Laserfiche WebLink
There are references to ore stockpiles at the SM-18 Mine and on other DOE sites. The April <br />2005 inspection report notes a stockpile of approximately 50 tons of ore on site. DRMS also notes the <br />site was in full production. At the next inspection in October of 2006 no stockpile was noted on site. <br />This notation bolsters the fact that stockpiles on-site are temporary by design and that no ore remains <br />on-site longer than 180 days per DRMS policy. The 5000 tons of ore on other DOE sites are non- <br />jurisdictional and irrelevant to this proceeding. <br />The appellant notes the possibilities of uranium sulfate. It is duly noted that DRMS did not <br />request or receive any data on uranium sulfate or UO2SO4. UO2SO4 is both an aqueous species and a <br />solid, which means that if Uranium and Sulfate are both present in water, then the aqueous species <br />UO2SO4 will be present as a dissolved aqueous species in the water. If the concentrations of Uranium <br />and Sulfate aze high enough to reach a certain threshold the dissolved UO2SO4 can precipitate from <br />solution as a solid. However, this scenario will only occur below pH of around 6, because UO2SO4 is <br />only stable under conditions of acidic pH. Above pH of about 6, U will form complexes with other <br />aqueous species, thus preventing UO2SO4 from forming as a dissolved species and from precipitating as <br />a solid. Dissolved Uranium in water has a far greater complexation affinity for dissolved Phosphate and <br />Carbonate than it does for Sulfate, meaning that if dissolved Phosphate is present in the water, or if the <br />pH of the water is neutral to alkaline (usually meaning that dissolved carbonate species are present), <br />then it will be very difficult for UO2SO4 to even form due to thermodynamic constraints, as U will tend <br />to form complexes with Phosphate and Carbonate preferentially over Sulfate. If the pH is above 7, <br />UO2SO4 does not form as either an aqueous species or as a precipitated solid, with or without the <br />presence of Phosphate or Carbonate, because U will complex with Hydroxyl ion (OH-) rather than with <br />Sulfate. <br />Unfortunately, DRMS has no data for pH, Phosphorus, or Carbonate species in the SPLP <br />leachates, and cannot draw any specific conclusions regarding the likely stability of UO2SO4 in the <br />]eachate waters. DRMS can infer a pH from the concentrations of certain ions, such as Aluminum. At <br />neutral pH, the concentration of Al should be no greater than a few ug/L, if detectable at all, so an Al <br />concentration of several hundred ug/L, in conjunction with other trace metal concentrations in the <br />detectable range, suggests acidic pH, probably below 6. <br />If an assumption of acidic pH is correct, and unless phosphate is present in the water, there is a <br />good chance that UO2SO4 will be present as an aqueous species. There is no way to be certain without <br />measurements of pH, P, and alkalinity (an indicator of carbonate). Additionally, the low concentrations <br />of Sulfate in the SPLP ]eachate from the SM-18 waste (ranging from 8 to 64 mg/L) suggest that <br />UO2SO4, if conditions are sufficiently acidic to favor its formation, will exist only at relatively low <br />concentrations, insufficient to induce precipitation of the UO2SO4 solid. <br />The appellant notes that DRMS did not test for Radium 226. Radium 226 is most commonly <br />found in aqueous solutions. Since no mine waters exist at the SM-18 the inclusion of this daughter <br />product seemed irrelevant. Other decay products noted of issue in ores exist over time. The ore <br />stockpiles are on site for less than 180 days. Therefore, decay products are minimal on-site and <br />represent no immediate long-term impacts. Concentrations of ore contamination within the permit <br />boundaries are being addressed through new strategies. The removal of built up materials through <br />shipment to a mill, or if in final reclamation the deposition of the materials within the mine workings <br />prior to capping, will help reduce surface exposure to near background levels. This strategy is being <br />implemented with new permits and older ones under revision. <br />