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~ ~ III IIIIIIIIIIIII III <br />RESPONSE TO COMMENTS BY RADIATION CONTROL DIVISION <br />• IN LETTER TO JIM McARDLE DATED APRIL 5, 1983 <br />CDH Comment (1) <br />"What will be the use of the "emergency storage pond?" <br />Cotter Response <br />The emergency storage pond, which is subject to the provisions of the ore <br />sorter Radioactive Materials License, will be used far the purpose of <br />storing untreated mine water during unscheduled major maintenance activity <br />at the mine water treatment plant. <br />CDH Comments (2) - (5) <br />"Gross beta, in addition to gross alpha, for the leach potential test <br />would provide useful data at a low cost (see Appendix E.1). <br />An action level for further analysis, based upon gross alpha and cross <br />beta results, should be set so that the contribution from other radio- <br />nuclides can be individually assessed should uranium not account for the <br />• gross alpha activity, particularly with regard to radium-226 and the <br />thorium decay chain. <br />An action level based upon the leach potential test should be set in order <br />that waste rock with too high a leach potential be disposed of in an <br />alternate manner. <br />Cotter Corporation's procedure for the leachate test indicates the use of <br />deionized or tap water, adjusted to pH-5 (in an unspecified manner). <br />It is recommended that the EP Toxicity Test (40 CFR 261.24 and Appendix 2] <br />be used, with the inclusion of the analysis for U and Mo committed to by <br />Cotter, with the inclusion of the analysis for radium based on a discussion <br />that follows, .and the omission of the pesticide analyses. <br />The Department's chemistry section is able to run this test if a split <br />sample can be'obtained. <br />Drinking Ovate standards are 5 pCi/1 for radium-226, 15 pCi/1 for gross <br />alpha (excluding uranium), and 50 pCi/1 gross beta. A standard of 40 pCi/1 <br />for uranium has been applied to Ralston Creek. <br /> <br />