ML20198B660
| ML20198B660 | |
| Person / Time | |
|---|---|
| Issue date: | 09/24/1985 |
| From: | Konwinski G, Pettengill H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-186, TASK-TF, TASK-URFO NUDOCS 9801070027 | |
| Download: ML20198B660 (5) | |
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DISTRIBUTION URP WM-186/GRK/85/08/09/0-1 URF0 s/f URP WM-186 SEP 2 41985 kag"rt,RIV GKonwinski l
BBrown, RIV
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i URFO:GRK URP WM-186 040WM186101E MEMORANDUM FOR:
File Code URP WM-186 FROM:
Gary R. Konwinski, Project Manager Licensing Branch 2-
)
Uranium Recovery Field Office, RIV
SUBJECT:
REMEDIAL RECLAMATION - UNNAMED HEAP LEACH SITE, GAS HILLS, WYOMING During-the November 30,1985. site visit to the Gas Hills Uranium Mining District, several heap leach sites were visited by the Wyoming Department of Environmental Quality (DEQ)(, Energy-Fuels Nuclear (EFN) and the Uranium Recovery Field Office URF0). During the visit two sites were identified which were in need of additional work:- The Day Loma heap leach site and an Unnamed heap leach site.
The Day Loma site is being handled under-Amendment No. 23 to SUA-56.
.This action specifically required that all remedial action be-completed
-by-July 15, 1985.
A subsequent request by Western Nuclear Inc. resulted in amending'the time for completion of.' remedial action on the Day-Loma (J
. pile until December 31, 1985.
3-The Unnamed heap leach site represents an early research effort to heap leach low grade ore. The original research work was conducted by Western Nuclear Inc., but is currently covered under a mining permit, issued by
-the State of Wyoming to Centurion Nuclear Inc. which is owned by Energy Fuels Nuclear.
The Unnamed heap leach site has gone through a series of mining and reclamation events which have removed most of the residual byproduct
. materials.
These materials were voluntarily removed in 1982 by Centurion. The heap leach byproduct materials were removed to an adjacent pit and covered with mine spoil from subsequent mining 9eo1070027 850924 PDR WASTE m 186 PDR L. _l.......
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t URP WM-186/GRK/85/08/09/0-2 operations.
Based upon field observations, it appears that approximately 30 feet of mine spoil cover the leached materials which are about 50 feet above the static ground water level. Due to the small quantity of byproduct material and the method of disposal, the staff-concludes that
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little or no potential for release to the environment exists.
The staff
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further concludes that a-long term possession license in accordance to
~Section 83 of the Atomic Energy Act of 1954 as amended will net be required.
Although this. removal included digging up most of the leached ore, disposing of the plastic liner and drain pipe as well as removing some of. the underlying substratum, no radiological survey or final reclamation was completed for tne heap leach site pad.
Based upon an NRC request, EFN obtained eight (8) soil samples from the heap leach pad area and adjoining areas.
Five of the soil samples came h directly from the heap leach site and the remaining three samples were v obtained from adjacent areas. The samples were transmitted to the NRC by letters-dated June 26 and April 3, 1985. The samples were analyzed, by the NRC, for U-238 and Ra.226 and represent the activity of the heap leach site and background locaticns.
Figure 1 shows the locations of the l
sample sites, f
The sample-results, as shown below, indicate that the Radium 226 content of the heap leach pond area is about 10 times higher than that of the background samples. Similarly, the uranium content of the heap leach area is approximately 4 times lower than the background samples.
These data indicate that a disequilibrium situation exists between Ra.226 and U.nat on the heap leach area.
It is assumed that the original uranium content of the materials en the heap leach area.were -in, or approaching, equilibrium with the radium. Based upon the lab results, the staff concludes that the heap leach materials represent byproduct materials and as such must be appropriately disposed of to achieve regulatory-(s-requirements.
)
- Sample No.
U-nat(uCi/g)
Ra.226(pCi/g)
Heap Leach Samples 1
1,56 x 10-7 27.8 2
1.49 x 10 5.7 1.62 x 10-6 24.2 3
1 1.22 x 10 6 28.3 4
5 1.56 x 10-6 24.6 i:
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- Figure 1 Unnamed Heap Leach Site -
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glll-l esir.s 1 l p // l o 7%ll/ f' '/' li[Y s / / I \\ 6 i ~ f-R A (h. h eaon. 32;l$.6%HEA R L4JACH PIL \\. I +4 h,[$6:' 2 f$D 8 "?'- c.;
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t t.h h. D \\ q**ce-[$ _ _ _;l t g J / ,( \\ / 6388 3 y l E367.7l / / 1 / O / / Q /
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n 6373.5 i 6360.6 \\ l 15 1.2 \\ i f s I l LEGEND Adjioning reclaimed area Scale in feet s 6ff Unnamed heap leach area 4; Neighboring mine spoil area 0 100 200 .c q j O soil sample sites A
a 9 URP WM.186/GRK/85/08/09/0 4 Sample No. U-n'at(uCi/g) Ra-226(pC1/g) Background Samples 6 7.2 x 10 6 2.4 7-5.2 x 10 6 3,9-8 7.2 x 10'0 2.7 Two clean up options exist for the site: reclaim and stabilize the materials in place or remove the materials to an-authorized disposal site. Either of these options would be acceptable to the NRC as discussed below. Should the bury in place option be selected, EFN would have to O demonstrate that the residual materials could be sufficiently covered and V stabilized to remain isolated from the environment for 1000 years. Such a stability analysis would include calculations of wind, water and gully erosion; a method for diverting runoff away from the reclaimed area and a determination of radon exhalation rates. If this option is chosen, EFN l should determine the total quantity of byproduct materials and discuss whether transfer of possession and long-term monitoring and maintenance of the site is warranted as specified under Section 83 of the Atomic Energy Act of 1954, as amended. Current mining plans for the site: l indicate.that the residual heap leach materials will ultimately be
- covered by more than 50 feet of overburden from an. adjoining pit.
in epite of this the NRC feels that a stable cover is necessary as discussed above. This would sufficiently preclude any health and safety risks to the general public prior to covering the site with overburden as stated in the mining plan for the adjoining propeny. /% Should EFN choose to remove the materials to an authorized disposal area, i V no stability analysis would be required; however, a radiological survey 1 -with supporting soil samples would be required to verify Ra-226 clean-up -to the 5 pCi/gm above background standard. The staff concludes that EFN should be presented with these clean-up options and be required to submit-a proposal :for final reclamation of the site. The staff concludes that all reclamation work should be completed during calendar year 1985. 9 . E: E :85/09/23-l
URP WM-186/GRK/85/08/09/0 -5. l l 5 Gary R. Konwinski, Project Manager Licensing Branch 2
- Uranium Recovery Field Office,. RIV S
Approved by: Harry J. Pettengill, Chief Licensing Branch 2 i . Uranium Recovery Field Office, RIV l lv h7 s. F .URF / : 3. nski : HPet) 11 : - .......:.......7 3..:_...........:..........:............:.______...._:........__.
- 8 /09/23
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