ENVIRONMENTAL  SURVEY  OF  URANIUM  MILL
            TAILINGS  PILE,  MEXICAN HAT,  UTAH
                         by
                 Robert N.  Spelling
             Technical  Services Program
    Southwestern Radiological  Health Laboratory

    Department of Health, Education, and Welfare
               Public Health Service
Consumer Protection and Environmental  Health Service
                                                                    SWRHL-68
                    October 1969

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                                                                    SWRHL-68
         ENVIRONMENTAL SURVEY OF URANIUM MILL
           TAILINGS PILE, MEXICAN HAT, UTAH
                         by
                 Robert N. Snelling
             Technical Services Program
    Southwestern Radiological  Health Laboratory

    Department of Health, Education, and Welfare
               Public Health Service
Consumer Protection and Environmental Health Service
                    October 1969

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                             ABSTRACT
     At the request of the Navajo Tribal  Council  through the PHS
Division of Indian Health at Window Rock, Arizona, an environmental
radiological survey was conducted on the A-Z Minerals Corporation
uranium tailings pile, Mexican Hat, Utah, in May  1968.   The purpose
of the survey was to identify any radiation hazards which might
exist and recommend methods for their control.  The survey included
evaluation of external gamma radiation, airborne  radioactivity, and
waterborne radioactivity.  The results of the survey indicate that
the external radiation levels on the tailings area exceed recommended
exposure limits for individuals in the general  population.  Therefore,
the area should not be released for public use in its present state.
Action which would permit the release of the area would involve
covering the tailings with uncontaminated dirt to an extent that
would diminish the external radiation to an acceptable  level and
to stabilize the covering against wind erosion.
     Radiation levels in air and water do not exceed recommended
exposure limits.  However, to minimize the possibility  of increased
activity from weather conditions different from those existing
during the survey, it is recommended that the tailings  be stabilized
against wind erosion.  Otherwise, periodic monitoring will be
necessary in the future.

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             ACKNOWLEDGEMENTS
     Sincere appreciation is expressed  to the A-Z Minerals
Corporation for the cooperation and assistance provided
during the survey.   Without its cooperation,  the study could
not have been adequately performed.
                           11

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                        TABLE OF CONTENTS

ABSTRACT                                                          i
ACKNOWLEDGEMENTS                                                 i i
TABLE OF CONTENTS                                               i i i
LIST  OF TABLES                                                  iv
LIST OF FIGURES                                                   v
      PURPOSE                                                     I
      LOCATION AND DESCRIPTION                                    I
      ENVIRONMENTAL SURVEY                                        3
      A.  Sampling Procedures                                     3
          I.  External Radiation Exposure                         3
          2.  Air Samp I ing                                        3
          3.  Water Samp I ing                                      8
          4.  Tailings Material                                   8
      B.  Analytical Procedures                                   8
IV.   RESULTS                                                    II
      A.  External Radiation                                     II
      B.  Ai r Samp I ing                                           15
          I.  Long-lived Airborne Particulate Radioactivity      15
          2.  Radon Gas                                          15
          3.  Radon Daughter Products                           22
      C.  Water Samp I ing                                        22
      D.  Tailings Sampling                                     22
V.    DISCUSSION OF RESULTS                                     27
      A.  External Radiation Exposure                           27
      B.  Ai r Samp I ing                                          28
          I.  Long-lived Airborne Particulates                  28
          2.  Radon-222 and Daughter Products                   30
      C.  Water Samp I ing                                        31
VI.   SUMMARY AND RECOMMENDATIONS                               31
REFERENCES                                                       ,4
DISTRIBUTION

                                  iii

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                          LIST OF TABLES

Table I.      External radiation measurements, Mexican Hat           12
             Uranium Mi I I, May  1968.

Table II.    Comparison  of TLD and E500B data.                     16

Table III.   Gross alpha particulate radioactivity  in air,         17
             Mexican Hat Uranium Mi I I, May  1968.

Table IV.    Long-lived  airborne particulate radioactivity,        18
             Mexican Hat Uranium Mill.

Table V.      Atmospheric radon-222, Mexican Hat Uranium Mill,       19
             May  1968.

Table VI.    Particulate radon daughter products in air,            23
             Mexican Hat Uranium Mill.

Table VII.   Long-lived  radioactivity in water,Mexican Hat         24
             Urani urn Mill.

Table VIM.  Tai I  ings anal ys is, Mexi can Hat Uranium Mi I 1.           25
                                iv

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                         LIST OF FIGURES

Figure  I.  Mill site, Mexican Hat, Utah.                         2
Figure  2.  Mill property, A-Z Minerals Corp. Mexican Hat,        4
            Utah.
Figure  3.  Air sampling locations.Mexican Hat Uranium Mill.      5
Figure  4.  Radon sampling locations,Mexican Hat Uranium Mill.    7
Figure  5.  Water sampling locations,Mexican Hat Uranium Mill.    9
Figure  6.  Tailings material sampling locations,Mexican Hat      10
            Uranium Mill.
Figure  7.  External radiation measurements.Mexican Hat           13
            Urani urn MiI I  tai  |jngs pi Ies.
Figure  8.  External radiation measurements.Mexican Hat           14
            Uraniurn Mill.
           	  	     	      *
Figure  9.  Long-lived alpha activity in air, Mexican Hat         20
            Uranium Mill.
Figure 10.  Atmospheric radon-222, Mexican Hat Uranium Mill.      21
Figure II.  Natural uranium  in water, Mexican Hat Uranium Mill.   26

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               ENVIRONMENTAL SURVEY OF URANIUM MILL
                 TAILINGS PILE, MEXICAN HAT, UTAH
I.   PURPOSE
     On December 21, 1967, the Director,  Division of Indian Health,
requested the National  Center for Radiological  Health to conduct a
study of the A-Z Minerals Corporation's tailings pile located at
Mexican Hat, Utah.  It was requested that the study identify any
radiation hazards which might exist and recommend methods for their
control.
    - In response to this request, the tailings  area was surveyed in
May 1968.  The results and conclusions of the survey are presented
herein.

II.  LOCATION AND DESCRIPTION
A.   Location:
     The mill was originally operated by  the Texas-Zinc Minerals
Corporation and transferred to A-Z Minerals Corporation in 1963.
Uranium production was discontinued in February 1965.
     The mill property is located approximately one mile southwest of
the community of Mexican Hat, Utah (Figure 1).   The site is situated
on the Navajo Indian Reservation; the property  being leased to the
company by the Navajo Tribal Council.
     The San Juan River flows from east to west approximately one mile
north of the mill property.  Gypsum Creek (actually a dry wash) is
located approximately one-half mile east  of the tailings pile.  The
surrounding land is unpopulated and at present  is not used for either
farming or grazing.
B.   Description:
     For purposes of description, the mill property is divided into
three main areas:  the tailings area, the mill  area, and the housing

                                 I

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Scale : 1" = 1OOO ft.
                   Figure 1.  Mill  site, Mexican Hat,  Utah.



                                        2

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area (Figure 2).
1.   Tailings Area.  The tailings area covers approximately 35 acres
     and contains an estimated 2.2 x 106 tons of tailings material.*
     The radium content estimated from the average uranium assay of
     mill feed material (assuming radium in equilibrium with uranium)
     is approximately 1000 pCi/g, or 6500 total curies.*
2.   Mill Area.  The mill area includes the mill buildings and former
     stock pile areas.  It is located adjacent to and west of the
     tailings area.
3.   Housing Area.  The housing area is located approximately 0.5 miles
     southwest of the tailings area and consists of approximately 60
     dwellings, a school, and various community buildings.

III.  ENVIRONMENTAL SURVEY
A.  Sampling procedures:
1.   External Radiation Exposure.  External  radiation measurements were
     obtained using portable geiger survey meters.** Gamma (closed
     window) readings were obtained at the surface and at the three-
     foot level.  A grid was established over the area of interest and
     readings obtained at 240-foot intervals.  A total of 212 pairs of
     readings were recorded.
     In addition to the portable instrument readings, thermoluminescent
     dosimeters (TLD's) were placed in triplicate at the three-foot
     level at each of the air sampling stations (see Figure 3).   The
     TLD's respond only to gamma radiation.
2.   Air Sampling.
a.   Long-lived Airborne Particulate Radioactivity:
     Airborne particulate radioactivity was sampled by drawing air through
         * Division of Raw Materials, USAEC,  1967.

        ** Model E-500B, Eberline Instrument  Corp., Santa Fe, New Mexico

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        HOUSING
      r=  AREA
Scale : 1" = 1OOO ft.
   Figure 2.  Mill property,  A-Z Minerals  Corp. , Mexican Hat,  Utah.

                                    4

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                                 -AREA  TAILINGS
Scale : 1" = 1OOO ft.
      Figure 3.  Air sampling locations Mexican Hat Uranium Mill.




                                     5

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     a  0.8u  pore  size  filter.*  A  high volume air sampler was used
     at a  flow  rate  of about  five  cubic feet per minute.  Nine
     sampling stations were established on and about the tailings
     area  (Figure 3).   Continuous  24-hour samples were obtained at
     each  station on each  of  eleven  consecutive days.  Each indi-
     vidual  filter was analyzed for  gross alpha activity.  In addi-
     tion, all  filters from each station were composited for analysis
     of natural uranium, radium-226  and thorium-230.
     Radon Gas:
     Eight locations were  selected for the collection of radon gas
     samples (Figure 4).   The sampling technique consisted of
     pulling filtered  air  through  a  small low-volume pump (10 ml/min)
     into  a  30-liter Mylar bag. r  A  continuous 24-hour sample was
     collected  at each location.   The collected samples were picked
     up by PHS  aircraft and flown  to Las Vegas for  immediate analysis
     for radon-222.
     Short-lived  Particulate  Radon Progeny:
     The short-lived particulate radon daughter products were sampled
     by pulling air  through a glass  fiber filter using a high volume
     air sampler. Each sample was collected for 15 minutes at a flow
     rate of about 10  cfm. Samples  were collected  at the radon
     sampling locations (Figure 4).  The filters were alpha counted
     immediately  in  the field utilizing a specially designed alpha
     scintillation counter.   Activity was calculated using the
     Tsivoglou  technique.2
          *Gelman Acropore Filter,  Gelraan  Instrument  Company,
Ann Arbor, Michigan.

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                                M|LL     TAILINGS
                                  AREA
Scale : 1" = 1OOO ft.
     Figure 4.  Radon sampling locations Mexican Hat Uranium Mill.



                                     7

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d.   Meteorology:
     Wind direction and speed were estimated by visual  observation.   The
     predominant wind direction at the mill  site for the 11-day sampling
     period was from the southwest.   According to A-Z Minerals Corp.
     personnel, this is the predominant wind direction throughout the
     year.  During the first seven days of sampling, the wind was light
     (0-5 mph).  During the last four days,  however, winds estimated  at
     10-20 mph were encountered during the daylight hours.  In general,
     lapse conditions were encountered during daylight hours with light
     inversions at night.
3.   Water Sampling.
     Two springs were located in the vicinity of the tailings area at
     which ground water samples were taken (Figure 5).   The first was
     located about 1000 feet northeast of the tailings area in the
     wash running from the tailings  area (Sta. 1).  The wash was dry
     between the spring and Gypsum Creek.  The second spring was just
     south of the junction of Gypsum Creek and the wash from the tailings
     area (Stations 2 and 3).  Gypsum Creek  was dry upstream from the
     spring.  In addition to the ground water samples,  the drainage
     from the acid blowdown operation at the mill was sampled.  One-
     gallon grab samples were obtained at each location, some stations
     being sampled on several occasions.  The samples were analyzed  for
     radium-226 and natural uranium  activity.
4.   Tailings Material.
     Samples of tailings material were collected at the locations indi-
     cated in Figure 6.  Approximately 400cc of surface material was
     taken from each location.  The  samples  were analyzed for thorium-230,
     radium-226 and natural uranium.

B.   Analytical Procedures:
     All  laboratory analyses were performed  at the Southwestern Radio-
logical Health Laboratory.
1.   Gross alpha and gross beta determinations were performed, after  sample

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                                                                MEXICAN HAT
    MILL
I PROPERTY
                f
           N'
                                                                         R/VER
   Scale : 1" = 1OOO ft.
          Figure  5.  Water sampling locations Mexican Hat Uranium Mill.


                                          9

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       TO
        e
        H

        ft)
       TO


        3
        ft)
        rh
        n>
        0
       TO

        I—1
        O
        n
        ft)
        c-h
        M«
^      O
o      ts
        CO
       cl
       
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     preparation, by counting directly in an end window,gas flow, pro-
     portional counter,
2.   Radon analysis was performed by cryogenic separation and subsequent
     alpha scintillation counting.
3.   Radium-226 was determined after sample preparation by the radon
     emanation technique.
4.   Uranium analysis was accomplished by fluorometric technique.
5.   Thorium-230 analysis was performed by means of solvent extraction
     and subsequent alpha counting.

IV.  RESULTS
A.  External Radiation:
     Table I summarizes the results of the portable instrument survey on
each of the unique areas.  Figures 7 and 8 indicate the location and
magnitude of the individual measurements at the surface level  and at
three feet.
1.   Natural Background.  The natural background radiation was found to
     average 0.03 mR/hr both at the surface and the three-foot level.
2.   Tailings Area.  The radiation exposure at the three-foot level  on
     the tailings area ranged from a minimum of .02 mR/hr on the extremi-
     ties of the pile to a maximum of 3 mR/hr on the pile.  The average
     was 0.5 mR/hr.  No significant difference was noted between the
     surface and three-foot level.
3.   Mill Area.  The average exposure at the three-foot level  within the
     mill area was 0.1 mR/hr with a range of 0.02 mR/hr to 0.5 mR/hr.
     Again, there was no significant difference between readings at  the
     surface and at three feet.
4.   Housing Area.  The average exposure at the three-foot level in  the
     housing area was found to average 0.03 mR/hr.  This exposure repre-
     sents background radiation.
5.   Thermo!uminescent Dosimeters.  A comparison of the results obtained

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            TABLE I
External Radiation Measurements
   Mexican Hat Uranium Mill
           May 1968
Area
Background
Housing Area
Mill Area
Tailings Area
Number of
Measurements
10
74
31
97
mR/hr @ Surface
Ave.
0.03
0.04
0.17
0.5
Range
0.02-0.06
0.01-0.2
0.02-0.5
.01-3.0
mR/hr @ 3 Feet
Ave.
0.03
0.03
0.15
0.5
Range
0.02-0.06
0.01-0.1
0.02-0.5
.02-3.0
               12

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                                                                                              XA/AS!l
All values in mR/hr.                    /
Upper value = Gamma exposure (cD 3 feet
Lower value = Gamma exposure (5) surface
Values in parentheses = Thermoluminescent
dosimeter data.	/	

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                                                                      -.0.2nMII-L     07
                                                                             AREA  0.8
                                                                              (.05)
                                                                              .05
                                                                              .04    0.1
                                            •Q2
                                            .02   -04
                                                                  TRAILER
                                                                04   CAMP
                                                                04
                                      .0.4
                                      .03
                          COMMUNITY
                          HALL
                               i
           (.01)
     •Q4  ' j06
                         0_6    .OJ
                         04    .04
                         .04   .02
                         .04   -01
All values in mR/hr.
Upper value = Gamma exposure @ 3 feet
Lower value = Gamma exposure @ surface
Values in parentheses = Thermoluminescent
dosimeter data.
     Figure 8.   External radiation measurements  Mexican Hat Uranium Mill.


                                           14

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     from the TLD's and the portable instrument measurements are shown
     in Table II.  The results are in good agreement.
B.   Air Sampling:
1.   Long-lived Airborne Particulate Radioactivity.
     The gross alpha radioactivity found on individual  filters is shown
     in Table III.  The background station (Sta. 1)  averaged less than
     1 x 10"5 pd'/l for eleven days of sampling.  Stations 2, 7, 8 and 9
     also averaged less than 1 x 10"^ pCi/1,  indicating background levels
     of activity.  Stations 3 and 4 averaged  slightly  above background
     (Sta. 3 = 2.2 x 10~5 pCi/1; Sta. 4 = 1.5 x 10"5 pCi/1).  Stations 5
     and 6 were significantly above background levels.   Station 5, located
     on the northeast edge of the tailings pile, averaged 10 x 10"^ pCi/1
     with a range of 4.6 x 10~5 pCi/1 to 27 x 10"5 pCi/1  for seven days
     of sampling.  Station 6, located approximately  500 feet northeast
     from the tailings, averaged 19 x 10"^ pCi/1 with  a range of from less
     than 1 x 10~5 pCi/1 to 51 x 10   pCi/1 for eleven days of sampling.
     The average station results are shown in Figure 9.  It is apparent
     that the activity concentrations are higher than  background in the
     vicinity of the tailings pile and that the values downwind from the
     tailings are higher than those upwind.
     Table IV shows the average gross alpha activity along with radium-226,
     thorium-230, and natural uranium activity for each station.  It should
     be noted that stations 3-6 (those indicating positive gross alpha
     results) display radium concentrations averaging  about a factor of
     ten higher than the other stations.  These same stations show signi-
     ficant concentrations of thorium-230, whereas all other stations do not.
     Although the natural uranium concentrations average slightly higher
     for stations 3-6, the increase does not  appear to be significant with
     the exception of Station 3.
2.   Radon Gas.  Table V summarizes the radon-222 activity concentrations
     found at various sampling times and locations.   Figure 10 represents
     the average radon concentrations at each sampling location.
                                \5

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                      TABLE II
          Comparison of TIP and E500B Data
Station
1
2
3
4
5
6
7
8
9
BG 1
BG 2
mR/hr @ 3 Feet
TLD1
.01
.03
.05
.55
.42
.04
.02
.01
.02
.01
.01
E500B2
.06
.05
.05
.50
.40
.06
.03
.02
.03
.02
.03
1)  eleven day exposure period
2)  single survey meter reading
                         16

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                                       TABLE III
                     Gross Alpha Particulate Radioactivity in Air
                               Mexican Hat Uranium Mill
                                       May 1968
Sta
f
1
2
3
4
5
6
7'
8
9
Gross Alpha Activity 10"5 pCi/L
May
27 28 29 30 31 ]
1.2
1.9
2.8
—
27
LT 1
LT 1
LT 1
LT 1
LT 1
LT 1
1.1
LT 1
	
1.5
LT 1
LT 1
LT 1
LT 1
LT 1
1.5
0.9
	
8.4
LT 1
LT 1
LT 1
LT 1
LT 1
1.9
4.1
7.8
24
2.4
LT 1
LT 1
LT 1
LT 1
1.4
1.2
10
3. "6
LT 1
LT 1
LT 1
June Ave.
L 2 3 4 5 6 7
LT 1
LT 1
2.2
LT 1
4.6
2.4
LT 1
LT 1
LT 1
LT 1
1.0
1.5
	
4.8
LT 1
LT 1
LT 1
2.7
5.7
LT 1
27
38
LT 1
LT 1
1.0
LT 1
4.0
1.0
	
51
LT 1
1.2
LT 1
LT 1
4.0
2.0
5.1
25
LT 1
1.1
LT 1
5.0
1.8
6.1
6.6
37
LT 1
1.2
LT 1
LT 1
2.2
1.5
10.0
19.0
LT 1
LT 1
LT 1
LT 1 = Less Than 1 x 10"5 pCi/L (assumed equal  to zero  for averaging)
	 = Sampler failure
                                           17

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                               TABLE IV
             Long-lived Airborne Particulate Radioactivity
                        Mexican Hat Uranium Mill
Sta.
#
1
2
3
4
5
6
7
8
9
Days
Sampled
11
11
11
10
7
11
5
11
11
Gross
Alpha
10"5 pCi/1
LT 1
LT 1
2.2
1.5
10.0
19.0
LT 1
LT 1
LT 1
22*Ra
10"5 pCi/1
0.02
0.02
0.2
0.1
0.5
0.7
0.07
0.02
0.03
230Th
10" 5 pCi/1
ND
ND
0.7
0.3
0.7
1.4
ND
ND
ND
U Nat
10"5 jig/1
0.02
0.1
1.0
0.2
0.3
0.4
0.06
0.1
0.1
LT 1 = less than 1 x 10"5 pCi/1
ND   = not detectable on composited sample
           Minimum detectable activity for 226Ra  =  0.1  pCi/sample
           Minimum detectable activity for 230Th  =  5.0  pCi/sample
           Minimum detectable activity for natural  U  =  0.1  pg/sample

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         TABLE V

 Atmospheric Radon-222
Mexican Hat Uranium Mill
        May 1968
Station
1
1
2
3
3
4
4
5
5A
5B
6
Midpoint of
Sampl i ng
Date
5/27
5/28
5/29
6/6
5/30
6/4
5/31
6/3
6/2
6/1
Hour
2030
2300
2100
0030
2330
2400
2100
2300
2300
1930
Radon-222
pCi/1
0.3
0.4
1.6
0.6
5.7
0.7
8.4
14.0
13.0
7.5
        19

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                                                                LT  1   LT  1
                                                                   1 mile from tailings
    Scale : 1" = 1OOO ft.
All values in 1CT5pCi/l
LT 1:  less than 1XlO-5pCi/|
      Figure 9.  Long-lived alpha activity in air Mexican Hat Uranium Mill.
                                          20

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Scale : 1" = 1OOO ft.
      V
     Figure 10.   Atmospheric radon-222 Mexican Hat Uranium Mill.
                                   21

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     Station 1, a background station, showed a radon concentration of
     0.3 pCi/1.  Station 2, 0.4 pCi/1, can also be considered background
     level.  Those stations on and about the tailings area showed levels
     of radon significantly above background.  Individual  samples ranged
     from a minimum of 0.6 pCi/1 at station 3 to a maximum of 14 pCi/1 at
     Station 5A.
3.   Radon Daughter Products.  Table VI summarizes the results of the radon
     progeny evaluation.  It should be noted that the levels of activity are
     several orders of magnitude lower than the radon concentrations given
     in Table V.  It must be assumed, therefore, that a very low state of
     equilibrium existed between the radon and its progeny during the sur-
     vey period.
C.   Water Sampling:
     Table VII shows the average radium-226 and natural uranium results
     for each sampling location.
1.   Background.  Because there were no suitable ground water sources in
     the immediate area, ground water samples from the Monument Valley
     area (approximately 22 miles distant) are used as background indi-
     cators.
2.   Ground Water.  The uranium levels are significantly above background
     averaging between 1090 ug/1 and 1690 yg/1.
3.   Acid Slowdown Water.  The acid blowdown water showed  a natural
     uranium concentration of 15 pg/1 which is only slightly above back-
     ground.
     Figure 11 shows the average natural uranium concentration for each
     location.
D.   Tailings Sampling:
     Table VIII shows the results of the thorium-230, radium-226, and
natural uranium analysis on tailings material.  The radium content averaged
370 pCi/g.  This average is somewhat below that predicted  from the average
assay of mill feed material (1000 pCi/g).  Thorium-230 averaged 1900 pCi/g
with individual values ranging from a minimum 220 pCi/g to a maximum of
                                22

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                  TABLE VI

Participate Radon Daughter  Products  in Air
         Mexican Hat Uranium Mill
Sta.
#
SB
5B
5A
5
5
4
3
Collection
Date Time
6/2 2000
6/3 1100
6/3 1400
6/3 1900
6/4 1045
6/4 1430
6/5 1400
pCi/1
218
RaA, Po
0.12
0.21
0.01
0
0
0
0.22
21
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                         TABLE VII





           Long-lived Radioactivity in Water



               Mexican Hat Uranium  Mill
Sta.
#
1
2
3
4
BG
Location
Wash (spring)
Gypsum Creek
Gypsum Crk (spring)
Acid Slowdown
Monument Valley
Number
of
Samples
3
2
1
2
5
226
Ra
pCi/1
1.5
0.2
0.2
0.5
0.5
U Natural*
ug/1
1690
1090
1160
15
2
1  pg/1  of U natural  equals 0.7 pCi/1  of alpha  activity
                          24

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      TABLE VIII

   Tailings Analysis
Mexican Hat Uranium Mill
AREA
Tailings # 1



Tailings # 2




AVE
#
1
2
3
4
5
6
7
8
9
10
X"
U
ug/g
63
350
69
27
40
70
73
470
120
180
150
230
Th
pCi/g
2400
3000
3700
3200
2800
220
220
2400
480
1200
1900
226
Ra
pCi/g
340
130
31
27
860
580
390
550
320
470
370
       25

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Scale : 1" = 1OOO ft
      Figure 11.  Natural uranium in water Mexican Hat Uranium Mill.
                                    Z6

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3700 pCi/g.  Natural uranium averaged 150 yg/g (.015%) with individual
values ranging from a minimum of 27 yg/g to a maximum of 470 yg/g.

V.   DISCUSSION OF RESULTS
A.   External Radiation Exposure:
     The code of Federal Regulations, Title 10, Part 20 indicates a
maximum allowable whole body dose to an individual in an unrestricted
area of 0.5 rem in any period of one calendar year.  The regulations
further indicate a maximum allowable dose for continuous exposure to
individuals in an unrestricted area of 2 millirems in any one hour or
100 millirems in seven consecutive days.
     The Radiation Protection Guide (RPG) adopted by the Federal Radiation
Council recommends that:  "The yearly radiation exposure to the whole
body of individuals in the population (exclusive of natural background
and the deliberate exposure of patients by practitioners of the healing
arts) should not exceed 0.5 rem."3  The Council further recommends,
however, that "every reasonable effort should be made to keep exposures
as far below this level as possible."
     To evaluate the potential long-range hazard associated with the
external radiation emitted from the tailings material, the average
yearly whole body exposure for an individual having 24 hour/day resi-
dence on the area is calculated and compared to the recommended RPG of
0.5 rem/yr.  The net gamma radiation (i.e., minus background) at 3 feet
is used for this computation.
1.   Tailings Area.
     The average exposure at the three-foot level on the tailings area
     was found to be 0.5 mR/hr (background was assumed negligible).  The
     whole body average yearly dose for an individual having 24 hr/day
     residence on the tailings area, on the basis of this exposure rate
     is approximately 4.4 rem/yr.  This is nine times the recommended
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     RPG of 0.5 rem/yr.   These  findings  serve  to  preclude  the  release
     of the tailings area for public  use.   Action which  would  permit
     release of the area  would  involve covering the  tailings with
     uncontaminated dirt  to an  extent that  would  diminish  the  external
     radiation to an acceptable level and to stabilize the covering
     against wind erosion.   Otherwise, the  area should be  fenced and
     controlled as a radiation  area.
Z.   Mill Area.
     The average radiation exposure at the  three-foot level around  the
     mill area was 0.15 mR/hr.   Subtracting an average background of
     0.03 mR/hr yields an average net exposure of .12 mR/hr.   The yearly
     average dose to an  individual  having 24 hr/day  residency  in this
     area, on the basis of the  average value of 0.12 mR/hr, is 1 rem/yr.
     This dose is twice  the RPG of 0.5 rem/yr  but represents the highly
     unlikely condition of continuous occupancy.   With reasonable
     occupancy assumptions it would not  be  expected  that a yearly average
     dose in excess of 0.5 rem  would  occur.
3-   Housing Area.
     The radiation exposure at  three  feet in the  housing area  was found
     to consist entirely  of background radiation.
&.   Air Sampling:
1.   Long-lived Airborne  Particulates.
     In order to assess  the potential  long-range  health  hazard associated
     with the inhalation  of airborne  radionuclides,  the  average activity
     concentrations observed for each sampling station are compared  to  the
     recommended radiation concentration guides  (RCG's)  as indicated in
     The Code of Federal  Regulations, Title 10, Part 20.  Because the  RCG's
     are applicable to yearly average concentrations, this comparison
     assumes that the meteorological  conditions  imposed  during the  sampling
     period are representative  of the yearly average conditions.
     The Code of Federal  Regulations, Title 10, Part 20, indicates  a radia-
     tion concentration  guide (RCG) for  unidentified natural radionuclides
     in air of 8 x 10"5  pCi/1 (when protactinium-231 is  assumed absent).
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If gross alpha activity is above this guide, identification of the
specific radionuclides contributing to the total  alpha activity is
necessary in order to evaluate the potential long-range hazard
associated with the inhalation of the airborne particles.
The nuclides in the natural uranium decay chain most significant as
potential health hazards are the alpha emitters.   These nuclides and
their appropriate RCG are shown below:
          Thorium-230 (Sol.)              8 x 10'5 pCi/1
          Radium-226 (Insol.)           200 x 10'5 pCi/1
          Natural Uranium (Insol.)      200 x 10'5 pCi/1
          Lead-210 (Sol.)               400 x 10"5 pCi/1
          Polonium-210 (Insol.)         700 x 10'5 pCi/1
It is apparent from comparison of these values with Table  IV that
none of those stations showing elevated gross alpha concentrations
exceeds the RCG's for individual radionuclides.
The following conclusions can be made:
(1)  The tailings pile is resulting in elevated concentrations of
     radioactivity in air in the downwind direction.  At the present
     time, however, these concentrations cannot be shown to exceed
     the recommended guides for individual isotopes.
(2)  It is impossible to predict whether the condition will worsen
     in the future.  At present, the pile is still quite moist and
     displays a clay-like consistency.  As the pile dries  out, the
     condition could very well worsen.  On this basis two  courses
     of action are possible:
     a.   The tailings area may be stabilized against wind erosion.
          This action would preclude further carriage of tailings
          material into the surrounding environment in the future
          and would eliminate the potential for any long-term
          hazard to anyone inhabiting the area downwind from the
          mill property.
     b.   If the tailings area is not stabilized, periodic monitoring
          will be necessary to insure that the recommended concentra-
          tion guides are not exceeded.
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Radon-222 and Daughter Products.
The Code of Federal Regulations,  Title 10, Part 20, indicates a
radiation concentration guide for radon-222 in air in unrestricted
areas of 3 pCi/1 above natural  background.  The daughters of radon-
222 are assumed to be present to  the extent that they exist in
unfiltered air (this is interpreted as meaning equilibrium con-
ditions).  To evaluate the potential long-range hazard associated
with the inhalation of radon and  its progeny,  the atmospheric
radon concentrations are compared to this guide.
(1)  Tailings Area
     Average radon concentrations in the tailings area ranged
     from a minimum of 3.2 pCi/1  at Station 4  to  a maximum of
     14 pCi/1 at Station 5A.  These values are equal  to or
     greater than the RCG of 3 pCi/1.   It was  found,  however,
     that a very low percent equilibrium existed  between radon
     and radon daughters.  Since  approximately 95% of the dose
     to the lungs due to inhalation of radon and  its  daughters
     is due to the particulate daughters, the  elevated radon
     levels cannot be considered  as representing  violation of
     the RCG.  It should be pointed out however,  that if enclosed
     structures were to be built  on the tailings  material a sub-
     stantial increase in both radon and daughters could be
     expected within the structure, and the RCG may be exceeded.
     Therefore, it is recommended that no enclosed structures
     be built on the tailings material.
(2)  Mill Area
     Station 3 indicated an average radon concentration of 1.1 pCi/1.
     Subtracting natural background gives a net average concentration
     of 0.8 pCi/1.  This is well  below the appropriate RCG.
(3)  Housing Area
     The housing area (Stations 1, 2)  showed essentially background
     levels of radon-222.
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C.   Water Sampling
1.   Ground Water.
     Ground water samples obtained in the vicinity of the tailings area
     showed natural uranium concentrations in excess of 1000 pCi/1.
     These values are significantly above background.  The Code of
     Federal Regulations, Title 10, Part 20, indicates a radiation
     concentration guide for natural uranium of 2 x 10  pCi/1.   It is
     apparent that the concentrations observed are a factor of  ten
     below the recommended guide.
     The RCG for soluble radium-226 is 3 pCi/1.   None of the samples
     collected exceeded this guide.  It must be concluded, therefore,
     that although ground water samples in the vicinity of the  tailings
     are significantly above background, they are still  well below the
     recommended concentration guides.

VI.  SUMMARY AND RECOMMENDATIONS
A.   External Radiation:
1.   External gamma radiation on the tailings area averaged 0.5 mR/hr
     at three feet above the surface.  This calculates to a yearly dose
     of 4.4 rem/yr for continuous  exposure and exceeds by a factor of
     nine the recommended Radiation Protection Guide (RPG) of 0.5 rem/yr
     for continuous whole body exposure to individuals in the general
     population.  These findings serve to preclude the release  of the
     tailings area for public use.  Action which would permit release
     of said area would be to cover the tailings with uncontaminated
     dirt to an extent that would  diminish the external  radiation to
     an acceptable level and to stabilize the covering against  wind
     erosion.  Otherwise, the area should be fenced and controlled as
     a radiation area.
2.   The tailings pile extends approximately 300 ft. to 500 ft. beyond
     the present property line in  the easterly direction.  The  size of
     the pile precludes the possibility of returning this material to
     the property area and therefore this area should be fenced and
     controlled as a radiation area.
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3.   The mill area exhibited external  gamma radiation levels averaging
     0.12 mR/hr above background at three feet above the surface.   This
     calculates to a yearly average dose of 1.0 rem for continuous expo-
     sure which is two times the appropriate RPG of 0.5 rem/yr.  With
     reasonable occupancy assumptions, however, the yearly average
     dose would probably not exceed 0.5 rem.
4.   The housing area displayed background levels of external  radiation.
B.   Airborne Radioactivity:
1.   Airborne transport of tailings material in the northeast  direction
    • from the pile is demonstrated by  higher than background levels of
     radioactivity in air.  None of the stations showing elevated  gross
     alpha concentrations exceeded the RCG's for radium-226, thorium-230,
     or natural uranium, however.  Since it is impossible to predict
     whether the condition will worsen in the future with the  drying out
     of the tailings pile, it is recommended that the area be  stabilized
     against wind erosion.  If the area is not stabilized, periodic
     monitoring will be necessary to insure that the appropriate con-
     centration guides are not exceeded.
2.   The gross alpha activity as well  as the radium-226, thorium-230,
     and natural uranium concentrations in the mill and housing  areas
     were well below the applicable radiation guides.
3.   Radon gas concentrations on and about the tailings area averaged
     from 3.2 pCi/1 to 14 pCi/1.  These levels exceed the RCG  of 3 pCi/1.
     It should be pointed out, however, that this guide is applicable to
     radon-222 and its daughters "as they occur in unfiltered  air".  This
     may be interpreted as meaning radon in equilibrium with its daughter
     products in air.  Since it was demonstrated that equilibrium  did not
     exist between radon and its progeny, at least at the time of
     daughter product sampling, it does not appear that the RCG has been
     exeeded.  Levels of radon-222 in  the mill area and housing area are
     substantially below the recommended guide.
     It should be emphasized, however, that if enclosed structures were
     to be built on the tailings material a substantial increase in radon
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     concentration would occur within the structure and the RCG may
     be exceeded.
C.   Waterborne Radioactivity:
     Ground water samples obtained in the vicinity of the tailings area
     showed natural uranium concentrations in excess of 1000 pCi/1.
     These values represent concentrations substantially above background
     but are well  below the appropriate RCG.
D.   Recommendation:
     On the basis of the data gathered in this survey, it is recommended
     that the mill tailings be properly stabilized against wind erosion.
     This action would preclude further carriage of tailings material
     into the surrounding environment and would minimize the potential
     long-term hazard to anyone inhabiting the area downwind from the
     mill property.  If the tailings area is  not stabilized, periodic
     surveillance will be necessary to insure that significant wind
     carriage does not occur.
     As a result of the external  radiation levels on the tailings area
     itself, this area should not be released for public use in its
     present state.  Action which would permit release of the area
     would be to cover the tailings with uncontaminated dirt to an
     extent that would diminish the external  radiation to an acceptable
     level and to stabilize the covering against wind erosion.
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                            REFERENCES

I.  Sill, Claude, "An Integrating Air Sampler for Determination of
    222Rn," presented at Health Physics Soc.  Mtg., Denver,  1968.
2.  Tsivoglou, E. C., Ayer,  H.  E., and Holaday,  D. A.,  "Occurrence
    of NonequiIibriurn Atmospheric Mixtures  of Radon and i1s  Daughters,"
    Nucleonics,  II,  40,  September, I953.
3.  FRC Report #l, May 13, I960.
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