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NO NuReo-Osse environmentII etatement related to operation of WHITE MESA URANIUM PROJECT ENERGY FUELS NUCLEAR, INC. pybppag p r?n"ngggn}!} : [ c .bu t a."L !ju D G.a MAY 1979 Docket No. 40-8681 790605012_g * U. S. Nuclear Regulatory Commission e g gety and afeguards
Transcript

NO NuReo-Osse

environmentIIetatement

related to operation of

WHITE MESA URANIUM PROJECTENERGY FUELS NUCLEAR, INC.

pybppag p r?n"ngggn}!}:

[ c .bu t a."L !ju D G.a

MAY 1979

Docket No. 40-8681

790605012_g

*U. S. Nuclear Regulatory Commission e g gety and afeguards

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Available fromNational Technical Information Service

Springfield, Virginia 22161Price: Printed Copy $11.00; Microfiche $3.00

The price of this document for requesters outsideof the North American Continent can be obtainedfrom the National Technical Infonnation Service.

NUREG-0556

FINALENVIRUNMENTALSTATEME$T

related to theEnergy Fuels Nuclear, Inc. ,

.HITE MESA URAN!UM PROJECT

(San Juan County, Utah)

Docket No. 40-8681

May 1979

prepared by theU.S. Nuclear Regulatory Comission

Washington, D.C. 20555

SUMMARY AND CONCLUSIONS

This Final Environmental Statement was prepared by the staf f of the U.S. Nuclear RegulatoryCmmission and issued by the Commission's Office of Nuclear Material Safety and Safeguards.

1. This action is administrative.

2. The proposed action is the issuance of a Source Material License to Energy Fuels Nuclear,Inc., for the construction and operation of the proposed White Mesa Uranium Project with aproduct (U 0 ) production limited to 7.3 x 105 kg (1.6 x 106 lb) per year.3 3

3. The following is a sumary of environmental impacts and adverse effects.

Impacts to the area from the operation of the White Mesa Uranium Project will includea.the following:

Alterations of up to 195 ha (484 acres) that will be occupied by the mill, mill,

facilities, tailings area, and roads. Approximately 135 ha (333 acres) will be per-manently comitted to tailings disposal.An increase in the existing background radiation levels of the mill area as a*

result of continuous but small releases of uranium, radium, radon, and otherradioactive materials during operation.

Socioeconomic effects on the towns of Blanding and Monticello, Utah, where the*

majority of mill workers will be housed during mill construction and operation.

Production of waste material (tailings) from the mill, which will be produced*

at a rate of about 1.8 x 10' kg (2000 tons) per day for 15 years and will bedeposited onsite in subsurface pits.

b. Surface water will not be affected by normal milling operations. Mill processwater will be taken from the Navajo aquifer and process water will be dischargedto the tailings impoundment at about 1.18 m5 (310 gal) per minute. Approximately

35.9 x 105 m (480 acre-f t) of water per year will be utilized by the mill, and thisis not expected to have an effect on the Navajo aquifer.

c. There will be no discharge of liquid or solid effluents from the mill and tailingssite. The discharge of pollutants to the air will be small and the effects negli-gible. The estimated total annual whole-body and organ dose comitments to thepopulation within 80 km (50 miles) of the proposed mill site are presented below.Natural background doses are also presented for comparison. These dose estimates werebased on the projected pop 2 ation in the year 2000. The dose comitments from normaloperations of the proposed White Mesa mill will represent only very small incrcasesfrom those due to current background radiation sources. Radiation dose comitments toindividuals living in nearby residences will not be permitted to exceed the 25-uillirems-per-year EPA limit (40 CFR Part 190).

Annual population dose commitmentsto the population within an 80-km

(50-mile) radius of the plant site in the year 2000

Dose (man-rems /yr)Receptcr organ Plant effluents Natural background

Total body 3.4 7,500Lung 7.1 7,500Bone 6.4 7,500Bronchial 13.2 23,000

epithelium

iii

d. Construction and operation of the White Mesa mill will require the commitnent or smallamounts of chemicals and fossil fuels, relative to their abundance.

e. Construction and operation of the White Mesa mill will provide employment and inducedeconomic benefits for the region, but may also result in some socioeconomic stress,

f. The area devoted to the milling operations will be reclaimed af ter operations cease,but the approximately 135 ha (333 acres) tailings area may be unavailable for furtherproductive use. However, when reclamation is completed and testing shows that radiationlevels have been reduced to acceptable levels, it may be possible to return the tailingsarea to its former use as grazir.g land,

q. Historical and archeological surveys have identified archeological and historic siteswithin the proposed project area. Pursuant to 36 CFR Part 63.3, the NRC requested adetermination from the Secretary of the Interior that the area on which the archeoloq-ical sites are located is ellaible for inclusion in the National Register of HistoricPlaces (National Register) as an Archeological District. The resulting deterninationwas that the White Mesa Archeological District is eligible for inclusion in theNational peqister. Although a similar request was made for determinations of eligi-bility for the historic sites, these de te rmi na tions await supplementary documentation.It is anticipated that the NRC will enter into a Menorandum of Aqreement under36 CFR Part 800, " Procedures for the Protection of Historic and Cultural Properties,"to ensure adequate mitigation of impacts to cultural resources

4. Principal alternatives considered are as follows:

a. alternative sites for the mill,b. alternative mill processes,c. alternative of using an existing mill,d. alternative methods for tailings management,e. alternative energy sources, andf. alternative of no licensing action on the mill.

5. The following Federal, State, and local agencies were asked to connent on the DraftEnvironnental Statement:

Department of CommerceDepartment of the InteriorDepartment of Health, Education, and WelfareFederal Energy Regulatory CommissionDepartment of EnergyDepartment of TransportationEnvironmental Protection AgencyDepartment of AgricultureAdvisory Council on Historic PreservationDepartment of Housing and Urban DevelopnentUtah Board of HealthUtah State Planning CoordinatorUtah Division of 011, Gas, and Mining

6. This Final Environmental Statement was made available to the public and to the specifiedagencies in May 1979.

7. On the basis of the analysis and evaluation set forth in this Environmental Statement, it isproposed that any license issued for the White Mesa mill should be subject to the followingconditions for the protection of the environment.

a. The applicant shall construct the tailings disposal facility to incorporate the featuresdescribed in Alternative 1 of Sect. 10.3 and in Sect. 3.2.4.7 and to meet the safetycriteria specified in NRC Regulatory Guide 3.11.

b. The applicant shall implement an interim stabilization progre that minimizes to themaximum extent reatonably at ievable dispersal of blowing tailings. This program shallinclude the use of written operating procedures, that specify the use of specific controlnethods for all conditions. The effectiveness of the control methods used shall beevaluated weekly by means of a dacunented tailings area inspection.

iv

The applicant shall implement the environmental monitoring program sumarized inc.Table 6.2 of this document. The applicant shall establish a control program thatshall include written procedures and instructions to control all environmentalmonitoring prescribed herein and shall provide for periodic management audits todetermine the adequacy of implementation of these environmental controls. Theapplicant shall maintain sufficient records to furnish evidence of compliance withthese environmental controls. In addition, the applicant shall conduct and documentan annual survey of land use (grazing, residences, etc.) in the area surrounding theproposed project.

d. Before engaging in any activity not assessed by the NRC, the applicant shall prepareand record an environmental evaluation of such activity. When the evaluation indi-cates that such activity may result in a significant adverse environmental impactthat was not assessed, or that is greater than that assessed in this EnvironmentalStatement, the applicant shall provide a written evaluation of such activities andobtain prior approval of the NRC for the activity.

e. If unexpected harmful effect- or evidence of irreversible damage not otherwiseidentified in this Environmer. al Statement are detected during construction andoperation, the applicant shall provide to the NRC an acceptable analysis of theproblem and a plan of action to eliminate or reduce the hamful ef fects or damage.

f. The applicant shall conduct a meteorological monitoring program as specified inSection 6.1 of this document. The data obtained from this program shall be tabulatedand made available for NRC inspection.

9- The applicant shall provide for stabilization and reclamation of the mill site andtailings disposal areas and mill decommissioning as described in Alternative 1 ofSection 10.3 and in Section 3.3 of this document.

h- The 3pplicant shall provide surety arrangements to ensure completion of the mill siteand tailings area stabilization, reclamation, and decomissioning plans.

i. The appi n. ant shall consult and coordinate with the Utah Division of Wildlife Resourcesregarding the extent of fencing and other ways to mitigate any adverse impnts thatmay occur to deer.

j. The applicant shall routinely monitor the tailings discharge system at 4-hr intervalsand document the results. The applicant shall monitor the use of the impoundment bywildlife in conjunction with the program to monitor the tailings discharge system.

8. On the basis of the analysis and evaluation set forth in this Environmental Statement, itis proposed that any license issued for the White Mesa mill should be subject to conditionsfor the protection of historic, archeological, architectural, and cultural resources. Theconditions should be similar to those outlined in the proposed Memorandum of Agreement inAppendix E.

9. The position of the NRC is that, after weighing the environmental, economic, technical,and other benefits of the operation of the White Mesa Uranium Project againstenvironmental and other costs and after considering available alternatives, the actioncalled for under the National Environmental Policy Act of 1969 and 10 CFR Part 51 is theissuance of a Source Material License subject to conditions 7a through 7j and in 8, above.

As announced in a Federd &giater notice dated 3 June 1976 (41 FR 22430), the NRC ispreparing a generic environmental statement on uranium milling. Although it is theNRC's position that the tailings impoundment method discussed in this Statement representsthe most environmentally sound and reasonable alternative now available at this site, anyNRC licensing action will be subject to express conditions that approved waste-generatingprocesses and uranium mill tailings management practices may be subject to revision inaccordance with the conclusions of the final generic environmental impact statementand any related rule making.

v

CONTENTS

Page

SUMMARY AND CONCLUSIONS . . . . . . iii

CONTENTS . vii. .

LIST OF FIGURES xi. . . . .

LIST OF TABLES xiii. . . . .

FOREWORD . xvii. . .. .

1. INTRODUCTION 1-1. . .

1.1 THE APPLICANT'S PROPOSAL . . . . 1-11.2 BACKGROUND INFORMATION1.3 FEDERAL AND STATE AUTHORITIES AND RESPONSIBILITIES

. 1-1. .

1-1.

1.4 STATUS OF REVIEWS AND ACTIONS BY FEDERAL AND STATE AGENCIES 1-31.5 NRC MILL LICENSING ACTIONS 1-3REFERENCES FOR SECTION 1 . . . 1-6

2. THE EXISTING ENVIRONMENT 2-1. . .

2.1 CLIKATE . 2-1.

2.1.1 General influences . 2-1..

2.1.2 Precipitation 2-12.1.3 Winds 2-1. . . .

2.1.4 Sto rms 2-1. ... .. .

2.2 AIR QUALITY . . . . 2-32.3 TOP 0 GRAPHY 2-4. . . .

2.4 DEMOGRAPHY AND SOCI0 ECONOMIC PROFILE 2-4..

2.4.1 Demography of the area. .

2-4.

2.4.2 Socioeconomic profiles. .

. .. . . 2-72.5 LAND USE . . . . 2-14. .. . ...

2.5.1 Land resources2.5.2 Historical, scenic, and archeological resources .

. . 2-14.

2-17. .

2.6 WATER 2-20. .

2.6.1 Surface water. . .

2.6.2 Groundwater. . . . 2-20. ... . .

2-32. .. . . ..

2.7 GE0 LOGY, MINERAL RESOURCES, AND SEISMICITY . 2-36.. . .. .

2.7.1 Geology . ... .. . . . . 2-362.7.2 Mineral resources 2-36. ... . . . ... .

2.7.3 Seismicity 2-39. . . ..

2.8 SOILS 2-39. .. . . .. . .

2.9 BIOTA 2-40. . . .

2.9.1 Terrestrial . ... . ..

2-40.. . .. .. ....

2.9.2 Aquatic biota2.10 NATURAL RADIATION ENVIRONMENT

. . . .. . 2-43...

2-45.. .. . . .. .

REFERENCES FOR SECTION 2 . . . .. .. . . 2-46

3. OPERATIONS 3-1. ... . . .. . .

3.1 MINING OPERE S 3-1. .. . .

3.2 THE MILL . . . . 3-1. . . .. . .. .

3.2.1 External appearance of the mill . . . .. .. . . 3-13.2.2 The mill circuit 3-1. ... . . .

3.2.3 Nonradioactive wastes and effluents . . . . 3-5. .

3.2.4 Radioactive wastes and effluents 3-8. .... . . .

vii

Ed9E

3-153.3 INTERIM STABILIZATION, RECLAMATION AND DECOMMISSIONING . .

3-153.3.1 Interim stabilization of the tailings area .

3-153.3.2 Reclamation of the mill tailings area .

3-193.3.3 Decamnissioning3-20

REFERENCES FOR SECTION 3 .

4-14. ENVIRONMENTAL IMPACTS 4-1

4.1 AIR QUALITY . ..

4-14.1.1 Construction .

4-14.1.2 Operation .

.

4-34.2 LAND USE ...

4-34.2.1 Land resources .

4-34.2.2 Historical and archeological resources4-4

4.3 WA1ER ..

. 4-44.3.1 Surface waters ...

4-54.3.2 Groundwater .

4-64.4 MINERAL RESOURCES .

. . . 4-64.5 S0ILS 4-64.6 BIOTA 4-64.6.1 Terrestrial .

4-84.6.2 Aquatic ..

4-84.7 RADIOLOGICAL IMPACTS 4-84.7.1 Introduction 4-84.7.2 Exposure pathways .

4.7.3 Radiation dose comnitments to individuals 4-8

4.7.4 Radiation dose commitments to populations 4-10

4.7.5 Evaluation of radiological impacts on the public 4-114-114.7.6 Occupational dose4-124.7.7 Radiological impact on biota other than man .

4-124.8 SOCI0 ECONOMIC IMPACTS4-124.8.1 Donography and settlement pattern .

4-144.8.2 Social organization .

4-174.8.3 Political organization .

4.8.4 Economic orqanization 4-17.

4-204.8.5 Transportation . . . .

4.8.6 Impact mitigation . 4-21.

4.8.7 Conclusions . . 4-21.

4-22REFERENCES FOR SECTION 4 . . . .

5-15. ENVIRONMENTAL EFFECTS OF ACCIDENTS . . . . .

5-15.1 MILL ACCIDENTS INVOLVING RADI0 ACTIVITY , . . .

5.1.1 Trivial incidents 5-2. . . .

. . . . 5-25.1.2 Small releases5-35.1.3 Large releases . . . . . .

5.2 NONRADIOLOGICAL ACCIDENTS 5-4. . .

5.3 TRANSPORTATION ACCIDENTS 5-5..

5.3.1 Shipments of yellow cake 5-5. . . ..

5.3.2 Shipnents of ore to the mill 5-7.. .

5.3.3 Shipments of chemicals to the mill 5-7. .

. . . . 5-9REFERENCES FOR SECTION 5

6. MONITORING PROGRAMS . . 6-1. . . . .

6-16.1 AIR QUALITY ,. . . . . . .

6.2 LAND RES0JRCES AND RECLAMATION . 6-1

6.2.1 Land resources 6-1. . . .

6.2.2 Reclamation . 6-1. .

6-26.3 WATER ,. . . .. .. .

6.3.1 Surface water . 6-2. . .. . . . .

6-26.3.2 Groundwater . . . . . . . . . . .

6.4 SOILS 6-2. ... . .. . .

viii

Page

6-26.5 BIOTA . .. .

6.5.1 Terrestrial 6-2. . .

6.5.2 Aquatic . . . . 6-56-56.6 RADIOLOGICAL . . . .

. . 6-56.6.1 Preoperational program6.6.2 Operational effluent and environmental monitoring program 6-5

REFERENCES FOR SECTION 6 . . . 6-9

7. UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS . . .. . 7-17-17.1 AIR QUALITY . . . .

7.2 LAND USE 7-1. .

7-17.2.1 Land resources . . . . .

7-17.2.2 Historical and archaeological resources . .

7.3 WATER . 7-1.. .

7.3.1 Surface water .7-1

7.3.2 Groundwater . 7-1.

7-27.4 S0ILS . . .

. . . . . 7-27.5 BIOTA7.. 1 Terrestrial 7-2

.

7-27.5.2 Aquatic7.6 RADIOLOGICAL 7-2..

7.7 SOCIOECONOMIC 7-2. .

8. RELATIONSHIP BETWEEN SHORT-TEmi USES OF THE ENVIRONMENT AND8-1LONG- # ERM PRODUCTIVITY , . . . . .

8-18.1 THE ENVIRONMENT . . . .

8.1.1 Air quality 8-18.1.2 Land use .

8-1

8.1.3 Water . 8-1. .

8.1.4 Mineral resources 8-1

8.1.5 Soils 8-1. . .

8.1.6 Biota 8-1. .

8-18.1.7 Radiological . .

8.2 SOCIETY 8-2. . . .

REFERENCE FOR SECTION 8 . 8-2

9. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES 9-1

9.1 LAND AND MINERAL 9-1, .

9.1.1 Land 9-19-19.1.2 Mineral . . .. . .

9.2 WATER AND AIR 9-1, .

9.2.1 Water 9-1. . . .

9-19.2.2 Air .. . .

9.3 BICTA 9-1. . .

9.3.1 Terrestrial . . . .. . . 9-19-19.3.2 Aquatic .. . . .

9-29.4 MATERIAL RESOURCES . . .

10. ALTERNATIVES . . . . . .. .. 10-1... . . 10-110.1 ALTERNATIVE SITES

10.1.1 Alternative mill and tailings disposal sites 10-110-210.1.2 Alternative tailings disposal sites in the White Mesa area . . .

10.1.3 Evaluation of alternative mill and tailings disposal sites . 10-610-610.2 ALTERNATIVE MILL PROCESSES . .. .

10.2.1 Conventional uranium milling procedures 10-6.

10.2.2 Uranium milling processes which produce low-moisture tailings 10-7. .

10.2.3 Evaluation of proposed milling process . . . . . 10-8

10.3 ALTERNATIVE METHODS FOR TAILINGS MANAGEMENT . . . . 10-8. . .. . . . . . 10-810.3.1 Introduction

10.3.2 Feasible alternatives for tailings management 10-8. .

ix

PdSe

10-1910.3.3 Evaluation of alternatives . . . . .

10.3.4 Alternatives considered and rejected 10-20.

10-2110.4 ALTERNATIVE OF USING AN EXISTING MILL . . .

10.5 ALTERNATIVE ENERGY SOURCES 10-22.. . .

10.5.1 Fossil and nuclear fuels 10-22.... . . . .

10-2710.5.2 Solar, geothermal, and synthetic fuels . .

10.5.3 By-product uranium . . . 10-2810-2910.5.4 Energy conservation . . . . .

10.6 ALTERNATIVE OF NO LICENSING ACTION 10-29.

REFERENCES FOR SECTION 10 . . 10-31..

11. NRC BENEFIT-COST SUMMARY FOR THE WHITE MESA URANIUM PROJECT 11-111.1 GENERAL . . ..... . . . 11-111.2 QUANTIFIABLE ECONOMIC IMPACTS 11-1. ... .

11-111.3 THE BENEFIT-COST SUMMARY . . . .. .. .

. . . . 11-111.4 STAFF ASSESSMENT

Appendix A. COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT AND NRC STAFF RESPONSES A-1

Appendix B. BASIS FOR NRC EVALUATION OF THE WHITE MESA MILL PROPOSAL B-1.

Appendix C. STATEMENTS OF GENERAL FUND REVENUES AND EXPENDITURES FOR SAN JUANCOUNTY, BLANDING AND MONTICELLO C-1.. . .

Appendix D. DETAILED RADIOLOGICAL ASSESSMENT D-1,

Appendix E. LETTER TO THE ADVISORY COUNCIL ON HISTORIC PRESERVATION . E-1

Appendix F. RADON RELEASE DURING MILLING OPERATIONS F-1.

Appendix G. CALCULATIONS OF TAILINGS PILE GAMMA RADIATION ATTENUATION G-1

Appendix H. ATMOSPHERIC DISPERSION COEFFICIENTS H-1.

Appendix I. RADON DOSE CONVERSION FACTORS 1-1. ..

x

LIST OF FIGURES

Figure Page

1.1 Location of the site of the White Mesa Uranium Project . 1-2

2.1 Regional map of the White Mesa Uranium Project site 2-5

2.2 Land ownership in the vicinity of the project site 2-18

2.3 Drainage map of the vicinity of the White Mesa Uranium Project 2-21

2-232.4 Streamflow sumary in the Blanding, Utah, vicinity . .

2.5 Preoperational water quality sampling stations in the White Mesa2-30project vicinity . .

2.6 Generalized stratigraphic section showing freshwater-bearing units insoutheastern Utah 2-33

2.7 Groundwater-level map of the White Mesa site 2-34

2.8 Tectonic index map 2-37

2.9 Generalized stratigraphic section of exposed rocks in the project vicinity 2-38

2.10 Comunity types on the White Mesa project site . 2-41

3.1 View of the proposed White Mesa Uranium Project 3-2

3.2 Generalized flowchart for the uranium milling process 3-3

3.3 Generalized flowchart showing re.covery of vanadium 3-4

3.4 Overall plot plan as proposed for the six-cell tailings disposal systemincluding possible future cell additions 3-7

3.5 Radionuclide dispersion pathways relevant to the White Mesa Uranium Project 3-9

3.6 Initial construction phase - detailed plan 3-13

3.7 Typical dike section . 3-14

3.8 Final dike section 3-14

3.9 System schedule 3-18.

4.1 Sources of radioactive effluents from the mill and exposure pathways to man 4-9

5.1 Torndao damage: 50-year dose commitment to lungs . 5-4

6.1 Sampling locations for terrestrial ecological characteristics in the.. . 6-6vicinity of the White Mesa project

xi

Li.TLre_ Pag

10.1 Alternative areas near Blanding for the White Mesa Uranium Project 10-3.

10.2 Alternative tallings disposal sites in the vicinity of the proposedWhite Mesa Uranium Project 10-4

10.3 Filtered tailings disposal belt extractor flow diagram 10-12

10.4 Conventional disposal, engineered embankment - full height 10-14

10.5 Conventional disposal, segmented settling pond and evaporation pond 10-16

10.6 Segregated disposal area - general layout 10-17

10.7 Summary of uranium requirements and delivery commitments as ofJanuary 1, 1977 10-25

10.8 Comparison of U 0s requirements and contracted deliveries plus inventories 10-263

B.1 The LWR fuel cycle B-2.

xii

LIST OF TABLES

Table Page

1.1 Status of regulatory approvals and pennits required prior tooperation of the White Mesa Uranium Project 1-4

2.1 Temperature means and extremes at Blanding, Utah 2-2

2.2 Precipitation means and extremes at Blanding, Utah 2-2

2.3 Federal regional priority classifications based on ambient air quality 2-3

2.4 Area and populatiun for Utah and Wayne, Garfield, and San Juan counties,1970 and 1977 2-5

2.5 Population centers near the White Mesa Uranium Project 2-6

2.6 Population projections, San Juan, Wayne, and Garfield counties, comparedto the State . 2-7

2.7 Visitor statistics, recreation areas in southeastern Utah 2-8.

2.8 Selected demographic characteristics, San Juan County, compared toUtah (1970) 2-10

2.9 Nonagricultural payroll jobs in San Juan, Wayne, and Garfield countiesfrom April 1977 to April 1978 2-11

2.10 Per capita incomes for Utah and Wayne, Garfield, and San Juan counties,1973-1977 2-13.

2.11 Total civilian labor and unemployment for Utah and Wayne, Garfield, andSan Juan counties,1970 and 1977 2-13.

2.12 Occupational characteristics of job applicants in the Blanding area,January-March 1978 2-13.

2.13 Retail and wholesale activity in San Juan County, Blanding, andMonticello (1976) 2-14

2.14 Traffic volumes in 1975 for San Juan County and Blanding-Hanksville route 2-15

2.15 Land c*nership, Wayne, Garfield, and San Juan counties, 1967 2-15

2.16 Land use in Wayne, Garfield, and San Juan counties excluding Federalland, 1967 2-16

2.17 Historic sites in southeastern Utah included in the " National Register of

Historic Places" 2-19

2.18 Distribution of recorded sites according to temporal position 2-20

2-222.19 Drainage areas of projact vicinity and region . .

2.20 Physical and chemical water quality parameters 2-25

xiii

Table Page

2.21 Surface water sampling stations 2-25

2.22 Water quality of surface waters in project vicinity, Blanding, Utah 2-26

2.23 Current surface water users in project vicinity 2-31

2.24 Water use of San. Juan County, 1965 2-31

2.25 Water quality of groundwater in the project vicinity 2-35

2.26 Community types and expanse within the project site boundary 2-40

2.27 Ground cover for each community within the project site boundary 2-40

2.28 Birds observed in the vicinity of the proposed White Mesa l'ranium Project 2-43

2.29 Threatened and endangered aquatic species occurring in Utah 2-44

3.1 Composition of liquid in plant tailings slurry based on laboratorytest work 3-11

3.2 Principal parameter values used in the radiological assessment of f heWhite Mesa Uranium Project 3-16

3.3 Estimated annual releases of radioactive materials resulting from theWhite Mesa Uranium Project 3-17

3.4 Species, seeding rates, and planting depths of tentative seed mixture to beused in reclamation of the project site 3-19

4.1 Federal and State of Utah air quality standards 4-2

4.2 Emission rates, sources, and release heights of major ai pollutantsassociated with operation of the White Mesa mill 4-2

4.3 Land disturbed by construction and operation of the White MesaUranium Project 4-4

4.4 Effects of initial construction phase 4-5.

4.5 Community types and approximate expanse to be disturbed by constructionand operation of the White Mesa mill 4-7

4.6 Annual dose comitments to individuals from radioactive releases due tooperation of the White Mesa Uranium Project 4-10

4.7 Annual population dose comitments within 80 km (50 mi) 4-11

4.8 Comparison of annual dos- ommitments to individuals with applicable radiationprotection standerds 4-12

4.9 Employment, White Mesa Uranjun. Project 4-13

4.10 Population influx associated with the White Mesa Uranium Project 4-13

4.11 Mill-induced population influx for the communities of Blanding, Monticello,and Bluff, assuming a 70-25-5% split of the in-moving population 4-15.

4.12 Housing demand and supply in Blanding, Monticello, and Bluff causedby the White Mesa Uranium Project 4-15

4.13 Taxes rela ed to the White Mesa Uranium Project 4-19.

xiv

Table Page

5.1 Fractional probabilities of occurrence and corresponding packagerelease fractions for each of the release models for LSA and type Acontainers involved in truck accidents 5-6

6.1 Preoperational monitoring program 6-3. .

6.2 Operational radiological environmental monitoring program 6-7

10.1 Alternatives considered and rejected 10-20

10.2 Reserves and current consumption of energy sources 10-22

11.3 forecast of gross energy consumption for 1980, 1985, ?nd 2000 10-22

10.4 Estina' ;d relative changes in resources to be used for generation ofprojecte.ed electric energy requirements 10-23.

10.5 Uranium requirements. 10-24

10.6 U.S. uranium (U 0 ) resouices 10-243 3

10.7 Current en u gy sources exces: mortality sumary per year per0.8-GWyr(e) power plant 10-27

10.8 Current energy source sumary of excess morbidity and injuryper 0.8 GWyr(e) power plant 10-28

B.1 Projected U.S. requirements for U 0s,1975-2000 B-53

B.2 Comparison of total and nuclear generating capacity, ooerating inyears 1977-2000 B-5

B.3 Comparison of U.S. reactor requirements and domestic resource availability(in metric tons of U 0s as of January 1978) B-63

D.1 Parameter values for calculation of annual dusting rate for exposedtailings sands D-3

0.2 White Mesa joint frequency meteorological data . . D-4

0.3 Physical characteristics assumed for particulate material releases D-5

D.4 Environmental transfer coefficients D-7. . .

D.5 Inhalation dose conversion factors D-9

D.6 Dose conversion factors used for external exposure . . D-9

D.7 Assuned food ingestion rates D-10

D.8 Ingestion dose conversion factors (mrem /pCi ingested) D-11

H.1 Annual average >/Q (sec/m ) at various distances for the 16 compass3

directions, release height 1 m .. H-4

H.2 Annual average x/Q (sec/m ) at various distances for the 16 compass3

directions, release height 6 m H-4.

H.3 Annual average x/Q (sec/m ) at various distances for the 16 compass3

o rections, release height 13.7 m . . . H-5

H.4 Annual average x/Q (sec/m ) at various distances for the 16 compass3

directions, release height 27.4 m . . H-5

xv

FOREWORD

This Final Environmental Impact Statement is issued by the U.S. Nuclear Regulatory Commission(NRC), Office of Nuclear Material Safety and Safeguards, in response to the request by EnergyFuels Nuclear, Inc., for the issuance of an NRC Source Material License, authorizing operationof the proposed White Mesa Uranium Project. This document has been prepared in accordancewith Comission regulation 10 CFR Part 51, which implements requirements of the NationalEnvironmercal Policy Act of 1969 (NEPA; P.L. 91-190). The mill will be owned and operated byEnergy Fuels Nuclear, Inc. (the applicant).

The NEPA states, among other things, that it is the continuing resposibility of the FederalGovernment to use all practicable means, consistent with other essential considerations ofnational policy, to improve and coordinate Federal plans, functions, programs, and resourcesto the end that the nation may

fulfill the responsibilities of each generation as trustee of the environment for*

succeeding generations;assure for all Americans safe, healthful, productive, and aesthetically and culturally*

pleasing surroundings;attain the widest range of beneficial uses of the environment without degradation, risk*

to health or safety, or other undesirable and unintended consequences;preserve important historic, cultural, and natural aspects of our national heritage*

and maintain, wherever possible, an environment that supports diversity and variety ofindividual choice;

achieve a balance between population and resource use that will permit high standards of*

living and a wide sharing of life's amenities; andenhance the quality of renewat'le resources and approach the maximum attainable recycling*

of depletable resources.

Further, with respect to major Federal actions significantly affecting the quality of the humanenvironment, Section 102(2)(C) of the NEPA calls for preparation of a detailed statement on

(1) the environmental iupact of the proposed action,(ii) any adverse environmental ef fects that cannot be avoidcd should the proposal be

implemented,(iii) alternatives to the proposed action,(iv) the relationship between local short-term uses of man's environment and the maintenance

and enhancement of long-term productivity, and(v) any irreversible and irretrievable commitments of resources that would be involved in

the proposed action should it be implemented.

Pursuant to 10 CFR Part 51, the NRC Division of Waste Management prepares a detailed statementon the foregoing considerations with respect to each apolication for a Source Material Licensefor a uranium mill.

In accodance with 10 CFR Part 40, Section 31, the applicant has submitted an EnvironmentalReport i the NRC as part of its license application. In conducting the required NEPA review,Commission representatives (the staff) met with the applicant to discuss items of informationin the Environmental Report, to seek additional information that might be needed for anadequate assesment, and generally to ensure that the Comission has a thorough understandingof the project. In addition, the staff sought information from other sources to assist in theevaluation, conducted field inspections of the project site and surrounding area, and met withState and local officials charged with protecting State and local interests. On the basisof the foregoing activities and other such activities or inquiries as were deemed useful andappropriate, the staff has made an independent assessment of the considerations specified inSection 102(2)(C) of the NEPA.

xvii

That evaluation led to the issuance of a Draf t Environmental Statement (DES) by the Officeof Nuclear Material Safety and Safeguards in December 1978. The DES was distributed to Federal,State, and local governmental agencies and the other interested parties for coment. A sumarynotice was published in the Fe,!cmZ icyistern regarding the availability of the applicant'sEnvironmental Report and the DES.

Af ter comments on the DES were received and considered, the staff prepared this FinalEnvironmental Statement that includes discussion of questions and coments submitted byreviewing agencies or individuals (Appendix A). Further environmental considerations were madeon the basis of these coroents and combined with the previous evaluation; the total environ-mental costs were then evaluated and weighed against the environmental, economic, technical,and other benefits to be derived from the proposed project.

It was concluded (see Sect, 11) that the overall benefit-cost balance for the White MesaUranium Project is favorable and that the indicated action is to license the White Mesa Mill.

his Final Environmental Statement was made available to the Environmental Protectior. Agency,to those agencies commen".ing on the Draft Environmental Statement, and to the public inMay 1979.

xviii

1. INTRODUCTION

l.1 THE APPLICANT'S PROPOSAL

Pursuant to Title 10, coJc f Federul licj:datica (CFR), Part 40.31 and to 10 CFR Part 51,Energy Fuels Nuclear, Inci (the applicant), on February 6, 1978, applied to the NuclearRegulatory Commission (NRC) for an NRC Source Material License to construct and operate auranium processing mill. This mill, hereafter referred to as the White Mesa Uranium Project,will process ores from independent and company-owned mines. There will be no uranium miningat the project site.

The project will consist of construction and operation of a mill with a nominal processingcapacity of 1800 metric tons (MT; 2000 tons) per day with provision for recovery of vanadiumas well as uranium.

The applicant presently controls by ownership, lease, or contract, ore reserves of approximately8600 MT (9500 tons) of U 03 with an average ore grade of 0.125%. The proposed operating3

schedule is 24 hr/ day, 340 days per year. At this schedule, enere are about 11 years of oresupply. The applicant has designed for a 15-year project lifetime with the expectation thatother ore sources will be discovered later. Based on these figurcs and a 94% recovery, themill will produce approximately 730 MT (800 tons) of U 03 3 per year.

Waste materials (tailings) from the mill will be produced at about 1800 MT (2000 tons) ofsolids per day ard stored onsite. Sequential preparation, filling, and reclamation of tailingsimpoundment cells are planned (Sect. 3.2.4.7). This will decrease the amount of tailings exposed(and radon exhaled) during operation of the mill.

In accordance with NRC Guides 3.5 and 3.8, the applicant has submitted a Source MaterialLicense Application (Form AEC-2),1 an Environmental Report (E8),2 and supplements to the ERin response to questions by the NRC staff.

1.2 BACKGROUND INFORMATIt;N

The proposed Energy Fuels Nuclear, Inc., mill will be located in San Juan County, Utah, about8 km (5 miles) south of Blanding, Utah (Fig.1.1). Ore for the mill feed will be providedthrough two existing ore buying stations, one near Hanksville in Wayne County, Utah, and theother adjacent to the planned mill on the same site (Fig. 2.1). These buying stations, ownedby Energy Fuels, purchase ore from independent mines and will also receive ore from company-owned mines.

The surface area of the project site is owned by Energy Fuels Nuclear, Inc., or controlled bymill site claims. The mill will occupy about 20 ha (50 acres) of the site, including 6 ha(16 acres) presently occupied by the existing ore buying station. At the end of the proposed15-year project lifetime, the tailings disposal cells will occupy approximately another 135 ha(333 acres).

The purpose of this Environmental Statement is to discuss in detail the environmental effectsof project construction as well as monitoring and mitigating measures pronosed to minimize theeffects of the project on the immediate ar ea and surrounding environs.

1.3 FEDERAL AND STATE AUTHORITIES AND RESPONSIBILITIES

Under 10 CFR, Part 40, an NRC license is required in order to " receive title to, receive,possess, use, transfer, deliver import , or export . source material ." (i.e.,

1-1

1-2

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1-3

uranium and/or thorium in any form or ores containirig 0.051 or more of uranium, thorium, ortumbinations ttiereof). 10 U R Part $1 provides for the preparation of a detailed EnvironmentalStatement pursuan*. to the National Environmental Policy Act of 1969 (NtPA) prior to theissuance of an NRC license to authorize uranium milling.

The NEPA became effective on January 1, 1970. Pursuant to Section 102(2)(C), in every majorFederal action significantly affecting the quality of the human environment, Federal agenciesmust include a detailed statement Dy the responsible official on

1. the environmental impact of the proposed action,

2. any adverse environmental effects that cannot be avoided should the proposal beimplemented,

3. alternatives to the proposed action,

4. the relationship between local short-term uses of man's environment and the maintenanceand enhancement of long-term productivity, and

S. any irreversible and irretrievable commitments of resources that would be involved inthe proposed action should it be implemented.

This detailed Environmental Statement has been prepared in response to the above requirements.

The State of Utah implements other rules and regulations affecting the project throughnecessary permits and approvals provided by State agencies. The Utah Division of Oil, Gas,and Mining is the responsible agency for all mine and mill sites within the State under the" Utah Mined Land Reclamation Act of 1975." Title II of the " Uranium Mill Tailings RadiationControl Act of 1978" gives the NRC direct licensing authority over uranium mill tailings.Sanding arrangements will be required to assure funding for reclamation of the tailingsimpoundment and mill site grounds and for decommissioning of the facility.

1.4 STATUS OF REVIEWS AND ACTIONS BY FEDERAL AND STATE AGENCIES

The only regulatory action required from the NRC is the issuance of a Source Material License.In addition, before construction and operation of the White Mesa Uranium Project can becompletely implemented, the State of Utah requires that permits or licenses be obtained priorto the initiation of various stages of construction and operation of the mill. The currentstatus of these regulatcry approvals and permits is given in Table 1.1.

1.5 NRC MILL LICENSING ACTIONS

In June 1976 [Fci in , w t. 41(108): 22430-22431 (June 3, 1976)], the NRC specified thatapplicants requesting a Source Material License prior to the NRC's issuance of its genericenvironmental impact statement on uranium tilling (scheduled for release in 1979) shouldaddress five criteria that will be weighed by the Commission in licensing and relicensingactions. These criteria are considered below as they apply to the White Mesa Uranium Project.

1. It is 'nely that can immual ieaaiy ut wn af ta u t ; e mula have a utilint aa t is indn o:Jent of Gw utilit cf 00.ar lianci% a3tu na J thic Q; e.

This statement is manifestly true for uranium mills in general and for the White Mesamill in particular. This mill is located near multiple mining operations producinglow-grade ore (20.13 ). The costs of hauling this are over longer distances.make thisproject virtually independent of other milling operations. This milling project canbe considered on its own merits, licensing actions with respect to other mills areindependent of this mill, and a separate cost-benefit analysis can be performed.

1-4

Table 1.1. Status of regulatory approvals and parmits requiredpnor to operation of the White Mesa Uranium Prosect

Perm.t or license Granting author ty * Date of application Date granted

Water appropnat:on permits USE O

47943 4 09 689) 3777 to 17 77

4 7331 - 109 G72) 12 10 76 42777

Water Quahty Construct.on Permit UBWQ. UWPCC 11 22 78,11 7 78 3 12-79

Putilic donking water system U8WO UWPCC 2 23-77 42077

Air Quahty Construction Perm.t U8AQ.UACC 11 22 78 In review

M.ll tail <ngs disposal UBSWM 11 22 78 None required

Recording of m.li site claims BLM Continuing

Source Matenal License USNRC 2 6-78 3 12-79

Sanitation facil. ties UBS None required

Prevent.on of sign.ficant detenoratton USEPA 11-15 78 in review

* Explanation of acronyms and initiahsms. Utah State Eng.neers Office. USEO. Utah Bureau of Water Quahty,UBWQ. Utah Water Pollution Control Committee, UWPCC; Utah Bureau of Aer Quality, USAO Utah Air Conser-vation Committee. UACC. Utah Bureau of Sohd Waste Management. UBSWM. U.S Bureau of Land Management.BLM. U S. Nuclear Regulatory Commission. USNRC. Utah Bureau of Sanitation. U8S. and U S. EnveronmentalProtection Agency. USEPA.

e cly ti;at tL takinj ef n , art.aular :tw er:cinj xiton of this i;qe =<rin2. It .c n:t : r sto t |me (m''e undco wn; L rd w:n wu.Li canalitute a rrritmnt of ri .:urect ti.at Mculatcmi to s ' :ni; c anti s forc 'lc ' thi ilic tm t ,. x ? 1 all.1ble z:ith ret; cet to an < i+ crin.ioia ,' : ecm inj a: ticn of thic t:q c.

The proposed action involves the construction and operation of a mill to produce yellowcake from local uranium ore bodies. As pointed out in the response to the first criterion,uranium mills are normally located close to economically exploitable ore bodies. The orewould not likely be exploited to provide feed for a more distant mill. As to the commit-ment of resources, none of the materials involved in the construction and operation of themill are unique or in short supply, hence, liccnsing this mill would not ef fect anylicensing action with respect to other mills. Air, land, and water resources would beused locally but not to an extent to preclude the erection and operation of another mill.

3. It la lih b! that any encircnmental iq acta m eiatea with an; iw iciaual Liecnain srticn cf thia tz.;c wuld te cus. that thn could a lcquatelj Le alirecced within thee:nte.rt ej the indlozaual m .sa a;; licaticn without crer:aning en memlativeencie:nr.cntal i ; i

This Environmental Statement contains an assessment of the environmental impacts associatedwith the proposed licensing action and their severity, and includes proposed Ir.onitoringprograms and actions to mitigate the impacts. Cumulative impacts have been addressedwithin the context of the individual license. The relative isolation of the proposedsite virtually ensures that all appropriate environnental impacts can be adequatelyaddressed in this site-specific Environmental Statement. Adverse effects characteristicof all ucanium niills will be evaluated in a forthcoming generic environmental statement.

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The major objective of the generic statement is the generation of proposals to mitigatesuch effects.

4. It la likely tout any te n.ni ni ia n a th2t , arice in tne = mrce of a rc a afind: idual |icen.:e alTlication cD; L-e resalved :.nihin thzt cente.rt,

The applicant has considered alternative mill processes, tailings, disposal methods, andother technical issues in its license application and Environmental Report. The staffhas reviewed the applicant's evaluations and, in addition, has evaluated other technical

issues. All of these evaluations and, presumably, any further technical issues thatmay arise during review are resolvable within the content of the individual licensingaction, inasmuch as this mill is independent of other mills. In addition, the licensewill be conditioned as required by the Fc!crul y ater notice of June 3,1976, to permitrevision of waste generation, waste management, and other practices.

5. . >ferm! cn lisenciq; aalm cf ti;i: n; c amid vw:t in cute t :ntial lum to ti:c; u!lis intercet av indie ncd n oe iv 'mee cf umniur; fuc repirecnts of c; eratinjvt ~LCF2 l'".d ro ]] t O W not W uCr OLnattmJtiCT

As previously stated by the NRCI "the full capacity of the existing mills will berequired to support presently operating nuclear power reactors and those expected toto begin operation in 1977." The White Pesa mill is one of a small number of new millsthat have been proposed in the last several years and a deferral of its operation coulddecrease the supply of uranium and extend the time required for the delivery of fuel toreactors now operating or under construction. This could adversely affect the abilityof reactors to deliver needed electrical power. Such a short-fall of electrical energyis generally construed to be harmful to the public interest. (See also Sects.10.5 and10.6 and Appendix B.)

1-6

REFERENCES FOR SECTION 1

1. Energy f uels Nuclear. Inc. , " Application for Source Material License (NRC-2)",February 6,1978, revised Septenber 26, 1978.

2. Energy fuels Nuclear, Inc. , " Environmental Report, White Mesa Uranium Project.San Juan County, Utah", January 30, 1978, revised May 15, 1978.

3. Energy fuels Nuclear, Inc., letter to NRC, Novenber 8,1978.

4 " Uranium Milling, Intent to Prepare a Generic Environrental Impact Statement," FederalRegister (41 FR 22430), June 3,1976.

2. THE EXISTING ENVPONMENT

2.1 CLIMATE

2.1.1 General influences

Although varying somewhat with elevation and terrain in the vicinity of the site, the climatecan generally be described as semiarid. Skies are usually clear with abundant sunshine,precipitation is light, humidity is low, and evaporation is high. Daily ranges in temperatureare relatively large, and winds are normally light to moderate. Influences that would resultin synoptic meteorological conditions are relatively weak; as a result, topography and localmicrometeorological effects play an important role in detemining climate in the region.

Seasons are well defined in the region. Winters are cold but usually not severe, and sumnersThe normal mean annual temperature reported for Blanding, Utah, is about 10*C (50 F),are Warm.

as shown in Table 2.l. January is usually the coldest month in the region, with a normal meanmonthly temperature of about -3 C (27 F). Temperatures of -18 C (0 F) or below may occur inabout two of every three years, but temperatures below -26 C (-15 F) are rare. July is gener-ally the wamest month, having a normal mean monthly temperature of about 23 C (73*F). Temper-atures above 32 C (90*F) are not uncmmon in the summer and are reported to occur about 34 daysa year; however, temperatures above 38*C (100 F) occur rarely.

2.1.2 Precipitation

Precipitation in the vicinity of the White Mesa Uranium Project is light (Table 2.2). Normalannual precipitation is about 30 cm (12 in.). Most precipitation in the area is rainfall, withabout 25% of the annual total in the form of snowfall.

There are two separate rainfall seasons in the region. The first occurs in late summer andearly autumn when moisture-laden air masses occasionally. move in frm the Gulf of Mexico,resulting in showers and thunderstorms. The second rainfall period occurs during the winterwhen Pacific storms frequent the region.

2.1.3 Winds

Wind speeds are generally light to moderate at the site during all seasons, with occasionalstrong winds during late winter and spring frontal activity and during thunderstorms in the

Southerly wind directions are reported to prevail throughout the year. Summaries ofsumner.wind direction and wind speed distributions are given in Tables D.1 and D.2 of Appendix D.

2.1.4 Storms

Thunderstorms are frequent during tne sumer and early fall when moist air moves into the areafrom the Gulf of Mexico. Related precipitation is usually light. but a heav'y local storm canproduce over an inch of rain in one day. The maximum 24-hr precipitation reported to havefallen during a 30-year period at Blanding was 5.02 cm (1.98 in.). Hailstorms are uncommon inthis area. Although winter stoms may occasionally deposit comparable amounts of moisture,maximum short-tem precipitation is usually associated with sumer thunderstorms.

Tornadoes have been observed in the general region, but they occur infrequently (seeSect. 5.1.3.1 for estimate of probability). Strong winds can occur in the area along withthunderstorm activity in the spring and summer. The White Mesa site is susceptible to occa-sional duststoms, which vary greatly in intensity, duration, and time of occurrence. Thebasic conditions for blowing dust in the region are created by wide areas of exposed dry top-soil and strong, turbulent winds. Duststorms usually occur following frontal passages duringthe warmer months and are occasionally associated with thunderstom activities.

2-1

2-2

Table 2.1. Temperature means and entremes at Blanding, Utah"- . . _ . _

_ . . _ . _ _ _ _

Means i = tiemes

' 'Mon th Monthly

. - . .lowmanmum m munum

o 9. highest y,, . .. . _ .e s t _ y,,

.. _-

"C "F *C 'F *C 'F 'C 'F

Januae v 39 39 1 -91 156 -26 27.4 16 60 1956 - 27 -17 1937

F e br u ar y 65 417 -64 20 4 01 32 1 19 67 1932 -31 23 .933

Mauh 11.1 51 9 -33 26 1 3.9 39 0 22 72 1934 17 2 1948

Ape d 170 62 6 09 33 7 H.9 48.1 28 H2 1943 12 11 1936

May 22 2 11.9 5. 2 41 3 13.7 %6 33 92 1951 -5 23 1963

June 28 2 82 8 96 43 2 18 9 66 0 38 100 1954 -2 28 1947

July 31 7 89 1 13 8 %9 27 8 73 0 39 103 1931 2 36 1934

August 30 3 86 5 13 1 55 5 21 7 71 0 37 98 1954 6 42 1950

'spiember 26 7 79 3 H7 47.7 176 636 35 95 1988 -2 29 1934

Oc t obee 19 0 66 2 2. 7 36 9 10 9 51 6 32 90 1937 -10 14 1935

November 10 4 50 8 -44 24 1 31 37.5 21 69 1934 - 22 -7 1931

Occemt er 5.3 41 6 ~ 7.4 18 6 1.1 30 1 16 61 1949 24 11 1935

Annual 17 7 63 8 19 35 5 98 49.7 39 103 July 1931 -31 23 F ebruary 1933

_ . _ . . _ _ _ _ _ . _ . _ _ _ . . _ _ _ _ _ _ . _ _ . _ _ _ - - - _ _ . . _ . . _ _ _ _ _ _ _ - ~ . _ _ _ _ . _ _ _ _

* Per uel of r ecord 1931 1960(30v eas si

%uu.e Plateau Hev>un es. Limited. Afeplu'atuws for Soone Ustenat L uemw. Table 2 21. p 2 6. Apr 3.1918

Table 2.2 Precipitation means and ==tren*s at Blandmg. Utah'_ _

T otal. _-

Mean monthly Maw. mum mor.th!y Greatest da.lvMont h -- -- Ye ar

tm in cm m cm in.

_ - .. _ . _ . _ . _ . . _ _ . -

Janua y 3 48 1 20 10 31 4 06 2 64 1 04 1952r

f etx uar y 2 95 1 16 4 39 1.73 2 62 1 03 1937

Man h 2 38 0 94 5.00 1.97 2 'A 1 00 1937

Apr if 2 18 0 P,6 5.41 2.13 2 69 1.06 1 ')S 7

May 1 63 0 64 5.11 2.01 2 39 0 94 1941

Ju ne 1 39 0.55 5.51 2.17 3.M 1 40 1938

My 2 13 0 84 7.79 3 07 3 35 1 32 1930

Avent 3 02 1.19 12 59 4 96 5 03 1.98 1951

Se ptemtwr 3 02 1 19 9 60 3.78 3 07 1 21 1933Oc toter 3 51 1 38 16 79 6 61 3.94 1 55 1940.

Novemt.cr 1 N8 0.74 5 21 2 05 2 41 0 95 1946Dec ember 3 20 1 26 9 29 3 66 3% 1.40 1931

_ - _ . . _ _ . . - . _ - - . _-- . _ . .

d Period of record 1931 - 1960 (30 year s).

Saur s e Plateau Fiesawces. Lsm,ted, Asphcathm for Sourte M.sterial License. T able 2 2 2. p 2 8. Apr.3.1978.

2-3

2.2 AIR QUALITY

The proposed mill site lies within the jurisdiction of the Four Corners Interstate Air QualityControl Region No.14, which encompasses parts of Colorado, Arizona. New Mexico, and Utah. Theair quality of the region is evaluated according to a classification system that was establishedin 1971 for all Air Quality Control Regions (AQCR) in the United States (ER, Sect. 2.7.4.2).The classification systeni rates the five major air pollutants (particulate matter, sulfurdioxide, nitrogen oxides, carbon monoxide, and photochemical oxidants) as having a priorityof I, II, or III. A priority I rating means that a portion of the region is significantlyviolating Federal standards for a particular pollutant and special emission controls are needed.If the emissions are predominately from a single-point source, then it is further classified asIA. A priority rating of II indicates a better quality of air in the region; a priority IIIrating classifies the highest quality. The concentrations that define the classification areoutlined in Table 2.3.

Table 2.3. Federal regional pnority classifications basedon ambient air quality

Air quahty for cath priority group #Pollutant Averap t mc

3 3 3Sulfur oxides Annual >100 pg m 60 - 100 pg m (copg'm

3 3 324 hr >455 pg m 260 -455 99 'm <260 pg 'm

3 23 hr 1300pg m <1300 pg m

3 3Par ticulate Annual >95 pg/m' 60 - 95 pg. m < 60 ug 'm

3mat ter 24 hr >325 pg/m' 150-325 pg m < 150 pg *m

3 3Car ton 8 hr >14 mq/m < 14 mg m

3 3monou ale 1 hr >55 mg 'm <55 mg m

3 3N.tr ogen Annual >11 o ug/m <110 pg m

d o m ide

3 3Photothemical I br >195pg'm (195 99 m

ox idants

d ln the absence of measured data to the contrary, any region containing an area

whose 1970 "crban place" populatnin exceeds 200.000 will be classified poority 1. Allothers will te classshed pr +ority ill. Hydrocarbon classdications will be same as f orptmtochemical cu nian ts.

Source E R. Table 2.7 20-

The priority classifications for the Four Corners Interstate AQCR, which includes the proposedmill site, are presented below:

Sulfur Particulate Nitrogen Carbon Photochemicaldioxides matter oxides monoxide oxidants (Hc)s

Priorityclassification IA IA III III III

The priority IA ratings for particulate matter and sulfur dioxide for the AQCR are due to emis-sions from fossil-fueled power plants located within the region (ER, Sect. 2.7.4.2). However,none of the power plants lie within 50 km (31 miles) of the mill site, which suggests that theair quality in the vicinity of the site may be better than the priority IA classificationindicates.

The Utah Division of Health monitors total suspended particulates and sulfur dioxide at astation located 105 km (66 miles) west-southwest of the site at Bull Frog Marina Except forthe short-term (24-hr) particulate measurement, all reported values (ER, Table 2.7-21) were

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well below the Federal and State of Utah air quality standards. The 24-hr particulateviolations are believed to have been c .used by dust blown by high winds.

Based on data collected from four sampling locations on the project site for one year, dust-2 2 occurring in August.1fall averaged 33 g/m per month; the highest monthly average was 102 g/m

Total suspended particulate monitoring from October 1977 thrnugh February 1978 revealed a geo-metric mean cf 18 pg/m tl Dustfall for this same time period averaged 23 g/m per month. If2

a linear relationship between total suspended particulate matter and dustfall is assumed, theannual geometric mean for total suspended particulates is expected to be 26 og/m l This valueis well below the Federal and State air quality standard of 60 t.g/mL The maximum 24-hr con-centration was 79 6.g/m , or approximately one-half of the Federal and State standard of3

150 ug/m L Sulfation-rate monitoring for one year at four locations on the site indicatethat sulfur dioxide concentrations at the site vicinity are less than 0.005 ppm.1 The Federaland State standard for the annual average of sulfur dioxide is 0.03 ppm.

2.3 TOP 0 GRAPHY

The site is located ~on a " peninsula" platform tilted slightly to the south-southeast and sur-rounded on almost all sides by deep canyons, washes, or river valleys. Only a narrow neck ofland connects this platform with high country to the north, forming the foothills of the AbajoMountains. Even along this neck relatively deepstream courses intercept overland flow from thehigher country. Consequently, this platform (White Mesa) is well protected from runof f flood-ing, except for that caused by incidental rainfall directly on the mesa itself. The land onthe mesa immediately surrounding the White Mesa site is relatively flat.

2.4 DEMOGRAPHY AND SOCI0 ECONOMIC FROFILE

The site of the proposed White Mesa Uranium Mill is in San Juan County in southeastern Utah(Fig. 2.1), approximately 8 km (5 miles) south of the city of Blanding. Energy fuels Nuclear,Inc., currently operates an ore buying station on this property. Energy Fuels also operates anore buying station near Hanksville Utah. It is intended that ore will be transported from

the Hanksville facility to the proposed mill on Utah Route 95, passing through portions ofWayne, Garfield, and San Juan counties (ER, pp. 2-4 to 2-7). It should be noted that plateau

Resources Limited currently operates a uranium ore buying station in Blandinc at a site locateddpproximately 3 km (1.9 miles) north of the Energy Fuels' White Mesa site.

Because of its close proximity to the proposed mill site, the city of Blanding is likely toreceive the largest share of this project's socioeconomic impacts. The comunities ofMonticello and Bluff also are likely to share the effects of mill-induced population increasesand ensuing social impacts. These three communities and Hanksville have been studied for socio-economic impacts. The counties of San Juan, Wayne, and Garfield have been examined where effectsare likely to be generalized uver a larger area.

2.4.1 Demo 3raphy of the area

2.4.1.1 Current _ population and distribution

Compared to most eastern states, Utah is rather sparsely populated with a 1977 population of1,271,300 - a 20I increase since 1970. This population represents an overall density of39.9 persons per square kilometer (15.4 per square mile), but nearly 701 of Utah's populationlives in the counties of Salt Lake Utah, and Weber where Salt Lake City, Provo, and Ogden,respectively, are located.

San Juan County, where the proposed White Mesa mill would be constructed, has a population of13,000 (an increase of 35.3% from 1970). Wayne County, the site of the Hanksville ore buyingstation, has a population of 1800 (a 21.4% increase since 1970). Garfield County has a totalpopulation of 3600 (an increase of 14% from 1970). The data in Table 2.4 111. .trate that whilethese three counties have experienced growth in recent years, their overall Jensity has remainedlow.

The closest city to the proposed mill site is Blanding (Table 2.5), which had a 1977 populationof 3075, up 37% from 1970. Monticello, the county seat, has 2208 residents, 54% more than in1970. Between them, these two communities account for nearly 40% of San Juan County's popu-latien (ER, p. 2-18). Another 46% of the total is made up of Navajo Indians living on or near

2-5

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Resources, Ltd. , ,;;pli..'iticr. for a .%rn meni d Lixn:e ;cr t :e Maniiny Cre ?:O qi i

reation, Grand Junction, Colo., Apr. 3. 1978.

Table 2.4. Area and population for Utah and Wayne, Garfield,and San Juan counties,1970 and 1977

_ . _ . _ . _ _ . _ _ _ _ . _ _ . _ _ _ _ _

Total popialat.on Population per square kdomt terState o, Land area

sq mdes 1970 1977* 'T -countV km2N km sq mde km sq. mde2

Utah, total 213.180 82.340 1.059.273 1.271.300 20 0 5.0 12.9 5.9 15.4Wa rrw 6.444 2.489 1.483 1.800 21.4 0. 2 06 0.3 u.7Garf. eld 13.507 5.217 3.157 3.600 14.0 0.2 06 0.3 0. 7San Juan 20.412 7.884 9.606 13.000 35 3 0.5 1.2 0.5 1.6

"Prehmmary data.

Source. U.S. Bureau of Census.1910. Utah Populat,on Work Committee,1977.

2-6

Table 2.5. Population centers near theWhite Mesa Uramum Protect

_

Appronimate dataxe fromthe progt Otes

Blanding site Hank sville site

km mdes km mdes_ . _ _ - . -- --- - - -

Cokn adoCr and Junct.on* 290 180 26o 160

Cor te t* 14o 85 346 215*

Duran93 21 0 13o 42o 260

UtahBlanding 8 5 209 130

Mon t n etto 48 30 225 140

Blutt 32 20 225 140

Hank sw die 225 140 16 10

Moat / 13o 80 193 12o

New MeocoF ar mmqton* 26o 160 1so 290

*Pcpulat.on geater than 4500 accoeding to 1975 Censusreror ds

?>urce Adapted from E R. Tatde 2.2-1.

the Navajo Reservation in southern San Juan County (ER, p. 2-15). The town of Bluff has apopulation of 280, more than double its population in 1970 (ER, p. 2-18).

Within a 290-km (180. mile) radius of the proposed mill ?.here are several larger cities thatare important regional centers (See Table 2.5 for distance relationships to the project sitcs).Moab, Utah, the closest and also the smallest, has a populatio16 approximately 4500 accordingto 1976 census records (ER, Table 2.2-1). Cortez, Colorado, ha a population slightly under6800 and Durango, Colorado, has nearly 12,000 residents. Both Grand Junction, Colorado, andFarmington, New Mexico, havo populations approaching 28,000.

Approximately 16 km (10 miles) from the Hanksville ore buying station is the town of Hanksville,which had a 1975 population of 160.

The area within an 8-km (5-mile) radius of the proposed mill is sparsely populated and primarilyagricultural. It is estimated that about 70 to 80 people currently reside here. The closestcurrently inhabitated dwelling unit is approxirrately 5 km (3 miles) north of the site (Appli-cant's responses to ER questions, Enclosure 2, p. 2), but most area residents live to thesouth in the Ute Mountain cornunity of White i sa. The Blanding airport also lies within this8-km (5-mile) zone, and approximately 30 to 49 people use that facility daily.

2.4.1.2 projected population and distribution

Between now and the year 2000. Utah's population is expected to rise steadily according toprojections prepared by the Utah Agricultural Experiment Station (Table 2.6). Both high and

The differencelow projactions assume a gradual decline in mortality and constant fertility.between them is that the high figures also assume a positive net migration while the lowfigures are based on no net migration at all. Projections for San Juan County indicate amuch greater growth rate than for the State a'_ a whole (Table 2.6).

According to the city manager of Blanding, a population increase of almost 1500 is expectedwithin the next three years, bringing the number of city residents to 4540 by 1981 (City Managerof Blanding, Utah, personal communication, July 10,1978). This estimate represents an increaseof 47.6% over the 1977 population and is based on the assumption that the proposed White Mesauranium mill will be built. Monticello's city manager is also predicting growth, but at alesser rate than for Blanding. Between now and 1983, an increase of approximately 600 (or30,1978).271) is expected (City Manager of Monticello, Utah, personal communication, July

2-7

Table 2.6. Population protections .' San Juan. Wayne and Garfeldcounties, compared to the State

__

1975" 198o 1990 2000"" '"'"'*

(1975--2000).-

. _ _ .

UrahH.gh 1,216,843 1.420.553 1.803.985 2.163.927 78Low 1.206.584 1,302,815 1.484.231 1.655.528 37

s.sn Juan CountyHigh 12.816 17.373 25.002 33.300 160Low 12.716 13.954 16.917 19,753 55

Warne CountyH.gh 1,960 2.660 3.7 70 4.530 131.1Low 1.950 2.060 2.310 2.51o 28 7

Ge field CountyH< gh 3.480 ~8.94 0 4.6 70 5.960 71.3Low 3.4 70 3.76 0 4.460 1,.120 476

* H gh protections assume a gradual dechne in mortahty, constant fertihty, and positwe netmigration. Low projections assume a gradual dechne in mortahty, constant fertihty, and no netmigr a t ion.

O U S. Census estimation for 1975 indecates that actual population for the State and all threecounties was below the " low'* projection prewnN in this table.

Source E R, Table 2.2 22.

The Blanding airport, about 5.6 km (3.5 miles) north of the prospective mill site, has plansto expand its existing runway and storage areas by summer of 1979. An increase in flightsto and from the facility may accompany these improvements (Manager of Blanding City Airport,personal comunication, Aug. 2,1978). The Ute Mountain Indian comunity of White Mesa iscurrently considering requesting the use of the idle Blanding Launch Site, part of the WhiteSands Missile Range, from the U.S. Ant:y. This property, which is approximately 6 km (4 miles)south of the mill site, would be used for a community center and would not have pennanentresidents.

2.4.1.3 Transient population

Although the permanent population in southeastern Utah is relatively low, this area receivesa substantial number of tourists each year (Table 2.7). Capital Reef National Park alone hadnearly 0.5 million visitors in 1976. The exact numbers fluctuate from year to year, but theoverail trend appears to be toward increasing visitation. Manti-La Sal Forest, which is sixmiles north of Blanding, is the nearest recreation area.

2.4.2 Socioeconomic profiles

2.4.2.1 Social profile

Housing

Blanding. From 1972 to 1975, approximately 12 new units were added each year, but in 1976 thatfigure rose to 37.2,3 In 1977, 43 new dwelling units were added, and this accelerated rate ofconstruction appears to be continuing (City Manager of Blanding, Utah, personal corm:unication,July 10, 1978). Mobile homes in this area are often found on individual lots in single-familyneighborhoods as well as in mobile home parks.

At present, the supply of new housing is keeping up with the number of residences, and thevacancy rate is very low. Approximately 200 lots are available for single-family houses inBlanding to accommodate future growth. There are also around 25 current vacancies in a localmobile home park (ER, p. 4-18). The supply of rerital units in Blanding, as in many smallcities, is low (ER, p. 2-50).

2-8

Table 2.7 Visitor statestecs. recreation areas in southeastern Utah *__

- - . - -

Area~ - - - -

- ~-

1972 1973 1974 1975 1976 197 7 (January -Septernher )

rMen Canyon Narronal Recreat on Area 60 8

Canyonlands Natiena' Park 60 r 62 6 59 o 71.8 80.0 67.3

Mante L4 Sal Nat.onal F orest 1o53 100 9 88.7 76.4 N A'

(ositor days)"

Capital Reet Nat.onal Pat k 272o 311 2 234o 292 1 469 6 364.2(through Augusti

Hovenwen National Monurnent 12 1 12 0 11 0 13 2 19.4 16 2d

Natural Bridges Nat.nnal Monurnent 58 5 42.7 40 3 48 4 71 9 67.1

_ _ _

# Data refer to at tual visitations for each area except Manti La Sal National Forest. Here, data indicate recreation wesetor

dayi A visitor day is the equivdent cf one person entering an area for 12 hr.# Data sefer to the Monticello Ranger D strict only.# indmates data not avadable.dData refer to the Smiare Tower Ruin Unit near Htarwfing

Souu e E R, Table 2.2 5.

i

Monticello. During the five years of 1972 through 1976, the supply of tausing in Monticellowas iidre~asing at approximately six units per year. V In 1977 this figure jumped to around60 units per year, and between 60 and 80 new units are expected to be const/ucted in 1978;however, the demand for housing has not yet exceeded tha supply (City Manager of Monticello,Utah, private communication, July 20,1978). An expected annexation will double the size ofthe city and provide room for at least 150 more single-family homes. Approximately 35 vacanciesnow exist in local mobile home parks (ER, p. 4-18). As in Blanding, rental housing is scarce.A 23-unit apartment is currently being constructed to accommodate some of the demand for thiskind of housing (City Manager of Monticello, Utah, private communication, July 20,1978).

Bluff. Over the last five years, the' supply of new housing in Bluff has increased at a rateoT TTve or six new housing units annually and the demand has not exceeded the supply. Theexistence of approximately 70 vacant lots with water connections and available spaces in twomobile parks within the city limits indicate that Bluff is capable of accommodating futuregrowth (ER, p. 2-56).

HanksvillP. HanksVille Currently has no excess housing supply, and the majority of familieslive in mobile homes. Hanksville is presently installing a new water system to service theexisting comunity and to provide service for 24 new building sites for permanent housing.

Public services3

Blanding. Water is obtained from. surf ace runof f and underground wells, and an 0.ll-m /secTM00-g .) sewage treatment plant is operated by the city. Water consumption in 1976 averaged0.023 m /sec (547,000 gpd). The current system is adequate to handle moderate populationincreases, and improvements are being planned to handle the influx of new residents expected by1981 (City Manager of Blanding, Utah, personal comunication, J:.ly 10,1978). Sewage treatmentis provided through a lagoon system, and improvements are planned for the near future. Elec-tricity is provided through a city-owned distribution system; the city also provides solidwaste collPction and disposal. Propane gas is available through two private distributors, butthere is no natural gas service (ER, p. 2-46). Local streets are maintained jointly by thecity and county (Treasurer of San Juan County, Utah, personal corriunication, July 25,1978).

2-9

Blanding has a f ull-time police force of three of ficers and an auxiliary force of eight, anda volunteer fire department provides fire protection. Health care is available through the36-bed San Juan County Hospital in Monticello, a 31-bed nursing home in Blanding, and two localdoctors, one public health nurse, and one dentist. There is a mental health clinic in townwith one full-time therapist (ER, p. 2-47).

Two elementary schools and one high school serve Blanding. The combined capacity of theelementary schools is 750 students, 630 are currently enrolled. With 874 students, however,the high school has 174 students more than the planned capacity. The opening of two new highschools, scheduled for the near future (one in 1978 and one in 1979/1930), should eare thecurrent overcrowding (ER, p. 2-48).

Blanding's recreational resources consist of one swiming pool, one li hted ball field, onenine-hole golf course, three parks, and a school sof tball field and gymnasium that are alsoavailable for public use.6 Local residents also have access to several National parks, forests,monuments, and recreation areas (Table 2.7). The San Juan County Library is located just northof Blanding (Treasurer of San Juan County, Utah, personal comunication, July 25,1978). Inaddition, the applicant has recently provided support for certain recreational endeavors in thelocal area through the sponsorship of athletic teams and related activities. To acconmodateanticipated future growth, the city has set apart an area for an additional ball field andpark.6

Monticello. Water is supplied by surface runoff and groundwater, and, as in Blanding, thereis a city-operated water treatment plant. Improvements to the water supply system are beingundertaken to raise its overall capacity (City Manager of Monticello, Utah, personal comuni-Cation, July 20, 1978). Primary and secondary sewage treatment is provided by a local digestorplant, and future improvements are planned (ER, p. 2-51). The City of Monticello distributeselectricity supplied by Utah Power and Light to city residents. The transmission system is nowat capacity, but Monticello's city manager has said that the city is currently consideringways to expand its service area. Natural gas is available through the Utah Gas Service (ER,p. 2-53). Monticello currently operates a waste disposal service, and street maintenance is ajoint responsibility of city and county.

Police and fire protection is provided by the three full-time police employees and one part-time police employee. They are aided by the County Sheriff's Department and a volunteer firedepartment with three trucks (ER, pp. 2 53 and 2-54). The 36-bed San Juan County Hospital anda small mental health clinic with one therapist and one outreach worker are in lionticello.There is also a public health nurse in town.

There are an elementary school and a high school in town, both of which are currently operatingat about two-thirds of their peak capacity. The elementary school, which can handle 550students, now has 365 enrolled. The high school, designed for 500, serves 370 students(ER, p. 2-54).

Three public parks, one swiming pool, one golf course, a local ski resort, and the Nationalareas listed in Table 2.7 provide recreational opportunities for area residents. One of thecity parks is currently being expanded, and it is the judgment of the city manager thatthese facil ies are adequate to handle future mill-induced population increases.6

3 (2 x 105-gal)Bluff. The water system for Bluff consists of three artesian wells and a 760-mstorage tank capable of servicing a population almost double the present one. Sewage treatmentis currently provided through individual septic tanks although construction of a comunitytreatment facility has been proposed (ER, p. 2-56).

Two sheriff's deputies are responsible for local police protection, and fire protection is theresponsibility of an eight-person volunteer fire department. Bluff residents have access tocounty health services in neighboring cities, and outreach workers for the Four Corners MentalHealth Agency are available.

One elementary school, with a capacity of 200, provides education for the 104 students. A pro-posal for expansion of recreational facilities was recently defeated by comunity voters,leaving one park, one ball field, and the recreational areas shown in Table 2.7.6

2-10

hanksville. A single privately owned well supplies water to panksville residents and isoperatTnfat peak capacity although installation of a new water storage and distributionsystem is under w iy. Na ver unity sewqe is provided. A county dep is available fnr citywnte disposal (Ep p. 2-/ J. The Gar-hane power Company supplies electricity in this area(ER. p. 2-74).

Law enforcer:ent is provided by one part-time sheriff and road maintenance is also providedby the county. Arbulance and emergency medical services are available in town * however, thenearest rnedical clinic is in Green River, 97 km (60 miles) to the north. The nearest hospitalis over 160 bm (100 miles) away in Moab (FR, p. 2-72).

Hanksville's Eg elementary students attend a local school with an enrollment capacity of 60.Middle and high schoolers are bused to Bicknell, 105 km (65 miles) away. The middle schoolhas a current enrollment of 105 and a capacity of 120; the high school has 155 students andthe ibility to take 200 (ER, p. 2-74),

tulture

Navajo and Ute Indian populations concentrated in southern San Juan County have their owncultural heritage. As shown in Table 2.3, altiost half of the county's residents are nonwhite(46.4;), and most of these are Navajos. Religion is another siqnificant influence in south-eastern Utah. The predominant Church of Jesus Christ of Latter Day Saints stresses within itst elief s the values of f.mily lif e, education, and c.arriaqe and provides a focus for comunitylife. Tatsle 2.8 also corpares the aqe and edxational attainc.ent of the three counties and theState as a whole.

Table 2 8 Selected demograptuc charactenst.cs. San Juan County, compared to Ut4h (19 70)

' , Jo .o G m% Wav + n onty God cut County U t ahr,

0.f c p ,po i,,s ., 9 6t m, 1.6 3 H 3.151 1.05'.12/3s

HeeMw s , l 'il 1,o13.8800 9. - i *. i 4n 4 74

f fm af.onW1 sn s. br a ,I ,c.u s 10 / 12 1 17 2 17 5

t o,npic teel (pr.sa laimr.2 5 v,.ar s ..d ose, i

Peo . , t ,,+ pou t,t ,. .n with 2/o 12 03 20leu than 5 year s

Peo eot of populat.on w,th H8 89 81 14 04 year s of rolley et t ru ir e

Ay

%bao af 18 0 7/ 3 70 4 23 0Peu e nf unde.t 5 yeas s 13 9 14 87 10 6Peu ent 5 11 36 0 35 4 32 6 29 6Pen ent 1H 04 456 49 3 49 4 52 5Peu ent t;5 + 45 79 98 73

- - . - - . -- - - _ -

soun e e n. rahn.s 2 2 4 ana 7 2 21

2.4.2.2 E c onom_i c_ p ro f i l e.

Between 1970 and April 1978, the number of nonagricultural payroll jobs in San Juan Countyincreased by over 1000 - from 1786 to 2452. The relative importance of the various economicsectors also shifted in that period. Services stayed nearly the same; the relative importanceof trade, transportation, construction, and manufacturing declined slightly; and the signifi-cance of finance, insurance, and real estate rose a little. The importance of mining and

2-11

government changed dramatically, however. Employment in government servic.es declinedfrom 31.6 to 24.5%, while mining climbed from 21.3 to 31.7':,of the total.

Because total emplopent increased so greatly, the absolute number of jobs rose in all cate-gories. The largest increase by far, however, was in mining, which grew from 381 iobs in 1970to 935 in April 1978. In the one-year period ending April 1978, the largest numerical increaseswere experienced in constr.uction, mining, trade, and services (Table 2.9).

Tatie 2 9. Nonagnmitural payroll jobs in san Juan. Wayne. and Garfieldcour ties from Aped 1977 to April 1978

_ _ _ . . _ . . _ . . . _ _ . ._.

Apr 1 Percent of Apr a Percent of1977 total 1978 total

San Juan County

Monutacturing 185 66 197 67 65

Mening 890 31.5 935 31.7 5.1

Constr uc tion 142 50 155 52 92Tr ansportation. commer ce. utdetas 157 56 168 5. 7 7.0

Trade 400 14.2 424 14 4 6.0Finance, insurann, reat estate 25 09 27 09 80

Serv <es 303 10 7 322 10 9 6.3

Government 718 25 5 724 24 5 08

T otal 2820 100 0 2452 100 0 47

Wayne County

Manuf actur ing 28 6.5 24 65 36M in ing 48 11.1 50 11.2 42

Con str u ct <>n 63 14.6 64 15 4 95Tra.wpor tat.on, comroe,ce, utd.t+es 2 05 2 04 -

Tr ade 44 11.4 52 11.6 6.1F .n.nre. insur ance, real estate 7 16 7 16 -

Services 23 53 24 54 4.3

Go w enment 211 49 0 214 47.9 14

Total 431 100.0 447 100 0 3. 7

Garfield County

Manu t actu r,nq 237 19.1 252 19 4 6.3Mining 46 3. 7 48 3.7 4.3

Constructmn 57 46 62 4.8 8.8

Tranun tation. commerce. utaties 66 5.3 71 54 7.6

Trade 184 14 9 195 15 0 6.0F inance, insurano, real estate 14 1.1 15 1.2 7.1

Serv.ces 288 23 3 306 23 6 62Gover nment 347 28 0 350 26.9 09

Total 1234 100.0 1244 100 0 4.8__

Snurce Utah Depes tment of Employment Searity, Research and Analysis Section, adapted fromQuarterly Employmerrt Newsterter of Southeastern Distnct of Utah, January -Apra 1978

The mineral industry is extremely important to San Juan County, and uranium production is asubstantial component of this sector. In fact San Juan County is the largest producer ofuranium in Utah, and this activity has increased dramatically since 1975 (Utah Geologicaland Mineral Survey, private communication, July 17,1978). Natural ges and crude oil arethe other important materials being produced here (ER, p. 2-32).

Tourism is also an important part of San Juan County's economy, a part that has been increasingsteadily in recent years. Between 1975 and 1977, tourist room rentals increased by 32.5%.

2-12

Total nonagricultural payroll employment in Wayne County was 447 in April 1978 (Tabic 2.9).The qwcr nr.ent employed almost 50: of those workers, and construction, trade, and miningactivities accounted for nearly 40

in Garfield County, nonagricultural er.ployment for April 1978 totJled 1244 (Table 2.9). Thegovernment accounted for slightly over 25L of this employment, services for slightly under 251,manufacturing for almost 20:, and trade for another 15?

iletween 197 3 and 1977, per capita income for the State of Utah rose by 44; f rom $4100 to$5900. Increases in per capita income f or San Juin County did not 6eep pace with raises else-where. I n t nrne in 1973 was $2400, 58.5! of the State average, and 1977 income was $3400 or57.6L of the State figare (Table 2.10).

Between 19/U and 1977, unemployment fell for the State as a whole and for Wayne, Garfield, andSan Juan counties The State figure went from 6.1 to 5.3:, Wiyne County, from 8.5 to 7.2t,Garfield, from 19.2 to 7.91, and San Juan, from 10.7 to H.1; (Table 2.11).

The characteristics of job applicants in San Juin County, where the ' white Mesa mill is to belocated, are listed in Table 2.12- Most jobs in eining are classified in the " miscellaneous"section.

1he number of retail and wholesale establishments and their sales are shown in Table 2.11 forSan Juan County and the cities of Minding and Monticello. Since 1967, county wholesale andretail sales have both nearly tripled. petail sales are almost ewenly divided between Clandingand Monticello, together accounting f or 94.3: of the county's total retail activity.

In 1977, San Juan County levied an ad valorem tax of 16 mills on the assessed value of allproperty in the toonty for the goneral fund. An additional 40 mills was collected for thecounty school district and a final 2 mills f or the countywide water conservation district. Thecomunities of Monticello, Blanding, and Bluf f also levied an extra 15, 21, and 10 mills,respectively, on the assessed value of all property within their torporate limits, finally,the Monticello and Blanding Cemetery Districts each collected 2 mills on all property withinthose district boundaries Mines and mills are subject to the above taxes as is all other realproperty. The total amount collected f rom all these f unds combined was $5,126,748 (Treasurerof San Juin County, Utah, personal cociconication, July 25, 1978), two-thirds of which went tothe CoJnty School District. In addition to the property tax, San Juan County also received$R7,49fi in sales ta ns.

San Juan County handles its financial af fairs through a number of separate f unds, the largestof which is the general fund (Appendix C). Within this fend, the prot;erty tax comprises thelargest single source of revenue, accounting for silqhtly over 33 of the 1977 total. Sharedrevenues f rom the State of Utah contributed another 20.1;, and Federal shared revenues andin-lieu-of-tax payments added another 15.3

The largest expenditure for San Juan County in 1977 was for road maintenance ($1,176,000)amounting to slightly over one-half of total county funds. Other large outlays were 11.2;for health services Jnd 6.4E for the Sheriff's Department,

in the fiscal year ending in June 1977, the largest source af revenue for the city ofBlanding's general fund (Appendix C) was the sale of a general obligation electric ,water , and sewer-improvement bond issue, yielding $225,000. This was followed byslightly over $55,000 from sales and use taxes and a little more than $44,000 from property

Federal revenue sharing and waste collection and disposal fees were the other majortaxes.sources of funds, each contributing about $18,000 to the total. Utility operations werefinacted through a separate fund.

Blanding's major expcnditures in the same year were for pubitc utility capital improvements andpolice expenses, nach of which cost less than $50,000. Street maintenance cost about half thisamount, and waste collection and airport funds made up the last of the major expenditures.

2-13

Table 210. Per opeta mcomes for Utah and Wayne, Garfield, andSan Juan counties, 1973-1977

. . . - . - _ . . . . _ . . . . _ . - _ . . . _

85 tate or county 1973 1974 1975 1976' 1977. . _ . . _ . _ _ - . - - . . _ _ - _ _ _ . . . -

Utah $4.100 $4.500 $4.800 $5.300 $5.900Wayne 3.100 3,400 3.800 4.100 6.100Gar f eeld 3.400 3.300 3.500 4.200 5 000San Juan 2.400 2.700 2.900 2.900 3.400

_ . . _ _ . _ _ . _ _ . . _ __ _ _ . . . _ _ _ _ _ _

# Rev6ed6 Preliminary estimateSour ce Utah Depar tmen t of Ernployment % urity, Researc h and

Analyses Sect.on, adapted from Quarterly Employment Neuwletter of$4wtheastern D, strict of Utah, J.nuai r - Masc h 19 78.

Tatde 2.11. Total cmtian labor and unemployment for Utah and Wayne,Garfield, ard San Juan counties,1970 and 1977

- - . _ _ . . . _ . . _.__ . _ . . _ _ _ . _ _ _ . - _ _ _

State or Labor force Un,*mploy ment Unemployment rate

(taant V 1910 1977* 1970 1977' 1910 1977'. . - - . -_ _ ._. . - _ . - _ - _ . - - _ - _ . _ - . - . _ . . - - . _ - . _

Utah 414.248 551.900 25.214 29.500 6.1 5.3Wayne 654 880 57 63 8.5 1.2

Gaf f aeld 1.483 1.773 285 140 19 2 7.9

San Juan 3.015 4,198 322 341 10.7 8.1_ __ _ . _ . . . . _ _ . _ _ . _ _ . . _ _ .

'Preliminar y .Sour ce Utah Department of Employrrwnt Secur.ty, Researth and Analysis Section,

miapted from Quarterly Employment Newsletter of Southeastern Dustnct of Utah,.lanuary March 1978.

Table 2.12. Occupational characteristics ofjob apphcants en the Blanding area,

January-March 1978

includes per sons actively seekir g employment,some of whom were employed at the time

_

Prof essional, technical, managerial 44

Cies ital. sales 59%vice 76Farm, fisheries, forestry 39Prncessing 5Machine trades 27Bench woe k 56Structural 156

Miscellaneous 51

Total 513

Source: Utah Department of Employment Security,Research and Analysis Section, adapted from Quar-terly Employment Newsletter of Southeastern Dos-trict of Utah, January-March 1978.

2-14

Table 213. Retail and wholesale activity in San Juan County,Blandeng, and h*onticello (1976)

_

San Juan County Btareng Mont.ceuo

Numte of reta,i 101 35 40estab6shments

Retail sales $15.300.000 $ 7.150.000 $7.280.000

Numte of wholesaic 9 3 3

estabbshments

Wholesale sales $ 5.000.000 N A* NA_ . . _ _ _ _ _ _ . . _ _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ ____

* NA. Infoemation is not avadable.

Source Utah Industnal Develtoment Information Svstem. Economic factsfor San Juan County, Bleding. md Mantoatlo.19 71.

As in Blanding, Monticello has a separate fund for operating public utilities. Over $350,000was spent during fiscal year 1977-1978. Slightly over half of the city's nearly $150,000 ingeneral fund revenues for the fiscal year ending June 1978 came from sales and use taxes, whileproperty taxes contributed another 254. Unlike the county, both Monticello and Blanding receivemore of their general funds from sales taxes than from property taxes. The largest expenditurein 1978 was the $54,800 spent on administration. This figure was followed by the $49,400 spentfor police protection.

2.4.2.3 Transportation

A systen of two-lane paved highways and unimproved roads accounts for virtually all transportof people and products in and out of San Juan County. Although Blanding, Bluff, Monticello,

' and Canyonlands National Park have small municipal airports, there is no rail, bus, or com-mercial air service (ER, p. 2-30).

U.S. Route 163 receives a greater amount of traffic than any other road in the county. Thishighway runs between I-70 on the north [approximately 161 km (100 miles) from the proposedmill] and U.S. Route 160 in Arizona to the south; the highway passes through Monticello,Blanding, and Bluff. The heaviest traffic in the county is on this artery just north ofMonticello, where the average daily vehicles were about 2685 in 1975. More recent figuresindicate a 43t increase in traffic in this area between 1975 and 1977 (ER, p. 2-30).

Traffic volumes on Utah Route 95 from the Blanding area to Hanksville are much lighter buthave been increasing in recent years (Table 2.14). From 1975 to 1977, an increase of 33% wasobserved on Highway 95 south of Hanksville (ER, p. 2-30). U.S. Route 666 from Monticello toCortez, Colorado, also carries a significant amount of traf fic.9 All of the roads in this areacarry a substantial amount of out-of-state traffic (Table 2.14).

2.5 LAND USE

2.5.1 Land resources

Southeastern Utah is known ts the Canyonlands area; an arid climate and rugged terrain havelimited permanent settlement of this region. Large rock formations and deep, narrow canyonsare characteristic of the area, and these, combined with the Indian ruins found here, areattracting increasing numbers of tourists (ER, p. 2-23). Much of this area is isolated, how-ever, and the population density is low (Sect. 2.4.1.1).

The site of the proposed White Mesa Uranium Mill consists of 600 ha (1480 acres), approximately8 km (5 miles) south of the city of Blanding off U.S. Route 163. About one-third of the totalsite is scheduled to be actually used for mill operations and tailings disposal. The irrediatearea is bordered by both privately owned and Federal land.

2-15

Tatde 2.14. Traffic solunws en 1975 for san Juan County and Blendens Hanks = die route

Appron , mate

#'*9' d''|Y D''''"' *9' OfH.@wat sepent

traff ac c(asets' out of statepassengre traf f rc

Utah Rouie 95 Stand.ng to Natural Bridges 310 20

Natt. MonumentNatural Brutps to Hite 95 10

Hite to Hanksveile 95-290 10-20

U s. Route 163 Monticello to la sal Junction 1490-2685 20 -35Mone.cetto to Bis ding 860 -1985 10- 25

Blandung tu Utah Route 262 turnott 740-925 20- 30

Utah Route 262 to Bluff 530 40

Bluff to Monaten Hat 500 40

Utah Route 263 Route 95 to Haus Crossing at 25 -35 20

Glen Canvon

Utah Route 261 Route 95 to Meu<an Hat 130 50

*Teo f, pares in reus coeurnn represent vabes yven few d.fterent points siong the route onefwre ersticates that a traf tc count was taken at only orie location.

Suorce E R. Tat 8e 2.2 9

Much of the land in San Juan County is Federally owned (see Table 2.15). Approximatelytwo-thirds of this land is administered by the U.S. Bureau of Land Management for multipleuses such as grazing, mineral extraction, timber production, and wildlife management. AnotherOne-fifth of the Federal land is managed by the National Park Service and slightly less thanone-sixth is under the control of the U.S. Forest Service (ER, p. 2-25). One-fourth of thetotal area is Indian land. Nearly all of this territory is part of the Navajo Indian Reser-vation, but a small portion belongs to the Ute Mountain tribe (ER, pp. 2-23 to 2-26). TheState owns 6.5% of San Juan County, leaving only 8.3% in private hands (Table 2.15).

Table 2.15. Land ownership, Wayne. Garfield, and San Juan counties,1967

Wayne County Garfield County San Juan County

ha acres Percentage ha acres Percentage ha acres Percentage

F eder al 542.055 1.338.875 84.2 1.195.842 4.953.729 89.n 1,208,247 2.985.630 59 8

State $4.3 73 146.651 9.2 90.167 222.712 6. 7 131,707 325.317 6.5

Ind;an 0 0 0 0 0 0 505.086 1.247.563 25 0

Pr ivate 40.472 99.965 6.3 53.578 132.337 4.0 168.664 416.600 8.3

Urban and 2.193 5,416 0.3 3.507 8.662 0.3 6.177 15.253 0.3

transportation

Small water # 54 133 b 389 960 b 404 907 b

Total area 644.146 1.591.040 100 0 1.343.481 3.318.400 100.0 2,019,940 4.991,360 100.0

* Includes water ateas of 0 8 to 16 ha (2 to 40 acres) and streams less than 0 20 km (0125 mdel m length

* Less than O.1%

Source E R. Table 2.2 23. e

In Wayne County, much of the land is Federally owned (Table 2.15). As in San Juan County,administration is split between the U.S. Bureau Of Land Management, the U.S. Forest Service,and the National Park Service. The State controls 9."e of the land in Wayne County, and 6.3%is in private hands. There is no Indian land.

2-16

Garfield County exhibits almost the same ownership pattern as neighbcring Wayne County. Federalland control is exercised by the U.S. Bureau of Land Management, the U.S. Forest Service, andthe National Park Service (ER, p. 2 63). State land accounts for 6.7t of the total, and privateland comprises another 4%. There is no Indian land (Table 2.15).

Because of the arid nature of this area, the primary agricultural use of the non-Federal prop-erty in all three counties is rangeland (Table 2.16). The land within 8 km (5 miles) of theproposed mill is primarily used for grating. In addition to the uranium ore buying stationcurrently operated at the site by Energy Fuels Nuclear, Inc. , nonagricultural land uses inthis area include the Blanding airport, a small commercial establishment, a part of the UteMountain Indian community of White Mesa, several structures connected with the U.S. ArmasBlanding Launch Site, and another ore-buying station, operated by plateau Resources. Inc.(ER, p. 2-29).

TsNe 216. Land use m Wayne, Geefield, and San Juan counties escluding Federal land.1%7"-..w.,--m.< >ow

Wavrie County Gar f.cid Count y San Jua i County

ha greg Pe r r.rn t ry ha au es Per cent asy ha ac.r es Pee t.cnta

Cr ositaml 8.829 21.815 H6 13.651 33.732 92 59.093 146.016 73

Ir rigated H.879 21.815 86 12.891 31.f%9 8/ 2.818 7.111 0'

Newur e opted 0 0 o 154 1.863 05 % 215 1 4.905 69

Pasture 0 0 0 1.481 3hbo 10 24.497 6t wM 30

H anyeland 69.465 1/1.645 68 0 91,923 221,139 62 3 511.139 1,263.001 t.10F orest 4.23; 10.464 42 24.331 60,120 16 5 181.100 462.318 23 0

Other* 17.7/1 42.691 16 9 12.302 30,398 83 23.314 57.608 29Ur twi and 2.192 5.416 21 3. <,06 8.662 24 6.113 15,253 08

tr arnpoe ta t u

Small * ate / 54 133 389 960 03 403 991

Torai nem f ederal 10.205 252.165 100 0 141.582 364.671 100 0 811.119 2.005.730 100 0

F eder al 541.843 1.338.8/5 1,195.374 2.953.729 1.208.284 2.985.630Total county ar reagn 643.894 1.59 t.040 1.342.956 3.318.400 2.020.n03 4.991.360

.~ - - _ __

* Water meat of mae tha 16 km (40 acre 4 and rivers w' der than 0 20 i m 10125 mild are en.!aled6"Orter" artluiles strip emne arcat salt nats, mud fiets. marshes. roi k ousuops, fee.1 tots, farm roads, efitt.h bankt and m u cilaneous

agr imi tur al Iand.' includes wat.r acas of J 8 to 16 ha (2 to 40 m reu and streams less than 0 20 km 10125 emiel m Icogth.

Sour e e E H. Tables 2.2 8 eul 2 2 24

2.5.1.1 Mill ownership,

The surface area Of the entire 600-ha (1480-acre) project site is currently owned by Energyfuels Nuclear, Inc. (ER, p. 2-4).

2.5.1.2 Farmlands

Because the rugged terrain and arid climate of the White Mesa region have restricted Jevelopmentof cultivated croplands, grazing is the predominant agricultural land use (Table 2.16). Dryf arming produces primarily wheat and beans. No unique or prime farmlands exist on the millsite or in the sufrounding area.6

The Federal gcvernment owns and administers, through the U.S. Bureau of Land Management,approximately 60% of the total land area of San Juan County (ER, Sect. 2.2.1.3). This land,

classified as multiple use, is leased for grazing, oil and gas exploration, and mining claims,and is managed for Wildlife and recreation. The majority (63%) of the private land in San JuanCounty is rangeland (Table 2.16).

2-17

The site for the proposed uranium mill (Fig. 2.2) was previously used for grazing. Also, poten-tial grazing land lies on all sides of the applicant's property (Fig. 2.2). Based upon primaryproduction for rangeland in fair condition, and assuming 50% of the primary production will begrazed, grazing capacity of rangeland in the vicinity of the site is conservatively estimated atabout 0.69 to 1.24 animal units nonths (AUtis) per hectare (0.28 to 0.5 AUMs per acre);10 that is,about 0.8 to 1.4 ha (2 to 3.6 acres) of rangeland are required tn support one cow or five sheepfor one month per year. The nearest cultivated cropland (alfalfa) occurs 2.4 km (1.5 miles)north of the site boundary, and the nearest garden plot lies approximately 1.6 km (1 mile)north.10

2.5.1.3 Urban areas

The concunities of Blanding, Monticello, and Bluff, all within 48 km (30 miles) of the proposedWhite Mesa mill site, and the town of Hanksville,16 km (10 miles) from the Hanksville orebuying station, have been discussed in detail in Sects. 2.4 1 1, 2.4.1.2, and '.4.2.1. The twolargest of these, Blanding and Monticello, have a number of .equlations govert nq land use,including zoning, subdivision regulationL, and bJilding Codes (City Manaaer of Blanding Utah,and City Manager of Monticello, Utah, personal conmunications, July 10, 1978, and July 20, 1978,respectively).

2.5.2 Historical, scenic, and archeological resources

2.5.2.1 Hi_storical sites

Although there are no cultural sites on or adjacent to the proposed mill site which are presentlyincluded in the Natior.al Register of Historic Places (National Register), the White MesaArcheological District has been determined eligible for inclusion in tre National Register.Landmarks of southeastern Urah currently included in the National Register are summarized inTable 2.17. Closest to the proposed mill site is the Edge of Cedars Indian Ruin, located inBlanding (approximately six miles north of the proposed mill site).

A historical survey was conducted on the proposed mill site, and six historical sites wereidentified. Five of the six historical sites are currently under review to determine eligibilityfor the National Register.

2.5.2.2 Scenic areas

Southeastern Utah is known for its unusual scenic qualities, in particular the abundance ofmassive stone arches and other outstanding rock formations. The general area features a uniquelyrugged terrain with wide vistas, badlands, and steep canyons.

Canyonlands National Park is an area of unusual, interesting geological formations, and the GlenCanyon National Recreation Area on Lake Powell is a man-made lake on the Colorado River.Capitol Reef National Park contains numerous colorful stone formations. At Natural BridgesMonument, rock arches span deep canyons, forming the largest natural bridges in the world.These and other natural and scenic landmarks draw visitors to southeastern Utah every year. Inaddition, the area contains an abundance of Indian ruins and petroglyphs. Newspaper Rock StatePark, Edge of the Cedars State Park, a v Hovenweep National Monument are noted areas of scenicar.d archeological interest (Fig. 2.1). Closest to the proposed mill site is Edge of The CedarsState Park (historicia monument), located in Clanding (approximately three miles north of theproposed mill site).

2.5.2.3 Archeological sites

Archeological surveys of portions of the entire project site were conducted between the fallof 1977 and the sprinq of 1979. The total area surveyed contained parts of Sections 21, 22,27, 28, 32, and 33 of T375, R22E, and encompassed 809 ha (2000 acres), of which 81 ha (200 acres)are administered by the U.S. Bureau of Land Management and 130 ha (320 acres) are owned by theState of Utah. The remaining acreage is privately owned. During the surveys, 121 sites wererecorded and all were determined to have an affiliatioh with the San Juan Anasazi who occupiedthis area of Utah 40m about 0 A.D. to 1300 A.D. All but 22 of the sites were within the

2-18

ES-4SS,

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.

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.

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Fig. 2.2. Land Ownership in the v?cinity of the project site (0BS = ore-buying station).Source: ER, Plate 2.1-3 and Sect. 2.1.

Note: Energy fuels Nuclear currently owns T375 R22E Section 33, SEk, but this quarter sectionis not part of the proposed project.

project boundaries. Table 2.I8 sunnarizes the recorded sites according to their probabictemporal positions. The dates of occupation are the best estimates available, based on pro-fessional experience and expertise in the interpretation of archeological evidence. ' Availableevidence suggests that settlement on White f4esa reached a peak in perhaps 800 A.D. , Occupationremained at approximately that level until some time near the end of Pueblo II or in thePueblo II/ Pueblo III transition period. After this period, the population density declinedsharply, and it may be assumed that the White Mesa was, for the most part, abandoned by about1250 A.D.

2-19

Table 2.17. Histor.c sites in southeastern Utahinduded in the " National Register of

Historic Places"_

Location Site

San Juan County

Blanderw Edge of Cedars indian Ruin

3s me!es southeast of Blandng Hovenweep National Monument

Southeast of Mexican Hat Poncho House

25 miles southeast of Monticello Alkale Ridge

30 miles west of Monticello Salt Creek A chaeologicalDistrict

Glen Canyon National Recreation Area Defiance House *

14 miles notth of Montiallo Indian Creek State Park *

Wayne County

Capital Reet National Park on Utah Fruita School HouseRoute 24

3 miles southeast of Bicknell Hans Peter Nielsnn Gristmill

60 miles south of Green Ravn, in Harvest Scene Pictograph

Canyonlands National Park

Green River vicinity Horseshoe ? Burier) CanyonPictograph Panel

Capital Reef National Park Gif ford Barn *

Capital Reef National Park Lime Kiln *

Capital Reef National Park Oyler Tunnef

Garfield County

46 miles south of Hanksville Starr Ranch

Snuth of Hanksville Susan's Shelter

Near Panquatch Bryce Canyon Airport Hangar

*Pending nominations to tte " National Register of Histonc Places "Sources. U.S. Department of the interior " National Register of

Historic Places." Fed. Regist. 41128), Feh,10,1976, and subsequentissues through 43(225), Nov. 21,1978.

Archaeological test excavations were conducted by the Antiquities Section, Divis''n of StateHistory, in the spring of 1978,11 on 20 sites located in the area to be occuplet ' tailingscells 2,3 and 4. Of these sites, twelve were deemed by the State Archaeologist to have sig-nificant National Register potential and four possible significance. The primary detenninantof significance in this study was the presence of structures, though storage features andpottery artifacts were also common.

In the fall of 1978, a surface survey was conducted on much of the previously unsurveyed portionsof the proposed mill site. Approximately 45 archaeological sites were located during this sur-vey, some of which are believed to be of equal or greater significance than the more significantsites from the e lier study. Determination of the actual significance of all untested siteswill require ao .ional field investigation.

2-20

Table 2.18. Distribution s.f recorded setesaccordmg to temporel position

--

Apswon .ma te gTempor al p% tion . tes'

(A D |

Badet Maber 111 575 -750 2

Bedet Maker till 515-850 27

PuetAo 1

Pucbio 1 750-850 12

Pueblo 1/Puchio il 850-950 13

Puebio ll 950-1100 14

Pueblo tt< Pueblo tli 1100 -1150 12

Pueblo ill 1150-1250 8

Pueblo 11 + b 5

Abiticomponent c 3

Unidentified d 14

_ _ __ _ _

* includes transitional seriodsAlttwasgh collections at these locations were lack8

sex) m diagnostic material. available ev derre ind. catesthat the site would have twen used or ocrupeed noearl er than 900 A D. and postetdy later.

'Cer amic collections hom each of the se sitesmd.ca te an occupation entending from Pueblo I

thenuch Pueblo il and into Pueblo Ill.# Rete setes did not pmiute eviderre strong

enough to just f y any identif cation.

Source. Adapted fenm E R, Talde 2.3 2, and fromsupplementar y repor ts on [wolect archeoiogy.

Note: These sites are shown m Fig 3 4.

Pursuant to 10 CFR Part 63.3, the NRC sutoitted on March 28, 1979, a request to the Keeper ofthe National Register for a determination of eligibility for the area which had been surveyedand tested. (The area Contained 112 archeological sites and six historical sites.) Thedetermination by the Keeper of the Natios,al Register on April 6, 1979, was that the White MesaArcheological District is eligible for inclusion in the National Register. Requirements forfurther a' tion to be taken are discu ued in Sect. 4.2.2 and in Appendix E.

2.6 WATER

2.6.1 Surface water

2.6.1.1 Surface-water description

The proposed mill site is located on White Mesa, a gently sloping (11 SSW) plateau that isphysically defined by the adjacent drainages which have cut deeply into regional sandstoneformations (Sect. 2.7.1 and Fig. 2.8). There is a small drainage area of approximately 25 ha(62 acres) above the proposed site that could yield surface runoff to the site. Runoff from theproject area is conducted by the general surface topography to either Westwater Creek, CorralCreek, or to the south into an unnamed branch of Cottonwood Wash. Local porous soil conditions,topography, and low average annual rainfall [30 cm (11.8 in.)] cause these streams to be inter-mittently active, responding to spring snownelt . d local ra. Storms (particularly thunderstonns).Surface runoff from approximately 155 ha (384 acres) of the project site drains westward and iscollected by Westwater Creek, and runoff from another 155 ha (384 acres) drains east into CorralCreek. The remaining 289 ha (713 acres) of the southern and southwestern portions of the sitedrain indirectly into Cottonwood Wash (ER, p. 2-143). The site and vicinity drainages carrywater only on an intennittent basis. The major drainages in the project vicinity are depictedin Fig. 2.3 and their drainages tabulated in Table 2.19. Total runoff from the site (total yieldper watershed area) is estimated to be less than 1.3 cm (0.5 in.) annually (ER, p. 2-143).

2-21

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Fig. 2.3. Drainage map of the vicinity of the White Mesa Uranium Project.Source: ER, Plate 2.6-5.

2-22

Table 2.19. Dramage areas of propect vicmity and region

Drainage areaBasin riescription 2k rn sq meles

Coreal Creek at confluence 15 0 58

with Hecapture Creek

Westwater Creek at confluence 68.8 26 6

with Cottonwood WashCottonwoort Wash at USGS 4531 A205

gage west of pec,ect site

Cottonwood Wash at confluence ABGo <332

with San Juan RiverRecapture Creek at USGs gage 98 38

R*captoee Creek at confluence <518 *200with San Joan River

San Juan River at USGs 9. ige (60.000 ( 23.000downstream of Bluff, Utah

_

Sour ce E R. Table 2 6 3-

There are no perennial surface waters on or in the vicinity of the project site. This is due tothe gentle slope of the mesa on which the site is located, the low average annual rainfall of29.7 cm (11.8 in.) per year at Blanding (ER, p. 2-168), local soil characteristics (Sect. 2.8),and the porous nature of local stream channels. Two small ephemeral catch basins are presenton the site to the northwest and northeast of the present buying station (Sect. 2.9.2).

Corral Creek is an 'ntermittent tributary to Recapture Creek. The drainage area of that portionof Corral Creek abo e and including drainage from the eastern portion of the site is about13 km2 (5 sq miles). Westwater Creek is also en intemittent tributary of Cottonwood Wash.

2 (27 sq miles) at its confluence withThe Westwater Creek drainage basin covers nearly 70 kmCottonwood Wash 2.5 km (1.5 miles) west of the project site. Both Recapture Creek and Cotton-wood Wash are similarly intemittently active, although they carry water more often and forlonger periods of time due to their larger watershed areas. They both drain to the south andare tributaries of the San Juan River. The confluences of Recapture Creek and CottonwcodWash with the San Juan River are approximately 29 km (18 miles) south of the project site. The

2San Juan River, a major tributary for the upper Colorado River, has a drainage of 60,000 km(23,000 sq miles) measured at the USGS gage to the west of Bluff, Utah (ER, p. 2-130).

Storm runoff in these streams is characterized by a rapid rise in the flow rates, followed byrapid recession primarily dut to the small storage capacity of the surface soils in the area(Sect. 2.8). For example, on August 1,1968, a flow of 581 m /sec (20,500 cfs) was recorded3

in Cottonwood Wash near Blanding. The average flow for that day, however, was only 123 m3/sec(4340 cfs). By August 4, the flow had returned to 0.5 m /sec (16 cfs) (ER, p. 2-135). Monthly3

streamflow sumaries are presented in Fig. 2.4 for Cottonwood Wash and Recapture Creek. Flowdata are not available for the two smaller watercourses closest to the project site, CorralCreek and Westwater Creek, because these streams carry water infrequently and only in responseto local heavy rainfall and snowmelt, which occurs primarily in the months of April, August,and October. According to the applicant, flow typically ceases in Corral and Westwater creekswithin 6 to 48 hr af ter precipitation or snowmelt ends.

2-23

Es-4594'

AVERAGE A1% CAL FL0d=800AF-(1965 1974)OR AIN AGE AR[ A= 3. 7 7 SQ. M! .

350 AVfRAGE A499AL TfELD=212.2 AF/50 "!-

24 300*

T! ELD-AF/SQ Mtv*

M14. A WE. MAX.I 26 212 862h (1970) (1972):

; 150?O 100 _.

:-! $0

____- ~__

oct wv Mc w vf.s una are my Aset AAv aso srptM04TH

AVE R AGE A44LAL FL0d=6300 AF (1964-1974)1600 CPAINAG[ AREA =20$ SQ. MI.Av!E AGE A44 VIELD = 31 AF/SQ. MI.

1400 ~

" _

ww

7 1200*

Y !f L D- AF/50. MI .%' M14. AVE. MAR.'

6.7 31 100g (1969) (1972)3 -

z

'J, 6c0W

$ 400::

3200 ff y L_

OCT 8Cv CtC As FE8 ta4R 4* MM AM AA v A4 SIPTMOMTH

Fig. 2.4 Streamflow sunnary in the Blanding, Utah, vicinity. (a) Upper portion of% e watershed near the headwaters of Recapture Creek near Blanding at 7200 ft MSL; USGS3 ge 09378630. (b) Cottonwood Wash about 11 km (7 miles) southwest of Blanding at 5138 ftMSL; USGS gage 09378700. Source: Adapted from the ER, Plate 2.6-6.

2-24

2.6.1.2 Surpce-wa_ter_ quality

The applicant began sampling surface-water quality in the project vicinity in July 1977 andcontinued through March 1978. Baseline data describe and evaluate existing conditions at theproject site and vicinity. Sampling of the temporary onsite surface waters (two catch basins)has been attempted but without success because of the lack of naturally occurring water inthese basins. The basin to the northeast of the proposed mill site has been filled with wellwater by the applicant to serve as a nonpotable water source during planned construction ofoffice and laboratory buildings in conjunction with the proposed mill (approximately six months).This water has not been sampled by the applicant but presumably reflects the poor qualityassociated with local groundwater (Sect. 2.6.2). Sampling of ephemeral surface waters in thevicinity has necessitated correlation with major precipitation events as these watercourses arenormally dry at other times.

The chemical and physical water quality parameters measured by the applicant are listed inTable 2.20. The locations of the surface-water sample sites are presented in Table 2.21 andFig. 2.5, and the water quality values obtained for these sample sites are given in Table 2.22.Water quality samples were collected during the spring at several intermittently (active streams(fig. 2.5) that drain the project area. These streams include Westwater Creek, SlR 59),Corral Creek below the small irrigation pond (53R), the junction of Corral Creek and RecaptureCreek (54R), and Cottonwood Creek (58R). Samples were also taken from a surface pond southeastof the proposed mill (S5R). fio samples were taken at 52R on Corral Creek or at the small wash(56R) locat. d south of the site.

Surface-water quality in the vicinity of the proposed mill is generally poor. Waters inWestwaterCreek(SlRand59)werecharacterizedbyhightotaldissolvedsolids(TOS;meanof674 mg/ liter) and sulfate levels (mean 117 my of 30 per liter). The waters were typically hard4

(totml hardness measured as CaC0 ; mean 223 mg/ liter) and had an average pH of 8.25. Estimatedi

flow rates for Westwiter Creek averaged <0.03 m/sec (< 0.3 fps) at the time of sampling.

Samples from Cottonwood Creek (SBR) were similar in quality to Westwater Creek water samples,although the TDS and sulfate levels were lower (TDS averaged 264 mg/ liter; S0 averageds

40 mg/ liter during heavy spring flow conditions [24 m/sec (80 fps) streamflow].

The concentrations of TDS increased downstream in Corral Creek, averaging 3180 mg/!!ter at 53Ran.i 6f 60 mg/ liter (one sample) at 54R. Total nardness averaged in excess of 2000 mg/ liter, andpH values were slightly alkaline. Estimated flows in Corral Creek were typically less than0.03 n/sec (0.1 fps) during sampling.

The spring sample collected at the surface pond south of the project site (SSR) indicated aTDS concentration of less than 300 mg/ liter. The water was slightly alkaline with moderatedissolved sulfate levels averaging 42 mg/ liter.

During heavy runoff, the concentration of total suspended solids in these streams increasedsharply to values in excess of 1500 mg/ liter (Table 2.22).

High concentrations of certain trace elements were measured in some sampling areas. tevelsof mercury (tetal) were reported as high as 0.002 mg/ liter ($3R, 7/25/77; S8R, 7/25/77).T .is level is 40 times the EPA reconmended limit for the protection of freshwater aquatic life(0.05 ug/ liter).12 Total iron measured in the pond (SSR, 11/10/77) was 9.4 mg/ liter, over ninetimes the EPA reconcended limit of 1 mg/ liter for the protection of aquatic life. These valuesappear to reflect groundwater quality in the vicinity (Sect. 2.6.2) and are probably due toevaporative concentration and not due to human perturbation of the environment.

2.6.1.3 Surface-water utilization

Regional surface water is primarily used for agricultural irrigation and stock-wateringpurposes. Water usage from the San Juan River in Utah alone amounts to approximately12.2 x 103 m3 (9900 acre-ft) per year. Table 2.23 lists the existing surf ace-water appro-priations within the project vicinity. Water uses in San Juan County are presented inTable 2.24.

2-25

Table 2.20. Physscal and chemical water quahty parameters_. __ _. __-

Spec <fic conductance (f.eid). micrombos cm ManganeseTott suspended solids AluminumTerr perature (f eldi As senicpH (lab, f eld) B ar sum

Redon potent +41 BaronTotal d.ssolved sol.ds CadmiurnD.ssolved on ypn (f. elds Chrom omO.! and grease Copper

Total hardness as CACO Lead3

Total alkal,nity as CACO M ccury3Carbcrate as CO Moly bdenum3

Chlor:de N ckelCyamde SeleniumF luor'de SirontrumNitrate as N Vanad.um

Sulfate as SO, 2,nc

Calcium S leer

Iron. total and dissolved Po 210Mapesium Pb 210Ammonia as N Th 230Phosphorus. total as P Uranium (natural)Potassium Ra 22G

S.I.ca Gross aSod.um Gross JChemical ou vgen demand (COD)

- . - - - - _ - . .

Source. E R, Table 61 1.

Table 2.21. Surface water sampling stations_ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _

Station oo. Locat on_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

SI R Westwater Creek at dowr. stream (south) side of H ghway 95 bridp

S2R Corral Creek at downstream (south) side of small bredge

S3 R Cor ral Creek at sosilway of small earthen dam

S4R Corral Creek at junction with Recapture Creek 0 40 km (0 25 mile)from end of geep road

SSR Surface pond south of mell s.te 0 20 km iu.125 milel west ofH.ghway 47

56R Small wash south of mill s:te,1.6 km (1.0 mile) west of H,ghway 47

S7R East side o' Cottonwood Creek, at seep trail intersect.on south-southwest of mill site

SSR East sase of Cottonwood Creek, at seep trailintersec'. ion west

southwest of mill site

SJ Est side of Westwater Creek, at jeep trailintersection- - - . - .-_-_ . . - . , . __

Source. EH. p. 61.

2-26

Tatde 2.22. Water quality of surfec.* waters in protect vecinery. C:endme. Utah

Zero values (0.0) are twlow detection Irmits.

_ . . . _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - . . - .

Samphrw; for dates as g venPa emets

7,25/77 11/10,77 3.23/78 3 23J78' 72577 11/10/77 3'23/78

Weu*ater Cieck. $1 RC 7.orr al Cice k. S2RC

F .cid sswf 4c conduct.vity. umhos 'c m b 490 620 a b

F. eld pH 76 83D.ssolved on y.pn

Temsm ature. "C 3 14

E st maind tion. en br Upo 219(002) 39 9 (0 031

Determination, meirter

pH b 8.2 8 35 b b

TDS (at 180*Ci 496 %9Redom pc,terit al 220 186

A'h ahn.tv f as CACO ) 206 2293

H.,rdoess, total (as CACO ) 262 2893

Castunate (n cop 00 23A'uminum. d ssolved 02 0 10Ammonta (as Ni <0.1 0 18

Arsen c. total 0 007

B ar sum. total <02 0 22

B. won. total 0.1 -40 1

Cadmium, total <0 002 CO 005Calcium, dissolved 76 140

Chhs de 17 38

Sultum, dissolved 31 60

Sfver, dissolved <0005Sulf ate. d.m>sved (as SOg 103 163Vanad+um, d ssot ed <0 01 <0005Manganese dissoNed 0.030 0 04Chromium, totai <0 01 0 01

Copper, total s0 005 0 01F iws .de, dasotved 03 04lion, totat 0 28 15

f ron. dissolved 0 17 0.21

Lemi. total < 0 05 (0 05

Vagneuum. d.uolvet 17 0 26

Wecurv. total CO0005 <0 00003Molytxtenum, d ssolved 0 002N tvate (as N) < 0 05 <0 05Phowd'iorus total Ias P1 0.05 0 06

Potass.um. desolved 28 2.0

Scler sum. Assolved 0003SI.ca d ssuivel(as SO,1 7 9St.ont.um, d. waved 0.44 0.76Uranium, eotal(as U) 0 006 0 004

Uraneum, d.ssolved (as VI O002 0 003

Zinc. d.uohed 0.09 0 04Total organic cartxv. 6 7

Chemeal on vgen ckmand 23 48Od and greew 1 1

Total suspended soleds 12 47

Determinanon. pCa/litar

Grom sis +4 t precis.un b 0.1 t 1.1 4 5 t 2.0 6 6 b

Gross teta t precision 0t9 8t11Ra 226 t prec.s.on 02103 0.2103Th 230 t precision 0.0204 01104Pl> 210 t preces on 0.7123 1.1138

Po 210 t precision 0.1105 00t07

2-27

Tatde 2.22. (Contmuod)__

Sampi.nq tor riates as givenPar ameter

1'25/77 11/10/77 3'23'78 3/23/78' 7 75/77 11/10/77 3.'23'78- - .

" " ' 'Coreal Creek. S3M Recapture creeks. 54Rc

F .eid ucif re conduc tivity. ymhosa m 2000 2400 3500 3500 d d 6000F. eld pH 68 7.9 78 79

D.ssolved os vynTemperature 'C 27.7 8 13 13 14

E st. mated flow. m/he ttpsi 98.7(0 09) 2191002: 65 8 t0 06: 65 8 t0 061 10 910 01)

Determmation, me /Istes

pH 67 80 8 23 8 15 d d 8.11

TDS tat 180'Cl 1350 3160 4095 4t30 6660

Red 2: poten tial 260 240 190 193 195

Aikalinetv (as CACO ) 70 172 23G 236 2743

Hardness. total ias CaCOjl 853 1910 2200 2200 2100

Cas twina te (as 00 1 00 0.0 00 00 003

Aluminum, dissolved 0 04 < 0.1 <01 <01 <0.1

Ammonsa las NI 0.15 ( 0.1 <0.1 0 13 < 0.1-

Arsenic, total < 0 01 0011 0 013 0 010

8arium, totat 0.36 04 0.18 0 22 02'

Baron total 0.1 0.2 02 02 0. 2

Cadmium, total 0.004 0 006 0 01 0 01 0 02

Calcium. d.ssolved 150 78 546 571 649

Chloride 54 152 214 189 556

Sodium. dissolved 115 160 312 315 1205

Silver, d1 missed 0 004 0 02 0.01 0 02

Sulf ate, damived Ias 50 ) 803 2000 2596 2854 37604

Vanadium, desmived 0 004 <0 01 0 005 <0 005 <0 005Manganese. d>ssolved 0 20 0 030 0 05 0.04 0.32

Cheomium, total 0 02 0 01 0 02 0 04 0 04

Copper. total 0.01 0.010 0 02 0 03

Fluoride. damived 0.32 06 08 08

leon. total 0.08 0.09 0.09 0.12 0.30

Iron. disso*ved 0 12 0 07 0 09 0 04 0.10Lead, total 0.04 0.15 0.10 0 08 0 14

Magwssum, diw>h,ed 120 20 359 3 76 353

Mercury, total 0 002 <00005 0 00003 0 00009 000002Molytxienum, dismived <0 01 0 004 0.003 0 004

N,trate (as Ni 0.21 0.11 0.81 0 81 < 0 05

Phosphorus, total las P) 0 21 0 06 (0 02 <0 02 0.06

Potassium, dissolved 13 4.8 69 68 68Selemum, dissolved O.16 0.032 0.027 0.005

Sdica. d.ssolved (as 5 0 ) 10 2 3 3 112

Strontium, dissolved 1.9 22 50 51 12

Ueanium. total (as U) 0.005 0 028 0 046 0 038 0.085

Us aneum, dasolved (as U) 0.002 0 028 0.04G 0036 0.082

Zinc. d.ssolved 0 06 0.02 0 02 0 01 0 02

Total organic cartx,n 11 17 18 22

Chem * Cal on ygen demand 79 234 155 61

0.1 and yease 1 2 <1 1

Total suspended sohdi 9 6 9 24

Determmation, PCs/ liter

Gross alpha t precision 15 t 2 1926 134266 0211 d d 7.022.9Gross teta i precmon 180t20 0 t 29 951 50 3724 25 t18Ra 226 t preces oo 0.0 t 0.3 0.3103 04204 0092003 0.2103

Th 230 t precesion 31105 0.1 t 0 5 13206 0201 1.510.7Pt> 210 t preces.on 1.412.1 2.4126 1.4236 011 1.423.7Po-210 t precevon 0.0 t 0.3 06107 05109 1411.1

2-28

Tau. 2 22. (Contmuodi__ __ _ ._. _ _ .. . _ _ _ _ _ _ . __

p,,,,,,, .__.- _ . _ _ _ _ . _ _"?^''N #_$#' '' ?'."_'_

7/25!77 11/10/77 3 73.78 3/23/ 7ff 7/25/11 11/10'77 3 73'78._ _ _ _ _ _ _ . _ _ __-~ _ .-. - . _ . __ . _ _ . . . _ _ _ _ . _ . _ . _ _ . _ _ _ - _ _ . _ _ _ _ . _ _ _ .

. . _ . _

S..us f ar e_ pond 55R_L Unisamed Wa_.h- .. _$C..#_Cottonwoort Cre_e_k. S__7e_ _ _ _ _ _ _ _ _ _ _ __

f. eld unc.fic corwiut t. wiry. pmhescrm e 100 l'io d d 320F ield pH 68 84 82D,wyved un ygen

femame ntore *C 7 20 12

i stimated f'ow. m h Upd 10971101

Determmation, mg/Ister

pH e 69 7 94 d d 8 36

TOS (at 1HO'C) 264 291 295

Rethan sxitentist 280 130 172

Alkatenity las CACO ) 218 138 1493

Hardrwn, total (as CACO 1 67 I?9 1543

Cartamete (as cog 00 00 23Aluminum, d.wdved 20 10 24

Amnw>ma (as Nn <01 0 19 0 15Assenic, total 0008 0 027

Baoum, total /02 0 33 0 66

tsoe(m. total 0. 2 0.1 s01Cadmium, total 0 007 0 005 0 006Cakium, d swived 22 72 134

Chien use 8 10 7

Smhum. dasolved 06 54 20

Silver, d.swived <0005 (0005.

Sulfate, d swivet (as M)4) 64 20 3 52 6Vaned um, d waved < 0 01 0 012 0 012

Mangewse. diw,lved 0095 0 15 0 69

Cheoeuom. total 0 04 0 04 0 03

Cotr.iev. total 0005 0 02 0 04F fu. wide, dissolved (01 01 02Iron, total 94 11 39

fr on. dinolved 1.2 10 17

tead, tot.1 ( 0 05 (0 05 0 08

Magrevum dawived 32 88 25Mermry. tot 4i (O twX)5 0 00005 0 00007Moi,t=1ermm. da w>aved 0002 0 004

N.trafe las N1 4 26 0 05 0 14Phosphorus, total (as P) 0 04 037 0 85

Poiasuom, diwilved 14 13 2JSeterieum, disu,8vett CD005 <0 (XJ5

Silica. d.swived (as 5 0) 2 7 10

Strontmm. diw3s ed 0 10 0 34 0 49v

Uramum. total 0 004 0 002 0 011

Us anium, dessosved Ies U) 0 003 <0 002 0 007lint, diweved 0.02 0 10 0 OttiTotal orgenec castwo 15 20 10

Chemirat m ygro de mamt 7I 5,8 600.I and yease 2 1 1

Total suse.wted soi.as 2t38 210 1600

Determination, pCi/le ter

Gross aspha t sweos.on e 1 1 t 1.1 12 t 1.1 d d 32e18Gross reta i pewoon 15 t 10 27 t 8 32111Ra 226 t precis.cm 0.2t03 0.110.9 06i15Th 230 t precmon 00t04 09t06 0.2104Pt>210 t pecovon 26t22 00t38 41 t 3. 7Po 210 t pr-c s.on 0 2 t 07, 00t06 00t07

2-29

Table 2.22. (Continuedl

%mpi.no for e14'es as g ven

12577 11/10< 77 3'23.'78 3.73 78' 7.75/77 11'10 77 3 73.78_

Contonarul Creeb 58RC Westwater Creek. SI

F eld son ific <.onttuctivor. umhos tm 550 445 240 240 d d 320F eld pH 66 6.9 81 79 80D 4sdved on yinTempnee ee. "C 35 6 ts 7 7 9u

Estimatert tsow, m hr Ifps) 04 0. 7 80 80 0 28

Determmateon mg1ter

pH 75 82 8 21 8 09 d d 8 20

TOS tat 180'Cl 944 504 275 253 969Redos po ant'al 220 260 210 224 190r

A;kalm+ty in CaCOy 134 195 155 155 147

Ha dncu. Total las CaCOM 195 193 148 154 117

Cae tenate tas cop 00 00 00 11 0 00Alumirmam. dinoivad 30 0. 7 2.4 0.16 40Ammorua las M 0.12 <0.1 0 13 0 16 0 75Arwn.c. total 0 02 0 041 0 032 0037Baium, total 12 02 0 85 1.1 0 81

Boron, total 0.1 02 01 <0.1 01C+1mium, total 0004 (0 002 <0005 0 01 0.006Calceum, diwdved 79 54 IIS 72 172

Chloe ide 13 24 7 6 18

Sod.um. dimisved 36 66 23 21 125

Sif ver. 4 isolvmi 0.002 <0 005 <0.005 0.006.

Suf f ere. d ssolved f as SOal 564 132 39.7 39.7 85Vanad.um, d.uol<ert 0 003 <0 01 <0005 <'O005 0 008Manganew. d;uoeved 0 84 0.065 0 78 0.02 0 60Chroneum. totas 0.14 < 0.01 0.04 0 05 0 60

Copper total 0.09 0.005 0.05 0 05 0 05Fluoride. d:ssolved 0.36 0.2 02 02 02leon, total 150 59 50 53 44

Iron, danoived 14 0 62 19 0.11 2.5

L.ead. total 0 14 0.05 0 10 0 10 0 10

Magnesium, dinoived 24 17 28 17 13

Mercury. totai 0 002 <0 0005 0 00006 0 0012 0.00012Moly bdenum, deswived (0.01 0 to 0002 0 002 0 006Niteate las M 1.77 0 14 0 13 0 12 0 05Phosphorus, total tas PI 0.05 32 0 96 0 84 0 83

Potawum, druoived 6.9 3.2 2.5 1.2 3?Seleneum, d.ssolved 0 08 <0 005 <0005 <0 005Sibca, d uolved las S.0,) 10 8 11 18 11

Stront>um, d uotved 0 64 0 60 0 56 0.34 0 65Uranium. total 0.027 0 004 0.014 0 014 0.004

L>anium. d ssolved (ar tJ) 0.015 0 004 0.008 0 006 0 002Zinc. deswived 0 06 0 05 0 06 0 008 0.12Total organic carbon 7 12 11 16

Chemwal on ygen demand 61 163 111 66Oil and grease 2 2 2 1

Total susperided sohds 146 2025 1850 1940

Determmation, pCi/leier

Grom alpha 1 precis >on 16 t 3 2.911.5 7.3124 2313 d dGross teta 1 precision 72117 0 t 10 28 t11 110 26Ra 226 t prects.on 0611.3 11205 1911.7 2.010.1Th-230 t precision 0.910.6 0.0104 00f03 0.210.1Pb 210 t precision 0.8 t 1.9 0 0 t 2.2 2.5 t 4 3 011Po 210 t p ecesion 0.0 t 0.3 0620.7 0.0206

___

'Rephcare sample analyred for quahty assurance on radeoactivity.'Not enmegh water m stream to sample adequately.* See Table 2.21 for locations of sampling ststions.

#No water in stream to sample.'Not sampled.Source- Adapted from E R. Table 2.6 7.

2-30

ES-4589

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Fig. 2.5. Preoperational water quality sampling stations in the White Mesa. projectvicinity. Source: ER Plate 2.6-10.

_

2-31

Table 2.23. Current surface water users in protect vicinity

poi cat on Apphcat.on Quant ryName Addr e ss ida te number cfs rn r sec

Corral Creek

F rerf Heihday Blanding. Utah August 12.1971 40839 0. 5 0 014

Cottonwood Creek or Wash

Willeam Keller Moab, Utah November 12,1907 1647 1.0 0 028

Hyrum Perkins Blu'f, Utah June 22,1910 3322 5.49 0.156

U S. Ind,an Ignacia. Colorado March 12.1924 9406 1.18 0 033

Service

U S. Indian Seevice Ignacia. Colorado March 24,1924 9491 0.738 0 021

U S. Indian Service Ignacia. Colorado March 24,1924 9492 0 298 0 008

Kloyd Pee kins Blanding. Utah Apro 13.1928 10320 1.455 0 041

W. R. Young Blandmg, Utah October 22.1928 104935 0 0015 0.00004

W. H. Young Blanding. Utah October 23,1928 1049G 0.0022 0 0006

W. R. Young B!andmg. Utah October 22,1978 10497 0 002 0 00005

San Juan Montaetto. Uta5 October 10.1962 34666 12.000 1500

Counts water (acre f t) (ha-a)

Conservat.on d strictE arl Perkins Bf anding. Utah April 16,1965 36924 5.0 0.142

Westwater Creek

Seth Shumway Blanding. Utah January 7,1929 10576 0.005 0 002

H. E. Shumway Bf andmg, Utah Segregation date' February 28.1970 37101a 0 7623 0 022

Preston N elsnn Bianding. Utah Segregation date' October 22,1970 37601a 02377 0 007

Parley Redd Blanding. Utah Claim date. October 16,1970 Claim 2373 0.015 0.0004

Kenneth Mcdonald Blanding. Utah Change of Appropriation: 42302 1.0 0.028

June 12.1974

Source: ER. Table 2 6 4

Table 2.24. Water use of San Juan County,1965._ __ _ _ _._ _.

ConsumptionUse

2 X 10' Acre f tm_ _ _ _ _ _ _ . _ . _ _ _ . .

Irrigated crops 15000 acred 6.785 5.500Reservoir evaporation 123 100

incental use" 1.603 1.300Municipal and industrial" 2,220 1.800

Minerais* 1.357 1.100

Augmented fish and wildi.fe" 123 100

Total 12.211 9.900

* Incidental use of irngation water by phreatophytes andother miscellaneous veyrtation.

* Includes evaporation losses apphcable to these sources of

depletion.

Source: ER. Table 2 6 5.

2-32

2.6.2 Groundwiter

A generalized section of the stratigraphic and water-bearing units in southeastern Utah isshown in Fig. 2.6. Recharge of these aquifers occurs from seasonally variable rainfall infil-trating along the flanbs of the Abajo, Henry, and La Sal mountains and along the flanks offolds. Recharge water also originates f rom precipitation on the flat-lying beds where itpercolates into the groundwater region along joints.

In the White Mesa area, 39 groundwater appropriations (applications for water wells) are on filewith the Utah State Engineers Of fice for wells lying within an 8-km (5-mile) radius of theproject site. All but one of thes? wells produce from the Dakota and Morrison formations.Thirty-five of these are for wells which are actually constructed (ER, Table 2.61). Most ofthese wells produce less than 55 m / day (10 gpm) and are used for domestic, irrigation, and3

stock-watering purposes. The remaining well, which was drilled to a depth of 548 m (1800 f t)by Energy fuels Naclear, withdraws water from the Navajo Sandstone. The majority (31) arehydrologically upgradient or cross gradient with respect to the project site. The remainingfour wells (three or: tite and one of f site, south) are on land owned by the applicant. Two ofthe onsite wells are located in the area of the proposed tailin 'I becompletely plugged with bentonite and/or another suitable clay.gs impoundment and9,0 The well which is offsiteand south will be capped o. used for monitoring purposes.

As is the case throughout most of the four Corners region, the Blanding area depends largelyen groundwater for its water supply. A porous soll, underlain by the Dakota Sandstone on topof a regional aquiclude (the Crushy Basin Menber of the Morrison formation), provides theBlanding area with a near-surface source of groundwater. This situation is somewhat unconnonin the highly dissected south-central portion of the Colorado plateat.

The Dakota sandstone on White Mesa has been completely isolated by crosion; consequently,all recharge to this formation comes from precipitation and irrigation on the mesa. No irriga-tion occurs close to the mill site, and normal precipitation is only 30 cm (12 in.) per year,most of which reenters the atmosphere as n=potranspiration (i.e., it does not nenetrate thesoils over the Dakota). The Dakota is the underlying bedrock under the proposed tailingsimpoundment and has a permeability coef ficient f rom 1.5 to 3 m (5 to la f t) per year (ER,Sect. 4.2.4.1 and Appendix H). Jointing occurs in the formation but is probably not fullypenetrating. An aquiclude, the Brushy Basin rember of the Morrison Formation, underlies theDakota sandstone, which accounts for the groundwater retainad in the lower portion of theDakota.

In the innediate v|cinity, only the Dakota Sandstone and the Salt Wash Member (including theWastwater Member) are significant aquifers. The Entrada and Navajo formaiions contain largerquantities of water, but their depth prohibits comon exploitation, in use for domestic watersupplies.

Comb Ridge and the Abajo Mountains are significant areas of recharge of the Salt Wash anddeeper aquifers. General gradients of groundwater movement in these aquifers follow theregional structure, and the water discharges ultimately in the vicinity of the San Juan River.

Because the Brushy Basin Member acts as an aquiclude to the Salt Wash Member in the uplands,the primary recharge areas for this aquifer are Brushy Basin Wash to the northwest of Blanding,Cottonwood Creek to the west and southwest of the town, and the upper reaches of MontcumaCreek, especially along Dodge and Long canyons.

Several permeability tests were conducted at the mill ard tailings retention sites. Theresults of these tests show a hydraulic conductivity of 1.5 to 3 m (5 to 10 f t) per year (seeFig. 2.7). The shallow groundwater movement at the nfll site is estimated to be about 0.3 to0.6 cm (0.01 to 0.02 f t) per year toward the south-southwest and the shallow groundwater move-ment at the tailings site is about 0.08 to 0.3 cm (0.0025 to 0.01 ft) per year in the samedirection. The values were derived using the following formula based on Darcy's Law:

V = Ki/0 ,

where

2-33

GE O LOG rcACE f5-4592

1

E>E

*38

ALLUVIUY P"sw. des paa quer.fitics of water,

from @anow **Ps Sua weht are sutnert~ ~ ~ - . _ _ '

to yeet scator^al vanat on in amount of y.esod$ Ver*M Sn The water s gerere y of poor gi.daity -a

U3 p,n o,, 5, \ pehtAv ow'''g to the s,.tfee ea8ts m thei

$v Memos snaieRurro Canyon F m k

u ,,. ( D AMOTA Sanitstone end upper pat of MOaa SONI

''p o,mp ,on ' F ormat.on Water of fe<r to pi.wsr wat.tvawedetde bv pumpsog

8h.f f Sandstone \ N .. BL UF F Sandstone Artneri awfer potat>ie\Surnenervme F m N, .ater Suppbes a si,r>r g east of 8.u"

g iretrada St 3sul wens sout*, of Hatch.4

4 s ~ Nsl

ENTR ADA Senduone Aorwan aqu.fer., co mes r m, y,,,,,,,,,, go,,,,,,,,,,,,

. N I orvi southerr5 parts of was but base

[ rea&es depth of near., 15fX) ft mKayente 6ormation \ \ |

**""#' '**\ m B'andmg basmi

- {\ \ . NAV AJO Sandstone Ar'es. art a pfero\ s\h

._t., ~ChmW F orenation \ o,,, ,n .esiern sno southern perm ofi \ ses erwJ rem hos depths of 18% ftF SNnaturnp Vemtwr \ | n,,, A ,,,, % o,3 v ,,d

Moenhooi Formatiori k\Wh.te Rim Ss N. WNG ATE Sandstone Artman aw.for\DeChesiv Se k \ D'""'dmq pn! quahty water for weils

g \.cut 1er 'a "*d e o' 8199.0,, om %,e

Certar Mesa \

[ Sarwistone \$ Ha+wto Forma ur

ho Format.on

| SHINARUMP 94emen.e of CNeleFormation. DeCHE L LY Senustone ofCuo r Grovo Lorally provide ipsde

Hermot, Forma,,on ,e sve w.e, see ne.r soone. ..v,cmity of Biu ttm

i

Fig. 2.6. Generalized stratigraphic section showing freshwater-bearing units insoutheastern Utah. Source: ERs Plate 2.6-1.

V = the rate of movement of groundwater through the formation s

K = the hydraulic conductivity of formation 1.5 to 3 m/ year (5 to 10 ft/ year),

i = gradient (calculated as 0.03 at mill site and 0.01 at tailings site),

o = porosity of formation (assumed as 20%).

Table 2.25 is a tabulation of groundwater quality of the Navajo Sandstone aquifer. The TDSrange from 244 to 1110 mg/ liter in three samples taken over a period from January 27s 1977, toMay 4. 1977. High iron (0.57 mg/ liter) concentrations are found in the Navajo Sandstone. TheU.S. Environmental Protection Agency recommends 0.3 mg of dissolved iron per liter for drinkingwater.13 tFeltis '* noted that the total dissolved solids in the alluvium and at shallow depthsin the Dakota Sandstone, the Burro Canyon Formation, and the Morrison Formation range from300 to 2000 mg/ liter.

The applicant has sampled groundwater from local springs and wells at locations shown inFig. 2.5. Total dissolved solids ranged from about 700 to 3300 mg/ liter. Standards forpublic drinking water were frequently exceeded for sulfate, selenium, iron, and arsenic. Thewaters are suitable for stock and wildlife use.

Es-e*et

.4

\it - . . . .--.^

.~t -

C & O

a \ 4

: = e/ z$ b

. I E 4

'.43 0 $ s- '-'] 9o-

g<.

8 2 b 29

5 a ; i I Io

e : 9 : ?3 : .___] r- - ]8 3 *

e/3 09 19 77 5634 4 56 5' 5577 9 ?

09 22 77 56 0' M78 4 6'

c j09 27 77 % 5' 5577 9 r11 04 17 56 8' 5571 6 . o7 ?

9 09 30 77 5679 3 100 0 % 79 3 0

11 04 77 99 8~ % 79 5 ,a

12 09 30 77 % 48 1 75 0' 55731 b*

11 04 77 81 3' 5%6g .f ,. VILL SIT E |94, / |

._[19 09 27 77 5600 3 110 0' 54M 3 g '

11 04 77 110 0' 5430 3 4 Sc O

28 09 22 77 % 47 6 75 0' 5472 6'

o3 w

|09 27'77 76 Cr 54716 i

2D11 04 77 75 T 5411 9 ' 1 C i2#+

|N E. 11 *M 77 5472 34 7' 5637 3 I" .

14U O./ | ,ae | (3o e

N 09.76'77 5653 93 0' 5560 0| 7.3 i

09 22 77 93 5' 5%95 N g p09 27 77 94 0 5559 0 8 hp09 08 77 94 7 5559 0 4 16 SW 0 95

"S. E. C9 08 7 7 5595 9'i 0' 5499 0 N o SEg

09 16 77 94 0' 5511 0 .j 19 00 !0 .s |

009 22 77 94 5' M'0 5 ' O gg09 27 77 84 5' 5510 5 2f

SW 09 08 77 5595 91 0' 5504 0 F k--- ---v

09 16'77 90 0' 5505 0 / 29g09 22 77 90 5' 5504 5 'A /\gN ''09 27'77 93 0' 5505 0

[ O11 04 77 90 T 5504 3

26 23 # 24KEY o 'N o y-55,20,- ELEV AT!ON OF W ATE R TABLE 1FE E T ABCvf USL) 7

: DIRE CTION 05 SHALLOW GROUND A ATE R VOV E VENT gc

028 soaE* OLE LCCA7'ON AND NUMBE R ENCOUNTERING W ATE A {Fig. 2.7. Groundwater-level map of the White Mesa site.

Source: ER, Plate 2.6-2.

2-35

Yeble 2 25. Water quehty of youndenter m ttie prosect oncenity'Zero valu s to 01 are twton detert,orilim tse

_ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ .____

Biarwt ng me!I s.te eest in fuveso Sandstone. G2RPar emew

1'27/71" 5 4 7f 72577 1205/77 3 23.7P

F ed ese 4 torntoctivity, Smhos em 400 310f eed pH 69 7.6Dinoivwf onypo ..

Yempeiature 'C 22.2 }}f stimated fion. m' day Igs,ml 109(201 ..

Determmetson, metter

pH 80 79 77 79 8 16

7DS (st 180'C) 244 245 1110 446 216

Re<1ns potent al 220 220 211

Aikehn.tv (as CACO ) 189 180 224 185 1873

Herdoess. total les CaCOp 146 208 195 177

Castenete tas CO l 00 0.0 00 00i

Aluminum, dissolved a'0 01 <01 <01.

Ammonia les M 00 <01 (01 0 16

Assen c. total 0 014 %0 01 <0 01 0 007

Bar um. total <00 0 13 <01 0 15.

B*on, total 0 040 <01 0 11 <01~

Cadmium, eonat 00 0 004 (002 *O005Casoum, d'uoived 51 49 51 57 112

Chlor wie 00 50 (1 2 4

Sodium, d.ssoNed 80 53 23 13

Silvee. disso6ved 00 <0002 0 010 0 006

bilate. d swived (as SO,1 24 17 17 83 26.7

Vanadium, d ssuived <0 002 0 16 0 005

Maneenese. d uolved 0 020 0 03 0 03 0 03

Chrom.um. total 00 0.02 (0 05 0 02

Copter, total 00 0 005 <0 010 0 005

F luus ide, diswivm1 0.17 01 0 22 02 02leon, tutal 0 54 0.61 0 35 21

Inon. disso+ved 0 51 0 30 2.3

Lead, total 0.0 0 02 <0 05 <0 05

Magnesium, distoNed 17 19 18 15 2s

Metcary. total 00 0.0 0 002 (JD 00002 0 00002Molybdenum. dissolved < 0 01 0 010 0 004N.trate (as NI 0 05 0 12 < 0 05 < 0 05 (0 05.

Phoss mrus. totel (as P1 0.03 <001 <D 02 0 03e

Potsu.um, disso8ved 30 32 28 24Seten.um diswNed 00 0 05 0 014 < 0 005

S.I.u. d ssolved (as SiO ) 12 58 12 6 82

Strontium, dissosved 0 67 05 0 60Usamum, total (as U) <0 002 0 16 < 0 002.

Ursneum, dessuNed (as U) <0 002 0 031 <0002lievt. d.ssolved 00 0 39 0 007 0 12

Total or genec caremn 1.1 16

Owmical oavgra demand <t 66

Ois and yeese 10 1

Totsi suspended not.ds 6 1940

Determination (pCs/ liter)

Grou alpha i prec.sion 7 10 2 t 2 6 16t13 19t14

Grom twea t perisson <20 73119 828 9t8Ra 226 e preces.un 01t03 0620.4 0320.3Th 230 t preosion O712.7 0.3106 01104Pb 210 t peces4on 10t20 07121 00140Po 210 t permon 00t03 00108 no106

'The susing ns Curral Creek. Station No G1R, aves tested on Julv25,1977,and aga.n on % ornher 10,1977. Becwee of the low ttouw, the spring could not he forated.

" Utah State Devis.on of Health Ana'ys.s. Lab No 77061' Partial analys.s by Haien Research. Inc., Lmple No HRI 11503.

Source: Acepted from E R. Tente 2 8 6, and Supplemental fieport. Basesme Water QuehtyEawiroam*ated fieport WNto wees Uranium Protect," June 29.1970

2-36

2.7 GEOLOGY, MINERAL RESOURCES, AND SEISMICITY

2.7.1 Geoloy

2.7.1.1 Regionalj aolog

The proposed project site is near the western margin of the Blanding Basin in southeasternUtah. Thousands of feet of marine and nonmarine sedinentary rocks have been uplif ted, moder-ately deforma , and subsequently eroded. North of the site is the Paradox fold and fault belt;to the west, the Monument uplif t; to the south is the San Juan River and the Tyende Saddle; andto the east is the Four Corners platform (the Canyonlands section n.crges with the SouthernRocky Mountain province; see Fig. 2.8). The area 's characterized by deeply eroded canyons,mesas, aad buttes fomed from sedimentary rocks of pre-Tertilry age. Regionally, elevationsrange f rom about 900 m (3000 f t) to more than 3350 m (11,000 f t). With the exception 07 thedeeper canyons and isolated mountain peaks, the average elevation is approximately 1500 m(5000 ft).

Exposed sedimentary rocks in southeastern Utah have an aggregate thickness of about 1800 to2100 m (6000 to 7000 ft) and range in age from Pennsylvanian to Late Cretaceous.

Shoemaker noted three origins of the structural features seen in the project area:(1) structures related to large-scale regional epetrogenic deformation (Monument Uplif t andBlanding Basini, (2) structures fomed due to diapiric deformation of thick evaport ties, and(3) structures formed due to magmatic intrusions (Abajo Mountains).15. R

2.7.1.2 Blanding site geol _oy

The proposed site is located near the center of White Mesa. Th nearly flat surface of themesa has a thin veneer of loess and is underlain by resistant sandstone caprock. Surfaceelevations across the site range from 1690 to 1720 m (5550 to 5650 f t). The maximum reliefbetween White Mesa and the adjacent Cottonwood Canyon is about 230 m (750 f t).

White Mesa is drained to the west by Cottonwood Wash and Westwater Creek and to the east byRecapture Creek. There streams are intemittent and flow into the San Juan River. In theproject area, exposed rocks are of Jurassic, Cretaceous, and Pleistocene-Recent age (see Fig.2.9). The Jurassic to Upper Cretaceous rocks are represented, in ascending order, by the SanRaf ael Group, the Morrison Formation, the Burro Canyon Formation, the Dakota Sandstone, and theMancos Shale. The rocks are primarily cross-bedded sandstones, conglomeratic sandstones,claystones, mudstones with some sandy shales, and limestones. Cenozoic rocks include eolianloess, stream-born alluvium, colluvium, and talus.

The structure of White Mesa is simple. The Dakota Sandstone and Burro Canyon Formation areessentially flat with gentle undulations and are commonly jointed. Two joint directions arefound usually perpendicular to each other.

2.7.2 Mineral resources

2.7.2.1 b ra nium_depos_i_t sl

Two types of uranium mineralization exist in the region: (1) tabular deposits nearly parallelto the bedding of fine-grained to conglomeritic sandstone lenses and (2) fracture-controlleddepcsits. None of the fracture-controlled deposits have yielded large production.17 Thetabular deposits occur in the Chinle, Morrison, and Cutler formations. Vanadium is a commonbyproduct of most uranium produced from the Morrison Formation. Principal uranium mineralsare uraninite and coffinite.

2.7.2.2 Other mineral resources

Seven wildcat oil wells were drilled about 6 km (4 miles) west of the proposed site. All weredry and were abandoned.

2-37

ES4537

* lbf 9alla ,# ffs -

y-~=W* f,,

5;'

N-

'.fo+

N',

.s / N|+ s ,

ghs O

ji. > #,.4 : 's k.# ' . .

I- so o, ,,

/ ..s' '

( ~,|,t+

's, Ig +.-,

<,-,, <c : -s_ s

p\g %,

,#'g %g s,' N <,Oseu *e ,

#'gi .s ig ',

a

e*t i s. ;# t.s, ,f.

ywg 4 % w a3* ,

\ * 4, j 4,- N, | +o- ,e= o

% I

) Fp. .. -... |t

s :,g:,.|\o ;o

;cr , ..

,-/,> x ,,

,,< r ,. ,' ,, . -*', =,

./i

,,de',N '*|

,

d84,,,) ',* * i

d .. 'o ,e #- o .- __,i g ,e e *

,o-

, ls a s " =

j / ," - PROJECT},,*'g- ',# m,e e .. .| = s -

, ' * A*[*o

| |, '" AREA * ' t,,', ,/ I \ \ o'

% '_t t

'@=="=_/[.$, been +*,.1 * g .., ,

|,[ij,'/C'*

*+

,

! N c +,,,. ,,

o o % o.a%~ . . ' * ** s .

~ITIlONA ,? f"

} CV~

a 4 O

,Q, I % ,, ,

i,,

e''+i TYEmoE / yd...

n

, -Rio ao = %<| N _ ,' +.,'

, *sanotE g'I '8E9 M L *, ,

E X PL ANATION g o g g y, -: --- - .

-----Cate.= m.tes

SOUNDaev 0F ftCtenec civ

| hasO40CL et, Essos;ng T eactOF asis aug OsttCY e0M OFDe9

- ,~A4 7 tCLiset, BueO9r48 TRACE

OF s.a.ss &#O 0+#f CTsCes OFe6 v

Sf hCotest, Smowisse TWACE

OF a.m.it ARO De#ECYtON OFn

Fig. 2.8. Tectonic index map. Source: ER, Plate 2.4-1.

,fdd$q @bEldd]C][\.q. rq' n

6i 3

2- 38

E S - 4 588

|S t.D I E S STRA TICRAPH IC TM I CF M t.5 5 8 gggg

LhlI (f )(Ages

Silt, sand and gravel in erroyos and st reamAlluvius J.J9

valleys.

blore wash, t alue and roc a rubble rangtrg

from e bbles a nd t ou! de r s t o massive blocksh No l oc ene Col tuvive and Talus 0-15*f allen fina clif f s and outcrops of resistantg (ggg g g L, y g,**'h-

A Ple t e t oc eneD Reddleh-brown to light-brm, unconsolide-

ted, well-strted s11t t o med i um- g r a i ne dg g,sand, partially remented wit h calic5e irsome area: reworked partly by water.

Lntonforetty -

Cray t o dart-gray, fissile, thin-bejded

Mancos 5baie f-II(') marine shale wit h f osallif erous sanf y time-

stone in lower strata.

Lpper Light yellowish-brown to ligt.t gray-arown,

teetateous (Mic h tedded to crees-bedded sandstone,

congloseratic s ands t one ; interbedded thinLakota Sandstore 30 - 73 lenticular grav stonneceous clavatone

CRETA( M 5 and lopure coal; Iccal course basal con-glomerate.

- - ~ ~ - -- - - Leconf oralt y - - - ---

and 11t t -b r ow, massive e r.d!. i tht - F r a y h

c ross-bedded c onglomeratic sandst one andint erbedded green and gr ay green oudst or e s**' tur ro Canvon f ormat ion 50 -150

Cretaceous localls contains than discontinocus bedsof s tit rified sandst one and 11mentonenear tep.

------ Leconfersity(?Verlegated gray, pale-greer, reddla5-brown,and purple bentontt ic mudatone and silt-

Brush, Basin Member 2 00- 4 '>0a t one rentaining t hin disc ontinuous sand-

atone and cons:ceerste lenses.E- IntenbeJded yel.cwlah- and greenish-gray

M j bestwater Canvan en riebts5-gray, f a r.e- to course-grained

Meaher araosic sandstone and greenish-gray to2 ;m. reddist-brown sanoy shale and mudst one.3

*' aa eInterbedded redJteh gray to llant browne

Rec apt ure Meaner 0 33 f i ne- to m=dium-grained sandstone and

j reddist gray silt y and sandy claystone.

Lpper Interneaded yelinwish-brown to pale

Jursee tc teJJ1sh-trown fine-grained te conglom-Salt hash Memoer 0- MO er g :1c seMst ones and greenish and

'LEASSIC r ed 31th-gr av mudst ene.L'econf eret t y

White to grayish-brown, mae s t ve , c ross-Bluff Sandstone 0-150+ bedded, f i ne - to medius grained eolian

sandst one .

c.$ Summerville Thin-bedded , ripple-marked reddleh-brown3, ; gj Formation mu41 d > samist one and sandy shale.

$ iteddish-brown to gravish-white, amasive.g,iso-iso cross-bedded, fine- to .ediv.-grained; s,,,,,,,,

" sandetone.

:Irre6u ary bedded reddish-brown muddy*

(* * '**II'* *sandst one and sandy a.udst one wit h local

thin beds of brown to grey timestone andMiddleJutsesic reddish- to greenleh-gray shale,

l'nc on f or al t y

eTo convert feet to seters, multiply f eet by 0.k%8.

Fig. 2,9. Generalized stratigraphic section of exposed rocks in the project vicinity.Sou rce : ERe Table 2,4-2,

u . J a#

2-39

Thin, discontinuous beds of impure lignite and coal up to 0.6 m (2 f t) thick occur throughoutthe Dakota Sandstone. Although several of these coal beds have been mined on a limited scalein the Blanding area, most of the coals are too impure for commercial use.M

Copper deposits are associated with the fracture-controlled uranium-vanadium deposits in theAbajo Mountains and with some sedimentary deposits. The copper content may be as high as 3%.Sand and gravel deposits are mined on the east and south slopes of the Abajo Mountains forpavement construction material.

Although water is produced from wells drilled to the Burro Canyon Formation and the DakotaSandstone this water is connonly mineralized and in some localities unfit for human con-sumption.y9 Deep wells drilled to the Entrada and Navajo sa idstones yield potable water.17.19Several springs in the project vicinity discharge groundwater from the Burro Canyon Formation.

2.7.3 Seismicity

Within a 320-km (200-mile) radius of the site, 450 seismic events occurred between 1853 and1978. Of these, at least 45 had an intensity of VI or greater on the Modified Mercalli Scale.

Within a 160-km (100-mile) radius of the project area, 15 earthquakes have been rec >rded. Ofthese, only one had an intensity of V, and the rest were IV or less. The nearest event occurredin Glen Canyon National Recreation Area, about 70 km (43.5 miles) northwest of the proposedsite. The next closest event occurred about 94 km (58.5 miles) to the northeast. The event ofintensity V occurred on August 29, 1941, just east of Durango, Colorado. M It is doubtful thatany of these events would have been felt in the vicinity of Blanding.

Based on the region's seismic history, the probability of a major damaging earthquake occurringat or near the proposed site is remote. Algermissen and Perkins : indicate that there is a 9012

probability that horizontal acceleration of 40% gravity (0.4 g) would not be exceeded within50 years.

2.8 SOILS

The majority (995) of the soil on the project site consists of the Blanding soil series (ER,Sect. 2.10.1.1). The remaining 1% of the site is in the Mellenthin soil series. Because theMellenthin soil occurs only on the eastern-central edge of the site (ER, Plate 2.10-1), itshould not be affected by construction and operation of the mill.

The mill and associated tailings disposal ponds will be located on Blanding silt loam, a deepsoil forw d from wind-blown deposits of fine sands and silts. Although soil textures arepredominantly silt loam, silty-clay-loam textures are found at some point in most profiles (ER,Table 2.10-2). This soil generally has a 10- to 13-cm (4- to 5-in.) reddish-brown, silt-loam Ahorizon and a reddish-brown, silt-loam to siity-clay-loam B horizon. The B horizun extendsdownward about 30 to 40 cm (12 to 16 in.) where the soil then becomes calcareous silt-loam orsilty-clay-loam, signifying the C horizon. The C horizon and the underlying parent materialare also reddish-brown in color.

The A ana B horizon both have an average pH of about 8.0, whereas the average pH at the Chor.40n is about 8.5. Subsoil sodium levels range up to 12% in some areas, which is close tothe upper limit of acceptability for use in reclamation work (ER, Sect. 2.10.1.1). Otherelements, such as boron and selenium, are well below potentially hazardous levels. Potassiumand phusphorus values are high in this soil (ER, Table 2.10-2) and are generally adequate forplant growth. Nitrogen, however, is low (ER, Sect. 2.10.1.1) and may have to be provided forreclamation.

With the well-drained soils, relatively flat topography (Sect. 2.3), and low precipitation(Sect. 3.2.1), the site generally has a low potential for water erosion. Hewever, the flowsresulting from thunderstcrm activity are nearly instanteous ar', if uncontrolled, couldresult in substantial erosion. When these soils are barren, 2ey are considered to have a highpotential for wind erosioi. Although the soil is suitable for crops, the low percentage ofavailable moisture (6 to 9%) is a limiting factor for plant growth; therefore, light irrigationmay be required to establish native vegetation during reclamation.

2-40

2.9 BIOTA

2.9.1 Terrestrial

2.9.1.1 Flora

The natural vegetation presently occurring within a 40-km (25-mile) radius of the site is verysimilar to that of the potential,M being characterized by pinyon-juniper woodland intergradingwith big sagebrush (Artenesia tridentata) communities. The pinyon-juniper community is domi-nated by Utah juniper (Jwriperas ostecsperu) with occurrences of pinyon pine (Pinus chlis) asa codominant or subdominant tree species. The understory of this connunity, which is usuallyquite open, is composed of grasses, forbs, and shrubs that are also found in the big sagebrushconnuni ties. Common associates include galleta grass (HiZ e ta M sii), green ephedra (Erhedraviridio), and broom snakeweed (Catierrai2 carethrac). The big sagebrush connunities occur indeep, well-drainM soils on flat terrain, whereas the pinyon-jtniper woodland is usually foundon shallow rocky soil of exposed canyon ridges and slopes.

Seven community types are present on the project site (Table 2.26 and Fig. 2.10). Except forthe small portions of pinyon-juniper woodland and the big sagebrush cormunity types, the majorityof the plant communities within the site boundary have been disturbed by past grazing and/ortreatments designed to improve the site for rangeland. These past treatments include chaining,plowing, and reseeding with crested wheatgrass (A;;rcppron descrtcram). Controlled big sage-brush comunities are those lands containing big sagebrush that have teen chained to stimulategrass production. In addition, these areas have been seeded with crested wheargrass. Bothgrassland comunities I and II are the result of chaining and/or plowing and seeding withcrested wheatgrass. The reseeded grassiand II comunity is in an earlier stage of recoveryfrom disturbance than the reseeded grassland I comunity. The relative frequency, relativecover, relative density, and importance values of species sampled in each conmunity are pre-sented in the ER, Table 2.8-2. The percentage of vegetative cover in 1977 was lowest on thereseeded grassland II community (10.7%) and highest on the big sagebrush community (33%) (Table2.27).

Table 2 26 Commurety types and expanse ethm the Table 2.27. Ground cover for each commumty mthm the

prcsect sete boundary protect site boundary

E x pense Percenty of each type of coverCommunity type Community type

ha acres Verptative cover Leter 8are ground-

Panyon-gun per woodland 5 13 Pinyon-juniper woodf and' 25.9 156 55 6

B g sdytw ush 113 278 Big sagetxush 33.3 16.9 49 9

Reseeded go assland i 177 438 Reseeded grasCand i 15.2 24.2 61.0

R.meded grasstand Il 121 299 Reseeded grassland il 10.7 9.5 79.7

Tamarsk salm 3 7 Tamarisk salix 12.0 20 1 67.9

Contrened tug sagetwusn 230 569 ControHed big sagebrush 17.3 15.3 67.4

D,stur ted 17 41 Distur ted 13.2 7.o 80.0

* Rock covered 4 4% of the cyound.

Based upon dry weight composition, most comunities on the site were in poor range condition in1977 (ER, Tables 2.8-3 and 2.8-4). Pinyon-juniper, big sagebrush, and controlled big sagebrushcommunities were in fair condition. However, precipitation for 1977 at the project site wasclassed as drought conditions (ER, Sect. 2.8.2.1). Until July, no production was evident onthe site.

23 occur on or near the project siteNo designated or proposed endangered plant species(ER, Sect. 2.8.2.1). Of the 65 proposed endangered species in Utah, six have documenteddistributions in San Juan County.2'* A careful review of the habitat requirements and knowndistributions of these specits indicates that, because of the disturbed environment, thesespecies would probably not occur on the project site.

2-41

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2-42

2.9.1.2 Fauna

The applicant has collected wildlife data through four seasons at several locations on thesite (Fig. 6.1). The presence of a species was based on direct observations, trappings, andsigns such as the occurrence of scat, tracks, or burrows. A total of 174 vertebrate speciespotentially occur within the vicinity of the proposed mill (ER, Appendix D), 78 of which wereconfirmed (ER, Sect. 2.8.2.2).

Although seven species of amphibians are thought to occur in the area, the scarcity of surfaceWater limits the use of the site by amphibians. The tiger salamander ( M ystona tigrinam) wasthe only species observed. It appeared in the pinyon-juniper woodland west of the project site(ER, Sect. 2.8.2.2).

Eleven species of lizards and five snakes potentially occur in the area. Three species oflizards were observed: the sagebrush lizard (Sea!c;aras graciccas), western whiptail(Cr:mib; huaa tigria), and the short-horned lizard (Theyncama Joaylassi) (ER, Sect. 2.8.2.2).The sagebrush and western whiptail lizard were found in sagebrush habitat, and the short-hornedlizard was observed in the grassland. No snakes were observed during the field work.

Fif ty-six species of birds were observed in the vicinity of the project site (Table 2.28). Theabundance of each species was estimated by using modified Emlen transects and roadside birdcounts in various habitats and seasons. Only four species were observed during the Februarysampling. The most abundant species was the horned lark (Fecm;' hila acpestia) followed by thecommon raven (Oma son x), which were both concentrated in the grassland. Avian countsincreased drastically in May. Based on extrapolation of the Emlen transect data, the aviandensity on grassland of the project site during spring was about 305 per square kilometer (123per 100 acres). Of these individuals, 947, were horned larks and western meadowlarks (SsurnclZaneg!mt2). This density and species composition are typical of rangeland habitats." in lateJune the species diversity declined somewhat in grassland but peaked in all other habitats. ByOctober the overall diversity decreased but again remained the highest in grassland.

Raptors are prominent in the western United States. Five species were observed in the vicinityof the site (Table 2.28). Although no nests of these species were located, all (except thegolden eagle, galla chryc.wtcs) have suitable nesting habitat in the vicinity of the site.The nest of a prairie falcon (Falco w xicanas) was found about 1.2 km (3/4 mile) east of thesite. Although no sightings were made of this species, members tend to return to the samenests for several years if undisturbed (ER, Sect. 2.8.2.2).

Of several mamals that occupy the site, mule deer (D!amilcua hemionas) is the largest species.The deer inhabit the project vicinity and adjacent canyons during winter to feed on the sage-brush and have been observed migrating through the site to Murphy Point (ER, Sect. 2.8.2.2).Winter deer use of the project vicinity, as measured by browse utilization, is among theheaviest in southeastern Utah [61 days of use per hectare (25 days of use per acre) in thepinyon-juniper-sagebrush habitats in the vicinity of the project site].26 In addition, thisarea is heavily used as a migration route by deer traveling to Murphy Point to winter. Dailymovement during winter periods by", deer inhabiting the area has also been observed betweenWestwater Creek and Murphy Point. The present size of the local deer herd is not known.

Other mammals present at the site include the coyote (Cania Zatrane), red fox (Vulrea mlpes),gray fox (Urc yos eisroargenteaa), striped skunk (3!qhstic nephitic), badger (Taxi &a taxas),longtail weasel (mstela fro:ata), and bcbcat (4n rafun). Nine species of rodents weretrapped or observed on the site, the deer mouse (T.-r m ccas nani a lataa) having the greatestdistribution and abundance. Although desert cottantails (Sy:W7q:e aWoni) were uncomonin 1977, black-tailed jackrabbits (Lepus ca iformicac) were seen during all seasons.

27Three currently recognized endangered species of animals could occur in the project vicinity.However, the probability of these animals occurring near the site is extr.:mely low. The projectsite is within the range of the bald eagle (!!aliacetua ImxcA2?aa) and the American peregrinefalcon (F2;m pcrepinas anatam), but the lack of aquatic habitat indicates a low probabilityof these species occurring on the site. Although the black-footed ferret (%stela eigripca)once ranged in the vicinity cf the site, it has not been sighted in Utah since 1952,;9 and theUtah Division of Wildlife feels it is highly unlikely that this animal is present (ER, Sect.

2.8.2.2).

2-43

Tebla 2.28. Birds observed in the vicimty of the proposed White Mesa Uranium Proiect- . _ _ _ _ _ _ _ . . _ -_ __ _ _ _ _ _ _ . . _ . . _ _ _

Statewide Statew derelative relative

3 gabundance abundanceand status * and status *

Mallard CP Pinyon gay CPPinta.1 CP Bushte t CPTurkey vulture US 8ew.ck's wren CP

Red ta. led hawk CP Mockingbird USGolden eagte CP Mounta.n bluebird CS

Marsh hawk CP Black tailed gnatcatcher H

Merhn UW Ruby crowned kingfet CP

American kestrel CP Loggerhead shrike CS

Sage grouw UP Staritng CPScaled quail Not listed Yellowrumped warbler CS

American coot CS Western meadowlark CP

K.lldeer CP Red winged blacktsrd CPSpotted sandpeper CS Brewer's blacktard CP

Mourn +ng dove CS Brown-headed cowb:rd CS

Common nighthawk CS Blue grosbeak CS

White throated swift CS House f.nch CPYellow bellied sapsucker CP Amencan goldftnch CP

Western kingbird CS Green ta led towhee CS

Ash throated flycatcher CS Rufous s6ded towhee CPSay's phoebe CS Lark sparrow CS

Horned lark CP Black throated sparrow CS

V olet green swallow CS Sage sparrow USBarn swanow CS Dark eyed lunco CW

Ct.ff swallow CS Chrpp.ng sparrow CSScrub iay CP Brewer's sparrow CS

B|ack tylled magp-e CP Wh'te crowned sparrow CS.

Common raven CP Song soarrow CP

Common crow CW Vesper sparrow CS.._ __ _____

*W. H. Beh:e and M. L. Perry, Ura r Birds, Utah Museum of Natur . H.s tor y,r

Un versity of Utah. Sa!t Lake C,ty.1975.

Helative abundance Status

C = common P = permanent

U = uncommon S = summer residentH = hypothetical W = winter vesitant

Source. E R. Table 2 8 5

2.9.2 Aquatic biota

Aquatic habitat at the project site ranges temporally from extremely limited to nonexistent dueto the aridity, topography, and soil characterittics of the region 6 d consequent dearth ofperennial surface water. Two small catch basins (Sect. 2.6.1.1), approximately 20 m in diameter,are located on the oroject site, but these only fill naturally during periods of heavy rainfall(spring and fall) and have not held rainwater during the year-long baseline water qualityrronitoring program. Although more properly considered features cf the terrestrial environment,they essentially represent the total aquatic habitat cn the project site. When containingwater, these catch basins probably harbor algae, insects, other invertebrate forms, andamphibians. They may also provide a water source for small mannals and birds. Similarephemeral catch and seepage basins are typical and numerous to the - W east of the projectsite and south of Blanding. The basin to the northeast of the preter.t ure buying station hasbeen filled with well water to be used during construction of the aW unt office and labora-tory facilities. Present plans are for it tre contain water for approximately six months. Thisbasin has not been sampled for aquatic biota since filling.

r

2-44

Aquatic habitat in the project vicinity is similariy limited. The three adjacent streams(Corral Creek, Westwater Creek, and an unnamed arm of Cottonwooc Wash) are only intermittentlyactive, carrying water primarily in the spring during increased ainfall and snowmelt runoff,in the autumn, and briefly during localized but intense electrical storms. Intermittent waterflow rmst typically occurs in April, August, and October in these streams, Again, due to thetemporary nature of thes streams, their Contribution to the aquatic habitat of the region isprobably limited to providing a water source for wildlife and a temporary habitat for insectand amphibian species.

fh populat ions of fish are present nn the project site, nor are any known to exist, in i ts ime-diate vicinity. The closest perennial aquatic h.ibitat to the proposed mill cppears to be a smallirrigation basin (approximately 50 m in diameter) about 6 km (3.8 miles) upgrade to the north-east. This habitat was not samoled for biota by the applicant, who reports that t;ie pond isinternittent and probably does not harbor any fish species.

The closest perennial arpatic habitat known to support fish populations is the San Juan River29 bm (18 miles) south of the project site. Five species of fish federally designated (orproposed) as endangered or threatened occur in Utah (Table 2.29). One of the five species, the

woundfin (! . , g + .. r w < f.v m ), does not occur in southeastern Utah where the proposedmill sita is located. The Colorado squawfish ( '. a a) and humpback chub (..

'

:I.a), ho ver, are reported as inhabiting large river systems In southeastern Utah. Thebonytail (Nb (o y , t'assified as threatened by the State and proposed as endangeredby federal auinorities is alsc limited in its distribution to main channels of large rivers.The humpback sutker (razorback sucher; q,e a r t n . u .:m), protected by the State and proposedas threatened by the federal authorities, is found in southeastern Utah inhaLiting bach aterpools and quiet areas of mainstreom rivers. The closest habitat suitable for the Coloracosquaufish, humpback chub, bonytall chub, and humpback sucker is the San Juan River ?9 km(16 miles) south of the proposed site.

Tatile 2 29 Threatened and endanigered aquatic species ouuremg eri Utah

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I hH. , v.ph.u 6 i n ,b l at .y e vs r s , s.t ene., e.ide t s aj f ede.ai ei ,r t.p :gce cr t YnGJJsypha hae k m tes 9 ate endan<yr ed

Cai iv ade t ht uplaiah Ma.n ( b.,ni eS of f.v ge r.ver sy srerns F edre 1 end.c erv ed Yesh

I'ts , ho, hedo s A n ,o s o ci 'o,,c to d, s rwy Srate endm.qee ed

Hos.td ihob Wo i Nnnch v,f leer t o,c, w steins f edee al gunpmed Yes(c' # e*epe s n Coh . ado d. a,naje i ndangered'

state threrer ed

b A. T ||,|) jf h M4# ||cf h k ,f. b A, at.' f $ b(lOf 5 )f''| (gi& Pej Mpd t4 f h et|t-r a| g)f 4 {h19 m j Yeg(l a .* Of |,elt $1 se de.h er ) yf f* i,3f)0 rna n f IVef s t hf e.gf efie(|*

.hira,n her fr%vro s state threarcom|

f nden, red and Theatened Yv4f 4 and ehrits.'' f eel /fegat 41(211) s7329 (1977)d'

^l odinred ani T hecatened WJd!.te and Ft4nt s," / en/ #redt 4141.h) 36419 atM 31 (19 7 7).

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't nd.vur ed and Ihn eatened W Whf e and Plane.. ' / cel Ref st 43(79) 173/5 1737 7 (19 7H1

2-45

2.10 NATURAL RADIATION ENVIRONM NT

Radiation exposure in the natural environment is due to cosmic and terrestrial radiation andto the inhalation of radon and its daughters. Measurements of the background environmentalradioactivity were raade at the proposed mill site using thermoluminescent dosimeters (TLDs).The result s indicate an average total-body dose of 142 millirens per year, of which 68 milliremsis attributable to cosmic radiation and 74 millirems to terrestrial sources. The cosmogenicradiation dose is estimated to be about I millirem per year.M Terrestrial radiation originatesfrom the radionucliJes potassium-40, rubidium-87, and daughter isotopes from the decay ofuranium-238, thorium-232, and, to a lesser extent, uranium-235. The dose from ingested radio-nuc!! des is estimated at 18 millirems per year to the total body.d 2 The dose to the total body

from all sources of environmental radioactivity is estimated to De about 161 millirems peryear.

iThe concentration of radon in the area is estimated to be in the range of 500 to 1000 pCi/m ,based on the Concentration of radium-226 in the local soil. ".31 Exposure to this concentra-tion on a continuous basis would result in a dose of up to 625 millirems per year to the bron-chial epithelium. < As ventilation decreases, the dose increases; for example, in unventi-lated enclosures, the comparable dose might reach 1200 millirems per year.

The medical total-body dose for Utah is about 75 millirems per year per person.31 The totaldose in the area of the proposed mill from natural background and tredical expost re is esti-mated to be 236 millirems per year.

2-46

REFERENCES FDR SECTION 2

1. Energy Fuels Nuclear, Inc. , " Supplemental Report, Meteorology and Air Quality.Environmental Report, White Mesa Uranium Project, San Juan County, Ltah," Sept. 6, 1978.

2. The Bureau of Economic and Business Research, Jmv:ity INuoni . Euta: FI.vLing, Utah -JJ7.,, prepared for Utah Industrial Development Information Service, Salt Lake City, Utah.

3. The Bureau of Economic and Business Research, cammity Eisnc-tic Fata blan!irj, Utdr -IJr, prepared for Utah Industrial Development Information Service, Salt Lake City, Utah.

4. The Bureau of Economic and Business Research, o mnity 1e ' mia Fanta Mantix ''o, Uti: --

IJ;", prepared for Utah Industrial Development Information Service, Salt Lake City, Utah.

5. The Bureau of Economic and Business Research, @.mnity Ewwi' F2ata: Mu;ti M la, Utah -177, prepared for Utah Industrial Development Information Service, Salt Lake City, Utah.

6. Energy fuels Nuclear, Inc., " Responses to Coments on White Mesa Project DES,"March 6, 1979

/. Utah Department of Employment Security, RGearch and Analysi! Section, adapted from@ v te r: , W; icycn t 7,nale t tir of nnth, wicrn fatrict of !]tah, January-March 1978.

8. Utah Industrial Development Information Service, munty ..m: m s F uta: T m .la r:

c: m t. -im

9. Utah Department of Transportation, ';te of Utan, t. Wor fqhuns Ma;>, Salt Lake City,Utah, 1976,

10. Energy fuels Nuclear, Inc., "Rcsponse to Comments from the U.S. Nuclear RegulatoryComission, June 7,1978, White Mesa Uranium Project Environmental Report," Denver,June 28, 1978.

11. State of Utah, Division of State History, " Archeological Test Excavations on White Mesa.San .1uan County, Southeast Utah," prepared for Energy fuels Nuclear, Inc., Denver,Colorado, May 1973; also " Additional Archeological Test Excavations on White Mesa.San Juan County, Southeast Utah," January 1979.

12. Environmental Protection Agency,,c,aZity criteria fer Rter, Report EPA-440/9-76-023,Washington, D.C., 1976.

13. U.S. Environmental Protection Agency " Water Quality Criteria 1972," Committee on WaterQuality Criteria, 1972.

14. R. D. Teltis, hter fran tvdr~k in the Colarub F:atezu of Utah, Utah State EngineerTechnical Publication No. IS, 1966.

15. E. M. Shoemaker, 'timatun! Fea* urea of !'authnutern Utah and AJ.!acant l'arta of Colcrula,R o / b i g , cv:J Arirna, b e h Geological Society Guidebook to the Geology of Utah No. 9,1954, pp. 48-69.

16. E. M. Shoemaker, stimatum! Featurco of the coloraio F!r m .r:J Their Iwlation to Urw:iur:Eq cals , U.S. Geological Survey Professional Paper 300, 1956, pp. 155-168.

17. H. S. Johnson, Jr. , and W. Thordarson, Unmucn Deposits of tha W2b, M2nticello, GitaCa n_wn , ml 'n:cwnt Val ey Districta, Utah cral Arizona, U:5. Geo1og1 Cal Survey Bulletin1222-H, 1966.

18. L. C. Huf f and f. G. Lesure, @ ology and UrunUcn Iqonics of Monte:c a cv:30n Area, um,Iu m canty, Utah, U.S. Geological Survey Bulletin 1190, 1965.

2-47

19. I. J. Witkind, Geolog3 v. the Abdo !Lw:tains Arc 2, Sm: cuan me:ty, Utah, U.S. GeologicalSurvey Professional Paper 453, 1964.

20. F. A. Hadsell, liist. L:rt;m2ke A e. Co:orado 63(1): 57-72 (1968).

21. S. T. Algernissen and D. M. Perkins, i. Prchtm lien Estimte cf ,.cfmc- A x ?arunm inink in tha untipcs " ted . cates, U.S. Geological Survey Open File Report 76-416,1976.

22. A. W. Kuchler, Totential . 2:ar:l Rgetaticn of the Centerics:,s Uni!cd States, SpecialPublication 36, American Geographical Society, New York,1964.

23. " Endangered and Threatened Wildlife and Plants " Fed. Regist. 41(117): 24524-24572 (1976).

24. S. L. Wcish, N. D Atwood, and J. L. Reveal, " Endangered, Threatened, Extinct Endemic,and Rare or Restricted Utah Vascular Plants," Ceca Fasin Nat. 35(4): 327-376 (1975).

25. J. A. Wiens and M. I. Oyer, "Rangeland Avifaunas: Their Composition, Energetics, and Rolein the Ecosystem," in Pecceedings of ne Syqcabe on Mr:a; ' t of Fcreat ani ?xyccabitats for 'mme Birds, U.S. Forest Service General Technical Report WD-1,1975.

26. State of Utah, Division of Wildlife Resources, letter to Jim Chadwick, Dames and Moore,July 27, 1977.

27. " Endangered and Threatened Wildlife and Plants " red. Regist. 42(135): 36419-36431 (1977).

28. R. L. Linder and C. N. Hillman, Frcseelin;c cf the Flan-Facted Ferret 2:1 Pruirie Dc;Varkshar, Ccptaber 1-6, 197J, South Dakota State University, Brookings, 1973.

25. L. B. Dalton et al . , :peu ica Liv cf Inrcrtebr zte n:JLfe that Inhtit scuhc2 stern Utah,Utah State Division of Wildlife Resources, 1977.

30. National Council on Radiation Protection and Measurements, s2tara! Faakgroana ~;ilarmin the UnitcJ States, Report No. 45, 1975.

31. K. J. Schaiger, " Analysis of Radiation Exposure On or Near Uranium Mill Tailings Piles,"liaiiaticn Dat : Rep. 14: 41 (1974).

32. National Academy of Sciences-National Research Council The Effects on Populat>ons ofE:peav to I.cu Levc's of 1~;izing E11iation, &part :| the nrieary Comittee on theBiologt 2l Effects of Ionicing Raafation (BEIR Report), NAS-NRC, Washington, D.C., 1972.

33. U.S. Department of Health, Education, and Welfare Pcralaticn Egasare to X-rays, U.S.1970, Report DHEW-73-8047, November 1973.

.

3. OPERATIONS

3.1 MINING OPERATIONS

The White Mesa Uranium Project will process ores originating in independent and company-ownedmines. Mines within 160 km (100 miles) of Energy Fuels are buying stations (in Blanding orHanksville) are expected to supply virtually all of the ore processed by the facility. EnergyFuels controls reserves of approximately 8600 metric tons (MT) (9500 tons) of U 0s with an3

U 0s (ER, p.1-1). Additioral ore will be purchased from independentaverage ore grade of 0.1253

mines. There will be no onsite mining activity. The environmental ef fects of the Blandingore buying station (on the project site) are included in this assessment.

3.2 THE MILL

The proposed mill will utilize an acid leach-solvent extraction process for uranium recovery.Provisions for vanadium byproduct recovery are included in the design. The nominal processingcapacity of the mill is 1800 MT (2000 tons) per day. The expected average ore grade is 0.125%V0. The process will recover approximately 94% of the uranium in the ore. The proposed mill3 3

would operate on a 24 hr/ day, 340 days per year schedule. Based cn the above design para-meters, the annual U 03 8 production of the proposed White Mesa mill will be approximately730 MT (800 tons). The estimated anr.ual vanadium (V 0 ) production is 1480 MT (1630 tons).2 3

3.2.1 External appearance of the mill

The plant buildings will be mainly of prefabricated construction. Although the facility willresemble the artist's rendition (Fig. 3.1), the final layout may vary, depending on finalequipment selection.

As viewed from U.S. Highway 163, the mill will consist of a series of long buildings. Portionsof the mill will stand above the natural skyline. The ore buying station, ore stockpiles, andthe natural terrain will obscure the view of portions of the mill. The proposed tailingsimpoundment should not significantly alter the landscape as seen from the highway, exceptaround soil stock piles and borrow areas.

3.2.2 The mill circuit

3.2.2.1 t'ranium circuit

The flow sheet for the uranium circuit of the proposed mill is shown in Fig. 3.2. The orewould undergo a sequence of crushing, grinding, leaching, counter-current decantation, andsolvent-extraction steps. The extracted uranium would be precipitated, dried, and packaged forshipment.

Most eres would be fed to the mill via the ore buying stations. Because the ores will originatefrom many different mines, blending will be necessary to ensure optimal processing amendability.This blending will occur as the ore is fed to the mill.

Ore received at the ore buying stations is crushed to less than 3.8 cm (1.5 in.) during thesampling process. As the ore is fed to the mill, a semiautogenous grinding (SAG) mill willreduce the feed size to smaller than a 28-mesh (0.589 mm or 0.0232 in.) screen. The ore slurryproduced by the SAG mill will be leached in two stages with sulfuric acid, manganese dioxide(or an equivalent oxidant), and steam in amounts that will produce an acid solution with atemperature of 71*C (160 F). Acid consumption will be reduced by neutralSing the alkaline

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3-3

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components of the ore with excess acid in the pregnant leach solution in a preleach stage(Fig. 3.2). It is anticipated that approximately 95*. of the uranium contained in the crude arewill be dissolved over a leaching period of up to 24 hr. The uranium-bearing solution will beseparated f rom the barren waste by counter-current decantation using thickeners. Polymericflocculants will be used to enhance the settling characteristics of the suspended solids. Thedecanted pregnan.t leach solution is expected to have a pH of approximately 1.5 and contain lessthan I g of U 03 per liter. The barren waste will be pumped to the tailings retention area.3

Solvent extraction will be used to concentrate and purify the uranium contained in the decantedleach solution. In a series of mixing and settling vessels, the solvent extraction processwill use an amine-type compound carried in kerosene (organic) which will selectively absorb thedissolved uranyl ions from the aqueous leach solution. The organic and aqueous solutions willbe agitated by mechanical means and then allowed to separate into organic and aqueous phases inthe settling tank. This procedure will be performed in four stages using a counter-flowprinciple in which the organic flow is introduced to the praceding stage and the aqueous flow(drawn from the bottom) feeds the following stage. It is estimated that, after four stages,the organic phase will contain abot,t 2 g of U 08 per liter and the depleted aqueous phase3(raf finate) about 5 mg per liter. The raf finate will be recycled to the counter-currentdecantation step previously described or further processed for the recovery of vanadium (Sect.3.2.2.2). The organic phase will be washed with acidified water and then stripped of uraniumby contact with an acidified sodium chloride solution. The barren organic solution will bereturned to the solvent extraction circuit, and the enriched stripping solution containing

3-4

about 20 g of U 0e per liter ill be neutralized with amonia to precipitate antonium diuranate3

(yellow cake). The yellow cake will be settled in two thickeners in series, and the overflowsolution from the first will be filtered, conditioned, and returned to the stripping stage.

The thickened yellow cake slurry will be dewatered further in centrifuges to reduce its watercontent to about 40! This slurry will then be pumped to an oil-fired multiple-hearth dryer(calciner) at f>S0'C (1200*F). The dried uranium concentrate (about 90? U-0a) will be passed

3

through a hammer mill to produce a product of less tsan 0.6 cm (1/4 in.) size. The crushedconcentrate, which is the final product of the plant, will then be packaged in SS-gal drums forshipment.

3.2.2.2 By-product vanadium recovery

Vanadium, which is present in some of the ores, will be partially solubilized durir,g leaching.The dissolved vanadium will be preseni in the uraniun raffinate. Depending on its vanadium;ontent, the uranium raffinate will either be recycled to the counter-current decantation step(Sect. 3.2.2.1) or further processed for recovery of the vanadium before recycling.

The var adium recovery process will consist of a separate solvent extraction step to treat theuranium raf finate and precipitate the vanadium from the stripping solution. The flowchartshown in Fig. 3.3 illustrates the process.

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3-5

The uranium raffinate will be pumped to a series of agitators where the electromotive force(oxidation potential) will be adjusted to -700 mV with sodium chlorate and the pH raised to1.8-2.0. The solution may possess some turbidity af ter this step and will be filtered prior topassing to a five-stage solvent extraction circuit. Except for the one additional stage ofextraction, the solvent extraction section will be essentially the same as utilized for theuranium. An amine-type compound carried in kerosene (Sect. 3.2.2.1) will selectively absorbthe vanadium ions from the uranium raffinate solution. The organic solution will then bes tripped of vanadium by contact with a soda ash solution. The barren organic solution will bereturned to the solvent extraction circuit, and vanadium will be precipitated from the enrichedstripping solution on a batch basis as amonium metavanadate.

The vanadium precipitate will bt thickened and filtered prior to drying in an oil-fired dryer.The dried precipitate will be subjected to a fusion step at approximately 800'C (1500'F) toproduce V;0s (black flake); packaging will be in 55-gal drums. Less than 0.005 percent U 0g will3

be contained in the vanadium product. H

3.2.3 Nonradioactive wastes and effluents

3.2.3.1 Gaseous effluents,

Milling operations will result in the release of nonradioactive vapors to the atmosphere.

Leaching

The leaching of ores in the uranium and circuit will produce carbon dioxide gas, sulfur dioxidegas, water vapor, and some sulfuric acid mist. Based on the projected calcite concentration inthe ore and process conditions, the applicant estimates emissions of carbon dioxide to be 2200

kg/hr (4800 lb/hr) and emissions of sulfur dioxide and sulfuric acid mist to be 0.023 kg/hr(0.05 lb/hr) from leaching (ER, p. 3--10). The staff agrees with these estimates'.

Solvent o traction

The solvent extraction processes used in uranium and vanadium recovery will release organicvapors consisting of kerosene (95;) and small quantities of amine and alcohol cor' pounds used inthe extraction. The applicant estimates the organic losses to be approximately 0.046 kg/hr(0.1 lb/hr) (ER, p. 3-10). There are no Federal or State emissions standards applicable tothe release of this mixture. However, Federal and State ambient air quality standards havebeen set at 160 ag/m', averaged over 3 hr. The applicant states that operation of the pro-posed mill will not result in hydrocarbon concentrations exceeding this level (ER, p. 3-10).

ProdJCt dryers _

The yellow cake and vanadium black flake dryers will burn approximately 11 liters /hr (3 gph)of No. 2 fuel oil ( 17 sulfur), producing gaseous effluents containing nitrogen, carbondioxide, water vapor, sulfur dioxide, and nitrogen oxides, as well as some amnonia from decom-position of the concentrate product. Radioactive effluent from this source is discussed inSect. 3.2.4.6. The applicant estimates that dryer off-gas concentrations of sulfur dioxideand nitrogen oxides will be 0.91 kg/hr (2 lb/hr) and 0.23 kg/hr (0.5 lb/hr) respectively (ER,p. 3-11).

Because the heat input to the yellow cake and vanadium black flake dryers will be only 4.7 x104 J/hr (4.5 x 10' Btu /hr), no Federal or State emission standards apply to this source.However, Federal and State ambient air quality standards will apply to nitrogen oxides, sulfurdicxide, and particulate concentrations due to dryer operation.

Building and process heating

Steam necessary for building and process heating will be generated from coal-fired boilers.Approximately 55 MT (60 tons) of coal per day will be required at a heat input of approximately5.3 x 10M J/hr (5 x 106 Btu /hr). As a result of the boiler combustion, various stack gaseswill be released to the atnosphere, including carbon dioxide, water vapor, sulfur dioxide, andnitrogen oxides.

3-6

State and Federal emission standards are not applicable to a steam generating boiler of thissmall size. However, Federal and State ambient air quality standards will apply to theresulting ambient concentrations. The combustion of 55 MT (60 tons) per day of 0.3? sulfurcoal would generate approximately 33 kg (720 lb) of sulfur dioxide per day (ER, p. 3-21). Basedon an industrial NO, emission factor of 10 kg/MT (20 lb/ ton) of coal burned, the staf festimates nitrogen oxide emissions to be 545 kg/ day (1200 lb/ day). Fly ash emissions from thisproposed boiler are div.ussed in Sect. 3.2.3.3.

Ana_1ytical laboratory

The mill facility will be complemented with an analytical laboratory that will routinelf assayproducts of ore, process streams, and final products to assure adequate quality control andplant operating efficiency. The laboratory fume hoods will collect air and mixed chemicalfumes for dilution and venting to the atmosphere. These gases will contain nonradioactive

The volume of gaseous fumes emitted f rom the laboratorychemicals, such as C0j, hcl, and NO2operations will be small and, considering the dilution in the collection stack and aireductors, should be inconsequential (ER, p. 3-22).

3.2.3.2 L_iguid effluents

All mill process, mill laundry, and analytical laboratory liquid wastes will be discharged tothe tailings impoundment for disposal by evaporation (Sect. 3.2.4). Sanitary wastes will bedisposed of by a septic tank and teach field designed and operated in accordance with appli-cable State of Utah, Division of Health, and U.S. Public Health Service standards and regula-tions.

Storm runof f from above the mill, ore storage piles, ore buying station, and the initial tail-ings impoundnent (cell 1 - initial) will be diverted to offsite drainages (Figs. 3.4 and 3.6).The runoff from the mill and facilities area will be impounded in a sedimentation pondlocated at the southwest corner of the mill and facilities area bounded by cells 1 and 2.

3. 2. 3. 3 Solid effluents

Nonradioactive solid wastes will be generated by the coal-fired boiler, the ore buying stations,and by maintenance and administrative activities at the mill. Dusts will be emitted f rom orecrushing and handling operations, are storage piles, unstabilized tailings, and from theuranium yellow cake and vanadium black flake dryer stacks. With the exception of the blackflake dryer, the dusts from these sources are contaminated with low levels of radioactivity.Radioactive solid ef fluents are discussed in Sect. 3.2.4.

Building and_ process heat _ing

The combustion of coal will produce two ash products, fly ash ar.d bottom ash. With a coalusage rate of 55 MT (60 tons) per day, the total ash production would be less than 5.5 MT(6 tons) per day, which will be sent to the tailings retention system. These ash productswould settle with the tailings solids and present no additional waste problems.

Stack emissions from the coal-fired boilers will pass through multiciones to remove fly ash,and less than 86 kg (190 lb) per day of particulate matter will be released to the atmosphere.Fly ash deposits from the precipitator will also be sent to the tailings impoundment(ER, p. 3-21).

Ore processing, maintenance, and administration

Scrap iron, wood, and other mine trash removed f rom the ore during crushing operations will beonly slightly contaminated such that it may be dispose.d of at nonradioactive waste. Trash,rags, wood scrap, and other uncontaminated solid debris will cesult from maintenance andadministrative activities. These materials will be disposed of in land fill areas approved bythe State Division of Health and the appropriate local authorities.

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3-8

Vanadium product dryer

When ore characteristics permit, the vanadium recovery circuit will extract the vanadium fromthe uraniun circuit ef fluent (Sect. 3.2.2.2). The precipitated vanadium product will be driedin an oil-fired dryer to give vanadium pentoxide (black flake). Vanadium pentoxide is toxic.Therefore, drying and packaging will occur in an isolated building, and emissions will becontrnlled by a wet fan scr'ubber operating at an equivalent venturi scubber pressure of 51 cm(20 in.) of water and an efficiency of 99t. The applicant estimates the particulate releaserate from this source to be 0.23 kg/hr (0.5 lb/hr).1

3.2.4 Radioactive wastes and effluents

Mining and milling of natural uranium releases some radioactivity to the environment. Uranium-233 and its daughter products in the ore are the most significant sources of radiation. The oreprocessed by the proposed White Mesa mill is eyected to have an average grade of 0.125% uranium(as U 0e). Ore of this grade has an activity of about 320 uCi of uranium-238 per ton of ore.3

The activity from uranium-235 and its daughters is only 5% of that of the uranium-238 series andmay be ignored as it is radiologically insignificant.

Ore buying, shipping, and milling processes offer several pathways for release of radioactiveef fluents to the environment (Fig. 3.5). The applicant's existing Hanksville and Blanding arebuying stations and the proposed mill are designed to minimize the releases through thesepathways. The ore buying stations are the subject of NRC licensing actions independent fromthe mill source material license, which is the subject of this document. Effluents from theoperation of these stations will be considered only as they impact the environment around thesite, in the following sections each potential effluent source is discussed, and estimates ofeffluent releases based on operating data from other similar facilities will be presented.

3.2.4.1 Ore crushing and sampling

Run-of-mine ore will be received at the applicant's are buying stations at Hanksville andBlanding. Ore from different mines will be segregated into " lots" to facilitate sampling andpayment. The raw ore will pass through a primary crusher and be reduced to less than 3.8 cm(1.5 in.). A fraction of the ore will be subjected to a crushing and sampling process that willprodJCe a representative sample of the entire ore lot being processed. During the samplingprocess, radon gas and low-level radioactive ore dust will be released.

The Blanding ore buying station is expected to process 114 MT (125 tons) of ore per hour, opera-ting on one 8-hr shift per day. All feeders, crushers, screens, chutes, and transfer points areenclosed in hoods connected via ducts to the three baghouse dust filters used in the plant. Thefilters are cleaned by a reverse jet of air, which knocks the dust into a bin at the bottom ofthe baghouse. The collected dust is recombined with the ore at appropriate points, so the oregrade is not altered (ER, p. 3-32).

The bag filters have a dust removal efficiency of around 99.5% (ref. 2). Assuming the ore to befairly dry (<6; moisture) and the dust load to the collector to be 0.008% by weight,3 the dustloss from the total crushing and samnling process would be approximately 4 x 10 d. Conserva-tively assuming that the entire mill are demand of 1800 MT per day is processed by the Blandingstation primary trusher, the annual dust emission would be 0.245 MT per year. At an averagegrade of 0.15% U 0 , slightly higher than expected, the concentration of uranium-238 in ore4 9would be about 423 pCi/g. Also, the uranium concentration of fine crusher dusts is reported tobe about 2.5 times the concentration in the gross ore. 3 Based on these data, and the assumptionof secular equilibrium, approximately 2.6 x 10' Ci per year of uranium-238 and each radioactivedaughter would be released.

Radon-222 gas would be released as a result of disturbance of the ore during processing. Roughly10% of the equilibrium amount of radon is released during crushing and grinding operations.''Use of this value for the Blanding are buying station is conservative because secondary crushingand grinding do not occur. Based on a 10% radon loss, an ore process rate of 1800 MT per day,and an equilibrium ore concentration of 423 pCi/g, aoproximately 26 Ci of radon-222 would bereleased each year.

3.2.4.2 Transportation of ore to the mill

Crushed ore will be transported from the Hanksville buying station to the proposed mill incanvas-covered dump trucks of 30-ton capacity. The ore will not be heaped in the truck beds butwill be evenly distributed to prevent are spillage during transportation. The use of a canvascover tied over the truck bed will minimize dust loss during haulage (ER, p.3-30).

3-9

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Fig. 3.5. Radionuclide dispersion pathways relevant to the White Mesa Uranium Project.

3.2.4.3 Ore pads

Quantities of ore will be stored in stockpiles at the applicant's are buying stations at Hanks-ville and Blanding. These ore buying stations are the subject of two additional licensingactions separate from the mill application. The ef fluents from the ore pad at the Blanding orebuying station, however, would act in synergism with the effluents from the proposed mill;therefore, the Blanding ore pad operations and effluents are discussed.

Because of present ore buying operations, the applicant is accumulating ore in a 2.4-ha (6-acre)area north of the existing Blanding ore buying station. The applicant estimates that a maximumof 2.3 x 10 tii (2. 5 x l o s tons) of ore will be stockpiled at the Blanding site at the time of$

mill startup. This quantity of ore would create a pile 6.7 m (22 f t) tall covering the 2.4-ha(6-acre) stockpile area. During operations, the stockpile would be reduced to under 9.1 x 104MT (1 x 105 tons).

Particulates and radon-222 will be the main atmospheric emissions associated with the ore piles.Based on the meteorological data and the dusting rates for tailings sands (as a function of windspeed) presented in Appendix D, and assuming that ore pile dust emissions will be 1% of thosef rom an equivalent area of fine-grained tailings, the annual average ore pile dusting rate isestimated to be about 1.8 x 10'7 2g/m -sec. For a surface area of 6 acres (2.4 ha), accountingfor side areas and surface roughness, the annual ore pile dust release is estimated to be 162kg. At a gross ore concentration of 423 pC1/g and a fine concentration of 2.5 times that figure,t% annual uranium-238 release from this source would be about 1.7 x 10 * Ci/yr. The release ofeach particulate daughter in Secular equilibrium would also be 1.7 x 10% Ci/yr.

3-10

The applicant intends to moisten pile surfaces af ter ore b added or removed and this will actto reduce these releases. As the release estimates presented here are basically proportional tothe area of the ore storage piles, they would not be siqnificantly affected by changes in thevolume of stored material as long as it is distributed over the same surface area.

Radon-222 will be produced in the pile from decay of radium-226. Most of the radon decays inplace with only a small fraction of the radon escaping the piles via dif fusion. The staffestimates the annual radon release for the maximum stockpile case to be approximately 240Ci/ year (see Appendix F). As mill operations progress and the size of the pile decreases to anequilibrium value under 9.1 x 104 MT, the radon release from this smaller pile will depend onpile geometry. The radon flux from the pile surface is virtually independent of thickness forthicknesses greater than 3 m (10 ft). Therefore, if the same area [2.4 ha (6 acres)) is main-tained for the equilibrium pile, the annual radon release would be the same as for the maximumstockpile, that is, 240 Ci/ year (Appendix F).

Dust control measures such as moistening the surface of the stockpiled ore will also reduceradon releases because the moisture will decrease the diffusion coefficient. This effect isexpected to be small.

3.2.4.4 Secondary crushin Land grinding

The applicant proposes to use a semiautogenous mill to perform secondary crushing and grindingof the ore. The semiautogenous mill will also function as a primary crusher for cres receiveddirectly from mines (and not through are buying stations). This process uses larger pieces ofore to crush and grind smaller pieces; thus the ore essentially grinds itself. Steel balls maybe added as necessary to aid in grinding.

Because the 3emisutuyeiioJ5 mill is a wet process, particulate releases will be small, Assuminga release fraction of 1 x 10'I, a gross ore concentration of 423 3Ci/g, a fine concentration2.5 times higher, c.nd a processing rate of 1800 MT/ day, the annual release of uranium-238 andeach daughter in secular equilibrium from secondary crushing and grinding is estimated to be 6.5x 10' C1. Based on a release fraction of 20% the annual release of radon-222 gas from thissource is estimated to be 52 Ci.

3.2.4.5 Leaching and extraction

Leaching and extraction are wet processes and should not make any significant contribution tothe release of particulates. Because the residence time of ore 11 the leaching circuit will beshort (12 to 24 hr), radon-222 will not build up to concentrations high enough to give a signifi-cant gaseous release.

3.2.4.6 _ Yellow cake drying and packaging

Normally, the uranium concentrate (precipitated ammonium diuranate) will be dried at 650'C.The product (yellow cake) will be about 90t U 0s and will contain about 941 of the uranium in3

the ore. In addition, yellow cake will contain about 5* of the thorium-230 and 0.2% of theradium-226 and daughters originally in the ore. The uranium product dryer and product crusherwill be isolated from other mill areas. Emissions will oe controlled by wet fan scrubbersoperating at an equivalent venturi scrubber pressure of 0.5 m (20 in.) cf water with anefficiency of about 99t The solution and particulates collected from the scrubbers will berecycled to the No. 1 yellow cake thickener in the mill (ER, p. 3-19). Data presented inTable 9.13 of Reference 3 indicate that about 1.2% of the annual yellow cake production may beexpected to reach the wet fan scrubbers. At a gross are grade of 0.15% U,0g and a recovery rateof 941, the annual production of pure yellow cake (U 0s) would be about 863 MT. With a3

scrubbing efficiency of 991, the annual yellow cake release would be about 115 kg of whichabout 104 kg would be U 0. The uranium-238 release rate is then calculated to be about

3

0.029 Ci/yr. Releases of other isotopes would be about 1.6 x 104 Ci/yr of thorium-230 and6.2 x 10" Ci/ year each of radium-226 and lead-210. Releases of radon nas from this sourceare negligible.

3-11

3.2.4.7 Tailings retention area

The tailings discharged from the counter-current decantation unit of the mill is a slurryconsisting of 897 kg (1977 lb) of solids and 0.9 m3 (237 gal) of liquid per ton of dry ore fedto the mill. The tailings liquid contains residual acid from the leaching step and dissolvedsolids placed in solution by the leaching and solvent extraction steps. The estimated com-position of the waste solution is given in Table. 3.1.

Both the liquid and solid portions of the tailings will be a source of low-level radiation dueto the uranium and daughter products lef t in the wastes. Approximately 6% of the originaluranlem, 95% of the thorium, and 99.8% of the radium remain with the tailings. The radio-active components of the waste show generally low solubility and remain mostly in the solids.The applicant conducted assays of synthetic tailings generated under conditions expected to befound in the mill and measured the thorium-230 and radium-226 contents at 1.5 x 102 pCi and3.7 x 102 pCi per gram of solids (ER, p. 3-12). The actual concentrations found in the milltailings will depend on the actual grade of the ore fed to the mill. The soluble radioisotopeconcentrations are listed in Table 3.1.

Because of the adverse radiological and chemical nature of uranium mill tailings, permanentenvironmental isolation is required. The tailings management plan should prevent excessiverelease of solids by wind erosion and of liquids by seepage, leakage, or overflow duringoperation of the mill. Following the cessation of milling operatians: the tailings managementplan should also provide for adequate stabilization of the tailings against long-term erosionand minimize the leaching of radioactive solids, the diffusion of radon-222 cas, and the

Table 31 Compos. teen of liqued in plant ta ;ingsslurry based on laboratory test we.k

Parameter Amou tn

Composetion (g'leter)V 0 24U 0 002sNa 4 90NH 0 0653

Cl 3 05SOa 82 2Cu I 62Ca 0 48V 4 06As 4 26Mn 4 58In 0 09Mo 0.00 7organ <s 02'pH 16-20As 00s2Ba 0.0003Cd 0 0017Cr 0 0000Pb 0001Hg 0 00rOO1Se 0 000'AAg 0 00006F 0 0014S 0 30

Radsochemical assay (pCa/hter)

Gross alpha em.wons 2 5 x 10'Gross beta emiss.ons 2 3 x 105Th 230 13 X 108Ra 226 23 X 10'Pt> 210 2 8 X 10'

'Wasured in gallons oer 1000 gal.

Souete ER.p 3 - 12, Eegv Fuels %ciear. Mc.." Responses to Comments on Where Meu Proeect oES."Me . 6.19 79.

3-12

direct gama radiation dose from the tailings. The tailings managerient plan proposed by theapplicant is discussed in the remsinder of this section. The merits of the proposed impound-

ment and alternative methods are discussed in Sect. 10.3.

The applicant proposes to build a six-cell im;)oundment system innediately to the west and southof the proposed mill (Fig.'3.4). The design storage volume of this system is 15 years. Theimpoundment would be constructed in a swale, a shallow natural basin. A cell would be con-structed by excavatinq the bottom of the swalf and placing an en bankment across the swale toform the downstre3n side of the cell.

Each retention embankment will have a final embankment elevation natching the level of theadjacent natural around that creates the ridges along the edges of the swale. Therefore, theerbankroents will only be as high as the undisturbed ground adjacent to the tailings cell. Thenaximm embankment ht ights will vary fron 7.6 to 13.0 n (25 to 42 f t), depending upon theindividual cell.

Each tailings cell will be filled to a level 1.5 m (5 f t) below the top of the embankment andthe adjacent ground and will be covered with a sufficient amount of cover to reduce the radonemanation to twice hackground. This cover will create a slight rise where the swale formerlyexisted to gently drain waters away from the reclained tailings area while minimizing erosionof the cover ma terial .

Seepage will be centrolled in the first three cells [ evaporation cells 1 - initial (1-l) and1 enlargement (1-E) and tailings cell 2] by state-of-the-art synthetic liners placed overand overlain by layers of packed silt-sand materials available onsite (see Sect. 10.3.2 fordescription). No seepage problems with this liner system are anticipated. The applicantproposes to line the renaininq cells with a 2-f t layer of compacted clay (permeability of about3 x 10" cm/sec) to control seepage. Cells 1-1 and 1-E will be used only as evaporation ponds.As the tailings slurry in cells 2 through 5 drains, excess liquid will be pumped to these pondsfor eva pora tion. Cell 1-I. cell 2, and the cell 2 " safety dike" will conpose the first stageof construction (see Fig. 3.6. ).

The embankments which dam the cells will be constructed of compacted soil available on thesite. The embankments would vary in height f rom a meter or more near the ridges of theswale to as much 13 m (42 f t) for dibes at the iowest point in the swale. All dikes wouldbe 6 n (20 f t) thick at the crest (allowing for an access road on the dike) and would haveslopes no steeper than 3:1 (horizontal to vertical; Fig. 3.7). The final exterior slope ofthe last enban6 ment on the perineter of the impoundment will have a slope of 6:1 and will beconstructed of excavated rock (Fig. 3.8). Because the dikes will not saturate during the briefperiod a given cell is in operation, engineercj embankments are not utilized. Geotechnicalstudies perforned for the applicant indicate that the proposed slopes would withstand anearthquake with a magnitude of VI on the Modified Mercalli Scale.

The proposed tailings system features simultaneous construction, operation, closure, andreclamation activities. The first two cells (cell 1-1 and cell 2) and the cell 2 " safetydike" (which will ultimately be part of the cell 3 cmbankment) would be con:tructed beforecomencement of mill operation (Fig. 3.6), with tailings being initially deposited in theseccad cell and the liquids decanted and pumped back to the first cell (cell 1-1) forevaporation. The " safety dike" of the second cell would form a downstream catchment areafor any release of tailings material in the event of failure of cell 1-I or cell ? embanknents.(Note that this failure is considered highly unlikely as the cell 2 embankment will bedesigned and constructed to meet Pegulatory Guide 3.11.) Durinq the filling of cell 2,cell I would be excavated and lined, and the " safety dike" for cell 3 would be constructed.Af ter cell 2 is filled to its final grade, the tailings disposal pipeline would be movedto cell 3. While cell 3 is being filled, reclamation of cell 2 would commence after the tail-ings had dried, and excavation of cell 4 would begin. Except for a small channel, whichwould be maintained through the cover of the first cell (and each subsequent cell) f orplacement of the tailings slurry pipeline and tailings liquids return line (to evaporationponds), the cells will be completely reclaimed. The slurry discharge pipe will also becontained in a second pipe (emergency containment pipe) where it passes throuqh embankmentsections to prevent embankment erosion in the event of slurry pipe failure. This pattern ofoperation would continue until the last cell is constructed. As with previous tailings cells,closure and reclamation of the last cell (cell 5) would be completed as soon as the tallingssurface is sufficiently dry for movement of heavy equipment over the pile. Cells 1-1 and1-E will be allowed to dry, construction materials from cell 1-E will be placed in cell 1-1,and cells 1-I and 1-E areas will be reclaimed.

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3-14

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Fig. 3.7. Typical dike section. Source: Energy Fuels Nuclear, Inc.,.waru Mncria?Liw.v. A; plica t ic n, k%ite M. ca Urani:r Mill, Pbrdim , i tah, Energy Fueis Nuc1 ear, Inc. ,Denver, Sept. 26, 1978, Appendix AA.

ES 4626

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Fig. 3.8 Final dike section. Source: Energy fuels Nuclear, Inc., Soarce MaterialLic.mec g rlicaticn, White Mcca Urri e Mill, Blandig , Utah, Energy Fuels Nuclear, Inc.,Denver, Sept. 26, 1978, Appendix AA.

The staf f has examined the water balance for the system and concluded that the 40 ha (98 acres)of available free water surface (cells 1-1 and 1-E; Fig. 3.4) plus evaporation from the slimesarea and evaporation from the mnist sand fraction in the tailings cells will enable theapplicant to dispose of excess water. If difficulties are encountered, the applicant canrecycle some of the ponded water for further mill use.

Effluents from the proposed impoundment will consist of wind-blown particulates, and radon-222.During tailings cell fill operations, wind erosion of the tailings will be minimized by keepingthe entire tailings surface moist by regularly shif ting the location of the slurry dischargespigot. liowever, as the final layer of sanos is deposited in a cell, the tailings dischargeline will be moved toward the downstream dike, allowing the upper end of the cell to dry out.Auditional drying will be necessary to allow operation of heavy equipment during reclamation ofthe cell. The staff will require the use of crusting agents, water spray, or similar means tominimize the erosion of the tallings by wind. If no successful mitigating measures were taken(conservative calculation), the annual average dry tailings pile dusting rate, nn the basis ofdata presented in Appendix D, would be about 1.8 x 10-5 g/m -sec which is equivalent to2

about 2.2 MT/ acre-yr. Corresponding estimated radioactivity release rates are 1.4 x 104C1/ acre-yr for U-238, 2.2 x 10-3 Ci/ acre-yr for Th-230, and 2.3 x 10-3 Ci/ acre-yr for Ra-226and Pb-210 (cach).

Due to uncertainties concerning the period of time necessary for drying prior to cell reclama-tion, the staff has conservatively assumed (for purposes of radiological impact analysis) thateach cell would have an area of 40 ha (100 acres) and that there could be 2 cells drying outwhile a third was being filled. If the cell being filled is 50% beach, there could be atotal of approximately 100 ha (250 acres) of tailings area available for dusting. The staffhas assumed that control measures to be implemented by the applicant will reduce dust emissionsfrom nonoperational cells by 80t. Under these conditions total annual radioactive particulatereleases are estimated to be 0.013 Ci of U-238, 0.20 Ci of Th-230, and 0.21 Ci of Ra-226 andPb-210 (each).

3-15

Radon-222 gas is expected to be released in significant quantities from dry tailings areas.Releases from saturated tailings, or tailings that are under water, are severely limited due tothe low diffusivity of radon gas in water. The staff assumes that two 40-ha (100-acre) cellsmay be drying prior to reclamation while a third cell is being filled. Radon releases from thedriest cell (8% moisture content), the other cell drying out prior to reclamation (15% moisturecontent), and the beach area of the filling cell (50I beach, 37% moisture content) are estimatedto be 5550 Ci/yr, 2480 C1/yr, and 30 Ci/yr, respectively (see Appendix F for details). Thetotal annual radon-222 release is estimated to be 8060 C1/yr. Radon releases from underwatertallings materials or reclaimed tailings cells are insignificant in comparison and have beenignored.

3.2.4.8 Uranium concentrate transportation

The uranium concentrate will be transported in 55-gal drums by truck because no rail trans-portation is available at the site. Uranium shipment, about 2000 drums each year, will resultin an external radiation dose'' to an individual of 2 mR/hr at any edge of the truckbed. Undernormal operating conditions, no significant release of radioactive particulates would occur.However, release could occur during transportation accidents as discussed in Sect. 5.3.1.

3.2.4.9 Source terms

Sections 3.2.4.1 through 3.2.4.8 describe the nature and quantity of radioactive effluentsconservatively estimated to be generated by milling operations at the White Mesa Uranium Project.Estimates employed in the above discussions were derived from project design parameters and datafrom similar mills.6-37 The estimates reflect operation of the fully developed mill andtailings area. Initial releases from the tailings area will be lower than the estimated valuesfor several years af ter startup. Therefore, the use of full-scale operation as the basis forestimates adds some additional conservatism to the analysis. Table 3.2 gives the design param-eters used in estimates of radioactive release rates. The source terms for the milling opera-tions and areas are presented in Table 3.3.

3.3 INTERIM STABILIZATION, RECL/JiATION AND DEC0f1ilSSIONING

3.3.1 Interin stabilization of the tailings area

Interim etabiH:: nim is defir.ed as measures to prevent the dispersion of tailings particles bywind and water outside the imediate tailings retention area. Such measures will be requiredat the White Mesa mill during the 15 years of operation (for in-use and drying cells) and theyears required to dry the final tailings cell and evaporation cells af ter operation (seeSects. 3.2.4.7 and 10.3.2, Alternative 1) prior to reclamation.

As a license condition, the staff will require that the applicant implement an interim stabiliza-tion program which minimizes dispersal (via airborne particulates) of blowing tailings to themaximum extent reasonably achievable. The program shall include the use of written operatingprocedures that specify the use of specific control methods for all conditions. The effective-ness of this control measure shall be checked at least weekly by means of a documented siteinspection.

3.3.2 Reclamation of the mill tailings area

In accordance with the Utah Mined Land Reclamation Act of 1975 and the requirements of the imC,the applicant has prepared a stabilization plan for the tailings area. The goal of the appli-cant's plan is to meet the performance objectives for tailinas managenent (Sect.10.3.1).

The proposed reclamation program calls for a 0.6-m (2.0-ft) layer of compacted clay, a 1.2-m(4-f t) layer of silt-sand overburden material, and a 1.8-m (6-f t) layer of rock overburdenmaterial over the tailings area. The proposed cover is considered sufficient to reduce

The cover would also be graded and sloped at a grade of 2% or less to prevent impoundment ofsurface runoff. Slopes on the perimeter of the cover would be no steeper than 6:1 (horizontalto vertical) and would be constructed of riprap. A layer of topsoil 0.15 m (0.5 f t) thickwill be placed over the cover. The area would be fertilized and revegetated with a suitablemixture of grasses, forbs, and shrubs. Grasses and shrubs whose root structures would penetratethe cover will not be planted. The approximate volumes of material required would be 7.38 x105 m (9.65 x 105 yd3) of clay, 1.76 x 1 M m3 (2.30 x 106 yd3) of overburden, 2.2 x 106 33 m

3-16

Table 3 2. Prmcipal parameter aalues used en theradiotopcal assessment of the White Mesa Uranrum Project

. . _ _ _ _ _ . . _ . . _ _ . _ _._ _ _ __ .

Par arr+ter Value*

General data

A.es age ore grade, % U 0, 0 153

Oreroacente ation, pCi of U 238 aist daugh ter s per giam 423Ore orocessmg rate. MT! day 1800Days of operation per year 340

Blanding ore crusher

Or e orocessing e are. M T e d..y 1800Fra<.tton reteased as par t culates 4 X 10 - #Fe,ct.on of raton released 0.1

Oust ore concentration ratio 25

Ore storage peles"

Ac tuoi at ca. ha (acres) 2.4 (6)Ef f ative dostmq a ca. ha (acres) 3.0(73)Annual average dint loss rate. a;m .sec 1.8X10''2

Dust ore concentration ratio 25

Semiautogenous grinder

Ore orocessing rate. MT day 1800f raction released as pas ticulates 1 X 10 - *Fraction of radon released 02Dust ore concentration ratio 25

Yellow cake drying and packagmg

Fraction U to ytllow cake 0.94F ract.on Th to yellow cake 0 05Fraction Ra and Pb to yellow cake 0 002

Annual U 0, product.on, MT 8633

Annual yellow cake production. MT 969Fraction of veHow cake to scruhtwe 0 012Scrubber relaase fraction 0 01

Taihngs impoundment system *''

Fraction U to ta>Iinto 0 06F raction Th to ta>Imqs 0.95Fraction Ra aruf Pb to tailings 0998Area, ha (acres) per cell 40 (100)

Area sub ect to dusting, he (acres) 100 (200)i

Annual aver afdust loss rate. g 'm2. sec 18 X 10 ' *Dust tails concentration ratio 2.5

* Parameter valves prewnted here are those selec ted by the staf f f or use inits radiological impact auessment of the White Mesa Uranium Proret. Thesevalues. whech enclude emissions from the Blandmq ore t'naying station,represent conservative selectrons from ranges of potential values m mstarxesWere msufficient data has been available to be more specific.

8Appendix F provides addirional informat.on regarding the ca|culation ofradon releases

'Ef fective dusting area is 36 ha (90 acres). 2(T% of twn 40 ha (100 acrelcells drying print to reclamation and 50% of a 40 ha (100 acre) operationalcell.

(2.89 x 106 yd3) of rock, and 2.2 x 105 m (2.88 yd3) of topsoil. Staged constructed, operation,3

and reclamation will minimize stockpiling and handling requirements.

The reclamation plans have been developed from recommendations from the U.S. Department ofAgriculture (USDA) Soil Conservation Service and Forest Service (ER, Sect. 9.4). These plansare also in accordance with the regulations of the State of Utah Division of Oil, Gas, and!11ning. 38,39

3-17

Table 11 Estimated annual releases of radioactrue materialsresultmg from the White Mesa Uranium Project

-

Annual releases (Cd*

U 238 Th 230 Ra 226 Rn-222

Blareng are uusher 2 6 X 10 - * 2 6 X to-* 2.6 X 10- * 26X102Ove storage paes 17X10'' 1.1 X 10 - * 1. 7 X 10 - * 2.4 X 10

Secorulsy crusher 65X10-* 6.5 x 10~* 6.5 X lo-* s2XtuYellow cake scrubber 2 9 X 10 - 2 1.6 X 10" 3 6.2 X 10-' ooTaengs system 1.3X10-2 2.0 X 10 - ' 2.1 X 10 - ' 8.1 X to'

* Releases of other isotopes in the U 238 decay chain are included in the radiologicalimpact analysis. These releases are assumed to be identical to those presented here forpsent isotopes. For instance, the release rate of U 234 is taken to he equal tc that forU 238.

*The project site will be revegetated to return it to the original uses of grazing and wildlifehabitation. The soils are relatively uniform and adequate for these reclamation procedures(ER, Sect. 9.1.1 ) . The reclamation schedule for the tailings impoundment site is depicted inFig. 3.9. The tailings cells will be reclaimed sequentially as each cell is filled, beginningaf ter about the fourth year of operation and every four years thereafter until termination ofproject operations. A clay cap [0.6 m (2 ft)], and onsite clayey-silt soil [1.2 m (4 f t)], androck overburden [1.8 m (6 f t)], will be placed over the dried tailings. Except for the rock-lined drainage ditches, rock-filled slopes along the edges of the soil-covered tailings cells,and the rock-filled southernmost dike of cell 5, about 0.15 m (0.5 f t) of topsoil will be placedon the surface of all disturbed areas and seeded with a mixture of grasses, forbs, and shrubs(Table 3.4). Any excess rock will be disposed of at the 14.6-ha (36-acre) borrow area prior toits reclamation.

The applicant's selection of seeds is representative of the vegetation on the site prior toconstruction and will suffice in reclaiming the site to the preconstruction land condition. Thestaged reclamation plan will permit optimizing the seed mixture for a maintenance-free vegetativecover which will maximize soil stability. In the long term native vegetation is expected toreturn to the area. The seed should be obtained from those areas that have soil characteristicsan1 climate similar to the project site.'d

The mixture of seed will be planted in November with a rangeland drill. Because soll nitrogenis low (ER, Sect. 2.10.1), it may be necessary to apply an appropriate fertilizer prior toseeding. The applicant claims that the topsoil will contain sufficient debris so that mulchingwill not be required. However, by the time reclamation begins, much of the debris will bedecomposed. Malches increase infiltration and reduce erosion and evaporation, thereby encour-aging seed germination and plant growth. Therefore, it may be necessary to crimp mulch into thesoll of all disturbed areas prior to seeding. Revegetated areas will be monitered (Sect. 6.2.2).

The staf f notes that the information developed in the Generic Environmental impact Statement onUranium Milling teing prepared by NRC could be used to modify or chan;e the procedures proposedherein. The generic statement will contain the results of ongoing research to asseis the envi-ronmental impacts of uranium mill tailings ponds and piles, and will suggest mea 7s for mitigatingany adverse impacts. The current NRC licensing action regarding the White Mesa mill will besubject to revisions based on the conclusions of the Final Generic Environmental Impact State-ment on Uranium tiilling Operations and any relatt-d rule making.

The applicant will be required to make financial surety arrangements to cover the costs ofreclaiming the tailings disposal area and of decommissioning the mill.

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IfARC. 50.'979

Fig. 3.9. System .chedule. Source: Energy Fuels Nuclear, Inc., " Transmittal of Conceptual Rev ew Construction Drawing Seti

and Synopsis, Tailings Management System, White Mesa Uranium Project, Blanding Utah," Apr. 2, 1979.

3-19

Tah6e 3.4. Spacees, meding rates, and plantmg depths of tentatrveseed menture to be used in reclamation of the propect site

- _ _ _ _ _ _ . . _ _ _ . . _ _ _ _ _ _ _ . . . _ . _ _ . . _ _ _ _ _ _

Stes - --- --

k g 'ha Ih/ acre cm m.

Gr asws

" Luna" putv scent wh*stgrass 6 16 55 o-0 64 o--4 25Fa.rway (c'estedl wheatyess 1 08 15 o- 0 64 0425

For bs

Yeuow sweettfover 1.12 1.0 127-254 o 5 -1.0Palmer penstemon o.112 0.1 0 -0 64 o--0 25Alf arf a 1 12 1.0 127-254 05-10

Shrutes

Fourwing sattbush 0 56 05 0 G4 -1.2 7 0. 5 - 1.0Comrnon wintertot o 56 05 o 64-1 27 0.5 -1 oB.g sebrush o112 0.1 o 64-1 27 o5-1o

Total 11 424 to 2_ _ _ _ _ _ _ . _ _

Soot ce Energi F uets Nuctear, Inc . Source Materos!s in.enn Apptrcation, WhiteMesa Uranwm Mal, Blamhng. Urah, Denver, Sept. 26,1978.

Prior to the termination of the license the NRC will require that the reclaime.J tallingsimpoundment area be deeded to the Federal government.

In dition, although revegetation is an effective erosion control method under nomal clim.tticand edaphic conditions, it is not known whether continued growth of vegetation can be assuredat this site without irrigation or other supportive measures. Therefore, to assure that astable cover will be established, the staff recomends that riprap (or gravel cover) over theentire basin be planned as an optional erosion control method. The final choice between graveland vegetation can be made based on some years of testing and research currently in progress,and on the perfomance of various reclamation schemes which are completed in the interim.

3.3.3 Decomi s s ior ing

Hear the end of the useful life of this project and prior to the termination of the license theNRC will require a detailed decommissioning plan for the White Mesa mill, which will containplans for decontamination, dismantling, and removing or burying all buildings, machinery,process vessels, and other structures and cleanup, regrading and revegetation of the site. Thisdetailed plan will include data from radiation surveys taken at the site and plans for anymitigating measures that may be required as a result of these surveys and NRC inspectionsBefore release of the premises or removal of the buildings and foundations, the licensee mustdemonstrate that levels of radioactive contamination are within limits prescri' ed by NRC and thev

then-current regulations. Depending on the circumstances, the NRC nay require that the appli-cant submit an Environmental Report on decommissioning operations prior to termination of thelicense.

. . . . _ _ . _ . _ _ . _ _ _ _ - - _ _ _ _ _ _ _ _

3-20

REFERENCES FOR SECTION 3

1. Enger) Fuels Nuclear Inc., D ara Material lia.nse Apr lication, White Meca Unmium Mill,Blar ling, t/cah, Energy fuels Nuclear, Inc. , Denver, Sept. 26, 1978.

2. National Air Pollution Control Administration, rd;0ilation of Air Follatant Disaicnastcro, Publication No. AP-42 U.S. Environmental Protection Agency Washington, D.C.,e

1968.

1. R. C. Dahlman, G. S. Hill, and J. P. Witherspoon, ccrrelation of Fadioactive Vas!c Tec2t-ment Costa mi tha Enviror.~.mta! Innt of Waste Effluenta in the N:<elear Fuel '?y 'le,vol .1, ORNL/TM-4903, Oak Ridge hational Laboratory, Oak Ridge, Tenn. , July 1975.Table 9.12.

4. Ref. 3, p. 151,

5. U.S. Nuclear Regulatory Comission, Final Envircnmental statc-wnt Felatul to Oremtion ofbear Creek PrcJeat, Docket No. 40-8452, June 1977.

6. K. J. Schlager, " Analysis of Radiation Exposures on or Near Uranium Mill Tailings Piles,"R2!iol. Il2ta Rep. 12: 17-28 (1971).

7. U.S. Environmental Protection Agency. Envirmntal Analynic of the Unmium Fuct Cyole,Report EPA-520/9-73-003 Washington, D.C., 1973.

8. U.S. Atomic Energy Commission, Envircrrenta! Cweep of the Unmfum Fuel Ople, ReportWASH-1248, April 1974

9. U.S. Energy Research and Development Administration, U.S. Na?? car Pouer F,rport Activitics,Report ERDA-1542, April 1974

10, R. C. Merritt, "The Extractive Metallurgy of f 'anium," Colo. Sch. of Mines Res. Inst.,Golden Colo., 1971.

11. D. A. Nussbaumer and D. F. Harmon, "The United States Atomic Energy Comission's RegulatoryControl Progranrie for Uranium Milling," reprint from Faiiologica! Health and rafety inMining of Narlear M2terials, vol. !!, International Atomic Energy Agency, Vienna,1964,pp. 519-533.

12. E. C. Tsivoglow and R. L. O'Connell, vaate cuide for the Uranium Milling Industry, U.S.Department of Health, Education, and Welfare, Technical Report W62-12, Robert A. TaftSanitary Engineering Center, Cincinnati, Ohio, 1962, 78 pp.

13. R. G. Beverly, " Unique Disposal Methods are Required for Uranium Mill Waste " Min. Eng.20: 52-56(1968).

14. Winche-ter Laboratory, Topical Report. .Tanuary ma ru-a. :y Report on I. The Centrol ofFadium and Tharium in the Uranium Milling Induatry. II. Radium-22C Analysie Prir.ciples,Interference and Enutice. III. Chrrent Winchester Laboratory Projecte, U.S. Atomic EnergyComission Report WIN-ll2, National Lead Col., Inc., Feb. 1, 1960, 97 pp.

15. U.S. Department of Health, Education, and Welfare, Process and F2ste characteristics atselected Umnian Mille, Public Health Service, Technical Report W62-17, Robert A. Taf tSanitary Engineering Center, Cincinnati, Ohio, 1962, 94 pp.

16. K. E. Tame et al . , Disposal of Liquid W1ste in the Durango-Type Uranium Milling Floucheet,U.S. Bureau of Mines, Report of Investigation 5874, 1961, 12 pp.

17. K. E. Tame et a1. , Diepcoat of Radioactive Waste in the Vitro-Type Uranium Milling Flou-sheet, U.S. Bureau of Mines, Report of Investigation 6011, 1962, 10 pp.

. . . . . - - . - - _ _-

3-21

18. K. E. Tame et a1,, :dio ,tice net d e; n: in the thir rm- p vraniw- Millig ?!n-cl.ect, U.S. Bureau of Mines, Report of Investigation 6045, 19u2. 9 pp.

19. K. E. Ta e and J. B. Rosenbaum, Sier' u ~f Li% s w f c in * he Foin- N-TV ;' N o Ur-:niwuMi ?in; fleca b e, U.S. Bureau of Mines, Report of Investication 6114, 1962, 11 pp.

20. K. E. Tame, iali w tivity in Alk |ir.c k h Milling LY:,',:se, U.S. Bureau of Mines, Reportof Investigation 6346, 1964, 8 pp.

21. R. G. Beverly, " Radium and Thorium Behavior in Uranium Milling Circuits - Statement of Airv.d Water Concentration Limits Prescribed in Part 20," presented at the Symposium onRadio-chenical Problems in Uranium Milling, Grand Junction, Colorado, Oct. 5 and 6,1960.

22. H. B. Harris et a1. , Mirann:nta: tm m!s Aaowatni uith tha Mil:iy ,f Urznim ?re - A

nem s ,<et, U.S. Atomic Enerqy Comission Report HASL-40 (REV), New York OperationsOffice, Health and Safety Laboratory, Revised Nov. 14, 1958.

23. A*. ri un Ct y !wl H il z u > Evata=tien s. Uranic M m e ml Mi:ls (Ccantratcro),sponsured by Atomic Industrial Forum, Inc., and National Safety Council, /cerican StandardsAssociation Inc. , New York, approved Oct. 3,1960.

24 A. Whitman and E. S. Porter, n. s -:2 stre c, Fc:lution fec, trent:c: ." ills, U.S. AtomicEnergy Comission Report WIN-99, National Lead Co., Inc., June 13, 1958, 43 pp.

25. R. D. Lynn and Z. E. Arlin, " Deep Well Construction for the Disposal of Uranium MillTailing Water b/ the Anaconda Co. at Grants, New Mexico," wns. "in. A T'm 223. 230-237,1962.

26. G. R. Yourt. " Radiological Control of Uranium Mine and Mill Wastes," in ent s fo Imlaatria!ete' * p:vems Ire m!fw, No.13, pp.107-120,1966..

27. D. F. Little et al. , "Two Years' Milling at Bicrof t Uranium Mines Ltd. ," mms. Min. A T":220: 458-468, 1961.

28. W. L. Lennemann and F. E. McGinley, " Advances in Uranium Ore Processing," Min, wgr. '.

45(7): 59-63, 1959.

29. W. D. Arnold and D. J. Crouse, " Radium Removal from Uranium Mill Effluents with Inorganicn 9. 4(3): 333-337, 1965.lon Exchangers," 7t!. Enj. Ch a N: n .'s pa. c

30. U.S. Department of Health, Education, and Welfare, " Disposition and Control of UraniumMill Tailings Piles in the Colorado River Basin," Federal Water Pollution Control Adminis-tration, Region VIII, Denver, Colorado River Basin Water Quality Control Project, March1966, 36 pp.

31. R. H. Kennedy, " Comparison of Foreign and Domestic Uranium Ore Milling Practices,"presented at the Tenth Annual Minerals Symposium, sponsored by the Colorado PlateauSection AIME, Grand Junction, Colorado, May 8, 1965.

32. " Radiation Regulation No. 2," Regulation of the Colorado State Department of PublicHealth Requiring Stabilization of Uranium and Thorium Mill Tailing Piles.

33. Ercelan Ontra! Uraniur Mill T:ilira Pro st, M:mtix!!c, Utah, U.S. Atomic EnergyComission Report RM0-3005, Grand Junction Office, Dec. 20,1963, 26 pp.

34. a pri m nt to the Reivrt of the Mentwel:o Mill railin) Frceien Central Tro.icct, M:nt:-ec?lo, Utah, U.S. Atomic Energy Comission Report Supplement to RM0-3005, Grand JunctionOffice, Apr. 20, 1966, 8 pp.

35. H. J. Paas, Jr., R1!ic!agical Apprair:1 cf the V:nticallo EYoNet hn Juan County, Monti-ullo, Utah, U.S. Atomic Energy Comission Report 100 12049, Idaho Operations Office,February 1966, 20 pp.

36. R. Havens and K. C. Dean, Chemical Stabili= tion c! the Uraniw- Taitinga at Tuba City,Ariac.a, U.S. Bureau of Mines, Report of Investigation 7288, 1969, 12 pp.

" Environmental Survey of Uranium Mill Tailings Pile, Tuba City, Arizona," Radiot. I!calth37Nta Rep. 9(11): 475-487, 1968.

,

3-22

30. Dames and Moore, "Pesponse to Corrients Telecopied from the NRC to Energy Fuels Nuclear,25 September 1978," Denver, Oct. 4, 1978.

39. State of Utah, Isisialan of rhl, ;w, .nl Vinin7, Changes and Adoptions to the GeneralPules and Pegulations. "auopted by the Board of 011 Gas, and Mining on Mar. 22, 1978,effective June 1, 1978.

40. A. P. Plunicer, D. R. Christensen, and S.11. Monsen, !c * *: rWj Hy.7cwlonp in r/ t a h ,Utah Division of Fish and Game, P'ablication No. 68-3, Salt Lane City,1968.

,

4. ENVIRONMENTAL IMPACTS

4.1 AIR QUALITY

4.1.1 Construction

The major nonradiological air pollutants associated with construction of the mill facility willbe gaseous emissions from internal combustion engines and fugitive dust generated from movingvehicles and wind erosion. In general, these emissions will not produce significant impacts toair quality.

The ma>.imum expected emission rate for any of the major pollutants (N0 , 50 , 00, and hydro-2 2carbont) from each piece of construction equipment is less than 0.2 g/sec.! Using conse .ativey/Q (sec/m ) values ( Appendix H. Table H.1), the staff calculated the annual atmospheric con-l

3centration of each pollutant per vehicle to be less than 1 ag/m at the property boundary in thedirection of the prevailing wind.

Fugitive dust associated with construction of the facility will average about 0.4 to 0.7 MT/ha(1 to 2 tons / acre) per month.2 Based on a total of about 142 ha (344 acres) disturbed at anyone time (Sect. 4.2.1), about 121 to 241 g/ set of particulates will be emitted. Annual averageatmospheric concentrations of particulates were calculated by the staff using the x/Q values(Appendix H. Table H.1) for the 16 compass directions at a distance of 2.4 km (1.5 miles). Theaverage of these 16 concentrations indicates that particulate loading due to construction will

3 (Table 4.1). These are conservative calculations because the x/Q valuesrange from 26 to 53 vg/massune a point source; the construction activities actually will be widespread, creatingmany scattered, diffuse sources. Furthermore, the larger dust particles would deposit rapidly,another conoition not accounted for in the calculation. Although dust could cause occasionallocalized degradation of air quality at the site, the duration will be only during theconstruction phase. To minimize fugitive dust, the applicant will frequently water exposeddreas and heavily traveled areas, and all vehicles will be operated 1t a reduced speed.3

4.1.2 Operation

Air quality during operation of the facility could be affected by atmospheric releases princi-pally from the building and processing boiler, yellow cake and vanadium dryers, tailings dis-posal system, and ore stockpiles. The applicant's consultant's estimates of emissions from eachprimary source and their release heights are listed in Table 4.2. The staff estimates (Sect. 3)are somewhat dif ferent, but the conclusions drawn (below) remain the same. In addition,insignificant quantities will be released from other sources including the coal stockpiles, oretransport systems, and acid leach system. Atmospheric dispersion coefficients (x/Q) for eachrelease height are listed in Appendix H. Tables H.1 through H.4. Assuming all processes areoperating simultaneously, annual atmospheric concentrations of particulates, 50 , and N0x at2the property boundary in the direction of the prevailing wind were calculated by the staff tobe approximately 13, 9, and 4 pg/m3 respectively. These concentrations are well below appli-cable Federal and State air quality standards (Table 4.1). Far reasons stated earlier, theparticulate concentrations are quite conservative. The applicant calculated the atmosphericconcentrations of the major pollutants using the CRSTER program, a program used by the U.S.Environmental Protection AgeNy.'' Calculations were for five distances: 2, 4, 6, 8, and 10 km(3.2, 6.4, 9.7, 12.9, and 10.1 miles). Concentrations were the largest at the 2-km (3.2-mile)distance and are as follows: particulates, annual average = 0.26 pg/m3, 24-hr average =3.7 pg/m3; 50 , annual average = 1.1 ug/m , 24-hr average = 15.4 ag/m , 3-hr average =3 3

2366.6 pg/m ; NO,, annual average = 0.51 ag/m3

Although operation of the mill facility should not have any significant impact on air quality,Utah's Air Conservation Regulttions5 require that air pollution control equipment and processesbe selectect and operated to provide the highest efficiencies and the lowest discharge raterthat are reasonable and practical. While the degree of control is subject to approval by treState Air Conservation Committee, the control must be a minimum of 85%. Utah regulations alsorestrict the sulfur content of coal and oil, used as fuels, to no greater than 1.0 and 1.5%respectively.

4-l

_ . _ . . _ _ . . _ _ _ . _ . _ _ _ _ _ . _ _ . _ . . _ _

4-2

Table 4.1. Federal and 5ts*. of Utah at quahty standards-

Pr,nu t an t Aver ay ng time' Pr er wr y st.vwle d S toridae y starstard

N in rn d on.di/' Antiust 005 ppm 0 05 ppm(100 pg 'm3) (10099 m3)

%Nr dion nie Annuat 003 ppmi

(80 pg m l

24 hr 014 ppm'365 pg m3)

3 hr 05 ppm3(1300 pg m )

3 lSr.,ervie il p.c t,r.u|ates Armual germetr it- 75 pq 'm f.,099'mmean

2 324 hr 260 pg m i $g gg .m

i f yile < < a bons (r or r et ter1 3 hr 0 21 ppm' O 24 ppmf or me t h.me l 6 to 9 AM t160py m's (160pg m'l

Photor hemtal on nLmts I hr 0 08 ppm 0 08 ppm(100pg m'l i I t,0 pq 'm )3

C rtum monom nie 8 hr 9 ppm 9 ppmi l(10 mq 'm l (10 mq 'm i

1 h' 35 ppen 35 ppm(40 mg m') (40 mg m 13

' All stande ds eun pt moni.ai average are not to be e=ceed.41 more trian or<c a year.* Nitregen d.om ide is the on'y one of the n.tnyen on oles conwkeed in the amb.ent standards'Ma=imum 3 br concenteat.on terween 6 aral 9 AMS ,m t e E R. Tatete 2 7 - 19

Table 4 2. Emission rates, sources, and releas ,

maior air pollutants associated with opern,.w,of the White Mesa mill

Air potiutant E m,ssion rate Release heightand souece ( g 'sec ) Im)

Sugerated par t eculateBo,ler 1.0 274Yeuow cake drver 0 05 13 7Vanad um dr yer 0 06 13.71aihngs 1 01 100 e stockp.les 1 08 30-60

SOBoiler 40 274Yellow < ake de ver 0 25 13.7

Vanais um dever 0 25 13 7

NO,Boder 20 27.4

Yefion cake rftver 0 06 13.7

Vanadmm drver 0.06 13.7

S >u rces Dames and Moore, "Respnn,es to Comments from theU S. Nuclear Hegulator y Commission. June 7. 1978. W hite MnaUr amum Pr otec t E nvironmen tal Report,'' Denver, June 28.1978.Dames and Moor e. " Supplemental Repor t. Meteorokay a n1 ArOuahty. Env.ronmental neport. White Mes: Uranium Project San JuanCounty, Utah, for E nergy Fuels Nuclear, Inc , * Denver, Sept. 6,1978Dames and Moore, " Responses to Comments Telecopied from NRC toEnergy Fuels Nuclear,25 September 1978.'' Denver. Oct. 4.1978.

.. . .. _ . . _ _ _ _- --

4-3

Pequlations promulgated by the U.S. Environu n :1 Protection Agency' require any rajor source ofair pollutants to comply with the Prevention of Siqnificant Deterioration (PSD) regulations.The White Mesa Uranium Project is currently being evaluated by the appropriate regulatory authort-ties to ascertain if the project is defined as a major source. If the project is deemed to be amajor source, then the applicant will be required to file for the appropriate PSD permit and tocomply with all regulations therein. Initial indications are that the atnospheric concentrationsof pollutants associated with mill operation will be well within the PSD allowable increments.

Southeastern Utah, known for its sc2nic qualities (Sect 2.5.2.2), attracts many visitors.Stack emissions (primarily steam) will be visible to the public traveling Highway 163 east ofthe site. However, they are not espected to be visible from major recreational areas in thevicinity. The closest historical site included in the National Pegister of Historic Places(National Pegister) is located atout 10 km (6 miles) north of the proposed mill site(Table 2.17).

4.2 LAND USE

4.2.1 Land resources

4.2.1.1 Nonagricultural

The proposed White Mesa Uranium Project is not expected to alter the basic pattern of landownership in the area (Table 2.15). Area land uses will change, however, as a result of theproposed mill. About 600 ha (1480 acres) are owned by Energy Fuels Nuclear, Inc., roughly195 ha (4M acres) will be directly used during operations (Sect. 2.5.1) for milling, ore buying,and tailings disposal. Increased residential and cornercial land use is expected in neighboringcomunities to serve mill-produced population growth (Sects. 4.8.1 and 4.8.2). The volume oftraffic using the highways in this area is also expected to grow substantially (Sect. 4.8.5),and mineral extraction is expected to increase in the project area in response to the mill'sdemand for uranium are (Sect. 4.8.l.2).

4. 2.1. 2 Agricultural

Construction and operation of the facility will disturb about 20 ha (50 acres) directly(Table 4.3). In adJition, the tailings will cover a total of aboJt 135 ha (333 acres), and39 ha (9d acres) will be used for stockpile ard borrow areas. Because the tallings disposalsystem will be constructed as six separate cells (two cells for evaporation and four fortailings disposal), with a full tailings cell being reclained as a new cell is opened, a total

maximum surface area cf about fa ha (222 acres) will te disturbed at any cne time by thetailings s, stem. Also, a maximum of about 15 ha (36 acres) of borrow area will be exposedat any given time. Therefore, total land area disturbed at any one time by constructionand operation of the mill facilities will be about 141 ha (343 acres). However, until alloperations have teminated, at least 195 ha (484 acres) will be unavailable for crating. Basedon the capacity of the tailings cells, the mill has a potential to operate 15 years. The dura-tion of the impact will be somewhat longer than this depending on the time required for con-struction, the length of time between disturbance and reclamation, and the length of time ittakes for a suitable vegetative cover to become established on each reclaimed area. Therefore,a realistic estimate of the amount of time the land will be disturbed is about 20 years.

Upon termination of the mill operations, all remaining disturbeo areas will be reclaimed toultimately restore the land to its original grazing use (Sect. 3.3.2). Loss of nearly 195 ha(484 acres) of grazinq land each year the land is disturbed represents less than 0.1% of theprivate rangeland in San Juan County (Table 2.16). With successful reclamation (Sect.3.3.2),this land could be returned to its original grazing capacity.

4.2.2 Historical and archeological resources

As discussed in Sect. 2.5.2.1, a historical survey was conducted. Of the six historical sitesidentified during that survey, five were considered to be eligible for inclusion in th< NationalRegister of Historic Places (National Register). Pursuant to 36 CFR Part 63.3, a re est onMarch 28, 1979, for determinations of eligibility for the historic sites was submitted and iscurrently under review. Of the five sites considered eligible, only one (" Earthen Dam") willbe adversely affected by the mill project, and mitigation will be specified if the site isin fact eligible. (See the proposal for a Memorandum of Agreement in Appendix E.)

. _ - - ..

44

A*. discussed in Sect. 2.5.2.3, arctmological surveys ani testinq have been conducted on thesite since the f all of 1977, and although additional field work will be required to determinethe significance of all identified archeoloqical sites, the NRC, af ter consultation with theUtah State Historic Preservation Officer (SHP0), determined that this area of White Mesa containsnunerous sites which are likely to yield information important in the prehistory of the region.The NRC accordingly requested a determination from the Secretary of the Interior that the areaon which the properties are located is eligible for inclusion in the National Peqister as anArcheological District. The resulting determination was that the White Mesa ArcheologicalDistrict is eligible for inclusion in the National Reqister. It is anticipated that the NRCwill enter into a Memorandum of Agreement under 36 CF R 800, Procedures f or the Protection ofHistoric and Cultural Properties. The proposed plan for mitigatory action is outlined in theproposal f or a Memrandum of Agreement in Appendix E.

Tatde 4 3. Land distueta d by u,nstructen andoperstmn of ttw White Mesa Uranium Protect

Area to ta-I ' ' h "* "P " " Y

A.e4 dator te df yeat s)

ha ac. es

Mat * 20 So

Evapoeation i ens i and E 40 98Ta l.nys cell 2 25 61 32Tal.nm ceu 3 25 63 46Taa ngs reti 4 23 58 38Taan, rett 5 21 53 35Safety d:ke 1 3

Topsoil sti< k paes 4 10

Overtuden stod pac 6 16

Rov k sto< h pae 15 36

Borrow area 15 36

inv l 195 4M 15.1a

'limh..les 6 ha (16 arres) otropmd by an ore buying station

Sow re E ncegy Foris Noctear. Inc.. "Transmotal of CorweptualHewiew Comtruction Dv wng Set and Synops.s, Todmgs ManagementSystem Wh,te Mew Uraveom Pr otect. Piand.nu. Utah." Apr. 2.1979

4.3 WATER

4.3.1 Surface waters

The construction and operation of the uranium mill should have minimal impact on the surfacewaters of the project site and vicinity. During construction of the mill, the ground surfacewill be disturbed by grading, excavation, road access, spoil and topsoil storage, and otherconstruction-related activities. The soils of the project vicinity are normally subject toerosion due to lack of consolidation and poor vegetative cover (Sects. 2.8 and 2.9.1). Duringperiods of flow in local intermittent streams, this natural erosion is reflected in values oftotal suspended solids which reach levels of >l500 mg/ liter (Table 2.22). Stonn runof f fromabove the mill, ore storage piles, and ore buying staticn will be diverted to of fsitedrainages. Runoff from the mill and facilities area will be impounded onsite in a sedimentationpond.

Sediment carrying runof f that can enter local streams will originate primarily from the steepsides of the temporary overburden stockpiles. Table 4.4 lists the ef fects of early con-struction (mill facilities, two evaporation cells, and'the first two retention cells). Thenet change in tons of sediment transferred to local streams is about -2450 MT (-2700 tons),or a reduction in total sediment transfer.

. __

4-5

Table 4.4. Effects of mit'st construction stages. _ _ _ _ _ _ _

Yearly sed mentArea orofuct.on to wral Ye arly net change Yearly change

(M at4005 ""d'" 5he acres MT/ha tons /sre MT tons

M T/ha ton s 'act e

Borrow area 15 36 0 0 -22 - 10 -330 - 360Topsoa stock pae slopes 02 05 1120 Sno 1098 +490 220 24 5Ovce turden stockpde slopes 0.4 1 1120 500 1098 +490 439 490inpsod c ntr ai stu kpde 36 9 0 0 - 22 -10 - 79 -90Over hur den i ener ai seu 6 p.h. 6 15 0 0 -22 -10 - 132 -150Evaporation cells I and E 40 98 0 0 -22 -10 -880 -980Taihng ceits ? ,nd 3 50 124 0 o -22 -10 -1100 -1240V.u soc arain yr 24 60 o o -22 -10 -528 - 600a

fJet -2390 -2685

Soone Energy F urls Nodcar. loc.. "Tr ansmettel of Corweptual Review Construction Drawing Set and Synopsn TaihngsManag, ment Sv stem. White Mesa Uranunn Prosect, Blarw0ng Utah " Apr. 2,1979.

There will be no discharge of frill effluents to local surface waters. In addition, sanitarywastes generated by mill operation will be retained in a sanitary drainage field (Sect. 3.2.3.2)and should not affect surface-water quality.

The construction and operation of the proposed uranium mill should not affect local surfacewaters to any significant extent.

4.3.2 Groundwater

4.3.2.1 Water usage

The applicant has obtained a permit to utilize up to 1.0 x 10'" m' (811 acre-f t) although themill will only use about 5.9 x 105 m l (480 acre-ft) of water per year, which will be withdrawnfrom the Navajo sandstone aquifer. All other wells within 8 km (5 miles) produce from otherformations. This usage will have no effect on other users.

4.3.2.2 _P_otential degradation of groundwater

The mill will discharge about 1.12 m3/ min (310 gpm) of liquid to the proposed tailings impound-ment (Fig. 3.4). The chemical and radiological composition of this waste liquid is given inTable 3.1.

The applicant has proposed to line the evaporation cells (1-! and 1-E) and tailings cell 2 witha multicomponent liner (of synthetic and onsite clayey-silt materials) and to line the remainingtailings cells with a 2 foot layer of compacted clay (pemeability approximately 3x10-8 cm/sec) toessentially eliminate seepage into the underlying Dakota formation; therefore, the possibilityof groundwater degradation caused by seepage of tailings liquids is considered to be remote. Afterreclamation, when deterioration of the liner may have occurred, the staff expects essentially noseepage into the Dakota formation because of the high net evaporation rate in the area. Pre-operational and operational monitoring of the groundwater is required (Sect. 6.3), and mitigatingmeasures will be taken if unexpected groundwater contamination is observed.

..

4-6

4.4 MINERAL RESOURCES

Only uranium, vanadium, and copper are present in suf ficient quantities to warrant processing.At present copper extraction is uneconomic. If this cooper, or any other mineral in the ore,becoces more valuable in the future, the overburden couid be removed f rom the tailings and theseminerals extracted; therefore, this project is not expected to have any impact on the avail-ability of other minerals.

4.5 SolLS

Construction of the mill and tailings disposal system will disturb about 195 ha (434 acres)(Table 4.3). The top 15 cm (6 in.) of soil, removed from the mill site, tailings cells, andterrow area, will be stockpiled at two locations totaling 4 ha (10 acres) (Fig. 3.4). Theremaining overburden and rock will be stockpiled at four areas, totaling 21 ha (52 acres).Removal of topsoil will disrupt existing physical, chemical, and biotic soil processes.Although topsoil will be replaced upon tennination of the project operations, a temporarydecrease in natural soil productivity is probable.7

Removal of topsoil and natural vegetation on the site will accelerate wind and water erosion.Generally, the duration of these impacts will be only during the construction phase, which isexpected to take one year. To minimize fugitive dust resulting from construction activity, theappilCant will frequently water exposed areas and heavily traveled areas, and all vehicles willbe operated at a reduced speed 3 The tailings impoundment will be constructed as six separatecells (Fig. 3.4), only four of which will be active at any given time. As a tailings cell isbeing reclaimed, another cell is being constructed. This construction sequence will result in aminimum disturbance of land at any given time. The material excavated from one cell can be hauleddirectly to a filled cell and placed over the tailings as part of the required cover, thusreducing handling of materials.

All mill facilities will be located upstream of the tailings cells. Evaporation cell 1-1 andtailings cell 2, which will be constructed sinultaneously with the mill facilities and asedirontation pond, will capture mill site runof f (Fig. 3.6). Although sediment transfer willbe increased within the site, the location of the mill facilities and tailings cells shouldminimize sediment transfer from the site, as discussed in Section 4.3.1. To minimize erosion,

the overburden and topsoll stockpiles will be stabilized by seeding with cereal rye and yellowsweet clover.8 Sunflowers, Russian thistle, and other annual plants will also become establishedand will aid in preventing crosicn of the stockpiles.Impatts to soils during operation of the mill include wind and water erosion. Soil over muchof the site will be stabilized by gravel and the presence of structures. The topography of thesite concentrates some of the surface water at two points directly north of the proposed mill(Fig. 3.4). During operations, diversion ditches will be constructed in this area to collect

surface runoff from the drainage above the mill site [25 ha (62 acres)], and the dischargefrom these ditches will be directed to the east into Cottonwood Wash. Rock from excavation ofthe tailings cells will be placed as riprap in the drainage channels to help prevent severeerosion. Rock will also be used to construct the downstream slope of dike 5 and areas on theperimeter of the reclamation cover. Mill and facilities area runoff will be contained by asediment pond (Fig. 3.4).Upon terminaticn of the mill operations, all remaining disturbed areas will be reclaimed torestore the land to preconstruction land uses (Sect. 3.3.2). Reclamation laws require successfulestablishment of a soil medium that is capable of sustaining vegetation without irrigation orcontinuing soil amendments. Assuming reclamation ef forts will be successful, long-term impactsto the soil are not expected to be significant.

4.6 BIOTA

4.6.1 Terrestrial

The primary ecological impact of construction and operation of the mill and tailings disposalsystem will result from the loss of habitat. However, the majority (85%) of the vegetationthat will be removed has been previously disturbed to varying degrees by either chaining,plowing, or reseeding (Figs. 2.10 and 3.4; Tables 2.26 and 4.5). Winter deer use of the project

vicinity, primarily pinyon-juniper-sagebrush habitats, is among the heaviest in southeasternUtah.9 However, because similar rangeland is very common throughout the region (Sect. 2.5), itis expected that loss of this relatively small parcel of land (less than 0.1% of the privaterangeland in San Juan County) shculd not significantly reduce the amount of habitat for theseanimals.

. . . _ _ _

- - -

.._ . . . . . _ -

4-7

Table 4 5. commu..ety types and approximateempense to be disturbed by construction and

operation of the White Mesa mall

Area to be

Cunmunity tm d < s tur bed

ha ac res

Pinyon pumper wsfland 2 68,g wybrusn 27 68Reseeded grassland i 29 73Reweded g,asstand 11 45 11sTamarisk-sah z 1 2Controih-f big sage brush 89 225Daturtw# 11 28

*Mcludes ove buying station.

Land clearing, operation of heavy equipment, and other construction activities will destroysmall animals that move too slowly to escape or that retreat to burrows for protection. Otheranimals will be displaced and may be lost because of predation or increased competition forfood, territory, and other habitat requirements. Although many of these species are importantmembers of the food chain, their destruction would not be a significant impact because theseanimals comprise a very small percentage of the total regional populations. Habitat that willbe disturbed as a result of construction and operation of the mill represents less than 0.05% ofsimilar habitat in the county.

Susp(.nded particulate matter will be emitted into the air by construction activities (Sect. 4.1).These particulates will eventually be deposited in part on the surrounding vegetation therebyreducing plant vigor or causing the plants to be less palatable to consumers. Although themagnitude of these potential impacts is not known, it is expected to be negligible. No signif-icant deleterious effects have been demonstrated at other construction projects of similar orgreater magnitude. Furthermore, if any impacts do occur from fugitive dust and/or gaseousemissions, they should be minor and short term.

Few data a:c available to demonstrate the effects of noise on wildlife, and much of what isavailable lacks specific information concerning noise intensity, frequency, and duration ofexposure.10 Probably, the noisiest period of construction will be during the excavation of thetailings cells. The applicant estimates the average sound level during the excavationphase to be about 66 dB(A) at 300 m (1000 f t) from the center of activity. Such noise is notexpected to seriously affect the area wildlife. The noise initially may cause migration by somewildlife away from the imediate site vicinity, but those that remain or return will generallybecome habituated to construction noises and activities.10

To balance yearly water inputs with yearly net evaporation, the evaporation cell design willrequire a surface area of about 40 ha (98 acres) of tailings water.11 These liquids will beunsuitable for use by wildlife due to radionuclides and other contaminants. However, the fencingaround the tailings impoundment will exclude large animals, and the acidic nature of the pond(pH of about 1.8 to 2.0), and the high salinity will make it unsuitable for most aquaticorganisms and subsequently an unattractive feeding place for waterfowl. However, a few waterfowlor other birds may rest on the impoundment for a short time during migration. Following ter-mination of the mill operations, the tailings disposal area would remain fenced until releasedfrom its status as a restricted area and will not be used for any purpose other than tailingsstabilization and reclamation.

Increased human population associated with construction and operation of the mill will adverselyaffect most wildlife in the area. Greater human population will cause an expansion of munici-palities for commercial, residential, and recreational purposes. Although some species maybenefit from large human populations, most of the larger mammals and predators will abandonhabitats in close proximity to intense human activity. Additional stress will be placed on theterrestrial blota as a result of greater hunting pressure (both legally and illegally) anddestruction of habitat by off-road recreational vehicles. Increased wildlife losses areexpected to occur as a result of greater vehicular travel on highways.

--

_ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . -

4-8

None of the proposed endangered plant species 12 that have documented distributions in San JuanCoun ty are espected to occur on the facility site or inmediate vicinity. Although the13

endangeredh American peregrine falcon (? ^ ' e rcn9m er) and bald eagle (it 2?, , ms? car h 2lw) range in the vicinity of the site, lack of suitable habitat indicates a lowprobability of these species utilizing the project site for feeding or nesting. The black-footed ferret (E c cl2 Qnd, a), which once ranged in the vicinity of the site, has not beensighted in Utah since 1952,3 and the Utah Division of Wildlife Resources feels that thepresence of this species is highly unlikely (ER, Sect. 2.8.2.2). Therefore, construction and

operation of the proposed mill is not expected to impact any endangered species.

4.6.2 Agu a t_i c

The operation of the uranium mill will not entail direct discharge into any surf ace waters. As'he cnnstruction and operation of the proposed uranium mill should not af fect local surfacewaters to any significant extent, the staf f does not predict any adverse impacts on aquaticLiota.

4.7 RADIOLOGICAL IMPACTS

4.7.1 Introduction

The primary sources of radiological inpact to the environment in the vicinity of the proposedWhite Neu Uranium Project are naturally occurring cosmic and terrestrial radiation, and naturallyoccurring radon-222. The average whole-body dose rate to the population in the site vicinity,including doses from natural background radiation and diagnostic medical procedures, is estimatedto be about 236 millirems per par (see 9ct. '.lC).

This section describes the results of the staf f's analysis of the mill-contributed incrementalradiological impacts to the environment and the population in the vicinity of the White Mesamill site. This analysis is primarily based on the estimated annual releases of radioactivematerials given in Table 3.3 and the models, data, and assumptions discussed in Appendix D.h tailed analyses of the radiological impacts of mill operations to nearcy individuals and theentire population within 50 miles have been performed. All potential exposure pathways likelyto result in significant fractions of the mill's total radiological impact have been included(see Fig. 4.1). Consideration has also been given to the occupational exposure received by millemployees and radiation exposure of biota other than man.

4.7.2 ixporurelathways_

Potential environmental exposure pathways by which people could be exposed to radioactive millef fluents are presented schematically in Fig. 4.1. Estimates of dose commitments to man havebeen based on the proposed plant design, and actual characteristics of the site environs. Thestaf f's analysis has included considerations of radioactive particulate and gaseous releates tothe atmosphere.

There will be no planned or routine releases of radioactive waste materials directly intosurface waters. 1 hile there is a possibility of some seepage of radioactive liquids from thetailings impoundments into the groundwater system, this possibility is considered remote and nosignificant contribution to dose via liquid pathways is expected. Furthermore, the applicantwill be required to perform environmental and other monitoring programs to provide earlydetection of any seepage that might occur and to take appropriate mitigating measures.

Environmental exposure pathways cf concern for airborne effluents from the White Mesa millinclude inhalation of radioactive materiais in the air, external exposure to radioactive materials

in the air or deposited on ground surfaces, and ingestion of contaminated food products (vegeta-bles and meat).

4.7.3 Radiation dose comitments to individuals

The nearest known resident lives approximately 4.5 km (2.8 miles) north-northeast of theproposed location of the mill building (ER, Plate 2 2-1). A mobile home about 3.2 km (2.0 miles)north of the mill was occupied until recertly but has since been moved. The nearest residencein the direction of the prevailing winds is located about 6.4 km (4.0 miles) to the south.Nearby population groups include the community of White Mesa, about 8.0 km (5.0 miles) to thesouthwest with a population of about 300, and the city of Blanding 9.6 km (6.0 miles) to thenorth-northeast with a population of about 3300 (ER, Plate 2.2-1).

E S4699CRE FFOM MINES

i'

CRE PAD, FEEDAND GRINDING

#<

'h/(

4,

kif

b INwAtATroNLEACHING AN") f" A b^ N ' A* I h u M t i

"~

EXTRACTION

4

AlaB%%E 8 er'' F utr nNet ,

'AOICALTIVITY t s FQ's 61^

g* 6 r

Y zph U-'a

[ h bTAILINGS 9

STCRAGE s 1r CW =s r

/g 3 nAoicACTevliv3 IN 50ll

u g$

YELLOWCAKE ORylNG

AND PACKAG|NG q, q,_

RADICACTIVITY INCESTIONIN t r, "

PRODUCT TO - W Tait 04 JL'

I l-MA8xET BEEF /

CATTL

Fig. 4.1. Sources of radioactive effluents from the mill and exposure pathways to man.

4-in

The rearest potential residence locations are along the northern border of the site, about1.9 km (1.2 miles) from the mill building. Substantial tracts of privately held acreageexist in this area. All other lands abutting the mill site to the east, south, and west arethe prc;;erty of f.nerg/ Fuels N; clear, Inc., or the U.S. Bureau of Land Management. The areairrediately to the north of the mill site, although suit 3ble for residential structLres,presently is believed to be used only for the grating of meat animals (beef). It is assumedthat neat animals could be grated along the northern site boundary and eaten by the nearestactual residents. The calculated ingestion doses for consumption of beef grazed at this locaticoare coc: parable to those calculated for other locations around the site at which grazing couldt,e expected to occur.

Table 4.f> pre ents a surrary of the individual dose commitnents calculated for the nearestc

actual residen(e, the nearest dClual residDOCe in the prevailing Wind direction, and the nearestpotential residence. At each of these three locations, it is assumed that individuals ingestm at grown at the location of the nearest potential residence, along the northern siteboundary. Table 4.6 also presents the inhalation and external doses calculated for thecornwnity of Wnite Mesa and the city of Blanding.

Tabla 4 6. Annual dow commitments to mdevuluals from radroactivereleaws due to operation of the White Mesa Uramum Mell

Arauul d ew mmm.f m e 1 (mahvemd

( ,, at.on i s posur e pathww tb orn huit ot al t mfy BMs luuj 4

N r est n t d. eu e Intdat "o 0 039 to 0 89 19

4 ', b m I? R o d. o nor th ou thr.nt [ = ter rut te om (loos) 0 12 0 12 0 12I m temM t.om gunm.t 0 81 0 81 0 81

Vegetatae muestion 9 J4 40 0 34

Meat m9mt,oo 10 10 10

1 ott 24 la 32 14

N.w st e eu teoi c m lohd at no 0 013 0 34 0% 25

p, .v aroy md E = tee ial f r om i lowl 0 22 0 22 0 22

a os imo. o 4 6 m f . t.., nai f r om 9,0o 4 0 24 0 24 0 24

4 4 0 mded south Veget..ide nn u" .o 0 094 11 0 094

Meat mynt.oo 10 10 10

T<tM 16 12 21 25

tkar est =,t. otal l ohd a t u m 0 13 3$ 41 18

e es de,4 c. I96m I = reroal Mm i tout 0 20 0 20 0 20

(12 m4d .me th I a ter od 'I om 4'oumi 32 32 32

W- Jetatde myntm 13 15 13Meat er9,t.o i 10 10 10

T ov al L8 32 98 78

0.mmmot, of inhd ar m 0023 0 60 0 00 20

W hite M..a 8 0 k m f = ternd timn e I.x11 0 19 0.19 0 19

(5 0 mded vio thant E = temM f rom gromwt 0 16 0 46 0 4G

T otal 0 37 13 1.3 20

C.t v of B: nod nq lohd tm 0 00/4 02 0 24 81

9 6 k m W 0 mded nov th nor thent F nlm mal from thul 0 000 0 09 0 09E ate,ne tiom 9,ourd 0 13 0 13 0 13

T otal 0 23 0 42 0 46 81

. .- _ -- - . - - - - - - - - - --

an.ws tc> the tw oot h.M epithchum resu't from the mhMat on of the shor t hvett d.sughters of Rn 222

4./.4 Radiation dose cocinitments to_ populations

lhe annual doses to the population estimated to exist within 80 km (50 miles) of the site inthe year 2000 are presented in Table 4.7 along with estimated annual doses to the same populationfrom natural background radiation sources. Population dose comitments resulting from theoperation of the White Mesa uranium mill represent less than 1% of the doses from naturalbackground sources.

' '

. _ _ . _ _ _

4-11

Table 4.7. Annual population done commitmentswithin 80 km (s0 males)

Populaton dows.

Organ man tems! year *

Plant etfluents Na' ural bu k ground *

Total twxty 3.4 7 500Bor'e 64 7.500Lung 71 7.500Bron(heat epithehum 132 23.000

8 Bawd on a prorated year 2000 population of 46.500.b The estimated natural harkground dose rate to the whole txxty es

161 mah ems per year. The bronc.hial epithehum dose from naturallyorrurrmy Rn 222 es assumed to be 500 melloems per year (Sat. 2 tot

4.7.5 Evaluation of radiological impacts on the public,

All radiation doses calculated to result to the surrounding population from uranium millingoperations at the White Mesa site are small fractions of those arising from naturally occurringbackground radiation (see Table 4.7). They are also small when compared to the averagemedical and dental x-ray exposures currently being received by the public for diagnosticpurposes.

Calculated annual individual dose commitments are only small fractions of present NRC limitsfor radiation exposure in unrestricted areas, as specified in 10 CFR Part 20. " Standards forProtection Against Radiation." Dose commitments to actual receptors are also well belowlimits specified in the EPA's " Radiation Protection Standards for Normal Operations of theUranium fuel Cycle" (40 CFR Part 190), which is to become ef fective for uranium millingcperations in December 1930. Table 4.8 provides a comparison of maximum calculated annualdose cocnitments with the radiation exposure limits of 10 CFR Part 20 and 40 CFR Part 190.

As indicated in Table 4.8, radiation dose cormitments to the bone of an individual living atthe nearest potential residence could exced the 25-millirem per yeae EPA limit by about MThe staf f has also determined that bone doses from the ingestion of meat fr&t animals grazedto the south of the present site would be in excess of 40 CFR Part 190 limits; however, theapplicant is currently negotiating to obtain this land and would be able to restrict access bygrazing cattle." Meat and/or vegetable ingestion doses could exceed 40 CFR Part 190 limitsat locations to the east if dusting of tailings sands is not controlled adequately. Therefore,the staff would require the applicant to

1. implement the environmental monitoring program outlined in Table 6.2;

2. perform and document an annual land use survey to determine changes in land use (e.g., forgrazing, residence, and well locations); and

3. implement an interim stabilization program for all exposed tailings areas to minimize theblowing of tailings. The program would include a weekly, documented inspection to assessthe effectiveness of the control methods being used.

4.7.6 Occupational Dose

Uranium mills are designed and built to minimize exposure of both the mill workers and thegeneral public to radiation. Occupational exposures for workers are required to be monitoredand kept below NRC limits. In addition, protection measures to reduce occupational exposuresare periodically reviewed and revised in accordance with the requirement to make such exposuresas low as is reasonably achievable.

Special studies 10 at selected mills have shown that the exposures of mill workers to airborneradioactivity are nomally below 25% of the maximum pemissible concentrations given inAppendix B of 10 CFR Part 20 and that external exposures are normally less than 25% of10 CFR Part 20 limits.16.17 A recent reviewie of mill exposure data by the NRC staff hasindicated that only a few uranium mill employees may have exceeded, over a one-year period,15 to 20% of the pemissible exposure to are dust, 25i, of the pemissible exposure toyellow cake, or 101 of the pemissible exposure to radon concentrations. Except for a fewindividuals, the combined exposure of an average worker to these radioactive components overa one-year period probably does not exceed 257, of the total permissible exposure.

4-12

Table 4 8. Comparison of annual dow commitments to mdsvidualswith appbcable radsation protection standards

fitsma ted Apphcat>le Frarsongdow, rne em ', r I mit, mrem /yr of Irmit

_ _ _ _ _ . _ ____

herest at rual resr&nce,4 5 km (2 8 m&st north northeast

Prewnt NRC regulation ( to CF R Part 20)

Total t=xty 24 50) OMSBone 16 3000 o 005Lurig 32 1500 o002H e onr haal epithebum o o0015 WL* o033%L o 005

hFuture EPA standard (40 CF H Part 190t

Total tafy 14 25 0 06Hone 15 25 o6Long 22 25 o 09Brorx hial epithel um 19 c

Nearest porentral resr&nce,1.9 km (l 2 miles} north

Present NRC regulation (10 CFR Part 20)

Total tuff 58 boo oofBone 32 3000 0ofLorsq 98 1500 o 001Broewhial epithehum o ooo36 WL o o33 WL 0 01

Future EPA standard (40 CF R Part 190)^

Total t=#f y 25 25 oIH one 29 25 12Lung 65 25 o3B om h.al epithchum 78 c

* Ret,ation stamteds for cupomte to Rn 222 and its short hvm1 dasghtersare em pressed in terms of wor king level (WL) carg entrations One WL es theamount of any conitsination of short hved radio <sctive daughters of Rn 222 in Ihter of air that wd4 releaw 13 X lo' P&V of alpha energy dunnq their decay toPt> 210

bbys n&ted for evaluation of Cornpliance with 40 CF H Pas t 190 areless than total dows twcmw dose uintributi<>ns from Rn 222 released from thesste, and any rad: oat five daughters that grow in from releawd Rn 222 have trenehminated Limits in 40 CF R Por t 190 do not apply to Ho 222 or its radios tivedaughters

'Not bmeted

4.7.7 Radiological impact on biota other than man

Although no guidelines concerning acceptable limits of radiation exposure have been establishedfor the protection of species other than man, it is generally agreed that the limits for humansare also conservative for those species.39-26 Doses from gaseous ef fluents to terrestrial biota(such as birds and mannals) are quite similar to those calculated for man and arise from the samedispersion pathways and considerations. Because the effluents of the mill will be monitored andmaintained within safe radiological protection limits for man, no adverse radiological impact isexpected for resident animals.

4.8 SOCI0 ECONOMIC IMPACTS

4.8.1 Demography and settlement pattern

4.8.1.1 Population increase from direct employment

A peak employment of 250 construction workers will be reached in August 1979 and maintained forthree months. Over a 12-month period, there will be an average of 175 employees. Mill opera-tions are expected to employ 85 workers (Table 4.9). If 60% of the construction workers re-locate from outside the project area.27 an average of 105 workers and a peak of 150 workers willmove into the region. If construction workers are accompanied by 0.9 nonworking dependents.28the population increase attributable to construction will be as shown in Table 4.10.

a-13

Table 4.9. Employment, White Mese Uransum Propct Table 4.10. Popuiation influm associated with

the White Mesa Uranium ProtectConstruction

Oper ations Con s truc t + on

Aver age Peak Operations

A ver age Peak

Derect employmentDirect employment

Ca'a''ed stof f 25* * h mm mnm m 1% 57*Corntruct:on workeri i75 2<,o Nnneorkmg dependents * 95 135 120

H ** b er s 85" Total d. rec t 200 285 177bTotal da ett 175 250 11o tadirect employment

truferect employment in movmg workers 47 47 432-587Nonwor k ing dependen ts' 99 99 907-1233

Yaned sta f 26r 8

Total ind a ect 146 146 1339-18209 220 -2W Total in movirig wor kers 152 197 UT 6C

NY'n9 staton 5* T otal influ n 346 431 1517-1997Ser vice (nonbasici 100 100 578 -626*

Total mdera t 100 100 829 -90/* * FuH capacity.Total employment 275 350 939 -1017 *To firx1 the total number of nonwork ang dependents, mult. ply the

number of ennstruction workers arwi operations personnel by 0.9 and* Reptesents ini reases over corrent amployment. 2.1 respectrvely.

F ull capac 't y c ro f,rwi the torG numb-r of nonworking deperwients, multiply theSources E R, p. 413. Energy Fuels Nuclear, Schedule of number of workers )y 2.1.

Pro /ected Mancome Serprements; Murd r1 Vaclette, Vice Sources E R, > 413. Energy Fuels Nuclear, ScherA;/e of Pro /ectedPres. dent for Operatws. Energy Fuels . mclear, Inc. personal Afsnponer Reqc,ements; Murit D. Vincele tte. Vice President forcommunicatron with Martm Schweif ter. Ook R.dge National Operations. Energy Fuels Nuclear, Inc., personal communication withLaboratory, July 12,1978, and August 15.1978. and E r'k J. Ma,tm Schweitier. Oak Ridge National Laboratory, July 12,19 78, andStench em and James E. Metiger. A framcaork for Pro /ecting Enk J. Stenehjem and James E. Metzger, A framee *r4 for Pro /ect,ngi

Employment and Poptdstion Changes Accompanying ErnergY Employment and Pbpulation Obanges Accompane Energy Develop-Development, Argonne Natwal Labor ator y. Argonne, Ill.. ment, Arganne National Laboratory, Argonne, lH., ;4ugust 1976. and1976- Mountarn West Research. Inc., Cons'ruction Worker Profde. Old West

Regional Commimon, December 1975.

Juring operations, 75% of the jobs available could be filled from the " local" labor pool. Up to30% of these workers may relocate closer to their new place of employment (Vice-President forJperations, Energy Fuels Nuclear, Inc. , personal communication, July 12,1978). In San JuanCounty, there are 2.1 nonworking dependents for every worker.P If this relationship holds forrelocations, the population may grow by 177 individuals.

4.8.1.2 Population increase from indirect employment

Indirect employment is the total of new jobs created in industries that supply factors ofproduction and that produce the goods and services demanded by project workers.28 Between0.3 and 0.9 indirect employees are generally needed for each construction worker during theconstruction phase of an energy project.29 Because there is nonnally a lag between the crea-tion of direct jobs and the indirect jobs they induce, it is likely that during the relativelyshort construction period in question indirect employment will stay at the low end of the scaleand not rise above 100 (Table 4.9).

Because there are many clerical, sales, and service workers seeking employment in the Blandingarea (Sect. 2.4.2.2), many of the indirect jobs created by mill construction may be filled fromthe local area. At most, the same proportion of workers will move in as is expected in thecase of mill operators (47 employees or less). Including nonworking dependents, 146 personswill move into the area (Table 4.10).

During mill op: ration, the proportion of indirect to direct employment will increase. Tooperate at capacity, the White Mesa uranium mill requires 1800 MT (2000 tons) of ore daily,which will be supplied by area mines. According to the applicant, the ore buying stations(one located at the propos ?d mill site anc the other in Hanksville) are currentl., buyingslightly over one-fourth of the ore the mill will consume at peak operations. This fractionmeans that only one-fourth of the miners that will eventually be needed to supply the millare already employed. An increase of 220 to 250 miners over current emoloyment levels is expected(Table 4.9). If between one-half and two-thirds of these future jobs are filled by personsmoving into the area, then about 110 to 165 miners will migrate in for a total population gainof 340 to 510, based on 2.1 nonworking dependents for every worker.

. . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _

A-\d

Currently, the Energ/ Fuels ore buying stations employ ten people. Five additional jobs at theBlanding station when mill operations start will rean an increase of five in area population.The 21 workers employed by Energy Fuels in ore exploration is not expected to change.

In San Juin County's economy, there are 1.6 nonbasic jobs for each basic job. The b3 sic sectorbrings in revenues f rom outside the imnediate area. The nonbasic sector provides goods andservices in response to local demand. Because the White Mesa project is expected to add 361 to331 new basic jobs to the area economy, it can be predicted that 578 to 626 new jobs will becreated in the nonbasic sector. If the proportion of in-migrants taking nonbasic jobs is appromi-mately the same as descrit'ed earlier, roughly 309 to 400 jobs in the nonbasic sector will beta6en by persons moving into the area, causing a pooulation increase of 930 to 1240.

4.8.1.3 To_tal_pppulation increase

About 120 hourly workers and staff will be involved in mill operations hearly 60 of theseemployees should be now to the area. Indirect jobs stimulated by the mill are expected to be inthe range of 830 to 910. The total population increase would range from approxinately 1500 to2000 (Table 4.10).

4.8.1.4 Distribution of new residents

The 431 new residents expected as a result of construction of the White Mesa Uranium Projectrepresents 3.3% of the San Juan County population. Their settlement pattern will be determinedby a number of factors including the availability of housing, public services, and arenities inthe surrounding communities and the proximity of those communities to the nill site. Blanding,Monticello, and Bluff are all within 48 km (30 miles) of the proposed mill and are capable ofabsorbing the projected population growth.

Because it is closest to the site, Blanding is likely to experience more in-migration than theother two communities.

The population influx during the operations period will be much grea'er than that associated withconstruction. The 1500-2000 new residents expected represents 11.5 to 15.4r of San Juan County'scurrent population.

The majority of mill-related personnel are espected to reside in the three above-named communi-ties; however, since the mining operations selling ore to the applicant are geographicallydispersed, sone in-migrating miners will locate in the outlying rural areas.

4.8.2 Social orga_nization

Studies of other areas impacted by energy projects indicate that rapid PCpulation growth can leadto inadequacies in the provision of housing and essential public services, such as water andsemage treatment, education, and health care. An annual growth rate of 151 is of ten cited asthe point where these problems become severe.l? Assuming that Blanding gets 70t of the popula-tion growth induced by the White Mesa uranium mill, Monticello gets 25:, and Bluff receives 51,none of these connunities will emperience even a 101 population increase in the one-yearconstruction period. However, during the three-year period from early 1980, when mill operationsare scheduled to begin, through the end of 1982, when most of the direct and indirect populationincreases should have occurred, the number of in-migrants will be much gr ater (Table 4.11). If

the total population influx reaches 2000, Blanding's rate of growth will average nearly 151annually over the three years in question. While Monticello and Bluff will not grow at thisrate, their increases will be substantial (see Sect. 2.4.l.2).

Balanced against this rapid growth are plans for providing additional housing and public servicesin the impacted communities. Action from both the public and private sector is anticipated,which will help reduce the adverse effects that can result from unmanaged growth (Sects. 4.8.2.1and 4.8.2.2).

4. 8. 2.1 Housing

During the construction period,197 workers are expected to relocate in the project area. It islikely that a number of these workers will share accommodations; therefore, between 145 and 197new housing units will be demanded during this time.

_ . . . . . . . _ _ . . . . . _ _ _ . . _ _---

... ._. _ _. _ _

4-15

Table 4.11. M.Il induced population .nflum for the communities of Blanding. Monticello,and Bluff, suummg a 70 25 5% spiet of the m movmg population

B l ae w f .ng Monte ello Bluff

Population in 197 7 3075 2208 280Peak r onitiuc tion periot inf N=* 302 108 22

Peak constr urt ron lee rtal infla s 98% 49% 7. 7%

as a percentage of 1977 populationOsmtions par eof intN=8 1050-1400 315-500 75 -100Operations per. ext infNa as 34.1-455% 17.o--22 6% 26 8 -35 M

a percentage of 19 77 population

* Peak construtt:on p-r eorf iriflum is projectest to be 431." Operations perunf influu is isop c ted to te approvimately 1500-2000

In the operations period. 439 to 644 new jobs are expected to be filled by in-migrants. Becausethese workers are much more likely to become permanent members of the comunity and to relocatewith their families, it will be assumed that one housing unit is required for each of them.

Table 4.11 projects the future growth of each of these co runities using previous assumptions( Sec t. 4.8.2) . If this distribution is used as a guide, roughly 100 to 140 housing units will beneeded in Blanding. 35 to 50 in Monticello, and 7 to 10 in Bluff during the construction period.During operations. Blanding will need 340 to 450 units, Monticello 120 to 160, and Bluf f 25 to 30(Table 4.12). Although no new workers are anticipated at the Hanksville ore buying station,mining activity in the area may create some demand for additional housing in the town ofHanksville. Under current conditions this would not be easily acconnodated although futureimprovements in the local water system (ER, p. 2-74) may make residential expansion possible.

Blanding

In August 1978, plans for a ll7-space mobile home park, scheduled to be ready for occupancy byFebruary 1979 were approved in a newly annexed portion of the city. At the sane time, a 242-unit subdivision was approved in another newly annexed section; construction is scheduled tobegin in January 1979.

Table 4.12. Housmo demand and supply m Blandmg, Mont* cello, and Bluff caused by the White Mesa Uranium Project

Constructson peracef Operations periorf

Supply Supply #City Demarxf* Demar=f*

E xist.ng* In process PossMe Total E s istirwj* In proceu Poss ble l otal

Bfamtng 100 -140 25 149 174 340-450 25 391 200 616Montitelio 35-40 35 23 58 120-160 35 23 200 258Bluf f 7-Io 20 20 25-30 20 o -70 20-90

Tot al 142-200 80 172 252 485-640 80 414 400 -470 844 -964

* Assumes a 70 25 5% split of the in moving population between Blanding. Monticello, and 8'uff." As of Aupst 1,1978.'Operat.oni perend supply udales those unets drveloped dur-,g the construction period.Sourcer E R. pp. 4-18 and 2 56, and Phii.p D. Taylor, President. Taylor & Associates, August 17,1978. Terry Palmer,

Palmer Builders. July 13, 1978, Richard Terry, Monticello City Manager, August 4,1978, private communications withMartin Schweitrer. Oak Ridge National Latw>ratory.

- - ~

_ . . .

9

,1- U

The 117 nobile home spaces, corbined with 25 existing spa w s in Blanding (ER, p. 4-18), aresuf ficient to satisfy the maximum demand projected for the construction period. In addition, a32-unit aprtment complex is now in the financing stages and local builders estiN te that 50 to60 new single-f amily houses could be constructed annually for at least the next three years onthe 200 vacant lots estimated to te available within the city limits (Palner Builders representa-tive, personal conrunication, July 13, 1978). The total number of potential additional housingunits is around fs00, nearly enough to absorb all rill-related growth. Counting only those unitsi sw existing or having city approvJl, the number is stiti nearly 400, nid-way between the highand low projections of Blanding's share of expected growth (Table 4.12).

Mo n_t i c e l l_o_

There are 15 vacancies in a local mobile home park (ER, p. 4-18), and a 23-unit apartn:entbuilding is being constructed. In addition to these 58 units (more than the 35-50 needed duringconstruction), 200 single f amily homes are espected to be built by 1981 (Monticello City Manager,personal communication, July 20,1978). This quantity will be more than enough to accomodateMonticello's expected share of mill-induced growth during the operations period and indicatesthat this city has the potential of absorbing additional growth (Table 4.12).

B l_o f_f

The 20 mobile home park spaces now available in Bluff (ER, p. 4-18) can accorrodate twice theprojected growth for the construction period and two-thirds of that expected during operations.Because the town also has 70 empty lots (ER, p. 2-56) suitable for developnent, it is possiblethat more growth than was postulated may occur here (Table 4.12).

4.8.2.2 Public services

Blanding

* Population increases should not strain the cxisting electricity distribution or solid wastedisposal systems Streets and recreation facilities are also adequate. Water and sewage systemsare adequ3te for tne 300 new resteents expected during the construction period (Blanding CityManager, personal communication, June 21, 1978), but they are not suf ficient for the mill-inducednewcomer s However, expansions in both water and sewer facilities, which are planned forcompletion by 1931, should be adequate to provide acceptable services to these in-migrants.

Additional public safety and health care services are likely to be necessitated by the operationsperiod population influx. Blanding has plans to add a new full-time rember to the police forcein fiscal year 1979 ([R, p. 2-47).

Approximately 120 new school age children are expected during the construction period.''i ll

During the operations period 384 to 504 new students will be entering Blanding's schools.'t inthe fall of 1978, a new high school in southeastern San Juan County will relieve current over-crowding in San Juan High School and leave it approximately 100 students below capacity. Theopening of a second new high school in fall 1979 in southwestern San Juan County will leaveroughly 300 vacancies in San Juan High School. Blanding's two elementary schools are currently120 students below capacity; therefore, the ir' of additional students during the constructionperiod snould not present a problem. However, the influx of 200 to 300 new elementary studentsdurinq the operations period will necessitate operating at 80 to 180 students over capacity. Theschool district is prepared to provide new facilities as the need arises (San Juan County SchoolDistrict, personal communication, August 18, 1978).

Mon t i c el_lo_

Existing solid waste disposal and recreation f acilities appear adequate to accorriodate theprojected population influx, as does the local system of streets. Improvements in public safetyand health care facilities are likely to be required. To supply future needs, the comunity iscurrently attempting to expand the city-run electricity transmission system.

The existing sewage treatment plant is currently operating at its design capacity; the growthassociated with mill construction and operations would cause overloading. Improvements are beingplanned to allow service for 3000 residents, but completion is not anticipated until at leastmid-1980. The city's share of the associated expenses will amount to roughly one-quarter million

. _ .

_

4-17

dollars and is likely to be financed through general obligation bonds. The remainder of therequired funds will come from the Federal government. Monticello's water supply system 1scurrently operating near capacity. However, improvements to the existing system are scheduled tobe completed by August 1979. Untti that time, lack of water is a limitation to growth. After-ward, the system will be able to accomodate nearly 800 new people. The city's e. hare of projectexpenditures will be approximately $600,000, financed by general obligation and revenue bonds(Monticello City Manager, personal comunication, July 11,197d).

Because both the elementary and the high school are operating at approximately two-thirdscapacity, with room for over 300 students between them, the addition of 140 to 180 new studentsduring the operations period should not present a problem.31

Bluff

Most existing public services in the town of Bluff are currently adequate to handle the limitedgrowth anticipated. The local water system is capable of accomodating a 791 increase in usage.Sewage disposal is currently handled by individual septic tanks. Public safety, recreation, andhealth f acilities may all require incremental improvements to keep up with rising population.Educational facilities are also more than adequate for the expected in-migration. Growth beyondthat shown in Table 4.11, however, may strain existing public services and call for improvementsnot considered here.

4.8.2.3 Culture

Nearly 45% of San Juan County residents are native Americans (predominantly Navajo), andanother 35t are memoers of the Mormon Church.32 Changes in the relative numbers of these twogroups could alter the social climate in the area of the proposed mill,

in addition to potentially changing the racial and religious composition of the community, asubstantial population influx could also create tensions between established "old-timers" and" newcomers." As area population grows, long-time residents may feel a loss of intimacy, andvalue conflicts may arise between those who favor a more " urban" lifestyle and those who wish topreserve a small town atmosphere.'3 However, because the greatest growth will occur during theoperations period, when in-migrants are much more likely to settle permanently than duringconstruction, it is expected that eventually a mutual accommodation of "old" and "new" valueswill occur.

4.8.3 Political organization

Changes in the political as well as the cultural characteristics of an area frequently accompanyrapid growth. Expansion and "professionalization" of local government of ten occur in response tothe changing size and characteristics of the population. This trend is evident in the area ofthe proposed White Mesa mill where the city of Blanding has recently hired a full-time cityengineer in response to the accelerating growth rate (Blanding City Manager, personal corxnuni-cation, August 14,1978), and Monticello anticipates the eventual need for more public employeesto handle future in-migration (Monticello City Manager, personal communication, July 11,1978).

The local power structure can also be altered by the growth associated with a project such as theWhite fiesa Uranium tiill. Political control may pass from the hands of established residents tothose of newcomers associated directly and indirectly with mill operations.33 As in the culturalarena, a balance is likely to be reached over time between divergent political interests.

4.8.4 Economic organization

4.8.4.1 Employment

Peak employment during the construction of the White Mesa mill is expected to be about 350; ofthese workers, approximately 150 are expected to come from the immediate area. During opera-tions, between 939 and 1017 new jobs are expected to be created directly and indirectly by themill. Roughly 300 to 500 of these jobs should be filled by area residents. At 8.1%, the

L13

unemployment rate in Sar luan County is significantly hiqher than the state average of 5.3(Sect. 2.4.2.2), and i. is highly probable that mill-induced erployment will result in a loweringof this figure.

4.8.4.2 Income

Of the additional 350 needed during construction, 250 will be construction workers whose wagesare substantially higher than the local mean. The remaining 100 will be employed in lower-payingjobs in the nonbasic sector. During operations, nearly 40% of all new workers will be highlypaid miners or mill personnel. According to the Utah State Departrent of Employment Security,the avera in this state is $1500 to $1833 and for a miller, $1000to $1500.go monthly salary for a miner1

These high-paying new jobs will elevate average per capita income in San Juan County and increasethe amount of money spent in the local connunities These increased expenditures may lead to theavailability of a wider range of goods and services. Competition from the new, high-wageindustries may also have the ef fect of raising salaries for other jobs. 4'

4.8.4.3 Tax revenues

During the construction period, San Juan Coun'y will continue to collect property taaes on theunimproved value of the White Mesa site (Sect. 2.4.2.2). Sales tax will also be paid nn mate-rials purchased in connection with this project. The comunities of Blanding, Monticello, andBluff each have the local option tan; outside of thcir boundaries the local tax goes to thecounty (Utah State Tax Comission representative, personal communication, August 23,1978).

The applicant estimates tha* of the $18 million to be spent on equipment and supplies duringconstruction, $432,000 in sales tax will accrue to the State, and $81,000 to the locales n whichpurchases are made. Of the local share, $13,500 will end up in the southeastern counties. Theore buying stations operated by Energy Fuels Nuclear, Inc., will also pay property taxes duringthis period.

Area mines selling ore to the applicant's ore buying stations will be subject to as many as fourdifferent taxes. Property tax will be levied at the normal county rate on twice the value ofaverage net proceeds plus the value of the land, if patented, and the personal property andim;irovements onsite (Utah State Tax Comission representative, personal connunication, July 14,1978). A lt mine occupation tax is levied on the gross value of all are sold, less a standardesemption. These revenues go to the State general fund. Sales tax will be paid on all purchases,and a State corporate franchise tax of 41 on net taxable income will supply monice to the State'sUniform School Fund.

Workers will be subject to Federal and State income taxes; the applicant estimates that roughly$1.3 million will go to the Federal and State governments fron construction worber incomes(ER, p. 4-23). Taxes on the salaries of nonbasic employees will contribute additional income taxrevenues. Workers will also pay sales tax on all purchases and ad valorem taxes on any propertyowned in the area. Assuming nationwide expenditure patterns, 38.3; of family income (ER,p. 5-31), $2.82 n.illion for construction workers alone (ER, p. 4-24), will be spent locally onpersonal consumption expenditures.it Sales tax on this will amount to $112,800 for the State and$21,150 for the jurisdictions in which the purchases are made.

During operations, the mill will pay property taxes of approximately $456,000 to San Juan County(ER, p. 5-28). Two-thirds of this amount goes to the school district. Sales tax will be paid onmost equipment and materials purchased but not on the raw ore to be processed (Utah State TaxCommission representative, personal communication, August 23,1978). Finally, the Federal andState governments will levy corporate franchise and income taxes.

If mining activity increases in the area the tax base of San Juan and neighboring counties willincrease, as will the revenues received by the State. Corporate-owned property would be subjectto the State franchise and Federal income taxes. The ore buying stations and independently ownedmining operations would continue to pay taxes as outlined above.

San Juan County and the communities of Blanding, Monticello, and Bluff are also expected tobenefit from increased property taxes due to the construction of new comercial and residentialbuildings and rising property values. Sales tax will be paid on roughly $4.5 million in personalconsumption expenditures in the area.33 Around $180,000 will go into the State treasury and$35,000 will be returned to the county or municipality where purchases are made.

4 - 1 ')

During both construction and operations, the State of Utah receives a substantial portion of thetax revenues generated by the White Mesa mill and related activites. The State receives theentire mine occupation and corporate franchise taxes and splits personal income taxes with theFederal government. Sales tax revenues are split with local governments, with the majority ofthe funds being routed to the State govermment (Table 4.13).

Tatde 4.13. Tames related to the White Wsa Uraneum Prosect

Construction per ort Operat.ons per odTau

Entity tamed Recipient of tas E ntity tamed Recip,ent of tan

Pr ops %s Unempe owed Lo Juan County White Vesa San Juan County

mdl site M.lt

Ore buy.ng Ln Juan amt Ore buying Ln Juan and Wayne

stations Wayne counties stations count es

Uramum mines Ln Juan and neighbor ng Uranium mmes San Juan and neighboring

counties counties

Property owning Ln Juan County, Bland;ng, Propert / owning San Juan County,

wen k er s Mont<cedo, and Bluff war h er s Blanding, Montecello, amiBluff

SMes ta= M,il rnaterials Utah Lo Juan County, Md! supphes Utah, San Juan County,

Br mtmg, and Monticello Blamimg, and Mont<elloa

Mine suppl.es Utah, Ln Juan County, M ne suppi es Utah, San Juan County,

Blanding. and Montmello Blandmg, and MonticeltaWorker purchases Utah, Ln Juan County, Wnsker purch vs Utah, San Juan County,

B:4mbng, and Mont(elfo Blamt.ng, and MonteceHo

Mme onupation tax Uranium mines Utah Uramum mmes Utah

Corporate frarx tuse tan Some uramum Utah Some uran um Utah

mines mmes andWhite Mesa mill

Fersonat erwome tau All wor k ers Utah, Umted States All wor kers Utah, United States

Both San Juan County and its municipalities will receive property and sales tax revenues from themill and related activities (Table 4.13). Most purchases are likely to take place in Blandingand Monticello, which will receive the local option sales tax. During the operations period,these two comunities may share as much as $35,000 annually from personal expenditures, which isrelatively minor compared to the $456,000 in property taxes which San Juan County will receivefrom the mill itself. The ad valorem taxes paid to the county by area mines could also besubstantial when mining activity is at its peak. Increased property tax revenues will accrueto the cities of Blanding, Monticello, and Bluff from new houses and businesses, but these addedrevenues will be significantly less than the anounts received by San Juan County.

4.8.4.4 Public expenditures

Financing improvements in public services needed as a result of rapid population growth can placea strain on local governments. Estimates of the required capital itivestment range from $1000(ER, p. 5-27) to $5000 for each additional resident. " For the 1500 to 2000 in-movers expectedas a result of operating the White Mesa mill, this amount would be approximately $1.5 to$10 million. As much as anothe- $1000 per person should be expected for operating costs 3''

adding an extra $1.5 to $2 million annually to the expenditures of local governments in thevicinity of the proposed mill. The capital and operating expenses listed above would be sharedby San Juan County and the communities of Blanding, Monticello, and Bluff.

Blanding and Monticello are expected to need improvements in their water and sewage systems aswell as in their health and public safety services. Blanding will probably require additionaleducation facilities, and Monticello will need an expanded electricity distribution system. Themajority of the costs associated with these services will be borne by the impacted municipalitiesthemselves.

' 20-

Although the largest share of the new tax revenues generated by the White Wasa project willaccrue to San Juan County, the co-runities of Blanding, Hinticello, and Bluff will receive someof these monies, in addition, other sources are expected to provide funds for needed publicservice improvements. Capital outlays for water and sewage systen erpansion are expected toinclude Federal and State f unds (Sect. 4.8.2.2), and tap fees will aid in repaying local waterand sewer improvement bonds. ' It is the judgment of the staf f that, given all the revenuesources available, the impacted communities will be able to provide services for the expectedpopulation 1 ' flux without long-range fiscal dif ficulties.

4.8.5 Trarmpt,tation

Both heavy truck and automobile traffic will increase in the area as a result of the proposedWhite W sa Uranium Project; therefore, traffic congestion, road wear, road noise, and trafficaccidents will also increase.

During the peak construction period, 250 workers are expected to drive to and from the mill siteeach day. Because most workers are expected to live north of the site in the cities of Blandingand Monticello, traffic will increase substantially on U.S. Route 163. The 100 additionalnonbasic workers expected during this time will also add to traf fic on area roads, although alarge portion of these employees are likely to live and work in the same corrunity. Nonworktrips will also increase on area roads, as will traffic within the conmunities of Blanding,Munticello, and Bluff.

During the operations period, the number of automobile trips between Blanding and the nill sitewill decrease, but auto traf fic in the surrounding area will rise. About 85 hourly millemployees plus 20 salaried staf f and 10 buying station erployees will travel to the White Mesamill daily along U.S. Highway 163. In addition, approximately 220-250 new miners will beemployed in the area and their trips between home and wtrk will considerably increase traf ficvolumes. Finally, about 600 new workers in the nonbasic sector will add to local traffic, eventhoJgh many Wili reside in tneir community of empioyment.

Heavy truck traf fic will also increase substantially in the project area. During the operationsperiod, when area mining is at expected peak levels, approximately 53 round trips per day will bemade between area mines and the Blanding buying station. Another 17 round trips between othermines and the Hanksville station and an additional 15 round trips between the Hanksville andBlanding stations will occur each day (LR, p. 5-34).

The heaviest truck traffic will take place on U.S. Route 163 and Utah Route 95, but U.S.Route 666 and Utah routes 262, 276. 263, and 24 will also be af fected. In addition to thesepaved roads, secondary roads are als. expected to handle up to 151 of total truck traf fic (ER,p. 5-34).

4.8.6 Impact mitijation

Energy fuels Nuclear, Inc. , has expressed concern about maintaining a stable work force andhas instituted programs to mitigate potential negative impacts on the project area. The appli-cant has cooperated with a Denver-based developer to provide additional housing for expected in-migrants in Blanding. Preliminary plan approval was received in August 1978 for a 117-spacemobile home park and a 242-unit single-family subdivision (Sect. 4.8.2.1) on land that waspurchased by Energy Fuels Nuclear for resale to the developer (Vice-President for Operations.Energy fuels Nuc' ear, Inc. , personal communication, Jae 27,1978). These dwelling units willsatisfy a large portion of the total mill-induced housing need. Company benefits, such as anannual cash bonus and profit-sharing plan, encourage job stability.

Public action is also being planned to mitigate prospective social impacts at the area of theproposed mill. Section 4.8.2.2 details the steps being taken by local governments to provideadditional publiC services to meet expected population increases.

Additional actions can be taken to further mitigate potential mill-induced impacts. Hiringunemployed area residents can keep the total population influx down and simultaneously reducelocal unemployment. Negative impacts can be diminished by ensuring that planned improvements topublic services are made before anticipated growth occurs. Early solicitation of Federal andState aid and early issuance of local bonds can provide funds for needed expansions beforeexisting services become inadeo'. ate.

. - - - . . .-

4-21

The are trucks pa ning between the Hanksville and Blanding stations, and possibly adJitionalmill-boand truck s criqinating at area mines, will travel along Utah Highway 95, which alsoprovides access to tha Natural Bridgns National Monument. According to the Utah Departmentof Transpcrtation, this increas"d activity could af fect traf fic novewnt during the su riernonths, but the extent of the impact is not currently quantifiable. The arplicant will attemptto redate possible negative impacts on area traf fic flow by providing acceleration lanesand turnouts Wh.re the traffic will enter and exit the project site. "

Both San Juan County and its municipalities have the fiscal responsibility of providing neededservices for new recidents. Neither these costs nor the tax revenues generated by the White Mesamill and related activities, hnwever, are evenly distributed. The cor<nunities of Blanding andMonticello face substantial capital and operating costs for providing for new residents. Afraction of the additional taxes accruing to San Juan County and the State of Utah could bedistributed by reans of a revenue-sharinq arrangement based on the distribution of the costs ofnew required services.

Although it is certain that residential and corrtercial growth will occur in the corr' unities ofBlandinq, Mnnticello, and Bluff, the form of this growth is difficult to predict. Advance land-use planning should ensure that the spatial structure of eventual qrowth is cor'patible withcorriuni ty goals.

4.8.7 Cenclusions

Both positive and negative socioeconomic impacts are probable as a result of the proposed WhiteMesa Uranium Project. The reduced unemployment, higher per capita income, increased tax base,and qreater availability of goods and services, all of which are likely to accompany the mill andits related activities, could be considered benefits for the project area. On the negative side,public service expenditures will rise, existing cultural and political balances may be changed,and road traf fic and associated impacts will increase as a result of increased road use. Althoughmost project-related socioeconomic impacts can be mitigated, the distribution of impacts andresponsibility for mitigation of the impacts may not coincide. The importance of a coordinated,joint planning ef f ort by incoming industrial developers and local and state governments should beemphasized in order to mitigate some of the adverse impacts of the rapid population changeex pec ted in t he Blanding area. The staf f has concluded that the potential benefits of the pro-posed project outweigh the asscciated costs.

4-22.

REFERENCES FOR SECTION 4

1. U.S. Environmental Protection Agency, Depi ation cf Air Fallate Fmiaaien Fntcra, 2nded. , Of fice of Air Quality Planning and Standards, Research Triangle Park, N.C. ,1976.

2. U.S. Environmental Protection Agency, hji+. . h at - ;oaru s. P iseiena, uni ecntr; ,Of fice of Air Quality. Planning and Standards, Research Triang.e Park, N.C.,1973.

3. Dames and Moore. " Response to Corrents from the U.S. Nuclear Regulatory Commission.June 7,1978 White Mesa Uranium Project Environmental Report," Denver, June 28, 1978.

4. Dares and Moore, " Supplemental Report, Meteorology and Air Quality, Environmental Report,White Mesa Uranium Project, San Juan County, Utah, for Energy Fuels Nuclear, Inc.."Denver, Sept. 6,1978.

5. State tf Utah, Division of Health, Air conserv2 tic, Fqalationa, Salt Lake City, May 22,1977.

6. Fel. !*yist., June 19,1978.

7. U.S. Environmental Protection Agency, Ae e acwne of knvivenecuta! Aarearc cf Urni:c,m i v an.f Milling, Report EPA-600/7-76-036, Washington, D.C., 1976.

8. Dames and Moore " Responses to Coments Telecopied from NRC to Energy Fuels Nuclear,25 September 1978," Denver, 7_t. 4, 1978.

9. State of Utah, Division of Wildlife Resources, letter to Jim Chadwick, Dames and Moore,July 27,1977. ,

10. U.S. Environmental Protection Agency, Fff.vte cf '.cice en wil! life anl ether Anc.a?s,Report NTlD300.5, Office of Noise Abatement and Control, Washington, D.C. ,1971.

11. Energy fuels Nuclear, Inc., " Source Material License Application, White Mesa UraniumMill, Blanding, Utah," Energy Fuels Nuclear, Inc., Denver, Sept. 26, 1978.

12. " Endangered and Threatened Wildlife and Plants," Fed. F.giat. 41(117): 2d524-24572 (1976).

13. S. L. Welsh, N. D. Atwood, and J. L. Reveal, " Endangered Threatened. Extinct, Endemic,and Rare or Restricted Utah Vascular Plants," Cre21 B;ain nt. 35(4): 327-376 (1975).

14. " Endangered and Threatened Wildlife and Plants," Ful. F.>giet. 42(135): 36419-36431 (1977).

15. R. L. Linder and C. N. Hi11 man, hwelinja of the Ma9-Fxtc.1 Ferret ani Trairie.W)wr4ebp, certceer 4-e, 2s7s, Soutn Dakota State university, Brookings,1973.

16. B. R. Metzger, " Nuclear Regulatory Comission Occupational Exposure Experience at UraniumPl ants ," C;nfcrcee on ocupat wna; !!calth F.q cric*:x vith Uranitc , Report ERDA-93,Washington, D.C., 1975.

17. International Atomic Energy Agency, safety serics ?!o. 4J, M maa? cn F2.liatian 7afety inUnwire al Arkci Minea and Mills, IAEA, Vienna, 1976.

18. Presentation to the Environmental Subcomittee of the Advisory Subcommittee on ReactorSafeguards, Occupational Radiation Exposure Control at fuel Cycle Facilities, 26 January1978, by the Chief. Fuel Processing & Fabrication Branch, U.S. Nuclear RegulatoryComi s sion.

19. S. I. Auerbach, " Ecological Considerations in Siting Nuclear Plants. The Long-Term BlotaEf fects Problem," titel, saf.12: 25-35 (1971). I

20. hwe.fings of the D:pirp:runful Flatonitc, Srposi:cn, Report LA-4756, Los AlamosScientific Laboratory, Los Alamos, N. Mex. ,1971, and A Frvoec1 Interin stamlant forFlatanian, Report LA-5483-MS, Los Alamos Scientific Laboratory, Los Alamos, N. Mex. ,1974.,

21. Fn. xtak Radiolo.7Ln: Surwy, UJAEC Report NV0-140, Nevada Operations Office, Las Vegas,Nev. ,1973.

22. N. A. Frigerio, K. F. Eckennan, and R. S. Stowe, " Background Radiation as a Carcinogenic, Hazard," sal. Fes. 62: 599 (1975). .

4-23

23. A. H. Sparrow et al. , " Chromosomes and Cellular Radiosensitivity," :l. Fea. 32: 915(1967).

24, 711r >2nioity in the M:r N Fn>!rp m nt, Peport of tne Comittee on Oceanography, NationalAcademy of Sciences-National Research Council, Washington, D.C.,1971.

25. R. J. Garner, " Transfer of Radioactive Materials from the Terrestrial Environment toAnimals and Man," D: +4r;n. a ntr H 2: 337-385, 1971.

Elli!e A p2ti i rg.zn ia~s,26. S. E . Thompson, C wn trmn F2? tare :f Cl.cmis.1: E*r cr to > -

USAEC Peport UCRL-50564, rev.1, October 1972.

27. Mountain West Pesearch, Inc. , cctatru '* fon trNr Pref .ie, Old West Regional Comission,Decemtser 1975.

28. Erik J. Stenehjem and James E. Metzger, A Fenrxrk for hwcetina ITZeyment cn..f Pc"u?a-tien Onjes Anrg unging Enargy Dcuelorcnt, Argonne National Laboratory, Arconne. Ill . ,August 1976.

* l :;re * h frn D: rjy Pec|c a t s !kis fcr " tat > an.1 Lo al Asti:n, Department of Housing29. n i. .-

and Urban Development, Office of Community Planning and Development,1976.

30. John S. Gilmore and Mary K. Duf f, mm Town cimE vr:ay,ent A C2sv rt u la cf Fo "r;rie:N;ccen ve, ry:riuJ, Westview Press, Beulder, Colo.,1975.

31. 1 c%n t,, year uk, D 7 7, National Association of Counties and International City Manage-ment Association, Washington, D.C., 1977.

32. Energy fuels Nuclear, Inc. , " Responses to Coments on White Mesa Project DES," March 6,1979.

33. Keith D. Moore, Diane M. Hammond, and John S. Gilmore, " Socioeconomic Considerations "Chap. 5 in LHnistrztcr's Gui<la fue oitin)

ad G. ration cf[Urw un Minin) ed Mil:in) Prepared for Western Inter-Fr iUttca, Stone and Webster Engineering Corp., May 1978.state Energy Board under Contract No. 68-01-4490 to U.S. Environmental Protection Agency.]

34. Yelth D. Moore, Finin.'inj @ t iana f.e C.ms.it iec Ww Lar; Ercrgy Eco :cinnte, 1978.

35. cuain) E r jr z for Enargy Fue*e .a3:ew, Ins Plamiinj, L t v., Taylor & Associates,Denver, Colo., no date.

5. ENVIRONMENTAL EFFECTS OF ACCIDENTS

The occurrence of accid'nts related to operation of the White Mesa mill will be minimizedthrough the procer design, manufacture, and operation of the process components and througha quality assurance program designed to establish and maintain safe operations. In accordancewith che procedures set forth in the appropriate regulations, Energy Fuels Nuclear, Inc., hassubmitted application < :ontaining descriptions of the facility design, the organization ofthe operation, ar.. me quality assurance program. These documents, together with theEnvironmental Report and supplements, have been reviewed by various agencies to ensure thatthere is a basis for safe operations at the site. Moreover, those agencies will raintainsurveillance over the plant and its individual safety systems by conducting periodic inspectionsof the facility and its records and by requiring reports of effluent releases and deviationsfrom normal operations.

Despite the above precautions, accidents involving the release of radioactive materials orharmful chemicals have occurred in operations similar to those proposed by the applicant. Inthis assessment, therefore, accidents that might occur during milling operations have beenpostulated and their potential environmental impacts evaluated. Section 5.1 deals withpostulated accidents involving radioactive materials and Sect. 5.2 deals with those notinvolving radioactive materials. The probabilities of cccurrence and the nominal consequencesare assessed, using the best available estimates of probabilities and re'listic assumptionsregarding release and transport of radioactive materials. Where information adequate to arealistic evaluation was unavailable, conservative as>umptiers were used to compute environmental

Thus, the actual en dronmental impacts of the postulated accidents would be less,impac e

in sw.c cases, than the effectu predicted by this assessment.

Exposure pathways considered in estimating dose comitments resulting from accidental releaseswere inhalation and immersion in contaminated air. It was assumed that exposure through thein;estion and surface pathways could be controlled if necessary.

5.1 MILL ACCIDENTS INVOLVING RADIDACTIVIiY

The specific activities of the radioactive materials handled at the mill are exh dy low:=10-3 Ci/g for the ore and tailings and =10" Ci/g for the refined yellow cake products.* Thequantities of naterials handled, on the other hand, are relatively large: 773 metric tons(MT) of yellow cake per year, representing =472 Ci of radioactivity. To be of concern, the.;every low specific activities require the release of exceedingly large quantities of materials;drivin- forces for such releases will not exist at the proposed White Mesa mill.

Guidelines have not been published for the consideration of accidents at uranium mills; there-fore, the postulated plant accidents involving radioactivity are considered here in the follow-ing three categories:

1. trivial incidents (i.e., t Mse not resulting in a r %;se M the environment),

2. small releases to the environment (relative to , nl itlease from normal operation),and

3. large releases to the environment (rel.ti- .;al release from normal operatiuns).

sIn contrast to the relatively gh specific activities of a number of prominent radio-

nuclides (i.e., =10-1 Ci/g for plut' .1um-239 and =10-i Ci/q for cobalt-60).

5-1

5-2

Trivial incicents include spills, ruptures in tanks or plant piping containing solutions orslurries, and rupture of a ta11ir@ disposal system pipe in which the tailings slurry isre' eased into the tailings pond. Small releases include failure of the air cleaning systemserving th: concentrate drying and packaging area, a fire or explosion in the solvent extractioncircuit, and explosion in the yellow cake dryer. Large releases include a igjor tornado.w

For nost of the postulated cases resulting in a release to the environment, the analysis givesthe estimated naqqitude of tN release, the ccrresponding maximum individual dose at variousdistances f rom the mill, and the estirated annual likelihood of occurrence. The latter

estimates are based on a diversity of sources, including incidents on record, chemical industrystatistics, and failure prediction methodologies. Data and nodels for the t,ehavior of radiationin accident situations were taken from AIRD05-II corputer ccdel and from the Internationaltomission on Radiological Protection (ICRP); and were updated by dose conversion factorsbased on the lung model of the ICRP Task Group on Lung Dynamics.

Durira the three decades of nuclear facility operation, the f requency and severity of ac(| dentsT. ave been m rkedly lower than in related irdJstri31 operations. The esperience gained fromthe few accidents th3t have occurred has resulted in improved engineering safety features andoperating procedures, and the probability of the occurrence of similar accidents in the futureis very low. Based on analysis, it is believed that even if major accidents did occur therewould probably not tse a significant of fsite release of contamination and that radiologicalexposure; would be too scall to cause any observable effect on the environment or any deleter-ious ef fect on the health of the human population.

5.1.1 T r i v i a l_ _i _nc iden ti

The following accidents, due to human error or equipment failure, would not result in therelease of radioactive materials to the environnent.

5.1.1.1 Minor _ leakage of tank s or_pipi_ng

Uranium-bearing slurries and solutions will be contained in several tanks connrising theleach, washing, precipitation and filtration, and solvent extraction stages of the mill cir-cuit. Human error during the filling or emptying of tanks or the failures of valves or pipingin the circuit would result in spills that might involve the release of several hundred poundsof contcined uranium to the reon; however, the overflow will be collected in sumps designedfor this type of spill, and sump pumps will be used to return the naterials to the circuit.Therefore, a rupture in a process tank or a leaking pipe would not affect the environment.

5.1.1.2 Major pipe or tank rupture

All aill drainage, including that from chenical storage tanks, will flow into a catchmentbasin upstrean from the tailings impoundment site. The mill will deliver approximately75.3 M! (83.3 tons) of solids per hour and approximately 76.1 m' [75.95 MT (84.02 tons)] ofsolution per hour to the tailings cell. Should the rupture of a pipe in the tailings distribu-tion system occur, the liquid would flow into the catchment basin where it could be pumped tothe tailings cell. Chenicals could be recovered, transferred to the tailinos cell, nr neu-tralized in the catchnert basin. Residue from a slt-ry loss would be cleared up and the con-taminated soil removed to the tailing ratention area.

5.1.2 Small releases

The following accidents, due to human or equipment failure, would release small quantities ofradioactive materials to the environnent. The estimated releases, however, are expected to besmall in comparison with the annual release from normal operations.

5-3

5.1.2.1 Failure of the air cleaning system serving thegellow cake drying arca

Because of system designs, this type of accident is unlikely to occur or go undetected. Aloss of water pressure to the scrubber or the failure of the fan drive would sound an alarm. Inthe event of electrical or mechanical failure, however, it was estimated that approximately14.83 kg (27.97 lb) of U ,0.3 would be lost from the stack over an 8-hr shift. All of thisinsoluble uranium was assumed to be in the respirable size range'.

Because the meteorological data at the time of the postulated accident is unpredictable, itwas assumed that for this stack release the conservative meteorological conditions of 1 m/secwind speed and a Pasquill type-B stability would exist. It was also assumed that all thematerial was distributed over a single 22.5 sector. The maximum dose comitments to thenearest resident [4.8 km (3 miles) from the point of release] were as follows: total-body.0.0009 millirem; bone 0.026 millirem; long, 0.32 millirem; and kidney, 0.008 millirem. Themaximum dose comitments to the potenti>l nearest resident [1.6 km (1 mile) from point ofrelease] were as follows: total-body 0.009 millirem; bone, 0.25 millirem; lung, 3.0 millirems;and kidney, 0.072 millirem.

5.1.2.2 Fire in the solvent extraction circuit

The solvent extraction circuit will be located in a separate building that is isolated from otherarea 5 due to the large quantities of kerosene present. From chemical industry data, theprobability of a major fire per plant-year" is estimated to be 4 x 10-*- However, at least twomajor solvent extraction circuit fires are documented in the literature, one of which destroyedthe original solvent extraction circuit at one mill in 1968." There have been approximately540 plant-years of mill operation in the United States, equivalent to about 320 plant-yearsindling 390,000 metric tons of ore per year. Thus, judging from historical incidents, the

likelihood of a major solvent extraction fire at the proposed mill is assumed to fall in therange of 4 x 10" to 6 x 10-3 per year.

In the event of a major fire, it is conservatively assumed from previous estimates that1; of the maximum uranium inventory, or approximately 4.5 kg (10 lb), would be released intothe environment.'' It was assumed that the conservative meteorological conditions of 1 m/secwind speed and a Pasquill type-O stability would exist for the ground-level release. It wasalso assumed that all the material was distributed over a single 22.5 sector. The maximumdose comitments to the nearest resident [4.8 km (3 miles) from point of release] were total-body, 0.0'd4 millirem; bone, 0.01 millirem; lung, 0.122 millirem; and kidney, b.003 millirem.The maxir i dose comitments to the potential nearest resident [1.6 km (1 mile) from point ofrelease] re total-body, 0.005 millirem; bone, 0.15 millirem; lung, 1.8 millirem; and kidney,0.04 mil m.

5.1.3 Larae . 3ases

Incidents that mignt release large quantities of radioactive materials to the environment com-pared with annual releases from normal operations are Considered in this section. By virtue ofcomplex and highly variable dispersion characteristics, however, the individual impacts will notnecessarily be proportional to the total amount of radioactivity released to the environment.

5.1.3.1 Tornado

The probability of occurrence of a tornado in the 1 square in which the White Mesa mill islocated is negligible. Using closest available data, the probability is approximately 8 x 10-6per year.7 The area is categorized as region 3 in relative tornado intensity * [i.e., for a" typical" tornado, the wind speed is 335 km/hr (239 mph /hr) of which 305 km/hr (190 mph /hr) isrotational and 79 km/hr (49 mph /hr) is translational]. None of the mill structures are designedto withstand a tornado of this intensity.

The nature of the milling operation is such that little more could be done to secure the facilitywith advance warning than could be done without it. Accordingly, a "no-warning" tornado waspostulated. Moreover, because it is not possible to accurately predict the tctal amount ofmaterial dispersed by the tornado, a highly conservative approach was adopted. Because the

5-4

yellow cake product has the highest specific activity of any material handled at the mill and asmuch as 45 MT of product may be accumulated prior to shipment, it is assumed that the tornadolif ts 4550 kg (10,031 lb) of yellow cake.

A con w rvative nodel, which assumes that all of the yellow cake is in respirable form, was useddispersion analysis.' The model assumes that all of the material is entrained in thefor ''-

tr as the vortex passes ovtr the site. Upon reaching the site boundary, the vortexd- ites, leaving a volume source to be dispersed by the trailing winds of the storm. The

tal is assur.ed to exist as a volume source representative of the velocities of the tornado,ra'

and it disperses through an arc of 45' Due to the small particle sizes postulated, thesettling velocity is assumed to be negligible.

The model predicts a maximum exposure at a distance of approximately 4 km (2.5 miles) from themill, where the 50-year dose comnitnert to the lungs of an individual is estimated to beapproximately 1.1 x 10'' rem. The 50-year lung dose comitment as a function of distar ce isplotted in Fig. 5.1.

* grin' r :nn - rqmrr-[[">

[,

t^Ipi

'bt

! fs ,

,c e

i*

i

,, , - A E2' i b'1' ' .C.o .o .o .g

c .s u u ... .,

Fig. 5.1. Tornado damage: 50-year dose commitment to lungs.

5.1.3.2 Tail _ings dam fai?"re

Because of the multiple cell design (Sect. 3.2.4.7; Fig. 3.4), the tailings retention embankmentdesign (in accordance with Regulatory Guide 3.11), the short period of cell use, and thelow head [<9 m (30 ft)], a large release of tailings and tailings fluid is not credible. Smallreleases would be retained by downstream catchment ponds.

5.2 NONRADIOLOGICAL ACCIDENTS

The potential for environmental effects from accidents involving nonradioactive materials atthe White Mesa mili is small. Failure of a boiler supplying process steam could releaselow-pressure steam .0 the room, possibly causing minor injuries to workers, but would notinvolve the release of chemicals or radioactive materials to the environment. Forced-airventilation systems are provided in several stages of the process to dilute the chemicalvapors enitted and protect the workers from the hazardous fumes. Failure of these ventilationsystems might result in the interim collection of these vapors in the building air. Such afailure might af fect individual plant employees but would have no persistent effect on theenvironment.

5-5

A number of chemical reagents used in the process will be stored in relatively large quantitieson the site. Minor leaks and spillage of reagents will be captured in sumps and returned tothe mill circuit. Major spills could flow across the mill site and enter the drainagediversion ditch protecting the tailings impoundment. The staff recommends either theconstruction of dikes around storage tanks or the construction of a catchment basin belowthe mill for any major spills. Spillage in the mill will be washed down and pumped backinto the mill circuit.

The only chemical that might seriously affect the environment is amonia. A break in theexternal piping of the anhydrous amonia tank would not result in a release, because, upon adrop in pressure, an excess flow valve would automatically close, thus preventing any loss.The line carrying amonia to the storage tank from the tank truck possibly could be ruptured,in which case the release rate would be limited to 100 g/sec of the vapor.10 Beyond a dis-tance of 10 km (6 miles), the resulting concentration would be below the 600 ug/m' short-termair qualit. _landard derived from State of Colorado regulations, the most restrictive currentregulati m.l! Beyond a distance of 700 m (2300 ft) from the mill, concentrations of ammoniafrom t'e accident would be less than the 40,000 ag/m needed to produce a detectable odor andwould not be noticeable by offsite residents; these concentrations would pose no health riskbecause they would be less than the 69,000-sq/mi limit for prolonged human exposure.''Thus, the released ammonia would not be noticed by offsite residents and would pose no healthrisk to the environment.

The solvent extraction and dryer units in the vanadium circuit will be similar to thecorresponding units in tne uranium circuit with respect to fire and explosion potential(Sect. 5.1). Vanadium pentoxide (V;0 ) and/or organic complexes of vanadium would be3

released as would very minor amounts of thorium-230 and uranium, which may also be presentin the crqanic solvent. Thorough washing of contaminated areas would minimize the riskto mill employees. The general public should receive no significant health effects fromaccidents in the vanadium circuit.

5.3 TRANSPORTATION ACCIDENTS

Transportation of materials to and from the mill can be broken down into three categories:(1) shipments of ore from the mine to the mill, (2) shipments of refined yellow cake from themill to the uranium hexafluoride conversion facility, and (3) shipments of process chemicalsfrom suppliers to the mill. An accident for each of these categories has been postulatedand analyzed. The results are given in the following discussion.

5.3.1 _ Shipments of yellow take

Refined yellow cake product is generally packaged in 55-gal,18-gage drums holding an averageof 364 kg (800 lb) and classified as Transport group III Type A packaging (49 CFR Parts 170-189and 10 CFR Part 71). It is shipped by truck an average of 2100 km (1300 miles) to a conversionplant, which transforms the yellow cake to uranium hexafluoride for the enrichment step of thelight-water-reactor fuel cycle. An average truck shipment contains approximately 45 drums,or 16 MT (17.5 tons), of yellow cake. Based upon the White Mesa mill capacity of 618,200 MT(680,000 tons) of ore annually and a yellow cake yield of 773 MT (850 tons), an average ofapproximately 48 such shipments are required annually.

From published accident statistics,1 bl* the probability of a truck accident is in the range of1.0 x 10" to 1.6 x 10-* per kilometer (1.6 x 10-' to 2.6 x 10-6 per mile). Truck accidentstatistics include three categories of traffic accidents: collision, noncollision, and otherevent. Collisions involve interactions of the transport vehicle with other objects, whethermoving vehicles or fixed objects. Noncollisions are accidents in which the transport vehicleleaves the transport path or deviates from normal operation in some way, such as by rollingover on its top or side. Accidents classified as other events include personal injuriessuffered on the vehicle, records of persons falling from or being thrown against a standingvehicle, cases of stolen vehicles, and fires occurring on a standing vehicle. The likelihood

. . . . _ _ _ . _ . . . _ . - . . . _ _ _ _ _ _ _ . _ _ _ .

5-6

of a truck shipment of yellow cake from the mill being involved in an accident of any typeduring a one-year period is approximately 0.13.

The ability of the naterials and structures in the shipping package to resist the combinedphysical forces arising f rom impact, puncture, crushing, vibration, and fire depends on theN gnitude of the forces. These magnitudes vary with the severity of the accident, as doesthe frequency with which they occur. A generalized evaluation of accident risks by NP.Cclassified accidents into eight categories, depending upon the combined stresses of impact,puncture, crushing, and fire.15 On the basis of this classification scheme, conditionalprobabilities (i.e., given an accident, the probabilities that the accident is of a certainmagnitude) of the occurrence of the eight accident severities were developed. Thesef ractional probabilities of occurrence for truck accidents are given in Column 2 of Table 5.1.Io assess the risk of a transportation accident, the fraction of radioactive material releasedin an accident of a given severity must be known. Two models are postulated for thisanalysis, and the fractional releases for each model are shown in Columns 3 and 4 of Table 5.1.Model I assumes complete loss of the drum contents; Model II, based upon actual tests, assumespartial loss of the drum contents. The packaging is assumed to be type A drums containinglow specific activity (LSA) radioactive materials. Considering the fractional occurrence andthe release fractions (loss) for Model I and Model II, the expected fractional release inany given accident is approximately 0.45 and 0.03 respectively.

Table 5.1. Fractional probabihties ofoccurrence and correspondmg package release

fractions for each of the velease models for LSAand type A contamers involved

in truck accidents__

Accident F r ac tiornal

seven t e occur.ence Mmk l i Mo+t il

categor y of acc+nt

1 0 55 0 011 0 36 10 0 01

111 0 07 10 0.1

IV 0 016 10 10V o002R 10 10VI 0 0011 10 10

VII 8 5E 5 to 10

Vlil 1 SE 5 to 10

S mice U.S Nuc! car Requ!a tor y Commiss,on, Gna! Envoronmental Statement on theTransportation of Radios tive Afstenats by Airs d Other Mo&/s. Report NUREG 0170 Off(e of Stamtsds De=Wopment. February 1977

(dr af d

Model I and Model Il estimate the quantity of yellow cake released to the atmosphere in theevent of a truck accident to be about 7400 kg (16,200 lb) and 500 kg (1100 lb) respectively.Post of the yellow cake released from the container would be deposited directly on the groundin the imnediate vicinity of the accident. Some fraction of the released material, however,would be dispersed to the atmosphere. Expressions for the dispersal of similar material tothe environment based on several years of actual laboratory and field measurements have beendeveloped.h The following empirical expression was derived for the dispersal of the materialto the environment via the air following an accident involving a release from the container:

J = 0.001 + (4.6 x 10")[1 - exp(-0.15e)]V 7".

_ _ . . . . . . . . . _

5-7

where

f = the fractional airborne release,

a = the wind speed at 15.2 m (50 ft) expressed in m/sec,

t = the duration of the release, in hours.

In this expression, the first term represents the initial " puff" immediately airborne whenthe container is in an accident. Assuming that the wind speed is 5 m/sec (10 mph) and that24 hr are available for the release, the environmental release fraction is estimated to be9 x 10- t If insoluble uranium (all particles of which are in the respirable size range)is assumed and a population density of 160 people per square mile (which is characteristic ofthe eastern United States) is supposed," the consequences of a truck accident involving ashipment of yellow cake from the mill would be a 50-year dose comitment* to the generalpopulation of appro timately 13 and 0.9 man-rems to the lungs for Models I and II respectively.

In a recent accident (September 1977), a comercial truck carrying 50 steel drums of uraniumconcentrate overtui s d and spilled an estimated 6800 kg (15,000 lb) of concentrate on theground and in the ti ck trailer. Approximately 3 hr after the accident, the material wascovered with plasti to prevent further release to the atmosphere. Using the above formulaand values of wird . peed for a fractional airborne release for this 3-hr duration of release,approximately 56 kg (123 lb) of U 03 would have been released to the atmosphere. The3

consequence of this accident would De a 50-year dose comitment to the general populationof 11 man-rems for a population density of 160 people per square mile. The consequence forthe accident area, where the population density is estimated to be 2.13 people per squaremile, would be a 50-year dose commitment of 0.146 man-rem, which can be compared to a 50-yearintegrated lung dose of 19 man-rems from the natural background.

The applicant will submit to the NRC an emergency-action plan for yellow cake transportationaccidents. This emergency-action plan is intended to ensure that personnel, equipment, andmaterials are available to contain and decontaminate the accident area.

5.3.2 Shipments of ore to the mill

Hanksville and Blanding are ore buying stations servicing small- and intermediate-sized ninesthroughout southeastern Utah and southwestern Colorado. Because of the small sizes of themines, shipments of ore will be sporadic; therefore, the average shipping distance for theore will vary throughout the life of the project. The applicant estimates the radii of theHanksville and Blanding buying station service areas to be 160 km (100 miles) and 201 km(125 miles) respectively. Ore collected at the Hanksville station will be shipped an additional193 km (120 miles) to the mill at Blanding. Based on projected capacities of the two orebuying stations, approximately 25t of the total ore requirements would be supplied by theHanksville station. On this basis the are will be shipped an average of 258 km (160 miles).This value is an upper limit because most of the mines will be well within the service areas.

To deliver 618,200 MT (680,000 tons) of ore in trucks with a 30-ton capacity would require22,670 trips per year, or a total of 5.84 x 106 vehicle-km (3.63 x 10" vehicle-miles). Forthe accident probability cited in the previous section,1.0 x 10" to 1.6 x 104 accidents perkilometer (1.6 x 10d to 2.6 x 104 per mile), accidents involving ore trucks would occur atthe rate of 7.6 per year. However, because of the low specific activity of the ore and theease with which the contaminant can be removed, the radiological impact is considered to beinsignificant.

5.3.3 Shipments of chemicals to the mill

Truck shipments of anhydrous anmonia to the mill, if involved in a severe accident, couldconceivably result in a significant environmental impact. Approximately 17 shipments ofanhydrous amonia will be made annually in 18 MT (20-ton) loads from a supplier locatedapproximately 320 km (200 miles) from the mill.

.

Doses integrated over a 50-year comitment following exposure.

5-8

The annual U.S. production of anhydrous annonia shipped in that form is approxicately6.9 x 10' MT (7 6 x 10'' tons) . About 26" of the shiprents are made by truck (the remainder byrail, pipeline, and barge). If the average truck shipment is 19 MT (21 tons), the approximately93.000 truck shipnents of anhydrous annonia are made annually. According to accident datacollected by the Department of Transportation, there are about 140 accidents per yearinvolving truck shipments of anhydrous ammonia. For an estinated average shipping distanceof 560 km (350 miles), the resulting accident frequency is roughly 2.7 x 10-0 per kilometer(4.3 x 10-' per mile) . Data from the Department of Transportation also reveal that arelease of ammonia [an average of 770 kg (1700 lb)]. occurred in approximately 80% of thereported incidents and that an injury to the general public occurred in roughly 15% of thereported incidents that involved a release (nost of the injuries were sustained by the driver).

Utilizing these data, the probability of an injury to the general public resulting'from anaverage shipment of anhydrous arronia is roughly 3 x 10 ' per kilometer (4.8 x 10- perr..le).

This estinate is probably too high for shipments near the White Mesa mill because of therelatively low population density. Nevertheless, if this estimate is used, the likelihood ofan injury to the general public resulting from shipmen".. of antonia to the mill is predicted tobe roughly 1.6 x 10- ' per year.

Sulfuric acid shipments to the White Mesa mill will anount to about eiqht truck loads per day.Tentative plans are to ship acid into Moab or Thompson, Utah, by rail; the acid will then beloaded into specifically designed tank trucks for transportation to the White Mesa mill. Moabis about 130 km (80 miles) from the site. Usinq statistical data from Sect. 5.3.2, less than0.1 accident per year should be observed. Because sulfuric acid is not volatile, the risk tothe general public is no areater than that from other collisions.

Amine shipments will be made by truck into the White Mesa mill. Only one truck load aboutevery 45 days will be required, and the risk of injury to the general public should be no greaterthan 8 x 10-" cer year. Transport of all such commodities will be in accordance with allapplicable State and federal rules and regulations.

. _ .

-

5-9

REFERENCES FOR SECTION 5

1. R. E. Moore, The AIRDCS-II Ccquier Code for Eatimting FaFation Dcae to Man fcrAivkrne Palionuclidaa in Areaa Surrmlinj vu: lear Fa: :itiec, Report ORNL-5245,Oak Ridge National Laboratory, Oak Ridge, Tenn. ,1977.

2. "Recomendations of the International Comission on Radiological Protection, Report ofCommittee II on Permissible Dose for Internal Radiation," Health rhys. 3: 1-380 (1960).

3. ICRP Task Group on Lung Dynamics, " Deposition and Retention Models for Internal Dosimetryof the Human Respiratory Tract," Ecalth rhys. 12: 181 (1966).

4. Directorate of Regulatory Standards, U.S. Atomic Energy Comission, Envimvental Suracyof the Urarii:c, fact cycle, Report WASH-1248, April 1974.

5. Batte11e Northwest Laboratories, Consilentions in the Acacarent of the Consequences ofEfftwnte fr m Mixe l C. cide Fuel F:Erication Plante, Report BNWL-1697, Richiand,Washington, June 1973.

6. Directorate of Licensing U.S. Atomic Energy Commission, Trg csel Final Envire mental::ta t men t, Liquid retal Fact Presler .ucactor Prajr r , Report WASH-1535, December 1974.

7. H. C. S. Thom, " Tornado Probabilities," "on. Wather Rer. 91: 730-737 (1963).

8. E. H. Markee, Jr. , and J. G. Beckerley, Techni nl Basis for Interim Rejicnal TornadoCriteria, Report WASH-1300, U.S. Atomic Energy Commission, May 1970.

9. F. C. Kornegay, Ed. , Condenced Pmeeedinja of the Spocium on the Disrcreion ofParticulate Yztter by : tatami Vartices, held at Argm.nc 72tional L:bamtory, Arjonne,Illiras, Aujuat 1J7e (in preparation).

10. U.S. Nuclear Regulatory Comission, Fir.al Environnenta! Statement Related to Oremtion of. av Cecok Procect, Docket No. 40-8452, June 1977.

11. Colorado Air Pollution Control Comission, " Regulation to Control the Emissions ofChemical Substances and Physical Agents," Regulation No. 8, effective fiay 1,1974.

12. F. A. Pa tty, in laatrial Hajiana and Toxicolojj, 2d ed. , rev. , vol . II, Texicology,David W. Fassett and Dan Irish, Eds.. Interscience, New York, 1963.

13. Directorate of Regulatory Standards, U.S. Atomic Energy Comission, Environ-ental Sarreyof Tmne_ vtation of Radioactive Materiala to and from |iuclear Plants, Report WASH-1238,December 1972.

14. Battelle Northwest Laboratories, An Assese-cnt of the Risk of Tr:nsportiny Plutoniumcr!Ja and Liciaid Plutoniw- //itrate by Tr ek, Report BNWL-1846. Richland, Washington,August 1975.

15. U.S. Nuclear Regulatory Comission, Final Enviremcntal Statement an Tmnaportation ofRadicactir > Materiala by Air and Other MaJes, Report NUREG-0170, February 1977 (draft).

16. U.S. Bureau of the Census, Statistical Abstract of the United States: 197C, 97th ed.,1976.

.

. _ . _ _ _ _

6. MONITORING PROGRAMS

6.1 AIR QUALITY

Particulate matter, measured by dustfall samplers, and sulfation rates, measured by leaddioxide plates, were monitored at four locations on the project site for one year beginning inMarch 1977. Beginning in October 1977, total suspended particulates were measured for fivemonths at one location by a high-volume air sampler. The ore buying station located on theproject site (Fig. 2.10) began operation in May 1977.

An estimate of 502 concentrations (ppm) was obtained by multiplying sulfation plate data(milligrams per 100 cm2 per day) by 0.03.2 In addition to the onsite monitoring, the UtahBureau of Air Quality operates a monitoring station for suspended particulates and sulfurdioxide approximately 106 km (66 miles) to the southwest, at Bull Frog Marina. The applicantwill be required to conduct a monitoring program to collect onsite meteorological data, e.g.,wind speed and direction at one hour intervals, the results of which will aid in the determina-tion of compliance with 40 CFR Part 190.

The applicant did not present an operational monitoring program for nonradiological airquality. Because no significant impacts to air quality due to operation of the facility areexpected (Sect. 4.1), the staff does not recommend an operational monitoring program for airquality.

6.2 LAND RESOURCES AND RECI.AMATION

6.2.1 Land Resources

6.2.1.1 Land

The applicant acquired land-use data from published reports (ER, Sect.13), discussions withpersonnel of various Federal, State, and local offices, and onsite visits. The staff wouldcondition the license to require the licensee to conduct and document a land use survey on 6nannual basis.

6.2.1.2 liistorical, Scenic and Archeological Resources

The existing conditics of the site was determined as described in Sect. 2.5.2. Additionalmonitoring, will be per formed as described in Sect. 4.2.2.

6.2.2 Reclamation

Reclamation plans are in accordance with the regulations of the Utah Division of 011, Gas andmining.1 2 The vegetation on reclaimed areas will be monitored and maintained until stand estab-lishment and perpetuation is assured.2 In accordance with the State of Utah Division of 011,Gas, and Mining (Reclamation Regulation, Rule M-10), the revegetation will be deemed accomplishedand successful wnen the species

1. have achieved a surface cover of at least 70% of the representative vegetative comunitiessurrounding the operation (vegetation cover levels shall be determined by the operatorusing professionally accepted inventory methods approved by the Division),

2. have survived for at least three growing seasons,

3. are evenly distributed, and

4. are not supported by irrigation or continuing soil amendments.3

In addition, the applicant states that aerial photographs will be taken every third year tomonitor the progress of reclamation efforts.2

6-1

. _ . .

6-2

The staf f feels that the applicant's revegetation procedures and monitoring programs areadequate to ensure successful reclamation. Suf ficient records must be maintained by theapplicant to furnish evidence of compliance with all monitoring. The applicant will file aperformance bond with the State of Utah to ensure performance of land reclamation."

6.3 WATER

6.3.1 Su_rf ace water

Guarterly monitoring of surface-water quality will continue +hroughout the life of the project.Sample locations are described in Table 2.21 and Fig. 2.5, and the chemical and physicalparacrters to be measured are given in Table 2.20. Because of the temporary nature of many ofthe watercourses in the site vicinity, it is recommended that the applicant take advantage ofseasonal rainfall and snowncit in scheduling the collection of water samples.

6.3.2 Groundwater

The applicant has supplied chemical constituent data for samples from each of two abandonedstock wells on the project site. Water from these wells (G6R and G7R on Fig. 2.5), completedin the Dakota Sandstone, is of poor quality. Total dissolved solids are in excess of 2000 ppm,which would have adverse effects on many crops. Total sulfate is in excess of 1300 ppm comparedwith an acceptable value of 250 ppm; dissolved iron is in excess of 3 ppn compared with anacceptable value of 0.05 ppm; and lead is in excess of 0.12 ppm compared with an acceptablevalue of 0.05 ppm.' Data from local springs indicate that the water is suitable for stock andwildlife use only.

Additional sampling in accordance with Table 6.1 will be required. During operation, the applicantwill be required to monitor the groundwater from wells installed and located as specified inthe Source Material License to detect potential groundwater contamination (as discussed inSect. 4.3.2.2) until reclamation is completed. The applicant is also required to submit a planto mitigate such contamination if observed.

6.4 SOILS

During September 1977, an existing soil survey of the site was field-verified by a retiredUSDA Soil Conservation Service scientist, and a soil scientist for the applicant's consultant(ER, Sect. 6.1.4.1). At least one soil profile for each rapping unit was located and sampled.Soil analyses for potential uses in reclaration operations included contents and characteristicssuch as texture, water-holding capacity, saturation percentage, pH, line percentage, gypsum,electrical conductivity, exchangeable sodium percentage, sodium adsorption ratio, organiccarbon, cation exchange capacity, boron, selenium and available phosphates, potassium, andnitrate / nitrogen (ER, Sect. 6.1.4.1).

6.5 BIOTA

6.5.1 Terrestrial

Plant connunities at the project site were mapped by aerial photographs and field verification(ER, Sect. 6.1.4.3). Vegetation on the site was surveyed during the spring and summer of 1977(rig. 6.1). Five 1.0-m2 quadrats were placed every 10 m along 100-m transects. The numberof transects varied depending upon the size and homogeneity of the community. The larger andvore diverse communities had the greatest number of transects. Species collected were ten-tatively identified in the field and later verified at the Rocky Mountain Herbarium of theUniversity of Wyaning. The density of each species was determined by counting the number ofindividual plants in each quadrat. The percentage of cover for each comnunity was estimatedvisually within each quadrat, and all quadrats were then sumned and divided by the totalnumber of quadrats to reach a mean percentage of cover for the entire community. Productionstudies were also conducted during the 1977 growing season (April through September) endexpressed as kilograms per hectare (pounds per acre). The number of 1.0-m2 samples taken ineach community on the site to measure production varied from 5 to 40, depending upon the sizeand homogeneity of the community.

-

.

Table 6.1. Preoperation.! mon'.oring program

TypeSample coliect on Sample measu ementr

of . . . _ . . - _ . _ . . _ . . __

sample Num ber L ocat.on Type and frequency Test frequency T v pe of measureme't- - - - - - - - - -

A:r

Pctic ulate 3 Locat.ons or,s te at or near site Cont nuc,us weekly Oosterly compos tes of samples Natur al uranrum. R4 226. Th 230boundar.es and Pti 210

Part.culate 1 Locat.ons of f s.te mclud:ng Cont >nuous, weekly Quarterly compos'tes of samples Natural urJaaum Ra 226 Th 23d.r'earest residences and Pb 210

Part.culate 1 Background locat on remote from Cont.nuous. weekly Quarterly compos.tes of samples Natural uranium. Ra 226. T h 230.

s te and Pb 210

Radon gas 5 At same locattons where par t culates Cont nuous (ane acek Each 48 hr sample R n-222

are sampied per month. same

period em.h month),samples collected for48 hr intervals

'A at er

~

3 Wells located around tailings C'ab. quarterly Ouarterry o,ssolved naturas ur anium. Ra 226.G oundwaterdTh-230. and chemicaisdisposal area (one downgradier:t

and two crossgradtenti deep) Sem.annuaH y DmM Pb M W Po N

1 Weus within 2 km of ta,i,ngs d:sposal Grab, quarterty Quarterty Total and disso!ved natura: urari.um. ces

Ra 226. Th 230 and chemtcais* O(from each welli areas (could be used for potableSemiannuaMy Total and d.ssolved Pt>210 andwater or errigation)

Po 2101 Well located up grad ent from d,sposal Grab quarterly Quarteily O ssolved and natural uranium. Ra 22ti.

area far tuckground Th 230. and chem,cals#

D.ssolved Ptr 210 and Po 210Semiannuallt

Surface water 1 Ons te or of fote streams (Westwater Grab. quarterly Quarterly Suspended and deolved natur41

(from each body Creek Core al Creek. Cottonwood uran.um. Ra 226. T h 230

of water) Wash, etC ) which may be potentiallycontaminated by direct surf ace dra.n- Grab semiannually Semiannually Suspended and dissolved

age or ta Angs impoundmrnt f a. lure Pt> 210 and Po 210

Vegetat.on (for age) 3 Grazing areas near the mill site in Grab. three t mes Three t mes Natural uranium. Ra 226. Th 230.

different sectors having the durmg grarng Pb 210. and Po 210

hegbest predicted particulate season

concentrations durmg millingoper att Ons

Food (crops. hvestoc k) 3 within 5 km of m.fi site Grab: three times One time Natural uran.um. Ra 226. Th 230.

(of each type) during harvest or Pt>210, and Po 210

slaughter

Fish Each isody of Collect +on of game fish (if any) Grab semiannually Two times Natural uranium. Ra 226. Th 230,

water from streams in the site environs Pt>210, and Po-210

which may be contaminated bysurface runof f or tail.ngs im-poundment failure

- . . . .

_ . _ . . . . . . .... . . .

Table 6.1. (contmuedt_. _ _ _ _ . _ _ . _ _ _ .- - _._ - _

Ty pe S, mole coi!,ction Sample meamrementof

Number Locat on Tvpe and frequency Test te equency Type of meas,,rernentsample

S.te survey

Gamma dose rate 80 150 m mter*als to a d. stance of Gamma dose rate. One t:me Pressurowd on. tat on chamber or1500 m in each of e ght d' rect ons once priw to orapedy cal.brated portabicfrom a po nt euwdistance between construct on survey mstiumeet

the millmg area and ta,imia pund

10 150 m mtervals in both hor zontal Gamma dose rate. One t me Pressered .oru tat'on cha vtserand vertical transverses across the once follow.ng or properly cahtwated r,ortatJemilling areas preparat.on of sevey mst'ument

m,ll.ng site

5 At same locat.ons as used fu col C amma dose rate. Q uar ter!y Pressortied toru rat'on chamber orlection of part<ulate samples oarteri, pr operly car brated portable

s rvey instrumentu

Surface soil 40 300 m intervals to a d stance of Grab. onc.e prior One 14me All samples for Ra ??6 10% of1500 m in each of e>ght d. rect ons to site construct,an samples for natura! uta uvmfrom a poent equidtstance from Th 230. and Pb 210m Il and ta, lings pond s,tes

6 300 m mter vals m both a horizontal Grab. once foHow ng One time All samples for Ra 226 one samplefor ennatu al uramum. Th 230. and Eand vertical transverse acrcas the sste preparat'on r

mill.ng area Pt> 210

5 At same locat:ons as used for col Grab. once pr.or to One tirr.e Natural uranium. Ra 226 Th 230.lect on of air particulate samples site construct.on and Pb 210

Subsurface so.1 profee 5 750 m meervais m each of four Grab once prior to One time AH samp:es for Ra 226 one set ofd rect.ons from a po.nt equi s<te construct'on samples for natural uransm T h 230.

distance from the mdl and ta+1.ny, and Pb 210

pond s:tes

1 At center of m.ll bu.ldiry area Grab. once foCowing One time Natural uran <um Ra 226.1h 230.s,te preparat on and Pb 210

Sed. ment 2 Upstream and downstream of waters Grab. once folto*ing Two t.mes Natu ar u an um. Ra 226. Th 230.rr

(from each streami that may receive surface water run- spring runoff and and Pb 210off from potentially contam nated once en late summerareas or that could be affected by follow;ng period ofta'hngs impoundrnent fa lure extended low flow

Radon 222 fluw 10 At center of m'll s:te and at 750 and Two. to three day Each sample Rn 222 flus1500 m m each of four d.rectrons period, one samplefrom the s'te durir'g each of three

months (normalweather)

*Noneadiological chemical po ameters listed in Table 2 25.r

Source ~ Branch Pos t.on for Preoperatronal Radio!o9 cal Environmental Monitoring P.ogram for Uran >um M lls." U S. Nuclear Regulatory Commission, Memorandum from L C Rouse. Ch.efof Fuel Process.ng and Fabncatson Branch. Jan. 9.1978

_

6-5

A census of birds was taken in February, May, late June, and October by roadside counts (ER,Plate 2.8-3) and a walked-transect count (Fig. 6.1). For the roadside count, all birds were

tallied within a 0.4-km (1/4-mile) radius every 0.8 km (1/2 mile) along the transect. Theroadside count is an adequate method for determining the cor4 0sition and abundance of birds.The walked-transect counts, described by Emlen,6 are useful for estimating densities in specifichabitats. Raptor nests were investigated by visiting possible nesting sites.

Data on big gane were based on signs (scat, tracks, etc), direct observation, and informationsupplied by the Utah Division of Wildlife Resources (ER, Sect. 6.l.4.3). Livestock informationwas obtained from the U.S. Bureau of Land Management. Rabbits and hares were counted along tworoadside transects on two consecutive evenings each season (ER, Plate 2.8-3). A census of smallIMiTials was taken at three trap grids placed on the site for each of three consecutive nightsin August and October 1977. Each grid consisted of 12 rows and 12 columns of traps spaced 15 m(49 f t) apart for a total of 144 traps. Sherman live traps were used in the study and alltraps were checked each morning and night. The captured animals were eartagged and released toestimate the population through a standard capture / recapture method. However, not enoughanimals were captured to make a meaningful population estimate (ER, Sect. 6.1.4.3). In additionto the grids, two traps lines consisting of 20 to 26 traps each were placed in pinyon-juniperand tamarisk-salix habitats to determine relative abundance, diversity and distribution ofsmall mammals (Fig. 6.1).

Although potentially harmful amounts of radionuclides and other contaminants in the tailingsimpoundment are not expected to result in any significant impacts to wildlife, the actualextent of this impact cannot be quantified (Sect. 4.6.1). Therefore, the staff will require

that the applicant monitor the use of the impoundment by wildlife in conjunction with theprogram to monitor the tailings discharge system (Sect. 3.2.4.7). The monitoring plan shouldbe submitted to the Utah Division of Wildlife Resources for their evaluation and approval.Because surf ace water is limited in the area, daily monitoring would be especially importantduring the fall and spring migration periods of waterfowl and shorebirds. The data shouldbe submitted to the Utah Division of Wildlife Resources and the NRC on a yearly basis forevaluation to determine if there is a need for additional monitoring.

6.5.2 Aquatic

Secause of the lack of aquatic habitat (Sect. 2.6.1.1), subsequent paucity of aouatic biota(Sect. 2.9.2), and the low probability that the aquatic habitat could be significantlyimpacted by mill construction and/or operation (Sect. 4.6.2), an extensive, long-term aquaticbiota monitorin) program is not considered necessary by the staff. However, because the local,mhemeral streams (Corral Creek, Westwater Creek, and Cottonwood Wash) have not been sampled.or aquatic biota during times of water flow, the staff will require the applicant to undertokea biotic survey of these environments under appropriate conditions to characterize any temporalaquatic biota, if the groundwater monitoring program indicates levels of potential contaminantsare increasing.

6.6 RADIOLOGICAL

6.6.1 Preoperational program

A preoperational, radiological monitoring program is being developed at the proposed WhiteMesa mill site to establish the baseline radiation levels and concentrations of radioactivematerials occurring in air, biota, and soil, as well as in regional surface water and localgroundwater. The sampling program, begun in July 1977, is ongoing, and results are incomplete.The preoperational monitoring program will conform to that recommended by the NRC and shown inTable 6.1.

6.6.2 Operational effluent and environmental monitoring program

The objectives of the effluent monitoring program are to ensure that the proposed mill dischargesare as low as reasonably achievable, to develop criteria that can be used in the design ofnew operational procedures, and to aid in the interpretation of the results of such other studiesas the environmental monitoring program. The procedures for controlling effluent release andperforming monitoring and surveys will conform to applicable U.S. Government regulations. Theprogram that will be iirplemented (Table 6.2) will consist of measurements of radioactivity inthe air, surface water and groundwater, soil, and biota.

6-6

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VEGETATION NTronste' Locotons

P- J - Peyon - Jun.oer Commurw'y RG 2 * Resseded Grossiand E Comm nityu, -BS - Og Sageorush Commurvy 0 Disturbed Commuruty .p ~)

CBS - Corfroned 81 Sogeerusn Comenurt'y T- S - Tomorist-Soks CommunityRGl Reseeded Grassland i Comra ntyu

WILDLIFE

Smon Mommoi Live Tropping Tronsect1 Pinyon-Jurwper Transect 3Grosskmd Grid (Reseeded Grossiond I)i Tomorsk - Gross Tronsect ( Tomorish-Schs ) G86g Sogeorush/ Gross Grid ( Controlled Big Segebrush )

G Bi; Sogetrush Gr d

Modefied Emien Berd Tronsect SCALE I 156250Errwen t - Grossiond

C org.n o direct on of troveEmien2 Bq Sogeor shu

F19 6.1. Sampling locations for terrestrial ecological Characteristics in the vicinityof the White Mesa project. Source: ER, Plate 2.8-1.

. _ . . . _ . __... . . . _ _ . . _ . . _ . . _ _ __

Table 6.2. Operational radiolowcal environmental monitorme program

Sample collection Sample measurement

Numter L.ocation Method and frequency Test frequency Type of measurement

Aar

Particulates 3 At site boundaries and in dif ferent Contmuous. weekly or Quarterly compos,te Natural uranium, Ra 226. Th 230.

sectors having the highest pre- more frequently as arid Pb 210

dicted concentrations required by dustload ng

1 At nearest residence Continuous; weekly or Quarterly composite Natural uranium, Ra 226. Th 230.

more frequently if and Pt>210required by loading

1 Controllocation-more than 15 km Contmuous; weekly Quarterly ot>mposite Natural uranium, Ra-226, Th-230.

from mill site m least prevalent or more frequentty and Pb 210

wind direction if required by duste

load ng a

w

Radon gas 5 Same as for air part culates Continuous; at least Each 48 hr sample Rn-222i

one week per monthat approximately thesame period eachmonth, samples

collected for 48 hrintervals

Particulates 1 Ore crusher stack Isokinetic and repre- Semiannual Natural uranium, flow rate

sentative* semiannual Semiannual for Ra 226. Th 230. Pb-210stack sample first year

1 Yellow cake dryer and packaging Isokinetic and repre- Quarterly Natural uranium, flow rate

stack sentative* monthly Semiannual,1 or 7 (1) Ra 226 and Th-230 orstack sample and (2) natural uranium,either (1) semiannual Ra-226, and Th 230stack sample or

miannual for 62M(2) semeannual productst year,1 or 2(yellow cake) sample

_ _ . . . . .

. _ . . . . . . . . .. .. . .

Table 6 2 (continuvel

Sampic conect.oqType of sample Sampic measurement

Nu mue r Loc,t< on Methad 4,d frequency est frecuency Type of measurerrert_ _ _ _ _ _ . . . . _ . . _ _. _ _ _ _ _ _ _ _ _ _

Water

Groundwater 9 Two ceep ce="gra:1 eat. two Grab. rr.ontru v Mor thly. quarterty D-ssoNed natural uramom. Re 226.deep crcssgraaient, and fivetouarter!v af ter after f rst year Th 230. Pty210, and Po 210;

f,hisellsest&sostii, first .ds* and TDS'1 Coctrol location-+.ydrolog+ cat er up G r ab. ouartert, Quarterly D.ssoNed naturat uran um. Ra-226.

gradeemt hot inf'venced by taAngs Th 230. Ptr210, ar d Pct 210.seepep)

chem-cats and T OS.

1 Each weit used for drmk.ng water or G rab; quarter ty Quarterl., Total natural uran,um. Ra 226.(from each meri) watering I.vestock or crops within

Th-230. Pb-210. and Po 210.2 km of ta; lings pond or m.ne#

chem.cais and TDSSurf ace water 2 Surf aa waters pass;ng tnrough or Grab.quartedy when Quarterty when Total natural uranum. Ra 226.

(from each stream) close to the mai. one sample flowing or foltoa.ng flowing or fotton. Th 230. Pt> 210. and Po 210.upstream and one downstream precip, tat <on event ing precipitat.on suspended soledsof locat.on of potent:al influence event

Direct radiata 5 Same as for air particulate sarnpies Pressurised ion;2ation Quartedy Measurement of a <ay and gammachamtw.r. prope rly exposure ratesCahbrated portable

e

survey instrument or "thermoruminescentdosirneters *1th two ormore phospho's each

Soil 5 Same as for a r particulate sar .p'es Grab. annually AnnuaHy Natural uraneum and Rs 226Vegetation or forage 3 From animal grai.ng areas near mal Grab. three t.mes Each sarnpfe Ra 226 and Pt> 210

site wh.d have the h.ghest pre- during gr azingdicted concentration Orcluding season b e.. Apref.nearest ranchesi Joty, and Octot.eri

*To be taken durme operation of the stack vent.lation system and the respect <ve process s estem. Minimum samphng time, 3 hr per stack8 Chemical parameters to be analysed wdt be determined from an anaiysis of samp es taken from the taAngs pond once mdl operat.ons have tegun'TDS = total dissolved sohds.d

it a large number of wells are located within 2 km, only those weIIs nearest tadmgs empoundment or the rmne need be sampled.

. - - .

6-9

REFERENCES FOR SECTION 0

1. A. P. Plucrier, D. R. Christensen, and S. B. Monsen, -catering rig-G2m Range in Uta;:,Utah Division of Fish and Gane, Publication No. 68-3, Salt Lake City,1968.

2. Energy fuels Nuclear, Inc. , " Responses to Comments from the U.S. Nuclear RegulatoryCommission, June 7,1978, White Mesa Uranium Project Environmental Report," Denver,Jure 29, 19/8.

3. State of Utah, Division of 011. Gas, and Mining, " Changes and Adoptions to the GeneralRules and Regulations " adopted by the Board of 011, Gas, and Mining on March 22, 1978;effective June 1, 1978.

4. Energy Fuels Nuclear, Inc., " Responses to Comments Telecopied from NRC to Enerly FuelsNuclear, Sept. 25,1978,' Oct. 4,1978.

5. Office of Water and Hazardous Materials, USEPA, pa:lt ty Q-::cria fce water, Washington,D.C., 1976.

6. J. T. Emlen " Population Densities of Birds Derived f rom Transects Counts,' Aak 88:323-342 (1971).

7. R. L. Smith, ro-Z> , ami FieZJ Efv!c ;<, 2d ed. , Harper and Row, New York,1974.,

7. UNAVOIDABLE ENVIRONMENTAL IMPACTS

7.1 AIR QUALITY

An unavoidable impact of construction and operation of the mill facility would be a slightincrease in particulate matter and ambient concentrations of gaseous emissions. Because theconcentration of these pollutants would be below the Federal and State air quality standards,the staff feels that they will not significantly contribute to the decline of the regional airquality.

7.2 LAND USE

7.2.1 Land resources

7.2.1.1 Nonagricultural

Area land uses will change as a result of the population growth that would be induced by theproposed mill and any related mining activities. Possible adverse impacts are those whichwould result from increased traffic on the highways.

7.2.1.2 Agricuitural

Construction and operation of the mill would result in an unavoidable loss of nearly 195 ha(484 acres) of potential crazing land. Following project termination, about 70% of this totalarea [approximately 135 ha (333 acres)] would be occupied by the reclaimed tailings impoundmentarea and would be considered pemanently committed to tailings disposal. This area might beavailable for grazing af tr it has been released from its status as a restricted area. Theremaining land would be reclaimed to permit unrestricted use.

7.2.2 Historical and archaeological resources

If the program of mitigation outlined in Sect. 4.2.2 is followed (avoidance of sites when oossible,full excavation of those which cannot be avoided, and protection of potenC.al or currentlyunidentified sites), adverse impacts should be minimized.

7.3 WATER

7.3.1 Surface water

Erosion of disturbed soils during construction and operation would minimally impact the localstreams and only during heavy, erosion-producing rainfall. f3 adverse impacts due to mill-siterunoff are expected, because thi! runoff will be impounded on the mill site during operations.No adverse impacts on surface w.ter caused by groundwater transport of tailings material areexpected. Overall, no adverse impacts to surface waters are expected.

7.3.2 Groundwater

Operation of the proposed fr.ill should result in the use of about 5.9 x 105 m (480 acre-ft) of3

water (drawn from the Navajo aquifer) per year. The usage of water by the applicent should haveno adverse effect on other users. Preoperational and operational monitoring of tt.e groundwateris required (Sect. 6.3.2), and mitigating measures will be taken if unexpected groundwatercontamination is observed.

7-1

7-2

7.4 SOILS

Construction and operation of the mill facility would disturb about 195 ha (484 acres). Topsoilwill be removed from the construction areas and stockpiled for replacement upon termination ofoperations. However, a temporary decrease in natural soil productivity is probable (Sect. 4.5).Some sot 1 will be unavoidably lost, primarily fra, wind erosion, but proper mitigating measures(Sect. 4.5) would minimize this impact. Peclamation laws require successful establishment of asoil medium that would be capable of sustaininc vegetation without irrigation or continuing sollamendments (Sect. 3. 3.2) . Long-term impacts to the soil are not expected to be significant.

7.5 BIOTA

7.5.1 Terrestrial

The proposed project would result in a temporary unavoidable loss of about 195 ha (484 acres)of vegetation and a concomitant loss of wildlife (Sect. 4.6.1). Although some vegetation andwildlif e loss would be unavoidable, such loss should not result in any long-term adverseimpacts.

7.5.2 Aguatic

The impact on limited available aquatic habitat due to mill construction or operation isprojected as insignificant (Sect. 4.6.2 and 7.3.1). No adverse impacts on aquatic biota areexpected.

7.6 RADIOLOGICAL

Radioactive emissions f rom transportation, storage, and milling of the ore would increase thelevel of radioactivity in the surface environment.

7.7 SOCIOECONOMIC

The infusion of people into the local area would strain certain public services and the housingmarket, unless these areas are expanded rapidly. Both old and new residents would be affected.

The present consumer prices for goods and services in the area of the site would be stimulatedby the project. A rising cost of living primarily affects original residents who have notincreased their income at the same rate as energy-development workers.

The general inconvenience caused by expansion to meet the needs of the new residents - suchas construction tctivities, temporary buildings, and decline in services - can rarely beavoided in large projects such as uranium mill construction. The staff expects that suchinconveniences will affect many in the area of the White Mesa Uranium Project but that theseeffects cannot be avoided.

8. RELATIONSHIP BETWEEN SHORT-TERM USES OF THE ENVIRONMENTAND LONG-TERM PRODUCTIVITY

3.1 THE ENVIRONMENT

8.1.1 _ Air quality

The short-term increases in suspended particulates during plant construction and the increasesin suspended particulates and chemical emissions associated with mill operation are expectedto have no impact on the long-term quality of the atmosphere in the region.

8.1.2 Land use

The land on which the mill is located could be returned to its present state and capacity byreclamation activities. The tailings area, however, under present regulations may be unavail-able for further productive use.

While uranium milling is a short-term activity, a mill tailings disposal site will constitute apermanent disturbance of the land surface, rendering it unsuitable for future archaeologicalinvestigation. Therefora, any such investigation must be conducted prior to the initial surfacedi s tu rbance.

8.1.3 W_ater

Because water for milling operations will be drawn from a deep and lightly used aquifer, nochanges in the water-use patterns of the area are expected to occur as a result of mill operation.

8.1.4 fiineral resources

No mineral resources are known to exist on the site. Reworking of tailings for extraction ofother minerals could occur if economics warrant.

8.1.5 Soils

The applicant's reclamation program is designed to return the soils to a condition ofproductivity that is consistent with their present and historic usage -- that is, theproduction of forage and habitat for livestock and wildlife. The program will begin as soonas practicable and will continue throughout the life of the project. As a result, abouthalf the disturbed soils should be back in production by the time mill operation ceases.

8.1.6 Biota

8.1.6.1 Vegetation

Revegetation of disturbed areas will begin as soon as practicable and will continue throughoutthe life of the project. A satisfactory vegetative cover is expected to be established in twoor three years. About half the disturbed area will be revegetated by the time mill operationscease, and the remainder will be revegetated shortly thereaf ter.

8.1.6.2 Wildlife

Terrestrial vertebrates now inhabiting the project site will either perish or will escape toundisturbed areas surrounding the mill, where populations will be controlled by natural means.Af ter reclamation, the more adaptable individuals and species will repopulate the area asfavorable stages in the vegetative succession are reached.

8.1.7 Radiological

The tailings will be impounded in lined cells. Such enclosures would be overlain with covermaterial to meet radon release standards, and then reclaimed. The reclaimed tailings areawill constitute a source of radon emission of about twice the natural background flux.

8-1

, , . . . . . - - - -

_

8-2

8.2 SOCIETY

No significant long-term impacts on the socioeconomic character of local coctnunities canpresently be attributed to the project with certainty. The nature of such impacts will dependon the prevailing community conditions when operations of this mill cease:

1. If the local econuny and population continues to grow when the operation tenninatesand project personnel migrate from the area, the additional housing and public facilitiesbuilt to accominodate project-related personnel will help to accoher.odate needs of theespanding economy.

2. If, at project te .iination, the economic activity and populations of communities aredeclining and surpluses of f acilities and housing exist, somc of the resources initiallyinvested to accoeurodate needs of the White Mesa mill employees will not have beena mo r t iled . This situation could be aggravated if bonds used to finance public fcr.ilitiesdirectly attributable to this development have not been amortized during the operating(or cther tampaying) life of the project.

A loss of long-term productivity may result f rom disturbance of archeological sites. However,the mitigating actions that would be taken should result in preservation of archeologicalmaterials that might otherwise have been destroyed. This is consistent with the opinion of the

1Utah State Historic Preservation Of ficer who has advised as follows :

The work to identify significant sites and sites that will be adversely effectedis nearly complete and while certain sites within the property may be significantunder the federal criteria, as more fully explained in the State Archaeologist'sreport, you should t'e aware that the significance of these tites lies not withtheir becoming public attractions or monuments, but rather with the informationthey have yielded about certain prehistoric cultures. Sites of this nature areplentiful throughout the southeastern part of Utah, but have not been tested.It is only the opportunity presented by the desire of Energy fuels to build auranium mill in this area that pennitted us to devote the time and energyto a thorough study of such sites. In essence Energy Fuels project will permitthe recovery of archaeological data that without the project probably neverwould have been recovered.

REFERENCES FOR STCTION 8

1. Utah State Historic Preservation Of ficer, letter to NRC, dated December 5,1978.

9. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

9.1 LAND AND MINERAL

9.1.1 Land

The land occupied by the reclaimed tailings cells may not be available for further productiveuse. This would be considered an irreversible commitment of resources.

Work to reclaim archaeological sites may result in an incom;lete recovery of archaeological dataor resources, or in an inadvertent destruction of a portion of those resources.

9.l.2 Mineral

No major irreversible or irretrievable commitments of mineral resources are anticipated otherthan (1) the uranium and vanadium that will be recovered; (2) the 23,000 MT (25.000 tons) ofcoal that will be burned each year; and (3) the yearly consumption of 6.6 MT (7.3 tons) ofkerosene and 95 m3 (25,000 gal) of fuel oil in processing operations.

9.2 WATER AND AIR

9.2.1 Water

Ground and surface waters are not expected to be impacted by '.ne proposed project. Because ofthe large volume of groundwater available, use of that water during mill operations is notconsidered an irreversible or irretrievable commitment of resources.

9.2.2 Air

Air is not depleted as a result of construction and operation of the nill facility but thereis a potential for the air quality to be impaired primarily as a result of an increase intotal, suspended particulate matter. However, because the atmosphere is self-cleaning ofthe pollutants at the anticipated low concentrations, no irreversible or irretrievablecommitments of air resources are expected.

9.3 BIOTA

9.3.1 Terrestrial

Although a total of about 195 ha (484 acres) of soils and associated vegetation will betemporarily disturbed or lost for the life of the project, the land and wildlife habitat canbe restored in time to acceptable levels as a result of approved reclamation efforts(Sec t. 3.3.2) . Current regulations, however, require the tailings disposal area [about 135 ha(333 acres)) to remain fenced until it is released from its status as a restricted area.Wildlife will undoubtedly use this area af ter it is fully reclaimed. This restriction is notconsidered an irreversible commitment of resources.

9.3.2 Aquatic

The staff does not expect any irreversible or irretrievable commitments of aquatic biota orhabitat from project operation.

9-1

--_ _ _ _ _ _

9-2

9.4 MATERIAL RESOURCES

*Major irretrievable and irreversible comitments of material resources incurred per year ofWhite Mesa mill operation are 6.04 x 10- MT (6.66 x 10' tons) of sulfuric acid; 4.8 x 103 MT(5.3 x 108 tons) of manganese dioxide, 2.47 x 103 MT (2.72 x 10' tons) of sodium chlorate;1.92 x 104 MT (2.12 x 10$ tons) of soda ash; 4.39 x 102 MT (4.84 x 102 tons) of amoniumsulfate; 2.93 x 102 MT (3.23 x 102 tons) of anhydrous ammonia; and 0.91 x 102 MT (1.0 x 102 tons)of flocculent. In addition small amounts of Isodecanol, Amine, and various laboratory chemicalswill be consumed.

These materials are not in short supply and are common to many industrial processes.

' Assuming 25% of the ore is processed for vanadium.

.. . . _ . . . _ _ - - . - . - -

10. ALTERNATIVES

10.1 ALTERNATIVE SITES

The following factors were among those considered in selecting and evaluating mill andtailings disposal sites:

1. availability of suitable land; accessibility, but with limited public exposure(population doses);

2. proximity to producing mines and known ore bodies for reducing haulage costs anddecreasing the impacts associated with ore transport;

3. geotechnical, meteorological, and hydrological factors: (1) direction and intensityof prevailing winds, (2) presence of mineral resources, (3) subsurface structuralstability, (4) availability of naturil tailings impoundment liner materials (5) ade-quate quantity and quality of materials available for reclaiming the tailings dis-posal area and other disturbed surface areas, and (6) suitable drainage and floodcharacteristics;

4. topographical f actors such as (1) surface suitability for construction of facilitieswith minimum alteration of terrain, and (2) minimal drainage area atcve the tailingsimpoundment;

5. proximity to natural and man-made areas that could be adversely af fected by theconstruction, operation, and reclamation activities related to the project;

6. existence of unique habitats that might support protected, threatened, or endangeredspecies;

7. availability of incustrially important services such as transportation, power, andcommunications.

The staff has determined that the most important factors to be considered durirg the siteselection process are those which ensure an acceptable tailings management program. The NRCtailings management performance objectives for siting and design are listed in Section 10.3.1.

10.1.1 Alternative Mill and Tailings Disposal Sites

The applicant's Hanksville and Blanding ore-buying stations were located to collect uraniumore from small producing mines in southeast Utah. The majority of the ore for the mill willnot be coming from company-owned mines located in close proximity in a specific geographicalarea but will be collected thru ore-buying from widely scattered mining operations in the FourCorners region. There are, theoretically, a multitude of potential sites in the Blanding -Hanksville region.

As was the case with the existing ore-buying stations, alternate sites for the mill would beoptimally located with respect to the ore to be processed to minimize hauling distances, i.e.,transportation impacts.

In addition to the alternative sites discussed below, the following alternatives were evaluated:1. The alternative of storing the mill wastes in the mines from which the ore was extracted.

This alternative is not feasible for a central milling operation that will be processingore from approximately 100 small, widely distributed mines with diverse ownerships.Adequate control of the transportation, handling, and storage of the tailings would bedifficult, and accessing and monitoring the effects of the tailings on the scattered,site specific environments would be both difficult and expensive.

2. The alternative of milling the ore purchased at the buying stations at existing uraniummills (see Section 10.4 for discussion).

The applicant evaluated two basic siting options: (1) locating the mill and tailings impound-ment in the Hanksville area, and (2) siting the processing and waste disposal fat.ilities inthe vicinity of Blanding.

10-1

__

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._ _ _ __ _ _

10-2

The option of locating the mill and tailings disposal facilities in the Hanksville area wasconsidered unacceptable by the staff for the following reasons:

1. Socioeconomic limitations (Section 2.4.2). These limitations include (1) limited (apac-

ity of Hanksville to absorb growth (excess housirv) is nonexistent); and (2) limitedavailability of power, communications, and tran5portation (air and rail) services.Hanksville (population 160) could not support the population increase that would benecessary to implement this project. The population change wuuld be similar to thatprojected for Blanding (Section 4.8.1); however, the impacts would be significantlygreater.

2. Increased are haulage distances. Approximately 75% of the known uranium ore depositsavailable for processing are located near Blanding (ER. p. 10-2).

Based on a consideration of socioeconomic and transportation impacts, the staff has concludedthat other potential alternative sites in the southeastern Utah region would be no better thanthose located in the vicinity of Blanding, Utah. Four alternative mill and waste disposalsites in the Blanding area were evaluated by the applicant (fig. 10.1): (1) Zekes Hole( Area 1), (2) Mesa ( Area !!), (3) Calvin Black property ( Area 111), and (4) White Mesa(Area IV). Zekes Hole is publicly-owned land located approximately 8 km (S miles) southwest ofBlanding, adjacent to and on the south side of State Highway 95. The Mesa site alternative islocated approximately 6.4 km (4 miles) southwest of Blanding, adjacent to and on the southside of State Highway 95 and consists of two sections of public land. The Calvin Black propertyencompasses approximately 290 ha (720 acres) of privately owned land and is located approxi-mately 3.2 km (2 miles) south of Blanding along the north side of State Highway 95. The WhiteMesa site is composed of 600 ha (1480 acres) of privately owned land and is located approxi-mately 10 km (6 miles) south of Blanding on the west side of Highway 163 and is crossed by theBlack Mesa Road and an existing power line. (The site is owned by Energy fuels Nuclear).

These sites were evaluated primarily with respect to the availability of suitable land, hydro-logical and topographical considerations, and accessibility of services:

1. Availability of Suitable Land. A drawback for the Calvin Black property is that it isTTkm (2 miles) f rom ETEMng and there are private residences within a 0.4-km (0.25-mile)

-

radius of the site. The White Mesa site, 10 km (6 miles) south of Blanding, on the otherhand, is bounded on east, west, and south sides by publicly-owned land and tie nearestpotential resiaence it 1.6 km (1 mile) north (the nearest current resident is approxi-mately 3 miles north),

2 Hydrolo ital and Topographical Considerations. Cottonwood Wash drains through the middle'M e eTes Hole site and the drainage at this location is greater than 500 km (193osquare miles). The Calvin Black property lies directly in the Westwater Creek drain 1ge.The Mesa and White Mesa sites are both located on gently sloping lands and are not crossedby major drainages.

3. Accessibility of Services. There is limited accessibility to commercial power at themes ETe and Mesa sites; power is available at the Calvin Black property and White Mesasites. The applicant claims that the water supplies at the Mesa site and at the CalvinClack property might be inadequate to support the proposed mill. Access to roads is nota problem at any of these sites.

Based on a comparison of the four areas with respect to the characteristics listed above thestaff concluded that the mill site area chosen by the applicant (White Mesa) was asenvironmentally suitable (or was better) than any of the other three.

10.1.2 Alternative Tailings Disposal Sites in the White Mesa Area

The applicant evaluated four potential sites for mill tailings disposal in the White Mesa area(see Fig. 10.2). At two of the sites (East and West), the tailings would be stored incanyons; and dams of considerable height would be required as part of the impoundments. Atthe North and South sites, tailings impoundments would cover larger surface areas and would beshallow, requiring the construction of dikes of low height.

The West site is located in Westwater Creek Canyon. The terrain in the area is steep, and a15 year impoundment would require a dam approximately 10.1 m (230 f t) high. A single-cell,above grade impoundment, sized to hold 15 years of tailings, would cover a small area[approximately 28 ha (68 acres)], and the drainage area would be aDout 340 ha (850 acres).The applicant rejected this tailings disposal site alternative for the following reasons (ER,Appendix H, p. 5):

. . --.- ._______ _

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10-3

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. _ . _ _ _ --

10-5

1. Because the dam would have to be quite hi@ to provide me r jired storage capacity andthe toe of the dam would be in the flood plain of Westwater teek, t ie long-term statsil-ity of the impoundment would be questionable.

2. Prevention of excessive seepage into the nearhy vertical sandstone canyon walls would hedifficult.

The East site is located in Corral Creek Canyan. A conventional, above grade tailings impound-ment, designed to hold 15 years of mill tailings, would cover approximately 49 ha (120 acres),would require a dam approximately 36.6 m (120 ft) high, and would have a drainage area ofabout 1400 ha (3400 acres). This tailings disposal site alternative was rejected by theapplicant for the following reasons (ER, Appendix H, p. 6):

1. Although the reservoir surface area would be small, which is beneficial for reclamationpurposes, the drainage area is large; and water erosion over the long term is potentiallysevere.

2. Prevention of excessive seepage into the ' teep, mostly sandstone canyon walls would bedifficult.

The South site, which was picked by the applicant as the optimum site, is downgradient fromthe proposed mill site. The area is gently sloping, disturbed rangeland containing a slightswale in the general area where the tailings impoundment would be placed. A single-cell.above grade,15-year innoundment at the South site would cover approximately 100 ha (2D acres),would require a dam approximately 19.8 m (65 f t) high, and would have a drainage area c'about 240 ha (590 acres). 'he impoundment that is part of the tailings nanagement systemproposed by the applicant is to be located at the South site and is discussed in detail in

Sects. 3.2.4.7 and 10.3.2 (Alternative 1).The North site is located on gently sloping land upgradient from the proposed mill site. If 'conventional, above grade, dam / pond disposal facility, sized to hold 15 years of mill wastes,were to be constructed in the area, the applicant estimates that the impoundment would cover87 ha (215 acres), would require a dam approximately 24.4 m (80 ft) high, and would have adrainage area of approximately 170 ha (420 acres). With the exception that the tailings wouldhave to be pumped uphill for a slightly greater distance, there are no significant differencesbetween this site and the SoutF site.

Assuming that the mill would be located at White Mesa and utilizing the following criteria toscreen feasible site alternatives from a multitude of potential sites in the Blanding area,the staff located and evaluated three additional alternative tailings disposal sites:

1. To minimize long-term wind and water erosion problems, the areas chosen for further studycontained naturally excavated basins which 1) are almost completely enclosed by substan-tial rock barriers (such as cliffs) and would require a dam with a small length, and 2)which would have minimal drainage areas above the tailings impoundment.

2. Only basins that could be impounded to contain at least 15 years of mill tailings andwhich could be readily accessed by road or by slurry pipeline were considered.

The three additional alternative tallings disposal sites cvaluated by the staff were 1) Recap-ture Creek, 2) Brown Canyon, and 3) Alkali Canyon. The Recapture Creek site is loc 1ted inSectior. 26, T375, R22E, east of the Corral Canyon tailings disposal site (" East site") investi-gated by the applicant, and east of the White Mesa site boundary. The Brown Canyon site islocated northeast of the White Mesa mill site in sections 13, 14, and 23, T375, R22E (thumajority of the tailings impoundment would be in section 14). The Alkali Canyon site islocated east-northeast of the White Mesa mill site in sections 10 11, 14 and 15, R23E, T375.

A tailings impoundment at the Recapture Creek site would cover approximately 37 ha (90 acres)and would require a dam approximately 48.8m (160 ft) high. At the Brown Canyon site an impound-ment would cover approximately 84 ha (205 acres) and would require a dam approximately 30.5m(100 ft) high. A tailings retention area at the Alkali Canyon site would cover approximately66 ha (161 acres); the dam required would be about 54.9m (180 ft) high. All sites are acces-sible by road; the haulage distances would be approximately 5.3 km (3.3 mi) to RecaptureCreek, 8.5 km (5.3 mi) to Brown Canyon, and 19.5 .4 '12.2 mi) to Alkali Canyon.

.

10-6

The tallings retention areas at these sites would be smaller than the proposed impoundment atWhite Mesa,and the local topographies of f er excellent protection f rom wind and water erosion.However, the dam heights would be greater, and the canyon walls are steep and consist of highly*

perrmable and fractured sandstone; the prevention of seepage from the tailings retention areaswould Le dif ficult,ar.d the long-term stability of the dams would be questionable. The staffcnncluded that no appreciable additional environmental benefits could be gained by storingthe tailirigs at these sites.

fvf uatinn of Alternative Mill and Tailings Disposal Sites10.1.3 l

The stif f has concluded that no net environmental advantages would accrue if the mill andtailings disposal facilities were to be located 3t sites other than the site propsed by theapplicant (White Mesa); i.e., the site proposed for the projected facilities is better, from aenvironmental standpoint, or at least as suitable as other potential locations. It must beemphasized that this conclusion is only possiole because a similar conclusion can be madeconcerning the acceptability of the proposed tailings management system (Section 10.3.2,Alternative 1), which enhances the environmental suitability of the chom site.

10.2 ALTERNATIVE Mllt PROCESSES

10.2.1 Con,entinnal tiranium Milling Processes

The milling precesses proposed by the applicant ire conventional and conform with thosecommonly used by the damestic uranium milling industry. In general, yellow cake is produced ,

by the mi' ling of uranium ore via the following procedure: (1) ore preparation (involvingprimarily the crushing and grinding of the ore), (2) leaching, (3) separation of pregnantleach liquids f rom wiste solids (tailings), (4) concentration and purification ;f the uraniumby extraction f rom the pregnant solution, (5) precipitation of the uranium f rom the extractsolution, and (6) drying and px kaging. The specific manner in which each of these steps,singly or in combination, is accomplished varies from mill to mill, depending on differing orecharacteristics. Normally, process decisions are based on overall economic considerations,including costs of controlling chemical and radiological effluents to air, water, and land.

Crushing and grinding of ore are needed to reduce overall particle size to ensure efficientcontact with the uranium-dissolving reagent. Normally, the ore is moved from stockpiles tothe crusher by trucks, bulldozers, or by f ront-end loaders. 3 Conventional crushing equipmentusually reduces the size of the ore particles to approximately minus 1.9 cm (3/4 in.). Controlof the moisture level in the feed ore is crucial in the crushing process and generally shouldbe less than 10% to prevent crusher malfunctions. In most mills the crushed ore is storedtemporarily in bins before further processing. Grinding is usually accomplished by rod orball mill, with the ore being ground to approximately 28 mesh for acid leaching and to approx-imately 200 mesh for alkaline leaching.' At the White Mesa mill the ore [w5ich has alreadybeen crush to less than 3.8-cm (1.5-in.) size at the ore buying stations] will b. fed by afront-ena .% 1er through a primary grizzly to a secondary grizzly and then fed by c nveyorbelt to a sc fautogenous wet grinding mill. The mill will operate in closed circuit withscreens, with the minus 28 mesh output (underflow from the screens) being pumped to threemechanically agitated, wet-slurry storage tanks.

The leaching method chosen for removal of the uranium from the ground ore is heavily dependenton the chemical properties of the ore. Ores containing low Icvels of basic materials (primar-ily time) are usually leached with sulfuric acid. An alkaline leach reagent (normally sodiumcarbonate-bicarbonate solution) is usually used when the lime content of the ore is high anduneconomical quantities of acid wouid be required, significantly increasing processing costs.Some processes add acid in " stages" to minimize excessive initial frothing and to moeitor acidcontent (pH control). The applicant evaluated the effectiveness of acid and alkaline leaching

# processes on ores purchased by the ore buying stations (ER, p. 10-6). Although some of theore could be successfully treated by alkaline leaching, acid leaching usually resulted in

C higher recovery rates; therefore, a conventional sulfuric acid leach process was chosen by theapplicant. The leaching circuit at the White Mesa mill will be designed for the extraction ofvanadium as well as uranium. The ore will be leached in two stages utilizing sulfuric acid,manganese dioxide (depending on availability and delivery, an equivalent oxidant such assodium chlorate might be used), and steam. The overall uranium recovery rate is expected tobe about 95L

The separation of the pregnant leach solution from waste solids is usually accomplished bythickening or by filtration. The majority of the acid leaching mills in the United States use

- counter-current decantation in thickeners for liquid-solid separation.2 The apriicant hasalso chosen to achieve liquid-sulld separatioa by counter-current decantation washing andthickening methods. (The belt filtration alternative is described in Sect. 10.2.2.) Eitherconvrational, multistage, counter-current thicker,ers or Enviro-Clear type thickeners will be

.

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10-7

e mloyed. To reduce f reshwiter requirements, barren raf finate will te added to the finalthickner for washing the leached residue. Polymeric flocculants will be used to increaseseparation efficiency, and the waste solids (underflow slurry from the last thickenerccntaining 50% water) will be pumped to the tailings impoundment area.

Ccncentration and purification of the uranium from the pregnant leach solution is necessaryfor the produ. tion of a high-grade uranium product. This is usually perfor"ed by either asolvent estraction or an ion exchange proce n The applicant has decided to utilize asolvent extraction m thod where the decanted, aqueous uranium-bearing leach solution will becontacted with an organic solution consisting of an amine-type compound dissolved in akerosene diluent. fhe dissolved uranyl ions are more soluble in (and transfer into) theorganic solution. Resin-based processes, such as resin-in pulp and resin ion exchange in

'clarified solution, were evaluated by the applicant and rejected for economic reasons, pri-marily because of relatively higher operating costs. The solvent extraction process will becarried out in a series of mixer and settling vessels, with the organic and aqueous solutionsbeing mechanically agitited and separated into organic and aqueous phases in the settlingtanks. This separation cperation would be performed in four stages using a counter-flowprinciple where the organic flow is introduced to the preceding stage and the aqueous flowfeeds the following stage. The depleted aqueous phase (raffinate) will be recycled to thecounter current decantation stage or processed for the recovery of vanadium (Sect. 3.2). The'uranium-loaded extract (organic solution) will be washed and stripped of uranium by contactwith an acidified sodium chloride solution; the resulting barren organic solution will bereturned to the solvent extraction circuit.

The milling process generally concludes with the recovery of the uranium frcm solution bychemical precipitation. When acid leach methods are utilized, the uranium is precipitated byneutralization with a base such as ammonia, lime, magnesia, or hydrogen peroxide.2 The precip-1 tate is then dewatered, dried, and packaged. At the White Mesa nill, the uranium-richsolution from the stripping operation will be treated with ammonia to neutralize tha solution,precipitating ammcnium diuranate, or yellow cake. The precipitate will then be thickened,dewaterad by centrifuge, dried in a multiple-hearth, oil-fired dryer (calciner), crushed tominus 0.6-cm (0.25-in.) size in a hammer mill, and then packaged in 55 gal drums for shipment.The drying, crushing, and packaging operations will be isolated and enclosed in an area thatis maintained at a negative air pressure to contain and collect (by wet scrubbing) airborneU 0a particles. As an alternative to the drying, crushing, and packaging operations, yellow3

cake slurry can now be shipped directly to a UFe conversion facility. lhe applicant investi-gated this alternative processing option but rejected it because of uncertainties concerningthe long-range availability of sufficient capacity at this type of conversion facility.=

v

10.2 2 Uranium Milling processes which Produce low-moisture Tailings

There are several alternative uranium milling processes currently in use in other countries1 which produce low-moisture tailings, which might be amenable to direct burial in unlined

disposal retention areas, ruch as depleted open-pit mines or specially prepared pits.For example, a dewaterinq method developed by Burns and Roe /Pechiney/Ugir:e Kuhlmann utilizesa belt-filtration process instead of conventional vacuum drun filters and thickeners toseparate the pregnant leach solution from waste solids. The liquid-solid separation methodproposed by the applicant will produce tailings that will be approximately 50% water byweight; the rate of discharge will ue approximately 1800 MT (2000 tons) of tailings and1800 MT (2000 tons) of water per day. If the Pechiney milling technique, which uses a beltfilter, were to be implemented, the " cake" would be counter-currently washed in two stages,with the barren tailings being @ watered to a moisture content of approximately 22%. Thetailings can be neutralized before or on the belt filter. The tailings would then bebelt-conveyor or truck transported to the tailings disposal site. Because the tailings areessentially " dry," the area required for tailings storage might be reduced; and the problemsassociated with the control and monitoring of seepage from a disposal site might also bedecreased. The possibility of using this type of belt filtration process is dependent onconsistent physical characteristics in the ore processed, as this is the basis for the designof the filter. The ore to be processed at the White Mesa mill will have a wide range ofphysical and chemical characteristics.

The applicant evaluated the effectiveness of utilizing a belt filter or disk filter system toreduce the moisture content of the mill tailings. The filtration circuit evaluated, however,would not replace the propcsed " thickener" liquid-solid separation process but would acceptthe tailings from the thickener circuit and segregate the slimes and sands for separate dispos-al. This alternative tallings disposal method is discussed in greater detail in Sect. 10.3.2(Alternative 3).

e

. ,

10-8

10.2.3 Evaluation of Proposed Millino Precess

The milling processes proposed by the applicant are conventional, state-of-the-art techniquesutilized in the domastic uranium milling industry and are as environmentally sound as othercommonly used processing combinations. Further unf oreseen developments, such as increasedprocessing costs due to changes in the theracteristics of the ore or changes in the relativecosts of reagents, may result in the applicant proposing changes in the mill circuit. Wnensuch changes are suqqested, the environmental istpacts associated with their implementationwill be assessed.

10.3 AtilRNAllVE M[iHODS FOR TAILING 5 MANAGEMINT

10.3.1 Introducticn

f or the purposes of this section, tailings mana')enent is defined as the control of thetailings and waste solutions following renoval of the uranium values. Engineering techniquesto control pollutants f rom tailings, both during operational and post-operat ional stagesof a milling proje<.t. have been proposed. The unique characteristics of each facility mustbe identified, and then appropriate environmental controit must be applied. The staff hase,amined alternatives considered by the applicant "' as well as alternatives consideredfor other mills in preparing this section.'-Il Alternatives presently available or feasible(i.e., potentially available with existinq technology and at a reasonable cost) are describedin Sect. 10.3.2 and evaluated in Sect. 10.3.3. A list of additional alternatives for tailingsmanagement that the staf f has concluded are not feasible with existing technology is presentedin Sect. 10.3.4

f ach alternative tailings management plan has t,een evaluated against the following set ofperformance objectives developed by the staff:

Siting and desh n

1. Locate the tailings isolation area remote from people so that population exposures willbe reduced to the maximum extent reascnably achievable.

2 tocate the tailings isolation area so that disrq ttun and dispersion by natural forces iseliminated or reduced to the maximum extent reasonably achievable.

3. Design the isolation area so that seepage of toxic materials into the groundwater systemwill LA eliminated or reduced to the maximum extent reasonably achievable.

During operatioq

4. Eliminate the blowing of tailings to unrestricted areas during normal operatingconditions.

Post reclamation

5. Reduce direct gamma radiation from the impoundment area to essentially background.

6. Reduce the radon emanation rate from the impoundment area to about twice the emanationrate in the surrounding environs.

7. Eliminate the need for an ongoing monitoring and maintenance program following successfulreclamation.

8. Provide surety arrangements to ensure that sufficient funds are available to complete thefull reclamation plan.

10.3.2 feasible alternatives for tailings management

Alternative 1: Tailings disposal in impoundment cells built _, filled and reclaimedfn sta y s

This alternative involves the construction of a six-cell impoundment system with a safety dikein a swale (shallow natural basin) irrediately to the west and south of the proposed mill site.Two of the cells will be used as evaporation ponds. As proposed by the applicant, tFe total

. . . . . . _ . _ _- - - - - - - -

10-9

tallings disposal area would be sized to contain 1800 netric tons (MT; 2000 tons) per day oftailings produced during 15 years of nill operation (see Fig. 3.4). The proposed tailingssystem involves simultaneous construction, operation. and reclamation of individual cells. Asone r. ell is t.eing used for tailings disposal, the previous used cell will be dryinq and thenext cell downgradient will serve as an emergency catchrent basin (Sect. 3.2.4.7). An

individual cell would te sized to hold approximately four years production of tailings and wouldcover approximately 24 ha (60 acres) of surface area. Cells would be constructed by excavatingthe bottom of the impoundcent and by building successive ettbankments across the open (southern)end of the f. wale to contain the tailings. The ercavation of a limited amount of bedrock material[1.5 to 1.8 m (5 to 6 ft) deep], in addition to overburden soil, would be necessary. Because ahigh degree of weathering is anticipated at these depths, excavation would be accomplished byripping; no blasting would be used for excavation of the rock (except for localized lcnses ofunweathered rock). Excavation slopes no steeoer than 3:1 (horizontal to vertical) are specifiedfor sInpe and lining systen stability. The dikes would be homogeneous, conpacted, carth-filledenbanbments constructed fron soils present in the overburden at the tailings disposal site. Theenbankments would vary in height fron approxinately 7.6 n (25 f t) for cell 1-E to 13 m (42 f t)for cell 5, where the dikes cross the lowest part of the swale. Each d!ke would be 6.1 m (20 f t)thick at the crest to allow for an access road and would have side slopes no steeper than 3:1(horizontal to vertical) (Fig. 3.7). When passing between individual cells, the tailingsdischarge pipe would h' contained in an outer "energency containment" pipe. The "energency con.tairrient" pipe would M secured in a pipe trench lined with a double layer of synthetic liningwhich would be built into the crests of embankments. The downstrean slope of the final,southernrost dike (cell 5) is the only dike that would ultimately have an exposed face (afterfinal reclamation); therefore, to reduce the potential for excessive crosion of this embankmentaf ter cessation of mill operatinns, a 6:1 sloped layer of rock fill would be used in the con-struction nf the dcwnstrean seqnent of this dike (F;g. 3.8). Additionally, to minimize water

and wind Crosion during operations, excavated rock sould be used to protect drainaqe channelsand to cover the exterior slopes on the perimeter of the impoundment. The entire tailingsretention system (includinq the cell 5 safety dike) would cover approximately 135 ha (333 acres)of surface area if the mill were to operate at 1800 MT per day for 15 years; the total affectedacreage (includes land weded for stockpiling and horrow areas) would be approximately 195 ha(484 acres). (See Table 4.3.)

To prevent seepage of liquid wastes from the impoundment facilities, the applicant initiallywill line all ir,tericr surfaces of each celi with ' state-of-the-art synthetic liner such asPVC ri inforced with a nylon scrim (the final liner and liner system specifications and theprogram for installation, maintenance and inspection of the liner system will be reviewedand approved b/ the NRC staff prior to use). To prevent puncturing of the syntheticliner, a smooth (projection free) subliner of locally obtained clayey-silt soil would beplaced over the excavated rock surfaces of each cell floor. The entire synthetic linersurface (including the liner on the upstream portion of the dikes) would be overlain with30.5 cm (12 in.) of clayey-silt soil to minimize liner deterioration caused bj winds, sunlight,and the tailings materials and also for protection from operating equipment. No slurry dischargewill be permitted directly onto the cell lining cover. Because (1) the cell floors would be flat(2! slopes or less) for other than excavation slopes (no steeper than 3H:lV), (2) the cells wouldbe shallow impoundments, and (3) dense, relatively incorrpressible materials (Dakota Sandstone)would underlay the liner, differential settlement should not be of sufficient severity tocompromise the liner integrity.

The expectea net evaportion rate at the site is 0.9 m (3 f t) per year, and the total liquidtransported with the tailings would be 5.9 x 10 m (480 acre-ft) per year. On the slightly5 3

sloping impoundment surfaces, the staff expects the tailings to drain and settle to a voidfraction approaching 0.34, which would contain pore water at 50% of saturation. This quantitywould be ef fectively bound by capillary forces at 0.17 mi (0.17 ft') of water for each cubic

m (57 acre-f t) per year. With no' seepage,lmeter of settled tailings or about 7.0 x 104equilibrium between input and evaporation would be achieved with about 56 ha (139 acres) ofponded liquid. Because the surface areas of the evaporation cel'/i Muld be only 40 ha, (98 acres),the staff has concluded that corrective measures, such as recyclina.Jeilings solutions to themill, may have to be instituted to satisfy water balance requirements. However, this shouldnot be required because the moist tailings surface and the ponded slimes will provide at leastan additional 24 ha (60 acres) of evaporation surface in addition to the 40 ha (98 acres) ofevaporation pond.

10-10

During operations, a freeboard of 1.5-m (5 ft) minimum would be maintained in the evaporation andtailings cells. In addition, interceptor ditches would be constructed to divert surface drainageaway from the operations and impoundment areas. These ditches, sized to pass the probable maximumflood, would be constructed north, east, and west of the tailings and operating areas. Riprap,consisting of excavated rock, wou d be placed in the ditches to aid in preventing erosion. Overl

the long term, the interceptor ditches would fill with silt and becoce revegetated. The sculldrainage area upgradient from the reclaimed tailings impoundrent [upgradient drainage area is0.065 km' (0.025 sq mile)] obviates concerns over dispersion of the cover from flooding.s

Reclamation would be implemented sequentially for the tailings cells as each cell is inactivatedand as soon as an individual cell has dried suf ficiently to allow the movement of equipmentover the pile. To reduce radon gas emanation and qanna radiation from the tailings toacceptable levels, the applicant proposes to cover the tailinqs with a 0.6-m (2-f t) layerof contacted clay obtained f rom of fsite deposits,1.2 n (4 f t) of onsite clayey-silt materia;,1.8 m (6 ft) of rock, and 15 cn (6 in.) of topsoil. Slopes on the perineter of the cover wouldbe no stecper thin 6H:lV and would be constructed of riprap. The compacted clay would bedesigned ard constructed to prevent damage by differential settlement. To reveqetate thetallings area, the applicant has proposed to seed the tailings cover with a mixture of grasses,forbs, and shrubs

Pecause the cap would be almost 4 m (13 f t) thick, the staff has concluded that root penetra-tion into the tailings is not likely, reducinq the possiblity of adverse impacts associatedwith the upward migration of radionuclides and toxic elenents thr' ugh plant root systems.Althouqh the disposal area would be located in a relatively arid region, the proposed coveris not expected to develup significant shrinkage cracks because the clay content of the soilsto be utilized is low (except for the imported, remolded clay).

The reduction of the ga rta radiation that results f ron capping a tailings pile is dependent onthe degree of compaction and nass stopping power of the cover material. As shown in Appendix G,similar coser was calculated by the staff to reduce the gamu radiation from the tailings toapproximately 1 x 10-' milliroentgens per year, thus meeting the performance objective forreduction of gama radiation.

The radon flux at the surface of uncovered tailings was calculated by the staf f to be approxi-mately 439 pCi/m' sec. The covering schene proposed by the applicant [0.6 m (2 f t) ofclay overlain with 1.2 m (4 ft) of clayey-silt material, l.R m (6 ft) of rock, and 15 cm(6 in.) of topsoil) was estimated by the staff to reduce the radon emanation rate from thereclaimed tailings area to approximately 1.16 pCf/m set and meets the intent of the performance2

objective for reduction of rad 7n exhalation. These calculations will be experimentallyconfirmed.

Discounting and deflating the expected costs to 1978 dollars (101 discount rate and 8 rate ofinflation per annum), the total estirated costs for this alternative is approximately$20.7 million. (The costs for a synthetic liner for the entire impour.dment and for the claycomponent of the cover are estimated at $5.5 and $2.0 million, respectively.)

The major benefits that could accrue with implementation of this tailings disposal alternativeare the following:

1. The tailings would be stored in the head end of a natural basin and below the ridges boundingthat basin on all but the southern (open) end. Although the tailings cover is only partiallybelow these ridger [at least 1.5 m (5 ft)], the slight grade ( ?! overall) on the cover andsmall upqradient drainage area [0.065 km (0.025 mi2)] should provide a high degree of pro-2

toction fran wind and water erosion. Slopes on the perimenter of the impoundment coverwould be no steeper than 6H:lV and would be constructed of riprap. The entire area would berevegetated; and a layer of riprap would be placed on all exposed slopes around the impound-ment, further minimizing potential erosion problems. Although the downstream side of thelast dike (on cell 5) has an exposed face, it will have a 6:1 slope and will be constructedof rock overburden.

2. The cellular desiqn allows staged reclamation, minimizing the quantity of tailings exposedat any one time. Overburden storage and handling requirements are also reduced, that is,overburden renoved daring excavation of later cells can be transported directly to cellsbeing reclaimed.

3. The low dikes and the shallow depth of the cells increase dike stability.

,

___

10-11

Alternative 2: Below-grade burial in a specially excavated pit

This alternative involves the excavaticn of a basin of sufficient size and depth to store allof the tailings and tailings cover completely below grade. The impoundment would be linedwith a synthetic liner to minimize seepage from the disposal area. After conpletion of filloperations and as the tailings reach sufficient dryness to allow the movement of equipmentover the pile, the tailings would be covered with corpacted clay, locally obtained rock andsoil, and topsoil in the same configuration as proposed for Alternative 1. Therefore, the

radon gas a1d gamma attenuation estimates would be the same as for Alternative 1.

In the versicn of this alternative proposed by the applicant, the tailings would be storedbelow grade; but the tailings cover would protrude above grade. However, a true below-gradedisposal systen would have to include the cover below grade, wnich would require modifica-tions in the applicant's oroposed plan. Further excavation downward would significantly increasecosts and would require extensive blasting to remove unweathered Dakota Sandstone. Implement-ing either version of this alternative would be advantageous as no retention embardment would berequired; thus the probability of release and dispersion of tailings would be minimized.

The estimated cost of Alternative 2 is $32.6 million (discounted to 1978 dollars). This doesnot include the cost of the additional excavation of bedrock that would be required to make thesystem ''below grade" The benefits that this alternative might have over Alternative 1 do notjustify the additional costs.

Alternative 3: filtered tailings disposal

This alternative features partially below-grade burial of dewatered tailings in unlined basinsor trenches. Dewatering would be accomplished by either horizontal belt-type or disc-typevacuum filters. The filtration circuits would not replace the proposed " thickener" liquid-solid separation process but would accept the tailings frm the thickener circuit and segre-gate the liquids and solids for separate disposal (see fig. 10.3). The dewatered tailingswould be transported to the disposal area either by truck or by a portable conveyor Systen.The liquid filtrate would be discharged to three 28-ha (70-acre) lined evaporation ponds.Af ter completion of milling operations, the ponds would dry out. Soluble residue and con-taminated clays and underlying materials would be removed from the pond areas and buried inthe tailings disposal area. The evaporation ponds would be constructed above grade, would varyfrom 1.8 m (6 ft) to 2.4 m (8 ft) in depth, and would be lined with a clayey-silt materialavailable onsite.

The total volume of tailings produced over the 15 years of project operation would approach6.88 x 10' m 3 This volume would cover an area of 160 ha (400 acres), 4.6 m (15 ft) deep. Tobalance excavation quantity (4.74 x 106 m ) and cover requirements, the applicant proposes to3

construct a 160-ha (400-acre) impoundment, 3 m (10 f t) deep. This design would result in atailings projecting 1.5 m (5 f t) above grade and the tailinos cover completely above grade.The same cover scheme proposed in Alternative 1 would be utilized.

The major disadvantages associated with the implementation of this alternative are as follows:

1. The tailings would be partially above grade, and the long-term stability of thereclaimed tailings impoundment would be questionable.

2. The absence of an impermeable liner under the evaporation pond increases the possibilityof long-term leaching of toxic elements from the tailings. (The impermeability ofthe compacted clayey-silt material has not been proven.)

3. The reliability of the filter system would be questionable due to the wide variety ofores to be processed by the proposed mill.

The total cost of this alternative is a function of the dewatering system and tailings transportsystem chosen. With haulage of dewatered tailings by truck or by conveyor belt and filtrationby horizontal belt or disc filters, the costs rance from approximately $24.7 to $25.0 million.(The cost of the clay cap would be approximately $2.4 million.)

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. . _ - _ _

10-13

Alternative 4: Solidification of tailings utilizing cement, asphalt, or other chemical fixants

In this option, mill tailings would be fixed with cement, asphalt, or other chemicals to forma solid, less leachable product for disposal. The solidified tailings could then be stored inan impoundment. The disposal area would be reclaimed by covering the material with layers ofuserburden and topsoil and revegetating it to minimize water and wind erosion.

Portland cement could be utilized to fix either the entirs. tailings solids or the slimes only.In either case, the tailings would be neutralized (probably by the addition of lime), and thewiste slurry would be dewatered to a minimum of 60% solids before being mired with the cement.A minimum of I part cement to 20 parts tailings would be required for solidification; strength,leaching resistance, and cost increase as the ratio of cement to tailings increases (ref. 11,p. 43). The 1:20 coment to tailings misture could be pumped, if necessary, via a slurry pipe-line to a disposal site.

Neutralized, dewatered (dried) slimes and waste solutions could be fixed with asphalt, and theW'en firstfinal product would contain approximately 60% slimes solids (ref, 11, p. 42). n

mised, the product would be fluid and could be shipped via a pipeline to a disposal site. Themajor advantages of solidifying tailings in asphalt are (1) leaching resistance is high and(2) ra1on exhalation is reduced because asphalt is an effective radon diffusion barrier.

Commercially available chemical fixants could also be used to solidify the tailings. If thiswaste stabilization method were to be implemented, the chemicals would be blended into thetailings slurry and the resultant mixture pumped to an impoundment where solidification wouldoccur within a few days to a few weeks The waste material would either be entirely entrappedor the pollutants (primarily heavy metals) would t>e chemically bound in insoluble comolexes. *

Although theoretically feasible and environmentally desirable, solidification of tailings isexpensive. The applicant investigated the costs of utilizing chemical fixants to solidify thetailings, finding the costs to range from $7 to $36 per ton of treated tailings.* If a nominalcost of $10 per ton of tailings is assumed, chemically fixing the waste material produtad by15 years of mill operation would cost approximately $91.3 million (discounted to 1978 dollars).The staf f estimates that the costs of asphalt or cement fixation would range f rom $90 millionto $105 million.

Alternative 5: Conventional above grade tailings disposal using an engineered embankmentto retain the tailings

This alternative consists of creating a tailings impoundment by constructing a dike to enclosethe lower end of the natural basin south of the proposed mill site (Fig.10.4). A full-heightengineered embankment constructed of borrow material would be used to retain 15 years of milltailings. Because the basin created by the embankment would be filled with tailings by distri-bution from the top of the dam, construction of the embankment would have to be completedbefore the system could be used. The downstream segment of the embankment would be construc-ted of perneable sand. To minimize seepage, the upstream section would be constructed ofcompacted clayey-silt and silty-sand and would be tied into the soil liner on the bottom ofthe impoundment. The dam would be approximately 20.7 m (68 ft) high, with a freeboard allow-ance of about 1.5 m (5 ft) for wave protection. The tailings reservoir would cover approxi-rately 103 ha (250 acres). To prevent erosion c7 the downstream dam slo;)e,15 cm (6 in) cfgravel, overlain with 30.4 cm (1 f t) of riprap or a 10 cm-thick (4 in-thick) concrete capreinforced with wire mesh, would be placed over the downstream segment, fhe floor of theimpoundment would be lined with 0.6 m (2 f t) of conoacted, locally obtained clayey-silt materialto limi t seepage from the impoundment.

Af ter the completion of mill operations and as the tailings reach sufficient dryness to allowthe movement of equipment over the pile, the tailings would be covered with layers of compactedclay, clayey-silt material, and topsoil of the same configuration as prooos?d forAlternative 1, and the area would be reveqetated with appropriate plant species.

The total estimated cost for this alternative is $9.6 million (discounted to 1978 dollars) ifriprap is used for slope protection. The cost of the clay cap is roughly $1.5 million.

10-14

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_-

---

10-15

The applicant also investigated the construction of an engineered embankment in stages, witheach stage being sized to retain the tailings from five years of mill operation. With theexception that the dam would be exposed to erosion during the operational period (because noriprap could be adequately placed untti the final stage is completed', the impacts of stageddam construction would be about tha same as would occur if a full-height engineered embankmentwere to be used. The cost would be approximately $9.4 million (discounted to 1978 dollars).This estimate does not include the cost described above for the clay cap.

Alternative 6: Conventional above-grade tailings disposalHorage oTliquid wntes ~~

utilizing an evapration pond for~

This alternative consists of discharging the tailings slurry into a segmented settling pond,with liquid wastes bein9 dacanted into an evaporation pond. The settling basin and the evapora-tion pond would be enclosed by engineered embankments (Fig.10,5). The evaporation pond wouldbe 1200 m (4000 ft) by 165 m (540 ft), or 20.3 ha (49.5 acres). The main basin would coverapproximately 103.7 ha (253 acres). The maximum height of the settling pond embankments wouldbe 12 m (40 f t); the dam around the evrporation pond would be about 9 m (30 f t) high. Smallembankments constructed of tailings sands would be constructed in the main basin to create fivesegments. Tailings would be delivered to the tops of these dikes, with the excess liquids beingdecanted into the pond area outside the tailings impoundnent. As each divided segment is filledto design capacity, it would be allowed to dry and then covered with a layer of compacted clay,soil material, and topsoil of the same configuration as proposed for Alternal.ive 1. Themain basin and the evaporation ponds would be lined to limit seepage with a 0.6 m (2 ft) linerof clayey-silt materials. The lengths of the embankments required to surround the impoundmentswould be approximately 4180 m (13,700 f t) for the settling basin and approximately 1550 m(5080 f t) for the evaporation pond. The total cost of this alternative would be approximately$10.7 million (discounted to 1973 dollars). The cost of the clay cap is $1.8 million.

Alternative 7: Segregated disposal

In this alternative, tailings sands would be separated from slimes and liquids. The dewateredsands would be placed in unlined trenches, and the slimes and liquids would be discharged toclay- or synthetic-lined evaporation ponds (Figure 10.6).

The sands disposal area would cover approximately 126 ha (310 acres) and would consist of aseries of parallel, unlined trenches. The total excavation requirements for the area would approach4.18 x 106 3m- Sands would be placed in the trenches by a " Mobile Disposal Unit," which would(1) receive the total slurry, (2) remove the sands from the slurry by means of either standardhydrometallurgical cyclones (hydrocyclones) with or without a dewatering screen, and(3) would deposit the moist sands (20 to 25% moisture) in the unlined trenches. The depositedsands would drain to 15 to 20% moisture, and all drainage would be recycled to the mill. Useof the hydrocyclone-dewatering screen option would result i; drier sands being deposited, thusminimizing the seepage from the trenches. Each individual trench would be reclaimed after itis fillei The sands would be leveled to the natural grade and a 2.7-m (9-ft) layer of com-pacted clayey-silt material would be placed over the sands to limit radon emanation and toprotect the sands against erosion.

Slimes and liquids would be directed to a 36-ha (90-acre) evaporation pond. The applicant hasexamined four alternate pond configurations: two above grade (lined with onsite soils), onepartially below grade (synthetic-lined), and one below grade (synthetic-lined). Engineeredembankments would be constructed for the above-grade and partially above-grade options, and thebelow-grade option would not require embankments.

The major differences in the costs of the alternative configurations are related to the amountof excavation necessary in construction of the ponds. Dike construction for the above gradeoption would require 1.13 x 106 m of fill materials from onsite borrow areas. The partially3

above grade option would result in the excavation of 1.53 x 106 m , with 305,800 m being used3 3

in embankment construction. The below grade option would result in the excavation of3 35.35 x 106 m of material, of which 2.78 x 106 m would be solid rock.

Reclamation would be achieved by covering the area with a suitable radon diffusion barrierover the dry slimes. Given the high radium content of the slimes, the staff feels that thecover configuration proposed in Alternative 1 could be inadequate for the slimes area.

_.__

.

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10-16

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Energy Fuels Nuclear, Inc., Fig. 3-6 in " Investigations of Alternative Tailings Disposal Systems,White Mesa Uranium Project, Blanding, Utah," April 1978.

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10-18

The cost of this alternative as estimated by the applicant is a function of the slime-sandseparation method and of the slime pond configuration chosen (the increas in costs due toincreases in cover material thickness over the dried slimes is not included):

Hydrocyclones andHydrocyclones only dewatering screens Evaporation pond

$16,720,000 $16,921,000 Above grade slimes

$25,147,000 $25,350,000 Partially below gradeslimes

$31,368,000 $31,571,000 Below grade slimes

$16,720,000 $16,924,000 Above grade disposalwith several small ponds

Alternitive 8: Neutralization of tailings

This alternative consists of treating the acidic tailings with various bases to yield aneutral solution. According to ref. 11, pp. 132 and 133, neutralization " causes theprecipitation of 90% of the radium, almost all the thorium, and much of the iron, copper,cobalt, arsenic, uranium, vanadium, and other heavy metal ions as insoluble oxides or hydrox-ides. Seepage from neturalized, compacted tailings covered by a pond, or runoff fromneutralized tailings, carries very little radium, in contrast to seepage or runoff from unneu-tralized tailings which may carry dissolved radium."

In Canada, liquid wastes from acid-leach uranium mills are routinely neutralized prior todischarge to natural waterways. Neutralization reportedly requires about 7.3 kg (16 lb) oflimestone (CACO ) and 4.5 to 22 kg (10 to 48 lb) of lime (Ca[0H]2) per ton of ore.12 A theo-3

retical value of 15.6 MT (34.4 tons) per day of lime for an 1800 MT (2000 tons) per day millhas been reported.1 The White Mesa Uranium Project would be processing approximately 1800 MT(2000 tons) of ore per day for 340 days per year; therefore, neutralization could requireapproximately 11,000 Mf (12,000 tons) per year of lime [ assuming 32 MT (35 tons) per day).

The applicant investigated the possibility of introducing milk of lime into the tailingsstream to neutralize the tailings effluent. Neutralization could be applied to any of th.tallings disposal alternatives discussed in this section. For alternatives 1, 2, and 6, theapplicant estimated that neutralization of the tailings would precipitate about 91 kg (200 lb)of salts (including water of hydration) per ton of tailings. The precipitate would be gelati-nous and of low density, and the total volume of tailings would increase slightly. The totalcapital and cperating costs for neutralizing 15 years of mill tailings was estimated to beapproximately $18.55 million (discounted to 1978 dollars) for these alternatives.

The applicant also evaluated the consequences of neutralizing the slimes portion of the tailingsproduced by segregating the slines and sands (see Alternative 7). The applicant estimated thatapproximately 82 69 (180 lb) of salts would be precipitated per ton of tailings, increasing theweight of the slimes and reducing the resulting mixture to approximately 40% solids. Theapplicant also estimated that to maintain an adequate evaporative rate, the evaporation pondwould have to be uoubled in size to approximately 73 ha (180 acres). ( About 36 ha (90 acres)would be needed for unneutralized slimes.) The total capital and operating costs for neutrali-zation of only the slimes portion of the tallings were estimated to be $16.34 million, assuming15 years of mill operation and discounted to 1978 dollars.

10-19

10.3.3 Evaluation of alternatives

Alternative 1 is the preferred alternative of the applicant and the staf f. The tailings wouldbe stored in the head end of a natural basin and below the ridges bounding that basin on allbut the southern (open) end. Although the cover is only partially below these ridges (approxi-mately 5 of the 12.5 f t of cover). the final grade on the reclaimed impoundment is slight (<2%),and the slopes on the perimeter of the cover would be no greater than 6H:lV and would be

constructed of riprap. Revegetation of the area and the placement of containment material (riprapor concrete) on all downstream slopes would minimize wind and wgter erosign. In addition, thesmall drainage area above the reclained tailings area [0.065 km (0.025 mi )) obviates concernsover dispersion of cover from flooding which can be a severe problem over the long tem. There-fore, the proposed cover meets the performance objectives for reduction of radon exhalationand ganrna radiation and should eliminate the need for an ongoing monitoring and maintenancep rog ram. The segmented impoundment design, which allows for staged reclamation, would minimizetailings exposure during operations. Theliners on cell interiors would essentially eliminateseepage.

Storing the tallings below grade (Alternative 2) in a specially dug pit would minimize long-term wind and water erosion of the reclaimed tallings impoundnent. In addition, the proposedcover (same as for Alternative 1) would meet the radon exhalation and gamma radiation criteria.However, to provide sufficient pit capacity to contain both the tailings and cover completelytielow grade, significant amounts of bedrock would have to be excavated by blasting, which couldfracture the bedrock incrcasing its permeability substantially. Because the water table is only15 to 23 m (50 to 75 ft) below the surface and the pit would be deep (7.6 to 9.2 m (25 to 30 ft)),any failure of a liner could result in liquid wastes reaching the water table through thesefractures. In addition, the cost of this excavation could be prohibitive.

Alternative 3 involves dewatering the tallings. The major disadvantages for this dewateringalternative as proposed by the applicant are that the tailings themselves would be partiallyabove grade and susceptible to long-term wind and water erosion following reclamation and thatthe success of filtration, which depends greatly upon the amenability of the ores to the methodchosen for filtration, would be questionable because of the variability of the cres. Also, theclayey-silt liner proposed for the evaporation pond has not been shown to be capable of reducingseepage to the maximum extent reasonably achievable.

Alternative 4 involves solidification of tailings. Although this could be environmentallyattractive, tM technology is not well established, and at present, the costs far outweigh anybenefits that me iht accrue.

Alternative 5 con ists of conventional above-grade dam and pond systems. The reclaimed impound-ment area would bc highly susceptible to wind and water erosion and would not eliminate the needf or ongoing mont tcring and maintenance over the long tem. In addition, the proposed clayey-siltliner has not brem shown to be capable of reducing seepage to the maximum extent reasonablyachievable.

Alternative 6 consists of discharging the tailings slurry into a segmented, above-grade settlingpond and transferring the tailings liquids to an enclosed, above-grade evaporation pond. Thereclaimed impoundment would be susceptible to erosion over the long term. Also the proposedliner has not been shown to be capable of reducing seepage to the maximum extent reasonablyachievable.

Alterna tive 7 involves the segregation of tailings sands from the slimes at liquids anddisposal of the sands in unlined trenches and storage of the slimes / liquids in clay- or synthetic-lined impoundments. The slimes ponds would be either above grade, partially below grade, orbelow grade. The proposed alternative would result in above-grade systems that would be highlysusceptible to erosion. Also, the cover over the slimes might not reduce radon exhalation to twotimes background.

10-20

Neutraltration of the entire tailings ( Alternative 8) might partially eliminate the need for aliner which is needed to prevent seepage,however, it has not been shown capable of retarding themovement of anions in the tailings. Neutralization of the slimes produced af ter segregation ofsands from slimes (Alternative 7) or neutralization of dewatered tailings (Alternatives 3 or 6)would appear to be the most effective programs. However, the supplemental costs for neutraliza-tion would be high, and are not considered to be justified at the present time by the benefitsgained at the White Mesa site.

For all of the alternatives considered, tne applicant muld be required fn implement an interimstabilization prcgram to minimize the blowing of tallings to the maximum extent reasonablyachievable.Based on the above discussion and evaluation of alternatives, the staff believes that thetallings managerv'nt plan descritied under Alternative 1 is the bes ' plan for the White Mesa

10.3.1) andsite when considered in terms of both the staf f 's perforrance objectives (Sect.economic f act ors. This alternative represents the most envircnmentally sound, reliable, andreasonable method of tailings management for the proposed White Mesa site using existingc o ercial technolorly. It should be noted that the choice of the preferred alternative isbased on present standards and existing tecnnologies. However. if the final Generic Environ-rental Impact Statement on Uranium Milling and associated regulations show that modification

.:ie chosen alternative is necessary, the plan will be changed accordingly.o.

10.3.4 Alternatives considered and rejected

Table 10.1 lists some of the additional alternatives considered and rejected.

Table 10.1. Alternatives considered and rejected

Alternative Peason for rejection

Precipitate radioactive and tonic elements T ec hnol og y is not develeped (wouldto to ttm o' the tail t ys pond and rewire a selectively perineablec or.s i der tnp cf talling as cover bottom liner)

install dratns t.elow pond to collect and Technolow is not available to allowdistrarge to a local waterway seetage water treatment sufficient

to a ttain water that is environ-mentally and legally acceptablefor release

of f site disposal in mines Control of transportation. unloading.stcrage, and placement cf thewastes in the man / small mines asell as montiering an.1 control ofw

racan gas ecossiors. particulateemis sions , ground a ter contamination,and ot%r detrimtal impacts wouldbe scry difficult (sect. 10.1.1)

Covering of the tailings with a synthetic AJditional overburden and topsoilliner material wth as concrete. aspealt, weald be rewired to redace ga Twi

or PK plastic to redace redon emanation radiation to the eatural backgroundlevel, to prevent plant rootpenetration into tee tailings, andto minimize erosion problems. Thecost of the cap would tre excessive.compared to cost of the soil theliner wwld replace. The integrityof the liner could not be guaranteedover the long-term due to the effectsof freezing and thawing cycles. settle-ment of tee tallin95, and possiblechemical attack t)y the tailings

Transport of tailings to currently active Tre envircnmental hazards and the coststailings impoundments of mitigatinq the adverse impacts

associated with tailings disposalwould only be shifted from theBlanding area to another location.lhe closest active disposal areas arelocatej in Nab and Lasal. Neitherimpoum1 ment is Capable of holdingthe dest 1n output of the proposed mill.Addittonally, transport of tailingswould incur risks of accidents. dis-persal of tailings, and exposure toworkers and others along the transportroute

..____ _

_ .

10-21

10.4 ALTERNATIVE OF USING AN EXISTING MILL

The option of utilizing existing ore processing mills requires the evaluation of numerousfactors, including (1) the method and distance of mine-to mill transport, (2) variations inare grade, (3) quality of haul roads (4) total tonnage to be transported, (5) haulage sched-ules, (6) traffic and weather conditions (7) possible interin transfer and storage costs,(8) handling and milling costs, and (9) environmental costs and benefits.

The nearest currently operating uranium ore processing facilities (in relationship to theapplicant's Hanksville and Blanding are buying stations) are locateri in Mnab, Utah; La Sal,Utah; and Uravan, Colorado. The approximate highway distances of these mills from the Hanks-ville and Blanding stations are, respectively, Moab,189 km (118 miles) and 134 km (84 miles);La Sal, 243 km (152 miles) and 74 km (46 miles); and Uravan, 339 km (212 miles) and 170 km(106 miles).

Although the mill located in la Sal (Humeca) is reasonably close to the Blanding ore buyingstation, it would have drawbacks as an ore processing alternative for the following reasons:

1. The Humeca mill utilizes an alkaline leach process. Although tests conducted by theapplicant indicated that some of the ores bought by its are buying stations could besuccessfully treated by alkaline leaching, higher recovery rates could be obtained withacid for the majority of the cres. Because most of the ores are low grade (about0.125!), any significant lowering of recovery rates would decrease the economic feasibil-ity of ore shipment from the scattered, small mining operations.

2. Currently, only ore from a company-owned and company-operated mine is being processed;therefore, it is questionable whether the mill has the capacity, processing capability orthe willingness to accept additional cre.

The mills at Moab and Uravan utilize acid leaching (the Moab mill also has an alkaline leachcircuit); therefore, with process adjustments, acceptable recovery rates could be obtained.However, primarily because of high haulage costs and the limited capabilities of the mills toprocess additional ore, the staff has concluded that processing the ores at either or at bothof these mills is not feasible. Assuming that (1) transportation costs are 10e per ton-mile 6

and (2) the average grade of the ore bought at the applicant's Hanksville and Blanding ore-buying stations will be 0.125%, the staff estimates that, if the rre is shipped to thesecurrently operating mills, costs of producing each pound of U,0, would increase by the followingamounts for additional transportation costs alone (i.e., does not include incremental costfor toll milling):

1. Moab mill - $3.20 per pound.

2. Humeca mill (La Sal) - $3.04 per pound.

3. Uravan mill - $7.84 per pound.

Transporting the ores to existing mills could reduce the total land requirements for processingthe ores. However, the environmental costs associated with uranium ore processing and tailingsdisposal would not be decreased and would only be shif ted away from the Blanding area to thearea of the mill receiving the ore. If the proposed mill is not constructed, there is a highprobability that other mills (or expansions in capacity of existing mills) will be proposed inthe area to process the ore now programmed for the applicant's mill. If no mills (or expan-sions) are constructed, a substantial economic base for the Hanksville-Blanding area will beremoved because many of the small independent mines would not be economically viable.

_._

10-22

10.5 AtTERNATIVL INLRGY *,00RLl5

10.5.1 F oss i l an.d nuc l ea_r f uel s.. -

10.5.1.1 In t roduc t_lon.

The uso of uranium to fuel reattors f or generatin<3 electric power is relatively new histori-cally. Coal was the f irst f uel used in quantity for electrical power generation. Coal usewas reduced bec ause of the ready availability and low price of oil and natural gas, which arecleaner bur ning than coal and easier to use. Uranium fuel is even cleaner (themically) thanoil or qv, and at precent is less estensive, on a thermal basis, than any other fuel used togenerate elettrit power. The followinq discussion concerns the relative availability of fuelsfor power generation over the next 10 to 15 years and a comparison of the health effects ofutiliting coal and/or nuclear f uels as eiergy sources.

10.5.1.7 Overv.iew of U.S energy, age anej_availabilj ty;

According to the n ei. +: n ib r i i m, published by the Carter Administration in April 1977,,

the United States uses tuore enerqy to produre qoods and services than any other nation andconsumes twlte as much energy per (apita as does West fiermany, which has a similar standardof l i v i ng '. I ' in 1975, the United States consumed approximately 71 quadrillion Btu's(71 x 10- ), or 71 quads (q), of energy, with about 93% of this energy being supplied by threefossil fuelu oil, natural gas, and coal. h Approximately 75% of our enerqy needs aresupplod by natural gas and oil; however, because domestic supplies of these valuable resourcesare limited (about 7% of proved reserves are oil and gas), ' he amount of oil imported f romforelyn sourfes has increased, undermining our military and economic security. h Table 10.?illustrates the disparity between availability and usage of energy sources in the United States.

T able 10 2. Heweven and current consumptu,n of annegy . urrei

eencnt y of po,ven U h energy een cedag of total U s energy, ~ , ,,, e m .. .,, m. . n , . n, .. .t .i, m.,_e, ,,,r, r . ,m,, a,o , a ,,,with en estarw)(191s) ter hoolvigy e4, h energy r,g.,on o

Coal no 180;I 3 46Gu 4 2nNuc le ar 3 3O s her o $

%un e l ate 4 T ee b. Int . / riery;y /.a r nonA l'l//, pe ce ped inwice the d.rce tion ofthe D r re test , Navy ( tierq r ar.if Naritinal Hessissr(eg Hesees t h aiul (),*vele y,anent Of f g e,A pr .1 I q / /

Despite concentrated ef f orts to slow down our consumption of oil and natural gas, increase theusage of coal-burning f acilities, and further the utilitation of nonconventional (nerqy sources,energy demand forecasts indicate that by the year 2000, approximately 43% of eur energy willstill be supplied by oil and gas, 215 by coal, and only a small percentage (77) by solar, geo-therrut, and oil shale (Table 10.3).I'

Table 10 3 f orecess of gro s energy a,niumpt ori for 19110,198s aint 2000_- - . - . _ . . _ _ . .___ __ - .._.._. _ _..

19HO IWs 2000- ._. -.- - . . . . . . . . . . . . _ . . . - - - - . . . .

P*"*"'+*gg ; Htu 10' ' Hm P#"'*" ' *9* P*" *" t *9"t10'3 HNni gr nu of geou r,f ge nn

~ . . - . - - _ - _ _ . . . ~ . . ~ ~ . - . . - . - - - . . . ~ . . - . . - . _ - -

Coal 17.150 19 / 21.2'/) 20 6 34. /'4) 21 3cen oleum 41.040 47.1 4s.630 44 1 51.200 31 3Natuest yds 20.600 21 6 20,100 19 4 19JdN) 12 0Oa shala 810 0H 5,130 3sNm leaf power 4.%0 b2 11,H40 11 4 4 6.01.10 211 2Hydropower eswl

geothe< m e 3.800 44 3.Bs0 37 0.010 37

Totals N/.140 100 0 103.640 100 0 103,4.10 100 0_._ - . _ _ _ . . _ - _ . _

Sor.n t e U S nareen of Menes, Unsteot Stsres (norgy throsafr the Veer 2000. December 1916

10-23

Of the 71 q of energy consumed in the United States in 1975, 20 q consisted of electric energy.An esticated 8.6% of this electric energy was generated using nuclear fuels, but within tenyears this percentar;e is espected to increase to 2fA Coal was used for producing 59 of theelectric energy generated ty cont >ustion of fossil f uels in 1975; oil and gas produced 20 and217 respectively. Use of oil and gis to generate electric power has decreased about 10 overthe last three years, a reflection of high oil prices and gas unavailability.Il

Current and projected requirements for electric energy (1970-1935) and relative changes inht report ll are shown inresources used for generation, as estimated in the Th .i _ D. r

Table 10.4. The evidence available at this time indicates that, of the resources currentlyused in electric-power generation (coal, uranium, oil, gas, and hydro), coal and uranium mustbe used to generate an increasing share of U.S. energy needs. The supplies of oil and gr,available for electric power generation are decreasin1 and the United States dces not havesufficient oil ani gas reserves to ensure a long-run supply.

Table 10 4. E stimated relative chenes en resources to be usedfor generation of prosected electric er ergy requerements

Thermal energy reqmred by years, %Fuel remurce uwd

1970* 1974 19de# 19tVf6

__ _ _ .

Coal 45 45 45 4tfO,Iandgas 38 34 25 16

#N ucle ar 2 4 ll 26Hydr o. waste. etc. 15 1/ 13 12

Tntal qmeds of energsr e q u.e ed 15 6 20 25 5 34

* Actual%timated from f eder al Energy Administrat:on. Narumf

f riergy Our/ooA. U S Government Prmt nq O'fice. Washmgton. D C.. Februar y 19 76.

' Coat usage must mcreaw 7 7% by 1985 to attain this level#Ur an,um f ueled reactors f urrmhed 9 % of the total U.S

production m January 19 76Source Ferke al E nergy Admen stration. Profert /ndepend

em e, US Gover nmen t Pe mteng Of f 4e. Washmoton D C.,November 19 74.

With increasing energy demands, both foreign and domestic, expectations are that in the nextfew decades the prices of oil and and gas will increase rapidly as reserves of these tworesources become severely depleted. Because of the time lag between initial extraction andconsumption of tbc rasource for energy production (three to five years from mine to generationplant for uranium and coal, five to seven years for construction of a coal generating plant, andseven to ten years for construction of a nuclear generating plant), the exploitation of bothcoal and uranium resources must be integrated with contemporary energy needs. Although coaland uranium resources are adequate for foreseeable energy needs, major expansion of bothuranium- and coal-producing industries will be required, _. neither of these industries is con-sidered capable of singly supplying future energy requirements.

The determination of availability of uranium in large enough quantities to fuel the projectednuclear generating capacity (for 1935 and beyond) is currently a matter of study. !" Resultsof those studies are given in Appendix B, which includes an estimate of reactor installationthrough the year 2000 and the relative percentage of total electricity-generating capacitythese new installations would represent.

10.5.1.3 Coal oroduction

Congress and the Carter administration have stressed, via passed and proposed legislation,the necessity of future decreases in oil and gas demand to alleviate cur dependence on foreignenergy sources and to reorient our energy consumption patterns. The Project Mcynhn3report of November 1974 and the X1tiaul D:crj Oatknk of February 1976 both proposed that

10-24

coil production tm insreased f rom present levels (approximately (50 million tons per year) toapproeiru tely 1.7 billion tons by 1%5. I' ,l ' The malor espansion of coal pr oduction will libelyt.e in tr e west (f rom a; proeinately 92 million tons in 1974 to about 330 million tons in 1935),because of the low sulfur ()ow air pollutant) content of cost western coals The potential forenv irurr,en tal d ri. age (due tc di s tur bance of <p r i r.ill y fragile ecosystems) in the westernUnited States will t e increised. Em aEe the o a lcr markets for the coal produced will be locatedhundreds of miles from the western nines, transportation costs will le hi@ , as w'll the envi-ronn.en t a l ir. pac ts associate 1 with tran',portation system' Currently, transportation costs forbrir.ging western coal to the eastern United States account f or the ma jor por tion r f the marketprice. Also, for a given thermal content, transport f acilities for U A per year fire minimalcompared to those f or coal t ecause of the much higher energy content of uran!un fuel. Approxi-nately ?$0 tons of U,0- per year are required for a 1000-MW nuclear plant eperating at a plantf actor of 0.8, Annual western coal requirerents for an equivalent 1000 #W coal piant would f.eFore than is lfr tons, or the load capacity of at least one unit-train (100 cars of 100 tonsec h), per diy of plant operation.

10.5.1.4 U ra n i ur i f ue l, p rod _uc t i on

E stima tes present ed in the 'i a l > !> n. v' A' indirate that 140,000 to 150,000 PWo ofnuclear generating capacity will be needed to supply PM of she total electrical enerqy used in19a5. The first ie 't ,, e l'rerort indicated that nuclear capacity could increase. . ,

to more than 200,000 MWe by 1945. A nore recent and Inwor estimate resulted f rom lowr projec-tions of elec tricity der.and, finar.cial problems experienced by utilities, uncertainty aboutgovernment policy, and continued siting and licensing problens The more recent projectionsof urantun requirew nts are given in Table 10.5.

Tabl,10 5 Ursmum requiremerits_ _. _ _ _

t A v.nc U 0 reqwrernents noin)3 3MWe nier at +9 ,,, ,p,,, a ca pMt M f or

by 14Ws --

oH ob

e 47, coo 960.000 /04 000

Sour c e F raeral [ nergir Aarmnatrat or N.rreeuw/ i neryyOor6 =4, U e, Goven. ment Pr.n t a q OHme. Wehuwfon [] C .F er r oar y 1916

lable 10.6 presents estimates of quantities of uranium available at dif f erent recovery costlevels. Assuming reserves recourable at a forward cost of production up to $30/lb of U 0 ,3 cthe Department of Energy (DGE) estimated that in January 19,~d the total of all variously knowncategories of uranium resources was approximately 1.M x 10' tnns.3' An estimated 6.9 x 105 tonsof these resources consisted of knnwn reserves, that is, drillinq and sampling have estat>lishedthe existence of ttese '. ; o'.i ts t e rnd reasonable duubt. I ' Approximately 5.2 x 10' tons ofU ,0 a could be recovered f r w very low grade ore and Chattanooga shale for about $100/lb andapproximatel{4x 10' tons of U,0 f rom seawater for an estimated cost of tetween $ 300/lb and$/50/lb. *

Table 10 6 U S. utamum(U Od rewsurus3

Ce nt r ateq< w y* n. ,e r ves'' Po t r h ''d' ' r 5' ""4 "$ ( f o'"I__

(5 lb) ( t ond Pr obabb/ Pms bie %pe r.ot a t , v e#d

1s 310 000 'Ao oco 490.000 165.000'10 6'M),000 I.015.000 1.135.000 4t5000

50 Huo.000 1.3'J5,ono 1,515.000 %5 orx)- -

* I 4. h e o't i atmvr y uw luaes all lowrr < ust ewe ves arwl res,mertes

be #f ve's are ifI kiKfWH t$11msits' er en..ble rem,rtes have cot been rir almi arat s,iny,but as e n fermely as

e cwe v nd

eossade avut seemlatrve rescastr es have treo ntimarea by ardeerrwe ferien(p-oh ey ev.<ler< a and I trote a umphrvj

% rte Degw twent of f nergy. Statista I vara of the Uranrurn In<sustry,Heport G JO Ino!18). Jon 1.1978

10-25

Historically, resources of uncertain potential have becore established at an average rate of7% per year since 1955.1' If this rate were to persist over the next decade, total reserveswould exceed requirements (1,340,000 tons of reserves vs a maximum 960,000 tons required forlifetime nuclear generating capacity rated at 142,000 MWe) by about 380,000 tons. Assumingno transfer of possible resources into the "prcbable" category, probable resources would stillcontain 430,000 tons

Mill capacity in the United States as of January 1978 was 39,210 tons of ore per day. Thesenills operated at 79: of capacity in 1977. Uranium oxide output was approximately 14,946 tons,equivalent to about 2.5 lb of U 40, per ton of ore.

A survey of U.S. uranium marketing activity completed by ERDA in May 19772 indicated thatannual contracted daliveries of U,0< for nuclear-powered electric generation plants (assumingno recycle of pluton um and uranium and 0.20 uraniur'-235 enrichment plant tails assay untilOctober 1, 1980, 0.251 thereaf ter) will exceed annual requirements until 1979 (see Fig.10.8).Contracted imports of U,0 will exceed contracted exports by a considerable nargin over thenext few years. Through 1990, cumulative contracted imports of U30< are 47,200 tons (approxi-mately 50: of f uture contracted imports will come from Canadian sources), cor' pared to 13,500 tons

requirements, donestic deliveries, irrports,to be exported. Figure 10.7 illustrates total emand exports through 1990.

(5404sg

,s~ m , ~~

/m'w"#40--- / HtcuiHivtNTS

/ r0 20 T All s 11N Tit/ 10180 0 25 THE F4 Af 1i H

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76 77 78 79 80 81 82 83 84 85 86 87 88 89 90

YEAR

Fig. 10.7. Summary of uranium requirements and delivery commitments as of January 1, 1977.Source: Energy Research and Development Administration, s m ey of W ite<! stat.y crinim virket-iny Anicity, Division of Uranium Resources and Enrkhment, Of fice of Assistant Director ofRaw Materials, May 1977.

Cumulative U.S. supplies of U 0g (including domestic and foreign inventories and contract3

comitments) will exceed DOE enrichment feed requirements until 1983. The gap betweencumulative suoply and cumulative requirements is expected to be approximately 58,000 tons by1985 and widen '' approximately 233,000 tons by 1990 (see Fig.10.8).

10-26

f 5 4612St h) -

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l' i i l 1 1 I I | | | | 1 1

nri ntu con mo iwi om/ 1981 om4 vms rme, emi rma Im iuo

Fig. 10.8. Comparison of U 0 requirements and contracted deliveries plus inventories.3 3

Source: Energy Research and Development Administration, J:arv y of Drite l 1 t 4tu umniwi Mvht-in, A civity, Division of Uranium Resources and Enrichment. Office of Assistant Director ofRaw Materials, May 1977.

10.5.1.5 Comparison of health of f ects of the uranium fuel cy_cle_and the coal fuel cycle

Research conducted by the U.S. Nuclear Regulatory Comission23 comparing the health effectsassociated with the coal fuel cycle (mining, processing, fuel transportation, power generation,and waste disposal) and the uranium fuel cyt.le (mining, milling, uranium enrichment, fuelpreparation, fuel transportation, power generation, irradiated fuel transportation, and wastedisposal) indicated that increases in the use of coal for power generation may cause the adversehealth impacts related to electric enerqy production to increase. As defined by the study,health ef fects are stated in terms of " excess" nortality, morbidity (disease and illness),and injury among occupational workers and the general public, where " excess" implies illnessand injury rates higher tian normal and premature deaths. The estimated excess deaths per0.8 qigawatt-year eMtric [GWyr(e)) (i.e. , per 1000 MWe power plant operating at 80% ofcapacity for one yea,) were 0.47 for an all-nuclear economy (assumes that all of the elec-tricity used within the nuclear fuel cycle is generated by nuclear power) and 1.1 to 5.4 f f allthe electricity used in the uranium fuel cycle (primarily for uranium enrichment and reactoroperation) came from coal-fired plants. Excess deaths for the entire coal cycle varied from15 to 120 per 0.8 GWyr(e). Mortality estimates are shown in Table 10.7.

Excess morbidity and injury rates for workers and the general public resulting from normaloperations and accidents in an all-nuclear cycle were estimated to be about 14 per 0.8 GWyr(e),with injuries to miners from accidents (falls, cave-ins, and explosions) accounting for ten ofthese occurrences. If all the electrical power used in the uranium fuel cycle originated fromcoal-fired plants, these rates would increase to approximately 17-24 per 0.8 GWyr(e). Theestimated excess disease and injury rate for the coal cycle was 57-210 per 0.8 GWyr(e). Coal-related illnesses among coal miners and the ganeral public and injuries to miners account forthe majority of nonfatal cases. Table 10.8 illustrates these comparative illness and injuryrates.

10-27

Table 10.7 Current energy source escess mortality summary per year per o 8 GWyr(el power p;ent

Occupat orial General pubhc_

Acci+nt Disease Accident D.sease

Nuclear fuel cycle8

All nuclear o 22' O.14" o 05' o 06 0.47

With 100% of the electe.c t y used in the G 24 - 0 25* ' o 14 -o 46 ' o.1o -8 o 64 -4 6* 11-548 r

f ael cycle gr uOted by coal powe #

Coal f uel cycle

Reg,onal population 035-065' o -7' 1 28 13-11o* 15-120

Ratro of coal to nuricar: 32.200 (all nuclear L 14 ?? Iwith coal powerP

8Pr1mardy f atM nontadiological acc+nts, sah as fMrs, emplosions, etc.*Pnrnarily f atal radiogemc cancers and leukemias from normal operations at mmes, mills, power plants ard

reprixessing plants.'Pomanly f atal transportation acc+nts (Table S 4,10 CF R Part 511 and senous nuclear accidents.# U.s population for nuclear effects. regional population for coal ef fects'Pnmanly f atal mining accidents, such as cave ms, fires, emplosions, etc.'Pnmanly cual workers pneumocnnios s and related resp 6ratory diseases leading to respiratory f ailure.'Pomarily rnemtwrs of the pneral public kdfed at rail crossmgs by coal trams." Pnmar dy respiratory f adure among the sick and elderly from combustion products from power plants but

mcludes deaths from waste coa! bank fires'Iorn at ,:1 e!ectocity consumed by the nuclear fuel cycle produced by cam power, amour,ts to 45 MWe per o 8

GWyr fe tSouic e: R L Gotchy, Health Effects Attnbutable to Coal and Nuclear fuel Cycle Alternatnes, Report

NURE G 0332, D.wiuon of Site Safety and Environmental Analors Of fice of Nuclear Reactor Regulation. U.S.Nutlear Hegulatory Commission, September 1977.

Although the adverse health effects related to either the uranium fuel cycle or the coal fuelcycle represent small additional risks to the general public, the study concluded that " .

the coal fuel cycle may be more harmful to man by factors of 4 to 260 depending on the effectbeing considered, for an all-nuclear economy, or factors of 3 to 22 with the assumption that

"all of the electricity used by the uranium fuel cycle comes from coal-powered plants(ref. 23, p. 13). Additionally, the Impact of transportation of coal is based on firm'

statistics; this impact alone is greater than the conservative estimates of health effects forthe entire uranium fuel cycle (all nuclear economy) and Can reasonably be expected to worsenas more coal is shipped over 1reater distance . . (ref. 23, p.13)."

10.5.2 Solar, geothermal, and synthetic fuels

Estimates reported in the li2ti m ? Ners cattookl6 indicate that solar and geothermal sourceswill each supply about 1% of U.S. gy requirements by 1935 and about 2% by 1990. Suppliesof synthetic gas and oil derived f:, 'oal will probably not exceed 1% of U.S. energy reouire-ments as of the year 1990. These pro;ections are based on many considerations. The technologyexists in all cases but not in a provrn, commercially viable tranner. The potential for provingthese technologies on a cemercial scale is great, but timely development will require a favor-able market as well as governmental incentives. A maximum of 6% of projected 1990 energyrequiremente is expected to be derived from solar, geothermal, and synthetic fuel resourcescombined.

The NMonal Dmry ?!ad 3 does not set specific goals for increased use of synthetic fuels orgeothermal energy, but does state that, as a possible goal, solar energy will be used in2.5 million homes by 1985.

10-28

Table 10 8. Current energy source summary of excess mortudity and maury per 0 8 GWyrW power plant

Occupat onal General publ.ci-- Totals

Mor tmlity inpry Merbutity Insury

Nuc' ear fuel cycle

#All nudeat o 84* 12'' O.78' o1 14

W th 10m, of electricity uwd by etw I7-41' 13 -14* 13-538 o 55^ 17-24fuel cycle produ ed by coal sw>wer"c

Coal f uel cycle

Region t population 20 - /o' 17-34' 10-100' lo" 57-210

Hano of mal to notlear ; 4.1 15 (all nuclear). 3 4 8 8 (w.th coal power f

*Pnmardy nonf atal rancers arwi thyrout norfules.''Primar dy nonf atal ingue ses amoated with accitients in uranium m.nes, such as rock f a:fs, emplosrons, etc.'Pomanly nonf atal canc ers, thyroid nodules. genetically # elated d,scases, and nonf atal dineswg following high

rad.at'on dows, mch as ta hitron thyrodtis. pec/ftomat vormting, and temrergary stent ty# Transportation related enturies froen Table S 4.10 CF R Part 51.'U S. pupulation for nucicar effects, req,onal pmulat un for coal effects.'Primardy nonf a as diwa es anocated wita coal minmq, such as coal wo#kers pneumocontosis, twonchitis,r

emphywma, etc8Pomarily respiratory diseases arnong arfults and children from sulfur em.ssions from coal fired power plants but

mcludes waste cor; bark fires

"Pomarity iny.cs to coal miners from cave ins, fires, emp8os oris, etc.'Pnmardv nonf atal miones among members of the general public from collisions with coal trains at radroad

CT OM uigt

'10fh, of all electsirity cor*sumed by the nuclear fuel cycte produced by coal power, amounts to 45 MWe per o 8C h yr d e t

Source' R L. Gotchy. Health Effec ts Attninitable to Cool anti Nuclear fuel Cycle Attematwsz ReportNUH E G o332, Div.sion of Site Safety and E nvironmental Analyus, Othee of Nuclear Reactor Hegulation, U SNuclear Hewlatory Commmion, September 197 7.

10.5.3 By-p_roduct uranium

Uranium recoverable as a by-product of phosphate fertilizer and cooper production is estimatedto be 140.000 tons through the year 2000.11 These reserves are in addition to tte 690,000 tonsof $30 uranium available from conventional mining and milling sources.

The following is noted in a report by the National Academy of Sciences:24

L.ike all by-product comodities, by-product uranium is entirely dependent uponpecduction of the primary comodity, is limited in amount by the level of productionof the primary cocmodity, and is unresponsive to the demand for uranium. By-producturanium couid be obtained from the mining of phosphate, copper, and lignite.

Much phosphate is treated with sulfuric acid to produce fertilizer and goes througha phosphoric acid step. Uranium in the phosphate can be recovered from thephosphoric acid. . . It has been estimated that about 2500 ST V 03 per year3could be recovered from Florida phosphate mined for fertilizer.

The Bureau of Mines studied the sulfuric acid leaching of low-grade dumps at 14 porphyrycopper mines and concluded that about 750 ST V 0g per year could be recovered. This

3

would be recovered from rocks whose uranium content ranges from 1 to 12 ppm.

The Bureau of Mines thought that other porphyry copper deposits might also be possible sourcesof by-product uranium.

The staff has studied available uota on the potential of uranium production from phosphatefertilizer production 2s and from copper dump leaching, and estimates that production couldreach 3000 to 5000 MT (4000-6000 tons) per year from phosphoric acid extraction and 400 to900 MT (500-1000 tons) per year from copper dump leaching.25,26 Much effort has been expendedto determine the amounts of uranium that might be recovered from coal and lignite. Some uranium

. . . . _

- - - - -

10-29

was recovered from lignite ash 'n the early 1960s, but the lignite itself was not a suitablefuel for the process; supplemestary fuel was needed for the necessary conversion to ash. Nouranium has been recnvered as by-product from the ash of coal- or lignite-fired power plants.Ash samples continue to be analyzed for uranium, bat to date no ash containing more than 20 ppmU 0,3 has been found, and most ash samples contain from 1 to 10 ppm U 0a. "3 3

10.5.4 Enersy_conservatinn

The cornerstone of the ti2ttn ! D erryj TI m is conservation, the cleanest and cheapest source*

of new energy supply.

If vigorous conservation measures are not undertaken and present trends continue, energydemand is projected to increase by more than 30; between now [1977) and 1985.13

T he 'i s t m:a? D:ow !1m lists the following consuming segments as being prime targets forenergy conservation:

1. transportation,

2. buildings, including residences,3. appliances,4. industrial fuel use, and

5. industries and utilities using cogeneration of electricity and low-grade heat.

Part of the twr:a! Dvej , llan will be the utilization of all possible governmental means(tax reduction, incentives, direct subsidy, and legislation and regulation) to change the pastrelationship between energy production and use of energy requirenents in the United Stateswhere energy usage is two times higher per capita than in other industrial countries forenergy consumption and production and energy use.

The ?,c us D:cejj F:m clearly states that both coal and nuclear electrical generationfacilities will be needed to meet estimates of U.S. energy requirements through the year2000, even if the conservation goals of the Plan are met. The relative amounts of eachenergy source used will depend on economic and regional environmental considerations.

10.6 ALTERNATIVE OF NO LICENSING ACTION

Among the alternative actions available to the NRC is the denial of a Source Material Licenseto the applicant. Classifications of source materials are discussed in 10 CFR Part 40.13(b);these classifications are based on Section 62 of the Atomic Energy Act of 1954, which specifi-cally exempts "unbeneficiated ore" from control. Under these regulations Energy Fuels couldmine the ore but could not process it, should the NRC deny the Source Material License.

Exercise by the NRC of this option would thus leave the applicant with three possible coursesof action: (a) mine the ore and have it processed at an existing mill possessing a SourceMaterial License; (b) postpone the project while attempting to remove the objections that ledto the denial of the license; or (c) abandon the project. Alternative (a) nas Deen discussea inSect. 10.4. Alternative (b) is essentially the applicant's proposal (merely shifted in time),which is the subject of this Statement. Alternative (c), therefore, is the only alternativediscussed herein.

If the applicant were not awarded a Source Material License, the uranium concentrate it intendsto produce would not become available for use as fuel in nuclear reactors in as timely amanner. The relationship of electrical energy produced by nuclear reactors to the total U.S.energy requirements has been discussed in Sect. 10.5.

The yellow cake produced by the White Mesa mill will contribute to the worldwide supply ofuranium which will be used as fuel in nuclear reactors that are either coeratino nr underconstruction in the United States or abroad. As was stated in Section 10.5.1.4 contractedimports of U309 will exceed contracted exports over the next few years. Lack of fuel wouldrequire those reactors short of fuel to reduce their output and could conceivably result inthe shutdown of some of them.

14-10

The applicant has indicated the ef fects of losses of local and regional economic benefits thatwould occur if the White Mesa mill were not licensed and has also pointed out the environ-it: ental costs that would not be incurred should no license be issued Overall, the benefitsaccruing from the mill out-elyh the costs.

10-31

REFERENCES FOR SECTION 10

1. D. A. Cl a rk , ~ * ite-of- %-A r t rev ne Miniy , Mil:iy , ani ? | in ig bu!acry, ReportE PA- 6f>0/2- 74 -033, National Environmental Research Center, Of fice of Research and Development.U.S. Environmental Protection Agency, June 1974

2. R. C. Merritt, % ' F. rte:' tin M. tAlajy of ":w:ite, Colorado School of Mines Research'nstitute, Golden, Colo., 1971.

3. Energy fuels Nuclear, Inc., " Proposed Tailings Disposal System, White Mesa Uranium Project,Blanding, Utah". Sept. 20, 1978.

4. Energy Fuels Nuclear, Inc., " Investigation of Alternative Tailings Disposal Systems, WhiteMesa Uranium Project, Blanding, Utah," April 1978.

5. Energy fuels Nuclear, Inc., " Report of Evaluation of Long-Term Stability of Uranium MillTailings Disposal Alternatives, White Mesa Uranium Project, Near Blanding, Utah,' Aug.11,1978.

6. U.S. Nuclear Regulatory Commission, f raft Ewirm.n - 7 .tatement Fe? !cl to !L 3!!nce:ZsE.rpivva t i v a q.s.y 's , u tnit er ten :c Tra|a r t , L it er l'>unty, n -iny, DocketNo. 40-8584 December 1977.

7. U.S. Nuclear Regulatory Commission, Firal rneirc untal rt ztc cut c7atcd to the '!uhbat ruth a !, Ins ta ky ?!s au lii !o Urs :ac Mill, Docket No. 40-2259, November 1977.

8. U.S. Nuclear Regulatory Connission, craft F miv mnta? Putemmt Felat.'! to the Orceztic-uf M > ; Fr:ni:c Wi!, Atlaa Wwr:|a Disicien, Attu ' r; . , ;rm! nunty, Utah, DocketNo. 40-3453, November 1977.

9. U.S. Nuclear Regulatory Commission, r2f a Eviv nr.c 4 N t.mme Fc iarc l t o the E w nMince z!s emow v. . A. , !!ip!and cr o ium |a * t cn Mirw:) Iv & ~ t , m eerc e C.:w; t y ,a

v;e ciy, Dod et No. 40-8102, May 197f..

10. U.S. Depar tment of Agriculture, f orest Service, pr2f' Fwiry,.-cnral ma gew,.* '' > r t h."

I!cmeat we Mtnz.cg C 7;' .y 's li+ h recj.n.!, :;p.w cmty, g*mp, ggjy j4, jg7g,

11. M. B. Sears et al . , Cet tefatien cf Radicac twe D!a ste 7 tcarmnt Oc5 05 and the inv ocn-F:sel C. h f:r Un in Eatab!!chiniw. r a: in; '* cf Wac *e Eff|:wn f a in t he %'|m v L

"Aa tco an I?; t ie rbic" Gaiha villiny ~f Unmi:e Dr.v, Report ORNL/TM-4903, voI .1,Oak Ridge National Laboratory, Oak Ridge, Tenn. ,1975.

12. D. Moffett, " Uranium Waste Pesearchers Consider Alternate Means of Tailings Disposal,"nc:. Min. J. , January 1977.

13. Executive Of fice of the President, & *!2ticrul. INerjy T'!m, Energy Policy and Planning,April 1977.

- w ?, prepared uncer the direction of the Directcr,14 Tetra Tech., Inc., Encejj F u r w

Navy Energy and National Resources Research and Development Office April 1977

15. U.S. Bureau of Mines, 7nitel eratcc E>arjg thec .A ti:e Ycar Ncc, December 1975.

16. Federal Energy Administration, S: tion! fnerjy catlxk, U.S. Government Printing Office,Washington, D.C. , February 1976.

17. Federal Energy Administration, treJeat Indqceleree, U.S. Government Printing Office,Washington, D.C., November 1974,

18. Department of Energy, I,atent Eatinate cf U. . "rmi;c im ?ar cc, April 1978.

19. Department of Energy, statistival ::ta of the Urani:e DLLatry, Report GJ0-100pd),January 1,1978.

20. f.w? car Neva, July 1975, p. 37 [ reprinted in Evrjy raathc.ok - 977].

21. U.S. Rureau of Mines, Receery of Drani:c fr* Im-Craie Fea mrc.w, December 7,1977(unpublished).

. .

10-J2

22. Energy Research and Development Administr ation, c;.re y | Unit / St a t. c Urw e'.'2r!.et inj A tic / * ,, Division of Uranium Pesources and Enrichment, Of fice of Assistant

.

Director of Raw Materials, May 1977.

73. R. L. Gotchy, H.1:*r ?' * t t ri!a t.:!,:. ta c : > ! <*',:n Fu.:: _..l. A:* e,:t! .'c,*. ,

Report NUREG-0332, Divis.on of Site Safety and Envirorrental Analysis, Of fice of NuclearReactor Pegulation, U.S. fluclear Regulatory Comission, September 1977.

24. th tional Academy of Sciences "".c.-r! i . . ar * 'a :! t b Fn'ir > .'nt. Qf 7.-~.: n t :rg/.;cr* ! . ac e: c :l li 4r - f tic :n De in t ; .. Washington, D.C., 1975, p. 106.. .,

25. J. Flerenic and D. Blanchfield, " Prod-;ction Capability and Supply (of Uranium)," paperpresented at Grand Junction, Colo., ERDA Uranium Conference October 1977.

26. J. F. Pacer, Jr. , " Production Statistics," paper presented at Grand Junction, Colo. ,[PDA Uri ilum Conference October 1977.

%

,

,

f

% -

.

. _ . --

11. NRC BENEFIT-COST SUMMARY FOR THE WHITE MESA URANIUM PROJECT

11.1 GENERAL

Implicit in the decision of a utility to construct a nuclear rswer plant is that the uraniumneeded to fuel the reactor is available (Appendix B). For each application to the NRC for apern.it to construct a nuclear power plant, an Environmenta' Statement is prepared which includesa review of the availability of uranium resources. The uraq1um to be produced by tne White Mesamill is among the total U.S. resources considered to be atailable to the commercial market forreactor fuel; thus, the uranium from this mill is needed tt neet the demands of the nuclearpower industry. In the Environmental Statement, the benefits (the electrical energy produced)of the nuclear plant are weighed against the economic end environmental costs, including aprorated share of the environmental costs of the uranium fuel cycle. These increnental impactsin the fuel cycle are justified in terms of the benefits of energy generation. However,because these costs and benefits are not localized, it is appropriate to review the specificsite-related benefits and costs for an individual fuel cycle facility such as the White Mesamill.

11.2 QUANi!FIABLE ECONOMIC IMPACTS

Section 4 of this Environmental 5+'rement treats the quantifiable ecoromic impacts for theWhite Mesa Uranium Project. On the une hand, many monetary benefits accrue to the communityfrom the presence of the mill - for example, local expenditures of construction and operatingfunds and payments of State and local taxes. Against these monetary benefits are the monetarycosts to the dif ferent communities involved - for exaNple, costs for new or expandedschJols and other connunity services. It is not possible to arrive at an exact numericalbalance between the benefits and costs for any one community unit or for the mill becausethe distribution of revenues to support services may not be timely or completely consistentwith those geographical locations where impacts occur.

11.3 THE EENEFIT-COST SUMMARY

As stated in Sect. 11.1, the benefit-cost summary for a fuel cycle facility such as the WhiteMesa Uranium Project rests on a comparison between the societal benefit of an assured U 0s3supply (ult' aately providing electrical energy) and local environmental costs for wnich thereare no directly related compensations. For the White Mesa mill, these uncompensated environ-nental costs are basically two: radiological impact and disturbance of the land. As shownin Sect. 4.7, the radiological impact of the White Mesa mill is acceptable by current standards.The disturbance cf the land, as shown in Sect. 4.2, is a long-term impact that is judged tobe small in comparison to alternative uses the land may support in the future.

11.4 STAFF ASSESSMENT

The staff has concluded that the adverse environmental imcacts and costs are such that use ofthe mitigatise measures suggested by the applicant and the regulatory agencies involved wouldreduce to acceptable levels the short- and long-term ad.erse environmental impacts and costsassociated with the project.

The White Mesa Uranium Project, along with other energy-related projects in tne area, willcreate a short-term stress on the political and social systems (including housing and schools)of the area. The quantity of total tax noney appears to the staff to be 3dequate but thedistribution cay not De (see Sect.11.2). This aspect of the project is currently receivingattention by the institutions directly concerned, and mitigation appears possible.

11-1

_ _ . .

.o

.

11-2

As was shown in section 10.5.1.4, U.S. requirenents for U Oa will exceed production capabilityfor the next few years. Although the applicant may expor', the uranium derived f rom the U303 4produced at the White Mesa Mill, the United States is a n't importer of uranium and f ailure tolicense the proposed project would only result in the foreign demand being filled by otherdomestic / foreign mills that could be producing uranium for consumption in the United States.

In considering tne energy value of the U 02 produced, minical radiological impacts , minimal3

long-term disturbance of land, and mitigible na'. ore of the impacts of growth on the local com-' munities, the staf f has concluded that the overall benefit-cost balan.e for the White Mesa

Uranium Project is favorable, and the indicated action is that of lice.: sing.

|

<.

J

_ _ _ _ _ _ _ _ _ _ _ . _ _ _

\

*.

:

Appendix A

COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENTAND ';RC STAFF RESPONSES

1

i

n

. _ _ - -

f

. . . _ _ . _ . _

_ _ _

Appendix A

COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENTAND NRC STAFF RESPONSES

In this appendix, the letters of comment on the Draft Environmental Statement pertaining tothe White Mesa Uranium Project are reproduced in full. The staff respanses are printed con-veniently close to each connent. Specific comments and responses are keyed by numbers in themargins of the letters and at the beginnings of the corresponding responses. In addition,changes in the text have been made where needed.

Letters of concent were received from the following:

U.S. Department of the Interior +

U.S. Environmental Protection Agency, Region VIIIAdvisory Council on Historic PreservationU.S. Department of Health, Education, and WelfareDepartment of the Anny, Corps of EngineersU.S. Department of Agriculture, Soil Conservation ServiceFederal Energy Regulatory CommissionU.S. Department of Agriculture, Science and Education AdministrationU.S. Department of Transportation. U.S. Coast GuardState of Utah, Department of Social ServicesState of Utah, Department of Development ServicesUtah Department of Employment SecurityWilliam A. LochstetR. W. BergCi+y of BlandingCi;y of Monticello

San Juan School DistrictSan Juan Center for Higher EducationCollege of Eastern UtahChurch of Jesus Christ of Latter Day SaintsJim Dandy, Navajo Indian TribeCouncilman, White Mesa Ute TribeChamber of Commerce of Monticello, UtahA. W. EgbertJohn Mitchell, Wasatch Financial Corp.Tom Redd, Wasatch Financial Corp.E. A. BlackZelma ActonCalisbee BlackEarl E. StevensPhil B. ActonE. Brent Redd, Abajo Petroleum, Inc.Jim H. ActonCity Council of Monticello, UtahKay R. Johnson, JTN Insurance, Inc.Robert E. and Joan Hosler, Thin Bear Indian Arts, Inc.

A-3

..

_ _ _ . . . _

useasts

gh'h United States Department of the InteriorCQ'Eld?~ ./ 01IICE OF TfiE SI CB E1 ARYYd % ASi![M.J t u, ll C :n DO

In Ecply Re fer Tc IES I IECS-I'R- 7 8 /122 2Matt Stop 760

Mr. Ross A. ScaranoUranini Pill Licensir,z SettienDivision of Fuel Cycle and

Material safetyNuc1 car R( quiatcry CarrissienWashington, D.C. 20555

Dear F.r. Scarane-

the Departrent'ef the Intericr's c cmren t s on th draf*. ' . /3'1This is in resacnse to your let ter of Decemter 15 recuesting

f

environment.41 s t a t ea . er cc.e ro t ien of the b~.ite P.esa b l ' / '/j',<Uranium Pr3 ject. Jan Juan County, Utah.

We find that the draft s ta tc* m " is ir:ce :rlete in its treat- /// P''

me-nt of cultural and receratfor.11 rnscurces, and that a k''/),,jA *fuller di:cussica ei t>e ini:astructure cf the local c r- M/ , // A

*munities "oe;et he r with the pot ent ial impacts, includ. ;

/financial turdens. c.n these co r ities is warranted. (g f- ',Further discussian of the impact o. the project or recov-

erability of mine rai rescurces erber than uranium is also N 4/V ,

desirable. ,

h,The statement should deal mere adequately with the avail-ability cf tround water and with potential centa-ira 1:n cfwater resources, especially with regard to the lor.g-t ystability of mill tailir.gs

CENERAL CC:Cri::TS

The draft statement dees not adequatelv discuss project A. Sections 2.5.2 and 4.2.2 have tseen revised and Appendia E has been includedimpacts to arche nog' cal resources, aaJ the cor pliance with concerning the currently identified cultu al resources and the mitigatoryr

historic preservatten laws and reculations is incomplete. actions that will be taltefi,

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Although at least 78 archeological sites have been iden-tified in the project area by field survey and preliminarytesting, there is no indication that the eligibility of thesites for the National Register of Historic Places, eitherindividually or as a district, has been determined pursuantto 36 CFR 63, nor that consultation with the Advisory Councilon Historic Preservation required by 36 CFR 800 has taken place.These steps should be completed prior to preparation of thefinal environmental state:.c;'t. As the statement recopizes(p. 4-4). "a precise statement of impacts is not possible,since further consultations are needed to prepare an appro-priate avoidance / mitigation plan and conclude the Memorandumof Agreement. When this is done, the statement shculd berevised to discuss both the specific mitigation measurest ha t have been agreed to and the extent and severity ofremaining unavoidable adverse impacts to archeologicalresources.

The discussion of alternative mill sites concludes that on B. Modifications to the applicant's croposed tailings impoundnent plan (sect. 3.2.4.7)the basis of socioeconomic and transportation impacts there will result in impacts to a smaller land area. The staff also agrees with theare "no better" alternative sites in southeastern t' rah Utah State Historic Preservation Of ficer (5HPO) Apoendix A, p. A-35, that(p. 10-2, par. 2). It appears, however, that alternative archaeological resources would not result in the c% ice of anotter of thesites have not been evaluated on the basis of impacts to alternative sites in this case.

environmental and cultural resources. In view of the den-sity of archeological sites on and in the vicinity of theproject area, as well as the amcunt of land disturbancerequired to construct the mill and tailings ponds, we rec-ommend further study to identify alternative locations withlower densities of archeological sites and thus lesser >

aimpact s to these resources. Any analysis of such sites_ should be included in the final statement.

We are concerned that.the statement does not adequately C. A detailed listing of present and proposed recreational f acilities in the com-recognize the effect of population increases on recreation munities of Blanding, Monticello, and Bluf f has been added to Sect. 2.4.2.1. In

. . _resources and facilities in the projen area, particularly light of the planned expansion of local f acilities in Blanding and Monticello.

_J- in the community of Blanding. There is no discussion of the where the bulk of plant-induced inwgration is espected, and the abundance offacilities in or capacity of the fr ar public parks in Blanding, n.sart+y Federal and State recreation areas (Table 2.7), the staf f judgment that,*

_but simply the statement that the acilities ar g" adequate" current and m acted populations can t'e adequately served appears to be(p. 4-7). Although these may be dequate for the'present justified.

population, it is not clear whether the facilt ies couldaccommodate a population increase of nearly S N ercent. 4. Regarding the provision of other public services and their associated costs,

in- Sect. 4.8.2.2 discusses the capability of present and planned f acilities to*Moreover, inviewoftheprojected$1.5to$2mitkyng accorriodate anticipated growth in the conriunities surrounding tne proWedthe conclusion that , fallcosts and the apparent s..d r sC_. crease in local government 4

White Mesa mill. As stated there, Blanding is planning to expand water and'tQ' % sewer f acilities to accocrudate expected plant-indated population growth, andin tax revenues (pp. 4-19 and 20),t~ C impacted communities will be able to provide services for

C the expected population influx without long-range fiscal %_ Moni.icello is working on improvements to their water supply, sewage treatment,and electrtgity distribution systems, an ef fort also aimed at accooriodatingdifficulties" appears unwarranted. g'(en g row th . The capital for these improvements is expected to come from a variety

.of sources, with Federal and State funds significantly bolstering the localciwQbut dF.

CJ The $1. <to $2 million annual operating costs cited earlier will be cet by avariety of sources; the combination of property and sales taxes with the utility's[s .};g operating income and other revenues is expected to balance needed empendit. ares,&'7 supporting the staff's original contention that the provision of services should

r[ not entail long-range financial dif ficulties.'

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3 RE SPohsts

The final statement should analyze the capacity of existing D. The response to the previous coment outlined tee capacity of esistieg andfacilities to accce odate projected population increases, plannej recreaticral f acilities to accorrodste projected local copulation growth,recognize the adverse effects resulting from anv inadequacy Continuing company co@eration eith local ccer'untties 45 evidenced by housingof capacity, and discuss e at action will be taken by the planniy (Sect. 4.S.6) is expected in the future.Nuclear Regulatory Cerr-ission and the project spensor toassure the provision of adequate recreation facilities. !n E. Petertially cwercial coal cccurs locally only in the Cakota Formation. Noparticular, we urge that the pro}ect sponsor explore with coa! is evident in the local [0.8 to 2.4 km (0.5 to 1.5 ri resM outcrops erlocal officials and the l'tah Outdcar Recreation hency nas been cbserved der 1N well drilling on the site. Uranium-vanadium descsitsvarious means of providing aid for the develcpment of needed could occur in the Morrison remation at doths or 70 to 280 m (23010 920 f t)recreation facilities. at t he site. If deposits are present, undercround miat'n would be redired and

the tallings area would net pre <.lude this. 011 egloration and pcssitie productionE Known mineral rescurces in the millsite vicinity include would not tie af fected tecause tco casing would be set below the tail 1Ns or of fset

uranium-vanadium, coal. copper, and sand and gravel. These drill teg techniques could be used.resources are discussed in general and it is pointed outthat seven petroleum test wells drilled about 4 miles vestof the site were dry. We believe, bewever, that more n'ightbe said about the possible co= itment of mineral resourcesunder the tailings area because co= itment of tt.e 450 or soacrea required for this use is virtually permanent Thus,in additior. to the general statement in sectibn 2.7.2.1(p. 2-36), something should be said as to whether or not anyexploration or evaluation has been dene to determine thepossible loss of resources under the preposed tailings areas.A map showing proposed or existing mining operat'5 ns thatwould supply this mill veuld be helpful in identifyingthe need for the project.

SPECIFIC COMPEh~rS

O1 Page 2-5, fig. 2.1: The man indicates that the highway that 1. A discussten of the impact of heavy track traffic alen9 Utah Highwav 95 on &2

would receive much of the heavy truck traffic provides the Natural Bridtjes National Monument has been added to Sect. 4.8.6.access to the Natural Bridge National Ponu=ent. The impacton access to the Monument should be assessed in section 4.8.5 2 Section 2.4.2 provides a profile of the social, economic, and transportation(p. 4-21). systems of the mill impast area, including a descriptian of the various public

O2services provided in the coreunities of Blanding. Monticello, and Bluf f.Pages 2-7 to 14 sec. 2.4.2: l'nder social economic profile it is the staf f's judjnect tnat the treatment given therein tc water, sewer,

it is difficult to grasp rhe current situation. Existing power, waste disposal, public ssfety, health, and educational systems providescapacities for water, sewer, and other components of the a clear and accurate picture of the local infrastructure.infrastructure should be described,

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O3 Pages 2-16 to 17, sec. 2.5.1.2: The discussion of farmlands J. A discussion of this issue has been aJaed to sect. 2. 5.1. 2.should indicate that no unique or prime farmlands exist in

Tre U.S. Bu eaa cf Land Manapent's Visual Resou ce Inventory evalaatesthe area. 4 r r

an area's scenic q.aalit y based on land f cre, ve jetation, water, color,4 age 2-17. sec. 2.5.2.22 In the discussion of scente areas influence, scarcity, ans cultoral nodi ficatix. According to these criterta.

Visual Resource Management ratings should be included, the proposed mill site itself does not rack as an outstanding scenic area.receiving a " Class C" rating, as shcwn below.

O5Page 2-32, see. 2.6.2: Two of the onsite wells are located sco,, cc,rck Appropriate leve0in the area of the proposed tailings i=poundment and it is 5, g%%jM Clo s f acotestated that these wells would be capped. We sugest that to H, gh sedan Lowprotect the aquifer (s) properly and to avoid the possibility ' # "' s 3 0 ' ' " ' ' ' " "

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of fu:ure problems in monitering and contamination control. Cioss A -inithe wells in the tailings impoundment area should be thoroughly 2 V'a* m e s 3 O 12ette aiversity

Class B _l].- l.!plugged both in and belcw the uppermost impermeable layer I wmer 5 3 O r.cne

below the base of the tailings and above the aquifer (s). a comr 5 3 O relatively uniform Class C ll or lessOtherwise, deterioration of the abandcned wells surrounded 3 Kf h'ence 5 3 O unaffectedby tallings could furnish ready avenues for the movement of SOFU Fmo[ Rotmpollutants into the aquifer (s)'. If, on the other hand, l 5" C '' ' ' 2 O commn W Eplans include future use of the wells--for example, for 2 G u m w heebon 2 0 9 malftei for gra: Arm

monitoring--the statement should describe precautions to 0 C 4ensure the continued integrity of the casings. Subtoto! + + 0 . Total .

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O6 Page 3-12, par. 2: Despite the assertion that the " tailings 5. The section has been revised to state that the two wells will be completelywould be stored completely below grade" (p. 10-19, par. 1), plagged,this is not clear trom the description of the dike construc-tion in chapter 3. Embankment height at the icwest point in 6. Sections 3.2.4.7 and 10.3 ( Alternative 1) have teen revised to clarify thethe swale is given as 30 feet and from the description and description of the croposed system. The tellinos area will be constructedfigure 3.7 it appears that this would be 30 feet above the in a natural s. ale with each cell teicq e=cavated to previde edittienal ,natural ground. A bett er description of the tailings grade depth. Each reter' ambankmeet vill be constructed across the excavated Lt

in relation to natural grade and the dike farthest downstream cell with the fines embankment matching the level of the adjacent naturalwould be helpful- ground that creates the ridges alcnq tne edges of the swale. Therefore,

O7the embankments =f11 only be as high as the undisturbed ground adjacent

Page 3-14 sec. 3.3.2: The source of cover material for the to the tailings cell. The maximum embarkment beignts will vary f rom 7.6 tocallings area should be described. As this area will prob- 13.0 m (25 to 42 f t), depending on the individual cell. The lastably need extensive reclamation, we recommend a discussion cibankment will be constructed with a 6:1 downstream slope and will beof this topic, constructed of riprap for lorg-ter, stability.

O8Page 4-1: The project area is close to major recreation Each tailina cell will be filled to a level 1.5 m (5 f t) below the too ofI

areas where visual impacts are of great concern. A d!s. the embankment and the adjacent ground and will be covered with a sufficientd_CD cussion of impacts on visibility from emissions would be amount of cover to reduce the radon emanation to twice background. This

[c_/ appropriate. cover will create a slignt rise where the swale formerly existed to gently2drain waters away from the reclaimed tailings area while minimidng ercsion

of the cover material.CQy Page 4-3 sec. 4.2.1.1: How long will the 1,480 acres be

C"N' disturbed? 7. The silt-sand, rod, and topsoil are available f rom cell encavation and the

,

O10Page4-5.onsite borrow area snown In Fig. 3.4. Ciay for cell linings and cover will

sec. 4.3.2.2: 14ha t is the permeability or esti- probably te removed from Brushy Basin outcrops on hestwater Cree 6 Canyon.mated life of the liner for the tailinds ponds? These tarren, heavily dissected outcrops will lose no potenUal use from

SL clay removal. No reclamation is required because they presently support4[j no vegetation,

b 8. A discussion of impacts of visibility from emissions has been added to thetent.{}

[~ 9. The total project site [599 ha (1480 acres)] will not be disturbed by

g~!-project acticities. As stated in Sects. 4.2.1.1 and 4.2.1.2, about 196 ha(484 acres) will be disturbed by construction 'and operation of the millfacility. A realistic estimate of the minimun amou t of time the land hill- ' ' n

lI,.9 be disturt,ed is about 20 years. Note that the reclaimed tailings areau restricted use.C} will not be availatie for n

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10. No long-tem data on service life is available. No detectoretton during0 1 1Page 4-6. sec. 4.6.1: Which deer Mrd is affected? the elli cperating lifetime is eeected, and because final reclamation is

under drained corditions, no long-tem problems should occur. If properlyPage 4-7. par. 3: This paragraph does nct adequately de. testalled, pemeabilities less tnat 10-* cm per second are espected.scribe the impa to of the project en mule deer use of the

11 The deer heed onder consideratton is part of UtaC s Civision of kildlifeproject site as discus 3 on page .-4 (par. 6). .eer useof the area will be in..uenced by . actors other than just Resources heed unit 31-A (San Juan-81.e Mountain). As discussed innoise. Approx t: ately M3 ha occupied s y the 11. rtill See 2.9.1.2. deer migrate through the vicinity of the site to Nrpey Pointfacilities, tailings area, and roads wil., not .e available (Fig. 2.5) to winter. Cally movement durinq winter periods ty deer

,inhaniting tne area,has also been otserved between kestwate* Creek ardfor use by deer. :iew much of the total project site, crspecific f'acilities within the site. will be fenced ard what "'## "I 9"bare the patterns of h=.an use cf the facilities that will 12. Altnough about 154 ea (383 acres 1 for the mill f acility and tailings impouad-influence the daily movement and use of the area by deer? ment will be fenced, an additional a0 ha (93 acres) will be disturoed as aWe rec m eni that the applicant fence as little of the total result of stockpiles and bc>rrew areas. As stated tn Sect. 4.2.1.2. a tota larea as possible by limiting fencing to areaa where required cf about 195 ha (434 acres) would be disturbed. In addition to these directfor specific safety or other crerational rrquire ents. We impacts as a result of haD1 tat disturbance and h.r.an activities at the site,also recommend that the applicant during censtruction and the deer may t.e f urther impacted as discussed in paragraph 5. page 44.operation of the project, cocrdinate witn the Utah Divisien Greater human populatton associated with construction and ooeration of theof Wildlife Resources concerning ways to mitigate any impacts etli can result in greater hunting rressure (both legally and illegally)to deer that :may develop during this time. and destruc tion of habitat by of f-road recreational vehicles. Although

O13the staf f does not espect the movenents of deer across highway 163 to bePage 4-7 par. 4: The discussion concerning the quantity of influenced, increased wilditfe Icsses are e=pected to occur as a result of

tailings water (28 ha) that nay impact wildlife is in conflict greater venicular travel. The applicant will be required by Itcensewith the discussions of the proposed tailings system en condition to consult and coordinate with the Utah Division of Wildlifepage 3-13. There, figures concerning the surface acreage of Resources regarding extent of fee.cing and other ways to mitigate anytailings water that may be present at one time range from adverse 1% acts to deer that may occur.33.2 ha to 100 ha. What is the maximum surface acreage oftailings liquid that would te present at any one time that 13. The staf f estimates that t*e 40-na (9fs-acre) area of the evaporation cellsmight serve as an attraction to waterfcwl or shorebirds"

may te rewired. Because the moist tailings also provide evaporation surf ace.

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Page 4-13 sec. 4.7.6: The paragraphs en occupational the total area of the evaporation ponds may nct te required. inhealth are somewhat limited. Discussien of follevup on 14 The section has been modified slightly to clarify that manimum radiationemployee health might be included, both here and in section 6.6 exposures for both mine and mill workers have been set by regulatcry

O15Page4-17agencies to protect the workers f ram undue risks and that protection

sec. 4.8.2.2. par. 1: It is mentioned that the measures to reduce occupational dose are reviewed and revised to keeptown of Blanding has adequate water and sewer facilities for radiation cuposures as low as reasonatly achievable.300 new residents. However even in a good year, water mustbe watched very carefully. During a drcught seasen their eecause doses to occupational workers are measu ed and maintained belesrwater supply has been down to less than a two-week supply, occupaticaal dose limits no increase in discussion is warrarted in the FES.Monticello has similar proble=s.

O16Page4-15,sec.4.8.2.3:15. Although water scarcity is indeed a reality in southeastern (Jtah, inforination

What is meant by "a large portion supplied by the Blanding city manager indicates the ability of existingof the population"? Figures are available to determine the f acilities to accoreedate 300 additional resider.ts. Growth of a greaterpercentage of various groups. magnitde, however is contingent upon planned improvements in the water

g su? ply system (sect. 4.8.2.2).//gd/M 16. A quantification of hormon and Native American populations in San Juan County[/,p has been added to Sect. 4.8.2. 3.

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17 Sections 4.8.2.1 and 4.8.2.2 describe planned capansions cf the housingO17 Page 4-21, par. 1: It is concluded that the project can be stoo and various public services designed to accors,odate projected growth

accomplished "without long-range financial difficulties for in the im act area. This apparent readiness fer eill-induced populationthe local communities. Actual experience in similar situa- rowth indicates a likelhood that the adverse impacts esperienced in Emerytions. particularly Carbon and Drery Counties, indicates and Carbon co cties =111 be avoided here. As stated in Sect. 4.8.6. athat there have been sabstantial lags between needed tax strong defense against such impacts lies in making sure that plannedrevenues and demand f cr bousin:; and public tervices. S iric e improvements are made t+fere growth occurs. An esplanation of how neededthese lags have resulted in air,nificant impacts on the expenditu es are expected to be balanced by future revenues, thus avoidingr

affe-ted cc= unities, we suggest further analysis of this Icog-range financial dif ficulties, is f ound in the response to generalissue. conrent "C" abc .e.

Pa;te 6- 3, par. 3: Further explanation should be provided in 18. Althcugh no data exist on the use of uranium mill tailings ponds bythis parar.raph as to how "potentially harmful amounts of migratory waterfowl, the staf f does not anticipate that contact with theradionuclides and other cent minants in t he tailines im- tailings will result in increased mortality. The salinity of the tailingspoundment" amount to insignificant .rpac t s t o wildlife liquid (mostly sulf ate) is in encess of 100,000 ppm, whic.h makes it(water f owl and shorebir h) . We fully wppert the need for 8 unpalataole f or drinking by any species. The ef fective acid concentrationmonitoring pregram to detect any adverse impacts of the (0.016 molar) is too low to cause physical damage but is expected to resulttailings impoundment on saterfowl and shorebirds. Of par- in sufficient irritation to the skin of the feet and legs of waterfowl thatticular 1:tportance would be to note the benavlor of the tney will not spend extensive periods of time on the tailings pond,birds usinv. the 1.poundm nt. Is there any indication of Consequently, e=posure time is not expected to be suf ficient for waterfowlsluggish flight or difficulty in takir; off oncc oirds have to contract high body burdens of radionuclides and toxic chemicals f rom thelanded on the pond (s)? L'aes t here seem to be an increase in tailings. In addition, the acidic nature of the tailings will preclude thepreening activity? We rc.o rend that at the first sign of growth cf aquatic plants and invertebrates used as food by most waterfowl.&ny probler.3 (behavioral thanres or mortalities; the appli- making it unlikely that other consumer organisms (including man) will becant should 1: mediate ly not if y the Utah Divisioa of Wildlife esposed to significant levels of radionuclides through the ingestion ofand the Fish and Wildlife Service so appropriate mitigative waterfowl e= posed to tailings. The staf f is unaware of data that documentmeasures can be pursued. the impacts to waterfowl f rom exposure to uranium mill tailings. The staff

does not espect that anything but an occasional landing will be observed9 Also, the possibility of any impact to publAc health as a but requires that the applicant observe any use by waterfowl and matntain

result cf radienuclides or other centa-inates entering the a record of such observations to confirm that this is true. >

human food chain (ute r f ewl) sheuld be discussed in this *

paragraph. This would be a function of the length of use of 19. No potential ef fects on human health are espected because no sustainedthe ponds by the birds. the mechanism of t heir contamination. ingestion of the saline water by birds is credible. See response toand the probability of tbcir being harvested These items conenent 18.should be discussed in this paragraph and in section d. 6.1(p. 4-6). 20. The staf f cantacted the USGS. nater Resources Division. Utah District. For

the four Corners area, the range of Navajo characteristics were as follow:O20Page 9-1: The statcment should give a better concept of the

characteristics and water-bearing proper ies of the Navaio Coefficient of transmissivity (god /tt ) 450-38002

Sandstene aquifer. Yield and drawdown or specific capacity Coef ficient of storage 10.005information Ior the Blanding site well is the NavajoSandstone aquifer sheuld be given, if no aquifer test has Specific capacity (gan/f t drawdown) 0.74-3.24been made, such informaticn would permit at least quantita-tive assessment of ground-water impacts. The basis for the The city of Blandin a has completed one well in the havajo about 11 kmassertion in section 9.2.1 concerning. the large amount of (7 miles) north of the site. Static water level was 152 m (500 f t);water available in the Navajo Sandstone aquifer of the the well produces 200 gpm (309 acre-f t per year) with 122 m (400 f t) ofproject area should be indicated. The environmental report drawdown. Other Blanding wells are completed in the Entrada.

The staf f estimates that, at the site, both the Entrada and Navajo aquifers

/ contain about 25,000 acre-f t/sq mile (formation thickness times 0.25effective porosity). Most usage in the area is f rom the Entrada. Eveng - without recharge the staff considers the impacts minimal in the low

bg &ypopulation density region.

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for the project asserts (p. 2-120) that in 1977 developmentof the deeper aquifers of the Entrada Sandstone and theNavajo Sandstone was progressing near Blanding and Monticello,Utah. Because of the proximity of the town of Blanding, theaquifer (s) utilized by the municipal wells should be identi-fled. The statement should also indicate whether wells onthe Ute Indian Reservation tao the Navajo Sandstone aquifer.The following references may be useful in considering theproperties of the aquifer in the general area.

(1) Irwin, Ja:nes H. . 1966, Ceology and availability ofground water on the Ute Mountain Indian Reservation.Colorado and New Mexico- U.S. Geological Survey Water-Supply Paper 1576-G.

(2) Cooley, M. E.. Harshbarger, J. W., Akers, J. P., andHardt, W. F.1969 Regional geohydrology of the Navajo andHopi Indian Reservations, Arizona, New Mexico and Utah:U.S. Geological Survey Professional Paper 529-A.

Thank you for the opportunity to comment,

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__ ry E. MeierottoDeputy A:sistant SECRETARY

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WAR 16 IOMREF: 8AH-WM ,| '\Leland C. Rouse, ChiefFuel Processin2 & Fabrication Branch -gDivision of Fuel Cycle and Material Safety \'.*.yU.S. Nuclear Regulatory ComissionWashington, D.C. 20555

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Cear Mr. Rouse:

We have completed reviewing your Agency's recertly-issued Craf tEnvironmental Statement (DES) on the khite Mesa Uranium Project( N'JR EG-0494 ) . The enclosed final comments do not dif f er f rom thosepreviously submitted to you in draf t form.

In general, there are no major problems with this document.Overall, EPA's reviewing staff found the DES to be a well-preparedstatement which supports the construction and operation of a uranium ,mill at the proposed location. he are pleased to ccte that this CES 2.,

incorporates many of our comments on previous CES's developed by the --

Conraission for other brante milling projects.

The most positive feature of the proposed project is the planfor the dispossl and long-term stabilization of the radioactiveresiduals. By disposing of these tailings in below ground and linedcells which are to be filled and reclaimed sequentially, any

,

environmental impacts should be minimized. /pCAk uWe are concerned with the proposed sizing of the tailings .

impoundment cells. This may create situations where insufficient h, ''/. .storage volume is available for total evaporation, or there is a lack L ,/ ; -?i

(( ,of reserve vclume in the event that a rupture of one cell's dike wealdbreach the next cell's dike. This ccncern is compounded by our doubt Mg'.)* hat the filled cells will dry as quickly as indicated dJe to the ( g'c.

s 'nimized seepage through the proposed imr andment lining. Expansion vo' the tailings disposal arda with shall er cells appears more .-

de tirable than increasing the individu cell voltares through raised '

do height increments. '

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We concur with your Agency's policy of evaluating thejustification for licensing uranim milling projects, in part, withthe need for urania to fuel nuclear powe' plants that will produceelectric power f or sale to U.5. consmers. In this regard, we weresurprised to learn that the 5tc licensed Beae Creek Oranie Mill,owned by the Rocky Mountain Energy Co., has negotiated a large sale o*uranium to a Swedish utility. The hRC FES for Bear Creek did notacknowledge such an eventualtty por does the DES f or the W9tte MesaProject describe any f oreign sales of its prodsct. To maintainfederal Credibility me feel that the hRC shoald strive to give a moreaccurate account of the marketing of uranic by its licensees. Thisis partiCularly itaportant when the question of envirCNental Costsversus the gain s,f Certain benefits are used to justify a givenproject.

According to t% procedores EPA has adcated to rateeevirorsnental statements, NURfG-0494 mill te listed in the FederalRegister as ER-2. This means that EPA has reservations cor<erning theenvirorseentP1 ef fects Of Certain aspects Cf the proposed action andneeds additional data as indicated by (Pe enclosed Carpeits.

he will be glad to discuss these comrsnerts if you need furtherClarification or desire additional guidance on how these Ca9 De dealtwith in the final Envircnmental Staterent.

S ince rely,

Alan PersonRegional Aministrator >

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1. The last paragraph in Sect. 1.3 has been revised to include a statement thatWHi~~ PESA tJRANIU:W PRO tCT Title !! of that act gives the hRC direct licensing authority over uranium

mill f ailings. ( Sec t . 1.5 does not appear to be af fected.) The preposedtailings mJnagement plan for this project is currently considered stateof the art, and the act itself should not result in the stipulation ofadditional technical requirements. The act does requf re that " reclaimed *

1. Paje 1 h Section 1.5: The DES does not appear to reference haC's land used for tailings storage be deeded to the Federal government andrespunsElity under the recently enacted *tirantum Mill Tallings this requirement shall be corrplico with. The proposed tailings impound-Radiation Control Act of 1978*, What additional requirements will t,e ment would te located on lands owned by Energy fuels Nuclear. Inc. , eacept

I N "" ''' *"' I U "d 'stipulated? What changes, if any, in tallings maragement will result?

?. Pa(FES)je 717, Section ?.5.2.3:shosid contain dre detailed information on the significance andJanuary 1919. Aoditional information has been included in this FES.

~~ The Final Environmental Statment 2. The results of the survey conducted in the f all of 1975 were not reported until

location of all archselogical sites. The staf f mentions (p. ?-19) thata surf ace survey was conducted in the Fall,1978, yet tFe results of 3. Admittedly, the replicate samples do not show ood agreemen t , t'u t t hi s i s3the survey are not presented. Further fleid investigations and understandable as the samples are replicates with respect to locationanalysis (as suggested by the staff) are needed in order to deter:alne and not with respect to time. Activity levels and other parameters canthe potential inportance of the sites as mell as any adverse impacts vary widely as a function of flow conditions. ?hhich may occur f rom the proposed mill. These results should be Opresented in the FES, it is true that the gross alpha results are generally less tran the

uranium act iv t ty. However, this is evidently not untQJe to this work alone.3. b3cs ?-?6 thru 2% Table ?.??: The radiological analyses look An [PA publication (EPA 936/9-75-002) entitled 6:r<r uIitj Imi u ce ; micsomewhat suspect. #esults for the two replicate saeples are not in

W"5, stated the following as two of its study results:W W C ?N htirit ka in the !m ra "ivm! h ? +, Lv w.rfs , Septenter>

good agreement. Gross alpha results seem to generally be less than the 197urantum activity. At location SIR, it is diff icult to see bcw tFecreek could have enough water for one spple but not enough for the The uranium isotopes (uranium-234. -235. and -238) are the main contribution*

replicate sample. Some of the saeples also seem high for bactrground to the gross alpha result; however, in several determinations, gross alphasamples, underestimated the activity present from natural uranium.

4. PaSe ?-30, F igure 7.5: This ficure is too cluttered for case of ; * It is daubtful that the gross alpha determination can even be used as anin terpret a t ion. It s'hMd only be a scheretic showing the intermittent indicat r of the presence of other alpha emitters (e.g. ura' tium-naturaldrainages, proPct boundaries, and s vpling lo<.at ions. The contour and polonium-210), and because the gross alpha results generally have suchlines and other markirgs shculd be eliminated, large error terms, no meaningful determination of percentage of radionuclidem

GC) to gross alpha can be implied.WThe adequacy of 51R's sample size to permit a replicate is not known. hutbecause all of the other samples are without replicate, at least one sample

g was analyzed (although an inden of reproducibility was possible).q

HC) Some of the activities do seem high for background values (e.g.. radium-226hM averages equal 0.03 pct / liter in North Amertcan streams - less than statedC-y ' values), but statistical fluctuations and local environmental conditions must

be considered.

C-[ 4 The staf f considers the level of detail in this figure to be appropriate.Mm~.__m.M

::a

-

_ . _ - - - . . ... ..

a - -'

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-2- EE SPCN5ES

5. Par 2-32. Sect hMJ@ This Secticn is r.ot very specific en 5. Tne Dakota sin 3 stone on weite Mesa has been coreletely isolated ty crosion,the rechar ge ' baracter ist ics of the apifer underlying the site f 0 nota conscwet t y. all recnarje to this f ormation cor-es f rom precipt tation and55) . Irriaation on the mesa. Na irr ? gation occurs close to the e111 site, and normalThere shculd be more detail cn !r ssible rect arge in the treediate om al precipitaticn is only 10 cm (12 in.) per year, mest of which reentersa v

a *2de sme detail as to the the atanphere a evapotranspiration (i.e. ., does not penetrate the soils overvicinity of the ellf. This shcuiuprevalence of f ractures ar=d po*rts whie mauld provide aver.ves of t*e Oakota). The Dakcta is tne under1,ing bedrect under the prencsed tailingsrecharge. It wculd te be!pf ul to also have site specific inflitration impoundment and has a re'meability coef ficient from 1.5 to 3 m ($ to 10 f t) peedata for the soils and underlying bedrock in the vicinity of the y e a r ( E R, Sec t . 2. 4. 2.1 and Ap wd i a 5). Jointing occurs in the for*atien but

propcsed tailingt ponds. A discussion on the pessitiltty that joints is vrebably not f ully penetrat in). An aautclude, the Brushy Basin mrriber of the

may te caen enough to provide a direct path to tre yound water would Morri wn Formtion, i.nder l i es tne Pacta sandstone, which ec ounts f or the

be appropriate, groundwater retained in tre Tw portico of tre Dakota.

6.Pay [lbe oepth2-JkF,igure 2.6:A vert ical scale range would be telpful in 6. Trichnesses cf stratigraphic units in the vicinity are shown i n F i g . 2. 9.

to varhus units.findt

7. Some formations suwn in Fig 2.6 are not shown m Fig. 2.9 because the former7. Pay 2-3are ilsoT(dFip re 2.0: Sirce the DES states that uranium deposits is a generalized stratigraphic section showing the f reshwater-tvaring units of

e fn the 'Icle, ar,d Cutter fermations and they are shewn southeast Utah, and T'g. 2.9 is a stratigraphic section showing the rocks espcsedin the stratigraphic se '. lon in Figure 2-6, why aren't they repre seeted in tne project vicinity. The clJest unit snown ja fig. 2.9 is the Carmel Formationin Figure 2-97 In adJition to describing the lithography of the Chinie because this is the c1 dest rock esposed in the vicinity. TFe Qin,e f ormationand Cutler formattens in Figure 2.9 It should show which macters of occurs at an estimated depth of 518 m (17C0 f t) and the Cutler Formation at overthe P'orrison forretien are roteot tally uranm bearing. 975 m (32% f t) at the project site. If uranium is presect in these f ormaticas,

undergrou d mining would te required.n8. PaSe 3-! d ection 3.2.2 l: Since the ore vill be purchased fromdiverse sources and will _coes_ist of a riuture of dif f ering See DC! corvnent E regarding the Morrison Fcemation.chararteristics, it is dif ficult to dettraine if tre propcsed millingmethod is the sicst envircrmentally acceptable without additioral 8. Dre samples f rom the Asnksville and Blanding area were ot,tained by the applicantinformation about the ore. It is not clear that the sulfuric acid f rom approximately 50 mines that will be shipping ore to the Wite Mesa will.Teach circuit is the ir.ost acceptable doe to the apprent alkalinity of Samples from eacn of ine xtnes were comaosited on a weighted ba sis (percectage of ,sore of the ore. rice production) for laboratory testing, which included alkaline and acid-leach '

*studies for comparisoris. These studies shewed that urante recoveries were9. Page b6 sec t i on 3. 2. 3. ?. . We corcur with the staf f that the higher by approximately 2% and vanadium recoveries by approximately SM whenudrainage design Wuh be alMred to iscla*e mill site runcf f into a acid-leech was used cocipared to alkaline leaching. This discoverf was the basisretention pend. f er t*e applicant's choice. Tne staf f considers bcth acid and alkalire etiling

-} a :cer table. ( See Sec t . 10.2.1. )10. Pace 3-F f f gure 3.4: The prepnsed lard acvisitien skoma inuFigureT4C appears to be such tco small. Even with the precautions 9. All surface runoff fram tne mill and ore stcrage sites be imp %ndedtaken that are described in tte text, d:pasitic: of af rtorre

.__ omite in a sedimentation pond.contaminacts frca stacks or resuspemien will praatly contaminate land 6

_3--t.eyond the boundar ies shown. The size cf the buf fer uce sMuld te e. 10. The MC staff retoontres that operation of the white Mesa Uranium Mill and itsincreased. c-" taillags impountent system may result in some of f stte icw-level contamination

p- of ground surf aces . The levels and impacts of such contaminatio7 t. ave been!!. Pace 3-11, Section 3.2.4.7: This Section presents data on the considered in detail in the preparation of the radiological impact evaluationcomposition cf the tailings that will be going into the prds, but of the pro;iesed projec t. The results of this evaluation are presented inthere is no estimate on the smua.t of selenium cr arsenic that might be C Sect. 4 7 ard include an assessment of compliar.ce with relevant FeceralIS-7 regulaticas governing of f site contamination. Staf f analysis indicates thatin tFe material. It is hard to envisicn that tie ore teing cilled will

cQ] the project will, if operated in accordance with planned license corditions,ret contain tirse two elements. Data on t*cse elmerts s*ould beinc luded. cG fully comply with these regulations. The monitoring program outlined in

RCD Section 6 is designed to provide the data necessary to confirm this conclusion.

V -Q, 6,:'

11. The concentration of ten minor constituents, including arsenic and selenium,6;.C.3 have been added to Table 3.1.Ge )

^

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-3- RESPONSCS

12. Pace 3-1? Section 3.?.4.7: The thincess cf ite cover o.er the 12 with toe procedures and controls proposed f or the installation cf the liner insynthetic Ti6e,,r raises concern atout assuring the intege tty of the cells I-I,1-E, ans 2, the staf f believes that the impermeable synthetic linerliner over the life of the project. TPere is no data as to whether the will limit seepa ge to a very minor quart t ty, if any.taflow structures will be desigred to insure that the liner is notdamaged by the ir, flow of tailings. Also there is eo infcreation on the This statenent has not attempted to detall the procedares by which the impoundmentlong term ef fect of the Ctemical in the tailings on the liner. There will be constructed or the liner placed. However, the appi tcot has proposedshould be sore discussion as to the feasibility of implacing a natural installing a smooth, rv..f ree surface witnout protrusions as iner base toclay liner with a permeability of less than 104 cm/sec. This would ot f er protection to the meet,rane during placenert and subseg ise. Followingte vastly superior to a synthe*1c liner because it would have integrity the installation of tre liner, a protective sdl cover would t- . aced o,er thef or a longer period of time. A clay Itner shculd be required, but if a liner, anJ a maintenance and inspaction program f ar the liner ,ystem will besynthetic liner is used, trere should be a thicker cover over the liner a condition of the license. Note that discnarge of tailings directly onto tne liner(4-6 inches of silt) in the areas where inflow will be occuring. cover will eot be permitted. A 2-f t liner of compacted clay has been proposed for

cells 3, 4. and 5. A review of tests results f or the proposed clay material =}ll13. Page 3-1?, Sec t ion 3.7.4.7: Even if it is believed that the dikes be completed prior to system approval to ensure trat a perateability of Ia 10'will not saturate, good practice calls for installation of pietometers cm/sec can te achieved under the conditions anticipated.or soil moisture tubes to monitor dike r'oisture.

13. Pietometers will be required in the dines.

14. P ne 3 13 sect ico 3.2.4.7. . The assumption is siade that if apipellni feT) uvre occurs in ene cell enj tailings loss would te 14- Section 3 2 4 7 ha5 been revised and should eliminate these concerns. :n addition,contaired. It would seem that this would depend on the scenario the slurry and decant lines will pass throup a safety centainment pipe in theselected. A pipelice treat such as the 11nited Oclear-Homestake dikes between cells. hn failure by erosion a credlble under these conditions.Partners break, which took out the dika, could cccceivably treach all finally, the tailings impoundment system will be monitored at 4-hr intervsls.of the completed dikes for the White Fesa system if it occur red on an

15. Pluarer, Christensen, and Monsen* {1968) have stated that stand establishmeetupstreas dike. This prewees that at least one pand is full, that thenext pond is partially full, and that the break cc(urs in the first to arm Mth im tu D c (9 A) p@ mWmW Wil m pM1yd ik e. Sir (e the FAC staf f analysis conclufes that hater evaporation succeed without irriga tion. Tee Blanding site, however, receives an average

ww l WWW@ M WA 2'L 7 m (11. 7 A ). b @t% mM We nnmay not proceed as rapidly as ty erplitant proposes, this problemstould t,e caref ully ccesidere t in pipelire routing, pastures already estabitsbed in this area without irriqation are good evidence >

that the species suggested for reclaSation can be established in the reclaimed i"" # #" I # " *" " H #D15. Page 3-14, Sec t ion 3. 3. 7. . The San Juan Rive >r area is a water

shor t. ~areaT'The arid cliria~te will make revegetat ion of mill tatlin3s M M a M t W i WWof the plants. Areas that are irrir;ated for several years following seedingareas dif ficult, without f requent use cf irrigation during the gro*1"9will undoubtedly produce an euellent tilant cover, but it is likely that theseseason. On page 2-39, the f ast paragra;.h, the staff states. " light

irrigetion may be required to establish native vegetation durin9 plants would tie f ar less able to survive an interruption or :essation ofreclamation." We do not telieve this stateurt adequately reflec ts the trrigation than those whose growtri character t stics reflect the arid charac ter-reciaadtlon ef fort that would te needed in this area. istics of the site.

16. Pace 3-14, Sec t ion 3.3.7. ' 15 the e e<egetat ten pia i f or The applicant recognires that complete success should not te expected inntnirrigated plantings. Therefore, It1ht irrigation may t.e required in therec 1hhkd of 'tbe null ~ taTIIngs area recessary for long term t~~i y.istability? If so, have revegetation tests been parforc'ed that j initial establishment stages. Further, the arplicant is coar'itted to monitoringand maintaining the reclai ned areas until stand establishment and perretuation&monstrate succeuf ul revegetation? pQ is assured in accordance with the State of Utah Division cf 011. Gas, and Mining,MM./ Reclamation Regulation Rule M-10 (Sect. 6. 2. 2 ) .17. Pace 4-3 Sec t icn 4.?.2. : Tre first perograph is iristeading to the

hcr[reade$ N ic,ks'iM isg owr inf erriat ion pre se ted in Sectionr - 16. The revegetation plan for reclamation of the mill tailings area is necessary for2. 5. 7. ?. The results of tte historical servey and reconcerdations of g- p long-term stability for several reasons. The roots of the plants help statilizethe Council on Histcric Preservat ion and the St ate Historic p5f/ the soil to reduce wind erosion. and the cover helps break the ground-level windPresersat ion Cf ficer should te fr.cluded in the ftS.to reduce wind eroston, reduces ra norop splash and downslope mover'ent of runof f,and adds a yearly increment of organic matter to aid in rebuilding the soilC'

e( ..pro fi le.

'.1~-

C ac - Q, A. P. Plumer D. R. Christensen, and S. B. Monsen, Mg .S - W J m. e i n, .- J Publication 6:1-3, Utah Division of fish and Gov, Salt Lake City,1968.t .7 79,

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RESFC*iSES4

18. Paae 4 Section 4.3.7.?: With rep'd to seepage into gro nd Revegetation can occur in tne project area as evidenced by the past treatmeetswateInf tir~-5ITner deter aciration, the recently published CAP /LV-/8-8 of the lar.d to improve range condition. These treatments have included chaining

u

(Water Kovement in Uranium Mill Talliegs Prct bles) suggests that of sacebrush, plowing tre surf ace, and reseeding with crested wheat;rassscepage may continue f or the lif etime of the pile. CRP/tv-78 5 (Study (Sect. 2.9.1.1) . Coverirq the disturbed areas with previously stockpiled teasot tof Engir.eering and Water Panagenent Practices that will Minimize the and reseedtag .ite %na" putes;ent wheatgrass, crested wheatgrass, forbs, andInfiltration of Precipitatten into Trenches Coctaining Padioactive shruts (Tacle 3.4) will closely replicate these past treatments of tre lanc andWaste) also notes that clay liners (and caps) are entremely susceptible should result in successful re.egetation, aswing that proper planting time,to t,lological damage and should be protected f rca f reezing. Native the addition of appropriate soil amendnents (sucfi as nitrogen and poss f D1yclay contains substantial portions of non-clay material which irrigation fc initial stand establishrentl. and protection f rom crazing and

otter distu tances are provided.diminishes its sealant value. r

19. P.43e 4,-5, Sec tion 4.3.7.2: Although the amnunt of ground water in Please note that the staged reclamation plan should provide an cprtenity tothe khtte Mesa area (5 mile radius from project site) trat is used for vertfy the viaotlity of the proposed cover.domestic, livestock, or agricultural purpcses is small, and carefulmcnf toring of this groued water supply will be required (during 17. Sections 2.5.2 and 4.2.2 have been revised and Appendia E has been includedconstruction and operation), we believe that ARC shoald consider concerning the currently ideetified cultural resources and the mitigatory actionsadditional monitoring requirements cf the ru of f water frca r?tention that hill be taken.n

ponds. Since the ground water supply is 1ccated very close to the 13. CRP/LV-78-8 clearly states "under limited rainfall conditions . anysurf ace, there is a potential for ground water contamination in thisarea. Cultivated creps are located as close as 1 mile north of the significant vegetation cover on the tatlings ptie would use all available

precipitation, leaving little or no water to flow below the ront zone toproject site. greater depths." Because revegeta tion will occur and because a 3.2-m (10.5-f t)

cover (minim) is proposed over the clar cap to pectect it from tiological damage70. Pne 4-5 $rction 4.3.7.?. ; The description of the retection

penis 74Wcatchment basWfor potential ruptures of piped tallings) is and f reezing. the staf f does not ecect signifiunt seepage f rom the tailings2

not adequate as presented in the DES. Mention is made of rock teing impoundmen t .

placed along the dikes of tte retention pWs, but what kind of soil or 19. Please ref er to Fig. 3.4 and Sect. 3.2.3.2. Runof f f rom the rill site will beliner will be placed underreath the rock? impounded on the site. No monitoring of runof f water appears necessary underthese conditions. P

71. P The ingestion pattvay should inclufe 5wildlNa-e 4_-A F,igure 4.1:e, such as deer. 23. See responses to corewnts 14 and 19. Tallings imr wndment constructioc andoperation are disc.ussad in revised Sects. 3.2.4.7 and 10. 3 Altemative 1.

22. Pane 4-l?, Table 4.8: The NRC regulatien (10 CFR 20) applicable Oibe construction is shown in Fi n. 3.7 and 3.8.dose %iTTor the brcnchial epithelium is reported in werking levels(WL) in this table, tivt has reported in cuculative wor king level s.cnths 21. The meat ingestion pathway considered as part of the overall radiological imp.(CWLM) in Table 4.6 of .voab CES. This incc isistency is conf using to evaluation implicitly accounts for ingestion of wildlife, although the mod esthe reader and make cenparisons difficult. TFe estimated radiation and parameter values used "cifically applicable for beef cattle. T!

T_.yj)i is accomplished througn (n. ' conservative occupancy f actors, envir,doses to the bronchial epithelium as reported in mrem /fr in this tableappear to be too low. gg] transfer f actors, and ingest,on rates. Witn specific regard to the incl

.

' a-9 deer as part of the ingestion pathway for meat, nurertcal values in all23. Page 4-13 Section 4.7.7 . Wile probably not of great of these categories would be reduced, causing a net decrease in the estisigni7ica'nc5 it seems unfiGly that there sculd te ro adverse h. ;g- t

doses f rom the meat ingestion pathway,radiological impact cn e csident turrowing animals in the tailings ar eas. f

h.h* 22. The noted change was made to more accurately represent the actual limitation or.V radon-222 daughter concentrations expressed in 10 CFR Part 20. Similarly, the

presentation made in this Statement will continue to be maje in future Statementsr5Q until refinements are considered justifiable. The estimate 1 bronchial

epithelium doses were calc' ated using the models Arid data provided in

{J< ]> Appendix D and have been ' ound to be numerically accurate.

23. The staf f agrees that v ring project operation such animals could receive oc%-

CD in rems per year. but at suf ficient to CaJse observable ef feCts. After4d reclamation, consider .qq the cover to be placed over the tailings, the statf$/S considers potential exposures to t,e extremely small.L' D,Ce/pJmCM

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.$. FC SPONSE S

- % ection 5. Q . The mapr toxicity of yellew ce e 24. The staff retognizes that irhalation of yellow cake dust can ca se healtha24. Page 5-5 5appears to le reavy retal poisoning to the kidney, ect radiation ef fects due to the cwical tealetty of uranium. However, no clinical ef fet t sdamage. A chemical tos tcity evaluation of accicent al dispersal to the were cbserved ameng the individaals who were involved in a recent (Septemberpublic should te made. 1977) yellow cake truck accident or la t5e subsegaent c lean-up. Alsa, uraatum

bioanaf s af 27 persons who were in the vicinity of 1 4 spill (including the25. Pane 5-6 5cction 5.3.1.. Yellow cake shipmerts in con;ested law-enforcement and rescue personnel) inotcated that pnysically damaling urantebrban areas appear to te neglected in the accident mcdels. A intake did not occur. The highest reported bicassay t'etng 18.1.g of urantrix

population density of 160 people per square m. e is not an accurate liter of urine.

representatico of an urban area, where larger traf fic volees and busyintersections Inc.rease the likelihood of an accidert with a higher l,i th respec t to radicto41 city , the critical organ and fepact for yellow-cake-population dose pctectial. An accident rodel, ut tlizing specific data uranie inealation is dependent on the solubility catevry assarvd. I f yellcw-for a metropolitan area such as Cenver, kould t,e usef ul in evaluating cake-urant e sclability in human lung flgid is assurwad to be Class T (years),

then radiation enosare to lung tusue is critical. That assurytton has bee 1the most severe accident consequences, ude for this analysis follawing ICRP recorrendations, however, receetcontractor data indicate varying solubiltties for uraniam in yellow ca6e26. Page 5-7. Secticn 5.3.7.'. When ccesidering the likelltcod of 7.6 depending on the specific chemical compounds constituting the yellow cake andore Duck accidents per year from the Hanksville ore buying statice and

the economics of hauling low grade ore 163 miles to tre khite Fesa the calcining tenerature. This issue is presently under NRC staf f review.Project site, it seems apprcpriate to consider the alternative of 25. The populatian density used by the staf f ts tonsidered conservative. Denver hashauling the Hanksville ore to the preposed Shocting Canyon Prcject to a popalation density of $418 people per sqaare mile, and a potential similarbe located south of Hanksville. accident would calculate to 44] man-rems and 30 man-rems for NJe t s I and !!

emosed inoividuals w uld not te more severe than27. Parf~ Td be di'sc'ussed,% R, sectica 5.3.3.'.Truck sFirents of amnet and sulfuric re spec ti vely. Effetts or n

acid' shou ~ - the accident discussed in Sec t. 5. 3.1.

26. Beside tne fact that there is no regulatory Sasis uptn which transfers of are28. Paje 6-? Sec t ion 6.3.?. : This Section indicates that monitoringwells wilflIInsfalled he~d the tailings ponds to detect certamir. ants between correting operators could be required, there is no overwhelming reason

' rom an environmental standocint why this would be advantageous.if they reach the ground water. By the time any conteminants resch theground water in a detectable level there would be a f airly large amount .

27 Thts information has been added to the test. ;of material moving through the unsaturated zune. If t'.e applicant "

installed one vacuum lysimeters below each pond in the unsaturated zone 28. For the initial groundwater monitoring program, the applicant plans to install(5-15 feet below the bottom of the pond), it would te possible to five deep wells completed in and cased down to the Dakota Sandstone aquifer,detect teachate movement sell before it reached (P.e grond water. If

as well as five shallow wells with monitoring tones in (a) the soil andsuch a device was irstalled, it would rot endanger the integrity of the residuum and (b) f resh rock above the saturated zone. Of these wells, oneItner and would allow the applicant to .se fewer monitoring wells. Thewill be uporadient and four generally downgradient; the remainh r will bebest monitoring well scheme would have ore to three wells on the up cross-gra t. The two deep downgradient wells will be operated as pumpinggradient side of the pond area and three to five wells on the cwn wells. The m nitoring proaram will be expanded with the construction ofgradient side. The wells should not penetrate ircre than Ib30 feet of additional tailings cells. The downgradient pumping wells are planned to drawthe formatjon to minimite the dilution ef fect caused by sampling a finw f rom along the edges of the cells to the wells and to decrease flow and-large perforated interval. contaminant detection times by increasing the hydraulic gradient. A program ofmitigation will be initiated if leakage is detected. The monitoring programg-

( C,~ s appears adequate as proposed.

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-6- #t SP; sit 5

29. La;e. 6. .5,l .a&Ll: Se follemir; additiars to 19 ; :.pc se d 29 (a) Secaese of v*e coa-terly ccepc sitig of air f ilters . *.he * al s of a*al y z"1Iprec ;er a t ic ca me ttering proyam are rt a v r -d for poWip-210 is essertially el151aated taa.se cf t%e relatively **e secas

a) Air Partica? ate of col 1+c ted peino e over several mcatr s. Ary pelon4#-210 Dresea! C d 'sla;aw e,aT TRai pectccol to incl de poiriure - 210 4 x to decar of lead 210. ' race retals are cet coccted to be tra saceted inyparticuistes (meight en filter), an: 51ptf u ent sig-tf caet er aa arately reaseable awts ta tv srC 1 partities c'trace retals pre sert in the ore (e.g., arsenic ae mc!yteceum). rarticwistes antic oatet

b) Cer'u c .ater it! See ste.e resecrse to 28 for a ceurutte c+ the crc;cse<t gmed . stern

M siditirTog rewirco.ents set forth oc pa;e 6-2 vp11es a m + term; reogran. in:e 6.1 has teen c*as+c axrecrtate t y.greater r.wrder cf mells for me itering t'a tailirgs dis:mselarea than the sf s indicated in Table 6.1. This aparert (c } aad (d) esiN reasoM ; swiler to that prese-ted in ' a l, nei tner pcicM r-2incc.rsisteacy swid te esplai ed. C.e to the cc r,f.s vg %r t-sce metals sh-M d te snied m s.,rf a:e sel c.e sew t

prenthetic remark *f resa ea:h well", it is ret clear ec ranymells are within 2 kitcrete-s of tre tailirgs dispesal areaand h*at the ss9 ing f regaency is,1

c} krf ace Scil'$aifes~a aT ted f e,r 1 cad-210 5%14 also te analyzed f ers3polcaisr-210 and sipificaat t ace retals f a.N m the ore.

d) Strew' SMiwrti d t h c' si fcr 3 rf ace scil syptes.

30. P age 6 7 T ele 6.2: n e fc11c W ) a 'fi t iers to t* e p-! csed 30 (ai as ui t*e ate.e reswse N 2M a), aaaines of filter samles *cr-

Crer aticrainka tor is c-c ;ra, a e , cco . eeed:-

Pol or i sa 's , rart 'c u' a es ( >* ' r t cr f'1 ters ), a 3 trace metais are ict coa-s ucced recessary. we -itri , cf the reem caeiination me,, .m be

Air P 4-t scwlate cIO5'If actrclied it asccrea*.ce =ita written eperat ton ;recedores au isa) UsTsif,J a t h t% reccmerdatic, f- t*r pre perat teral ,cc'a 5 i d* *'d * :m t'- ;

r.ceitori, preve . analysts cf filter sr;>tes fv r anim.4) & W We mriN at tae pertvery of tee tailius c's:csal area ts c.ct

=-210 (at le vst se$i-anally). p3 t:culates (aei#t cc filters).and s tpif $ccr t trace ret als. A ir re-t icu' ate se iers s % !d mucere recenary as ce use of s ue weary air s. viis nat us s%.14te located on tre parl;*ery cf the act ue tailiess disocsal L+"" t tre as ses swet c' ':me rad :r 'o ic al e f fi sect s to t*e 9e e ra i pco.l a t t ~i .r

This is esDeCially tr e since the seTlirg IXatio*s will be chCsen usir;areJ (cf.e u?wiM ar.d sueral dJ* nsind) Pccit or t*e ef f( Ctheress u

cf the inter k st atil'tation prc-ras Sv;1ieg secsid te . - . - the 'clio-t eg f ac '* s :

CCnti"luous with f liters rcpl4& d'aeck ly. fac*n sc7 e * % Id le 'l'? ,

afaly7ed Wt f rcrthIf cT VstliCS for 3 ,' 'O "IC"'

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site bouraaraes r.esrest to tre eill, cre piles. 44 tattims ciles,g pg g .

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of radicactive material.Trese C; _ lxat 5 d en matN tac e# conce-trat ?cn*dispcsa t area to quartify etissler s frcm this y a

st ati es will have to te (;* *tc1 i f* the E'M1 eC 7 tic 9

nr m to emre t*e ef f ect i.*wss cf tra rec 1 * - c n :.rw e.;

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c) Ground water (c ) ",ee he respocse t- '7(D) . Tacle 6.2 has t+co change 3 appropriatel y.The monitor ing requirement set forth on page 6-2 iriplies a muchlarger number of wells for ronitoring the potential tr;act of (d) Inis is nct comidered recessary as contarison of gre- and operational totalseepage from the tailings dispesal area than the fcur indicated concer.trations is as inforeative.In table 6-2. (e) The staf f does not require sediment samling in tFe operatienal monitoring

Surface Water program Surf are-water analysis is as in formative.d) 10 proTToe a mean'ngful corpparisen with pre-operational data,

analysis for total and dissolved concentarations of specific (f) soil sampling at the perisery of the ore rites or the tailings piles isradionuclides thcuid be conducted, not cnly total not consicered necessary. w'ith an annual collectiun trecenc y and considering

the interative colletting functiun of soil, the results would probably beconcentrations. inconclusive as to the origin of a radionx tide (e.g. , whetner or not tneStream Sediment

radium-2J6 in a sample f rom the ore pile periphery includes contr1Ntions f rome) E I M nt~Iri the preoperational m6nitoring program, annual or the yinding and crushing stack, tailings pile, etc.1.

semi-annual sampilng of sediment at the surf ace water stationsshould be continued during the c;erational peried. (g) The staf f does not feel these suggested changes are necessary.

f) Tn additisi to the proposed 5 stations, soil collection stationsSurf ace Soil

should t,e established on the pery:hery of the ore storage padand the tailings disposal area. Collection should be annuallywith routine analyses f or ramm-226 and uranium. Selectedsuples (10 to 20%) should te analyzed f or lead-210, polonium-210, and significa $t trace s etals,

g) for a totally comprehensive mu t tering provam, on site as wellVegetation

"

as of f site, vegetation should t.e c.onitored f or radienuclides 3conc en t ra t ions. Perhaps, three to five on-site staticos with

analyses for radium-226 and urante on all samples, end lead-210, polonium-210, and significant trace metals on selectedsamples.

31. Pue 10-9 Sect ica 10.3.2.: ke concur with the staff that 31. Ndifications in the tatitngs management program proposed by the applicant should2 ebviate these concerns. Tailings depostted in lined cells will be gravity-drained.AlternatWI TFthe most environmentally sound long term tailings and the liquids will be parted back to the evapnration cells (cell 1, Initial and

manaFment plan. We are how.ever, concerr.ed with the potertial of a cell 1, Inlargement). The probability of a sequential f atlut e of entarkmentssequential cell dike f ailure causin) an unctntrolled tailings release becones very small af ter cell 2 has t;een filled and reclaimed. In addition, the(indicated in earlier corvnent) and the likelihood cf the predicted embankment that forms the final barrier for containmerit of tallings (at s''y pointtatilngs drying time due to the synthetic finer. The recent [ -publication * Water Povement in Uranium Mill Tailings Profiles.PA O in the operating sequence) will be constructed only af ter review and approval in

accordance with Regulatory Guide 3.11.(CRP/LV-78-8) Indicates that the tallirgs ray never d"y akquately for bs

fleal staMlization and reclamatien actics without cosihrable C)additional materials and ef fcrt. We surest that a tailings duatering <splan te added to this alternative, p

32. As was shown in section 13.5.1.4, U.S. requirements for 0 03 3 will exceed32. Page 10-24, Section 10.6: This Section states (as in previous

D[5'il WaFThe uranium production is needed to fuel reactors that prodaction capabilit.y for the next f ew years. Although the applicant mayenort the uranium derived f rom the U 0g produced at the WM te Mesa Mill, tne3produce electric power to U.S. consumers. If this is an important United States is a net importer of uranwn and f ailure to license the proposedconsideration in MC licensing action, and we feel It should be, it rm'

deserves further evaluation. We are becoming increasingly aware of tc project would only result in the foreign demand being filled by other domestic /foreign saf e of yeifow cake that the MC stated in the specific FES was

- f reign mills that could be producing uranium for consumption in the United

destined for U.S. energy needs. Since much criticism is being !;$3 States. Sections 10.5,10.6 and 11.4 and Appendin B have been modified to betterger.erated by the general public concerning the hazards associated with - 15 - reflect this current situation.nuclear power and the unpopular radioactive waste disposal issues '7' -

(including ta' lings), misstatements such as the above will f urther kyerode public onfidence in Federal actions related to nuclear energy. Sin

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33. This t ypograpeical error l'as teen ccerec t ed.33.Page_D_-fuSec t i In the first paragraph, the referenceshould be tasGreca D.4.1..cplung Model.

,ee basis for t*e staf f,5 oose conversion f actcr for droccM al epithelipemposu e o.e 13 irhalation of snort-lived redon-T dad.ters is now cetailedrThis section is sivch to abtreviated for pec;,er evaluation and reeds'" *W"* * I -espansion. The reticeale for essetng that intor radcn daseter

Concentration would be 50% of the outecor rahn cloud conce-tration, 34. The staf f const $ers the treatreet of racon enalation saf *1ciently conservativeshould te explaired. Since a WLM is hsed on 170 Peurs eunre, it in Gendia F. The conclusion is t"e result of the follOwing coesiderattons:should be esplained Scw ccatirsoas esp'su e to I s.1 is etal to 25 b.tMr

per year _ he feel that the brcacrial epitaelie dese ccr.ers ten f acter ,he estrates for rahn cessions were tased en 100 ea (251 acred of..

of 0.625 s.ree/yr is net aparcpriate. A rae cbetween this value and the 4 rees/yr pa r pci/c)mservative estirate tailings esposed to radan evalation. ihe :da mum area cf the iwntent

estNate in (cceraticeal tail trgs aad evaporation cells) sut.;ec t to rajon esalationEPA-520/1-76-0G1 w ould be r.c-re appropriate f cr M; I tcensing ac tion. at an y peint in the e111 I t fetime s%uld be ro mere than 90 ha (Zu ac re s ) .tw w . cells and am evapcratwn Ms % W 494 heme

34. Pace F-7 Sec t ion F.2. ; Again, the rejan esissicc flu estintes cp u an mirtf uaM a%ud v nun Malam. N . W wad JshoMWr re conscrvative. Fcre conservative (hiper) estimates for amN a( a d d tail g su W omdry, solst, and satgr'ated tails sec*s appec,friate f cr M; licensing enhalation at any point bring the lifetime of the mill. Se consi ser.* "* ation of the area suSject to radon enhalation introduces ccrservativism

ir.to the final redon entssion estimates of 5500 Ct/ fear. 2443 Ci / year,35. No specific _ pan: We are increasirgly reccatag arare cf reports and 30 Ci/ year for cry, motst aad sat rated tailings respectively.of sto' Ten quantities of urania yellow cake. Ore such re .or t d=scritesa

7,000 lbs. of yellow cake valued at 5?O,cc0 v.hich was stolen frua * m are corsisered toThe parameter vales for the calculatica of the radan fiu*Pew Pes tco mill. Previcusly it was felt that 55 gallon dres .eighing te reawable c* 'ces in tre literatu e.' *

r

' its. and valued at $8/lb. (but 'cr which there were no u author 11edtuyers, would nct te readily stolen. N ever, in light cf tte dramatic e The staf f has ss culated adf1tional controls to dusting such as water spray orrise in ti.7 price of .ranius and availability cf further prccessing similar erans, which would in turft redace radon ennalation by increasing theplants around tre world, it is time to consicer ircreased plant misture cnr. tent of tre tailings su face.r

security r.easures.

J5. The applicant tas provided a cescription of security measares to prevent thef tas fallows:

Each terrel of yellow cake proLced will be weiPed and an identification reter [stenciled on tre side and top ct the der. These weights and nurters will t'e o

recorded and filed. Ltds =111 be tclied coto the dr rn and * sealed.*' Tre sealu

nurtier will also te recorded and filed. The yellow cake packa g mg room wf il t'elocked unless authorized shipments are beir.g maje f rom tre rom.

v llow cake that is stored inside tre plant area will te in a fenced areae(6-f t chain lina) that will te within the mill area 6-f t fence with the gatelocked unless authortzed deliveries or shigeerts are teing edde.

Mt c' A The entire mill area will te fenced with a 6 f t chain-lien-type f ence as

_M indicated above. All gates and entrances to the will will be kept locked with,j' t*e enception of the main gate by the administrative of fice. This latter gateC, will te under surveillance er locked at all thes. Ecclo,ees will te reu red

Cg' to park outside the fence and pass thecu;h the # ate on foct.%

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4. B. Tanrier. "RaSon "1gration in the Ground: A Rev tew," i n .N .t m.m. :-

4 6 r f.: >irm ., J. A. 5. Adams and W. M. Lowdero Eds. , Universt ty of Chica go>(5 Press , Chicsga.19f 5.

h,,W M. B. Sears et a l . , New b:r m ., ' = * w nce . arc N :m-u Osts ni tu.

s in ws: :~r . :! .w.1 %ma in % h.:o2r he: .:a pr :se int

's' utd;ien *a u <. u .% d .e * M ke - m L:i.: M e- % r, Report

%d OR4L/tM-4 E3, vol . 1, Cak Pidae Mat tonal Laboratory,' Oa'k Ridae. Tenn. , May 1975.

-

usemstsAdvisoryCouncil OnIIistoricPreservation

Is22 B Strese NWvm.heaston [LC2aous

0,January 17. 1979

hMr. Ross A. Scarano. Section Leaderf[j,/ZUranium Mill Licensing section \ '6"/Fuel Processing & Tabrication Branch

(/7 'Division of Fuel Cycle & Material Safety '

U.S. Nuclear Regulatory Commission hWashington. D.C. 20555

f'Dear Mr. Scarano:f|/, .

7 p;*This is in response to your request of December 15,1978, forcomments on the draf t environmental statement (DES) for the N -gWhite Mesa Uranium Project. Utah. We have reviewed the DESand note that the undertaking will af fect numerous archeological b - [/4

v , ,,/4properttee that may be eligible for inclusion in the NationalRegister of Historic Places. (/4., '.'/ }G ,/ I(,,/ 5Pursuant to Section 106 of the National Historic PreservationAct of 1966 (16 U.S.C. 470f. as amended. 90 Stat. 1320) Federal \fagencies must. prior to the approval of the expenditure of anyFederal funds or prior to the granting of any license, permit,or other approval for an undertaking af ford the Council anopportunity to conument on the ef f ect of the undertaking uponproperties included in or eligible for inclusion in theNational Register.

A. Sections 2.5.2 and 4.2.2 have t'een revised and Apoendia E has t.een included concern-While we note that the Nuclear Regulatory Commission appearsto be implementing steps which will result in compliance with ing the turrently identified cultural resources and the friticatory actions that millSection 106, until the requirements of Section 106 are met * be taken.the Council must consider the DES incomplet- in its treatmentof historical, archeological, architectural and culturalresources. To remedy this deficiency, t he -,ounc il willprovide, in accordance with its " Procedure, for the Protectionof Historic and Cultural Proferties" (36 CIR Pat t 800),substantive comunents on the ef fect of the underta1 Ling onthese croperties.

Fage 2Mr. Rose A. ScaranoWhite Mesa I?ranium ProjectJanuary 17 1979

Please call Brit Allan Storey at (303) 234-4946, as FTSnumber, to assist you in completf rg Enis process.

Stacerely,

g,ou S. Wall. ChiefWestern Of ficeReview and Compitance

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U.S. Buclear Regulatory Commission aWashington, D.C. 20555

At t ent ion : Director, Division of Fuel Cycle and Material Safety

Dear Sir: RESPONSES TO HEW CCef MS

Following are comments on the DEIS (KUREG-0*94) related to the operationof White Mesa Uranium Project. These comments are related only to the 1. Staf f analysts indicates that irigesticn of mest grazed in the area insnrdf atelyradiological impac ts ' described in the document. South of the site would result in doses in escess of those allowable under

40 CFR Part IM, wn1ch becomes enforceable f or uranium ellls as of Decepeer I MO.1. Page 4-10 indicates that bone dose (Table 4.8) f roe ingestion shoul3 the subject area remain available for grazing as of that date and sneuld

of meat would exceed I+0 CFR 190. Ref erence in document to further NRC evaluation continue to result in dase estimates above compliancenegotiations to rest rict access by grasing cat tle weld not, levels, the mill operator would be required to undertake ettigattnq actions thatin my opiaton, constitute a definitive action to allay concerns could conceivably include mill shutdown. However, the primary sources ofconcerning this potential impact. potentially excessive meat ingestion doses are radium-226 and lead-210 transported

in airborne tailings dusts. Due to the progressive nature of the tailings cell2. Occupational doses are discussed for normal operating conditican construction-fill-reclamation scheme, the availatle dusting area of dry tailings ?

(p. 4-13) . There is no discussion of potential occupational would be minimal. Thus, actual releases during this time would not be expected ddoses under accidental conditions. to amount to the gaantities asseed for this licerising evaluatian, and noncom-

pliance with 40 CFR Part 1% would not be anticipated. The MC staf f intends to3. From calculations in sec.4, bone appears to be the critical remain fully cognizant of this particular situation and to fully enforce tne

organ. How ev e r , la discussing the impact of accidents. dose limitations on of f site exposure embodied in 40 Cf R Part 191commitments are calculated for the lung, rather than for bone.While it is recognised that bone doses are most likely to 2. No attempt has theen made to quantify 19e potential occupational doses underoccur through the ingestion pathway, I believe that doses to accidential conditions because there is no evidence that this information wouldthis arges merits discussion under accidental circumstances, q} , add to that already provided in Sec tion 4.7.6. That section includes a brief

-? sumary of mill exposure data which are required to be reperted to the hRC and

'Dhsingsrely yours.(0 ' ~ s

notes that the combined exposure of an average worker to the radioactive components' present (under all conditions) does not exceed 25% of that permitted. Tha t'

[ g, 4l b,,' Q are periodically reviewed and revised in accordance witn the requirement to makesection also notes that protectiori measures to reduce occupational exposuresf

ABernard Shleien. Pharm.D. ~ > such exposures as low as is reasonably achievable.Assis t an t Direc tor f or Scientific T

Af fairs 3. For ingestion pathways, bone doses are Critical. However, following an accidentBureau of Radiological Health situation, f ood ingestion exposure would be controlled through monitoring and,.sc'. condemnation procedgres, if necessary. Therefore, only inhalation cuposuresi

- ' are routinely evaluated for accidents.

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DEPARTwf NT Of ME ALTH. EDUCATION. AND WELF ARENaue w6 A1 TM 5E4WhCE liFV-23 . ,/y . t9g.V econ ano onu.c.mou.sisvaaromx,c . <, u . . na~o mu

January 19, 1979

U.S. Nuclear Regulatory CommineionWashington, D.C. 20535

At t ention: Director, Division of Fuel Cycle and Naterial Saf ety

Dear Sir

Attached are comments on DEIS (NUILEG-0494) related to the operationof White Mesa Uranium Project. These connents pertain to sectionsnot covered by the review of FDA's Bureau of Radiological Health,who sutaitted their coments in a letter dated January 10, 1979.As the coordinating of fice, I normally would have asked the Bureauof Radiological Health to incorporate substantive copnents of otherPHS agencies and/or REW regional offices into a single set of coments.Having received the Center for Disease Control consents af ter theBoreau of Radiological Health forwarded their coments. I amattaching CDC's separately for your Departaeot's considerat ion indealing with comments received by February 5,1979, the DEIS comment d

'

,

Adeadline.//;,%],Sinc erely yours.

Renneth E. Taylor |,' D.7.M. [/FDA Environmental Coordinator ,

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Dr. Kenneth E. Taylor pers January 1$.1979e

Food & Drug Administration

. mow Chief. Envirocreatal Af faire GroupEnvironmental Health Services Division /BSS

.t sJter USNRC. DES Eelated to Operation of White Mesa Uraniwa Project (San JuanCounty. Utah)

x tion 3.2.3.2 has teen revised and should clarify that this runof f mill beSectia 3.2.3.2 states: " Storm rwof f f rom the mill, ore storage pilas, 1, e

t Nmeded . Sections 4.3.1 and 7.3.1 have also been approrristely modified.and ore buying stations will be directed to the interceptor drainage

ditch along the eastern margin of the tailings impoundment. The staf f

recomunends that the drainage design be altered to isolate a M site

runof f into e retention pond." We agres with the staf f recommendation;

mill site runof f should be ;.nded and evaporated if feasible. Sections

4.3.1 and 7.3.1 s'uould incorporate this idea. p4m

$aFrank S. Lisella, Ph. D.

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SfKID-W 11 January 1979

Mr. Rose A. ScaranoDraalus Mill Licensing SectionIIuclear Regulatory CommissionWashington, D.C. 20313

Dear Mr. Scarano

Thia is is reply to your letter of 15 December 1978 requesting review ofthe draf t environmental statement for the I.hite Nase Uranium Project nearBlandtag Utah. The proposed project is within the area under jurisdic-tion of Sacramento District, Corps of Engineers, and accord!ngly, LosAngeles District referred the correspondence to our offico for reply.

Corps of Engineers interest la the project is primarily the ef fect theproject would have on flood problems in the area, *% relationship of theproject to Corpe projects and studies, and cosapliance with Corps reguia-tory permit programs. lie bave no connears since the project does not % rpm 4 r@ mtappear to contribute to, or af fect, flood problems in the area, does notconflict with Corps flood control projects or plans, and it appear s that sthe project aaould not require e Section 404 permit undae the Clean WaterAct (33 USC 1344). ''

/

Thank you for the opportunity to review and coussent en Lts proposed Y\(''). /1

proj ec t. //G,,' mr}

Sincerely yours, '

- cv(f.taJ N1h'EOGE C. WEDDELLf/A $?),gjj,Chief. Engineering Division v A ,h

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4 O=ted 5:etes 5<m1 4012 Federal Bu113162 Rf 590M.E5(L A ' . Department ed ConseNatum 125 South State Streat4, Agnrwhose We Salt take City. UT 84133

January 19, 1979

DirectorDivtston of Fuel Cycle and Material SafetyU.S. Nuclear Regulatory ComissionWashington, D.C. 20555

Dear Str:

i.e have reviewed the December 1978. Draf t Env ironmental Statement,

related to the operation of Whita Mesa tiranium Project by Energy FuelsNuclear. Inc. This document was identified as Docket No. 4]-8681 andw s transmitted to us by your December 15, 1978 letter.

The points of consideration where the SC5 has interest or expertise havebeen adquately addressed. We have no specific coments.

f Vj&Yw*ef h/| 'N'Jbyj f Me*n;Accrge D. McMillan #

State Conservationist

No response is reowired.

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FEDERAL ENERGY REGULATORY COMMI55804 RE SPON5t $

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february 22. 1979

Mr. Ross A. ScaranoSection teeder. Uranium Milltirensing Section

Division of Fuel Cycle ar.dMaterial Safety

Nuclear Regulatory ComissionWashington. D. C. 20555

Dear Mr. Scarano:

I am replying to your reqast of December 15. 1973 to the federalEnergy Regulatory Commission for connents on the Draf t ErvironmentalImpact Statement for the White Mesa Uranium Project. This Draf tIIS has been reviewed by appropriate FERC Staff components upon whoseindependent evaluation this response is based.

The staff concentrates its review of other agencies' environmentalimpact statemerts be.sically on those areas of the electric power.natural gas, anc oil pipeline industries for which the Commisst m has No response is required. Pjurisdiction by law, or where staff has special expertise in evaluating Menvironmer.tal impacts involved with the propc::d action. It does notappear that there would be any significant impacts in these areas of -''

concern nor serious conflicts with this agency's responsibilities should CA %

(u a)this action be undertaken. cm

Thank you for the opportunity to review this statement. ".7 j )V,

Sincerely. '{f;'y,V

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%$ QLs~s w W " ' ( ,

ack M. Heinemann pM)Advisor on Environmental Quality vc,-;p

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Fr. Russ A. $raranaFuel Pr c,ce s ir.g 6 Fab r ic ar i. n 'r>3 -

Davtsion of fuel (yele and M.st e r i a l f. s f a t y

11 . 5 Nalear Regulatary Cs& Lss t nL ashingt on, D. C . 20'd >

Dear Mr . S u r.c o '

T1. t n is in rceponse to yes r let t. ct 15 Dm e 6 -- r 1915 ' o na r d e thd r.if t eny t ts:n wot.1 A m,uit t t.t .it . wn : <n t t.c . irs 5 . .i t r a, m Tr . . t

f r ccmwr.t.

TW c ortcerned operat !r.g ad al n is t r,tt ia t, ..n | St.iff of the , .4 r t -- 'r (T r an s p ,r r a t i aa h .i ee revictud t hir m .t c rie 4 a tLe 4i* e a " rara uNt ei l mla Rc;; 21.<t io t has t'.c f o 11. r.1, . t ,m y, t ..

''Se c t l en S. 3.1 - Fi rst senten c: T,e Iw; ,i t * - et (1f Tra ir t .' t b 5 3"

d v s n( t c lassify cr r t a 'r er < es Tvi'e A. 2- i s f .* L 'c t% M In f " ,f 3f,1

TN cp: >ot t un i t y to review t!.i s .ir a f t sta v .r. t a a et t (,. - { ' ,+

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U.S. 'sucleer Re wf atory Co r i ss ionhashington, D.C 2055$

De: W%1te %54 t;ranium Proje(tEnvironrental lavatt Statenent

CentImn:

A reytew of the above referenced re; ort revests that questionsrenin (c.ncerei j air pollution.

,/ ' '. \This 1e espleined by the enclosed tr;ies of remranda from os pc.- V ;e

Bureau of Air Quality. - , u

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we will apprec tate receiving clarification of these me:ters. '"; . ,. ~ - .}S i nc ere l y ,t .- , ,

O (w 'jhb - d \\ ,_ %Richard C. Hansen

i; , S'Associate Ceputy Director of Heal th g '' ; ^Envirocur,tal Pealth Services Erartn '

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Social Services Memorandum$12 *.c8

To: File 0,,e 'm e cer '' 103

From: Cas; er A. Ne l mo

Sub ect hh t t e pes a UTani .en Still ~ I nc rg." F ue l a. % clear. I r.Pl

EIN. In prcheses to c er s t r ac t and opera' e an ac a d l eas h urana wa ti.1and associated facilities for prodacing yellcm cair uranium ct:sentrete and amore limited untit y of was4J a w. tencent rate in hn Juan Cost s arr meatcivsix miles snut h of & lard:ng. San Juan Count y is classified as Class 11 area.

The projec t site is adjacent t o an eaist .r g bay ang stat ,in whic' . , ' u.!c s.

a stockpiling area and saglir.g mill. It is estin ted that . '' t c r. s ofore mill be stoth piled prac t to start-up of the sall .

T5e mill will have a dc sip 6.c. city cf 2 ;! TD Operat tens me.dd te The Mite Mesa Project is currently beln) evaluated by the arpropriate re.Tulatoryc ont i nwas , H0 day s per year. Cenventional milling met h ds mill t e ; r.c tic N auth( rities to ascertaift tf P50 regalatiors accly. Tee applit. ant must cos'pI V

,hich I r.c l ude * grinding, two stage leaching, w ! v e r.t estractlen. p rec t ; 1t at ien with alt agplicable retalations uNer the PSD rules, teclading any rew red ;-and thickening drying and packaging. Becaae vanadum is net g resent in all saepling methods to demoastrate perf arwence.

cre receipts, the vanadium c ircuit . a ll 0;-e rate a pp rox imat e ;v 120 aa9 per year.Vanada.xn precipit.te mill be dried and fred before peka ga r j;.

Orcs are 1eing blended and will continue to be tiended ac t o rdeg tachetical and metall rgical i.haracteristics. CrMed cre mill be w e t - g-ou.nd(54d - sem14ntegenous grandarg) prir tc the H;W4 lenh , Acid leat . .r g =111produci 50; and acid mast in suf ficient q antity to reqaire cevered t ns anddemister sshaust f ans ver.tirg directly to the atmphere. The leach so twn6 ~:t ainin g '.Se uranium f and var sdits) mill ga to the solsent e s' -ac t r section.D e barret: maste will be puq ca to the t a t 11r.g s re j ec t a-m cells.

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Aa actre-type coq.ounJ carried in ke resene (org anic ) is used to at .arbthe dissolved urany l ions fre a tne aque ot.s leach so lut icn. Ke re ser.c thyJra arN n) e, ;;vapor 15 enit ted to a limited ext ent durin2 this solsent cat racti.m aad str1r :

ping pr3 cess. It is propc'ed to vent t his vaper ta tae ata03 Scre by fo r ced ,

air t.ailding sent11at10n at o char.a:es per ha.r. [- ,

( .;lellow cake (am:wn an di t.rar t e) is preenitated f rom the s t r y. so l e e: ' "

Vwith awnia tellow cake b it.rry 15 to be de= at t red c. a cent ri f n and ;m;w l

to a b' diameter oil fired a.altiple.bearth drver (c a l c ine r) . Ec dried ccr.- ,-centrate is reduced t o minus 1/ 4" slie t h rawh a haver irill and pacl aged ir.

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53 gallon dru. s fcr shipk nt. It is pr q sed to , >nJoc t the dry i ng . c rm irg Isen . ,scJ bu1131 r.g n i t h r.c, a t16 e k ,', -and packaging cf yellw cake In an is,1.c ed,

pressare to contain and collect (by wet s c rul ' In g ) all air Nrre part.cles t-'>

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page 2Memo - Energy Fuelss2/7/78

By-prmh.c', vana diac , when p re sen' , =111 rep rt m ath the aqueous paseof the solvent ext ract ion prt,ceu. An artne- ty pe corrand carried in k ert sene

l ot s f r.;m th i s equeoa ( r a f f ir.aT e jmill be used to selectively absorb the war.adta as an am-s o l ut ion . The organic L11 te stripped of van 4dium with seda ashsonnua metavandate prec ip itate. The s it,rry i s to t,e filtered, dried 1r amultip|e-hearth fur-ace,ard f. zed to produce black t !ak e 0 ;De,1. m% ,ch 14 alsot3 be packaged in 55 gall:en drums. Ris eperation is to be conexted underccnditions like that for prepartr.g yellow c ak e f or market , including wet scrub-bing for collection of particulate r.atter.

Ccal mill be used as tre mator fuel fer both process steam and spaceIt is estas.atedheating, witn oll-fired teller as stanabs for 30 days p*er wear.

that the maalms heat input requirew.t m111 be 53 1 1.- BTT s per hcur (42 tons

coal per dev). Fly ash and bottoo ash will be sent to the tatlings ponJ. Itas proposed that the coal fired boileri be equipped utth a csclone f;v ash col-lector of 9C1 control ef ficiency. DLe to the ssall si;c of the propcsed 011-

6 BTU /hr) and lia.ited operating time (30 days / year), therefired boiler (10 K ITis no intent to apply particulate emissions control tc this source. ffN, Inc

environmental report Indicates that the sulfur content of the enal to te usedwill be 0.31, which is about one-half the aserage sultur ontent of Utah coals.

The bhite Mesa Urantum project includes construction and use of a laboratcry.Caseous fumes emitted from laboratory operations mill t e small and consideringthe dilution in the co? -tton stack should t e inconsequential.

M

There util be ft.> .a ve particulate caissions resulting f ram censt ruct taaactivities; wind eroston of stockpile d ore and coal, f ront end loader har.dllr.g

vehicularof ore and coal; mind trosion of a portion of the tallings area;t raf f te on unpaved roads.

See notes and calculatior,s on Appendia A sheets and Table 4.1-1 - Cas- g)Fee-Dust Generation Areas; Table 4.1 2 - Stack Heights and Emission Data. ,4

See pages 6-13 - Envirorur.ent al Report. Dares and Mucre four.d that 'j(>h'

- -

max.mm ground level concentrations f rom the dryer and boiler stick wereootained f rom stable cor.dit aons and low wind speeds. Theref are , dif fuslen ~ kc ")calculations should include use of a stable etsuphere (F Stability) and wind b,speed of 2 meters per second. Terrain fluctuations are slight within 2000 k

be consideredmeters of the proposed m.11; theref ore, terrsin prebably need net .-Ain dif fusion calculations. .-"D',

David Markley, Env tronn-ental Coordinator, was contacted by t ele phoneDe c embe r 6, 1979, relative to need far additional information and clarifica- (Y['6v,% ?tion of seme statements and data an the Feru.it Application of November 21, 1973. CHe will cor. fire repliek by letter. fc ;. {

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Social Services MemorandumTo- Richard C. Hansen, Associate Deputy Date Jana r y 25. 1779

Cires tar of Hesit'

F rom - Alvin [. Richers. Director. BureaJ Of Air Quality

Sub ect- White Mesa Uranium Projectt

Tne envirconental 1.rpact statements for the Weite Mesa UraeteProject prenared by both Cames & Pk re and the Nuclear Regalatory Ccm-etssions tave been reviewed.

While both statements address air quality in a very general way,The bac6grou d ambient air q.alitythere is concern about bot't docurents. n

data from the proposed plant site which are referenced in both documentsmere obtained by static sampling. This method * * .wot equivalent to the LP Areference method and therefere. the data arc sabiert to qaestion. It isdoubtful that such data w]uld be acceptable garticularly if it were protesedfar use ta fulfill the requirements of the Federal Prevention of Siget f tcant 7Deterioration of Air Quality criteria. O

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UNITED STATE 5 DEP ARTME NT G8 ACr..Ci;LTURE q;r 33 r 5

SCIENC( A'43 EDUCATION AC W,N 3'm aTiO4

Ge *Kt ce Twe Dee, v omecrea p wa atCuttu at agge ancwm.c.s.,msre o c aorw

Sub j ec t : Draf t Environmental Statement-White *.ema Uranius Project

To : Boss A. Sc a r a au. Os t ion Le.ederU.S. hclear Replatory ConastesLoaDiv. of Fue.1 Cycle & Material Saf ety

W ahington. D.C. 2055%

We have reviewed the draf t environeental is et s t a t emen t related tooperation of the proposed White Mesa tranium Praject loc a t ed inSan Juan County, Utah.

We have no commeo's to add to the staf f evaluation and recor.nendations.

We appreciate '.aving the opportunity to review this d3cument,

fy a-

H. L. BARRoads o MWnu is MM M1.Acting Deputy Assistant Administrator .

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Y[pAssistant DirectorFuels Cycle Safety and Liceruilng / d,s g ;thited State Nuclear

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| pZM791S Eastern Awnue 9 W< . j f - />)/ ,f [M?Silver Springs, Meyland 20!O1 , *| > , - -~

RE: White Ekma, San Juan Omnty,

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Dear Mr. krtin: xx,;/ ; ;4

The purprie of this letter is to addmsa srie additional mncerns that % 's - ,

V ' [)the Nclear Rmulatory Ormiminn and ttw Adytsery Quncil nty haw , / ./mncerning the mitigation of cultural resn2Tes that are teing impacted ( ,'.by the develc5mmt of a processing nlant on White Hesa by Erwrgy hels ,

Nuclear. g ;#

Oie issue is alternate site location for the rrdll and tailings. It is 1. The staf f agrees with the cyrient.Our tuWrstanding that altemate site s wre mit considemi tx'caum ofhydrology prtblem and that twause of this, arctww>lcgical sitriim weresvit Crie of thme areas. It is tre opinion of our staff that if studienswxild have been dme of the four alternatiw sites, that a higher oremial degrw of density or arctmlwical sites wuld haw two locatoiarn rinre arplicated mitigation risy have twn requirni.

A mvond 1smw concerns the p wsibility that this area could te coutsideresi 2. This opinian was revised by the Utah State Histeric Preservation Of ficer,as a presible rknination to the National P4xister of Historic Places as an The White Mesa Archeol>gical District has since been determined to be eligiblearchmlwical district. It is our @1nion that this informat tart by itself for inclusion in the hetional Register of Historic Flaces.wjuld te insuf ficient for rmination as a district, it is felt that thetotal area of White 4 sa wmld haw to tw= laaed at to te nminated. Thetxundaries of this project wuld be comWm1 artifical and wmid ruttake into crxisi& ration the natural tarriers that wmld te nece*sary fora rkninaticul.

In strrnary. the altematin sites. ewn if trere wmld haw t**m rn hydro-Icgical problms, unld protxtbly have preent.wi a larger pr.blm in themitigatiori of cultural rmurces and that t% rvrunat ten of the sectimsof land anjund the ptwewing plant w:old r'rtbahty te unacceptable as anardroirvical district.

i!%3n% Ot . IND( $1 RITI. rkdalOIlON IR M i t IM % f l 014:l % I . I Nrt WillON% . 4141 t IllslOH) 'f%f % .li

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Jarman 15, 1979 w t.se ca.. t i.h set :4Teneptione 490t s S11996t

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0Mr. Ihmis A. Scarara) WFuels Cycle Safety aza! Lice nsing 4 /

thitesd States Nuclear Itegulatory lg' '? -)Ormisuim /-

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AIE: Quramts m Drift EIS Staterent, White Nsa Uraniam prnyt

h-Dear Mr. Scarns): gq

v.-/>In mapone to ymr rnluest for review of the draf t envirun ntal bi " G D

inpact statwomt on t>e White nk sa l'ranitra IWJwt, the staf f has 3 'S Uone Eeneral a.rTymt and thrw sprific arrrats oncerning the ' , . ,

,

cultural receaurces and the p>tential inpact on thr,*e remunw. V, f. . , '3y(/ ; ,,In general, gerhaps mre space emuld havt> te allottasi fer a

j ,. - ,9discussion of the fuckgnund of arcimlogical 1.7 mets and pmpet U

mitigatiora of trame inpacts. W ,'%

Specific errrwets abtut the statewnt are:

( 1) 2.5.2.3, ggt. 2-19 lh last paracrarn shuld read 43 arctwo-. 1. The tent has been chanced to the correct nufrcer of sites.logical sites instead of 25 archeoleq*1 cal sites.

(2) 2.5.2.3, pg. 2-20 - Chart 2.18 shuld raflect all 112 isites 2. Table 2.1S has teen updated and a footnote added that af fected sites are show.

located. It tai rval12nd that the inforratio i on all site was in Fig. 3.4.probalily Ik>t available at tte tire of tic draf t, tut t hr new in for-

ristion stuvald te reflected in the final staurent.

(3) 4.2.2. pg. 4-4 - Crwerning pararraph 3.1t is stwestal that 3. Appendia E % been included and shoald resolve this corrent. The actual

ttwre shuld be mmitoring of act ivities at the ' Jill Sites for motiltoring plan will be c'eveloped in consultation with the Utah 5 tate Historic

sulmlent dwlopent activities, which we artw wit h. tu w ver, Preser vation Of ficer.the Lt* of the tem 51111 O[*: ration siwsts that an archeologisttwa put m the staf f to nucitor all n!111 Oe"2t i'm for the life ofits* Mill, ami w fwl thi.4 is unn+wwsa r.

' 8 % INION Of l%Dt' silt | Al Filostull4 5% . IM M lf 181 % |l t DW hNI- I Nh allI4 8% 43 %le tilS l oh ) (INI gMig-

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ler. Ikms A. ScaranoJanuary 15,15r/9Page 2

If yw have any qtystiaris or cornrrns, pleu# contact W1LS c G. hrtin,(801) 53M4)l7, or Jses L. IMc un. (801) SNKXJO, Utah State HistoricalSxiety, 307 West 3]O Suuth, Salt Lake City, Utab EL110 L

Sincerely.

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andState Historic Preservation Of ficer

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Ns _ )17 D6 P\R D1LST OFMr. Jack Martin Dt u tOPstLNT M RitCESAssistant Director

" . . d r a'-HeFuels Cycle Safety and LicensingUnited States Regulatory Comstssion7915 Eastern Avenue o,,,, %w w ,, mSilver Springs, MD 20901 w s.m. ona =4 unu

*****#"*"Dear Mr. Martin:

Several issues have arisen during our discussion of the WhiteMesa Mill and Tailings Development. We would like to go overthose concerns one at a time.

First, the selection of sites for the location of the mill and A. The staff agrees that a consideration of archeological resources would notresult in the choice of ancther of the alternative sites in this case.tailings. He understand that alternate sites were not

considered because of hydrology problems. However, it is theB. Pu-suant ta #6 (FR Part 63.3. the White Mesa Archeological District has

opinion of our staff that if the four alternative sites had been determined to be eligible f or inclusion in the National Registerbeen researched for archeological resources, that areas of an of distoric Places.eq ual or higher degree of density would be found since thesealternative sites have similar characteristics and the problemof high archeological densities would remain. y

*Second, we did not consider nomination of the site as adistri:t at this time. The portion of the property beingdeveloped by Energy Fuels Nuclear would of neccessity have tobe the boundaries of the district, since sufficient researchhas not been done for the whole White Mesa area. Under ourrules, this would be considered an artifical boundary and would

Rh"' 'not be an acceptable perimeter fer a historic area. Therefore. --we have considered the individual si tes or, an individual basisof eligibility. This criteria would apply regardless of - ,7whether it were a district or not, since the sites they have CC^found not eligible would also not be eligible within a historic ;;

{ '>district. -

.:,If you have any questions or concerns, please contact Wilson G. DC-

6' , _Martin, Preservatiort Development Coor dinator, Utah St atellistorical Society, 307 West 200 South, Salt Lake City, Utah

'-84101, (801) 535-6017. .-

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{g>,'J ,Phillip Keene IIIExecutive Director --

hj-andState liistoric ?: .ervation Officer C*

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February 2,1979

U.S. Nuclear Regulatory CornissionOffice of Nuclear MaterialSafety and SafeguardsWashington, D.C. 20555

Dear Sir:

The staff of the Blanding Job Service Office has been rather oceplyinvolved with the Energy fuels huclear operation from the time itfirst started in San Juan County. The past, current and, we believe.the future impact of the inergy fuels program, has teen and willcontinue to te very positive.

Our business is jobs and this is what Erergy fuels is providir.g. Inan area which needs jobs very badly. Tra draf t environmental state- No response is reodred. 7inent which was issued in Decenter 1973, does rot #idress sory socio- *economic conditions wnich relate to the need fer jobs. For instance. "

the November 1978 report from the Uta5 Cepartment of Social Serviceslists 555 families containing 2.084 individuals ho are receivingpubitc assistance in San Juan County. Tnis c,*s not f aciude inh vi-duals who are on redical assistance only. Tus reans that 14.78s ofthe total county population is roceiving putlic assistance under AF DC '\or GA categories. This is by far the hi?est welf are percentage in t' A )fthe entire 5 tate of Utah. It ts our feelirg that the only way to HOreduce this 'Inancial burden and br ein tne dependency cycle is to /. , /provide high quality joos. [f .]

'sA review of the craf t statement indicates that Ecergy Fuels is pre- b[- .5pared to do an excellent lob with enviromntal and other cocrar;ity c<''concerns. On the basis of these and c>t*er 'ac ts . .e support the con- f.structica and operation of the nihite "ess uranium mill and u ge you

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to issue appropriate Itcenses as soon as possible. -1- ' ,)C. M'?.oVery truly yours. (q-

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Penn. State University

University tark, Pa

16EC2

5 February 1979

Director, Division of

Fuel Cycle and Faterial Safety

U.S. Nuclear P.egulatory Comissioni|ashington, D.C.

20555

Gentlemen:

Enclosed is my analysis of the bhite Mesa Uraniu:n Projact.

Please note that the infomation is my own and not necesnrily

the opinion of The Pennsylvania State University, whichaf1111ation is given for identification purposes only.

The scalysis ir. the draft does r.ot seen to satis fy NEPA. yZ

I would here that these r.stters are addressef in the final Es.

Sincerely,

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D OAn Analysis of tha Preosad

%ite F%sa Uranie Project

by

William A. Ine net

The Pennsy11rania State lle.iversity* The staf f has chosen to liW its radiolojical assessment te ar. eval ua tion of t he do se

February 1979 to t*e population witnin an 0-km radios cf the plant integrated ever a 50-year period

The Nuclear Regulatory Comreission has atte*rted to evaluate "" " #''# '" ' '## "'"9"*'

the environnental imoact of the proposed lite foesa Uranim 1 The radon dose comitmerS becomes a very small tractim of the natural bac h roaddose t'e,ond E0 km. T a bl e 4. 7 c f f.h t s coc eer t shows t ha t t he bro % h t a l er s t Na l t epcpulation dose witnin 8) km (132 man-rees per year) is caly 425: cf theTroject (Ref. 1). The long term radiological effects arebroncMal epithelium population dose f rom ratu al badrou d (23.000 nan-re-s perr n

dismissed by estimating thtt the radon eiissions fre tFe mill Y''d '2. The cstculation of the mauf mum anr.ual dose free ene year of empowre integrated

tailings will be twice background. Erosion of the abandoned over 53 years provide a realistic estimate than can easily be c* pared toapplicat,le stanJerds and replations. The sta'f coes not f eel that it is

tailings is to be minimised. These e forts will be examined realistic or ireantvul to ccnstder effects on a time sca!e of 4.5 m 10' yearsr

as pecposed by the c omentor. It should te noted that the 3.2 = 10' deathshere. es timated by the comector cwer 4.5 billion years is only 0.GM statistical

premature deaths per year.

In 1976, Pohl (Ref. 2) pointed o2t that the thorium-230- Also, twcause tne depleted urante tails from the enr1chment process are not

. necessarily waste and it is a NEFA goal to attain mantmum use cf depletablein mill tiilinats decays to radium-220, which in turn dac3ys to resources, we would consider the errichment tails as a resourc e. If. hcwver

E they are to be corstdered as waste, tbc staf f pel f e,es the relucticn f actoeradon-222 with a time setle det ermined ty the 8 x ID . ear half for radon of 200 to be unreali s t ic. In f act we would assign a zero tr; crease i

w

of radon above that naturally occurring if the depleted eartc' rent tails are ~

16fe of thorium 230. Recently, Keoford (s*f. 3) has s'cwn buried at a certh and crosicnal environment similar to that of tae d e f ormerplace of natural deposit. hiithout the ecrtchnect tails, tre 5. 3 a If deaths

that the urantual 23d in the mill tailin;s and in the urantun estimated by the correntor over 4.5 btllton years is only 0.018 stattstica!p re"a t ore deaths per year,

eneichment tailing,s,of the rmoun diffusion elants, decaysThe Dakcta Sandstone underlying the tail tne impou dnents is about 70 milliennyears cid. The staf f considers it unlikely that tt will erode away in theQ by several eteos thru thorium-230 to radon-222, a ni s?nid

LJ foreseeable f utu e.r

f2Q be considered. This crocess orerates on a ti .e s M le :'F emnedC- C Recert public hearings before the Atomic Safety and licensing Board to consider

the question of the proper assessment of the f.tpact of raden releases f rom theM. by t he 4. 5 x 10 yea r hal f li fe o f ura ni ri-/3 e. These natters nuclear fuel cycle and health ef fects that can reasonably be assumed associated59 therewith have supported the staf f's position.(y}p' We believe that to attempt to fin absolute figures for health impacts

over hundereds of thcusands of years, as Dr. Pohl aid, represents* The oninions and calculations prese.t ai here are ovTi, snd pure sreculation . Our " rule of reasen" then, would be to look atb_ _I)( not re-assari]v th9se of The Pearselvania P i t- ' -i v > rsi t'r absolute figures only for those periods for which reasonable estimates

can be made . and to accept the notion that ef fects beyond thatcmq ry a f filiation is riv+ n hera far 'entificTti e o rroses only. time can be adequately quantified by no(Al snell" compared to natural tackgrounds,}ing that they are "tecasurablyr~ 7

G)[y *

The July 24. 1978 Partial Initial Decision of the Atomic Safety and 11certingt -c;) Board Authorizing limited work Authorization, Black Fon Station. Units I and 2.G .-c :aLWp

7-

N

-

. . _ _ _

'. hite l'e n 2EE SFOMI S

rave been aldresse d by Dr. R.L. 'htcr y of t i-a W Ltaff (Ref. L)* . we tci tcve that we ha ve an ebit gat ten to a ssess tw ef fec ts o'* * '' "I' "5 ''" ' * t"re cener a t tans . .c certa W f %st cecuece

T.nese argueents will be considere t in * r e ene of t r e any s'nown ef fet ts on ou i-re31 ate s#ccessors as of f ercrtance com-r

parable to ef f ects on trose new livins. When tt naes to telsacinq'hite Mesa Uraniun Project. aJoerse ivacts to 15ese descandaats w o may f alle= a et111cn yearsA

The Tite Pesa mill is expected to rro hce 7.? x 15ke; cf '"'' "''. against tre berefits to tne pesert eeneration. we wo#14wet #t t.enefits to tne present ecW14 tion. Toe t'enefits arecertain - the tsacts nypetectical T*e a:t toa creseatly proposed

U0 per year which for 15 years o f areration wul. vield34

' is act ene that presents a se-sous risk to any f tare severation.

7a total of 1.1 r.10 kg (Ref.1, P. 3-1). Of IFis tml, inis evaluation is suarted ty the ora't weric Envirowntal 1%act Statewnton Uraniam Milling, EREG-C511, April 1979. Spec i f ic a l l y, re'er to Tabie 5 in

9.3 x 10kg would te uranium metal. This is the waterial s51rpet tv surmary of that ox2nent, ertitled Crepariser. cf Ccet+neas Releases ofRahn try Urania* Mill Tailing =6t9 Cther Centi vous fiaito Releases."

away from the mill for isotopic enrichnent. The mill is

exoected to operate at a 94T. recovery rate for uraniwn (Ref.1,6P. 3-1). In this case a total of 9.9 x 10 ag o, urmim 411

be contained in the ore sueplied to the =111. Of tFis,

5.9 x 10 kg of uranium will remain in the mill tailinz,s. d5

g@Pith an extraction efficiency of 955 for ttoriura, (Ecf. 1, P. 3-11) , p',(.

a.these mill tailings will also contain 101 kg. of %oriur-2f 0, { .

Iwhich remains from the total that was in secular ecuilibrium (M

v

vith the urantu.m-23 A in the ere. Of *he uraniu- s51*; e.1 am y, ,.g7.'. x 10 kg will remain as tailings (derlat ed uranium) fron tr e 'h6

>-', - Z,,2enrichment process. - -cq

,

t'/, 3The ultimite decay of tra 5.0 x 'O'se 3* urci m in *he

. . .N, [g . )4l-ill tails will tro Nee a * tal -f '.5 x lo curies of

ra d an-222 The decay of tr.e 161 k g o f th r l '. - ? ? ^ ili yield "/ '--' ''

2 . !. x 1010 curies of x radon 722. The decay of -- 7., x idhg'

, ' , ,,,,

\ ['of depleted uranium from the e,rict-ant troecs: will result inV

161.1 x 10 'curias af radon 222i t,,;n eTha Wtcrp1 in to rc h a ra :n - ee-n to <

:n . a- i ~ i , The July 14, 1978 Partial lettial Decision of the Atomic Safety and LtcerslagTF 3 e * 111 cal c 0,+ 1 m f :,f. 1 * . i m e-

Beard, ferk tes P.;cicar station. Unit s 1. 2, and 3.

rara of I r,i/ "in- 'i * * ~ " - -ir'te 1 :-~

' hit e resa 3

20.9. 001/m eec. The diffarence of 0.?o ,21/n2 see is t he excess

exoected due to the tailings. The area i s ta k en a s t ha t of

6 cells of 26 ha cach (Ref.1, P.10 0) -ttb a total area of61.68 x 10 ,2 This results in an emiss n rat e of 1.3 x 10-6ggj,,c.

or 40 C1/ year. Considering the ratio of thorium to thorium in

the tailings and the half lives involved, this results in a total10of 1.6 x 10 Ci of radon released to tha air, primarily fron

the decay of uranium-234 This of ecurse assumes that thesoil cover remins intact for a reriod er time longar than

9the 4.5 x 10 year half life of uranium-23?. This is not likely.At present, some recent dry mill tailinfs piles have two

feet of dirt covering. In this case the EDA estimate is that

1/20 of the radon escapes to the air (F.ef. 5). The promseistabilization will have more than this e:vering. The downstreamslope of the filst final, soutrern.most fike is prorosed to be

'

6:1| Ref. 1, P. 10-9). This will not -to . erosims. The only u

ouestion is how long it will be before erosion cuts into the-.

o,tallings volume. The effects of erosion must be considered &over a tir e s pa n messured by the half life of uranium-234

,/,On this reologie time a scale it is cle c that hte entira : e sa y,,.

y, wwill eroie away. The tro;osed site is 0;anied on the we .t bywestwater creek where tFe surface drns way as much as

7,,._240 feet in 1/4 mile. Directly east of Ja site, t he surface J

y. ,O',

D(,,,

drors away into corral creek as much a s 123 feet in 1/4 to 1/8 hCof a mile. The difference in rel eir i- '3tt,nv,v' C n an

is un to 750 feet ( Aef. 1, " 2- b). e cu s ti3, is hw lov // '" W. . , -will it tefare t h e antire me- e rMe = s Ta ' ve ra ov-r '. .

_ . _ . .

" bite besa k

the effect s of erosion over lone; rariods of time eni possible

re-burial it will te assued that 1/20 of tre radan troducadin the mill tailin6s escaras to tFe atmosyncre. It sh3uld benoted that this figure ref resents an averare ovar ti-e ar.1

loestions. Deterioriz2tien of the stabilintion of nill tailsoiles is recognized by the N20 staff ( Ref. 4, P.f.), but not

discussed in the EIS (Ref.1). It should te noted that thissituation could t,e mitigated if the nill extracted more of the

uranium and thorium, or if the ta111r.es vere located elsewhere.It should be noted that trucics will be returning from the 3

mill or ore buyir.g station to t he mines in an empty state.

These trucks could carry tailings with little addition 21

effort.

At present there is no clear Lisa for the disn7 sal of>kthe depleted uranium fro * the isotorie enrichmnt trocess. +

At present such material is located in the eartern part ofthe country. It is assumed that it will Le buried rear its y

L,qrresent location at so,e sballow derth. A reduction fa ctor of 7: s

C/-)1/200 is ased here to acco ent for t*c 'et*.r c3ndition of k'['g-

.--)^15the si soil. Thus, of the 1.1 x 10 01 af Rn rea beed ty M-]

h-dt he dacay of tFe enrichnent tails it is estimated tnt

12'.3 x 10 Ci escar e to the atmosr5ere. .f .- q

- _ jTo estirtste t he F 41t h conse,uan ca = of ther* -alenses, it ?

b}gg)s

t nece m ry to deter-ine t se r uu12 tie, . ri: - - - o e.21 < 13 n

,) o' . ~ ~, 2 5v ' .: e of q 'pe m iderei b re is thtt of t'- '

.

G

WoCCI

T

'hite Pesa 5

tFe rest of tr.e northern hemispr ere, r ace it is r.3t t,ssikle

to credict the U.S. populat ion thourar ds of years into t ra

future, the present population with its tresent s atial

distribution will ba used as a first estimite. TFe !.iC Stafftas already done this, assu,ing a U.S. population of

300 million (Ref. 4, P.3), with the result tr.a t t r.e relesse

of one curie of rad 7n-222 from a typical pile x will result

in a total of 0.56 person-rai to tha tronchial epithelium,for the total population. The total d ases which result are

shown in Table 1. It shou 11 be noted that 10 CGt fart 50,Appeniix 1 presents a guideline of $ 1000 per total body

person-rem. If this were applied to th bronchial cr itheliws,10the NRC estimate of 1.6 x 10 C1 released would result in

8.7 x109 rerson-rem for a cash estimate of $a700 billion.?The K9C estir. ate of eineer risk is 22.2 decsths perS

million rarson-ram to the t ronchial crithelium (Tief. 5, P.7), "NC9/and is takan fron MA0H-14N) and Gesm3, Even though this f;;}sestimate in too low, it will be usej here. The results, ( j'. ~- ?)'

stown in Table 1. are t ha t the thyrium in the rill * ails vill (I< . ,c))Vcauses attut 15,000 deaths, while t r e uranium therein will

C" ,_

-

result in 51 million deaths. The derlet e 2 uranium sill result ,s -

({' . 1,)Nin 66 rillion dead. Even the NJG estinite of ra don relea sas C- /I:-o.- : -will result in 196,000 dead.'dI,- - -,- s

The,e deaths will be accumulated Svar a v rv 1 ng;i-e U, e ')'t - ',-;rario1. Tra a*ti* ate is trottuly ir.correc du an ' ,);f < )u- br -* i.ma t ion o f tor u1 ' t ion r" .' r , ~r. ..ly te he' '

IS',

<M.

4hite Mesa 6

consecuences for runy years into th e future. Trere is no ta is

for an arbitrary cutoff at any poir. in ti-e. In fact tne long

time period used here is renuire;i ty footnote 12 of ?RUC v.

U3nc, %7 F. 2nd 633 (J.C. Cir.1970), which st e es in Tart:

ke note at the outset that t!is stardard is risleading

because the toxic life of tre vastes under dis ussion

far exceeds the life of tre tlar.t being licensed. The

environmental effect s to be cor.sidered are those flowir.g

from reprocessing and tassive storage for the full

detoxification period.

It is felt that this state **nt takes trecident over statments

of the Atomie Safety and 1.ieensine Boards in th* Perkins

and Black Fox cases.

The comparison of these health ivaets to tickground is

totally irrelevant, and contrary to t he f;attorul Environmantal

Policy Act of k 1969 (NEPA). To carry out a prcier cost - benefit

analysis, the total costs must te considered, re ardless ofr

whether or rjot it mig.ht Le possible to statistically detect

or measure them. NEPA does not recuire an environmental0,' Q-

iassessme nt of backr.round. It does renaire an assess 9ent of

, . 'r.).. . h.(

the activity in questien. I n t hi s s i. . a r.cocer cost - L* nefit ',

(i . , . i..ganalysis will bs Performed. In rarticalsr, in 041 vert Cliffs_.

Coordinating Connittae v. USAE;,1.4+ 7 2nd 1109 (L.; Cir., 0

1071) the court stated: -,

/:' )('yWe conclude, then tNit Saction 102 of N r?s m 9 dates a '- ,. ,) )

-

'('p,f1particular sort of cir-ful un t ; r fo r-ai tectrin9 - rikire

rirocass a91 crav es ,in.*Let'll" -Perc2ble ?tos..... (: . 3;

Y ZBut if th* "acisin9 ms rea c' a t race nr 11y _ -,ut

M{gtr.aivu m i- n-c -,m e ,n f . 1 , r., 1

%w.fa c - - , ~ fm y . , . . - n_. .. .,

I# "o" i } k 7 '[ 9['% C",.'[' * yp7{e,

M.ite F.esa 7

Thua it is required tt.a t tha ansl: sis t e con it.cte d hw tly

without ruling out cost s procedurally. T ere it no tasis for

an arbit rary cutoff in t1*e er in distance frci the facility.

It is ho*ed that t t ese issues are a ddressed in the final

environeental state-ertt.

h,r1 5

em3mtgash

%?)&>V

lf)d')/// |j/,Yv

y, 0?t.f~,/ Q .,

*

%,f'i'/i;f

' hi * e !'e sa 8

D: se Commit-ent, to Drans le t o i* it e *'e sa Fill

Table 1

Oririn of Radon neat.cti n ro7.;13 tionSadon renerated

Fact:r DJseCuries 9

PrenchialErittellit,

Person-rem

Thorium in 10 g2.L x 10 20 6.7 x 10 15, COO

rill Tails

Urtnium in 13 12 78.5 x 10 20 2.4 x Ic 5.3 x 10Pill tails

PUranium in O

15 12 7Fatri c Fm ent 1.1 x 10 200 3.0 x 10 6,6 x 10Ta ils

l'ill Tails

10rec 1.6 x 10 nona 4.7 x 109 51.9 x 10Estimate

thite Mesa 9

Re fe ren ?1

1 Craft Environ. ental Statement rela ed ta oc . tion er

thite Mesa Uraniu= Froject, Faerr.y P els :Nc. ar. Inc.,

LT RILC49!. . Docket ?.o. 40-86dl, U.3. huelear Eer,ulatoryCommission, December 1978

2 R.O. Pohl,"Fealth Effects of Eadon-212 from Uranium

Fining", Search,2 (5),345 - 3 50 ('urust 1976)

3 Testirony of Dr. Chauncey R. K er fe.-d , "Fealth Effects

Comparison for Coal and Nuc} ear Tower" in ti e ratter of

Three File Island Unit 2 (Docket ! $0 - 320) ort-rating

license hearings and portier.s .of t rarscript related,in which the NRC staff supports h er ford's nu.mb ers.

4 Affidavit of R.L. GoteFy, KRC Sta ff, * A rp-ndix","Radiolorical Irnact of Raion-222 Releases", U.S. NRC,in the matter of Three t'ile Isler.1 Unit 2 ( Docket y/ 50 - 320), (January 20, 197!). $

$ " Environmental Analysis of the Uranium Fuel Cycle, Fsrt 1 -Puel Supply" ETA-520/9-73-003-3, U.S. EnvironmentalProtection Agency, (Cctober 1973).

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. tat t ed st.tes ~c , ..,ui stor t -i e s,on , emu.r,3.Ic9

City d Blanding50 WEST RST SOUN STREET

*

FOST OFNE tion tieBL. ANDS *eG UTAN e4%tt

idOh 678 2 yet

cul t..ary = ate r surply and #1 str a t=t ton syster. However , the closeF e bru ar y 1. 19 79

?- relationehty with Energy Fuele managecent has enabled us to plan and, p _.s prep ar e adequat el y for that i mpac t . It t o our understasatira that the

,l ere con.truc uen u e. t .u e 1. - i .r , e i , in .re w. of e e t.-le.tPegul atory Coe*t eston. be r espec t f ull y ut s e g reert and f avor ab;e ac tiong g

(p i on the elll licecee so t * a t tre tweleweeting of our plane sav be espeditedcon s t et ent wt 3 antle trated emane t c growth.t!nited States Nuclear g f ,

Penulatory CoseisotoaM''"'l?*7915 Eastern avenue un ,

Silversprinas, Maryland C, ecc ; ,

a u, . - .* s e -

At t en tion: Pr. Rose Scarano 4'

LeLae4r ci bbnna , P.D.,

Ma yo r-

Ceetlemen:TEN: e in

As elected represent atives of the cittaene of the City of cc: Overter of Ut ahBlanding, Ut an, the City Council and I here=tth set forth our conseent s (m er emotocol Pet r ement at ivesrelative to the Draf t Environe' ental St atement on t he khtte Pese traniusPro ject proposed for development by Energy Fuels Mclear, Inc.

During the past several year s, while Energy Fuels has beenperforeing baseline environmental studies and prerating the mill etteapplication, our primary consideration has been the impact the millosseret ton and increased resource development and production will have yon required municipal ser vi c e e. We have developed a cooperettve wut h. M.,

ing relationohtp with Company ennagement, which we f eel will assure that.

the tepacts and demands on the City and it s services will not be d i s-

ruptive.

Since the discovery of t'rantum-Vanadiusa bearing ores in the giarea in the late 1930's, etning has played a significant role in the b'y / )-

local ocorney. Wen there has been an obsence of a earket f or ur an t um '- s

ore, the economy has been deprea.ed, la recent ye ar s such a depression g.,-has esteted until Energy Fuele revitaltaed market activity by estabit shing (~ '3buying statione at Blandt og and Mack oville, t'tah. Since that time, eeny

k- -of our cit t aene have found productive, well. paying jet,s developing and,.h'mining uranium ore. For the first time, eeny of our young people who were ',(prewtously forced to leave the area for estisf actory employv4nt, now have

the opportunity to reesin and find fots out table to their talents, y_

( ';. ' -Direct and indirect growth per. orated by the plant con s t r uc t io n, ,

resource development and production will teract quite heavity on the City (; ;vf.k./ ,- 's?!' \ <}

ne ,e

y(h/,,./,Q',

-

he'<-y - /g('/

s

_ . .

. ~ !g? 03TY OF MONTICELLD .,. _ _ _

San Nn Schoo! Dbt,ct -- ' ""- - - ,_,n,mrm.: , _; --

_.u we < e4 Lia* H i . >

. . , ..--

iwr. - ti,"" ' " * * * * February 7, 1979

t- [%F , _

U. 5. hucleae Regulatory CommissionI'L' # ( ! IIII 7915 Eastern Avenue

Silversprings, Maryland 20910Directe A T T E N TIO*4 : Mr, Ross ScaramoDivisien of F el fyr.le and paterial Safetyb.$ hxlear Regulatory Ceen a s s ion har Mr. bram -Washirston, D .C . 20555

an uan wa is e nsup a7 ateRe: Wnite Mesa tirani e Projec t - focke t #40-f f s lof Energy Fuels huclear, Inc. for a source materials hcenu whh respect

Gentleren' to its pr@osed ureneum mail to be kxated appromimately sim asies south ofEilanding, Utah.

Af ter studing the env i ronmen t a l s t a te er. t ard attending a twS!!c eeetir;.'I**''C"* *d * ' * * * " E"P*CI d" " . .

of energy evelopment in our county.'*The propo,ed energy developmentheld by [nergy Fuel s hclear, lec . , mg t he C i tv c f moe t i< e l Ic. =oul d 14 keto go on record giving approval f er tre atrese r.a =J project . program well add sagnificantly to our county tas base and will create an

attractive bb market for our high shot aM co!!cge graduates.S i ec ere l y *

T he benefits of the proposed energy p'ograte are siqnifKant. Yo-

T ' *C I TV, C F #aCN, I CE. LLC , For the soove reawns me resper avully urge that this le(ense be issued en. p.

~Re [t h,,9. Redd- 8, ',4 the hortest time possible.

Mayor$*nc erely ,

s'.NS /f 2E'wegti La=l, Presederit

,- hSan Juan Board of Edaation?RDLtc s, -

[1-i s',: - a

.)L. ,d

W-n'

. '

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t /XO))'V-: '(O,> T '.

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Vs %. /b .

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SC w.vun w;-w

(v i ?./g;:SAN JUAN CENTER FOR ''

(, ,1 .

HIGHE R E DUCMIO N < -7e( t ;

Lynn Lee. Drecxor s V [/. . ' CeUegt af EastarT.M-y \... \-- (s

p. ~ 't. '(.,' Februar v 5,1979Fd rarf 5, 1979 ! . -3 , D " h'

k?f ' '.AM N

Dire-tor, Divisim of Pal Cycle and Material Safety Af\s -3f g

Ag V1:.rs. Mrlear Rivplatory CrTrissim 4 NyWashirytcs D.C. 20555 "

Dear SiriDire < tor. Pivision of Feel Cvele and %terial Safet y

I have reve1ww! a draft a4y of the Yhy_1r eruvytal_ Sta!as_ wit _Fw-l_ ate _i tc_the L' . 5. NLC1. EAR RECluTORT LPat!SSIMw ratim of hhtte Pbwa Urar.i.rt PrMM Ther g 79a 19 vrlmr, Inc. , anl disets- hiashington, DC N555

Q' sed the pr't[osa!' mill with [ersmnel Frd 'ther org Award 2:23 'like to arrumt--~y

Ee: Energy Fuels kc learSan Jan Cbety 1.s located in a rarte area of tJe bouthestern tk.ited States, White Mesa F*ciec t

is si.ars11y paulated ard has very fm imbstries. Uw swutherTt third of the Dnc h et tw. 40%siamanty, stud mntains rearly half tk residents, has an extr>rm ly h14t sawg ley-merit and underplopemt rate (5;t) with ordy 15% of the ele lator form zwwiv- Sear sir:W a salary of $5,000 or riare.

It has been broosht to av at t ent f an that you are current ly reestving Ine estAlishpuer t of a ura-am pm.pssirwi mall at Wate % sa m the very public cosanert e on t he envir.3nment al draf t f ar the White Mesa tranium Protect $

aise of reservatim land, represents a ptential for erpicypuet W.16 has pre- proposed by Enerar Fuels Muclear, Inc .viously bevet mavaildle. 12m rgy Fuels Nuclear has lmt its sqwrt ara $ hasleen involved in the develgremt of bill.mpal tralru.N ruterials e.id will The Collese of Eaorern Ut ah has been tavolved in the Standles, saamable bilirytal Nwalo attlts to galify for erplcymet in the paning irstastr). Juan Count y, tr ah, area since 1976. Althwah most of our of f orts have been f.aIn as nud as an eJtimata! T54 of tre 95 wirkers rapiral to gerate the vil the prof essional preparat tan of billagual/b1 cultural teachere and teas her a13eeauld arme frun the local jet market as wa=11 as a substantial percertain of non- we have had a chance to observe t he development of ene rge-related indust ry isbeste sector jrtas, the (Teatim of the utill reptvnents a s1Tufierant omtrdt.r- the area.tim to the owtall ermz9y of the mur.ty.

The uranium mill propcoed by Energv Fuele Ec lear, la ou r opinion.We a[preciate the omtributist Energy Pals has already nmie to our ctrrtr:- can indeed have a earteJ f avorable et tee t ce the residente of han Juan Count y.

ity ard we sunort their ef forts in aanstructiry tJu WMe %%s l'ranam Mill. Inasmuch as t he area is at present virt ua lly devoid of major indust ry , thee s t a b l i s hm en t of surh a mill could be able to st boulate the economy in a posittve

flespsctifully, manner. I personally urge voar f avorable consideratina of their draf t st at ement .

(t '. /

h NMg[{, -.

m- sin <erelv mur. ,

den loe, mructor. //w) w' [/" ,/ 4 AM

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w &N \h Juan Gmter for H1$a r PJta'atim # U

[ [.h -3 Dean M. MMonald/-I D, ~

Pr e s iden tD'at : eg ,

/am Kindrwi "c- (. ., _r

4 9111rm7ml Vocatimal Sprialist 'sIl/JK/fb

P O BOM 363 * BL ANDING UTAH 64511 . a804 678 2r0AFFw.E Or COLAEGE OF E ASTERN UTAH . DE AN M MCDONALD. PRESIDENT

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_

_ _ _ . .

AFebruary 7, 1979 N,

F y: 3 %Director P' \ C2" DDivision of Fuel Cycle

and Material Safety '

m3 Ch. amber a Ccmmerce of .WOMT:CILO, UTAHU.S. N.Jelear Negulatory Omu s s i onWashington, D.C. 20555

.

A -r." Jr 't utnec

- s

Ret Energy Fuels White Mesa Uranium Mill DM3' * Yei.t anry p|}L *

! 4. ,uars-an'a F[g g 3 0*,The Wh i t e Mesa Ute Indian Tribe supports the entstruction .ggn a ., p , g . ,.

heg gg ''and operation of the proposed Energy Fuels Uranium Mill to belocated on White Mesa approximately five (5) miles north of t he

80Ch5J cae /Ute Rese rvation. The White Mer,a project should be a benefit to L,, sn arm ; re- or

v,the Ute Tribe insofar as t ri be merters will benefit from the l aimn cf i e ry' le an.t wiwris care t yjobs created in the imme. iia te are n . The Tribe urges your %g gq . b le4r L r J 4t cry ami 3- r

*

favorable conside atior, of the issuance of the source material *M' me *' < " '% n.unglicense for the Ermrgy Fucis Mill. Your earliest , . x. h t b l eaction on the issuance of this lice.we will permit ae opening Fe: a* te w 4 Ura+m er? ?c t - :. > x e t s wtal,,y..of a substantial nurtaer of job o;por t unit ies to thi> Ute tribemembers. DINg,,n. .,

I'Ite Nr.t leello C5ai % r ( '' :.m.-re a w uij liv e to y a

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reu. rd as alvar4 c; almas s;; p r e t r.e above n.med' g. le% * 6r c o-s ; erat i . ! _ Nrt and er'.

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o. ma to tr,rrgy Fuels ! aucar, . r.c . i n t h* 1 r ve'.t are.

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4.ce9892EC35 02/02/79 !C5 IP"4hCZ C58 =$=6601e762839 PGM TDe% SLa%Cl%G UT 330 02 02 CaC38 EST

February 2.19??

CIGECTOR CF TPE O!vilION FutL tvCLEa%c MATER!al SAFETYU.S. AuCLEaa aEGULaToey CCa*I5510%

ma541NGTC% DC 20S55

DirectorDivision hel Cycle & Material SafetyU.S. Muelear Reg. Comm.Was. ington. D.C. 20555 REFEEthCE ENERGY FLELS = MITE PE5a weamggw es0 JECT Sa% Jwah CCu%7V bTaM%

00CNET muasER so sealImar Sirs thERGY FLELS Ma5 Ceta4TEC a Lea %Iuw CRE Buvi%G Stat!C% a%D nas 00%i

EITE%51WE EsPLodsigcN hrae GLah01 3 UTam FOR 3C TI*E. TMI5 Flag a%DWEev BENEFICtaL 70 Cu,"EI am writing concerning the proposed eill at Blanding. Utah. (Energy THEIR EMPLJYEES Matt SEEN a*Ea 4%0 cur EC0%0=v.hals nhite Nose Uranium Project. San Juan County. Locket F.0-86dl.) Aca. TMEY HEED 70 SUILO a4 C4E PdOCE551%3 m!LL TC UTILIZE tee CeE T*EV

MaVE LCCATED 1% THE GRcu%D, a%D aL50 To **CCESS f*E Cat TMEy Havg >I am very much in favor of this projoet. I think it would be a very pueCaa5ED. I U40E VCV 70 GRA%f ENEaGY FLEL5 Tal$ avimod1TV ch FE tiwV a a r b

good thing for the town of Blar. ding and the people of San Juan County. 57w.*

Your consideration will be appreciated. THE CIT!ZENS OP staN01%G ufam A8E WEev C0%CEe%E0 asas? T*E SarETv a%DTHE ENVIRON" ENTAL Impact CF THIS a!LL. 53 .E aaE PLEasEC Tc aso. TMafTHEIR DE31GN !$ acpE TMAN aCEQuaTE TO C3%T&!N T*E =&5TE Ta! LINGS. AAD

, THE PRODUCTICN Er*I5510 :5Tours truly. /

.// ' N QUR NATION %EE05 70 OEbELOP 7 vaa=ILM as a PATTER CF9 Suavival, 30 *E &#E FagED Fac"ESE SAFE V5E5 CF[g/k g,- d, $,f' g y[

m TME CauS=1%G euSCE%5 CF bay!%G "05T CFO OUR CIL OvfR$Eas, aND FROM TME LaCR CF Tat ENE23V *E htEC. =!Tm TFI5" D@y

/ ' - d.ichn W.jMit chell .~ t hLCLEAR DEVELCP"E%f aFE41Ca Ca% CvERCCNE bCTm Cua INFLa" 7% 4%c

'

SYaGNaTION P408LE"5.7/ WASATCH DA1CIAL CUL*. g<}- - 06R LCCAL SAN Juan COUNTY ECC%Cwy CEspaas

CRONIC UNE*pto'ELv HEE 05 a LCNG tee 4/7/jj ' .7 6 } Er8 lover TO >ELP SOLVE CLR v*E%f, =MIC= 15 csE OF Tatco: Division of Technical Information & Docuer.t Control (. 'i mC45T IN i-E haTICN.U.S. Nuclear Regulatory Coca. -

Wamington L.C. 20555 6' ,, J ' PLEA'.E LETYCUR INTELLIGENCE a%D yoga G;;; 5E45E 0.fwc0at T=E

' ANTI NUCLEaha aND * ANT!=0EVELOP"E%T* pa:! Cat Ge0ws5 a%D apn0WE THISMILL.p .a. ., -

C3' V0uel TRULY,

(b O)cPNC.. /. .A 704 REDO

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February 4 1979

*dVTJ- My .e . p

-.dV. c4 . -.a AO *'t 0 D1 rec t or[ Dietston of Fuels Cycle & hterials Safety

2/r.g y , .

[ Wasnangton. D.C. 205 %84 <f U.S. Nucleer Regulatory Coemisalon

//*

.. . d LfZd- _ 42h d5* 68V_ d LC .

s2/ .4E .mf (%. M}A-._

* " ' " " ' '

j)/ d / - Tnis letter is in reference to Energy Tuela Muclear Incorporated'a

. p. A A h & 4 White Pesa Project in San Juan County, Utah. It is Docnet ausber

P0L a m. p set, . I as very such in favor of this project and would like to see

,y g , it receave your approval. I have lived in this area post of my.4 li fe . !"ma rr sing my family here, and as operatsng a business.

_p ge_m ,seg,g . g I have had oc snion to asaociate with the prinetpala of EnergyFeels Nuclear on both a personal an3 business level. I havej

u g A j enjoyed this association.

I feel the white Ns.s Project will result in a sabetantaal' - - ' 1 econoate leprovement la this area. It will create jobs for

local people and will anject money into tne local economy. It9 g ,

p will teprove the local tax base.

b-" #

I also feel the White Mesa Project ta necessary on a rationallevel also. It will do something toward relieving the present

_ _ _ . . _ _ _ . . _ _ . . -- . . - - energy abortage.

Again, I urge your approval of this project. Thann you f e 7your cooperation. $

.C'%._ t& -.

.*# Drrfo '(\Regards,

NC LFEB0 g n [

/p Earl E. Stevens MM /' #Blanding, Utah D Kir f.'6 D. --),G % J .-

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vove [epewer///3445 so.n W.n sae 112 . P O fu 15%5 . set iane Cm Uuh E4:15 rwo.weg AG.ENTk-[', ..

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Director / Feeruary 5, imN,

Division of Fuel Cycle (,-

and Material Saf ety (. . .d O

JW' ]' M eectcr C7 DoCr1RDU.S. Nuclear Regulator y Commissien '

s. - ''s kn st an Fuel Cycle and Paterisi Sefety {f U5 MWashington, D .C . 20555 '

h.@^. s**

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Re Energy, Fuels White wesa Cranium Mill'' gh M**-vton. D.0- 20P,''

g7yyImer a,ir: ryy.p

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v-Centlement la reference M Dcchet No. 4.!t41 Enera hel s White Mesa "r=. 4 u(;~

The Monticello City Council endorses and supports the \s 'to j ec t in San Jun Outy Utah, which we ederstand is to t,* revie.*t-- '''

V by ye a emissim on February 21. W-) ee would '.ike to submit *heproposed Ene:gy Fuels Uranium Mill located approximatelyfive (5) miles south of Blanding, Utah. The trFact of the f G Ws-Mill construction and operation to Monticello as well as '*' haV* recently e:taE.ated a tranch of fice et 31andir.g "tah and meSan Juan County should be quite t>eneficial . Jobs will be are very entused about tne prospe:ts of econem. cal develement in Sanprovided to a number of individuals many of which will no Jan Omty. One of the hignlichta of this econzical developent isdoubt live in Monticello. A number of current e;ployees the ursatu . prwessing plant referred to above ehlen Feer,cy Fueleof Energy Fuels already reside in Monticello, proposes t o build at Whit e Mes.a. sauta M dinnding i; tan,

Although an increase in population of the City of ' e would like to voice our interest auf deep concern that you- e xcit esion"Monticello as projected f rom the construction and cperat ion of 8F''d11Y Fa8*cs the projec t for Enera hela so that San Juar. County e.aythe proposed uranium mill, the City is planning expansions to

E't n $1th the very intricate part sf the develement of enei ry far our w

^^tiOC 88 * ell as econx.2 c deveicpent f ar the peeple of San Juan County. chthe utility systems and feels that it will be well able to take"

ca'e of the irpact of any additional residents that may locate We f-el this auld te very astrwental in not ecly the econccisei t' the City. we look forward to E tergy ruels' early commence- d"*1epment in San Juan County but cf the State of ttsh and also in them+rt sf construction and asa that you favorably consider the Anterest of enero develepr:ent f ar cur r.ation.appitcation for the source material license.

Flease giva every cer. sideration tr the passing of this and try nct tolisten so intently to the chattering of swe of the special Interestpecpl4 who try t o destroy the econc ale developent of our country.

py;g /* ,/. y,**

C,it y Ccancil of M ant acellIM' tan he apprecaste your cor. sideration of this and any assistance you can giveto the early passing of this pro;ect as it is our understanding thatgq'4 Enerry Fuels is rea ty to t.egin construction in May and have went to a7

N , [.,vf

great deal of expr.: to line up ore and establish a program to begin this

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Appendix B gBASIS FOR NRC EVALUATION OF THE Wi;ITE MESA MILL PROPOSAL

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_ _ _ _ _ _ _ _ .

B-3

Appendix B

BASIS FOR NRC EVALUATION OF THE WHITE MESA MILL PROPOSAL

B.i THE NUCLEAR FUEL CYCLE

The nuclear fuel cycle comprises all the processes involved in the utilization of uranium asa source of energy for the generation of electrical power.

The nuclear fuel cycle consists of several steps:

1. extraction - removing uranium ore from the ground, separating the uranium content fromthe waste, and converting the uranium to a cnemically stable oxide (nominally U 0 );3 3

to a fluoride (UFs), which is a solid at2. conversion or fluorination - changing the U 033

room temperature but becomes a gas at slightly elevated temporatures, prior to enrichment;

3. enrichment - concentrating the fissionable isotope (uranium-235) content of the uraniumfrom the 0.7% occurring in nature to the 2 to 4% required for use in reactors for powergeneration;

4. fabrication - converting the enriched uranium fluoride to uranium dioxide (UO ), forming2

it into pellets, and encasing the pellets in tubes (rods) that are assembled into fuelbundles for use in power generating reactors;

5. nuclear power generation - using the heat resulting from uranium and plutonium fissionto generate steam for use in the reactor turbines;

6. spent fuel reprocessing - chemical separation cf fissionable and fertile values(uranium-235, uranium-238, plutonium) from fission products (waste), with concurrentseparation of uranium from plutonium; and

7. waste management - storage of fission products, spent fuel, and low-level wastes in amanner that is safe and of no threat to human health or the environment.

Step 6 (reprocessing, involving the recycling of plutonium), which had traditionally beenconsidered as an essential part of the nuclear fuel cycle, was recently deferred by theNational Energy Plan (NEP)! as a necessary part of the cycle. The U.S. comitment to advancednuclear technologies based on the use of plutonim ecovered by the reprocessing of spentlight-water-reactor (LWR) fuel has also been deferred. These policy statements enter into thestaff's evaluation of the need for licensing the White Mesa mill, because without repro-cessing, all LWR fuel must be derived from the mining and milling of new U 0e from projects3

such as the White Mesa mill and the related uranium mines.

This cycle, as defined by current policy. is portrayed in Fig. B.l.

Nuclear reactor operation converts about 75% of the fissionable isotope (uranium-235) intofission products, thereby liberating thermal energy and creating plutonium, another fissionableelement, in the process. Some plutonium is retained in the spent fuel.

The spent fuel removed from the reactor is stored at the reactor site (and later at the repro-cessing plant, if policy changes) to " cool." The radioactivity of the fuel i$ reduced by af actor of about 10 after 150 days storage. Without reprocessing, this spent fuel is consideredwaste. Policies and methods regarding its storage and/or disposal are currently under study bythe DOE and NRC.

B-4

E S 4694

NUCLE AR

POWIRG(N[R ATloN

OFUEL PR[PARAlloN FRf 5H COR[ RE A CTOR

MINING MilllNG CONVIRSION - [NRICe#ENT AND-+ a-

F A BRICA flON, 3 ; s

I \ ! /

| l '\ f

t \ '/ /#

TAILINGS \ ,I ,e' SPST/

Pla s ; f' COR[/

l / s'\x 1 / /

\ 'j ,s

' ", , , -W AST[ STORAG[ Rf ACTOR Slf[

gg SPENT FUEL STORAGl*AFR * Anay From Reactor

BURIALSteps involving Uranium \,Fuel (Fresh or Spents OR-

---Steps involving interrnediate-leveland icne-level Radicadive Wastes -

UtilYAT[ agg. spggyOl5PoSAL -

FU[L STORAGl

Fig. 8.1. The LWR fuel cycle.

B.2 USE OF NUCLEAR FUEL IN REACTORS

Two types of reactors are currently used to generate essentially all of the nuclear energy soldin the United States: the boiling-water reactor (BWR) and the pressurized-water reactor (PWR).Each reactor type is operated with a fuel-management scheme designed to meet the requirementsof the utility operator. Different fuel-management schemes result in different fuel burnuprates which, along with other design parameters, affect the quantity of residual fissionablematerials, the type and amount of radioactive wastes in the spent fuel, and the quantities ofnuclear fuel consumed.

The need for uranium fuel, as dictated by the installation of 380 GWe of nuclear capacityanticipated by the year 2000, is shown in Table B.1. A 1000-MWe reactor will require =30 MTof uranium fuel per year at a plant factor of 0.6 and 230 MT of uranium fuel for a plant factorof 0.8. The term " plant factor" indicates the ratio of the average power load of an electricpower plant to its rated capacity. For a 3". enriched fuel and 0.25% enrichment tails assay,7.9 times the metric tons of fuel replaced equals the standard tons of U 0 required for a3 31000-MWe power plant. The percentage of total electrical generating capac* over the sametime period that this schedule represents is shown in Table B.2. On the b. ; of recent state-ments by the industry and the DOE, the staff believes that this schedule represents a maximumfor nuclear reactor installations between 1990 and 2000 but is reasonably accurate through 1990.2

Cumulative requirements through the year 2000 would be 883,000 MT of uranium as U 0 (Table B.1).3 3Table B.3 compares this requirement with available uranium (reserves and probable resources)for the year 2000 and the 30-year plant lifetimes of the 380 GWe projected for installation bythe year 2000. Requirenents and resources are in reasonable balance;3 that is, the sum ofreserves and probable resources is approximately equal to the lifetime requirements of the380 GWe installed by 2000.

In 1977, 23 mills produced about 12,000 MT of U 0g while handling 32,000 MT of ore per day.3

These mills operated at 80 to 85% of capacity. The U 0e content of the ore was less than3

1.5 kg/MT (3 lb/ ton; <0.15%).4 Ores processed by the White Mesa mill will have a U 03 8 contentapproximating this national average.

B-5

Table B.1. Prosected U.S. requirements for U O., 1976-2000dhi

Annual Cumulative,

"' 'requ rements requ rements

(M T) (MT)

1976 43 9.500 9.3501977 49 10.000 19.1001978 53 10.000 29.1001979 57 11.000 40.2001980 61 11.000 52,000

1981 74 17,500 69.4001982 87 18.000 87,600

1983 100 20.500 108,000

1984 112 22,500 130.0001985 127 26.500 157.000

1986 141 28,000 185.0001987 154 30.000 215.0001988 167 32,500 248.0001989 181 35.500 293.0001990 195 38.000 321.000

1991 210 41.000 362.0001992 225 43,500 406.0001993 240 46.500 452.0001994 260 51.500 504.0001995 280 54,500 558.000

1996 300 58.000 616.0001997 320 61.500 678.0001998 340 65,500 743.0001999 360 68,500 811,000

2000 380 71,500 883,000

*The annual U 0, requoements were cdculated on the basis of3

annual discharges of 28 MT/GWe (0.7 plant factor) of spent fuel andreplacement of that spent fuel with a 3% entched fuel with tails assayof 0 25% in ennchment.

6To convert to short tons, mult, ply by 1.1.

Table B.2. Comparison of total and nuclear generating capacity, operstmg m years 1977-2000

"" "' '"9''' # *Total generating . . _ . _ _ _ _ _ _

Year CdDdC'IV ICW'P '#'Planned or under

' "' " * * " #Minimum Ma ximum construction

(%) 1%)

1978 507 507 49 12 12

1980 544 627 84 16 14

1985 624 840 127 20 15

1990 734 1131 195 26 17

1995 869 1525 280 32 18

2000 1039 2092 380 36 18

#From '' Electric Utilities Study" by TRW for ERDA, Contract E(4911-3885, pp. 1-19. et sea.Maximum case is 7 0% compounded annual growth through 1985, then 6.4% to 2000. M<nimum case is3 9% through 1985, then 3 5% to 2000.

2-6

Table B 3. Comparison of U.S. reactor requirements and domestic resource availabihtybn metric tons of U O, as of January 1978) .bi

_ _ . . _ . _ _ . _ _ _ _ . _ _ _ _ . _

Resource availabilityTime period Reactor demand

At $30/itf At $501t/

Through year 2000 883.000For 30 year hfetime of 380 Gwe 2.051.000Reservesd 626,000 808.000Protable resources 921,000 1,180,000Sum of reserves and probat,le resources 1.550.000 2.o00,000

*To convert to short tons mult: ply by 11.6 Based on enformat.on presented by U.S Energy Research and Development Administration (now U S.

Department of Energy) at the Uranium Industry Sermnar, Grand Junction. Colorado, October 1977, and in'TRD A Mekes Estimate of H gher Cost Uranium Resources," U S. Energy Research and DevelopmentAdmmestration. June 1978.

' Costs include all those incurred en property exploitation and product.on except costs of money andt a m es

dDoes not include 126.000 MT of U 0. whch could be produced as a by product of phosphate3

fertihrer and copper production.

As can be seen in Table B.1, the annual requirement for U 0e in 1931 (17,500 MT) exceeds the3output of existing uranium mills (12,000 MT). In 1980, the White Mesa Uranium Projectwould produce 6% of the national capacity for tons of ore per day, and its total production ofU 0g through the next 15 years of operation would be about 3% of the national requirements.3

Although this production is not currently planned for use to meet National requirementsdirectly, it will increase the overall U 0 supply available. The project will contribute to3 3meeting the demand forecast for the nuclear power industry.

REFERENCES FOR APPENDIX B

1. Of fice of the President, national Er:ergy Plan, Washington, D.C., April 1977.

2. Brown and Williamstn, U.S. Department of Energy, " Domestic Uranium Requirements, Policyand Evaluation," paper presented at the Uranium Seminar, Grand Junction Colo., October1977.

3. "ERDA Makes Preliminary Estimate of Higher Cost Uranium Resources," U.S. Energy Researchand Development Administration Notice, June 1977.

4. J. F. Pacer, Jr. , " Seminar on Uranium Resources," paper presented at the Uranium Seminar,Grand Junction, Colo. , October 1977.

Appendix C

STATEMENTS OF GENERAL FUND REVENUES AND EXPENDITURES

FOR SAN JUAN COUNTY,

BLANDING AND MONTICELLO

SAN JL'AN COUNT Y 5AM JUAN COUNTYGENERAL FLTD LINERAL FLHD

$1 ATEMENT CF REVENLTS, EXPENDITURES, AND COMPAR1h W 'elTH BL%tT STATEML!ri OF REVENUES, EXPENDITURE $, AND COMFA31 SON WITH BUDGETFoa TME YE AR E%FD DECEMF 9 31 1977 FOR TRE YE AR ENDED DFCE9ER 31, 1977

1977 CVER 1976 1977 OVER 1976IJIAL (CSDER) ACILAL TUTAL ( LNLE R ) ACTtAL

E X PE NDITURF S BUDCt t ACTLAl B"4ET PM li M itAR EXPFNDITUEFS SULu ET ACT1AL BClm.E T Palue ifAaCht,11AL e ERST NI

PAm, RENA1 M AG MIC NERM;L == t e . s .,a 3 31.950 $ 31,4J4 $ (Sab) $ 28,155

1, a n t s t. t ms t 3,150 2,v9* (456) 3,252 F4rke and rec seat son $ 71,293 $ 71,602 $ 309 $ 63,823

Let y .od precanct 5,we t e 15,0uo 22 364 7, b 15.918 Television 9.600 17,436 7.8 16 18, 70 ?

OtPei Judieial 6,500 1,907 (4,593) 922

e d r 98 39 7 , 97 ,

p r e $ 80, m $ 89,W $ 8,14 $ 82 J25

CWERVATION AND EMMIC DEVEWM[, (a 6) 3, 16r as r 63A.seasor 23,825 26,316 2,511 46,086 Agraculture and estenaton aervnce $ 1) 875 $ 16.07) $ 2,198 $ 13.346Nr.cy-s 39,970 37,706 (2,264) w.540 Total consenat ha andP l ..u. ing coura i s si on 1.0v0 727 (273) ****d" ""' I II I " I I '# I II'h.n d.partmental 185,500 222,525 37,025 192,005

MAL EXPENMRES - GEMRA1 M $ 1,N , % ) H 240. M $ % ,618) & 22), mA t ng and wasnunit y p r emiot ton te 3 ( 36 ) 3

Total general guvernm nt $ 510,625 $ 5tl 185 $ 340 $ *e m , %,0 La

EXCESS REVENUES (EIPENDITURE$) $ (517 428) $ 444,977 $ 982,405 $ 110,766PL8 Law bADETY:

bl.. s i t f $ 155,820 $ 144,320 $(11,500) $ 145,648

bis. department 5,835 5,787 (48) 4,273

L..a.ections (jaal) 36,100 36,156 56 31,021Osnas pisteetion 12,600 11,959 (741) II 272

Source: S a 's Jaan Cauary AM it ter 1977

Tutal publie safe ty 8 210 355 $ 196,122 $(12 2J)) $ 192,214

F l a t.l s hE ALTH :

Hs.lth .etwi.es $ 326,115 $ 250 157 $(76,158) 5 15's,554

H LL,ateAY AND PUbLIC IMPROVEMENT;

Hi ne,.fo $ 653,5Lo $ 7)0,896 $ 97.390 $ 76/,420

C1... "B'' roads 550,000 310,992 (239,008) 32 8 ,0u4

t 19estor ronda 580,000 16,583 (4S3.417) 20 J , 713

M e sse llaneous i t 9, tt00 17,899 (101,90t) 14 9 34

fotal highway andpwblic amprovement $ 1. 90 ) . 300 $ 1,176. 3 70 ( $ 7 26,910 ) $1 341.076

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E

CITY OF BLANDIRCBlandlas City, Utah

SCHEDUIE: "E"

STATEMI7tf 0F CIhTR AL FUND REVINUES and FIPENDITORES - FISCAL YtA35 INDED JUhE 30 1976 1917

RrvENUE 9tCEXPT5: June 10. 1976 June 3C. 1977Current Year Propert y Tesee $ 37.959.53 5 44,393.96Redemption - Prior Yeare Tanea 3,468.70 1,691.72Sales and Use Tesee 43,336.72 55,313.55Duelnese Licensee 489.00 45C.00Dulldtag and Copatraction Peret te 645.80 1,387.60ticycle Permite 7.00 6.00Other Licenees and Perott o 85.00 245.00Create Free federal Government 5,937.30 770.D0Federal Revenue $harlas 14,087.D0 18,227.00St at e Liquor Fund Allotment 4,248.20 4,248.2CClase "C" Road Fund Allotment 6,94C.83 14,278.44Other Governmental Create 2,056.46 5,626.70A t r nor t R evenue 1,782.33 1,351.87Cemetery Lot sales 700.00 280.00Court Fines and Penalties 7,879.00 6,718.50Weste Collection and Disposal Feen 17,451.37 18,462.50Weste Collection and Disposal Penalties 80.61 1C2.6LEarned interest . Clase "C" Road Fund 907.56 480.26Earned interest - Revenue Sheries Fund 1,335.16 760.33Eerned Interest . Airport Construction Fund 70.12 98.79Proceede Free Sale of C. O. Donde .. -- 225.000.00 r3Earned interest . C. O. Bond Funde 577.42 3,3d9.71 8

nPiecellaneova tevenues 318.52 1.193.11

Total Receipta $150,38 3.6 3 540u,476.05

Ceeh Account abilit y Adjustment e -A jd:

Cash Contribut ton . Electric. Water and Sewer Fund, Account Current 7,770.05 .. --

Dedvet:Discounto Allowed - Weste Collection and Dispoest (134.65) ( e 7. 7 3)

Balance - Cash Receipte $158,019.03 5406,388.32

Add:mon-Cash Revenues:Service Fees (Waste Collection and Disposal).

Representative of L'ncollectible Account s Charsed 127.25 180.C4Electric, Water and Sewer Ut t lit y Fund.

Account Current Credits 11,525.33 9,672.01'

Employee Peyroll Taxes, Ret t rement Funde, andInsurance Freetues Withheld' 8.219.98 9,6=5.59

Elected Of flet ale and Firemen Employee BenefitsAllo wed ; Insurance Freetume -- .. 1.522.94

Tot al Revenue Adjvetmenta $ 19,872.56 5 21,220.54

TOTAI Cross RrytNUFs 5177,891.59 5425,6G8.b6

CITT OF BLANDING

Blanding City, Utah

SCREDULE: "E" STATEFENT OF CENTD AL Ft'ND REVENt!!5 AND ENPENDITURES . FISCAL TEAar f Wcto JUNE 30, 19 76 19 7 7 . . . . . . . . . . CONTINUATION . .............

.......................................-............--..............................

ETPFWDTTrtt CRARCEStOperettas t aenditureer

Aestatstraftve $ 6,064.01 $ 5,606.53

rtunicipal Coert 2,742.42 3.536.93Election Erpenee 388.16 1,086.75Aedit Expense %89.50 589.50Police Desertment Frpense 47,288.56 66,929.58Fire Department trpense 2,396.21 6,766.62Inspeetten bepartment Espense 60.D0 60.00Street Departreet trpense 17,969.27 26,960.59De bt Service Bedemptione

Water bonde . Settee 11 147 1,105.00 1,075.00Sewer bonde . Sett es 12 1 54 1,532.20 1,698.50Light bnnd e . Ser t e e 5 1 5 7 6,522.50 6,275.00Water bonde . Settee 51 74 18,887.50 18.166.40

Weste Collection and Dispoeal tapense 12, 72 5.D4 16.666.88Airport f rpense 3,352.D4 4,826.35

Close "C" Road Fund Espense 2,180.06 .. ..

Parte and Recreation f rpense 75.13 105.14 y1cn

Total Operating Impendituree $123.857.98 $136.167.77

other trpenditures:Surplus Invested in Ftsed Assete 7,480.83 11,396.36Reutttance . Foployees' Withheld Tenee and Insurance Freetume 8.332.04 10.686.07Contrl but ton Electric, Water end Se=+r, Account current 156,330.36 68,3 32Refende . Weste Collection and Disposal 4.00 .. ..

Tot al other Expenditu.es 170,147.23 70,427.60

TOTAL ffPFNDITt"tts 5294,005.21 52D6,575.57

EXCE*S (DFFICIT): Revenue Recetrte Over Expenditures ( $116.113.62) 6219,033.29

Adtveteente:Incremental Increase in Uneppropriated $urplus .Esplayees' Insurance Preatuos Advanced, Increase ( 11.72) (1,032.76)Waste Collection end Dt eposal Account s Receivable, Increase 21.38 28.37Peyroll Tames Peyeble, Increase 123.78 142.98tiectric, Water and Sewer . Account Current. IRCreece I35,034.98 38,672.)]

Net increase In Unapproprt ated surplue $19,054.80 $256,8e4.19

MONTICELLO

CENERAL WND

1977-1978Mjusted

Bud Re t

RevenuesProperty taxes $ 37,536Sales tax 79,908Court fines 16,422class "C" Road Fund 4,950State Liquor Allotment 2,702Business licenses 1,602Other licenses and permits 2,066 7Other revenues 2.450 "

Total Revenues $147.636Disbunements

Mministrat ion S 54,800Court 3,700Police 49,400Fire 1,700Streets 10,200Parks 2,000

Total Disbursements $121,800Transfer to Bond Redemption & Interest Fund 19.500

$141.300

Excess of Revenues over Disbursements andTransfers S 6.336

Appendix D

DETAILED RADIOLOGICAL ASSESSMENT

D-3

APPENDIX D. CETAILED RADIOLOGICAL ASSESSMENT

Supplemental information is provided below which describes the models, data, and assumptionsutilized by the staff in performing its radiological impact assessment of the White Mesa UraniumProject. The primary calculational tool employed by the staff in performing this assessmentis an NRC-modified version of the UDAD (Uranium Dispersiel and Desimetry) computer code,originated at Argonne National Laboratory (Ref.1).

D.1 ANNUAL RADI0 ACTIVE MATERIAL RELEASES

Estimated annual activity releases for the White Mesa site are provided in Table 3.3. Theyare based on the data and assumptions given in Table 3.2 and described elsewhere in Section 3and in Appendix F, with the exception of the annual average dusting rate for exposed tailingssands. This dusting rate is calculated in accordance with the following equation:

M = 3.156 x 107 RF (D-1)0.5 s

where F is the annual average frequency of occurrence of wind speed group s,3 dimensionless;

R is the dusting rate for tailings sands at the average wind speed for wind speed5 2group s for particles < 20 am diameter, g/m -sec;

-

2M is the annual dust loss per unit area, g/m -yr;3.156 x 107 is the number of seconds per year; and0.5 is the fraction of the total dust loss constituted by particles < 20 cm diameter,

dimensionless (Ref.1)._

The values of R and F utilized by the staff are as given in Table D.l. The calculatedvalue of the anilual dulting rate, M, is 555 g/m -yr. Annual curie releases from the2

tailings piles are then given by the following relationship:

S = MA (1-f ) ft( )( . x 09 @-2)c

2where A is the assumed beach area nf the pile, m ;f is the fraction of the dus;Jng rate controlled by mitigating actions, dimensionless;f is the fraction of the are content of the particular nuclide present in the tails;S is the annual release for the particular beach area, Ci/yr;

423 is the assumed raw ore activity, pCi/g;2.5 is the dust to tails activity ratio; andlx10 12 is Ci/pCi.

Table D.1 Parameter Values for Calculation of Annual DustingRate for Exposed Tailings Sands

Frequency ofWind Speed Average Wind DustingRatg) Occurrence (F_ )Ib'i(R ), g/m -sec.

Group, knots Speed, mph.

0-3 1.5 0 --

4-6 5.5 0 -

7-10 10.0 3.92x10~7 0.283611-16 15.5 9.68x10 6 0.173617-21 21.5 5. 71 x10~ 5 0.0395

>21 28.0 2.08x104 0.0229

(a) Dusting rate as a function of wind speed is computed by the UCAD code(Ref. 1).

(b) Wind speed frequencies obtained from annual joint frequency datapresented in Table D.2.

D-4

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D-5

For the White Mesa site, it was assumed that two 100-acre cells would be available for dustingwhile drying prior to reclamation. Required mitigating actions to reduce dusting were assumedto reduce dust losses by 80 percent for these cells. It was also assumed that half of athird 100-acre cell being filled would be beach area and available for dusting. No controlwas assumed for the exposed beach area of the operational cell.

Dust losses from the six-acre ore storage pile were estimated by assuming they would be aboutone percent of those fr6m an equivalent area of tailings beach.

D.2 ATMOS M RIC TRANSPORT

The staff analysis of off site air concentrations of radioactive materials released at theWhite Mesa mill site has been based on a full year of meteorological data collected on siteoser the period 3/1/77 through 2/28/78 (Ref. 2). The collected meteorological data is enteredinto the. UDAD code as input, af ter assemblage and reduction, in tne form of a joint frequencydis'.ribution by stability class, wind speed group, and direction. The joint frequency dataemployed by the staff for this analysis are presented in Table D.2.

The dispersion model employed by the UDAD code is the basic straight-line Gaussian plume model(Ref. 1). Ground level, sector-average concentrations are computed using this model and arecorrected for decay and ingrowth in transit (for Rn-222 and daughters) and for depletion dueto deposition losses (for particulate material). Area sources are treated using a virtualpoint source technique. Resuspension into tne air of particulate material initially depositedon ground surfaces is treated using a resuspension factor which depends on the age of thedeposited material and its particle size (Ref.1). For the isotopes of concern here, the totalair concentration including resuspension is about 1.6 times the ordinary air concentration.

The assumed particle size distribution, particle density, and deposition velocities for eachsource are presented in Table D.3.

Table D.3 Physical Characteristics Assumed for Particulate Material Releases

DepositionDiameter, Density, Velocity, AMAD',

3Activity Source um g/cm cm/sec tm

Crusher Dusts 1.0 2.4 1.0 1.55Yellowcake Dusts 1.0 8.9 1.0 2.98Tailings, Ore pile 5.0 (30%) 2.4 1.0 7.75

Dusts 35.0 (70%) 2.4 8.8 54.2In-grown Rn Daughters -- 1.0 0.3 0.3

dAerodynamic equivalent diameter, used in calculating inhalationdoses (Ref.1).

D.3 CONCENTRATIONS IN ENVIRONMENTAL MEDIA

Information provided below describes the methods and data used by the staff to determine theconcentrations of radioactive materials in the environmental media of concern in the vicinityof the White Mesa site. These inclLde concentrations in the air (for inhalation and directexternal exnosure), on the ground (for direct external exposure), and in meat and vegetables(for ingestion exposure). Concentration values are computed explicitly by the UDAD code forU-238 Th-230, Ra-226, Rn-222 (air only), and Pb-210. Cancentrations of Th-234, Pa-234, andU-234 are assumed to be equal to that of U-238. Concentrations of Bi-210 and Po-210 are assumedto be equal to that of Pb-210.

D.3.1 Air Concentrations

Ordinary, direct air concentrations are computed by the UDAD code for each receptor location,from each activity source, by particle size (for particulates). Direct air concentrationscomputed by UDAD include depletion by deposition (particulates) or the effects of ingrowthand decay in transit (radon and daughters). In order to compute inhalation doses, the totalair concentration of each isotope at each location, as a function of particle size, is computedas the sum of the direct air concentration and the resuspended air concentration:

C,jp(t) = Caipd + Caipr(t) (D-3)

D-6

where C,9p(t) is the total air concentration of isotope i, particle size p, at time t,3pC1/m ;

C is the direct air concentration of isotc?e i, particle size p, (constant)aipd ipC1/m ; andCaipe(t) is the resuspended *ir concentration of isotope 1, particle size p, at

time t, pCi/m L

The resuspended air concentration is computed using a tire dependent resuspension factor,R(t), defined by

Rt~ -SR (t) = (1/V )l0 5 e (for t r 1.82 yrs) (D-4a)p

R (t) = (1/V )l0'3 (for t > l.82 yrs) (D-4b)p p

where R (t) is the ratio of the "esuspended air concentration to the ground concentration,P for a ground concentration of age t yrs, of particle size p, m~l;

V is the deposition velocity of particle size p, cm/sec;pis the assumed decay constant of the resuspension factor (equivalent toi na 50-day halflife), 5.05 yr;

109 is the initial vabe of the resuspension factor (for particles with a depositionvelocity of I cm/sec), m 1;

109 is the terminal value of tre resuspension factor (for particles with a depositionvelocity of I cm/sec), m'l; and

1.82 is the time required to reach the terminal resuspension factor, yrs.

The basic formulation of the above expression for the resuspension factor, the initial andfinal values, and the assigned decay constant derive from exnerimental observations (Ref. 3).The inverse relationship to deposition velocity eliminates mass balance problems involvingresuspension of more than 100t of the initial ground deposition for the 35 > m particle size(see Table D.3). Based on this formulation, the resuspended air concentration is given by

10 ' 1 - exp h9*+)R)1.82}alpr(t) = 0.01 CaipdC

- (A *+A p)

10' [ ex;. 1.82A*)-exp(-A*t)}~(D-5)g j

1 *9

.

where A * is the effective decay consta 4 for isotope i on soil (see [quation D-7), yr 1; and0.g01 is m/cm.

Total air concentrations are computed using Equations D-5 and D-3 for all particulate effluents.Radon daughters which grow in from released radon are not depleted du to deposition ' assesand are therefore not assumed to resuspend.

D.3.2 Ground Concentrations

Concentrations of particulate materials in and on soil are computed 4 rom direct air concentra-tions. Resuspension of deposited activity is not treated as a loss rechanism and redepositionis ignored. Ground concentrations are given by

Cg4p(t) = 0.01 Caipd p iY I ~ **P I'A *t)

. j_

(D-6)A *

g p(t) is the ground concentration of isotope i. particle size p, at time ti pCi/m ; andwhe e C 2j

A* is the effective decay constant for isotope i on or in soil, yr'l;g

and where A * = Aj+A* (D-7)j

where A is the radiological decay constant, yr'l; andj

A* is the assumed environmental loss constant for activity in soil (equivalent to a50-yr halflife),1.39 x 10 2/yr.

D-7

In general, the half-lives of the pertinent isotopes are such that it is appropriate to assumeeither complete ingrowth or no ingrowth. However, ingrowth of Pb-210 from Pa-226 is treatedesplicitly using the standard Batenan formulation.

D.3.3 Vegetation Concentrations'Concentrations of released particulate raterials can be environmentally transferred to the edible

portions of vegetables, or to hay or pasture grass consumed by animals, by two mechanisms -direct foliar retention and root intake. Five categories of vegetation are treated by the staffmodified version of the UDAD code. They are edible above ground vegetables, potatoes, otheredible below ground vegetables, pasture grass, and hay. Vegetation concentrations are computedusing the following equation

_ _

---1-exp( 1 1)> t B

+C - (D-8)C = 0.01 V C, F Egp p g r y ygpy ,

v v!

where B is the soil to plant transfer f actor for isotope i, vegetation type v. dimensionless;g

C is the resulting concentration of isotope i, particle size p, in vegetation v pCi/kg;ggE is the fraction of the foliar deposition reaching edible portions of vegetation v.y

dimensionless,

F is the fraction of the total deposition retained on plant surfaces, 0.2, dimensionless;r

P is the assumed areal soil density for surface mixing, 240 kg/m?;

t is the assumed duration of exposure while growing for vegetation v, set;y

Y is the a:sumed yield density of vegetation y, kg/m/,

is the decay constant accounting for weathering losses (equivalent to a 14-day half-)* life), 6.73 x 10 7/sec and

0.01 is m/cm.

The value of E is assumed to be 1.0 for all above grounnd vegetation, and 0.1 for all belowgroundvegetabTes(Ref.4). The value of t is taken to ?2 60 days, except for pasture grasswhere a value of 30 cays is assumed. The yYeld density, Y , is taken to be 2.0 kg/m/ except forpasture grass, where a value of 0.75 kg/m is applied. VaYues of the soil to plant transfer2

coefficients Bg, are provided in Tabb D.4.

Table D.4 Environmental Transfer Coefficients

U _ Th Ra Pb

!. Plant / Soil (Bg's)

a) Edible Above Ground: 2.5 x 10 3 4.2 x 103 2.0 x 10~2 4.2 x 10'3-

b) Potatoes: 2.5 x 10' 3 4.2 x 10'3 3.2 x 10 3 4.2 x 10~3c) Other Below Ground: 2.5 x 10~3 4.2 x 10~3 2.0 x 10~2 4.2 x 10~3d) Patture Grass: 2.5 x 10'3 4.2 x 10 3 6.6 x 10 2 7.8 x 10~2

-

e) Stored Feed (Hay): 2.5 x 10~i 4.2 x 10~2 a.6 x 10 ' 7.8 x 10 2

II. Beef / Feed (Fbi

pCi/kg per pCi/ day: 3.4 x 10 ' 2.0 x 10 " 3.0 x 10 3 2.9 x 10 '-

O.3.4 Meat Concentrations

Radioactive materials can be deposited on grasses, hay, or silage which are eaten by meatanimals, which are in turn eaten by man. For the White Mesa site, it has been assumed that meatanimals obtain their entire feed requirement by grazing, 6 months per year, and by eating locallygrown stored feed the remainder of the year. The equation used to estimate meat concentrationsis

D-8

QFbt (0.5 C + 0.5 Cg) (D-9)C ag p

where C is the concentration of isotope i in pasture grass, pCi/kg;4

C is the concentration of isotope i in hay (or other stored feed), pCi/kghi

C is the resulting concentration of isotope i in reat, pCi/kg;g

F is the feed to meat transfer factor for isotope i, pCi/kg per pCf / day (seegTable 0.4);

Q is the assumed feed ingestion rate, 50 kg/ day; and

0.5 is the fraction of the total annual feed requirement assured to be satisfied bypasture grass or locally grown stored feed.

D.4 bux 5 TO INDIVIDUALS

Doses to individuals have been calculated for inhalation, external exposure to air and groundconcentrations, and ingestion of vegetables and meat. Internal doses are calculated by the staffusing dose conversion factors which yield the 50-yr dose comitment, i.e., the entire doseinsult received over a period of 50 years following either inhalation or ingestion. Annual dosesgiven are the 50-yr dose comitments resulti:19 f rom a one-year exposure period. The one-yearexposure period was taken to be the final year of mill operation when environmental concentra-tions resulting f rom plant operations are expected to be at their highest level .

D.4.1 Inhalation Doses

Inhalation doses have been computed using air concentrations obtained by Equation D-3 (resus-pended air concentrations are included) for particulate materials, and the dose conversionf actors presented in Table D.5. These dose conversion factors have been computed by ArgonneN,ttional Laboratory's UDAD code (Pef.1) in accordance with the Task Ground Lung Model of theInternational Comission on Radiological Protection (Ref. 5).

Doses to the bronchial epithelium from Pn-222 and short-lived daughters were cou,ated based onthe assumption of indoor exposure at 100% occupancy. The dose conversion factor for bronchialepithelium exposure from Rn-222 is derived as follows (see Appendix I for additional details):

1) I pCi/ml Rn-222 * 5 x 10' Working level (WL ) . *

2) Continuous exposure to 1 WL = 25 cumulative working level nonths (WLM) per year.

3) 1 WLM = 5000 mrem (Ref. 6)

Therefore:

gh) x (25 Wh)x(5000 E[)=0.625 mremW1 pCi/t Rn-222 x (5 x 1073

and the Rn-222 bronchial epithelium dose conversion factor is taken to be 0.625 mrem /yr porpC1/mL

D.4.2 External Doses

External doses from air and ground concentiations are computed using the dose conversion factorsprovided in Table D.6 (Ref.1). Doses were computed based on 100% occupany at the particularlocation. Indoor exposure was assumed to occur 14 hrs / day at a dose rate of 70% of the outdoordose rate.

D.4.3 Ingestion Doses

Ingestion doses have been computed for vegetables and meat (beef and lamb). Ingestion dosesreported are based on concentrations obtained using Fquations D-8 and D-9, ingestion rates given

~

*0ne WL concentration is defined as any combination of short-lived radioactive decay products ofRn-222 in one liter of air that will release 1.3 x 105 MeV of alpha particle energy during theirradioactive decay to Pb-210.

D-9

Table D.5 Inhalation Dose Conversion factors (mrem / year /pC1/m )l

Particle Size = 0.3 Microns FB210 F0210

Whole Bod / 7.46E+00 1.29E+00Bone 2. 32E + 02 5.24E+00Kidney 1.93E+02 3.87E+01Liver 5.91E+01 1.15E+01Mass Average Lung 6.27E+01 2.66E+02

Particle Size = 1.3 Microns U238 U234 TH230 RA226 PBtl0 P0210

Density = 8.9 g/cm'

Whole Body 1.44E+00 1.64E+00 1.37E+02 3. 9 7E +01 9.42E+00 1. 7 7E +00

Bone 2.42E*01 2.64E+01 4.90E+03 3.97E+02 2.87E+02 7.22E+00Kidney 5.53E+00 6.30E+00 1.37E+03 1.40E*00 2.39E+02 5.33E+01Liver 0. O. 2.82E+02 4.94E-02 7.32E+01 1.59E+01Mass Average Lung 2.13E+03 2.42E+03 2.37E+03 3.04E+02 2.49E+01 1.12E+02

Particle Size 1.0 Microns U238 U234 TH230 RA226 PB210 P0210iDensity = 2.4 g/cm

Whole Bod, 1.65E+00 1.87E+00 1.66E+02 3.40E+01 8.24E+00 1.54E+00Bone 2.78E+01 3.03E+01 5.95E+03 3.40E+02 2.56E+02 6.29E+00Kidney 6.33E+00 7.22E+00 1.67E+03 1.20E+00 2.13E+02 4.64E+01Liver 0, O. 3.43E+02 4.22E-02 6.53E+01 1.38E+01Mass Average Lung 2.88E+03 3.28E+03 3.22E+03 4.04E+02 3.38E+01 1.48E+02

Particle Size = 5.0 Microns U238 U234 TH230 PA226 PB210 P0210

Whole Body 1.16E+00 1.32E+00 1.01E+02 4.47E+01 1.00'+01 1.96E+00

Bone 1.9CE+01 2.14E+01 3.60E+03 4.4 7E +02 3.llE+02 7.99E+00Kidney 4.47E400 5.10E+00 1.00E+03 1.57E+00 2.59E+02 5.89E+01Liver 0. O. 2.07E+02 5.55E-02 7.9 3E +01 1.76E+01

Mass Average Lung 1.24E+03 1.42E+03 1. 38E + 03 1.87E+0? 1.45E+01 7.01E+01.

Particle Site = 35.0 Microns U238 U234 TH230 R4226 PB210 P0210

Whole Body 7.92E-01 9.02E-01 5.77E+01 4.40E+01 9.66E+00 1.93E+00Bone 1. 34E + 01 1.46E+01 2.0H +03 4.40E+02 3.00E+02 7.84E+00Kidney 3.05E+00 3.47E+00 5.73E+02 1.55E+00 2.50E+02 5.79E+01Lfver 0, 0. 1.19E+02 5.47E-02 7.65E+01 1.73E+01Mass Average Lung 3.33E+02 3.80E+02 3.71E+02 6.38E+01 3.91E+00 2.58E+01

Table D.6 Dose Conversion factors for External Exposure

3Dose factors for Doses from Air Concentrations, mrem /yr per pCi/m

ISOTOPE SKIN WHOLE BODY

U238 1.05E-05 1.57E-06TH234 6.63E-05 5.24E-05PAM234 8.57E-05 6.64E-05U234 1.36E-05 2.49E-06TH230 1.29E-09 3.59E-06RA226 6.00E-05 4.90E-05RN222 3.46E-10 2.83E-06P0218 8.18E-07 6.34E-07PB214 2.06E-03 1.67E-03

BI214 1.36E-02 1.16E-02

P0214 9.89E-07 7.66E-07

PB210 4.17E-05 1.43E-05

D-10

Table 0.6 Cont'd

Dose factors for Doses from Ground Concentrations, mrem /yr per pC1/m2

ISOTOPE SV!N WHOLE BODY

U238 2.13E-06 3.17E-07TH234 2.10E-06 1.66E-06PAM234 1.60E-06 1.24E-06U234 2.60E-06 4.78E-07TH230 2.20E-06 6.12E-07RA226 1.16E-06 9.47E-07RN222 6.15E-08 5.03E-08P0218 1.42E-08 1.10E-08PB214 3.89E-05 3.16E-05BI214 2.18E-04 1.85E-04P0214 1.72E-08 1.33E-08PB210 6.65E-06 2.27E-06

in Table D-7, and cose conversion factors given in Table D-8 (Ref. I and Pef. 7). Vegetableingestion doses were computed assuming an average 50t activity reduction due to food preparation(Pef. 4). Ingestion doses to children and teenagers were computed but found to be equivalentto or less than doses to adults.

Table D.7 Assumed food Ingestion Rates,d kg/yr

Child Teen AdultI. Vegetables (Total): 48 76 105

a) Edibl' Above Ground: 16 29 42b) Po ta toes 27 42 60c) Other Below Ground: 5 5 3

II. Meat (Buf and Lamb): 28 45 78

a 4TT7ata talienToDieErence 4. Ingestion rates are averages for typical rural farm house-holds. No allowance is credited for portions of year when locally or home grown fo]d may notbe available.

Table D.8 Ingestion Dose Conversion factors (mrem /pci ingested)

Age Group Organ 238U 234U 234TH 230TH 226RA 210PB 210BI 210P0

Infant Wh. Bod 3.33E-04 3.80E-04 2.00E-08 1.06E-04 1.07E-02 2.38E-03 3.5SE-07 7.41E-04Bone 4.47E-03 4.88E-03 6.92E-07 3.80E-03 9.44E-02 5.28E-02 4.16E-06 3.10E-03Liver 0. O. 3.77E-08 1.90E-04 4.76E-05 1.42E-02 2.68E-05 5.93E-03Kidney 9. 28E-04 1.06E-03 1.39E-07 9.12E-04 8.71E-04 4.33E-02 2.0SE-04 1.26E-02

Child Wh. Bod 1.94E-04 2.21E-04 9.88E-09 9.91E-05 9.87E-03 2.09E-03 1.69E-07 3.67E-04Bone 3.27E-03 3.57E-03 3.42E-07 3.55E-03 8.76E-02 4.75E-02 1.97E-06 1.52E-03Liver 0. O. 1.51E-08 1.78E-04 1.84E-05 1.22L-02 1.02E-05 2.43E-03Kidney 5. 24 E-04 5.98E-04 8.01E-08 8.67E-04 4.88E-04 3.67E-02 1.15E-04 7.56E-03

Teenager Wh. Bod 6.49E-05 7.39E-05 3.31E-09 6.00E-05 5.00E-03 7.01E-04 5.E6E-08 1.23E-D4done 1.09E-03 1.19E-03 1.14E-07 2. lee-03 4.09E-02 1.81E-02 6.59E-07 5.09E-04Liver 0. O. 6.68E-09 1.23E-04 8.13 E-06 5.44E-03 4.51E-06 1.07E-03Kidney 2. 50E-04 2.85E-04 3.81E-08 5.99E-04 2.32E-04 1.72E-02 5.48E-05 3.60E-03

s ?,

Adult Wn. Bod 4. 54 E-05 5.17E-05 2.13E-09 5.70E-05 4.60E-03 5.44E-04 3.96E-08 8.59E-05 ::Bone 7. 67 E-04 8.36E-04 8.01E-08 2.06E-03 4.60E-02 1.53E-02 4.61E-07 3.56E-04Liver 0. O. 4.71E-09 1.17E-04 5.74E-06 4.37E-03 3.18E-06 7.56E-04Kidney 1. 75E-04 1.99E-04 2.67E-08 5.65E-04 1.63E-04 1.23E-02 3.83E-05 2.52E-03

1

-

D-12

REFERENCES FOR APPENDIX D

1. M. Momeni et al. , " Uranium Dispersion and Dosimetry (UDAD) Code". Argonne National LaboratoryReport, in preparation.

2. Perscoal cocrunication (letter), Environi ;al Coordinator, Energy FuelsNuclear, Inc. , to U.S. NRC, November 8,1978.

3. Generic Environnental Impact Statement on Uranium Milling, NUREG-0511.April 1979.

4 J. F. Fletcher and W. L. Dotson (compilers), " HERMES - A Digital Computer Code for Esti-mating Regional Radiological Effects from the Nuclear Power Indastry", Hanford EngineeringDevelopment Laboratory, HEDL-TMF 71-168. December 1971.

5. ICRP Task Group on Lung Dynamics, " Deposition and Retention Models for Internal Dosimetry ofthe Human Respiratory Tract". Health Physics 12:181, 1966.

6. National Academy of Sciences - National Research Council, "The Effects on Populations ofExposure to low Levels of Ionizing Radiation," Report of the Advisory Committee on theBiological Ef fects of Ionizing Radiation (BEIR), U.S. Government Printing Office,1972.

7. G. R. Hoenes and J. K. Soldat, " Age - Specific Radiation Dose Conversion Factors for a One-Year Chronic Intake," Battelle Pacific Northwest Laboratories, U.S.NRC Report NUREG-0172,November 1977.

Appendix E

LETTER TO THE ADVISORY COUNCIL ON HISTORIC Pr.iSERVATION

/pa -gn

* NEO ST AHSgi p ., NUCLEAR REGUL.ATORY COMMisslON NL p y {gg g{ y;.7

T r.js ta be h acted ty the Proposed[&' gl. e

**"""C"'White Pesa brani c Millv,;.

s,**"

In respense ta a recaest by Eneray Fuels % clear. Inc tre U.S. Eclearpeglatory Cyrissian preposes to issue a Source Material L? cease to possessand use source raterial at a uranic mill to te located on the White Mesaapprozinately five (55 miles scuin of Blancing. Utan. Uncer t*e provisiens

Advisory Council on of the Atomic Energy A:t of 1954. as arewed, and the regulatiens in Title 10Historic Preservation Code of Federal Reg 21ations. Part 40. the activity is subject to statutcry

Western Office licensira provisians atinistered by the U.S. Uclear Rulatery Corrissien.Review & Corpliance Energy f uels Oclear. Inc. sbitted its application for a Sarce MaterialATTN: Mr. Louis 5. Wall. Chief License on February (, 1978. Tre application is teing censidered forP.O. Box 25C85 arcroval ur. der the acplicable laws and regulaticrs.Denver, Colcrado 90203

A draf t envirer. rental stJte,ent (DES). copy attarned, relatie9 to theGentleren; crcposed isssance of the Source raterial License was issued in Deceser

cf 1979. The DL5 provides a aescription of the proposed project and anPursuant to 26 CFR 63.3 the U.S. Oclear kegulatory Conrission assesse.ent of tne environr'er.tal uT ac ts . Corrents were redested ardsubmitted to the Meper of the National Register a request for a received from various agencies of the federal covernment agencies of thedetemination of eligibility for the area included within the site state and local governments and interested individuals. Tne targe t dateof the proposed Energy fuels % clear. Inc., ihite Mesa Ura*ium for issuance of the final envirenrental statement (FIS) is May 15. M.M111. with the exception of the NEl/4 of Section 33. T375. R22E. Tne area of the propcsed mill lies within an archaaclogical district wnich(The NE1/4 of Section 33. T375. R22E has been su*veyed but the has been deterriined to be eligible for inclusien la the Natf0nal Registersignificance of the sites has not teen determined.) The attached of Historic Places. A desert: son of specific sites which will bePreliminary Case Report and a proposal for the contents of a affected by the pecJect is set forth in reports issued by the CivisionMemorandum of Agreement have been prepared and are reing submitted cf State kistory. State of Utah. The reports are attached hereto aspursuant to 36 CFR 800. Also attached is a letter from the Utsh Exhibits 8. C. and D.State Historic Preservation Officer unhicn centains his concurrenceon the pecposal. The opinion of the l'tah State Historic Preservation Officer (5HPO) con-

cerning the af fer*ed sites is sta'ed in letters to the % clear RegulatorySincerely. Coission dated Decerter 5,1978 and January 4.1979. ccpies of which are

attached tereto as Exhibits E and F.

'5" N ^ Alternative locations for the preposed project base been censidered bvthe Nuclear Regulatory Comission. tne Utah SHP0 and Energy fuels. The

Ross A. Scararo. Section Leader Utah 54PO. in a letter ta the Comission dated January 12.19 79, a copyUranium Recovery Licensing Brar1ch of wttich is attached hereto as Exhibit G stated that the project siteDivision of Waste Manrgement selected ty Energy Fuels will have the least adverse ef fect on

archeological resources of any of the alternstive sites considered in theEnclosures: As Stated area.cc: Mr. J. Phillip Keene !!!

A rorosal for the contents cf a Morandum of Ave.>nent has been de$wel-Utah State Historic Preservation Officer oped t:y the Cornission and is being forwarded. Sites which can be feasibly(w/o erclosures) and prudently avoided will be avoided.

E-3

- 2-3

Energy fuels has agreed to pay the f ull cost cf the data recovery progr 31i.pggttu,, w y gg y ggpgq7

The cost of construction of the pecject from its inception tc the cate ofy by the E nergs' fuels ENCLO5LRESthe commencement of the cperation is to bcrne solel

Nuclear, Inc. The f eaev al gcver3n+nt will not contribute to any part ofthe estimated cost of the project. 1 U. S. Eclear Regulatory Comm ssion, *0raf t 5tatement Related to the

Cperaticn of ' hite Mesa Uranium Frajec t, Energy f uels Nuclear,w

Inc.," Docket Ne 43-8661, Dec eric e r 1913.

2 Exhibit A - Mip of the aees w uth cf Ela, ding, Utah. This mapshows the eatire White Mesa and surroondirg areas. The area surveyedfcr archaeolcgical sites is delineated by the checked, heavy line.This area covers all of the mill site with the exception of the NESof Section 33 as = ell as additional area in Section 32, T375, R22E.This map identifies by legal subJivision (sections) the Cistrictboundaries.

3. Exhibit B - " Archeological Tes t Lucavatiers on ' *iite Mesa, SanJuan County, Swthentern Lt e " by ta'ar Lindsay, May 1978.

Note: The Plot Plan fcr the White Mesa Ura9ium Mill is includedThe t,cundary cf the guilt site is delir.eated by the dark blue lireand the area for desf @ ation as an Archeological District iscelineated in pirk. The pink line en the Plot Plan cerresoonds tothe cFecked line on the tap referred to in t5e description c'Exhibit "A" above. The Piet Plan shows toe ind .2 s.sl archeelogical sites.

4. Exhibit C - " Additional Archeological Test Excavati:ns and Inven-tcry on the White Mesa, San Juan County, Scutheastern Ltah," tyAsa 5. Nielson, January 1971 Phctogr e s are glossy black-and white.

5. Exhibit D - Repart prepared by David Merrill of the Utah StateHistorical Soc!ety. This report sumarites the findiMs of thehistcric survey of the White Mesa Area.

6. Exhibit E - Ltr f rom Utah SHP0 to NRC, dated Ceces.ter 5,1978.

7. Exhibit F - Ltr f rom btah SHP0 to NRC, dated January 4. 19/9.

8. Exhibit G - Ltr ? rom Utah 56P0 to NRC, dated January 12, 1979.

E-4

'UCT!74

Wr/> t FM T W U"i!NS C r A 2^'' up.QQ (g~ J y kg -'

Ccac err ing t*e Mitiga tion c f Akerse E f #ec * a t *.he'anite %sa Project willsite 1. If t% Car tssier issues a lic - se for the un ketakirg, it will

irtlee ccr jitions simlar to 'te failtwing ' N rein:

The U.S. Nucleae Pewlatory Comtssion pr a ctes ta isne a So.rce v terial a. '*e licensee shall a.cid by croject desicn whera feasiblea

License, puessant to the Atwic Er+rgy Ac t of I N , (42 L.S.C. 2Cllff.. as the sites desi; rated 111gible ' in the attac*ed T ele A.amended. f4 5 tat. 919), ta Ener;y O ls % clear Irc. in ccaractian with Sites that will ultimatel y t.e located w''H n 103 f ee t o f

its White M a Uraniun Will (*.ereiaafter referred to at t*e pro A *") the ;;er neter of t*e r< clained taili%s mognt ent area arelocated approxi ately five (5) -'iles s %th of Blanding, Ut# . consi dered anav:1 dele an d shall t.e recc.ced tacoa:h

arcteologj cal encavaticn.Energy f uels Nuclear, Inc has requested technical assistrce frm the

he licensee shall conh! testirg 45 re d rfd t0 en ele theCivtsion of State History, State of Utah, in the ijentification, protec- >

tien and mnagaraat of cultural resources. This assistarce hn Nen Cov issicn to sete m ne tf th,se sites desi cated 'undeter-1 red"provided in the for"i of cultural surveys and esca.atices en the lands in Table A are of significa*ce warraatir " etr redesi. ration asinvolved in the pr3 ject (pro)a't site). These activities re,ealed " Eligible. This action by ite licensee aill t'e co ph ted t+yneerous sites of cultural sir.ificance. (See E x h ibi t s ' , C and C. ) J inuary 1,1 %1. In all cases s x t testir; will be cxpleted beforeJ

any astec t of the unjertak ina a* tects a site.Accordingly, the $ccretary of the Interior w e re wested to i d e adeterminatian of eligibility. The re sul ting determinc tier., as set fortn in c. The licensee shall corut ar * >!.. 11 and histcricExhibit E, is that the area blinested M Edit it A ccrstttu'es a distric' sorwys ano testi n on the si t /4 of Secticn 33 T375 CE towhich is part of sw as yet undefir.ed larger Arcteolcgical C1 strict identify s/n aiditional sites as ray be lccated t*ere and tceligible for inclusien in the 'iat hnal Pe;ister of uist:ric Places. enable the t w ission to evaluate their signit r a r,c e . T*e

rasults of surveys and testina shall be reparu ^.a the

The l'.S. ',uclear Regulatcry Corrissicn in censultation with the Utah Cniss' m no later than Decerber 31, 1979. The licerseeState Historic Preservatien Of ficer, hn datermined that t*e land- Aall a m id any site within this area urtil tre Corrission

Ndifyiel creraticrs associated with the licensed activities (tereinafter has review *d the license't report aM *as advised thereferred to as "undertakinf) could have an al.erse ef fect upon the licersee of its # term rations. If the Comission, usar

property and pm su3at to Section ICE of the National Histrzeit P re s e rva- review, arends Tarle A ta ir.c l ade a Mt tinnal si th t*etion Act of 1%6 (16 J.S.C. 47CF, as wnded, 90 Stat. 132C), the licensee shall taka such action with respect t3 sa h additicral

U.S. Nuclear Regulatory Comissicn has rewested the ccrents of the sites as Ny te required for tte sites that have initiallyAdvisory Cconcil on Historic Preservation (hereinaf ter referred to as the teen desigaated."Curcil"),

d. Ynd1tien C, a'xve, will apply to lands associated with t*ePursuant to the requlaticns for tre" Protection of historic and CultJral O rtakirg, but which have not c urrently tei n iderti fied, e.;Frcaerties" (36 CFR Fart 800), the Utah State Historic Freservation to borrow a reas outside the current project tordaries, wit *Of ficer nd representatives cf the Advisory C:urcil on historic Pro the e=ception that t*e results of surveys and testing may teservation, and the U.S. Uclear Feulatory (mulissi0n hwe censultad and re?crted to the Corrission af ter Occerter 31, 1979.reviewd the undertaUng to corsider feasible and prudent altercatives toavoid, satisfactorily mitigate, or ninimite the adverse effect. Enerqv e. The licensee ;, ball avoid any site designated 7ndeter-ined~Tuels Nuclear, Inc. was invited to participate in the censultation. in T ele A.

In the light of such consultation, the Comission agrees that it will f. M en it is not feastble to avoid a site desierated *Eli)ible"take t*e followin; actions: in Table A, tne licensee shall institute a data recovery

prcgram with respect to the site which the Comission hter-ineswill satisf actorily mitigate any adverse ef fect.

E-5

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FNNi F0W THE CC W '75 (T A5 ' *~ % OL't C7 A7( MT

2. The Ce-rission will review all deter-inatlers of the 5 tateHistcric Preservati:n Of ficer with respect to sites wbse statn

L C C M ES(eligibility) has to date been found to te "urdetevner or .* f chare subsewently reported to the Conr ission as a result of surveysor discovery daring the conduct of the undertaking. If theComission cencars ith the deteMnations cf tre SrPO. theComission will take tre indicated administrative action (i.e.amend Tacle A, as referred to in tre literse conditiens). If theComission does n0t cor. cur with the deterrinations of the SHPC. 1. ibst A -Wg cf t** a*ca 50.1% et sta-erg.Lte (bis nap

-s '3e e" ire W"ite P o a a*3 se rr. s,c, q areas. Tre a aa serveyedit will request the cact ents of the Carcil t:efore any aterse

r 3r:Maeolr: cal sites 's delireated ty * *e c ecie:. *eivy li.e.'

ef fects upon such sites are terriitted.cc re rs all c f ' e ril' s i te .' th "e e xc e:t c, c f ' Fe M'.' cre

Sec' - 33 as wil as a:Dtir31 e-es in Sect'cm 32, T375 R22E.3. Tbe Corrission aill ccesult with the SPF0 with res;ect to any

** = naa id- tifies ty ! epi 5- : *1st:- (sectic s) the Cistrictdata recovery program to be undertaken ty t*e licensee ta nitigate: e caries.adverse ef fects and with respect to the monitoring progr3m milicn tre

licensee will tse reqaired to inle-ent. If the Comission concurs 9 - ' h elc: cal Tei,t E=:a,at m s c, Write esa, ss2- Em*" w'with ee recorrendations cf the SSPO. it will rewire '.re lice see ton

institute procrans in actordance trerewith. Othenvi se. * *e ~ an CZy , h' *e d s te r * ' 4" tv M a- Li-d ay, "ay 1978.

Comissicn will request the ccm ents c f the Coancil t.efore anyesa Pa .ie Mill is inciteed.S te: The Pict P'an 'cr t re wwite w

aberse ef fects upon the af fected sites are per"itted.The t Wr) .' ''e will site is deiireate d r, 'ae % = time line

4. The Corrissien will censult with the SHP0 with respect to the layout r1 ine a ea 'cr cesiratie, as a' A-:*c's;icel C hirict isCelireated - pirx. The p % lire ce 1 9 Plc' El e c r eer, W s toof haul roads prior to ghing its approval to ary rebest c f the ire c*ecaed line en t*e e c referr+d *, in 6'c de s p t on cf

licensee with respect thereto.E xr:t it * A" otove. The Pl.t Plan sN s '?e i v vic al art- .

5. Tre Corr:ission will exercise its inspection and enforcement le;ical sites.

authority in gecd faith to assure that the activities of thelicensee are carried out in accordance with its license and the 3. E=hibit C - "Miitleral ArJcol s;ical Test Encasatic-s c a Im en-

provisions of this Agreement. tory er t*e bhite Fesa, San Aan Cact> , G Ltrear e n tian,' tyAsa 5. Nielsen, JaNary 197t FN tog e/ s are gicssy tlack-and white.

6. The Comission will sut-it to the Keeper of tre National Register4. E t h i t, i t 0 - fercrt p epred t) Cav.d ''errill cf the (tan Statea request to e=pand the area of the Archeclcgical District to

include tre SE1/4 of Section 33, T375, U2E, unen initial deter- historical Society. This report suvarizes the fir;iss cf the

minations have been made concernirg the significance of indivital histcric sun ey of the White Fesa Area.sites within that area. 5. Exhibit E - t tr f rem keepe- of the Naticral Fe;ister, hat tenal

Park Service. DOI to UC, dated 4rtl 26.1979.

NOTE: Exhibits A, B C and 0 are comen to teth the Prell-irary CaseRepcrt 4-d the proocsal for a Mertraedir of A;ree ent.

E-7

. 4 1, , , ,; 4 . W '-

.: _ & i~

.). \ ,Y$s }*'7 I s'

, -

51.\ l1~. Ol l'I.\ll

s ,,i t si, mi ne nn. c..n o n..r

I)I l' \it I \llT I ()l'

I)l.\ l I ()l'\ll A i si.RVILI 5J Phi;ly Acrne til

1. nci on ne t hi ct ionMay 3, 1979 1u t suic cya .I

wh tac Gis. L'uh h4114i c tc p u.c. i m l > u 5 w e i

Mr. lux, A. Scar:ino, Sect ion Icad. r

!!r:ciliti '.fil1 Licen<iirc Sect ionIhl Pnx 2 ,ing :uid l'abricat ion IsranchDivi.; ion o f I'uel Cvele' anil

",t t e ri a l ;a le r yU. 'i. Wele.ar 3 palatory Orrr,hnionW:rdiingt on , D.C. 20555

lE. Pn iu ml for the 0;ntents of a 'kmrand:n of Agn4 n ntt'hite % ua, San Juan O)unty

D ar "r. Scarano:

'Ihe sta f f has revies d t he proposa1 n n > rand'ri o f acrn n nt .Tir n nar:c:d!m of agnxmnt will satisfy the necemarymit ia tion tu@r the r< viui n n etr, of I'Xi revivx pne nlun s.

!!ifa ver, t he agn xn nt d ser. ca11 for sare unnecessary mit1-gat ton trf t he develop r. We w>uld like to review t twwi t nx; individually at a later date.

If you ham any quest ions, pleam contact Wilson G. Mart in,801-5:G4017, or Jim IMr.an, 801-533-GXX).

Sincerely,

..

Phillip Keene III

IMeutive Dintetorand

State IIIstoric Pomrvation Of ficer

Energy 1hels Nuclear, Suite frid, 'lhne Park Central,cc

1515 Arapaho Drive, D nver, CO 80202

M71;jr:B7-ImJ

IG: Table A sinuld tw amndal to list sites 6391, G13(i, G137,G115, C646, GPR, (si,27, 7GfM in Eligible column, insteadof l'n&t ennincl. 'Ihe table is corn et to the lost of ourknowledge except for the alnive clunm

tilt iwlinN 01 : tNiil sl RI \l. l'RostolloN I K \\ ! 1.10.\ i t OPstl N I I .\PosilloNs . S t \ t t glisit pin . S IN E. ARis

E-8

.

Appendix F

RADON RELEASE DURING MILLING OPERATIONS

F-3

APPENDIX F. RADON RELEASE DURIf4G MILLIf.G OPERATIONS

F.1 ORE PADS

The radon-222 release from the ore pad can be estimated by the following data and assumptions:

Area of the ore pads (A) 2.43 x 10* cm/ (6 acres)

Thickness of ore piles (t) 670 cm (22 f t) - maximum case; and 305 cm(10 ft) - equilibrium case

Radium-226 concentration (cp3) 423 pCi per gram of ore

3Density of or e (t ) 1.6 g/cm

-1Decay constant of radon-222 (A) 2.1 x 10-t sec2

D .. (diffusion coefficient / void 2.5 x 10-2 cm /sec' fraction)

Radon emanation coefficient (generic 0.2Value giVen, actuai ore from nucerousmines may vary widely) (E).

The radon-222 flux (J) at the surface of an area with a finite deptt of unifom material maybe estimated:

J=C cf [(L/p[tanh[ p/(pgt),pg

where the syn.bols are as defined above.

The hyperbolic tangent factor corrects the infinite thickness radon flux for the thicknessof the pile. Substituting into this correction f *. tor for a 670-cn (22-f t) pile and a305-cm (10-f t) pile reveal that the radon release is reduced by 9 x 10-% and 0.75*.respectively. This reduction is negligible so the piles may be considered infinitelythick.

The radon flux (J) for an infinitely thick pile is given by

J=C CE Ykd'#)Ra e

Substitution of the above values gives

3 2 2J = (423 pCi/g)(1.6 g/cm )(0.2) V(2.1 x 10"' sec-2 )(2.5 x 10-2 cm /sec) = 0.031 pCi/cm sec .

F-4

Multiplication by the area gives the release rate:

JA = (0.031 pC1/cm2.sec)(2.43 x 100 cm2) = 7.54 x 106 pC1/sec = 7.54 pCi/sec = 240 C1/ year

This value applied to both the maximum and equilibrium stockpiles, as the flux is a function ofarea rather than thickness.

F.2 TAILINGS IMPOUNDMENT

For fill operations and prereclamation conditions the impoundment is assumed to have areas ofsaturated tailings, areas of moist tailings, and areas of relatively dry tailings. Tefollowing data and assumptions were used to detemine radon-222 release rates from tP.edifferent areas.

Radium concentration ('Ra) cf solids 423 pCi/g

Density 1.6 g/cm3

Emanation f actor 0.2

/r for dry tailings (8; moisture) 5 x 10-2 2cm /sec (ref. 1, Table 9.29)4

../r for moist tallings 1 x 10-2 2cm /sec (ref. 1,(151 moisture) Table 9.29)

P,/> for saturated tallings 5.7 x 10-6 2cm /sec(Vt moisture) (ref. 1, Table 9.29)

The " infinite thickness" flue is calculated by the expression

J, = Cpp Ya(L,/e)A

Substitution of the above values gives

2dry tails = 439 pCi/m -sec;.,,

2moist tails = 196 pCi/m -sec; ande,,

2=' saturated tails = 4.7 pCi/m -sec.*

Based on the conservative assumptions of 40 ha (100 acres) dry tails, 40 ha (100 acres) moisttails, and 20 ha (50 acres) saturated tails, the annual radon-222 release from the tailingsimpoundment system is calculated to be 8064 Ci. Radon releases from ponded areas arenegligible. Radon-222 releases from dry, moist, and saturated tails are 5552 Ci/yr,d82 Ci/yr, and 30 Ci/yr, respectively.

F.3 TAILINGS COVER REQUIRLMENTS

The following fomula was used in calculating the reduction in radon flux produced by theproposed cover system:

J=J exp - VA/(p/0)g , x ,

i=1

.--

.. ..._ _ _

F-S

where

the ith layer of a multicorponent cover (e is the number of components) ,*e

decay constant for radon-222 (2.1 x 10-6 sec-1) .A =

thickness of cover layer (cm) ,.c =

2, ' = resulting radon flux af ter attenuation through cover (pCi/m sec) ,

radon flux at the surface of the tailings (pCi/m .sec)2J =

The cover proposed by the applicant consists of 61 cm (2 f t) of compacted clay overlainby 1.2 m (4 f t) of silt-sand soil, a 1.8-m (6-f t) layer of rock overburden material, and15 cm (0.5 ft) of topsoil. The estimated D,/0 for these materials are 1.2 x 10-3 cm /sec2

cm /sec for the rest of the cover.2 The dry tailings2for the clay and 2.2 x 10-2(8% moisture) infinite thickness flux of 439 pCi/n sec is assured to model the long-2

term conditions for the system. Substitution of these values into the equation yields

.7=(439pC1/m2sec)exp{/(2.1x10-0)/(2.2x107)(320) - -(2.1 x 10-'')/(1.2 x 10-3)(61)}

(439 pCi/m sec)(3.42 x 10-3)2=

21.5 pC1/m sec=

3 the average background flux isAs reported in the Supplemental Environmental Report0.64 pCi/m sec. Because of its thickness, the silt-sand material is expected to contribute2

background flux,so the total radon flux would be essentially twice background. The proposedcover is adequate for areas where there is no significant accumulation of slimes. Theapplicant's proposed operating plan should prevent excessive sand-slimes segregation.

_ . . . _

F-6

REFERENCES FOR APPEf43!x F

1. R. E. Blanco et al. , correlatian cf R:.limtic+ wute Tre'1 * . >;t Cas ta v:1 ti:e !>.vir n-r..ntal ' ;ast of umte Affi:n nes, vol.1, Report ORNL/TM-4903, Oak Ridge National Labora-tory, Oak Ridge, Tenn., May 1975 Table 9.29.

2, Energy Fuels Naclear, Inc., n7:< cut t. * . Fr- 7 . c t i lilic :a w: >; a :i a:e t : ., n ite' a s :, rwn :o I r. ; c n , Oc t . 16, 1978..

3. Energy fuels N; clear, Inc. , .a ic .,tz! % .:rt, 5 uc lic.- !. -la.j !> t ec >r.: r. t .2 2 .h ; r t ,abite Me.r2 'ev:fr ir. ,t, n. h.in a .,*,, *ih, Sept. 26, 1978, p. 15.

Appendix G

CALCULATIONS OF TAILINGS PILE GMEA RADI ATION ATTENTUATION

.

*G-3

APPENDIX G

CALCULATIONS OF TAILIN'iS PILE GAMMA RADIATION ATTENUATION

Assuming soil to be composed mainly of $10 , the faass attenuation coef ficient for 1-2 MeV^

2

gama ray is 0.0518 cm /g.1 (Most of the dose rate from a typical natural emitter is inthis range.2) Assuming the gama radiation from the uncovered tailings pile to be aporoxi-mately 12 R/ year (same as for Bear Creek project) and the bulk density of the soil to be1.5 g/cm , the ef fect of the 3.28 m (10.75 f t) of soil materials proposed (excluding thel

shale layer) would reduce the gama radiation to approximately 10.3 pR year.

2 4I/I, = exp[-(i.. r/v).e] = eep[-(0.0518 cm /g)(1.5 g/cm3)(328 cm)) = 8.5 x 10 ,

I = (8.5 x 10-12)(12 fi, year) = 10.3 pR/ year

The background radiation dose as measured Ly the applicanti is 77.7 mR/ year. The gamaradiation from tne deposited tailinas would be insignificant compared to the natural

' gama background.

REFERE!CES FOR APPENDIX G,

'l. U.S. Department of Health, Education, and Welfare. -2dio?cji 2: He2!c;: n2r.JL x k, U.S.

Gevernment Printing Office, Washington, D.C., January 1970, p. 139.

2. H. May and L. D. Marinelli, " Cosmic Ray Contribution to the Background of Low LevelScintillation Spectrometry," Chap. 29 in r;;s Fine 2I F 2Hati:n 9::ircrnne, J. A. S. Adamsand W. M. 7 der, Eds., University of Chicago Press, Chicago, 1964.

3. Energy Fue Nuclear, Inc. , . ! .-~.:n t a : .4qc r:, 22ce:ir.e R2dioicL< Environe.cnt.1: ?q :r t ,. !n itc n o2 cc:nic Iw;et, Sept. 26, 1978, p. 27.

_ _ _ _ .

Appendix H

ATMOSPHERIC DISPERSION COEFFICICNTS

.

H-3

APPENDIX H

ATMO5PHERIC DISPERSION COEFFICIENTS

Tables H.1 through H.4 list x/Q (sec/m ) values calculated by the staf f using AIRD05-!!,l

a FORTRAN computer code,1 and onsite meteorological data supplied by the applicant.2

H-4

Table M.I. Annual average e/Q (se(/m') at various distantes for the 16 compassdirections, release height 1 e

_ _ - --- _ --._- _ _

Wind D i s t m. e fro ,effl *nt R%

f owa r i 315 7 'r) 541 1015 1400 17?9 2419

h 1.13E -t I . ? si -t it su - 7 6 EF-7 _ M [-7 _ g g 1Ahu 5.1 M 4 9 uM.7 6.ME-7 4 77E-7 7 w .] g, rgg. _3rpg.]_y,

--k*.- . __ LDL-L 1Af,L-L_LDL-L -- LDL1 ) lbE. L.-- I a (L-1- 1 RL-l _Wu 3.14i - C 6 h?t - 7 4.97[-7 3. pt . 7 2. 7 6,[ . 7 ,1gg(. 7 7 );t.3_,,,,_

W 3. M -6 5. C Jt - 7 3.4 st 7 7.5cr - 7 1 p[ - 7 147(-7 g(.L

w ', s 2.54[-6 4. 3?[ 7 3 Olf -7 ?. 2 3r - 7 1 3g .7 gyr .a 43.L', a 6.34[-6 1, ttt -6 7 g.1 e 4gt.L_ p[-_7 * "r -J_lbl-Lt

y,g 1. C4E - 5 1 6#E 6 1.171 -f. g. wr - 1 5. 34[. 7 3 s7(-7 1,gg n

5 ' . 31 E - 5 8. 24t -6 5. 6/f -6 4. %[ -f, 7. 51 F -6 1 g -6 URLsi.t / Mf -5 4 54f-6 3.11 L -6 ?.77i-6 1.40I-6 c "ar - 7 4, f[(-L

sr 2.54E-5 3 9?[ * 2. ist -6 1.9ar 6 1. ??t -6 a 09[-i 4,11[-7 _Its 9. H?f -6 1. 5 7r -6 1. cc t .c 7. 9 t(. {_,_4 gjt.y, 3 27c.7 j3gt.7_

i P.4af-6 1. lif - 6 9 44 -7 6&.7__{A-LJWLJ 1 (2L-Lg i;, 6 . C 3l - 6 1. 0 !I - 6 7. 2, I - 7 5 3 n .1 3 347-7 p pg.7 j j c3g.7

y 1.21E-5 2.16 E 4 1. 51 E -6 1.17t-6 6. Wi - 7 4 11[ 7 ? ,4 7[-L

et I.0 -5 1. 7 )[ 4 1. 71 f .6 9 Oit. 7 _3,4 ; t._l_j,nL- 7 ? . 0 4-]_.

Table H.2. Ann al average y/Q (sec/m ) et various distantes for the 16 compastiu

directions release te1 ht 6 m9

_ _ _ . .-- _

Wind Distam e fromeffloantJr)Toward J )5 790 949 1915 1431 17?1 74SO

g 7.10E-6 1.54E-6 1. f/*f -6 8.13[-7 5. lot - 7 yx-J___(Jg Lqw 5.10t -6 1.111 -6 7.93[ 7 5.93[-7 3. 74t.7 ? . 5 3E - 7 f . 33E-7

g 6.61E-G 1.43E-6 1.0/[-6 7. 6CE - 7 4. 7ht 7 3. 7 5f - 7 1.69[-7_4_3.91[-6 8.4?E-7 5.9 4E-7 4.48f-7 ?.8?f 7 1.91r-7 1.00E-7gy

2.94E-6 6. 70f - 7 4.75C-7 3. 51f - 7 2M7 lddL-7 _ldka_g,s 2.34[-6 5.53E 1 3. 9M - 7 2.9V -7 1.87[-7 lllE ? 6 d OA-_

,y 6.0$E-6 _ 1.441,-6 1.0?f -6 7. 60E - 7 4.77E-7 31t E-1 I d([ l_,

g 9.24t-6 ?. 34t -6 1.67[-6 1. ?4l - 6 7 PM-7 52[-7 Ll(L-l-S 4.59E-5 1. 2?i -5 8. 6 3f -6 6.4?t-6 WL-g ?.69f-6 L.17E -6

2. 4 /E - 5 6. 4)E -6 4. 6 3E -6 3. 4M -6 7.17k{ 1.4tE-6 7 4 [-]_..yg$g 2.1 RE - 5 5.78E-6 4.11 E - 6 3. 06 E - 6 1.9?r-6 1. 29f - 6 6 57[-7

8.61[-6 2. 2?E -6 1.58E-6 1.18f-6 7.41f-7 4 97[-7 2.56E-7gg_g 7.52t-6 1. 8Mf -6 1.34[-6 9.97E-7 6. ?tE - 7 4.??C-7 7.19E-7

pr 5.57E-6 1.34E-6 9. 5 8t - 7 7.17t - 7 4.54E-1 3. 0 7t - 7 1.61t-7

1. 20E - 5 '. 7 7E -6 1. 9 7E -6 1. 4 7E -6 9. 30r - 7 6. 2 7E - 7 3.78E-7gg

9.58f-6 2.17t - 6 1.540 6 1.16E-6 7. 3ri- 7 4.94t-7 2.59t.7g

. . _ . _ _ _

11- 5

Table H.3. Annual average ,/Q (sec/m') et various distances for the 16 cwpassdirections, release Pet /t 13.7 m

Wied D 6 s t a 3?_f re e f f l etj.* I

Toward 36 7N 9'3 10 % 1'00 1773 24M

q 3. 9 ?[ - 6 1.19E -6 9. 31 E - 7 7 4H-7 5.06E-7 3Jt E - 7 2. 'JEl_mg 2.BIE 6 8. 7BE - 1 6.84E-7 5. 45 E - 7 3.71E-? 2.64E-7 1.4aE-7

3.61L-6 1.13E - 6 8.80E 7 7. C ! E - 7 4. 7 7E - 7 3 W -7 1, 90E - 7ha

2. 22E -6 6. 73E-7 5. 25 E - 7 4.16E-7 2. 82E - 7 2. V;[- 7 1. I'E 7gg

W 1. 2iE -6 4. 76E - 1 3 R4E -7 3.13E -7 2.1 U7._ l.iti-7 PJL-1 ,_.

9 581-1 3. B M - 7 3.11E-7 2y -7 1. pF -7 Jl[ 7 7 O L.Rj,a

jw 2.151 -6 9. 4 7E - 1 7. P.5E - 7 6.511-7 4;6?E-7 3. 3g-1 1 94L-L _.

ej,a 2.21E-6 1. 37E 6 1.1 RE -6 1. rf:E -6 7. 32E -7 5.4K-7 3 1LL-l _

g 5.82[-6 6.28E-6 5. 7CE -6 4.95E 6 3.7C1-6 2.7o06 1.{,j[- L

$$r 3.11 E -6 3. 36E 6 3. CSE -6 2.65E-6 1. 9 7E -6 1.4H -6 8. 7 3E - 7

y 3. 25E -6 3. C2E -6 2. 7 3E-6 2&6 1. 76t -6 1.3?E-6 7.7tE-7

ggt 1.76E-6 1.25C-6 1.10E -6 9. X!- 7 6.8aE-7 5 .12E - 7 2.9)E-7e

g 2.10E-6 1.12E-6 9. 61 E - 7 8.11E-7 5. %E - 7 4.35E-7 2.52E-7

2.C4E 6 8. 9$E - 7 7. 3BE - 7 6. 09E - 7 4 32E-7 3.16E-7 1.R?E-7ggy5. 3;E -6 1. 9 4E -6 1. 5 7E -6 1. 26E -6 R.%E.7 6.%C-7 3. 7EE - 7g

4.74E-6 1.60E-6 1. 2 7E -6 1.02E-6 7. C]T - 7 5. l SE - 7 2. F.9E - 7pt

Table H.4. Annual average s/Q (sec/m') at various distances for the 16 cornpassdirections, release height 27.4 m

_

Wind Distance frm effleylld

T ward 335 7D 913 lh95 1413 1773 ?430

3 2. CtE - 6 B.0?E-1 6. 38E - 1 5. 20E - 7 3. 72E - 7 2.P1E-7 1. 75E - 7

1. 35E -6 5. PaE - 7 4.69C-7 3. 84 E - 7 2.76E-7 2.01E-7 1. 3CE - 7pg

1.82E-6 7. 6 ?I - 7 6. 06 E - 7 4. 95E - 7 3. 55E - 1 2. F.PE - 7 1. 6 7E -7gg

1. 0 7E -6 4. 6 3E - 7 3. 69E -7 3. 01 E - 7 2.15E - 7 1.61E-7 9 M 3E -8gg5.6EE-7 2. 76 E -7 2.27E-7 1. 91 E - 7 1. 44E - 7 1.13E-7 7. 4 3E -8g.

3.95E-7 2. 0 7E - 7 1. 7 3E - 7 1. 43E -7 1.14E-7 9. 04E -9 f 14[-j[_,as

7. 4 3E - 7 4. 74 E -7 4.05E-7 3. 5 3E - 7 2d3E-7 2. ? 7E -7 I Jg-79

5.82E-7 5.13E - 7 4.73E-7 4. hE-7 3. 75E-7 3.],3 E - 7 2. 37L-Ly$ 1.02C-6 1. 53C -6 1.57E-6 1.61E-6 1. st E -6 1.44E-6 1.15E-6

5.0l[-7 7. 99E - 7 8.43E-7 fL 64E -7 8. 33E-7 7. 72E- 7 6.1?E-7sst

gg 7.49E-7 7.94E 7 8.01E-7 8. 0 3E - 7 7. 5 EE - 7 6.97E-7 5.44-l _

4.85E-7 4.12E-7 3.90E-7 3.71[-7 3.29E 7 2.90E-7 2.19E-7gst

7. 6 7C - 7 4.69E-7 4.15E-7 3. 74E- 7 3.11E 7 2.64E-7 1.91E- LE

7.59E-7 4.47E-7 3. 82 E - 7 3.32E 7 2.62E-7 2.12E-7 1.45E-7DE

2.45E-6 1.12E % 9.15E-7 7. 72E- 7 5.83E-7 4.63E-1 3. 04 E - 7q

2.28[-6 9. 86 E - 7 7.96E-7 6.62E-7 4. 8FE - 7 3. 78E -7 2.44E-7ME

__.

li- 6

REFERENCES FOR APPENDIX H

1. R . E . Moo re , % A !i:Oc:;-II cc> ; u t e r cele fe r Ee t i"a t inj lodia t ion D.,cc ta M:n frc r-Airborne F1Jian.ali!ce in Arew currvun lir:) % lear Fa 'ilities, Report ORNL-5425,Oak Ridge National Laboratory, Oak Ridge, Tenn. ,1977.

2. Dames and Moore " Supplemental Report, Meteorology and Air Quality, Environmental Report,White Mesa Urantum Project. San Juan County, Utah, for Energy Fuels Nuclear, Inc." Denver,Sept. 6, 1978.

.

APPENDIX !

RADON DOSE CONVERSION FACTORS

I-3

APPEND!I !. RADON DO5E CONVER5 ION FACT 75

The t, asis upon which the hDC staf f has relied for its radon daughty inhat. tion dose conversionfactor consists of the f ollowing major cepceent carts:

from an outdoor redon-222The indoor working level (WL) concentration resulting WL;1.concentration of 1 pC1/mi t s appron tmately 5.0 a 10'

2. The nundser nf cumulative working level months (WLM) exposure per year for anaverage individual at a constant concentration of one WL is 25 WlM/yr; and

3. The cTuritted dose equivalent to the bronchial epithelle (basal cell nucleiof segrented broncht) per unit WLM esposure is 5000 mrem (5 rem).

These component parts enter into the following ecuation which yields the radon-222 inhalationdose conversion f actor used by the staf f:

5.0 a 10" WL 25 WLM/yr 5000 mrem 0.625 mrem /yr=a a

I pC1/m WL WLM 1 pCf/mii

Eat.M of tre three ccanponents identified above derive f rm sources and data identified below:

1 5y 10-6 WL per pC1/m' of redon-222 is established by the assumed indoor airconcentr a tion rat tos for redon-?22, polonium-218, lead-214, and bismuth-214of 1.0/0.90/0.51/and 0.35. These concentration ratios and the derived conversionf actor are representative of conditions in a reasonably well ventilated structure(Ref s. I and 2).

2. 25 WtM/yr per WL concentration deet ves from the assuirption tnat an averageindividual's everage breathing rate will be about 50 percent of that of aworking einer. A WLM is defined, in terms of esposure 10 a working miner,as one month's occupational esposure to a one-WL concentration. This assuredtireathing rate would result in en average individual receiving about 0.5 WLMas a result of the same length of esposure to air at a one-WL cortentration.The following relationship applies:

U "I'- * x 0.5 25 Wt.M/yrML(8760 hrs /yr) a if ars/wk n 52 wks/yr

3. Five rem /WLM is tPe value derived from applying a qua11ty f actor (QF) of 10for alpha radiation, to convert from *ad to rem (Ref t 1, 2, and 3), to thefigure of 0.5 rad /WLM as reported in the BEIR Report (Ref. 3, page 143).

The staf f considers the above basis for its radon-222 inhalation dose conversion factor to betmth sound and reasonable. The staf f acknowledges that radon dosimetry is entremely complexand strongly influenced by assumed enviroreental and biological conditions. In view of thelarge variations induced by rather small changes in the assumed free-lon fractton, relativeequilibrium, thickness of the intervening tissue and mucous layers, etc., the staff hasendeavored to use physical, environmental, and other data reasonat,1y representative of averagec ondi tion s .

peferences for Appendin !

1. ' Potential Radfological Impact of Airborne Releases and Direct Gansna Radiation to IndividualsLiving hear Inactive Urante Mill f ailings Piles," U.S. EPA, EPA-520/1-76-001, January 1976.

2. " Environmental Analysis of the Uranium fuel Cycle, Part I- Fuel Suppl)," U.S. EPA,EFA-520/9-73-003 6, October 1973.

3. 'The Ef fects on Populations of Exposure to Lor levels of lonizing 8ediation," Report of theAdvisory Corsnittae on the Biological Effects at lon12ing Radiations (BCIR), National Academyof Sciences - Rhtional Research Council, November 1972.

'U# U S. NUCLE AR REGUL ATORY COMMISSION1 11 NUREG-0556BIBLIOGRAPHIC DATA SHEETTITLE AND SUBTITLE (Add Volume No., sf appropriatel 2 (Leave bimk)

Final Environmental Statement related to operation ofWhite Mesa Uranium Project, Docket No. 40-8681 3 HE CIPIE N T'S ACCE SSION NO

AU T HO H (Si 5 O A T E HE POH T COVPL E TE D

MONTH YLAH

PE RF OHMING OHGANi/ATION N AME AND M AILING ADDHESS //nclude I,p Co*/ DATE REPOHT ISSUEO

U. S. Nuclear Regulatory Conmission ]y IQ""

gOffice of Nuclear Material Safety & Safeguards , ,t,,,, ,,,,,,

Washington, D.C. 205558 fleave blank}

. SPONSOHiNG ORG ANil ATION N AVE AND M AILING ADDRESS (IncIv* I.p Code /p

11. CON T H AC T N O.

Same as above.

T YPE Of RE POR T PE RIOD COV E PE D (inclus,ve dates)

Final Environmental Statement

. SUPPLEMEN T ARY NO TE S 14. (Lesve twe* /

. AUSTR ACT (200 words or less)

A Final Environmental Statement for Energy Fuels Nuclear, Inc. related to issuanceof a source material license for the White Mesa Uranium Project to be located inSan Juan County, Utah (Docket No. 40-8681) has been prepared by the Office ofNuclear fiaterial Safety and Safeguards. This statement provides (1) a summaryof environmental impacts and adverse effects of the proposed action, and (2) aconsideration of principal alternatives. Also included are comments of governmentalagencies and other organizations on the Draft Environmental Statement for this project ,

and staff responses to these comments. The NRC has concluded that after weighingthe environmental, economic, technical, and other benefits of the White Mesa UraniumProject against environmental and other costs and considering available alternative ,the action called for is issuance of a source material license, subject to stipulatedconditions.

KE Y WORD 3 AND DOCUVENT ANALYSIS 17a DESCRIPTORS

b IDE N Tlf IE HS/0/EN EN DE D TE RMS

. AVAIL ABILITY STATE MENT 19 SECURITY CLASS (Th,s reporff 21 NO. OF P AGE S

Release unlimited. 2o SECURITY cLASa (Thes papf 22 PRICEs

C FORM 335 (? 7 7)

IJ'stT E D ST A T E SNVCLIAH HffULATORY COMMi%3ON I l

W A%HING TON. O C. 20S5%Post AGE AND F E E E P AID

OFF ICI A L B USI N E SS u s mucLg An nEcuc Avony

PE N A L T Y F O R PH 4V A T E USE . $.100 00""'**'0"

LJ

.


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