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2009-08-28_REVISION - M2005050
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2009-08-28_REVISION - M2005050
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Last modified
6/15/2021 2:20:33 PM
Creation date
9/9/2009 8:52:11 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2005050
IBM Index Class Name
REVISION
Doc Date
8/28/2009
Doc Name
Amendment application
From
Gault Group Inc.
To
DRMS
Type & Sequence
AM1
Email Name
GRM
Media Type
D
Archive
No
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Rimrock Exploration & Development, Inc. <br />J-Bird Uranium Mine/ DMO/ EPP Geochemical Data and Analysis <br />has largely adopted the EPA thresholds. However, CDPHE has developed more stringent <br />values of their own when defining appropriate land disposal practices for defined <br />hazardous waste. The CDPHE standards which define whether an element is hazardous <br />(as per exceedence of a toxicity based standard) are also provided in Attachment C. <br />The EPA and Department of Energy maintain substantial databases that document <br />toxicity thresholds, preliminary remediation goals as well as environment-based transport <br />coefficients for radionuclides and other inorganic constituents. These toxicity thresholds <br />and coefficients can be applied to data sets such as the surface deposition material <br />analytical results, in order to infer possible toxicology effects; or environmental fate and <br />transport potential. Attachment C summarizes a subset of these values for comparative <br />purposes. <br />Results from the sample analysis as compared to the regulatory thresholds indicate that <br />only Radium-226 and Radium-228 occur at levels above thresholds. The remaining <br />detected constituents (i.e. arsenic, barium, vanadium, zinc etc.) all occur below the suite <br />of thresholds within Attachment C. This provides an indication that the leachate from the <br />J-Bird materials has few constituents of concern with regard to toxicity, or migration <br />potential. <br />An interim MCL of 20 ug/L for uranium is being reviewed (not listed in Attachment C). <br />The SPLP results for uranium of the Spot 5, 6" deep sample exceed this value. In <br />addition, the EPA has published soil radionuclide protective levels for migration to <br />groundwater. These thresholds are values below which migration to groundwater is not <br />anticipated. The values for Radium-226 and Radium-228 range from 3.26E-07 - 3.2E- <br />01, and 1.15E-09 - 3.2E-01 respectively (units of mg/kg). Assuming a density of 1 g/ml; <br />the SPLP results for these isotopes are considerably greater than the groundwater <br />migration thresholds. These results indicate that as a conservative measure, water contact <br />and release from the surface deposition material needs to be managed to protect any <br />underlying groundwater resource. Given the geologic settings and results of historic <br />drilling and exploration activities, it is reasonable to conclude that the existing <br />groundwater resource is at considerable depth and already enriched with native elements. <br />TCLP: Toxicity Characteristic Leaching Procedure (TCLP) was introduced in the <br />1986 Solvents and Dioxins rule. This testing procedure was specifically initiated <br />for evaluation of the solvent- and dioxin-containing wastes. The EPA requires <br />that when a waste extract is tested the TCLP is used to determine whether a waste <br />requires treatment. <br />24
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