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Id. at ES-3. No consideration of the adverse effects of radon exposure at the SM-18 uranium <br />mine was contained in the Division's non-DMO determination. <br />In addition to the health threats from radon and other radioactive elements, acid mine drainage <br />poses a unique concern at uranium mines. <br />Uranium and thorium, and radium to a lesser extent, can be mobilized by either acidic or <br />alkaline solutions. Pyrite and other sulfur-bearing minerals aze key determinants as to <br />whether acid mine drainage occurs. <br />Id. at 3-18 - 3-19. The SM-18 mine file and the July 16, 20071etter submitted by Cotter <br />concerning the JD-9 monitoring well indicate that sulfur is present in the ores and groundwater in <br />the region. The Environmental Protection Agency has succinctly summarized the unique acid- <br />forming characteristic of uranium ore: <br />When water comes in contact with uranium bearing ore either naturally in the ground, or <br />when extracted under license by regulated processes, several oxidation reactions take <br />place. The end product of these reactions is uranium sulfate (UOZASOa) which creates <br />uranium cake, sulfuric acid, and ferrous sulfate, which aze the major wastewater <br />contaminants needing treatment. Additionally, the following chemicals can be generated, <br />either purposely or inadvertently, by chemical reactions occurring with the ore releasing <br />additional contaminants to the wastewater: <br />• Bicazbonates generated due to treatment of the acidic water with lime. <br />• Sulfates generated from the oxidation processes described above. <br />• Chlorides added to process water as a stripping agent in the solvent extraction <br />process from backwashing ofion-exchange resins. <br />• Nitrates generated from explosives used for rock blasting and fertilizers used in <br />re-vegetation. <br />• Nitrites and ammonium generated from the degradation of organic pollutants. <br />• Calcium generated as a residue of water treatment with lime. <br />• Sodium generated from the solvent-extraction and ion-exchange processes. <br />• Iron generated from the oxidation of pyrite (Fe52} and other ferrous sulfides. <br />• Manganese generated naturally from various weathering processes, but also <br />added as an oxidant, in some leaching processes. <br />Exh. 6 {EPA TENORM Report) at 4-8 - 4-9. <br />Neither Cotter nor the Division has provided any analysis of the quantity of uranium sulfate <br />(UOzASOa) created at the SM-18 uranium mine when the stockpiled uranium ore or the newly <br />exposed uranium in the mine comes in contact with water. No analysis has been provided <br />regarding the production of uranium sulfate (UOZASOa) by contact with rainwater, and in <br />particulaz summer storm events. Therefore, any exemption to the DMO designation lacks the <br />necessary basis in record evidence. This is particularly important where the Division accepted <br />6 <br />