Final Report



### Review of Existing and Proposed Tailings Impoundment Technologies

Prepared by

S. Cohen & Associates 1608 Spring Hill Road, Suite 400 Vienna, VA 22182

Under

Contract Number EP-D-05-002 Work Assignment No. 4-11, Task 5

Prepared for

U.S. Environmental Protection Agency
Office of Radiation and Indoor Air

1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Reid J. Rosnick
Work Assignment Manager

September 25, 2008In accordance with the Quality Assurance Project Plan: Technical and Regulatory Support to Develop a Rulemaking to Modify the NESHAP Subpart W Standard for Radon Emissions from Operating Uranium Mills (40 CFR 61.25) , this document has been reviewed and approved by the following individuals:

Work Assignment Task Manager: ________________________ Date: __ 09/25/2008

__ Harry Pettengill

Project Manager: ________________________ Date: __ 09/25/2008

__ Abe Zeitoun

Corporate Quality Assurance Mgr: ________________________ Date: __ 09/25/2008

__ Gregory Beronja

Work Assignment QA Manager: ________________________ Date: __ 09/25/2008

__ Stephen Ostrow

WA 4-11, Task 4 – NESHAPs History i SC&A – September 25, 2008

### TABLE OF CONTENTS

1.0 Historical Conventional Tailings Impoundments ............................................................... 1

2.0 Profile of the Existing Industry ........................................................................................... 2

3.0 Anticipated Changes in the Industry Profile ....................................................................... 3

4.0 Comparison of Uranium Tailings Disposal Technology with the Requirements of RCRA, Subtitle C ................................................................................................................ 4

5.0 Discussion of Climate and Im poundment Size on Rn-222 Emissions ............................... 6

6.0 In-Situ Leach Uranium Recovery Facilities ....................................................................... 7

6.1 Scope and Background ........................................................................................... 7
6.2 Uranium Recovery Process for ISL ........................................................................ 9
6.2.1 Uranium Mobilization ................................................................................. 9
6.2.2 Wells ............................................................................................................ 9
6.2.3 Uranium Processing .................................................................................... 9
6.3 Radon Source Terms ............................................................................................. 10
6.3.1 Source Terms ............................................................................................. 10
6.3.2 Example In-Situ Recovery Radon Source Calculation ............................. 13 6.3.3 Decommissioning of Well Fields and Evaporation Ponds ........................ 16

6.4 Discussion ............................................................................................................. 16
6.5 Next Step ............................................................................................................... 17

7.0 References ......................................................................................................................... 17



### LIST OF TABLES

Table 1. Tailings Impoundments at Conventional Uranium Mills ................................................. 2

Table 2. Anticipated New Conventional Uranium Milling Facilities ............................................ 3

Table 3. Comparative Rn-222 Emissions over 70 Years ................................................................ 6

Table 4. Operating ISL Facilities ................................................................................................... 7

Table 5. Anticipated ISL Facilities ................................................................................................. 7

Table 6. Estimated Rn-222 Releases from an ISL Facility .......................................................... 17

WA 4-11, Task 5 – Impoundment Technologies ii SC&A – September 25, 20081.0 HISTORICAL CONVENTIONAL TAILINGS IMPOUNDMENTS

Although the recovery of uranium dates back to at least the 16 th century, large-scale operations did not commence prior to the 1940s. As there was initially little appreciati on of the radiological
or chemical hazards associated with the uranium tailings, early disposal practices followed those used in other metal extractions processes. The ta ilings were often disposed of in the least costly, most expeditious manner. Specific practices incl uded returning the tailings to a mined out pit, placing them on open ground adjacent to the mill, depositing them in natural depressions, depositing them in a valley behind a dam or dyke, or placing them in man-made impoundments known as ring dykes or turkey nest dams (IAEA 2004). Specific examples of such early practices include the following:

• Grand Junction, Colorado, where tailings were deposited adjacen t to the mill on open land bordering the mill or deposited in sha llow depressions behind levees bordering a
river

• Uravan, Colorado, where tailings were depos ited on an open bench on a canyon wall with nothing to prevent their movement to the canyon and river below

• Grants, New Mexico, where a massive ring dyke embankment was created using the course fraction of the tailings sands

Disposal of the tailings in wate r (either deep lake or river), wh ich has occurred in other countries, has not been practiced in the United States.

By the 1970s, the serious public health and ecological damage arisi ng from the past disposal of tailings led to the passage of the Uranium M ill Tailings Radiation Control Act (UMTRCA). Pursuant to the regulations promulgated unde r UMTRCA (40 CFR 192), the Department of Energy (DOE) at Title I sites and NRC licensees at Title II sites have almost completed the
restoration and stabilization of current tailings impoundments. For the most part, these
reclamation activities have entailed retrieval of wind-blown tailings fr om adjacent land and properties, stabilization of the piles in place under thick earthen covers with gravel caps, and riprap shoulders to minimize erosion. In extr eme cases, the tailings have been physically
removed to a new location to minimize thei r vulnerability to flooding or intrusion.

Impoundments at the few mills that remain opera tional and all future tailings impoundments must be built and operated to comply with the regulatory requirements of both the EPA and the NRC (or an NRC Agreement State).

WA 4-11, Task 5 – Impoundment Technologies 1 SC&A – September 25, 2008WA 4-11, Task 5 – Impoundment Technologies 2 SC&A – September 25, 2008 2.0 PROFILE OF THE EXISTING INDUSTRY

At the time the NESHAP for Operating Uran ium Mill Tailings Impoundments was promulgated (40 CFR 61, Subpart W, Decembe r 15, 1989 [FR 1989]), there were 11 conventional mills that were operating or on standby status. Of thes e mills, seven had unlined impoundments, while four had impoundments with synthetic liners. As the NESHAP revoked the exemption to the liner requirement of 40 CFR 192.32(a), the mills with unlined impoundments had to close them
and move towards final reclamation and stabiliz ation. Given the economics of uranium recovery throughout the ensuing years, all seven of the mills with unlined impoundments and one of the mills with a lined impoundment decided to dismantle the mills and move to final decommissioning and license termination. As a result, as of June 2008, the conventional uranium milling industry in the United States is comprised of only three facilities:

• The Sweetwater mill, with a capacity of 2,700 tonnes/day, owned by Kennecott Uranium Company

• The White Mesa mill, with a capacity of 1,100 tonnes/day, owned by UMETCO

• The Canon City mill, with a capacity of 1,800 tonnes/day, owned by the Cotter Corporation

The Sweetwater mill is located approximately 40 mills northwest of Rawlings, Wyoming; the White Mesa mill is near Blanding, Utah; and th e Canon City mill is near Canon City, Colorado. All three mills employ acid-leaching to extract uranium from the ground ore and dispose of the tailings in synthetically lined, partially belo w grade impoundments with earthen dams. Of the three, only the Canon City mill is believed to be currently processing ore; Sweetwater and White Mesa are being maintain ed in standby mode.

Only limited new data have been developed on th e current status of the impoundments. Based on the data developed during the 1989 NESHAP s rulemaking (EPA 1989), the impoundments are
as shown in Table 1.

Table 1. Tailings Impoundments at Conventional Uranium Mills

Mill Total Acres Ponded Wet Dry Radium Content (pCi/g)

Sweetwater 37 30 0 2 280

White Mesa 130 55 70 5 961 Canon City 130 128 2 0 400

The impoundments at the Sweetwater and Canon City mills are both single-cell impoundments. The White Mesa mill has a four-cell impoundment. Based on information reported in a 1 st Quarter 2005 Inspection Report (UDRC 2005), one cell holds processing liquids, two cells hold tailings, and the fourth cell, previously used to hold liquid wastes, has a torn liner. The liner and waste materials in cell four are being removed to cell two for disposal. The first of the two cells that holds tailings is filled and covered with random fill to control radon. The second of the two
cells has an earthen cover over about 40% of th e surface, with tailings and ponded areas covering
the rest.3.0 ANTICIPATED CHANGES IN THE INDUSTRY PROFILE

The rapid increase in energy costs, increased concerns about global warming, and the tremendous world-wide surge in energy use have a ll led to considerable new interest in uranium recovery. At the spring 2008 jo int National Mining Association/ Nuclear Regulatory Commission (NMA/NRC) Uranium Recovery Workshop, the NRC identified 29 projects that have or are anticipated to file applications for new licenses, expansions of existing ope rations, or restarts of existing operations by the end of fiscal year 201 1 (NMA/NRC 2008a). The vast majority of the new projects involve in-s itu leach operations (discussed below), one is a new heap leach facility,
and six are new conventional uranium mills. Of th e six anticipated new mills, one is in Arizona, two are in Wyoming, and three are in New Mexic o. Table 2 identifies eac h of these facilities.

Table 2. Anticipated New Conventi onal Uranium Milling Facilities

Owner Site State Expected Filing Date Strathmore Minerals Corp. Rocha Honda NM April 2009 Uranerz Energy Corp Mt. Taylor NM August 2009

Concentric Yavapai County AZ November 2008 Neutron Energy Marquez NM April 2010 Strathmore Minerals Corp. Gas Hills WY February 2011 Wildhorse Energy Sweetwater WY May 2011

It should be noted that the identi fied facilities are onl y those that the NRC is aware of. It is possible that additional faciliti es will be proposed in the Agreement States of Colorado, Utah,
and/or Texas.

None of the conventional mills have filed anything more than a letter of intent at this time, so there is no information available on the types of tailings impoundments that they propose to
utilize. In order to limit the potential radon that could be emitted from the tailings impoundments, Subpart W requires that the tailings be disposed of in a phased disposal system with disposal cells no larger than 40 acres, or by continuous disposal in which not more than 10 acres of undisposed tailings may accumulate at a ny time. Regardless of whether the new mills opt for phased- or continuous-dispos al, they will all have to also demonstrate that their proposed tailings impoundment systems meet the design criteria give n in Appendix A of 10 CFR 40. Criterion 3 of Appendix A identifies below-grade disposal, either in mines or excavated cells, as the “prime” candidate for tailings management. However, other methods may be approved if the applicant demonstrates that below-grade disposal is not feasible and that the proposed method will provide equivalent protection of persons and the environment. Additionally, every applicant will have to demonstrate that the proposed faci lity's operations will meet the NRC's ALARA (as low as reasonably achievable) requirement. The ALARA requirement almost certainly dooms any application that seeks to construct an above-grade impoundment with a ring dyke constructed with tailings sand. It also means th at some method will have to be used at all facilities to minimize the potential for wind to di sperse exposed tailings. The usual methods to minimize tailings dusting include using sprinkler s to keep the tailings saturated, applying a sealant, or simply covering them with a clay or earthen cap.

WA 4-11, Task 5 – Impoundment Technologies 3 SC&A – September 25, 20084.0 COMPARISON OF URANIUM TAILINGS DISPOSAL TECHNOLOGY WITH THE REQUIREMENTS OF RCRA, SUBTITLE C

The comparison of tailings facilities at current or future uranium mills and the final reclaimed configuration with RCRA subtitle C surface impoundments and landfills is not directly comparable; however, there are many salient sim ilarities in construction methods. There are significant similarities in the construction, even though the underlying “basis of design” of each
is different.

The basis of the design of the reclaimed tailings area is to prevent the release of radioactive material into the atmosphere, primarily radon gas, and secondarily radio active particulates. The prevention of radioactive material from leaching into the groundwater is also important via the Safe Drinking Water Act. Furthermore, all curr ent and future uranium tailings impoundments are expected to be in arid to semi-a rid areas in the western U.S., partic ularly in the states of Arizona, Utah, Colorado, New Mexico, Texas, Wyoming, Nebraska, and possibly Washington (the high desert area), with one possibl e exception in Virginia. Thus, on completion of the operating period, the reclamation of the tailings favors keepi ng water out of the tailings, i.e., total yearly evaporation is greater th an total precipitation. This is in c ontrast to an RCRA subtitle C landfill cover with multiple layers of protection specific ally designed to keep moisture away from the

waste.

The cover or final cap on a tailings pile is designed to limit the radon fl ux from the surface to less than 20 pCi/m 2 -sec. While this is called a “radon ba rrier,” the nomenclature does not reflect the physics of the situation. Rather than a barrie r, the cap is of sufficient thickness and density (actually tortuosity) that radon atoms diffus ing from the surface of the tails (higher concentration) to the surface of th e cap (lower concentration) must travel a long enough path that most will decay before reaching the surface. This is molecular diffusion through the soil. Obviously, soils such as clay or shale have much lesser poros ity then sand or gravel and, therefore, require the radon atom to use more tim e to diffuse through the material to the surface. As the half-life of radon is 2.8 days, a few feet of clay or shale soil is sufficient to reduce the
radon flux.

As briefly noted above, the typical RCRA s ubtitle C surface impoundment and landfill bottom liner systems have as a design basis the preventio n of moisture from mixing with the waste and leaching hazardous material in the groundwater. The landfills are sited throughout the U.S. in areas where precipitation is likel y to be greater than evaporat ion. Thus additional protection,
such as double confinement with a leachate collec tion system in between, is the standard. The confinement layer is also a composite compos ed of clay and a High Density Polyethylene (HDPE) liner. This is the typical base layer of the landfill. The caps can be equally complex with topsoil often used as a dr ainage layer (to remove precipita tion), and immediately below that is a liner which has been placed over compacted f ill. Their primary function is not to delay the diffusion of gas coming from the waste, but to prevent moisture from getting in and contacting
the waste.

The explicit similarities are more inherent to the technologies being applied. The use of synthetic liners, clay caps, and erosion barriers are co mmon to both and are used to achieve the

WA 4-11, Task 5 – Impoundment Technologies 4 SC&A – September 25, 2008WA 4-11, Task 5 – Impoundment Technologies 5 SC&A – September 25, 2008 regulatory goal of isolation of wastes contained therein from re lease to the environs (air and groundwater) over extended timeframes.5.0 DISCUSSION OF CLIMATE AND IMPOUNDMENT SIZE ON RN-222
EMISSIONS

A number of factors influence the emission of Rn-222 from tailings impoundments, including the climate and the size of the impoundment. For a give n concentration of radium in the tailings and a given grain size, the moisture content of the ta ilings will control the radon emanation rate; the higher the moisture content the lo wer the emanation rate. In the arid and semi-arid areas of the country where these impoundments are located or proposed, the annual evaporation rate is quite high. As a result, the exposed tailings (absent c ontrols like sprinkling) dry rapidly. In its previous assessments, the EPA has explicitly taken the fact of rapid drying into account by using a Rn-222 flux rate of 1 pCi/m 2 -s/pCi/g Ra-226 to estimate the Rn-222 source term from the dry areas of the impoundments (EPA 1984, EPA 1989). (N ote: The estimated source terms from the ponded and saturated areas of the impoundments are zero, reflecting the co mplete attenuation of the Rn-222.)

Climate also effects the source term from the impoundments once they are filled. The emplacement of the thick earthen covers that are necessary to assure the long-term stability of the reclaimed impoundments cannot be initiated until the tailings have dried sufficiently to allow heavy earth-moving equipment to be operated on the surface. For impoundments in arid or semiarid regions, the drying period will be shorter th an in areas where annual evaporation does not exceed annual precipitation. In its 1989 eval uation of mills for the Subpart W rulemaking (EPA 1989), the EPA assumed that a 5-year drying period would be required. In practice, a
number of facilities have been able to start c over operations earlier than that. For example, the White Mesa mill has a partial earthen cover on th e disposal cell that is still open to accept additional tailings.

The size of the impoundment has a direct linear correlation with the Rn-222 source term. Again, assuming the same Ra-226 concentration and grain sizes in the ta ilings, a 100-acre dry impoundment will emit 10 times the radon of a 10-acre dry impoundment. This linear relationship between size and Rn-222 source term is one of the main reasons that the Subpart W NESHAP imposed size restrictions on all futu re impoundments (40 acres per cell if phased disposal is chosen and 10 acres undispos ed if continuous disposal is chosen).

Using the sizes of the three existing conventional impoundments, and assuming identical grain
sizes and a Ra-226 concentra tion of 400 pCi/g, the effect of impoundment size on Rn-222 emissions can be illustrated for the operati onal period, the drying period, and the reclamation period as shown in Table 3.

Table 3. Comparative Rn-222 Emissions over 70 Years (Assuming 400 pCi/g Ra-226)

Operating Drying Reclaimed Total
Mill Total
Acres Ponded Wet Dry 15 yrs
Ci 5 yrs
Ci 50 yrs
Ci 70 yrs
Ci

Sweetwater 37 30 0 7 5.4E+3 9.4E+3 4.7E+3 2.0E+4

White Mesa 130 55 70 5 3.8E+3 3.2E+4 1.7E+4 5.0E+4 Canon City 130 128 2 0 0 3.2E+4 1.7E+4 5.0E+4

WA 4-11, Task 5 – Impoundment Technologies 6 SC&A – September 25, 20086.0 IN-SITU LEACH URANIUM RECOVERY FACILITIES

6.1 Scope and Background

Currently, in-situ leach (ISL) [also called in-sit u recovery (ISR)] has become the predominant method for uranium recovery in the United States . Table 4 shows the IS L facilities that are currently in operation under NRC or State of Texas control. As was made clear at the 2008 National Mining Association/Nuclear Regul atory Commission’s 2008 Workshop on Uranium Recovery, the number of IS L facilities is expected to increase substantially in the coming years. The National Mining Association estimated some 26 license/license amendment applications for uranium recovery facilities will be submitte d by the end of 2009 (NMA/NRC 2008a). This may be an underestimate, as the NRC at the same conference indicated it anticipated some 29 applications for facility restarts, expansions, or new licenses for uranium recovery by the end of fiscal year 2011 (NMA/NRC 2008b). Of these a pplications, 23 are for ISL facilities (14 new, 7 expansions, 1 combined, and 1 restart). Table 5 shows the company, site, type of project, and anticipated application data for these projects. As with conventional mills, this list includes only facilities established or to be developed in non-Agreement States, e.g., Wyoming, and those agreement states that do not regu late uranium recovery, e.g., Nebr aska. The list does not include
ISL or conventional faci lities in major uranium-producing Ag reement States, such as Colorado, Utah, and Texas. There are at leas t three proposed fac ilities in Texas.

Table 4. Operating ISL Facilities

Company Site State

Cameco Smith Ranch – Highland WY

Cameco Crow Butte NE Hydro Resources Crown Point NM Hydro Resources Church Rock NM

Mestena Alta Mesa 1,2,3 TX

Uranium Resources Kingsville Dome 1,3 TX

Uranium Resources Vaquez 1,2 TX

Table 5. Anticipated ISL Facilities

Owner Site Scope State Anticipated Application Date Cogema Christensen Ranch Restart WY Rec'd April 2007

Cameco North Trend Expansion NE Rec'd June 2007

Cameco Plant Upgrade Expansion NE Rec'd October 2006

Lost Creek ISR Lost Creek New ISL WY Rec'd October 2007 Uranez Energy Hank & Nichols New ISL WY Rec'd December 2007

Uranium One Moore Ranch New ISL WY Rec'd October 2007

Uranium One Jab & Antelope New ISL WY July 2008

Cameco Gas Hills Expansion WY July 2008

Kennecott Uranium Sweetwater Expand Resin WY January 2009

Cameco Three Crow Expand ISL NE February 2008

WA 4-11, Task 5 – Impoundment Technologies 7 SC&A – September 25, 2008Table 5. Anticipated ISL Facilities

Owner Site Scope State Anticipated Application Date

Lost Creek ISR Lost Creek Expand ISL WY October 2008

PowerTech Uranium Dewey Burdock New ISL SD October 2008

Cameco Smith Ranch Expand CPP WY May 2009

Cameco North Butte Expand ISL WY May 2009

Strathmore Minerals Sky New ISL WY April 2009 UR-Energy Lost Soldier NEW ISL WY January 2009 Uranez Energy Collins Draw New ISL WY July 2009

Uranium One Ludeman New ISL WY October 2008

Uranium One Allemand-Ross New ISL WY August 2009 Wildhorse Energy West Alkali Creek New ISL WY April 2009

Cameco Ruby Ranch New ISL WY October 2009

Strathmore Minerals Reno Creek New ISL WY December 2009 Wildhorse Energy Sweetwater New ISL WY May 2011

In-situ leach uranium mining is defined as the leaching or recovery of uranium from the host rock (typically sandstone) by chemicals, followed by recovery of uranium at the surface (IAEA 2005). Leaching, or more correctly the re-mobiliza tion of uranium into solution, is accomplished through the injection into the ore body of a lixiviant. The injec tion of a lixiviant essentially reverses the geochemical reactions that deposited the uranium in the first place, and assures that
the dissolved uranium remains in solution until it is pumped out of the ground and the uranium recovered. Two types of lixiviant systems can be used, loosely defined as acid or alkaline systems. In the U.S., the geology and geochemist ry of the majority of the uranium ore bodies
favor the use of an “alkaline” lixiviant or bicarbo nate-carbonate lixiviant and oxygen. Other
factors in the choice of the lixiviant are the ur anium recovery efficiencies, low operating costs, and the ability to achieve satis factory groundwater restoration. The acid systems once used in the United States are still used in Eastern Europe and Asia and recently in Australia on ore bodies in saline aquifers (IAEA 2005).

There are four major types of uranium depos its in the United States; strata bound, solution breccia pipes, vein, and phosphatic deposits (EPA 1995). Of these, in-situ leach is the uranium recovery technique used mostly on strata-bound or e deposits. Strata-bound ore deposits are ore deposits that are contained within a single laye r of sedimentary rock. They account for more
than 90% of the recoverable uranium and vanadium in the United States and are found in three major geographic areas—the Wyoming Basin (W yoming and Nebraska), Colorado Plateau or Four Corners area (northwestern New Mexico, western Colorado, eas tern Utah, and north eastern Arizona), and south Texas. A discussion of th e origin of the uranium ore, including ore body formation and geochemistry, may be found in the reference, Technical Resource Document Extraction and Beneficiation of Ores and Minerals - Volume 5 Uranium (EPA 1995). Much of the recoverable uranium in these regions lends it self to in-situ leach or recovery, based on the physical and geochemical propert ies of their ore bodies.

WA 4-11, Task 5 – Impoundment Technologies 8 SC&A – September 25, 2008Other important physical or geolog ic properties also in clude the location of the ore body. Ore bodies amenable to ISL are usually within an a quifer (EPA 1995). The water quality within the aquifer can also vary, depending on the pr esence of and boundary between oxidizing and reducing groundwaters (EPA 1995). Additional f actors important in the selection of the production method (lixiviant and well pattern) in clude chemical constituents, ore grade, permeability, and surrounding material. Ideally, the ore body should be confined by impermeable strata above and be low the deposit. This assures better hydrogeologic control of
the lixiviant and facilitates re storation of the groundwater foll owing completion of the mining (IAEA 2005). These hydrogeologic controls include preventing contamination of adjacent aquifers by excursions (leaks of lixiviant a nd other material from the ore body area).

6.2 Uranium Recovery Process for ISL

The following discussions are taken in part from EPA 530-R-94-032 (EPA 1995) and NUREG/CR-6733 (NRC 2001). The operational step s for the recovery of uranium are straightforward and consist of the three primary operations of uranium mobilization, uranium processing, and aquife r restoration.

6.2.1 Uranium Mobilization

First, barren extraction solution (lixiviant) us ually composed of groundwater enhanced by an
oxidant and carbonate/bicar bonate is injected through wells in to the ore zone. The lixiviant
oxidizes and dissolves uranium. Carbon dioxide in the lixiviant reacts with water, forming carbonic acid, which complexes with the solubilized uraniferous ions forming uranyl carbonates keeping the uranium in solution. The resulting solution is referred to as “pregnant lixiviant.” This process essentially reverses the geochemical reactions that initially caused deposition of the ore body particularly in “roll front” deposits. The solubilized uranyl carbonates and gangue minerals remain in solution as the pregnant lix iviant is pumped to the surface through production (recovery) wells. The pregnant lixiviant in cludes both radium and dissolved radon.

6.2.2 Wells

Three types of wells are used in the uranium r ecovery process; injection wells, recovery wells, and monitoring wells. The pattern of the inject ion and recovery wells is usually the 5-spot pattern or 7-spot pattern. In a 5-spot pattern, the injection well is in the center of a square with four recovery wells at the corners. The 7-spot pattern uses a hexagon fo r the recovery wells. The spacing between production and recovery we lls can range from 20 to 200 feet. Pumping rates are also variable, and at one facility ranged from 2 gallons per minute (gpm) to 30 gpm for injection wells and 5 to 40 gpm for recovery wells.

6.2.3 Uranium Processing

The pregnant lixiviant is pumped from the pr oduction wellheads through sand filters to remove any large particulates and then pumped to th e processing operations. Processing generally consists of three operations; ion exchange (IX), elution, and precipitatio n and drying. These are no different than that found in conventional mills, and indeed some ISL oper ations are co-located

WA 4-11, Task 5 – Impoundment Technologies 9 SC&A – September 25, 2008with conventional mills or truck the pregnant lixiviant (liquor) to a conventional processing facility.

The pregnant lixiviant is either stored in a surge ta nk or sent directly to th e IX resins. In the IX exchange resins, uranium is adsorb ed onto the resin beads. The ba rren lixiviant is recharged and sent back to the production well fields. When the IX resins become saturated with uranium, they
are taken offline and washed with a concentrated brine solution (the elution step). The uraniumrich solution, typically containing 8 to 20 grams/liter (g/l) uranium, is normally discharged to a holding tank. After a sufficient amount of pre gnant eluant is obtaine d, it is moved to the precipitation and drying circuit.

In the precipitation and drying circuit, acid is adde d to the pregnant eluant to destroy the uranyl carbonated complex and is precipitated out with the addition of hydrogen pe roxide. A base is added to neutralize any excess acid. The resultant sl urry is sent to a thickener, where it is settled, filtered, and dewatered. The thickened slurry ma y be transported to a uranium processing plant to produce yellow cake (U 3 O 8 ), or it may be dried and packaged (NRC 2001).

In terms of aquifer restoration, the objective is to provide exte nded flow through the mine field by injection, recovery, and bleed circuits, until it has been demonstrated that uranium is no longer being oxidized and released in the ore zone, and that confin ement has stabiliz ed within the aquifer.

6.3 Radon Source Terms

The above presents a capsule summary of the operati ons at an ISL facility. In this section, the potential radon source terms from these operations are identified and estimated.

6.3.1 Source Terms

The focus of this investigation is radon gas (radon-222, Rn-222), one of the principal contaminants in the uranium ore body and pregna nt lixiviant. Radon in groundwater is well known from drinking water and home radon studies th roughout the United States. These studies have found a range of radon concen trations from background to 10 5 to 10 6 pCi/l. While high, it
is noted that the theoretical so lubility limit for radon in liquid pha se at atmospheric pressure is
estimated to be about 3 × 10 16 pCi/L [8.59 × 10 -3 mol/L (NRC 2001)], considerably higher than what has been measured. Thus, concentrations of radon in water greater than that presented in the literature are possible.

To estimate the quantity of radon released dur ing the operation of an ISL, the methodology presented in Appendix D of NUREG-1569 was used (NRC 2003). The authors of this document estimated not only radon, but also releases of radium-226 (Ra-226) and some of its daughter products, and uranium-238 (U-238). They c onsidered effluent from the following:

(1) The drilling operation at new well fields (2) Uranium extraction operations at production well fields (3) Drying and packaging of yellowcake

WA 4-11, Task 5 – Impoundment Technologies 10 SC&A – September 25, 2008(4) Restoration operations of old well fields (5) Land application areas (bro adcast of holding pond water) (6) Decommissioning of well fiel ds and evaporation ponds

Of all these, the third is not relevant for radon. To provide some quantitative framework for a discussion of the radon released from ISL, the following was taken from Appendix D and modified to focus only on the radon issue. The parameters were also taken from the same
reference.

New Well Fields

New well fields are commonly investigated and esta blished using conventiona l rotary drill rigs. Investigation drill holes assist in mapping the ore body and determining the establishment of the injection and production wells. B ecause all exploration drill holes are sealed with bentonite to maintain aquifer isolations, no radiological particul ates are expected to be released from this operation. The only source of radi oactivity is the radon (Rn-222) from the radium in the drill cuttings, which are temporarily stored in a mud pit. During storage, Rn-222 is generated from the decay of Ra-226 and released to the atmosphe re. The amount of Rn-222 available for release on a yearly basis as a result of Ra-226 decay from stored cuttings can be estimated from the classic radon release equation:

Rn
nw = 10 -12 E L [Ra] T M N (equation 1)

where:

Rn
nw = Rn-222 release rate from the new well field (Ci/yr)

10 -12 = unit conversion factor (Ci/pCi)

E = emanating power or coefficient (dimensionless)

L = Rn-222 decay constant (0.181/d) (ln2 ÷ half-life of Rn-222) [Ra] = Ra-226 concentration in the ore zone (pCi/g)

T = storage time in mud pit (days)

M = average mass of material in mud pit

N = number of mud pits generated per year

Production Well Fields

No particulates are released from the producti on well field, because its process streams from production and injection wells to IX columns ar e all in a closed-loop circuit. The primary radioactive emission from the pr ocess streams is Rn-222. Duri ng the process, radon released from the ore body is readily removed by the lixi viant (process water) moving through the well field by injection and production wells. The 3.8 da y half-life of Rn-222 a llows it to circulate along with the process water in the well field over a long period of time before it decays (NRC 2001). Not all the Rn-222 is dissolv ed in the process water. The portion or fraction that remains is trapped in the ore zone. Also, a portion of the water in the ore zone is periodically purged (called the bleed) to maintain a cone of depression around the well field to prevent leakage of the mining solution outside the production zone (minimize excursions).

WA 4-11, Task 5 – Impoundment Technologies 11 SC&A – September 25, 2008The radon source term in the production ore can be estimated from the following:

S=10 6 L E[Ra] A D P (equation 2)

where:

10 6 = unit conversion (cm 3 /m 3 )

E = Active ore zone emanating power (fraction of radon released) [Ra] = Ra-226 concentration in the ore zone (pCi/g)

A = active area of the ore zone m 3

D = average thickness of the ore Zone (m)

P = bulk density of the ore material (g/cm 3 )

In the IX circuit, the water discharge from resin unloading, Fi can be calculated from the following:

Fi =Ni Vi Pi

where:
Vi = Volume content of the IX column (L)
Ni = number of IX column unloading per day

Pi = porosity of the resin material

Under steady state conditions, the Rn-222 concentration in the process water C Rn can be calculated from the following:

C Rn (equation 3)

where:

f = fraction of radon source carried by circulation water (dimensionless)

v = rate of radon venting from pipi ng and values during circulation (1/d)

V = volume of water in circulation (L) Fp = “purge” rate of treated water (L/d)

Fi = water discharge rate from resin unloading of IX columns (L/d)

When pressure is reduced during purging or wh en water is aerated du ring irrigation, radon is released to the atmosphere. The amount of Rn-222 available for release from the “purge” is dependent on the water volume purge rate, Fp, and on the Rn-222 concentration in the purged

water C Rn . Assuming conservatively that all availabl e Rn-222 in the purge water is released, the
annual Rn-222 emission is as follows:

Rn
w =3.65 × 10 -10 C Rn Fp (equation 4)

where:
3.65 × 10 -10 = unit conversion fact or (Ci/pCi) (d/yr)

Rn
w = Rn-222 release rate from purge water (Ci/yr)

WA 4-11, Task 5 – Impoundment Technologies 12 SC&A – September 25, 2008The annual Rn-222 release from occasional venti ng from wellheads and leaking transport piping can be calculated from the following:

Rn
v = 3.65 × 10 -10 v C Rn V (equation 5)

where Rn
v is the annual Rn-222 Release from Venting (Ci/yr).

The annual Rn-222 discharge from the unloading of the IX column content is as follows:

Rn X = 3.65 × 10 -10 C Rn Fi (equation 6)

where Rn X is the annual Rn-222 release from unl oading of IX column content (Ci/yr).

The total annual Rn-222 release fr om the production well field is the sum of the radon releases,

Rn
w +Rn
v +Rn X

.

Restoration Well Field

The basic operation of the restor ation well field is the same as that of the production well field. Groundwater in the ore body is restored to its pr e-mining level by flushing with fresh or treated water injections (groundwater sw eep). Again, the primary contam inant is the re lease of Rn-222 in the process water circulating within and di scharged from the restoration operations. The
annual Rn-222 releases from the re storation well field can therefore be calculated from equations
2 and 3.

6.3.2 Example In-Situ Recovery Radon Source Calculation

The following presents an estimation of the rado n source term at a “typical” ISL operation. For brevity, only those facilities expe cted to release radon are considered and include the following:

• One well field under development

• Two production well fields

• One restoration well field

• Main processing facility

• A holding pond

• Two radium-settling ponds

A satellite facility and irrigation plot is not considered. It is noted that the irrigation plot is also a source of radon; however, the c oncentration of Ra-226 in the water is limited. The example provided in Appendix D (NRC 2003) results in a surface soil conc entration of 1.3 pCi/g above background or total Ra-226 concentration of 2.3 pCi/g (background concentr ation of 1.0 pCi/g of Ra-226), which would give rise to radon flux of about 2.3 pCi/m2-sec.

WA 4-11, Task 5 – Impoundment Technologies 13 SC&A – September 25, 2008Generic parameters applicable to the entire facility:

• Yellow cake production rate = 520 me tric tons per years (MT/yr)

• Average ore activity of U-238 sand each pr ogeny in secular equilibrium = 280 pCi/g

• Ore porosity = 0.28

• Ore density = 1.8 g/cm 3

Considering the different wells fields separately leads to the following:

One Well Field Under Development

• The parameters selected for this well field are:

• Number of new wells peak year = 600

• Each well “covers” a 10 m × 10 m area = 100 m 2

• Number of new wells per mud pit =12

• Number of mud pits =50

• 1.6 × 10 4 L/d

• Drill hole diameter = 8 in

• Average ore material per well = 2.9 × 10 5 g

• Total ore material in mud pit per year = 3.5 × 10 6 g

• Average storage time of ore grade waste in mud pits = 12 d

• Radon emanating power = 0.25

Using equation 1 (Rn
nw = 10 -12 E L [Ra] T M N) and substituting leads to the following:

Rn
nw = 0.027 Ci/yr

The annual radon flux is estimated by dividi ng the total emission ra te by the area under development:

60,000 m 2 = 0.0143 pCi/m 2 -sec

Two Production Well Fields

The parameters selected for th e hypothetical production well fields are as follows:

Operating Parameter Well Field 1 Well Field 2 Operating days per year 365 d 365 d Active ore body dimensions: Peak area per year to be mined 50,000m 2 55,000m 2

Ave thickness of ore body 3 m 5 m
Total flow volume in circulation 4.2 × 10 7 L 7.7 × 10 7 L Facility (IX) parameters: Dimension/capacity of resin column 3,500 gal 3,500 gal Resin porosity 0.4 0.4 Number loaded resin unloading per day 3 3

WA 4-11, Task 5 – Impoundment Technologies 14 SC&A – September 25, 2008Operating Parameter Well Field 1 Well Field 2 Water discharge rate from unloading:
IX column 1.6 × 10 4 L/d 1.6 × 10 4 L/d Total wastewater purge rate 5.5 × 10 5 L/d (100gpm) 5.5 × 10 5 L/d (100gpm) Fraction radon in circulating water 0.8 0.8 Rate of radon venting during circulating 0.01/d 0.01/d

The radon concentration in the circulati ng water is calculated using equation 3:

C Rn

Substituting both sets of parameters leads to the following:

For well field 1, C Rn = 3.2 × 10 5 pCi/L; for well field 2, C Rn = 3.3 × 10 5 pCi/L

Substituting these values in equations 4, 5 and 6 leads to the following radon emission
estimates

Radon Emission Contributions Well Field 1 Well Field 2

Rn
w –Release rate from “purge” (settling pond) 64 Ci/yr 66 Ci/yr

Rn
v -Release rate from gas venting and leakage during circulation 49 Ci/yr 93 Ci/yr

Rn
x -Release from IX unloading 1.9 Ci/yr 1.9 Ci/yr
Total release rate 115 Ci/yr 161 Ci/yr

The parameters selected for the hypothetical restoration well field are as follows:

Restoration Well Field Expected restoration operation time = 7years Operating days per year = 240 d Area per year to be restored = 100,000 m 2
Average thickness of ore body = 5 m
Total flow volume in circulation = 100000 × 5 × 0.28 = 1.4 × 10 8 L Total treated water purge rates = 1.1 × 10 6 L/d
Fraction of radon source carried by circulating water = 0.8 Rate of radon venting during circulation = 0.01/d

The radon concentration in the circulating water is as follows:

C Rn

=3.3 × 10 5 pCi/L

WA 4-11, Task 5 – Impoundment Technologies 15 SC&A – September 25, 2008The radon released rate from purge wate r into the settling pond is as follows:

Rn
w =3.65 × 10 -10 C Rn Fp = 87 Ci/yr

The radon release rate form gas venting and leaking during circula tion is as follows:

Rn
v = 3.65 × 10 -10 v C Rn V = 197 Ci/yr

The total radon released from th e restoration field is 197 Ci/yr.

The radon flux from the irrigation plot is straightforward and was estimated as 1.3 pCi/m 2 -sec, not much over background.

6.3.3 Decommissioning of Well Fields and Evaporation Ponds

Evaporation ponds are typically lined temporary ponds with areas of 3 to 5 acres (10,000 to 20,000 m 2 ). They are designed with sufficient free board to contain the waste water from the process and any natural precipitation. As they ar e wet, they do not represent a source term for
either radon or radioactiv e particulates. Radon sources are also a function of the thickness of the soils generating the gas and containing the parent radium. The quantity of sediment (thickness) that eventually is deposited on the bottom of the pond is much less than that in tailings pond, and the generated radon is less and is covered by water. However, in many uranium production areas, the water balance favors ev aporation. Should the ponds begi n to dry out, they are sprayed to keep the surface wet, eliminating particulat es and minimizing radon. On closure of the pond, the material is typically excavated and dispos ed of as by-product 11(e02) materials (NRC 2003).

Upon completion of groundwater re storation, the operato r is required to decommission all well field piping and distribution sy stems, processing equipment, waste processing, and handling systems (including evaporation pond liners and resides) and to prepare it for appropriate disposal. Currently, under NRC guidelines, all re sidues and waste materials are treated as being uranium byproducts and disposed in licensed ta ilings impoundments. Radon emissions from well field piping and distribution ne tworks and evaporation ponds have not been demonstrated to add significantly to the Rn-222 source term.

6.4 Discussion

As indicated in the prior calculations, the am ount of radon released from the production well fields (115 Ci/yr and 161 Ci/yr) is greater than from the new pr oduction facility (0.027 Ci/yr) and comparable to that from the restoration we ll field (197 Ci/yr). The flux can be found by assuming the “foot print” of the area releasing radon is approximat ely equal to the area to be mined per year for the production well field and th e area to be restored for the restoration well field. It is also assumed that the ponds in both cases have an area which is a few percent of the
area to be mined or restored and can be ignored during the operationa l life of the facility. At the time of closure, waste from the evaporation ponds mu st be disposed of as if it were tailings waste. The NRC's preference is that it be di sposed of at existing conventional tailings

WA 4-11, Task 5 – Impoundment Technologies 16 SC&A – September 25, 2008impoundments, but where that is no t feasible it may be disposed of on-site. The fluxes are just the total radon release per year divided by the area. They are presented in Table 6.

Table 6. Estimated Rn-222 Releases from an ISL Facility

Process Being Considered Area (m 2) Annual Radon Release (Ci/yr) Average Radon Flux pCi/m 2 -sec New Well Field 60000 0.027 0.0143

Production Well Field 1 50000 115 73

Production Well Field 2 55000 161 93

Restoration Well Field 100000 197 63

While these radon fluxes are three to four times greater than that allowed in conve ntional tailing facilities (20 pCi/m 2 -sec), they are conservative. For the production well fields, they do not include the area of the ponds (pur ge water source term) or the ar ea of the processi ng facility (IX unloading source term). Also, in the case of the re storation well field, they are transient releases and revert to background on comp letion of the restoration.

6.5 Next Step

The prior discussion indicates some emission of ra don is estimated to be released from in-situ leach operations primarily during the operations period and during restoration. These releases could have an impact on the surrounding population. The estimated radon release is based on a number of parameters, many of wh ich are assumed to be “best estimates” in and of themselves. As a start, it is suggested that a critical review of the parame ters be undertaken to determine which are most susceptible to large variations and of these, which can be documented by actual or proposed but desi gned operations.

7.0 REFERENCES

10 CFR 40, Title 10, Part 40: Domestic Licen sing of Source Materials

, Appendix A: Criteria Relating to the Operation of Uranium Mills and th e Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source Mate rial from Ores Processed Primarily for Their
Source Material Content.

40 CFR 61, Title 40, Part 61: National Emission Standards for Hazardous Air Pollutants, Subpart W: National Emissions Standards for Radon Emissions from Operating Mill Tailing s.

40 CFR 192, Title 40, Part 192: Health and Environmenta l Protections Standards for Uranium and Thorium Mill Tailings

.

EPA (Environmental Protection Agency) 1984. Final Background Information Document Proposed Standards for Radionuclides , EPA 520/1-84-022-1, Office of Radiation Programs, Environmental Protection Agency, Washington, DC. October 1984.

EPA (Environmental Protection Agency) 1989. Risk Assessment Methodology Environmental Impact Statement NESHAPS for Radionuclides Background Information Document , Volumes 1–

WA 4-11, Task 5 – Impoundment Technologies 17 SC&A – September 25, 2008WA 4-11, Task 5 – Impoundment Technologies 18 SC&A – September 25, 2008 3, EPA 520/1-89-005, Office of Radiation Prog rams, Environmental Protection Agency, Washington, DC. September 1989.

EPA (U.S. Environmental Protection Agency) 1995. Office of Solid Waste, “Technical Resource Document, Extraction and Beneficiation of Or es and Minerals, Volume 5 URANIUM,” EPA 530-R-94-032, January 1995.

FR (Federal Register) 1989. Fi nal rulemaking package for Subpart W. Volume 54, page 51679. December 15, 1989.

IAEA (International Atomic Energy Agency) 2004. Long-Term Stabilization of Uranium Mill Tailings , Final Report of a Co-Ordinated Research Pr oject, International At omic Energy Agency. Vienna, Austria. August 2004.

IAEA (International Atomic Energy Agency) 2005. “Guidebook on Environmental Impact Assessment for In-Situ Leach Mining Projects,” IAEA-TECDOC-1428, May 2005.

NMA/NRC 2008a. “Uranium Recovery Licensi ng Activities,” Presentations at the 2008 National Mining Association/Nuclear Regulator y Commission (NMA/NRC) Uranium Recovery Workshop. Camper, Larry W., Accession Number ML081430061.

NMA/NRC 2008b. “Generic Environmental Report fo r In Situ Uranium Recovery Facilities,”
Presentations at the 2008 Na tional Mining Association/Nu clear Regulatory Commission (NMA/NRC) Uranium Recovery Workshop. Thomps on, Anthony J. and Christopher S. Pugsley.
Accession Number ML081430176.

NRC (U.S. Nuclear Regulatory Commission) 2001. “A Baseline Risk-Informed, PerformanceBased Approach for In Situ Leach Uraniu m Extraction Licensees,” Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, NUREG/CR-6733, September

2001.

NRC (U.S. Nuclear Regulatory Commission) 2003. “Standard Review Plan for In Situ Leach Uranium Extraction License Applications ( NUREG-1569),” Appendix D, “MILDOS_AREA: An Update with Incorporation of In Situ Leach Uranium Recovery Technology,” May 1997. Nuclear Regulatory Commission, Office of Nucl ear Material Safety and Safeguards, 2003.

UDRC 2005. Utah Department of Radiation Control 1 st Quarter 2005 Inspection Report.