
24'.1876.1 9
PROTOCOL FOR l)ETF:R\11~!.',(, WH£TH£H ALTERS Ht: Fu:o ,:\1,\T£R.lALS ARE LISTED HAZARIH)lS \\,",\.SID
• If the Material is a process waste and is lmown to be a listed hazardous
waste or to be mixed with a listed hazardous waste (Step 6),
+ [f Potentially Listed Wastes were known to be generated/managed at
the Site and to be disposed of7cornmiugled with the Material (Step l 0)
(subject to a .. contained-out" determination in Step l 3), or
+ If Potentially Listed Wastes were known to be generated/managed at
the Site, were not known to be disposed oflcommingled with the
Material but there are not any potential non-listed sources of the
Potentially Listed Hazardous Constituents detected in the Material
(Step L 1) (subject to a .. contained-out" determination in Step 13).
Proceed to Step 13.
13. HAS ST ATE OF UT AH 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 in 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 in
the Materials
the State of Utah will consider whether it is appropriate to make a contained-out
determination with respect to the Material.
If the Stale makes a contained-out detennil!atio,r, proceed to Step 16.
If the State does not make a contained-out determination, proceed to Step I 4.
14. IS IT POSSIBLE TO SEGREGATE LISTED HAZARDOUS WASTES
FROM OTHER MATERIALS?
24Jll76.l
Determine whether there is a reasonable way to segregate material that is a listed
hazardous waste from alternate feed materials that arc not listed hazardous wastes that
will be sent to rt.JSA's White Mesa Mill. For example, it may be possible to isola.J:e
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
to
"
PROTOCOi, FOR OETt:R."ttl'l'IC WHHHER A.1..TER.'liATE FEED MAT[R1.4.LS ARE LL!i'f£0 H .4./.ARn()l,~ w,,~TO
sampling frequency and exclude mate1ials with respect to which. the increased sampling
identifies constituents which hav~ been attributed to listed hazardous waste.
If yes, proceed ro Szep 15.
lf no, proceed to Step I 2.
JS. SEPARATE LISTED HAZARDOUS WASTES FROM MATERJALS.
Based on the method of segregation determined under Step 14, materials that are Listed
hazardous wastes are separated from Materials that will be sent to the White Mesa Mill.
For materials that are listed hazardous wastes. proceea to Step J 2.
For Materials to be sent to the White Mesa Mill, proceed to Step 16.
16. PROVIDE INFORMATION TO NRC AND UTAH.
ff the Material does not contain any Potentially Listed Hazardous Coll5tituents (as ·
determined in Step 7), where information concerning the source of Potentially Listed
Hazardous Constituents in the Material is ''unavailable or inconclusive .. (as determined in
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. fn such circumstances, fUSA will submit the following
documentation to NRC and the State: ·
• A description of the Source Investigation;
• An explanation of why the Material is not a listed hazardous waste.
• Where applicable, an explanation of why Confinnation/Acceptance
Sampling has been determined not to be necessary in Step 17.
• If Confumation/Acceptance Sampling 1w been determined necessary
in Step 17 , a copy of IUSA, s·: and the Generator's Sampling and
Analysis Plans.
• A copy of Confinnation and Acceptan~e Sampling results, if
applicable. IUSA will submit these results only if they identify the
presence of "new" Potentially Listed Hazardous Constituents (as
defined in Steps 7 and 8).
Proceed to Step 17.
17. ARE SAMPLING RESULTS OR DAT A REPRESENTATIVE?
l~JR7Ci.l
Determine whether the sampling results or data from the Source Investigation ( or, where
applicable. Confirmation/ Acceptance Sampling results) arc representative. The purpose
of this step ) js to detennine whether Confumation and Acceptance Sampling (or
Ll
l'ROHKOL rnR DETER"tlNl~G WUt:THER AI.Tf.R,..;,\Tf. Fuu :V(Xf£R1A1..::i ARE LISTED HA2.ARDOL;s '" ... ::, l"D
continued Confirmalion and Acceptance Sampling) are necessary. If the sampling resu::.,;
or data are representative of all Yfaterial destfacd for the White Mesa Mil~ based on the
extent of sampling conducted, the nature of the Material and/or the nature of the Sim
(e.g., whether chemical operations or waste disposal were known to be conducted at the
Site), future Confinnation/ Acceptance Sampling. will not be necessary. If the sampling
results ~e not representative of aJl Material destined for the White Mesa Milt, then
additional Confim1atioa/Acceptance sampling may be appropriate. Confirmation and
Acceptance Sampling will be required only where it is reasonable to expect that
additional sampling will detect additional contaminants not already detected.. For
ex.ample:
• Where the Material is segregated 'from Environmental Media, e.g., the
Material is containerized, there is a high probability the sampling results or
data from the Source Investigation are representative of the Material and
Confinnation/Acceptance Sampling_ w~uld not be required.
• Where IUSA will be accepting Mat~rial from a discrete portion of a Site, e.g ..
a storage pile or other de.fined ar~ and adequate sampling characterized the
area of concem for radioactive and chemical contaminants, the sampling for
that area would be considered representative and Confirmation/ Acceptance
sampling would not be required. · 1
I
• Where Material will be received from a wide area of a Site and the Site has
been carefully characterized for radioactive contaminants, but not chemical
contaminants, Confirmation/ Acceptan~e sampling would be required.
• Where the Site was not used for industrial activity or disposal before or after
uranium material dispo~ and the Site has been adequately characterized for
radioactive and chemical contaminants, the existing sampling would be
considered sufficient and Confirmation/Acc;eptancc sampling would not be
required. !
'
• Where listed wastes were known to be:disposed of on the Site and the lim.its of
the area where listed wastes I were managed is not known,
Confirmation/Acceptance sampling· would be required to ensure that Listed
wastes are nQt shipped to nJSA (sec Step 14).
If yes, prrx:e«d lo Step 4.
If no, proceed to Step 18.
18. DOES STATE OF UTAH AGREE THAT ALL PREVIOUS STEPS HAVE
BEEN PERFORMED IN ACCORDANCE Wlil11 THIS PROTOCOL?
' . Dctcnninc whether the State agr~ that this i Protocol bas been properly followc:d
(including that proper decisions were made at ;each decision point). The State shail
243876.l 12
l'l(OTuCOL 1:0R OETERMl'ilNC, WHF.TH F.R AL TE:ll..'\AH FEED :VIA 1'£1:<lAl.S ARE usn:o HAZ.>,RD()l:s \\· .>,~TES I ' i
review the information provided by IUSA in Step 16 with reasonable speed and advise
[USA 1f it believes !USA has not properly followed this Protocol in determining that the
Material is not listed hazardous waste, specifying the particular areas of deficiency.
I If thlS Protocol bas not been properly followed by IUSA in making its determination that
the Material is not a listed haz~dous waste, .then !USA shall redo its analysis in
accordance with this Protocol and,li f justified, res'~brnit the information described in Step
16 explaining why tbe Material is not a listed hhzardous waste. The State shall notify l ruSA with reasonable speed if the State still-believes this Protocol has not been followed. I : ,
lfyes, proceed to Step 19. I :, ;
If no, proceed to Step 1. I : i
19. MATERIAL IS NOTALISTE~HAZARDOUS WASTE,BUT
CONFIRMATION AND ACCEPTANCE SAMPLING AIU; REQUIRED.
The Material is not a listed hazardbus waste~ but ~onfirmation and Acceptance Sampling
are required, as determined necess~ under Step 17.
' '
Proceed to Step 20. i j :
! : I
20. CONDUCT ONGOING CONFIRM.A TION AND ACCEPTANCE
2431176.1
SAMPLING. I '. .
I . i:
Confirmation and Acceptance Sampling ·wm icontinue until determined no longer I , necessary under Step 17. Such s'*11pling will be conducted pursuant to a Sampling and
Analysis Plan (''SAP") that speci~es the frequency and type of sampling required. If
such sampling does not reveal any "new'' Potentially Listed Hazardous Constituents (as
defined in Steps 7 and 8), further ~valuation is not necessary (as indicated in Step 7). If
such sampling reveals the presence of "new" constituents. Potentially Listed Wastes must
be identified (Step 8) and evaluat~ (Steps 9 through 11) to determine whether-the new
constituent is from a listed hazarddus waste sourcei. Generally, in each case, the SAP will
specify sampling comparable to t~e level and fre~uency of sampling performed by other
facilities in the State of Utah that dispose of.1 le.(2) byproduct material, either directly or
that results from processing alt~m~te feed ~teri~s.
I 'I
Proceed to Step 7.
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Attachment 1
Summary of RCRA Listed Hazardous Wastes
There are three different categories of Ii sted hazardous waste under RCRA:
• F·listed wastes from non-specific sources (40 CFR § 26/.3/(a)): These wastes
include spent solvents (FOO l-F005), specified wastes from electroplating operations
(F006-F009), specified wastes from metal hear treating operations (F01Q..F012),
specified. wastes from chemical conversion coating of aluminum (F019), wastes from
the production/manufacturing of specified , chlorophenols, chlorobenzenes, and
chlorinated aliphatic hydrocarbons (FO 19-F028), specified wastes from wood
preserving processes (F032-F035), specified wastes from petroleum refinery primary
and secondary oiVwater/solids separation sludge (F037-F038), and leachate resulting
from the disposal of more than one listed hazardous waste (F039).
• K-listed wastes from specific sources (40 CFR § 261.32): These include specified
wastes from wood preservation, inorganic pigment production, organic chemical
production, chlorine productiori, pesticide production, petroleum refining, iron and
steel production, copper production, primary· and secondary lead smelting, primary
zinc production, primary aluminum reduction, ferroalloy production. vetcrimuy
pharmaceutical production, ink. formulation and coking.
' ; I
• P-and U-listttd commercial chemical products (40 CFR § 261.33): These include
commercial chemical products, 'or manufacturing chemical intermediates having the
generic name listed in the ''P" or .. U'' list of wastes, container residues, 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 fom1ulated for commercial or manufacturing use
which consists of the commercially pure grade of the chemical, any technical grades
of the chemical that are produced. or n:iarketcd. and all formulations in which the
chemical is the sole active ingredient. : It do:es not refer to a material, such as a
manufacruring process waste, that contains any!of the (P-or U-listed substances]."1
Appendix VIl to 40 CPR part 261 identifi~ the bazardo4k constituents for which the F-and K-
listcd wastes were listed. ! ! j ;
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1 P-lislcd wasw.. are identified as ''acutely hazardous wastes" ~d arc subject to additional management
controls wider RCRA. 40 CFR § 26L33(e) (1997). U-l'isted wastes arc identified as "toxic wastes." !.Q.
§ 26l.33(f). ;
2 40 CFR. § 26I.33(d) note (1997)_ Ii
24)117C.. l
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Michael 0 . L~:1Vitt
Gc:YCl'TIDI
Dianne R Sidsnn, l'h.O.
(:l.'.f'cu,,vc Duct1or
Denn is R. Downs
State of"' Utal1
DEPARTMENT OF E~VIRON:vtt.:::--:TAL QUALTTY
DIVISION OF SOLID At\D HAZARDOLS WASTE
2~8 North 1460 West r.o. llt\X I t14R!!Cl
Snit L.nkr. Cil)'. Ut:1h 84 l 14-48!!0
[phone]
[phone] Fax
[phone] T (> 0 .
www.tl~q.Slilll!-ULUS Web
Oec1::mber 7, t 999
M. Lindsay Ford
Parsons, Behle and Latim~r
One Utah Center
201 South Main Street
Suite 1800
Post Office Box 45898
Salt Lake City, Utah 84145-0898
RE: Protoeol for Determining Whether Alternate Feed Materials are Listed Hazardous
"'a.stcs
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 Mesa Mill are listed hazardous 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
determinations.
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 th.is protocol cannot be
used as a defense if listed hazardous waste is somehow processed at the White Mesa Mi II.
Thank. you again for your corporation. If you have any questions, please contact Don Vcrbica nl
538-6170.
Sincerely,
~t~ti~a~~ti~t;;etary
Utah Solid and Hazardous Waste Control Board
c: Bill Sinclair. Utah Division of Radiation Control
F.\SHW\HWCJ\DVERBICI\\Wl'\lvliitc111e~~.,11p<1
l.
PROTOCOJi FOR DETERMINING WllETHER
ALTER...~ATE FEED MAfdUALS ARE l)~TED HAZARDOUS WASTES1
i ; . :
N6VEMBER 16; :1999
I j• 1
SOURCE INVESTIGATION.I '. : :
I · : i
Perform a good faith investigationr(a "Source Investigation" or "S1")1 regarding whether
any listed hazardous wastes1 arb lbcated. at the site from which alternate feed material4
(''Material") originates (the "Sit6'')t This investiga~ion will be conducted in confom1ance
~ith EPA guidances and the! e~te?t of info~1ation r~qu.ire~ ~ill vary with the
circwnstances of each case. Fpll?wmg are ex~ples of mvestigattons that would be
considered satisfactory under !EPA guidm1ce and this Protocol for some selected
. . 11 .. s1tuat1ons: t :
• Where the Material is dr has been gene~ated from a known process under the
control of the generatoq: (a) an affidavit, certificate, profile record or similar
document from the den,erator or S1te ¥fanager, to that effect, together with (b)
a Material Safety .data Sheet ("MSDS") for the Material, limited profile
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l This Protocol reflects the procedures t~at twill be follow~~ by an Wlderstancling eet•Neea tAe Ul&h
Di•l'isi0a. 0f Selia anEI-UWl!atdo1:1s Waste, Dep'artmeat ef ~aYiroomeatal Q~&lity("Dl?:Q" er the "State")
aee: International Uranium (USA) Corp~r~tion ("WSA") ; for determining whether altemate feed
,naterials proposed for processing at the Wjhi~e Mesa Mill are; (or contain) listed hazardous wai.tcs. It is
based on current Utah and EPA rules and EP ~ guidance W1de.r;the Resource Conservation and Recovery
Act ("RCRA"), 42 U.S.C. §§ 6901 ct scql llbis Protocol wi,1 be changed as necessary to reflect any
pertinent changes to RCRA rules or EPA gµidance. . i
2 This investigation will be performed by! rtlsA. by the entlJ responsible for the site from which the
Material originates (the "Generator"), orb~ a bombination of ~~e two.
3 Attachment l to this Protocol provides~' a isumniary of th~ I different classifications of RCRA listed
hazardous wastes. I . ;
4 Al temate feed materials that are primary r !intermediate products of the generator of the material ( e.g.,
"green" or ''black" salts) are not RCRA ''secbndary materials'! or "solid wastes," as defined in 40 CFR
261, and ar.e not co_vcre~ by this Protoco.L / ~ . ; i . . .
5 EPA gmdance identifies the followmg sources of site-and waste-specific mfonnahon tbat may,
depending on the circumstances, be cons~dL+cd in such an investigation: hazardous waste manifests,
vouchers, bills of lading, sales and inv~ntory records, matJrial safety data sheets, storage records,
sampling and analysis reports, accident[ reports, site ! ;investigation reports, interviews with
employees/former employees and former O'Qners/opcrators, ;spill reports, inspection report.'! and logs,
permits, and enforcement orders. See e.g., l iFed. Reg. 18805 tApril 29, 1996).
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JU396 l. l I
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l'ROTOCOL FOR D£TF.RM1NING WUETHER ALTtfu"'ATE lfE:£0 MATERIALS ARE L1ST£ll HAT.AROOUS WASTES ii
sampling, or a material conJlosition detem1incd by the generator/operator
based on a process material biiance.
II
• Where specific i.nfonnationli exists about the generation process and
management of the Material~! (a). an affidavit, certificate, profile record or
similar document from the Generator or Site Manager, to that effect, together
with {b) an MSDS for the !Material, limited profile sampling data or a
preexisting investigation perf~bned at the Site pursuant to CERCLA, RCRA
or other state or federal enviro~nental laws or programs.
I.
• Where potentially listed processes are known to have been conducted at a Site,
an investigation considering i:the following sources of information: site
investigation reports prepared l:mder CERCLA. RCRA or other state or federal
envirorunental laws or programs (e.g .. an RI/FS, ROD, RFI/CMS, hazardous
waste inspection report); inteiyiews with persons possessing knowledge about
the Material and/or Site; :uid review of publicly available documents
concerning process activitie~ or the history of waste generation and
management at the Site. I·
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• If I.Oateria} from the same sdurce is being Of has beell accepted for direct
disposal as l le.(2) byproducf material in an NRC-regulatcd facility in the
State of Utah with the consentior acquiescence of the State of Utah, the Source I
Investigation performed by such facility.
11 Proceed to Step 2. 1. ,.
' 2. SPECIFIC INFORMATION OR AGREEMENT/DETER1\1INATI0N BY
RCRA REGUl..ATORY AUTHORITYJTHAT MATERIAL IS NOT A
303961.1
LISTED HAZARDOUS WASTE? :: . --
a. Determine whether specific informatiol from tho Source Investigation exists about the
generation and management of the Mate~al to support a conclusion that the Material is
not (and does not contain) any listed !!hazardous waste. For example, if speci fie
information exi.!Jts that the Material was not generated by a listed waste source and that
the Material has not been mixed with any !iisted wastes, the Material would not be a listed
hazardous waste. I! ..
b. Alternatively, determine whether the appropriate state or federal authority with RCRA
jurisdiction over the Site agrees in writir g· with the generator's detenninatiou that the
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l)ROTOCOL. FOR DF;T£RMlNING WUE'tll,1:-R ALTF.:RNATF. l~EED MA TERIAl,S ARE LISTED HAl.ARDOUS WASTES
3_
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Material is not a listed haiardous waste, has made a .. contained-out" determination6 with
respect to the Material or l~as concluded the Mate~al or Site is not subject to RCRA.
i I ; i1
Ifyes to either question, p,:
1
oceed to Step 3. i 11 I : ,,
If no to both questions, pr,ceed to Step 6.\ . \ ll
PROVIDE INFORMATION TO NRC ~D Ur AH.
i I . : I
If 'fi . r.: • I . ' 11 . th th M . 1 . d d a. spec1 1c m.i:ormanon extsts to suppo~ a cpnc.us1on at e . atena 1s not, an oes
not contain, any listed ~azardous was~e. ~te#ia.tione.l Uranium (UK,\) Gerporatioa
f!IUSA~ will provide a d~cdption of tlie So~c4 Investigation to NRC and/or the State
of Utah Department of Brivironmental Quality, Division of Solid and Hazardous Waste
(the "State"), together wi1th an affidavit explafiiing why the Material is not a listed
hazardous waste. ! i ; j J
b. Alternatively, if the ap~ropriate regula'.tory!au~ority with RCRA jurisdiction over the
Site agrees in writing with the generator'~ dctc~ination that the Material is not a Listed
hazardous waste, makes a bontained-out deterinuiltion or determines the Material or Site
is not subject to RCRA, lliSA will prov1de doclilnentation of the regulatory authority's
detennination to NRC and the State. IUSA(m4~ rely on such detem1ination provided
that the State agrees the coriclusions of th6 regulat6ry authority were reasonable and made I ' . I in good faith. 1
Proceed t.o Step 4.
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6 EPA explains the "contained-out" (ilso Tefen:ed to ~s "c~ntaw ed-in") principle as follows:
In prnctice, EPA has applied ~he contained-inlpt:m~iplt to refer to a process where a site-
specific determination is made that conccnlrations ofhbardous constituents in any given
volume of environmental mJdia are low endugh .to determine that the media does not
"c<mtain" hazardous waste. ·, Typically, these so-call6d "contained-in" [or "contained-' ,> . out"J detenninations do not mean that n'o hazardous constituents arc prcseot in
environmental media but simply that the lconccnl~tions of h:lZaI'dous constituents
I ' II present do not warrant management of the me,dia a~ hazardous waste.
EPA has not, to date, issued ~efinitive goidaJce:to es~blish the concentrations at which
contained-in detenuinations ~ay be made. As noted ~bovc, decisions that media do not
or no longer contain hazaril.ous wuste are! typicall~ made on a case.by-case basis
considering the risks posed by the contaminatl::d medial
63 fed. Reg. 28619·, 28621·22 (May ~6, 1998) (Pbase!N [~D~~reamble).
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JOJ961.l 3 I
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l'ROTOCOL fOK D1tf£R.'"lNING WHETHER ALTF.Rl"I/AT£ FEED MATERIALS ARE L1.S'f£0 HAZAROOr.;S WASTE.S j;
4.
5.
6.
30396l.l
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• l I . ' ' DOES STATE OF UTAH AGREE THATALU PREVIOUS STEPS HAVE I • .
BEEN PERFORMED IN.ACCORDANCE WITH THIS PROTOCOL? : I :!
Determine whether the S:tate agrees that :tliis .frotocol h:is been properly followed
(including that proper decisions were made lat ~ach decision point). The State shall
review the information provided by lUSA in~Step·~ or 16 t}l'OI-Ul:)tly with reasonable speed
and advise !USA if it b'elieves IUSA has I noi properly followed this Protocol in
determining that the Material is not listed h~ardo~s waste, specifying the particular areas
of deficiency. . : \ :1
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If this Protocol has not been properly follow~d b) IUSA in making its determination that
the Material is not a listed hazardous w:i.ste, then IUSA shall redo its analysis in
accordance with this Proto<?ol and, if justified, [resµbmit the information described in Step
3 or 16 explaining why the Material is not ~ li~ted hazardous waste. The State shall
notify IUSA f'F0m~Hy with reasonable speed ~f the State still believes this Protocol has
not been followed. l 1· .:i i "
If yes, proceed to Step 5. ; .:!
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If ,to, proceed to Step J. ; i )
MATERIAL IS NOT A LISTED HAZARDOUS WASTE. ~-t ! •
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The Material is not a listed hazardous was~e and no further sampling or evaluation is
necessary in the following circumstances: i :[j
I : • Where the Material is detemrinedlnot to be a listed hazardous waste
based on specific information aboµi th~i generation/management of the
Material OR the. appropriate RCRA.! regulatory authority with
jurisdiction over the Site agrees ,it~ th~ generator's determination that
lhe Material is not a listed HW, m~es.~ contained-out determination,
or concludes the Material or Site ~s pot:~ubject to RCRA (and the State
agrees the conclusions of the reg~atoI]
1
. authority were reasonable and
made in good faith) (Step 2); or j I j
+ Where the Material is detem1ined,npt tq be a listed hazardous waste (in
Steps 6 throllgh 11, 13 or 15) an.diCfmfpmation/Acceptancc Sampling
arc detennined not to be necessary (un4,er Step 17).
i I ·.: . .
IS MATERIAL A PROCESS WASTE KNO~ TO BE A LISTED
HAZARDOUS w ASTE OR T.O 'BE MIX.ED WITH A LISTED
HAZARDOUSWASTE?: II I :;I
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Based on the Source Investigation, detenniµe ~~ether the Material is a process waste
known to be a listed hazardous waste or to be thlxed with a listed hazardous waste. If the
Material is a process waste and is from a iiJtedi hazardous waste source, it is a listed . I .'.
: • !!
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l)ROTOC"OI, FOR DETERMlNlNG WHETHER A..LT.l::.K."lA"fl:'. FEF:Q MA.HRIALS ARE LlSTED HAZARDOUS WASTES ' .
, I
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haza(dous waste. Similarly, if the Material i)s a proc~ss waste and has been mixed with a
listed hazardous waste, it is a listed :hazardousiwaste under the RCRA ''mixture rule." If
the Material is an Environmental Medium, 7 it ciannot be a listed hazardous waste by direct
listing or wider the RCRA. "mixture rnle."8 I lf the Material is a process waste but is not
known to be from a listed source or· to be mix~d with a listed waste, or if the Material is
an Environmental Medium, prciceed to SteiJ,s 7 t~ough 11 to detenuine whether it is a
listed hazardous waste. ·;
Jfyes, proceed to Step 12.
If no. proceed to Step 7.
. . .
7. DOES MATERIAL CONTAI~ ANY POlf ;N1:'~LY LISTED
HAZARDOUS CONSTlTUE~S? I ! .;
Based on tbe Source Investigation (and, if ~pplicable, Confirmation and Acceptance
Sampling), determine whether the Material bohtains any hazardous constituents listed in
the then most recent version of40 CFR 26 ( !Appendix VII (which identifies hazardous
constituents for which F-and K-listed wastes '\ivere listed) or 40 CFR 26l.33{e) or (t) (the
P and U listed wastes) (collectively "Potenti~ijy Listed Hazardous Constituents"). If the
Material contains such constituents, a soured ~va.luation is necessary (pUJSuant to Steps 8
through 11 ). If the Material does n.Q! ~Jntain any Potentially Listed Hazardous
Constituents, it is not a listed h~ardous 1,aste. The Material also is not a listed
hazardous waste if, where appli~able, Con.fi~atiqn and Acceptance Sampling results do
not reveal the presence of any. "new" Pot~ntially Listed Hazardous Constituents (i.e.,
constituents other than those :that have JJ already been identified by the Source
Investigation (or previous Confinuation/A~c~ptance Sampling) and determined not to
originate from a listed source). j
If yes, ptoceed to Step 8.
If no, proceed to Step 16.
•' .,
7111e term "Environmental Media" mcans·soils, ground o~ surface water and sediments.
8 The "m1xture rule" applies only to. mixtures ·of listed h.h.ardous wastes and other "solid wastes.'' SC?e
40 CFR § 261.3(a)(2)(iv}. The mixture rule does j ~ol :ipply to mix.tures of listed wastes and
Environmental Media, because Environmental Media a :c not "solid wastes" under RCRA. See 63 Fed. i I ' Reg. 28556, 28621 (May 26, 1998). · I :
i
30396\.l 5
PROTOCOL FOR DETERMINING W1n;THER ALTKRNAT!i. Fr,~I) MATERIALS AR£ LISTF:.O HAZARDOUS w....sns
8.
9.
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E I·
. ' IDENTIFY POTENTIALLY LISTEO WAST ES. ; • I
• I
Identify potentially listed hazardbus wastes: ("Potentially Listed Wastes") b.i.sed on
Potentially Listed Hazardous Consiituents detected in the Material, i.e., wastes which are
listed for any of the Potentially Listed Hazardous Constituents detected in the Material, as
identified in the then most current version ,of 40 CFR 26 l Appendix VH or 40 CFR
261.33(c) or (f).9 With respect to !Potentially Li'.sted Hazardous Constituents identified
through Confinnation and/or Acceptance Sampling, a source evaluation (pursuant to
Steps 8 through 11) is necessJry only for ·!"new" Potentially Listed Hazardous
Constituents (i.e., constituents othcir than those that have ~ already been identified by
the Source Investigation (or previous Confumation/Acceptance Sampling) and
determined not to originate from a listed soW'Ce). : ' .
Proceed to Step 9. \:
WERE ANY OF THE POTENTlkL Y LISTED WASTES KNOWN TO BE
' I
GENERATED OR MANAGED AT SITE? !
1. ,,
Based on information from the Source Investigation, detemrine whether any of the
Potentially Listed Wastes identifi~d in Step ·8 are known to have been generated or
managed at the Site. This detecrni~ation involves !identifying whether any of the specific
or non-specific sources identified id. the K-or·F-lists has ever been conducted or located
at the Site, whether any waste fro~ such processes has been managed at the Site, and
whether any of the P-or U-listedi commercial chemical products has ever been used,
spilled or managed there. In pa~cular, this determination should be based on the
following EPA criteria: ! ;
i Solvent Listings (F00I-F005) !
Under EPA guidance, "to d¢temtlne if solvent constituents contaminating a waste
are RCRA spent solvent FOQ1-F005 wastes~ the [site manager] must know if:
I• ·. I I + The solvents are spent ~d cannot; be jreused without reclamation or
cleaning. 1. · 1
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• The solvents were used exclusively/or their solvent properties.
I ~
• The solvents are spent ~ixtures and blends that contained, before llse,
a total of l O percent o~· more (by vo/ume) of the solvents listed in
FOOl, F002, F004, and F:oos.
:i : ~
9 For example, if the Material contains tetrac~loroethylene, h1e following would be Potentially Listed
Wastes: FOOl, FOOZ, F024, K019. K020, K150;K15 Lor U210: See 40 CFR 261 App. VII.
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PROTOCOL. !"OR DETERMINlNG WHETHER AtTF.:RNA'fl:': FEED MATER[ALS AR£ L1sn::o fiAZA{U)OLIS WASTtS
I i:
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If the solvents contained in the (wastes] are RCRA listed wastes, the
' I . ' [wastes] are RCRA hazardous waste.· W:11en the [site manager] does not
have guidance infonn~tio·l1 on the: uiie of the solvents and their
characteristics before ust tHe [wastes] 1cati.not be classified as containing a
listed spent solvent"10 i Thb person perf~rrning the Source Investigation
will make a good faith ~ffoh to obtain irifom1ation on any solvent use at
the Site. If solvents were u~ed at the Sitb. general industry standards for
solvent use in effect at the time of use W:m be considered in detcnniuing
whether those solvents cont~ined l O per~eht or more of the solvents listed
in FOO 1, F002, F004 or FOOS . ; 11·:
. I ' ·' K-Listed Wastes and F-Listed!Wastes Other Than F001-F005
1 .I ! !• Under EPA guidance, to determjne ~hether K wastes and F wastes other than
F001-F005 are RCRA listeil wastes, piergenerator "must know the getteration
process infonnation (abciut Jach waste contained in the RCRA waste) described in
the listing_ For example, fo~ [wastes] to be identified as containing KOOl wastes
that are described as 'b~tto~ sediment s.l~dge from the treatment of wastewaters
from wood preserving processes that use breosote and/or pentachlorophenol,' the I I I I• [site manager) must know the manufactliri.11g process that generated the wastes
(treatment of wastewateis frpm wood preJ~rving process), feedstocks used in the
process (creosote and pentachlorophenolt and the process identification of the
wastes (bottom sedimentlstudge)."11 .! 11 . ' I I
P-and U-Listed Wastes ; : : : i Ii
I I ' EPA guidance provides ;thai ''P and li v.;astes cover only unused and unmixed
conunercial chemical prod~cts, particularly spilled or off-spec products. Not
every waste containing a P ;or U chenp.c~ is a hazm-dous waste. To determine
whether a [waste] contains f P or U wast~. the [site manager] must have direct
evid:nce of product us~ .. ~ particu1¥, ~e [site manager] should ascertain, if
possible, whether the ch~rrucals are: j ;
• Discarded (as described ih 40 CFR i61 l2(a)(2))-
+ Either off-spec co~ercJal productl or:a commercially sold grade.
·1 .
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10 Mat1agement of Investigation-Derived ~astes During s ite lilspections, EPA/540/G-91/009. May 1991
(emphasis added). : I . : ·1 1!
1 . . 1.
L Management oflnvcstigation-Derived Wastes During S#e Inspections, EPA/540/G~91/009, May 1991
( emphasis added). · I'.
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L'ROTOCOr.. FOR DF.T£1.t.'1JNING WHF;THER AI.TER."l'A.TE FEED M,\TF.RIALS AIU: L1sn:o HAZAP.DOUS WASTES
I .j :;:
t j]; ., . ,,
• Not used (soil contamiu~ted ~ith. spil:1:·ed unused wastes is a P or U
waste). i I . j:
+ The sole active ingredient in a fommlation. "12
: ! J
[f tl1e afl6'·"*'Bf to the ques~n m ~6ft6Jl iJ yes, I~1?otentially Listed Wastes were known
to he generated or managed at th~ Site,! furtherJ evaluation is necessary to determine
whether these wastes were disposec;i of or comnungled with the Material (Steps 10 and
possibly 11). If !:he &BS'Ner i5 noJ if Potentially! Listed Wastes were not known to be
generated or managed at the Site, tilten informatidn concerning the source of Potentially
Listed Hazardous Constituents in I the Matclialj will be considered "unavailable or
inconclusive" and, under EPA guidance, 13 !the Material will be assumed not to be a listed
I hazardous waste. I
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12 Management of Investigation-Derived W~stes During Site [nspcctions, EPA/540/0-91/009, May
., I I 1991. . I ;.
13 EPA guidance consistently provides that, ~here i:hrormatibn concerning the origiri of a waste is Rat
!ill.available 01· inconclusive, the waste may b6 assumed not ·~o be a listed hazardous waste. See e.g.,
Memorandum from Timothy Fields (Acting ,!Assistant AdniJinistrator for Solid Waste & Emergency
Response) to RCRA/CERCLA Senior Policy ¥anag9r~ ~eg~~ng '4Managvmcnt of Remedi~tion Waste
Under RCRA," dated October 14, 1998 ("Wh~re a fac1hty o~er/operator makes a good faith effort to
determine if a material is a listed h8.2ardow! w~tJ but caimot make such a determination because
documentation regarding a source of coniamination, cohtaminant, or waste is unavailable or
inconclusive, EPA has stated that one may ~ssurne the sohrce, contaminant, or waste is not listed
hazardous waste"); NCP Preamble, 55 Fed! Reg.: 8758 (March 8, 1990) (Noting that ''it is often
necessary to know the origin of the waste tol determine whbtber it is a listed waste and that, if such
docw11entatio11 is lacking, the lead agency may assu~e it is ~ot a listed waste); Preamble to proposed
Hazardous Waste Identification Rule, 61 Fed1! Reg. '18805 (fpril 29, 1996) ("Facility owner/operators
should make a good faith effort to determine wf ether!mcdia \l{ere contaminated by hazardous wastes and
ascertain the dates of placement. The Agenc! beliet es that .~Y using available site-and waste-specific
infonnation ... facility owner/operators would!~icaHy be able to make these determinations. However,
as discussed earlier in the preamble of today' J prop~sal, if i~Jormation ls not available or i11conclusive.
facility owner/operators may generally assuJie tlrat tJte nuiterlai contaminating the media were not
hazardous wastes."); Preamble to LOR PhJsc IV !Rule, 63 Fed. Reg. 28619 (May 26, 1998) ("As
discussed in the April 29. 1996 proposal, th~ Agenhy contihues to believe that, if information is not
available or inconclusive, it is generaily reasbnabfe: to assuine that contaminated soils do not contai11 l ; .,.
urrtreo.ted hazardous wastes ... ''); and Mem?randw;n from ,!olm H. Skinner (Director, EFA Office of
Solid Wi1ste) to David Wagoner (Director, EPA Air and yaste Management Division, Region VU)
regarding "Soils from Missouri Dioxin Site1s," dated Janu;ary 6, 1984 ("The analyses indicate the
presence of a number of tox.ic compounds :lin many of tiJe soil samples taken from various sites.
However, the presence of these toxicants in · the sciit docs hot automatically make the soi.I a R.CRA
(footnote continued on next page) : ·
I
ol
l'ROTOCOL FOR 0ETERMINl~G WHETHER ALTERNATE J:<"£.ED.'.\1A.TERlALS All£ L1S'f£l) IIAZAJWOt.:.S WAS'ft:S
10.
11.
12.
ff yes, proceed to Step JO.
If 11.0, proceed to Step I 6.
:.
ji
:'
1:
I•
I, I; i •: .:
I.I if
Ji, ~[ t ., ~ '! i I! . ll
. 1.1: :Ii
WERE LISTED WASTES KNOWN TO ~E DISPOSED OF OR
COMMINGLED WITH MATERIAL?, ri ii I, I ,:
If listed wastes identified in Step ~ wenhJI~wn![to be generated at the Site. detennine
whether they were known to be disJ·osed ~f & coriuuingled with the Material?
. I: ! t: 11 If yes, proceed to Step I 2. : i t t
If no, proceed to Step lJ. I I 1; I!
ARE THERE oNE oR MORE PbTENTFAL JoN-LISTED souRcEs OF
LISTED HAZARDous WASTE lcoNsrrtuFiNTS?
: !:i }
In a situation where Potential, y Listcl:i. Wi
1
kstes were known to have been
I I• • generated/managed at the Site, but jthe wa'.st~s we~c not kttown to have been disposed of
or corruningled with the Materia~ deteimllie Jrbether there are potential non-listed
sources of Potentially Listed Haza.r;dous Co~stitu~nts in the Material. If not, unless the
State agrees otherwise, the const~~uents l ~~ll b~ a.ssumed to be from listed sources
(proceed to Step L2). If so, the 1\1ateriat ~11 bJ ; assumed not to be a listed hazardous
waste (proceed to Step 16). Notwitbstandi.ng~ithe J~istence of potential non-listed sources
at a Site, the Potentially Listed Hazk.rdous,C~ostitiients in the Material will be considered
to be from the listed source(s) if. ~ased ~n fhc rdtative proximity of the Material to the
listed and non-listt,d source(s) ancLfor infoniratiod concerning waste management at the
Site, the evidence is compelling tba~ the liste~ so~ce(s) is the source of Potentially Listed
Hazardous Constituents in the Material. t:
·1
If yes, proceed to Step 16. 'I
If no, proceed to Step 12. Ii I
MATERIAL IS A LISTED HAZrO~~i~ A1TE.
The Material is a listed hazardous waste undJ} the i ollowing circwnstances: . . ' ~, J:
(footnote continued from previous page) ' : · i1 I;
' I ' jl • I •: '
: •I : . ' .
hazardous wast~. The origin of the toxicants tfiust be: lcrjown fu order to determine that they are derived
from a listed hazanlous waste(s). ff the ~act: origin'.o.Jif!~"e t~xicants is not lmow,1, the soils cannot be
considered RCRA hazardo"s wastes unless t11Jy exlu"bit ' 11e ~} more of the characteristics of hazardous
wa11te ... "). j' : .! 1li
. ; !1 ':
. fl!: ,;
I i! I I I
9 1 ll :J
303961.\
I
I ..
I
PROTOCOL rOR 01.TER~UNIN"G Wll£TH.£K AL"f(IUIIAT F. FEED MAl;ERIAlS ARE LrSTED HAZARDOUS WASTES . ·I
:·· :!!
+ If the Material is a process waste and i~ known to be a listed hazardous
waste or to be mixed with a listed bazatdous waste (Step 6),
,.: !Ii
• If Potentially Listed Wastes' w~rc known to be actually
generated/managed at the Site and. to ~·e disposed ofi'commingled with
the Material (Step 10) (subject to a "~ontained-out" determination in
Step 13), or :: ii
• If Potentially Listed Wastes· weie known to be aGtually
generated/managed at the Site, we~f not known to be disposed
oflcorruningled with the Material but there are not any potential non-
listed sources of the Potentially [isted Hazardous Constituents
detected in the Material (Step 1 l) '(subject to a "contained-out''
determination in Step 13).
Proceed to Step 13.
13. HAS STATE OF UTAH MADE A CONTAINJ;p-OUT DETERMINATION.
14.
30J961.1
I
If the Material is an Environmental Mcdiwnt.and; :
• the level of any listed waste co11stituen1s in the Material is "de minimist' ; or
• all of the listed waste constituents or ci~~sses thereof are already present in the
White Mesa Mill's tailings ponds as al:result of processing conventional ores
or other alternate feed materials in coJcentrations at least as high as found in
the Materials I:
the State of Utah will consider whether it is 1
1
1.a.ppropriate to make a contained-out
detennination with respect to the Material. j
If the State makes a co11tained-or,t determination, proceed to Step J 6.
If the State does not make a contained-out detennt iatiori, proceed to Step 14.
~~;;~~:iE~~=;ATE LISTED rZARDOUS WASTES
Determine whether there is a reasonable way lo segregate material that is a listed
hazardous waste from alternate feed materials that are not listed hazardous wastes that
will be sent to IUSA's White Mesa Mill. For hample, it ma.y be possible to isolate
material from a certain area of a remediation site a!hd exclude that material from Materials
10
I;
i
I 1
..
l
j' .,
I.
PRO'fOCOt. FOR DETF:RMIN.i'«, WHETHEK ALTl!.l<.~A'I £ FEED Mi\TF.:RIAJ .. S ARE LISTED HAZARDOUS WAST~S
:H : i:
that will be sent to the White Mesa Mill. Alternatively, it may be possible to increase • !I
sampling frequency and exclude materials with f.~spect to which the increased. sampling
identifies constituents which 11ave bee11 attribJte&.to listed hazardous waste.
If yes, proceed to Step 15. '. II;
lf110, proceed to Step 12. i 1:
15. SEPARATE LISTED HAZARDOUS WASTES FROM MATERIALS.
I 'Ii Based on the method of segregation detenni1~edl}mder Step 14, materials that are listed
hazardous wastes are separated from Materials th;t will be sent to the White Mesa Mil].
! !,,
For materials that are listed hazardous wastes, pr,pceed to Step 12.
: ,11
For Materials to be sent to the White Mesa M~ll. kroceed ta Step 16.
i ii:
16. PROVIDE INFORMATION TO NRC AND UTAH.
17.
303',161.I
i ~;
If the Material does not contain any Potentia;l)y Listed Hazardous Constituents (as
determined in Step 7), where in.formation con4ming the source of Potentially Listed
Hazardous Constituents in the Material is "unavailable or inconclusive" (as determined in
Steps 8 through 11 ), or where the State of Ut~ has made a contained-out determination
with respect to the Material (Step 13), the Materil l will be assumed not to be (or contain)
a listed hazardous waste. In such circum~tari~es, UJSA will submit the following
docamentation to NRC and the State: · j;:
• A description of the Source fnvestikaribn;
I f • An explanation of why the Material islnol a listed hazardous waste.
I t
• Where applicable, an explanation o~ why Confirmation/Acceptance
Sampling has been detennined not Ito ~c necessary in Step 17.
• ff Confirmation/ Acceptance SamphnJj has been determined necessazy
in Step 17 • a copy of IUSA's an.cf the Generator's Sampling and
Analysis Plans. I f:: ' r
• A copy of Confinnation and ! Aclccptance Sampling results, if
applicable. IUSA will submit these [results only if they identify the
presence of .. new" Potentially lj..ist~ Hazardous Constituents (as
defined in Steps 7 and 8). 1j1
Proceed to Step 17.
I·,
I iJ.
ARE SAMPLING RESULTS OR DATA REPRESENTATIVE?
Determine whether the sampling results or ~Ja Lm the Source Investigation (or, where
applicable, Confinnation/Acceptance Samplirig r~sults) are representative. The purpose
11
.! I
l'ROTOCOL FOR 0ETERMJ:-l1NG WHETHER ALURN/\TF, FF.eo M/\T;€Rl/\t.S ARF. LISTED R ,\.7.AROO\iS WASTES
303961.l
'.j ;
. ~ i
of th.is step ) is to detenuine whetller Gpnfirmation and Acceptance Sampling (or
continued Continnation and Acceptance Sarµpling) are necessary. If the sampling results
or data are representative of all Material de§tinecil for the White Mesa Mill, based on the
extent of sampling conducted. the nature o:f the I Material and/or the nature of the Site
(e.g .• whether chemical operations or waste:!disp~sal were known to be conducted at the
Site), future Confirmation/Acceptance Samj}ling ~vill not be necessacy. If the sampling
results are not representative of all Material destined for the White Mesa Mill, then
additional Confirmation/ Acceptance samplthg rriay be appropriate. Confirmation and
Acceptance Sampling will be required o~ly .J...here it is reasonable to expect that
additional sampling will detect additional/ con~aminants not already detected. For
example: !I I • I
• Where the Material is segreg~ted from Environmental Media, e.g., the
Material is containerized, there i~ a lugh probability the sampling results or
data from the Source Investiga~ion f e rcprcsentati ve of the Material and
Confirmation/ Acceptance Samplihg would not be required.
• Where IUSA will be; accepting Jaterilt from a discrete portion of a Site, e.g.,
a storage pile or other defined ax;ea, aild adequate sampling characterized the
area of concern for radioactive and c~emical contaminants, the sampling for
that area would be considered tepresentative and Confinnation/Acceptance
sampling would not be required. ·i [
• Where Material will be received1,fronl a wide area of a Site and the Site has
been carefully characterized forl radi~active contaminants, but not chenucal
contaminants, Confirmation/ Acc~ptanqe sampling would be required.
• Where the Site was not used for ~nduJtrial activity or disposal before or after
uranium material disposal, and tlie Site has been adequately characterized for
radioactive and chemical co~nahts, the existing sampling would be
considered sufficient and Confiimatien/ Acceptance sampling would not be
required. . :J I
• Where listed wastes were known to beldisposed of on the Site and the limits of
the area where listed wistes I were managed is not known,
Confirmation/ Acceptance samp~1g ~ould be required to ensure that listed
wastes are not shipped to IUSA (~ee S~ep 14).
lfyes, proceed to Step 4. :I !
If no, proceed to Step 18.
i
I
:1 .,
'I
• I
12 i
'
. I
PROTOCOL fOllDETERMINING WHETHER AL TERNA.TE FEED MA'l'RRlALS ARE LISTED HAZA.ROOUS WASTES
;[
18. DOES S1ATE OF UTAH AGREE THAT .~LPREVIOUS STEPS HAVE
BEEN PERFORM.ED IN ACCORDANCEIWITHTHIS PROTOCOL?
I
Detenuine whether the State agrees that this Protocol has been properly followed
(including that proper decisions were madd at each decision point). The State shall
review the infom1ation provided by IUSA in ;Step 16 preHttJtly; with reasonable speed and
advise IUSA if it believes IUSA has not properly followed this Protocol in detemiining
that the Material is not listed hazardous ;waste, specifying the particular areas of
deficiency. !
If this Protocol has not been properly follow~d by IlJSA in making its determination that
the Material is not a listed hazardous waste, then IDSA shall redo its analysis in
accordance with this Protocol and, if justifie~, resubmit the information described in Step
16 explaining why the Material is not a list~d hazardous waste. The State shall notify
IUSA fff6fflf'tlY with reasonable speed if the State still believes this Protocol has not been
I followed. .j
If yes, proceed to Step 19. I
If 110, proceed to Step 1. ·j
19. MATERIAL IS NOT A LISTED HAZARDOUS WASTE, BUT
CONFIRMATION AND ACCEPTANCE SAMPLING ARE REQUIRED.
The Material is not a listed hazardous waste,lbut Confirmation and Acceptance Sampling
are required, as determined necessary under $tep 1 7.
l
Proceed to Step 20. I
20. CONDUCT ONGOING CONFIRMATION AND ACCEPTANCE
SAI\iPLING. I
I
Confinnation and Acceptance Sampling {vill continue until determined 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 reveal any "new" Pbtentially Listed Hazardous Constituents (as
defined in Steps 7 and 8), further evaluation! is not necessary (as indicated in Step 7). If
such sampling reveals the presence of"new"i constituents, Potentially Listed Wastes must
be identified (Step 8) and evaluated (Steps ? through 11) to detennine whether the new
constituent is from a listed hazardous waste ~ource. Generally" in each case, the SAP will
specify sampling comparable to the level an'.d frequency of sampling performed by other
I facilities in the State of Utah that dispose of1 l le.(2) byproduct material, either directly or
that results from processing alternate feed m~teriafs .
. I
Proceed to Step 7. .;
I
·1
, .,
i I Attachment l i
Summary of RC.RA Listed Hazardous Wastes
I I .
There are three different categories of listed i1azardous waste under RCRA: .
• F-listed wastes from IIOn-specific sources (40 CFR § 261.31 (a)): The.se wastes
include spent solvents (F001-F005), s.pJcified wastes from electroplating operations
(F006-F009), specified wastes from metal heat treating operations (FOLO-FOl2),
specified wastes from chemical 'conversion coating of aluminum (FOI 9), wastes from
the production/manufacturing of spe~ified chlorophenols, chlorobenzenes, and
chlorinated aliphatic hydrocarbons (FO l 9-F028), specified wastes from wood
preserving processes (F032-F035), specified wastes from petroleum refinery primary
and secondary oil/water/solids separation sludge (F037-F038), and leachate resulting
from the disposal of more than one listed hazardous waste (F039).
• K-listed wastes from specific sources (40 CFR § 261.32): These include specified
wastes from wood preservation, inorglmic pigment production, organic chemical
production, chlorine production, pesticide production, petroleum refining, iron and
steel production, copper production, primary and secondary lead smelting, primary
zinc production, primary alwninum reduction, ferroalloy production, veterinary
pharmaceutical production, ink fonnulation and coking.
• p. a,id U-listed commercial chemical P,roducls (40 CFR § 261.33): These include
commercial chemical products, or manufacturing chemical intermediates having the
generic name listed in the "P" or uU'' list of wastes, container residues, and residues
in soil or debris resulting from a spill o'f these materials.• .. Toe 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 fom1ulations 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 s1.1bstances]."2
Appendix VII to 40 CFR part 261 identifies the hazardous constituents for which the F-and K-
li sted wastes were listed. · ·
.. . '
I
l P-listed wastes are identified as "acutely hazardous ·wastes" and are subject to additional management
controls under RCRA. 40 CFR § 261.33(e) (1997). U-ilisted wastes are identified as "toxic wastes.: Id . . I § 261.33(£). : : ·
Z 40 CFR § 261.33(d) note (1997).
Protocol for Determining if Alternate Feed Material is a Usted Hazardous Vvaste
8-
I
·--
:.'c/lt,J!'JONS
,, •• 1l•u•> 1:t•'5-'1'1\)ISI,... r.,,., ~ l1:•p,;iy1••Z:f\
a_
~c .. nr;e l,.,,,.ishg<Jlk)r,
I••,;. ot:l10o:"I A',ili5.
Rl e>istw",g <YJ•ir.c·;
dn~•mhotions. 01
o·r1.r'!1 co·1~s ,.-~("t
jn'o1rrotfc" 01 S:JH"'I·
oln9 0010 lr-::m
,-:,,_-..,e1ok~I
,., 1!•-iJ t!.J1,,i~i,;oJ,1~1~-~""P~fX;.¥.!"'J~:::1
l •' .-,~11:J <:t 'l/hrh• :Ag,10 •1Al
i1>".(°:' • W\ !i() I"-"!.\ •., J.":"15,° (:J:l:D\'l)'.~1.:l
pro• o,p,,,:"ti
fJ
:k.l"IC',\.TI 1101 10 be,
o, rx"'·:,11 er.:, L\lec, t<,•, on o 11::s ,eo-Jorur,·
c;v1hr, ,ly .,_,. n ncl!A tulSdc 1'Cn a,..,, s~ .. o;;,<IP.d ...ir, Qen,,,o·,~·•
O!l~rr-,ncrt10., tlwJI Mc!<!dol tS r,ol !$l-
ed 11',1'. rn:,,:h o ·con1orec1 oul'
oe:.,.,rlrralel' Cll d3le1
rrlnr.d I~ t.lQ!e,OI o,
!tl'ff ii noi sut:Cect
~n OCA'l\1
II YfS -··-······L_ __ _
11 ·a.· pr01,ida lo NllC ordtc:7 Ulm:
• SI • Aifldo·,il ti'( \l,ISA O! Gene,o!Of
e.,ploin·ng ·...nr nol 11Stecl HW
Ir 'b: prOlllde lo tlOC o,d,'o, utoh:
• L"..x:u,11a11!cJ~J1 110"11 ,egl)olory
oulhoril't
1t. 1,t1!f•• ,·St:~ · Ur:•.:t"•t~~t;.11<.Jl·,1.,.Jl'!MelOMil
ir-,.,•,f' · "• ~ r ! 1:11,} IJ Af•:"l\"!IS /l JU
,·, ·,,1:h 11) 1:\1r; ... .,1 )1olo ~JC-..<•n.strh.«1ls"' Ccr.JMU!!ols.
h;lf'tl -••«)Cl U 7,". /Ip(: •/.I Ol 11>;: ba;G (1;1 lslrQ
r, ,,rr-<laul ,,,,,.,., odn -40 C:Hl ~61.JJ(r.l ~1 lrl (P
<." q ,..~ISIM:I , , .,,.,,~:it, , "'"°~ .. l-l:.i.."ClJ001li ,oall!< .. hl:;h 01e
1L~i, ... 1 h~ r.,<rf ol n,-~ llited 1lor:, 1inu~ C'".Jl'l•til\..e")."J
< ~')r,"'(' '-ld,, n-e >.tct.cm.:JI 11:~111:on, .. •. C~li11rn1c•1
.-,, A· rep,;-,,o, S.-.ll"OMI as oentr c<l m ,I() CHI
76 1 '<.iJ\!I ·~ \'' ~J (.HI 761 33Jr?j r~ 111.
r ......... ,,, .. -Ct1l1"1'<nf"Y'•b>e '<.Jr ttM.1:'~ll..;,tl)Y.,..,U::h
•.1, 1P,?trfo p1 • JIP.I.
i •:,,, rr#~,,.u,,'~•-' ~.,....-~ .,...,.Jft:!' u"d s....~n .. irds
.,
D/ D
Ooas -· -~-r.110l11,..,1 -J
conlorr, (:'\V YES.~lderi•fl•l,lol l'olenflcrl·; lls'.eo Po1en'ccil·f
Homrdous I ,.
II -----l'rCNlde lo NOC ord/c, llto!i:
' SI • 1::,p'ono'l'Dl ""1',' not r,!ed
• w.s,opp!ccb'!!)
, Contl<tnofl001/Acc1tplOl'lce
Sorrl;)lrlg Resulh 411 o_pc,lfco-
t)l!!I
YES
NO
ConslilL-erJ~? tilled ~·o~lm
tID
fl
CondlJCI ongoing
Conrilmo1ion and
Accep!once
Somp,r,g end use
re:suilS 10 reevo'uo!e
wt1e1her Mo!B1(::iis
ore listed hazardous
v,asle~ ,
Se()ololg ll~"d
Ho10rc-::1.·~ \\';)Sles
1,cn• ott·,;;< t.1::ilet;·:i', HW
ATTACHMENT4
Review of Chemical Constituents in Silmet 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: April 18, 2019 -------------
Re: Review of Chemical Constituents in Silmet
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 NPM Silmet OU's ("Silmet") Uranium
Material (the "Uranium Material"), also referred to as the residue or Naturally-Occurring
Radioactive Material ("NORM") residue, to be transported from the Sillamae, Estonia facility,
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 ("the Mill") State of Utah Radioactive Materials License No. UT1900479 ("RML") 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 0.14 to 0.35 dry weight percent natural
uranium (0.17 to 0.41 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 di_ligence 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 system are provided in a separate memorandum.
2.0 Site History and Background
The Silmet Sillamae, Estonia facility (the "Facility") currently operates a niobium and tantalum
production plant. The Facility is located on a property that formerly contained a shale oil
production plant from 1927 to 1940. A uranium production pilot plant was constructed on the
site in 1944, following the Soviet Union's occupation of Estonia. The Facility produced uranium
oxides from local shale ores from 1944 through 1952. The Facility subsequently began receiving
other uranium-containing ores in 1952 and continued to produce uranium oxides until uranium
production ceased in 1990. In 1970, concurrent with the uranium operations, the plant began
receiving loparite ores and began the recovery of niobium and tantalum in one process area, and
rare earths in a separate process area. After 1990, the plant no longer received loparite ores, and
began to process columbite and tantalite ore residue concentrates for niobium and tantalum
production. No other processing activities, other than the current niobium and tantalum recovery
operations, have occurred at the site since 2000. Niobium and tantalum, recovery continues to
the present time. A chronology of the site history is listed below.
1927-1940 A. Nobel established a Shale Oil production factory, which was destroyed during
1944
1946-1952
1952-1970
1970
1970-1990
1988-1990
1990-1997
the Second World War
The Soviet Union occupied Estonia and began restoration of facilities, with the
aim of producing uranium from local shale ore
Pilot production of uranium from local shale ore
Processing of various uranium-containing ores to produce uranium oxide
Start of loparite ore processing to produce niobium (Nb), tantalum (Ta) and rare
earth element concentrates ('REE')
Processing of loparite to produce niobium and tantaluml 982-1988
Production of reactor grade enriched uranium products
Soviet occupation in Estonia ended and uranium production stopped
Facility reorganization as State owned company
1990-present Processing of columbite and tantalite concentrates to produce niobium and
1997
1999-2009
tantalum
Private Company established for Nb, Ta and REE production
Decommissioning of the former radioactive tailings pond. (Material from this
pond is NOT included in the Uranium Material.)
2000 to present Silmet begins accumulating Uranium Material in warehouse
2000 to present Niobium and tantalum recovery is the only operation on site.
The Uranium Material results specifically from the plant area and process operation which
recovers niobium and tantalum, as discussed below. It does not include residuals from oil shale
production, from uranium production or enrichment, rare earth recovery, or from other current or
previous operations at the Facility. The Uranium Material does not include any material from the
former radioactive tailings pond or from the decommissioning of the former pond, which has
been conducted by entities other than Silmet. The Uranium Material is comprised only of
residuals from the current Silmet niobium and tantalum recovery unit, which were directly
calcined, dried, and drummed after generation. This closed process is described in further detail
in Section 2.1, below.
2
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.
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 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 residuals from niobium and tantalum recovery from
columbite and tantalite ores, as described below.
Columbite and tantalite-containing mineral ore concentrates are crushed and milled in an isolated
area to control the formation of radioactive dust. Raw materials are loaded by hermetic feeder
screws into vibrating mills, where the material is milled to the required particle size, removed
from the mills by a hermetically contained discharge systems, and packed into metal drums. The
milling unit has an isolated ventilation system with particle filter system. Dust particles from the
filtered air are removed by cyclones and recycled to the process with raw material.
Milled columbite and tantalite is transported to the dissolution unit, located in a separate building
in the same plant area. Drums with the milled columbite and tantalite are placed on the top of
automatic feeder systems, where material is loaded into dissolution reactors containing
hydrofluoric acid solution. Raw material is dissolved at temperatures from 80-85°C (176 to 185
°F) in hydrofluoric acid, and sulfuric acid is added to precipitate out the impurities. The slurry is
filtered to remove the insoluble impurities including U and Th. After filtration, the filter cake is
washed with water several times to remove all Nb and Ta from the cake. Wet residue cake is
3
packed into 1-metric tonne plastic bags ("Big-Bags") and transported to the calcination unit
(located in the same building).
The residue is loaded from Big-Bags into electric rotary kilns via feeder systems and calcined at
temperatures from 550-600°C (1022-11 l2°F) for 1 hour. Calcined residue is transferred from the
rotary kilns into rotary coolers where the material is cooled down and packed into 200-liter
(approximately 55 gallon) metal drums which are lined with triple-walled polyethylene bag
liners. The Quality Control Department and the Governmental Lab Okosil AS, take samples from
every drum for gamma spectrometry analysis, and all drums are measured for dose speed. Each
nine drums comprise a lot, which is transported into the warehouse.
The process which generated the Uranium Material is isolated from the remainder of site
operations. As described above, columbite and tantalite ores are processed in a separate milling
area, for which the feed, grinding and discharge steps are controlled by hermetically sealed
equipment. Dissolution, washing, filtration, electric rotary calcining, rotary cooling and
packaging are all conducted in automated closed systems. Hence, the Uranium Material 1s
isolated from other materials on site from feed source through drum packaging.
Per the process description for residue production provided by Silmet, the chemical reagents used
in the above processes included:
• hydrogen fluoride (as hydrofluoric acid solution)
• sulfuric acid
The presence of residuals or reaction byproducts from these compounds would be expected in the
Uranium Material, as discussed in the sections below.
A schematic flow sheet depicting the process which produced the Uranium Material is provided
in Figure 1.
3.0 Basis and Limitations of this Evaluation
The Uranium Material to be processed at the EFRI White Mesa Mill consists solely of the
calcined residues from tantalum and niobium recovery, currently stored on site at the Facility.
Physical and chemical properties of the residues have been measured at different times to confirm
radiological content and support evaluation of disposal or recovery alternatives. Over several
years of niobium and tantalum recovery operations from 2015 to 2017, Silmet's internal quality
control laboratory periodically analyzed samples of the Uranium Material to assess mineral
content of the oxidized product. During the same time period, Estonia's national environmental
control laboratory at the Okosil Keskkonnalabor ("Okosil Environmental Center") sampled and
analyzed composites of drummed material for radionuclide content. In 2018, Silmet composited
grab samples representing all the drums into 15 composites for total constituent analyses of total
metals, inorganic anions, isotopic uranium, thorium, radium, Toxicity Characteristic Leaching
Procedure ("TCLP") metals analysis of eight RCRA metals, pH, ignitability, ammonia nitrogen
and nitrate as nitrogen. The evaluations are summarized in the table below.
4
Summary of Silmet Analyses
Sample Sampling/ Analysis Analyses Number of
Name/Laboratory Date(s) Composite
Samples
Quality Certificates 2015 through 201 7 Uranium oxides, 15
(NPM Silmet OU internal thorium oxides, rare ( every drum was
laboratory) earth oxides, metal sampled;
oxides composites were
made from 9
samples)
Okosil Keskkonnalabor 2015 through 2017 Radionuclides 19
Katseprotokoll ("Okosil ( every drum was
Environmental Center sampled;
Test Report") composites were
made from 9
samples)
ALS Laboratory 2018 Ignitability, TCLP, 15
inorganic ions, total ( composited by the
metals, ammonia and same method as
nitrate N, earlier samples)
radionuclides
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. Analyses provided with the
RMPR were performed by laboratories possessing State of Utah and/or National Environmental
Laboratory Accreditation Conference ("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 and historic Silmet Uranium Material analytical data.
2. Material Safety Information Sheet for Insoluble Mineral Fraction provided by Silmet
2019
3. Process description and historical overview of the site provided by Silmet 2018
4. Sample collection procedure provided by Silmet 2018
5. Communications with Silmet 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 Silmet Uranium Material (February 2019).
8. Basis of Hazardous Material and Waste Determinations from the RMPR (February 2019)
9. Affidavit of Signe Kask, Managing Director of NPM Silmet OU (January 2019).
5
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. Although alternate feed
materials are being recycled to recover uranium and hence are permitted to contain constituents
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 Silmet Uraniwn Material
NPM Silmet OU Radiation Activity License 14 010, approved on January 30, 2014, authorized
Silmet to collect and store up to a licensed limit of 615.5 metric tonnes of calcined Uranium
Material generated from the tantalum/niobium circuit. Silmet' s Radiation Activity License
expired on January 30, 2019. The quantity collected on site prior to expiration of the Radiation
Activity License, 600 metric tonnes (660 tons), approached the licensed limit.
Although the license limit has not been reached, Silmet and the Ministry of Environment of the
Republic of Estonia have agreed that Silmet will cease further production of Uranium Material,
and renewal of the Radioactivity License will be delayed until such time as Silmet demonstrates
they have confirmed an appropriately-licensed off-site destination for the material. Silmet has
suspended niobium/tantalum processing, the only source of the Uranium Material, pending
renewal of the Radioactivity License.
The Uranium Material, which has materially not changed in form or content since first being
produced in approximately 1997, 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.
6
4.2.2 Evaluation of Potential RCRA Listings Associated with Specific Constituents
For potential alternate feed materials that are not exempt from RCRA, the Protocol describes
additional steps EFRI will take to assess whether constituents 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 constituents in the material, and the review of
chemical process and material handling history at the generator location to assess whether the
known chemical constituents 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 Signe Kask. 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 the written source history provided by Silmet, and through interviews
with Silmet personnel from January 2018 to date, as well as the analytical efforts summarized in
Section 3.0 above.
5.1 Overview
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 tantalum and niobium recovery process which generated the
Uranium Material were used for their intended purpose and are not waste materials.
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)
7
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 (KOO 1)
• Inorganic pigment manufacturing (K002 -KOOS)
• Organic chemicals manufacturing (K009-K030, K083, K085, K093-K096, K103-Kl05,
K107-K118, Kl36, K149-K151, K156-K159, K161, K174-K175, K181)
• Inorganic chemicals manufacturing (K071, K073, K106, K176-178)
• Pesticides manufacturing (K031-K043, K097-K099, K123-K126, K131-K132)
• Explosives manufacturing (K044-K047)
• Petroleum refining (K048-52, Kl 70-Kl 72)
• Iron and steel production (K061-K062)
• Primary aluminum production (K088)
• Secondary lead production (K069, KlOO)
• Veterinary pharmaceuticals manufacturing (K084, K101-Kl02)
• Ink formulation (K086)
• Coking (K060, K087, K141-K145, K147-K148)
Evaluation of RCRA listings associated with the inorganic ions and metals analyzed m the
Uranium Material is provided in attached Tables 1 and 2 respectively.
5.2 Volatile Organic Compounds
The Uranium Material consists of acid digestion residuals from inorganic mineral ores, which
have subsequently been oxidized in a calcining rotary kiln at temperatures above 1000°F. The
only constituents remaining in the material following calcining are metals and inorganic ionic
species in their highest oxidation states. No volatile organic constituents can reasonably be
expected to be present in the Uranium Material.
53 Semi-Volatile Organic Compounds
The Uranium Material consists of acid digestion residuals from inorganic mineral ores, which
have subsequently been oxidized in a calcining rotary kiln at temperatures above 1000°F. The
only constituents remaining in the material following calcining are metals and inorganic ionic
species in their highest oxidation states. No semi-volatile organic constituents can reasonably be
expected to be present in the Uranium Material.
5.4 Non-Metal Inorganic Compounds
Analytical results indicate that low levels of ammonia nitrogen, chloride, fluoride, and sulfate are
present in the Uranium Material. Evaluation of potential RCRA listings associated with the
analyzed inorganics, 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 ALS samples
in 2018. The residues that form the Uranium Material were calcined at elevated temperature in
rotary kilns. At elevated temperatures tantalum and niobium, in addition to reacting with oxygen
to form oxides, are capable of absorbing atmospheric hydrogen and nitrogen into their metal
lattices. Other accessory metals in the ores and concentrates also absorb hydrogen and nitrogen.
8
Nitrogen is expected to be present at trace to low levels in both the reduced (ammonia N) and/or
oxidized (nitrate/nitrite) forms.
Inorganic nitrate/nitrite compounds and inorganic ammonia nitrogen are not associated with any
RCRA hazardous waste listings. These analytes have not been included in Table 1.
5.5 Metals
Analytical results indicate that the metals aluminum, arsenic, barium, beryllium, cadmium,
calcium, chromium, cobalt, copper, lead, lithium, magnesium, manganese, molybdenum, nickel,
potassium, sodium, silver, thallium, vanadium, zinc, and zirconium, were present in the Uranium
Material. Evaluation of potential RCRA listings associated with the analyzed metals, and why
they are not applicable to the Uranium Material, is provided in detail in the attached Table 2.
Additionally, the following metals were identified either in Silmet's internal mineral analysis,
ALS' 2018 analysis, or both. Cerium, cobalt, dysprosium, gadolinium, hafnium, iron, lanthanum,
molybdenum, neodymium, niobium, rubidium, samarium, scandium, tantalum, thorium, tin,
titanium, yttrium, ytterbium, and zirconium are not associated with any RCRA hazardous waste
listings. Each of these metals is commonly found at greater or lesser levels in rare earth,
columbite, tantalite and lanthanide ores and concentrates, and is expected to be present in the
concentrates processed for niobium and tantalum recovery at the Silmet Facility. These metals
have not been included in Table 2.
5.6 Summary of RCRA Listed Waste Findin~
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 mineralogy literature confirms that all of the constituents in the material are
consistent with those expected to result from columbite and tantalite ores and the niobium and
tantalum recovery process described by the generator
6.0 RCRA Characteristics
The Uranium Material is an oxidized/calcined product of precipitated and washed filter cake. As
a result, it would not be ignitable, corrosive, or reactive per the RCRA definitions of these
characteristics. Fifteen Uranium Material samples collected during 2018 were analyzed for eight
RCRA TCLP metals. 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 3.
Fifteen 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, a solid that can cause a fire and
sustain combustion. In addition, one of the samples of Uranium Material collected during 2018
was 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.
9
The Affidavit from Signe Kask of Silmet affirms that the Uranium Material has never been
classified for shipment or off-site management as a RCRA characteristic waste. This is consistent
with the source of the constituents and the treatment process used to develop the 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 1s not a RCRA characteristic
hazardous waste.
7.0 Conclusions and Recommendations
In summary, the following conclusions can be drawn from the RCRA analysis of the analytical
data and Facility 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 1 and 2 in the EFRI/UDEQ Protocol Diagram;
b) No volatile organic compounds are used in the inorganic mineral process for niobium
and tantalum recovery, 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 inorganic mineral process for
niobium and tantalum recovery, and no semi-volatile organic compounds can be
expected to be present in the Uranium Material.
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.
• Hudson Institute of Mineralogy Columbite Mineral Data accessed at
https://www.mindat.org/min-8667.html on 2/13/19
• Hudson Institute of Mineralogy Tantalite Mineral Data accessed at
httgs://www.mindat.org/min-3882.html on 2/13/19
• NPM Silmet OU Documented Procedure -Selection and Preparation of Samples of
Naturally Occurring Radioactive Material 2018
• NPM Silmet OU Technological Description for Production of NORM Containing
Residue 2018
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical Dictionary, JJ'h
Edition. Van Nostrand Reinhold. New York 1987.
11
FIGURE 1
FLOW SCHEMATIC OF PRODUCTION OF URANIUM MATERIAL (RESIDUES)
HF
H2SO•
H20 -------Cru ..__ __ ____, ------:hing •id Miling
EJ--------..... Dissof tion
Filtration and washing
i
NORM containing residues
Drying and Calcination
~
Cooling and packing of NORM containing residues
Nb and Ta
containing
INORGANIC CHLORIDES1
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
Ul34
Hydrogen fluoride
P043
Diisoproplyfluorophosp
hate
P056
Fluorine
P057
2-fluoroacetamide
P058
Fluoroacetic acid
sodium salt
NONE
TABLE 1 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH NON-METALS IN URANIUM MATERIAL
Specific Indnstrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Chlorination catalyst, sun lamp monitors.
Organic synthesis, tear gas, warning agent in
fumigant gases.
Used in organic synthesis for production of
urethanes, plastics and pesticides. Formerly
used as choking ag.ent in combat gas.
NONE
Specific Industrial Uses and Sources of U or P Listed
Sources Element or Compound
KList
Used in organic synthesis for addition of carbon
groups to other structures.
Used as refrigerant in air conditioners, and
direct contact freezing. Used in plastics
manufacture. and as solvent and blowing agent.
Catalyst in refinery alkylation, isomerization,
condensation, dehydration, and polymerization
processes. Used for organic and inorganic
flourination reactions, production of fluorine
gas and aluminum fluoride, some uranium
leaching processes, and as additive to solid
rocket propellant.
Insecticide
Production of metallic fluorides and
fluorocarbons, fluoridation compounds for
toothpaste and water treatment.
Primarily as a rodenticide.
Primarily as a rodenticide.
NONE
Page 1
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 site.
No. There would be no reason for this compound to be present
as pure product. byproduct. or off-spec product on site.
No. There would be no reason for this compound to be present
as pure product, byproduct, or off-spec product on site.
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
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. Fluorides are present in residual fluoride compounds
from the acid digestion of niobium and tantalum ore
concentrates for removal of uranium and thorium.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product on
site.
No F Listings
No K Listings
PHOSPHORUS
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely Hazardous
UList PList
U087
0,0-diethyl S-
methyl
dithiophosphate
Ul45
Lead phosphate
Ul89
Phosphorus sulfide,
Phosphorus
trisulfide
U249
Zinc phosphide
P006
Aluminum phosphide
P039
Phosphorodithioic acid
0,0 diethyl S-[2-
e(thylthio) ethyl diethyl]
ester (malathion)
P040
0,0-diethyl 0-pyrazinyl
ohosphate
P041
Diethyl-p-nitrophenyl
phosphate (parathion)
P043
Diisopropylfluorophosp
hate (DFP)
P062
Hexaethyl
tetraphosphate (HETP)
P085
Octamethy
diphosphoramide
(schradan)
P096
Hydrogen phosphide
(phosphine)
P094
Phosphorodithioic acid
0,0 diethyl S-
etheylthio) ethyl
diethyll ester
Pl09
Tetraethyl
Non-Specific
Sources
FList
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 Is This Listing Applicable to Uranium Material?
Sources Listed Element or Compound
KList
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents. pure product, byproduct, or off-spec product on site.
Used as a stabilizing agent additive in plastic No. There would be no reason for this compound to be present as
formulation. pure product. byproduct. or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents. pure product. byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
airents. used as rodenticide. pure product. byproduct. or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents, insecticide, fumigant, semiconductor pure product, byproduct, or off-spec product on site.
technology.
Fruit fly insecticide. No. There would be no reason for this compound to be present as
pure product, byproduct, or off-spec product on site.
Synthesis of thionazin insecticide, fungicide, No. There would be no reason for this compound to be present as
nemtatocide, chemical warfare agents. pure product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents. Insecticide and acaicide. pure product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents. pure product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents; contact insecticide pure product, byproduct, or off-spec product on site.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents. Systemic insecticide toxic to plant-pure product, byproduct, or off-spec product on site.
chewing insects.
Organic chemical synthesis, doping agent for No. There would be no reason for this compound to be present as
semiconductors, polymerization initiator, pure product, byproduct, or off-spec product on site.
condensation polymerization catalyst.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents, thion pesticides. pure product, byproduct, or off-spec product on site.
Insecticides, chemical warfare agents. No. There would be no reason for this compound to be present as
pure product. byproduct. or off-spec product on site.
Page 2
dithiopyrphosphate
(TEDP or sulfotepp)
Pl 11
Diphosphoric acid
tetraethvl ester
P122
Zinc phosphide
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
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents, incendiary weapons, stabilizer for pure product, byproduct, or off-spec product on site.
organic peroxides.
Synthesis of pesticides, chemical warfare No. There would be no reason for this compound to be present as
agents, used as rodenticide. pure product, bvproduct, or off-spec moduct on site.
No FListings
K037 Wastewater treatment sludges from the No. Uranium Material is not from this industry.
production of disulfoton.
K038 Wastewater from the washing and stripping of No. Uranium Material is not from this industry.
ohorate
K039 Filter cake from the filtration of No. Uranium Material is not from this industry.
diethylphosphorodithioic acid in the
production of phorate
K040 Wastewater treatment sludges from the No. Uranium Material is not from this industry.
production of phorate
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 are
Dimethyl sulfate in present in residual sulfate compounds from the acid digestion of
wastewater from the niobium and tantalum ore concentrates for removal of uranium
reactor and spent and thorium.
sulfuric acid from the
acid dryer from the
production of methyl
bromide
Page 3
ALUMfNUM
Commercial 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)
POI I
Arsenic trioxide
POI2
Arsenic
Pen to xi de
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 oreservati ves
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 site.
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
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
cacodylic acid production
K060 --
Ammonia still lime sludge from
coking
K084 -
Wastewater sludge from
veterinary pharmaceutical
production
KIO! --
Distillation tar residues from
veterinary pharmaceutical
production
Kl02 -
Residue from decolorization of
veterinary pharmaceuticals
Kl61 -
Purification solids, baghouse dust
and floor sweepings from
dithiocarbamate acids production
Kl 71 Spent hydrotreating catalyst -
from petroleum refining
Kl72 -
Spent hydrorefining catalyst from
petroleum refining
Kl76
Baghouse filters from the
production of antimony oxide,
and intermediate metals.
Kl77 -
Slag from production or
speculative accumulation of
antimony or antimony oxides
Page 2
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and_ concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium mes and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
BARIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely F List
UList Hazardous
PList
NONE
P013
Barium Cyanide
NONE
BERYLLIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
Beryllium --POIS
Beryllium powder
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
--
Beryllium powder is used in the aerospace
industry, as a neutron reflector in nuclear
reactor shielding, solid rocket fuel, and in
X-ray tubes. Also used in alloys and parts
in gyroscopes, guidance system
components, instrumentation and controls
such as solenoids. relavs. and switches.
--
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 site.
No F Listings
No K Listings
Is This Listing Applicable to Uranium Material?
No U Listings
No. There would be no reason for powdered beryllium
to be present as pure product, byproduct or off-spec
product on site.
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 site. Also it is present primarily as an accessory
metal in tantalum and niobium ores and concentrates,
which are not listed waste sources.
No F Listings
No K Listings
CADMIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
NONE
NONE
CALCIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
U032
Calcium chromate
P021
Calcium cyanide
Non-Specific
Sources
FList
F006
Wastewater sludge from
electroplating
F039
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
--
--
---
--·-
Leachates from land disposal of
wastes F20 to F22 and F26 to F28
K061 --
Steel electric furnace emission
control dust/sludge
K064 -·
Acid plant blowdown thickener
slurry/sludge from primary copper
oroduction blowdown
K069 --
Emission control dust/sludge from
secondary lead smelting
Kl77
Slag from production or
speculative accumulation of
antimony or antimony oxides
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
FList 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
cyanides.
NONE --
NONE -
Page4
Is This Listing Applicable to Uranium Material?
No U Listings
No P Listings
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings.
No K Listings.
CHROMIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
0032
Chromic acid or
calcium salt of
chromic acid
NONE
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
Used in manufacture of pigments,
oxidizers, catalysts, medicines, ceramic
glazes, colored glass, inks, paints, plating,
anodizing, engraving, plastic etching, and
textile dvejne:, and metal cleaninir.
F006 -
Wastewater treatment sludge from
electroplating
FOl9 Wastewater treatment -
sludge from chemical coating of
aluminum
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
K004 -
Wastewater treatment sludge from
production of zinc yellow pigment
KOOS -
Wastewater treatment sludge from
production of chrome green
Page 5
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 site.
No P Listings
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
pigment
K006 --
Wastewater treatment sludge from
production of chrome oxide green
pigments
K007 -
Wastewater treatment sludge from
production of iron blue pigments.
KOOS -
Oven residue from production of
chrome oxide green pigments
K048 -
Petroleum refining dissolved air
flotation ("DAF') solids
K049 -
Petroleum refining slop oil
emulsion solids
KOSO -
Heat exchanger bundle cleaning
sludge form petroleum refining
KOS! -
Petroleum refining API separator
solids
K061 -
Steel electric furnace emission
control dust/sludge
K062 -
Iron and steel manufacturing
pickle liquor
K069 --
Emission control dust/sludge from
secondary lead smelting
K086 -
Solvent, caustic and water wash
sludges from ink formulation
K090 --
Emission control dust or sludge
from ferrochromium silicon
production
Page 6
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
LEAD
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
U 144
lead acetate
U 145
lead phosphate
Ul46
lead subacetate
Pl 10
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
oigment
K003 -
Wastewater treatment sludge from
production of chrome molybdate
orange pigment
KOOS -
Wastewater treatment sludge from
production of chrome green
oigment
K046 --
Wastewater treatment sludge from
production of lead based
explosive initiators
Page 7
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
MANGANESE
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
K048 --
Petroleum refining dissolved air
flotation ("DAF') solids
K049 -·
Petroleum refining slop oil
emulsion solids
KOS! --
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 -
Solvent, caustic and water wash
sludges from ink formulation
KlOO -
Waste solution from acid leaching
of emission control dust/sludge
from secondary lead smeltino-
Kl76
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
Page 8
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
Is This Listing Applicable to Uranium Material?
PList
NONE
Pl96
Manganese
dimethyldithio
carbamate
NONE
MERCURY
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
Ul51
Mercury metal
Hg
P065 Mercury
Fulminate
P092
Acetato-0-
phenyl mercury
or
phenyl mercuric
acetate
NONE
NICKEL
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Ha:zardous
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
--
Primarily as a pesticide.
--
NONE --
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
metallunrv.
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 production
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
Page 9
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
Is This Listing Applicable to Uranium Material?
PList
NONE
P073
Nickel carbonyl
P074
Nickel Cyanide
POTASSIUM
Commercial Commercial
Chemicals Chemicals
Acutely Toxic Acutely
UList Hazardous
PList
NONE
P098
Potassium
cyanide
P099
Potassium silver
cyanide
F006
TABLE 2 (Rev. 0): SUMMARY OF POTENTIAL RCRA LISTINGS
IN 40 CFR 261 and APPENDIX VII
ASSOCIATED WITH METALS IN URANIUM MATERIAL
---
Electroplated nickel coatings, reagent
chemical
Metallurgy, electroplating
---
Wastewater treatment sludge from
electroplating
NONE ---
Non-Specific Specific Industrial Uses and Sources of U or P
Sources Sources Listed Element or Compound
FList KList
-
Extraction of gold and silver from ores,
reagent in analytical chemistry,
insecticide. fumi11:ant. electroplating.
Silver plating, bactericide, antiseptic.
NONE
K161 Dithiocaroamate production
Metam-sodium
Purification solids, baghouse dust
and sweepings form
dithiocaroamate oroduction.
Page 10
No U Listings
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. Uranium Material is not from this industry.
No K Listin11:s
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listin11:s
No K Listings
SELENIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U204
Selenious acid
or
selenium dioxide
U205
Selenium sulfide
or selenium
disulfide
Pl03
Selenourea
Pll4
Selenious acid
dithallium salt,
Selenious acid
dithallium salt,
Thallium
selenide,
Thallium
selenite,
Ancimidol
NONE
SILVER -
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P099
Potassium bis
(cyano-c) (I)
argentate
Silver potassium
cyanide
Pl04
Silver 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
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
Preparation of topical dermal and scalp
medications.
Production of dimethyl selenourea for
safety glass coatings
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
-
NONE --
Specific Industrial Uses and Sources of U or P
Sources Listed Element or Compound
KList
··-
Silver plating, bactericide, antiseptic
Used in silver plating.
-
NONE -
Page 11
Is This Listing Applicable to Uranium Material??
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
No. There would be no reason for this compound to be
present as pure product or byproduct on site.
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No K Listings
SODIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U236
3,3'-[(3,3'-
dimethyl[l,l'-
biphenyl)-4,4' -
diyl)bis(azo )bis[5-
amino-4-hydroxy]-
,tetrasodium salt
P058
Auoroacetic acid
sodium salt
Pl05
Sodium azide
Pl06
Sodium 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
-
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.
K161 Dithiocarbamate production
Metam-sodium
Purification solids, baghouse dust
and sweepings form
dithiocarbamate production.
Page 12
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
THALLIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U214
Thallium (I)
acetate
U215
Thallium (Q
Carbonate
U216
Thallium chloride
U217
Thallium (I)
nitrate
P114
Selenious acid
dithallium salt,
Thallium
selenide,
Thallium
selenite,
Ancimidol
PIIS
Sulfuric acid
dithallium salt
NONE
VANADIUM
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
NONE
P119
Ammonium
vanadate
P120
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
High specific gravity solutions for ore
flotation.
Laboratory standard for analysis for
carbon disulfide, synthesis of artificial
diamonds.
Chlorination catalyst, sun lamp monitors.
Analytical standard, green-fire
pyrotechnics.
Selenious acid and its salts are used for
cold blackening of metal parts for model
building and decorative finishes.
Pesticide, ant-ki Iler
-
Kl78 --
Residues from manufacturing and
storage of ferric chloride from
acids from titanium dioxide
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
Page 13
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. Uranium Material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
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 site.
No. There would be no reason for this compound to be
Vanadium
pentoxide
NONE
..
Commercial Commercial Non-Specific
Chemicals Chemicals Sources
Acutely Toxic Acutely FList
UList Hazardous
PList
U249
Zinc phosphide
(10 wt.% or less)
P121
Zinc cyanide
Pl22
Zinc phosphide
(greater than 10
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
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 14
present as pure product, byproduct, or off-spec product
on site. Vanadium and its oxides are naturally-occurring
in 80 different mineral ores, including tantalum and
niobium ores.
No F Listimrs
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 site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No. There would be no reason for this compound to be
present as pure product, byproduct, or off-spec product
on site.
No F Listings
No. Uranium material is not from this industry. Also it
is present primarily as an accessory metal in tantalum
and niobium ores and concentrates, which are not listed
waste sources.
ATTACHMENT 5
Review of Chemical Constituents in Silmet Uranium Material to Determine Worker Safety
and Environmental Issues and Chemical Compatibility at the EFRI White Mesa Mill
TECHNICAL MEMORANDUM j
To: David C. Frydenlund, Kathy Weinel From: Jo Ann Tischler ~(}
Company: Energy Fuels Resources (USA) Inc. Date: April 18, 2019 -------------
Re: Review of Chemical Constituents in Silmet
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 NPM Silmet OU's ("Silmet") Uranium Material (the
"Uranium Material"), also referred to as the residue or Naturally-Occurring Radioactive Material
("NORM") residue, to be transported from the Sillamae, Estonia facility, 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 system and GW monitoring requirements:
1) Will any constituents of the Uranium Material volatilize at the known conditions on the Mill
site or in the Mill circuits? If so, will they create any potential environmental, worker health,
or safety impacts?
2) Will the Uranium Material or any of its constituents create a dust or off-gas hazard at the known
conditions on the Mill site or in the Mill circuit? If so, will they create any potential
environmental, worker health, or safety impacts?
3) Will any constituents of the Uranium Material react with other materials in the Mill circuits?
4) Will any constituents of the Uranium Material create any impacts on the tailings system?
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 Uranium Material to be processed at the Mill consists solely of the calcined residues from tantalum
and niobium recovery, currently stored on site at the Facility.
The evaluation in this memorandum is based on information from the following sources:
1. Current and historic Silmet Uranium Material analytical data.
2. Material Safety Information Sheet for Insoluble Mineral Fraction provided by Silmet 2019
3. Process description and historical overview of the site provided by Silmet 2018
4. Sample collection procedure provided by Silmet 2018
5. Communications with Silmet personnel throughout 2018 and 2019.
6. Radioactive Material Profile Record ("RMPR") for the Silmet Uranium Material (February 2019).
7. Basis of Hazardous Material and Waste Determinations from the RMPR (February 2019)
8. Affidavit of Signe Kask, Managing Director of NPM Silmet 0-0 (January 2019).
9. Basis of Hazardous Material and Waste Determinations from the RMPR (February 2010)
10. Current technical literature from the internet and other sources on performance of liner materials
3.0 Site History and Background
The Silmet Sillamae, Estonia facility (the "Facility") currently operates a niobium, and tantalum recovery
plant. The Facility is located on a property which formerly contained a shale oil production plant from
1927 to 1940. A uranium production pilot plant was constructed on the site in 1944, following the Soviet
Union's occupation of Estonia. The Facility produced uranium oxides from local shale ores from 1944
through 1952. The Facility subsequently began receiving other uranium-containing ores in 1952, and
continued to produce uranium oxides until uranium production ceased in 1990. In 1970, concurrent with
the uranium operations, the plant began receiving loparite ores and began the recovery of niobium and
tantalum in one process area, and rare earths in a separate process area. After 1990, the plant no longer
received loparite ores, and began to process columbite and tantalite ore residue concentrates for niobium
and tantalum production. Niobium and tantalum, continues to the present time. A chronology of the site
history is listed below.
1927-1940 A. Nobel established a Shale Oil production factory, which was destroyed during Second
1944
1946-1952
1952-1970
1970
1970-1990
1982-1988
1988-1990
1990-1997
1990-present
1997
1999-2009
World War
The Soviet Union occupied Estonia and began restoration of facilities, with the aim of
producing uranium from local shale ore
Pilot production of uranium from local shale ore
Processing of various uranium-containing ores to produce uranium oxide
Start of loparite ore processing to produce niobium (Nb), tantalum (Ta) and rare earth
element concentrates ("REE")
Processing of loparite to produce niobium and tantalum
Production of reactor grade enriched uranium products
Soviet occupation in Estonia ended and uranium production stopped
Facility reorganization as State owned company
Processing of columbite and tantalite concentrates to produce niobium and tantalum
Private Company established for Nb, Ta and REE production
Decommissioning of the former radioactive tailings pond. (Material from this pond is
NOT included in the Uranium Material.)
2000 to present Silmet begins accumulating Uranium Material in warehouse
2000 to present Niobium and tantalum recovery is the only operation on site.
2
The Uranium Material results specifically from the plant area and process operation which recovers
niobium and tantalum, as discussed below. It does not include residuals from oil shale production, from
uranium production or enrichment, rare earth recovery, or from other previous operations at the Facility.
The Uranium Material does not include any material from the former radioactive tailings pond or from the
decommissioning of the former pond, which has been conducted by entities other than Silmet. No other
processing activities, other than the current niobium and tantalum recovery operations, have occurred at the
site since 2000.The Uranium Material is comprised only of residuals from the current Silmet niobium and
tantalum recovery unit, which were directly calcined, dried, and drummed after generation. This closed
process is described in further detail in Section 3.1 below.
3.1 Description of Process which Generated the Uranium Material
The Uranium Material consists of the residuals from niobium and tantalum recovery from columbite and
tantalite ore concentrates, as described below.
Columbite and tantalite-containing mineral ore concentrates are crushed and milled in an isolated area to
control the formation of radioactive dust. Raw materials are loaded by hermetic feeder screws into vibrating·
mills, where the material is milled to the required particle size, removed from the mills by a hermetically
contained discharge systems, and packed into metal drums. The milling unit has isolated ventilation system
with particle filter system. Dust particles from the filtered air are removed by cyclones and recycled to the
process with raw material.
Milled columbite and tantalite is transported to the dissolution unit, located in a separate building in the
same plant area. Drums with the milled columbite and tantalite are placed on the top of automatic feeder
systems, where material is loaded into dissolution reactors containing hydrofluoric acid solution. Raw
material is dissolved at temperatures from 80-85°C ( 176 to 185 °F) in hydrofluoric acid, and sulfuric acid
is added to precipitate out the impurities. The slurry is filtered to remove the insoluble impurities including
U and Th. After filtration, the filter cake is washed with water several times to remove all Nb and Ta from
the cake. Wet residue cake is packed into I-metric tonne plastic bags (Big-Bags) and transported to the
calcination unit (located in the same building).
The residue is loaded from Big-Bags into electric rotary kilns via feeder systems, and calcined at
temperatures from 550-600°C (1022-1112°F) for 1 hour. Calcined residue is transferred from the rotary
kilns into rotary coolers where the material is cooled down and packed into 200 liter (approximately 55
gallon) metal drums which are lined with triple wall polyethylene bags. The Quality Control Department
and the Governmental Lab Okosil AS, take samples from every drum for gamma spectrometry analysis and
all drums are measured for dose speed. Each nine drums comprises a lot, which is transported into the
warehouse.
The process which generated the Uranium Material is isolated from the remainder of site operations. As
escribed above, columbite and tantalite ores are processed in a separate milling area, for which the feed,
grinding and discharge steps are controlled by hermetically sealed equipment. Dissolution, washing,
filtration, electric rotary calcining, rotary cooling and packaging are all conducted in automated closed
systems. Hence, the Uranium Material is isolated from other materials on site from feed source through
drum packaging.
3
Per the process description for residue production provided by Silmet, the chemical reagents used in the
above processes included:
• hydrogen fluoride (as hydrofluoric acid solution)
• sulfuric acid
The presence of residuals or reaction byproducts from these compounds would be expected in the Uranium
Material, as discussed in the sections below.
A schematic flow sheet depicting the process which produced the Uranium Material is provided in Figure
1.
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 lined
with triple-walled polyethylene bag liners. The drums will be shipped in closed cargo containers,
such as Container Express ("Conex"), Sea Box, Intermodal Containers ("IMCs") or the equivalent.
3. The drums will be unloaded from the trucks onto the ore pad for temporary storage until the material
is scheduled 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. Because the material is in a dry, powdered state, the drum contents will be managed, if required, to
minimize dust generation upon emptying. Dust management may include emptying the drums
within an enclosure with water sprays, wetting the drum contents before emptying, or emptying the
drums submerged, as determined to be appropriate based on the material condition after receipt.
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 Material and Potential Effects in the Mill Process
5.1 Composition
Physical and chemical properties of the residues have been measured at different times to confirm
radiological content and support evaluation of disposal or recovery alternatives. Over several years of
niobium and tantalum recovery operations from 2015 to 2017, Silmet's internal quality control laboratory
periodically analyzed samples of the Uranium Material to assess mineral content of the oxidized/calcined
product. During the same time period, Estonia's national environmental control laboratory at the Okosil
Keskkonnalabor ("Okosil Environmental Center") sampled and analyzed composites of drummed material
for radionuclide content. In 2018, Silmet composited grab samples representing all the drums into 15
composites, for total constituent analyses of total metals, inorganic anions, isotopic uranium, thorium,
4
radium, Toxicity Characteristic Leaching Procedure ("TCLP") metals analysis of eight RCRA metals, pH,
ignitability, ammonia nitrogen and nitrogen as nitrate. The evaluations are summarized in the table below.
Table 1
Summary of Silmet Analyses
Sample Sampling/ Analysis Analyses Number of
Name/Laboratory Date(s) Composite Samples
Quality Certificates 2015 through 2017 Uranium oxides, 15
(NPM Silmet 00 thorium oxides, rare ( every drum was
internal laboratory) earth oxides, metal sampled; composites
oxides were made from 9
samples)
Okosil Keskkonnalabor 2015 through 2017 Radionuclides 19
Katseprotokoll ("Okosil ( every drum was
Environmental Center sampled; composites
Test Report") were made from 9
samples)
ALS Laboratory 2018 Ignitability, TCLP, 15
inorganic ions, total ( composited by the
metals, ammonia same method as earlier
and nitrate N, samples)
radionuclides
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. Analyses provided with the RMPR were performed by
laboratories possessing State of Utah and/or National Environmental Laboratory Accreditation Conference
("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.
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 calcined product of insoluble minerals precipitated from hydrofluoric acid
digestion of niobium and tantalum ores. In general, based on Silmet' s mineral assays, the compounds
aluminum oxide (Alz03) zirconium oxide (Zr02), and tin oxide (Sn02) together comprise up to 50 percent
of the material, and all other compounds are present at trace levels from mg/kg up to 1 to 2%. The Uranium
Material exhibits a relatively low pH, from approximately pH 2.5 to 3, due to residual fluoride from the
hydrofluoric digestion of tantalum and niobium, and from fluoride present in some of the ore minerals
themselves.
5
The drums, containing powdered calcined product, 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.
The concentrations of these constituents will be further reduced by introduction into the leach circuit, where
they will be present at fractional ppm levels, or lower, after the solid mass is diluted to a level of 50 percent
or less, with acid solutions, in the leach tanks. These constituents will be processed in the same manner as
natural uranium ores or other alternate feed materials are processed at the Mill, and will be discharged to
the Mill tailings management system in the same way as the non-uranium constituents from ores and other
alternate feed materials.
The majority of the soluble mineral salts will be converted to sulfate salt forms in the leach system. This
includes the three oxides that comprise up to half of the material, which are insoluble in water, but will
react with sulfuric acid to form soluble sulfate salts. 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, aqueous sulfuric acid, which will 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 he Mill has previously processed thousands of tons of alternate feed materials
comprised of residuals from tantalum, niobium and rare earth recovery operations similar to the Silmet
Facility, including:
• Cabot alternate feed (tantalum and niobium)
• Fansteel alternate feed (tantalum and niobium)
Each of these alternate feed materials contained a comparable, or even broader, spectrum of columbite,
tantalite or other rare earth element constituents as the Silmet 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 consists of acid digestion residuals from inorganic mineral ores, which have
subsequently been oxidized in a calcining rotary kiln at temperatures above 1000°F. The only constituents
remaining in the material following calcining are metals and inorganic ionic species in their highest
oxidation states. No volatile organic constituents can reasonably be expected to be present in the Uranium
Material.
5.2.2 Semi-Volatile Organic Compounds
6
The Uranium Material consists of acid digestion residuals from inorganic mineral ores, which have
subsequently been oxidized in a calcining rotary kiln at temperatures above 1000°F. The only constituents
remaining in the material following calcining are metals and inorganic ionic species in their highest
oxidation states. No semi-volatile organic constituents can reasonably be expected to be present in the
Uranium Material.
5.3 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.
5.3.1 Non-Metal Inorganic Compounds
As discussed above, the residues that form the Uranium Material were calcined at elevated temperature in
rotary kilns. At elevated temperatures tantalum and niobium, in addition to reacting with oxygen to form
oxides, are capable of absorbing atmospheric hydrogen and nitrogen into their metal lattices. Other
accessory metals in the ores and concentrates also absorb hydrogen and nitrogen. Nitrogen is expected to
be present at trace to low levels in both the reduced (ammonia N) and/or oxidized (nitrate/nitrite) forms.
AmmoniaasN
Ammonia nitrogen was present at very trace levels, averaging 66 mg/kg in the ALS analyses.
Anhydrous ammonia gas or high concentrations of ammonium hydroxide solutions are incompatible with
strong oxidizers, halogen gases, acids, and salts of silver and zinc. The very low levels of ammonia nitrogen
will not be present as anhydrous ammonia gas or ammonium hydroxide and will not contact halogen gases
at any time in the Mill process. If traces of ammonia are present in the reactive form ( ammonium hydroxide)
it will be at concentrations too low to react with the silver and zinc already present in the Mill tailings
management system, or with the moderate oxidizer that may be added in the Mill acid leach circuit.
Nitrate/Nitrite as N
Nitrate is extremely soluble in nearly all mineral forms. In the Uranium Material nitrate/nitrite nitrogen
was present at minute levels, averaging 0.1 mg/kg in the ALS analyses. It was not analyzed in the Silmet
mineral assays.
Nitrate nitrogen has been introduced into the Mill's circuit with natural ores and alternate feed materials at
levels as high as 350,000 mg/kg. The Mill has handled these compounds in the Mill circuit and tailings
management system with no adverse process, environmental, or safety issues. The extremely low levels
identified of nitrate/nitrite nitrogen identified in the ALS reports are inconsequential in comparison.
Phosphorus
Phosphorus is naturally present as a component of several of the accessory minerals commonly co-present
in the tantalum and niobium ores.
The trace levels in the insolubles from the niobium and tantalum digestion were converted in the calciner
to trace levels of the oxide P20s, averaging approximately 0.6 percent in the Uranium Material. These low
levels will react to form soluble ions in the sulfuric acid.
7
Fluorides
Fluoride is present as a residual of the hydrofluoric acid used at the Facility in digestion of tantalum and
niobium ores. It is also a component of several of the accessory minerals commonly co-present in the
tantalum and niobium ores. The average fluoride level analyzed in the Uranium Material was 4,923 mg/kg.
This level is well within the level present in other alternate feed materials already approved for processing
at the Mill, such as the Fansteel alternate feed material, which contained concentrations ranging up to
396,000 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 is a component of several of the accessory minerals commonly co-present in the tantalum and
niobium ores. The average chloride level analyzed in the Uranium Material was less than 16 mg/kg.
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 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, chemical form (mineral oxide) data for the calcined residues was available from
Silmet' s internal quality control laboratory. Additional metals, ions and RCRA parameter data was produced
in 2019. Data from both these sources was used to tabulate the types of 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 Silmet Uranium Material
Class Component of the Uranium Material
Alkali Metals Sodium, Potassium
Alkaline Earths Barium, Beryllium, Calcium, Magnesium
Cadmium, Chromium, Cobalt, Copper, Iron,
Transition Metals Manganese, Mercury, Molybdenum, Nickel,
Silver, Thallium, Vanadium, Zinc, Zirconium
Other Metals Aluminum, Lead, Tin
Metalloids Arsenic, Selenium
Rare Earth Elements Cerium, dysprosium, gadolinium, lanthanum,
neodymium, samarium, scandium, ytterbium,
yttrium
All species listed in Table 2, above, are natural constituents in tantalum and niobium ores, are expected to
be present in the concentrates processed, and the calcined residues produced, at the Facility.
8
As discussed above, in addition to the elemental analyses performed by ALS, Silmet routinely analyzed
samples of the Uranium Material for their actual mineral composition, that is, the compound form(s) in
which each constituent is present. Sufficient data and process knowledge of the Facility exists to
reasonably assess the chemical forms for each constituent, as discussed under each class of constituents,
below.
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 hydroxy lated (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 alkaline earth metals, sodium, and potassium are components of many of the accessory minerals
commonly co-present in the tantalum and niobium ores. All are expected to be present in the concentrates
processed, and the calcined residues produced, at the Facility. The two oxide forms identified by Silmet,
K20 and Na20, comprise together, on average, less than 3 percent of the mass of material. Both will be
converted to soluble sulfates in the leach acid.
Alkaline Earths
The alkali metals, barium, beryllium, calcium, and magnesium are components of many of the accessory
minerals commonly co-present in the tantalum and niobium ores. All are expected to be present in the
concentrates processed, and the calcined residues produced, at the Facility. Barium, calcium and
magnesium were identified in their oxide mineral forms in the calcined Uranium Material. Barium, calcium
and magnesium together comprise approximately 5 percent of the mass of Uranium Material. Beryllium,
analyzed in metal form in the ALS reports, can be assumed to be in its oxide form as well. In the ALS data,
beryllium ranged from 200 to 2,000 times lower in concentration than any of other alkali metals, and was
likely too low to be quantifiable in the mineral assays.
Although in some circumstances, the introduction of oxides of the alkaline earths in sufficient quantities
into an acid leach circuit has the potential to result in unwanted excess chemical reactivity, this situation
will not occur from the processing of the Uranium Material at the Mill. As described above, none of the
alkaline earths will be present as pure metals. Although they have been oxidized in the calcining process
at the Facility and are in the oxide state, they are present at low concentrations, will be diluted either during
drum emptying, leaching, or both, and none will be present at pure or high levels anywhere in the Mill's
circuit. 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 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.
Data from a recent sample of Cell 4A indicates that barium has been introduced into the Mill process and
to Cell 4A tailings. Barium concentrations as high as 43,000 ppm, or 10 times higher than the levels in the
Uranium Material, have been processed at the Mill with no adverse process effects, environmental impacts,
or safety issues. Incompatible materials listed for barium sulfate include phosphorous and aluminum. The
barium will not be exposed to these materials, and the addition of sulfuric acid at the Mill will not create
any additional worker safety or environmental hazards from contact with barium.
9
Transition Metals
The transition metals, cadmium, chromium, cobalt, copper, iron, manganese, mercury, molybdenum,
nickel, silver, thallium, vanadium, zinc and zirconium are components of many of the accessory minerals
commonly co-present in the tantalum and niobium ores. All are expected to be present in the concentrates
processed, and the calcined residues produced, at the Facility. IBased on the Silmet mineral assay data, all
of these components are present in oxide forms as a result of the calcining step at the Facility. However,
none of their oxides were present at greater than 0.5% in the Silmet assay, oxides of mercury, cadmium,
silver, thallium, vanadium, were below the detection limit of 0.02% (200 ppm) in the assay results. This is
generally consistent with the low levels detected in the ALS data.
Although in some circumstances, the introduction of oxides of the transition metals in sufficient quantities
into an acid leach circuit has the potential to result in unwanted excess chemical reactivity, this situation
will not occur from the processing of the Uranium Material at the Mill. As described above, none of the
transition metals will be present as pure metals, or at pure or high concentrations in the highest oxidation
state (oxide) form. Hazards associated with pure metals and high concentration oxides 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 or other insoluble salts, and discharged to the
tailings management system. They do not pose any incompatibility hazards in the Mill process.
Other Metals
The other metals, aluminum, lead, and tin, are components of many of the accessory minerals commonly
co-present in the tantalum and niobium ores. All are expected to be present in the concentrates processed,
and the calcined residues produced, at the Facility. As indicated by the Silmet assay data, these metals are
present in their oxide forms, as a result of the calcining step at the Facility.
Both the ALS data and Silmet assays show lead present at comparable levels, on average 0.4 percent in the
ALS data, and 0.5 percent lead oxide (0.46 percent lead) in the assay data.
Aluminum averaged 12.7 percent aluminum oxide (6.7 percent aluminum average, 9 percent maximum) in
the assay data. The ALS data averaged lower, at 0.44 percent average aluminum and 1.1 percent
maximum).
Tin averaged 15.6 percent tin oxide 12.2 percent tin average, 21 percent maximum) in the assay data. The
ALS data averaged much lower, at 0.001 percent average tin and 0.01 percent maximum).
Manufacturers' Safety Data Sheets ("SDSs") and National Institute of Occupational Safety and Health
("NIOSH") safety hazard information indicate that the metals aluminum lead and tin, and their lower
oxides, are incompatible with strong oxidizers, halogen gases, and some acids.
The Mill sometimes adds oxidants to the leaching system to improve uranium recovery from some types of
feeds. Sodium chlorate, the typical oxidizing agent used in the Mill's leach circuit, is a moderately effective
oxidizer. It will be introduced in relatively weak aqueous solution in the leach system, not in concentrate.
The oxides of lead and aluminum react aggressively with strong mineral acids such as nitric acid or
combinations of nitric and sulfuric acids. Sulfuric acid used at the Mill is a relatively weak acid (compared
10
to nitric or phosphoric acid) and not an oxidizing acid. Aluminum oxides would be converted to sulfates
in the leach step and removed from the system and transferred to the tailings management system.
As described above, neither of these metals will be present as pure metals. Both will be present initially as
oxides, and subsequently as sulfates once reacted with sulfuric acid. Hazards associated with pure metals
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. They do not pose any incompatibility hazards
in the Mill process.
The Mill has previously processed alternate feed materials with comparable levels of aluminum and tin,
ranging up to 13 percent aluminum and 2 percent tin, 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 material with up to 23.6 percent lead, with no adverse effects
to workers, the Mill process or the environment.
Metalloids
The metalloids, arsenic and selenium, are components of many of the accessory minerals commonly co-
present in the tantalum and niobium ores. All are expected to be present in the concentrates processed, and
the calcined residues produced, at the Facility.
In the Silmet assay data, selenium oxides averaged no more than 0.2 percent of the mass of the Uranium
Material, with one of the two oxides being below detection limit in all samples. In the ALS data, selenium
was below detection limit in all of the 15 samples. Arsenic oxides were at levels below the detection limit
of 0.02 percent in all the Silmet assay samples.
Although in some circumstances, the introduction of oxides of the metalloids in sufficient quantities into
an acid leach circuit has the potential to result in unwanted excess chemical reactivity, this situation will
not occur from the processing of the Uranium Material at the Mill. As discussed above, none of the
metalloids will be present as pure metals, and the minimal concentrations of oxides 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 the metalloids 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. 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.
Rare Earth Elements
The rare earth elements, cerium, dysprosium, gadolinium, lanthanum, neodymium, samarium, scandium,
ytterbium, and yttrium are components of many of the accessory minerals commonly co-present in the
tantalum and niobium ores. All are expected to be present in the concentrates processed, and the calcined
residues produced, at the Facility. The Mill has previously processed thousands of tons of alternate feed
materials comprised of residuals from tantalum, niobium and rare earth recovery, including:
• Cabot alternate feed (tantalum and niobium)
• Fansteel alternate feed (tantalum and niobium)
11
Each of these alternate feed materials contained similar, or even broader spectrum of rare earth element
constituents as the Uranium Material. Every one of the rare earth components of the Uranium Material has
been introduced into the Mill circuits at levels greater than those in the Uranium Material, with no adverse
effects to workers, the Mill process or the environment.
6.0 Potential Worker Safety Issues
The Uranium Material is expected to have an average moisture content of less than 1 percent. 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 control dusting
while emptying drums containing dry, powdered material such as the Uranium Material. Dust management
for the Uranium Material, as required, may include:
• emptying of the drums within an enclosure with water sprays,
• wetting of the drum contents before emptying and remove of the material as a moist cake, or
• emptying the drums submerged.
If required, the most appropriate method will be determined based on inspection of the material condition
after receipt at the Mill.
7.0 Radiation Safety
The Uranium Material is derived from the extraction of concentrates of tanatalum and niobium ores. The
Uranium Material contains the same radionuclides as previously approved alternate feed materials received
from rare earth, tantalum or niobium recovery facilities, at varying concentrations. 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. The Mill plans to manage the Uranium Material under a thorium-specific Standard Operating
Procedure ("SOP") developed for feeds with elevated thorium content.
It should be noted that when the Uranium Material is managed under the additional precautions in the
thorium-specific SOP, the procedures in the SOP will also protect workers from any potentially elevated
levels of metal oxides or other components of the calcined product from emptying of the feed drums through
disposal in the tailings system.
8.0 Potential Air E~ons Impacts
The introduction of a solid powder like the Uranium Material to any process may produce two potential
forms of air emissions: fugitive dusts, and/or hazardous gases. Discussions in the previous sections
demonstrate that engineering controls already in place at the Mill will prevent the generation or dispersion
of both of these types of emissions. The Uranium Material will have a moisture content of less than 1
percent. As described in Section 4.0 and 6.0, above, one of a number of available wet methods for dust
control will be applied during emptying of the drum contents, to minimize generation of radionuclide-or
chemical containing-dusts and vapors. 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.
12
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 even if they reach the air control system as solids from potential spills in the pre-leach area.
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 a calcined dry solid powder product from the rotary calciners and
rotary coolers at the Facility. A portion of this material may be insoluble in the acid leach process at the
Mill and therefore, the discharge sent to tailings may contain some solid material. The remainder of the
Uranium Material will be soluble and therefore be contained in the liquid phase after processing in the leach
system. 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 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 tailings, 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 a reasonable 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 Materials 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.
13
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, precipitated, 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 cells liquids;
2. detected in analyses of tailings cells solids;
3. detected in analyses of alternate feed materials licensed for processing at the Mill; or
4. detected in process streams or intermediate products when previous alternate 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, the constituents in the Uranium Material are estimated to raise the current
concentration in Cell 4A by no more than a few mg/L, and for many constituents, due to the low levels in
the Uranium Material, the resulting concentration in tailings is expected to go down, in some cases
significant! y.
based on the calculations in Table 4-1, lead concentrations may increase up to 14.9 mg/L 127%) compared
to the currently estimated concentration of lead in Cell 4A.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 lead will be much lower. When Cell 4A is later in its operational life cycle, the
relative effect of the Uranium Material residuals on lead concentration in the tailings management system
will more resemble the effect calculated based on Cell 3 (an increase of approximately one third (36%)
above the current concentrations, as indicated in Table 4-2. This represents an actual increase over the life
of Cell 4A, as represented by Cell 3, of 3.4 mg/L (36%).
Additionally, it should be noted that, the maximum lead content of 4,100 mg/kg in the Uranium Material is
substantially lower than the elevated lead levels of previously approved alternate feed materials such as
Molycorp and others, which have ranged up to 236,000 mg/kg, and the anticipated quantity of Uranium
Material is far lower than the quantities of those alternate feed materials.
Similarly, over the life of Cell 4A, the effects of the Uranium Material on the concentration of barium, will
also be more like the effects shown in Table 4-2 for Cell 3. That is, the concentration may be expected to
increase 1.6 mg/L ( 1,590%) when considering Cell 4A. However, this percentage increase represents and
actual increase of only 0.4 mg/L (71 %) when considering Cell 3 concentrations as representative of the
future composition of Cell 4A.
The chemistry of the tailings management system would limit the mobility of barium due to the abundance
of sulfate in the tailings cells. The insolubility of barium in the presence of sulfate is generally consistent
regardless of the liquid medium. That is, the solubility of barium sulfate in cold water is 0.022 mg/L and
in concentrated sulfuric acid is 0.025 mg/L (Handbook of Chemistry and Physics, 68th Edition). At the
listed concentrations of sulfate in the tailings solutions (67,600 mg/L to 87,100 mg/Lin Cell 4A), a change
in the ambient barium concentration in the tailings solutions 0.4 mg/L, or even 1.6 mg/L would be
negligible.
14
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.
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 fluoride, nitrite, sulfate and phosphate 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 Groundwater Permit, 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
Groundwater Permit is an effective indicator for the constituent.
15
With respect to barium, as discussed above, given the strong tendency of barium to partition to solids,
especially in the presence of sulfate in the Mill's tailings management system, there is no reasonable
potential for barium to migrate to ground water from the tailings management system at the Mill in the
unlikely event of a leak in the tailings cells. Calcium Kd value in UDEQ Statement of Basis for the permit
(December 1, 2004) contains published Kd values for calcium of 5 to 100 L/kg for sandy to clayey soils.
The Kd for barium is 100 to 150,000 L/kg for the same soil types indicating less mobility in groundwater,
and it has therefore been concluded that barium is sufficiently represented by monitoring for calcium and
has identified no technical reason to add barium to the list of constituents monitored in ground water in the
vicinity of the tailings management system
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
While elevated levels of certain constituents in the Uranium Material may be present, no additional material
management requirements during handling and processing will be needed. The Mill has successfully
implemented processing of previous alternate feed materials with similar or higher concentrations of each
constituent contained in the Uranium Material. For example, the Mill has successfully processed and
recovered uranium from tantalum and niobium recovery residuals, uranium-bearing salts, calcium fluoride
precipitates, recycled metals, metal oxides, and calcified product, all of which posed potential chemical
reactivity and material handling issues comparable to or more significant than those associated with this
Uranium Material.
Based on the foregoing information, it can be concluded that:
1. All the constituents in the Uranium Material have either been reported to be, or can be assumed to
be, already present in the Mill 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. The Uranium Material will raise the respective concentrations of most constituents in tailings by a
fractional percent or a few parts per million to 10 parts per million. In the case of most other
analytes, the resulting concentrations of constituents in tailings will be reduced
5. While the Uranium Material is elevated in lead, it is orders of magnitude lower in concentration
than previously approved alternate feed materials, and the quantity of Uranium Material is far lower
than those feeds. Over the life of Cell 4A, the Uranium Material may raise the concentration of
lead 3 to 4 mg/L.
16
6. The levels of barium in the Uranium material may raise the concentration of Cell 4A 1.6 mg/L, or
over its lifetime, 0.4 mg/L. These levels are insignificant compared to the sulfate levels of any cell
in the tailings management system, which precipitates barium in immobile forms.
7. 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.
8. 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.
17
11.0 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, 6sth Edition.
• Title 10 Code of Federal Regulations; Chapter I -Nuclear Regulatory Commission, Part 40 -
Domestic Licensing of Source Material: 40.4 -Definitions (10 CFR 40.4)
• Title 10 Code of Federal Regulations; Appendix A -Nuclear Regulatory Commission, Part 40 -
Domestic Licensing of Source Material: Criteria Relating to the Operation of Uranium Mills and
the Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source
Material From Ores Processed Primarily for Their Source Material Content (10 CFR 40 Appendix
A)
• 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 9D°C. 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.
• Hudson Institute of Mineralogy Columbite Mineral Data accessed at hltp ://www.mindat.org/min-
8667 .html on 2/ 13/ 19
• Hudson Institute of Mineralogy Tantalite Mineral Data accessed at http ://www.mindat.org/min -
3882.html on 2/13/19
• Mitchell, D.H., 1985. "Geomembrane Compatibility Tests Using Uranium Acid Leachate", Journal
of Geotextiles and Geomembranes, Vol. 2, No. 2, Elsevier Publishing Co., pp. 111-128.
• NPM Silmet 0-0 Documented Procedure -Selection and Preparation of Samples of Naturally
Occurring Radioactive Material 2018
• NPM Silmet 0-0 Technological Description for Production of NORM Containing Residue 2018
• Sax, N. Irving and Lewis, Richard L. Sr. Hawley's Condensed Chemical Dictionary, I I'" Edition.
Van Nostrand Reinhold. New York 1987.
• US EPA Chemical Fact Sheets -accessed at www .epa.gov/chemfact on 2/17 / 19
• US EPA Haxo H. E., Haxo Robert, Neson, Nancy, et.al. Liner Materials Exposed to Hazardous
and Toxic Wastes. EPA Hazardous Waste Engineering and Research Laboratory January 1985
• Utah Department of Environmental Quality, Statement of Basis for White Mesa Mill Groundwater
Permit 12/1/2004
18
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Chemical Concentration chemical form? these incompatible agents?
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 N20 4, hydroxylamines,
803, H2S
Beryllium Be 6.9 As BeO -gives off toxic gases in fire No. --
Cadmium Cd 28 As CdO -reacts with magnesium, No. No.
decomposes on heating to form cadmium
fumes
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 Ca0Si02 -none listed No. --
Cerium Ce None listed ----
Chloride c1· 110 As inorganic salts -none. As phosphorus Only as trace inorganic salts. Not as No.
pentachloride -magnesium oxide phosphorus pentachloride.
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Chemical Concentration chemical form? these incompatible agents?
Component Symbol (mg/kg) I ncompati bi I ities
Chromium Cr 260 As Cr02 -none No. --
As Cr03 -combustible materials (paper, No. No.
wood, sulfur, aluminum, plastics)
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
Iron Fe 20,000 As Fe203 -calcium hypochlorite, carbon No. No.
monoxide, hydrogen peroxide
As Fe2(S04)3 -decomposes at high No. No.
temperature
As As2Fe20e -decomposes on heating to No. No.
yield fumes of arsenic and iron
Lanthanum La 7,700 None listed -------
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(OHh 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.
Niobium Nb 2,300 As metal -hydrofluoric acid, hydrofluoric-nitric No. No.
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Chemical Concentration chemical form? these incompatible agents?
Component Symbol (mg/kg) Incompatibilities
acid mixtures, cold fluorine; or chlorine,
bromine or halocarbons above 200°c.
Nitrates/Nitrites NOx 0.18 None reported Yes. -
Phosphorus p 4,400 As P -oxidizers, halogens; No. No.
As PCb -water, reactive metals, nitric acid, No. No.
acetic acid, organic matter
As PCls -Water, magnesium oxide, No. No.
chemically-active metals such as sodium,
potassium, alkalis, amines
As P2Ss -Water, alcohols, strong oxidizers, No. No.
acids, alkalis
As PH3 -Air, oxidizers, chlorine, acids, No. No.
moisture, halogenated hydrocarbons, copper
As POCl3 -Water, combustible materials, No. No.
carbon disulfide, dimethyl-formamide, metals
(except nickel, lead
As P205 -Strong caustics, most metals Yes. 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
I 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.
Silver Ag 7.6 As Ag20 -fire and explosion hazard with No. No. Will not be exposed to ammonia
organic material or ammonia in circuit.
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)
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. --
Table 3: Incompatibilities and Chemical Hazards for Components of Uranium Material
Maximum Will constituent be present in this Will constituent be exposed to
Chemical Concentration chemical form? these incompatible agents?
Component Symbol (mg/kg) Incompatibilities
---
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 SQ4 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.
Tantalum Ta 440 As metal or metal oxide dust -strong Will be present as tantalum No. Moderate oxidizers only, if used
oxidizers, bromine trifluoride, fluorine pentoxide.
Thallium Tl 5.2 Varies with compound Will only be present in wet filter cake -
or aqueous solution.
Thorium Th 9,200 As thorium dicarbide -with sodium chlorate Will be present as thorium dioxide. No.
Tin Sn 120 As metal -chlorine, turpentine, acids, alkalies No. Will be present as tin oxides. No. Tin will not be present as pure
metal. In the oxide form It will be
consumed by the overabundance of
sulfuric acid in the leach system.
Titanium Tl 12,600 None listed ----
Vanadium V 18 As dust or fume -lithium, chlorine trifluoride No. No.
Ytterbium Yb 13,300 None listed .... --
Yttrium y 22,200 As metal -oxidizers No. Moderate oxidizers only, if used
Zinc Zn 180 As ZnO-none No. --
Zirconium Zr 5,100 As metal -potassium nitrate, oxidizers. No. Will be present as zirconium No. Moderate oxidizers only, if used
oxides.
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.
Values for cerium, lanthanum, phosphorus, titanium, tungsten, ytterbium and yttrium were estimated from mineral composition data from NEO internal quality
laboratory. All other values are from ALS 2018 report.
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 Feeds -Cell 4A
H
Difference
between Column
A C D Gand D I
Estimated Cone. Range in Estimated F G (Incremental Increase in
Average B Mill Tailings Average Cone. in E Mass in Mill Cone. in Mill Increase in Mill Mill Tailings
Cone. in Estimated before Mill Tailings before Estimated Tailings after Tailings after Tailings Cone. Cone. after J
Uranium Mass in Processing Processing Current Uranium Uranium after Uranium Uranium Cone. in Ores and
Material Uranium Uranium Uranium Material Analyte Mass Material Material Material Material Other Alternate
(mg/kg or Material Material (mg/Lor ppm)38' in Mill Tailings Processing Processing Processing) Processing Feed Materials
Component ppm)1 (tons)2 (mg/L or ppm )3A 3C (tons)4 (tons)5 (ppm)s (ppm)7 (%)8 (mg/kg or ppm)9
Inorganic
Nitrogen10 65.9 0.14 31-9133 3,410 2,046 2,046.1 3,398 -12.2 -0.4 350,000 11
Chloride 15.6 0.03 4530-10, 100 6,489 3,893 3,893.4 6,465 -23.6 -0.4 89,900
Fluoride 4,937 10.86 0.3-2,030 962.6 578 588.4 977 14.5 1.5 460,000
Phosphorus as
phosphate 2,600 Not analyzed in Mill tailings 65,000 11
Aluminum {AIJ 4,427 9.74 l ,bl u 1,510 906 915.7 1,521 10.7 0.7 .:'.,UUU-1 oU,UUU
.Arsenic (As) 5.0 0.01 60.5-626 143 86 85.8 142 -0.5 -0.4 3.5-16, 130
Barium (Ba) 435 0.96 0.10 0.10 0.06 1.0 1.7 1.6 1588.8 21-36,200
Beryllium (Be) 1.8 0.00 0.167-0.538 0.30 0.2 0.2 0.3 0.005 1.8 1-105
Cadmium (Cd) 2.6 0.01 0.844-3.85 2.4 1 1.4 2.4 0.001 0.04 0.004-59,000
Calcium (Ca) 4,912 10.81 445-707 604 362 373.0 619 15.7 2.6 up to 217,000
Cobalt (Co) 3 0.01 9.44-41 27.0 16 16.2 27 -0.1 -0.3 9-350,400
Chromium (Cr) 89.1 0.20 3.22-9.35 6.37 4 4.0 6.7 0.3 4.7 8-16,000
Copper (Cu) 74 0.16 99.2-683 428 257 257.0 427 -1.3 -0.3 8-296,000
Iron (_Fe) 8,767 19.29 2280-5320 3,350 2,010 2,029.3 3,370 19.8 0.6 up to 164,000
Lead (Pb) 4,093 9.00 5.27-16.4 12 7 16.0 27 14.9 127.4 9-236,000
Magnesium (Mg) 1,242 2.73 2,230-7,030 4,064.00 2,438 2,441.1 4,054 -10.3 -0.3 1,020-43,400
Manganese (Mn) 1,458 3.21 112-307 187 112 115.2 191 4.6 2.5 172-3,070
Mercury (Hg) 0.14 0.00 0.0008-0.015 0.004 0.002 0.002 0.004 0.0005 14.6 0.0004-14
Molybdenum (Mo) 2.3 0.01 24.2-59.1 39.6 24 23.8 39 -0.1 -0.3 12-17,000
Nickel (NI) 52 0.11 17.1-71 .9 49 29 29.5 49 0.01 0.02 7-450,000
Potassium (K) 1,480 3.26 558-2020 1,138.0 683 686.1 1,139 1.2 0.1 17-7,740
Silver (Ag) 3.6 0.01 0.078-0.521 0.24 0.14 0.1 0.2 0.012 5.2 0.007-90.8
Thallium (Tl) 1.3 0.00 0.162-0.727 0.37 0.22 0.2 0.4 0.003 0.9 0.02-960
Tin (Sn) 89 0.20 0.0696 0.0696 0.04 0.2 0.4 0.325 466.8 116,000
Vanadium (V) 7.4 0.02 237-1,090 732 439 438.9 729 -2.6 -0.4 10-25,000
Zinc (Zn) 88 0.19 142-406 250,900 150,540 150,540.2 249,984 -916.3 -0.4 8-14,500
Zirconium '(Zr) 1,885 4.15 2.53 2.53 1.5 5.7 9.4 6.9 271.8 8-14,500
Table 4-1 Comparison of Uranium Material to Tailings and Alternate Feeds -Cell 4A
Notes to Table 4:
1. The concentration in the Uranium Material is from 2018 ALS 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 2,200 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, Ba, Sn and Zr. 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 Band E.
6. The concentration in Mill tailings after Uranium Material processing is calculated by dividing column F by 602,200, which is the existing volume of tailings in
Cell 4A of 600,000 dry tons plus the assumed 2,200 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 the sum of ammonia nitrogen and nitrate/nitrite nitrogen.
11. Sources of data for cations in other feeds is provided in Table 5.
Table 4-2 Comparison of Uranium Material to Tailings and Alternate Feeds -Cell 3
H
Difference
between Column
A C D Gand D I
Estimated Cone. Range in Estimated F G (Incremental Increase in
Average B Mill Tailings Average Cone. in E Mass in Mill Cone. in Mill Increase in Mill Mill Tailings
Cone. in Estimated before Mill Tailings before Estimated Tailings after Tailings after Tailings Cone. Cone. after J
Uranium Mass in Processing Processing Current Uranium Uranium after Uranium Uranium Cone. in Ores and
Material Uranium Uranium Uranium Material Analyte Mass Material Material Material Material Other Alternate
(mg/kg or Material Material (mg/Lor ppm)38• in Mill Tailings Processing Processing Processing) Processing Feed Materials
Component ppm)1 (tons)2 (mg/Lor ppm)3A 3C (tons)4 (tons)5 (ppm)6 (ppm)? (%)8 (mg/kg or ppm)9
llnorgarnc
Nitrogen10 65.9 0.14 29-10,600 6,945 18,166 18,166.2 6,939 -5.8 -0.1 350,000 11
Chloride 15.6 0.03 2,460-115,000 26,545 69,434 69,433.8 26,523 -22.3 -0.1 89,900
Fluoride 4,937 10.86 0.6-46,500 5,873 15,362 15,372.9 5,872 -0.8 -0.01 460,000
Phosphorus as
phosphate 2,600 Not analyzed in Mill tailings 65,000 11
!Aluminum (Al) 4,427 9.74 -'-'U-.:'.0-'U 1,827 4,779 4,788.6 1,829 2.2 0.1 2,UUU-IOU,UUU
Arsenic (As) 5.0 0.01 0.87-489 120.6 315 315.5 121 -0.1 -0.1 3.5-16, 130
Barium (Ba) 435 0.96 0.021-0.1 0.048 0 1.1 0 0.4 761.5 21-36,200
Beryllium (Be) 1.8 0.00 0.21-12.5 1.89 5 4.95 2 0.000 0.0 1-105
Cadmium (Cd) 2.6 0.01 1.19-52.1 14.0 37 36.6 14 -0.010 -0.07 0.004-59,000
Calcium (Ca) 4,912 10.81 148-887 488 1,276 1,287.3 492 3.7 0.8 up to 217,000
Cobalt (Co) 3 0.01 4.44-120 62 162 162.2 62 0.0 -0.1 9-350,400
Chromium (Cr) 89.1 0.20 2.38-76.2 19.2 50 50.4 19 0.1 0.3 8-16,000
Copper (Cu) 74 0.16 9.72-3,000 589 1,541 1,540.8 589 -0.4 -0.1 8-296,000
Iron (Fe) 8,767 19.29 262-15,400 5,543 14,499 14,518.1 5,546 2.7 0.0 up to 164,000
Lead (Pb) 4,093 9.00 15.8-20.5 9.6 25 34.1 13 3.4 35.7 9-236,000
Magnesium (Mg) 1,242 2.73 1,910-84,400 18,031 47,164 47,166.4 18,017 -14.1 -0.1 1,020-43,400
Manganese (Mn) 1,458 3.21 82-5,690 1,435 3,754 3,756.7 1,435 0.02 0.001 172-3,070
Mercury (Hg) 0.14 0.00 0.0024-0.873 0.173 0 0.453 0 -0.00003 -0.01 0.0004-14
Molybdenum (Mo) 2.3 0.01 0.014-209 51.6 135 135.0 52 0.0 -0.08 12-17,000
Nickel (Ni) 52 0.11 7.22-241 96 252 251.7 96 -0.04 -0.04 7-450,000
Potassium (K) 1,480 3.26 133-6657 2,223 5,815 5,818.0 2,222 -0.62 -0.03 17-7,740
Silver (Ag) 3.6 0.01 0.101-6.78 2.01 5 5.27 2 0.001 0.07 0.007-90.8
Thallium (Tl) 1.3 0.00 0.021-4.7 1.31 3 3.43 1 0.000 0.0 0.02-960
Tin (Sn) 89 0.20 <5.0 5.0 13 13.3 5 0.071 1.4 116,000
Vanadium (V) 7.4 0.02 5.6-10,300 1,880 4,918 4,917.5 1,878 -1.6 -0.1 10-25,000
Zinc (Zn) 88 0.19 142-406 2,100 5,493 5,493.2 2,098 -1.7 -0.1 8-14,500
Zirconium (Zr) 1,885 4.15 2.3-38.5 12.20 32 36.1 14 1.6 12.9 8-14,500
Table 4-2 Comparison of Uranium Material to Tailings and Alternate Feeds -Cell 3
Notes to Table 4:
1. The concentration in the Uranium Material is from 2018 ALS 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 2,200 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, Ba, Sn, and Zr 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 Band 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 2,200 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 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 the sum of ammonia nitrogen and nitrate/nitrite nitrogen.
11. Sources of data for cations in other feeds is provided in Table 5.
Table 5
Chemicals Present in Alternate Feeds
Chemical Value in Supporting or Additional Source
Tailings Table 4 for Information
Concentration in Other
Alternate Feeds
Inorganic 350,000 mg/kg 35% (350,000 mg/kg) in Cameco Section II of Regen
Nitrates Regen Product alternate feed Product MSDS
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 36.2 % 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 TTLC 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)
Phosphorus 65,000 mg/kg Cameco Calcined alternate feed, 8 to MSDS for Cameco
as Phosphate 20% as P04-3 (2.6 to 6.5% or 26,000 Calcined Product
to 65,000 mg/kg)
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 R313-24 Interrogatory Template
DRC Interrogatory Where Adaressed 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 R313-24-3-0IA/01 Nonradiological impacts UAC R313-24-3 Attachment 5 ER Lie. App 3.1-3.10; 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 2.4, 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, 4.4.1 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/01 Waterways and Groundwater UAC R313-24-3 Section 4.1, 4.6, 4.7 GW Permit App. 2.5-2.7; ER Cell 4B 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 6.1.2.2 Section 4.1, 4.6, Attachment 4 GWDPTable 2
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 R313-24-3-0ID/01 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, 3.2.1, 3.2.2
Cross Index to UAC R313-24 Interrogatory Template
DRC Interrogatory 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)-02/01 General License UAC R313-24-4 license
Satisfied by ongoing compliance with mill
10CFR40.31(H)-03/0l 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 mi!T
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)-04/01 Terms and Conditions of Licenses UAC R313-24-4 Section 4.1 license
10CFR40.40.42(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
10CFR40.61-06/0l Records UAC R313-24-4 license
1 OCFR40.65(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 I 0.4
Meteorological Monitoring (Proposed Rec. Plan 1.l.l-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
10CFR40.INTR0DUCTIO 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 R313-24 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 R313-24-4 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-1620, 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 R313-24-4 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 3.1
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 1.1-1.3
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, 1.6.2.5
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 R313-24 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.l.2, 1.5.1.3,Figure 1.5-1, l.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
Site and Uranium Mill Tailings Characteristics 2.1.3 Section 4.1, 4.5 .1, Attachment 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, Attachment 5 GWDP I.A Table I, I.B, LC Table 2, I.E
10CFR40, APPENDIX A,
CRITERION 5A(2)-15/01 Liner UAC R313-24-4 Section 4.1, 4.6, Attachment 5 GWDP I.D.2, I.E.8 (c), I.E.7(t)
10CFR40, APPENDIX A, Exemption from Groundwater Protection
CRITERION 5A(3)-16/0l Standards UAC R313-24-4 Section 4.6, Attachment 5 Rec. Plan 2.3.1.1 (a)
lOCFR, APPENDIX A,
CRITERION 5A(4)-17/01 Prevent Overtopping UAC R313-24-4 Section 4.1, 4.5.2 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. l, 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
Cross Index to UAC R313-24 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addressed in Other Documents
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. I; ER Cell 4B Table 5
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. I 9; Rec Plan 3.3.6, 3.3.8
NUREG-1620, Section GW Permit App. 2. I 9; 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 Nonradiological Hazards UAC R313-24-4 Attachment 5 Dames and Moore 3.3.1; ER Cell 4B 9.0
Regional Nonradiological Characteristics RG 3.8, Section 2.11 Section 4.1 Dames and Moore 3.3.1; ER Cell 4B 9.0
Concentrations of Nonradiocative 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)-28/01 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, Attachment 5 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
Cross Index to UAC R313-24 Interrogatory Template
DRC Interrogatory Where Addressed in This
Number Topic Regulatory Basis Document Where Addr~d in Other Documents
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 EFRIRPM
Bioassay Program DG-3024, Section 5.7.5 Section 4.1 EFRIRPM
Contamination Control Program DG-3024, Section 5.7.6 Section 4.1 EFRIRPM
Airborne Effluent and Environmental GW Permit App. 2.9; Dames and Moore 3.3 ; ER
Monitoring Programs DG-3024, Section 5.7.7 Section 4.1 Cell 4B Appendix C
Groundwater and Surface Water Monitoring
Programs DG-3024, Section 5.7.8 Section 4.1 GWDP LE, I.F; ER Cell 4B 10.2; EFRI SOPs
Control of Windblown Tailings and Ore DG-3024, Section 5.7.9 Section 4.1 EFRI SOPs
10CFR40, APPENDIX A,
CRITERION SA-31/01 Daily Inspections UAC R313-24-4 Section 4.1 EFRI SOPs; DMT Plan
10CFR40, APPENDIX A,
CRITERION 9-32/01 Financial Surety Arrangements UAC R313-24-4 Section 4.5.3 Annual Surety
Financial Assurance DG-3024, Section 8.3 Section 4.5.3 Annual Surety
NUREG-1620, Section
Maintaining Financial Surety 4.4.3(10) Section 4.5.3 Annual Surety
10CFR40, APPENDIX A,
CRITERION 10-33/01 Costs of Long-Term Surveillance UAC R313-24-4 Section 4.5.3 Annual Surety
Duty to Apply for a Groundwater Discharge
UAC R317-6-6.1-34/01 Permit UAC R313-24-4 Section 4.1, 4.6 GWDPIV.D
U AC R3l7-6-6.3-35/01 Groundwater Discharge Permit Application UAC R313-24-4 Section 4.1, 4.6 GWDPIV
UAC R317-6.6.4-36/01 Issuance of Discharge Permit UAC R313-24-4 Section 4.1, 4.6 GWDPIV
UAC R317-6-6.9-37/01 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.1
UAC R317-6-6.10-38/0l Background Water Quality Determination UAC R3 l 3-24-4 Section 4.1, 4.6 GWDP LB ; ER Lie App. 3.7.3.2 (c)
Commencement and Discontinuance of
UAC R317-6-6.10-39/01 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 l 3-24-4 Section 4.6 GWDPLF.l
Reporting of Mechanical Problems or
UAC R317-6-6.13-41/01 Discharge System Failures UAC R313-24-4 Section 4.6 GWDP LG; GW Permit App 2.15
UAC R317-6-6.10-42/01 Correction of Adverse Effects UAC R3 J 3-24-4 Section 4.6 GWDPI.G
NUREG-1620, Section
Corrective Action Assessment 4.3.3.3 Section 4.6 GWDPI.G
UAC R317-6-6.10-43/0l Out-of-Compliance Status UAC R313-24-4 Section 4.6 GWDP LG
Cross Index to UAC R313-24 Interrogatory Template
DRC Int-errogatory Wt,sre Add?~d in 'l'hU!
Number Topic R~b!Wt:v B:\'S'JS Do~Ullk.mt
Procedure When a Facility is Out-of-
UAC R317-6-6.10-44/01 Compliance UAC R313-24-4 Section 4.6
UAC R317-6-6.10-45/01 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".
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".
Rec. Plan -"Reclamation Plan White Mesa Mill Blanding, Utah. Radioactive Material
License NO. UT1900479 Most Recent Version
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.
Annual Surety-"Revised Cost Estimates for Reclamation of the White Mesa Mill and
Tailings Management System".
License Condition -"Utah Department of Environmental Quality Division of Radiation
Control Radioactive Material License". License #UT1900479.
EFRI RPM -"EFRI Radiation Protection Manual"
EFRI SOPs -"EFRI Standard Operating Procedures"
EFRI DMT -"EFRI Discharge Minimization Technology "
Whtre Adtlr:~ iii 0.Jll.er-0 1>c~ts
GWDPI.H
GWDPIV.L