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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 (UOZASO4) which creates <br />uranium cake, sulfuric acid, and ferrous sulfate, which are 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 />• Bicarbonates 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 (FeS2) 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. Again, no serious analysis of these unique <br />characteristics was provided by the DRMS in support of its non-DMO determination. Likewise, <br />Cotter has not addressed these characteristics in its request for the Board to grant a DMO <br />exemption. <br />The DRMS Response seems to suggest that newly mined uranium ore does not contain "radium" <br />because the ore has not had a chance to "decay" at the surface. DRMS Response at 3 (reasoning <br />that because ore is not stored for more than 180 days, "decay products are minimal"). The <br />DRMS analysis appears to address the common meaning of "decay" as synonymous with the <br />rotting of vegetation or chemical reactions and wrongly assumes that the ore would produce <br />radium only when brought to the surface and allowed to rot ("decay"). However, "decay" is used <br />by Appellants in the unique manner that EPA uses the term - to describe the uranium and radium <br />in ore-bodies and in the waste, ore and protore encountered at a uranium mines. <br />Further, DRMS is wrong to assume that uranium ore that is at "equilibrium" does not contain <br />radionuclides that emit gamma radiation or that these materials cease to emit radon. DRMS <br />Response at 3("DRMS did not test fro Radium 226"). Radium-226 is measured in "equilibrium" <br />with uranium as a way to describe the relative amounts of uranium, radium and other <br />radionuclides in an ore body. That is, larger concentrations of uranium are accompanied by <br />proportionally larger concentrations of radium. <br />The discussion of Radium-226 and equilibrium in the EPA study was misunderstood by DRMS. <br />Response at 3. ("Since no mine waters exist, [Radium-226] seemed irrelevant.") Even when in <br />6 <br />