ENGINEERING EVALUATION/COST ANALYSIS

TRONOX SETTLEMENT N AVAJO AREA URANIUM MINES

SECTION 10 MINE
MCKINLEY COUNTY, NEW MEXICO

Prepared for:

U.S. Environmental Protection Agency, Region 6
1201 Elm Street, Suite 500
Dallas, Texas 75270-2102

EPA Contract No. EP-S5-17-02
Technical Direction Document No. 0001/17-044
Weston Work Order No. 20600.012.001.1044
NRC No. N/A
SEMS No. NMN000605371
FPN N/A
SSID A6PK
EPA OSC Warren Zehner

Prepared by

SOLUTIONS

Weston Solutions, Inc.

2600 Parkway, Suite 280
Frisco, Texas 75034

February 2023


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TABLE OF CONTENTS

EXECUTIVE SUMMARY	ES-I

1.0 INTRODUCTION	1-1

1.1	PURPOSE AND SCOPE	1-2

1.2	SITE DESCRIPTION AND BACKGROUND	1-2

1.2.1	Grants Mining District	1-3

1.2.2	Ambrosia Lake Sub-District	1-5

1.2.3	Site Location	1-13

1.2.4	Operational Status	1-13

1.2.5	Structures, Topography, and Vegetation	1-14

1.2.6	Geology, Hydrogeology, and Soils	1-15

1.2.7	Hydrologic Setting	1-16

1.2.8	Surrounding Land Use and Population	1-16

1.2.9	Historical/Cultural Resources	1-17

1.2.10	Sensitive Ecosystems and Wildlife	1-18

1.2.11	Regional Climate	1-19

1.3	PREVIOUS REMOVAL ACTIONS	1-19

1.4	NATURE AND EXTENT OF SOIL CONTAMINATION	1-19

1.4.1	Previous Investigations	1-20

1.4.2	Current Investigations	1-20

1.5	HUMAN HEALTH AND ECOLOGICAL RISK EVALUATION	1-28

1.5.1	Screening to Identify Contaminants of Potential Concern	1-28

1.5.2	Human Health Risk Assessment	1-28

1.5.3	Ecological Risk Evaluation	1-30

1.5.4	Evaluation of Grazing of Forage by Domesticated Animals and
Wildlife	1-33

2.0 REMOVAL ACTION OBJECTIVES	2-1

2.1	STATUTORY LIMIT	2-1

2.2	REMOVAL ACTION SCOPE	2-2

2.2.1	Action Level	2-2

2.2.2	Principal Threat Waste	2-7

2.3	SURFACE AREA AND VOLUME ESTIMATE OF CONTAMINATED

MEDIA	2-9

2.4	REMOVAL ACTION SCHEDULE	2-9

3.0 REMOVAL ACTION ALTERNATIVES	3-1

3.1 ALTERNATIVES SCREENED FROM CONSIDERATION	3-2

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3.2	APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

(ARARS)	3-2

3.2.1	Terms and Definitions	3-3

3.2.2	Other Considerations and Assumptions	3-5

3.3	ENGINEERING AND LOGISTICAL CONCERNS APPLICABLE TO

MOST ALTERNATIVES	3-6

3.3.1	Plans and Submittals	3-7

3.3.2	Mobilization and Site Setup	3-8

3.3.3	Site Security and Access Control	3-8

3.3.4	Road and Haul Route Improvements	3-9

3.3.5	Road and Haul Route Maintenance	3-9

3.3.6	Air Monitoring and Dust Control	3-10

3.3.7	Stormwater Management, Erosion Control, and Maintenance	3-10

3.3.8	Site Reclamation	3-11

3.4	ALTERNATIVE 1: NO FURTHER ACTION	3-12

3.4.1	Site Work Activities	3-12

3.4.2	Post-Excavation and Site Reclamation Activities	3-12

3.4.3	Site Controls and Security	3-13

3.4.4	Stormwater and Erosion Control	3-13

3.4.5	Operation and Maintenance Activities	3-13

3.5	ALTERNATIVE 2: EXCAVATION AND OFF-SITE DISPOSAL OF

CONTAMINATED SOILS AT A LICENSED LOW-LEVEL
RADIOACTIVE WASTE FACILITY	3-13

3.5.1	Off-Site Rule	3-14

3.5.2	Site Work Activities	3-14

3.5.3	Post-Excavation and Site Reclamation Activities	3-15

3.5.4	Site Controls and Security	3-15

3.5.5	Stormwater and Erosion Control	3-16

3.5.6	Operation and Maintenance Activities	3-16

3.6	ALTERNATIVE 3: EXCAVATION, CONSOLIDATION AND LONG-

TERM MANAGEMENT OF THE RADIOLOGICALLY
CONTAMINATED SOILS/DEBRIS AT A ABOVE-GROUND ON-SITE
REPOSITORY	3-17

3.6.1	Engineering Design	3-17

3.6.2	Site Work Activities	3-18

3.6.3	Post-Excavation and Site Reclamation Activities	3-19

3.6.4	Site Controls and Security	3-19

3.6.5	Stormwater and Erosion Control	3-20

3.6.6	Operation and Maintenance Activities	3-20

3.7	ALTERNATIVE 4: CAPPING OF CONTAMINATED SOIL IN PLACE	3-20

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3.7.1	Engineering Design	3-21

3.7.2	Site Work Activities	3-22

3.7.3	Post-Excavation and Site Reclamation Activities	3-23

3.7.4	Site Controls and Security	3-23

3.7.5	Stormwater and Erosion Control	3-23

3.7.6	Operation and Maintenance Activities	3-23

4.0 ANALYSIS OF ALTERNATIVES	4-1

4.1	ALTERNATIVE ANALYSIS APPROACH	4-1

4.1.1	Effectiveness	4-1

4.1.2	Implementability	4-2

4.1.3	Cost	4-2

4.2	UNAVOIDABLE IMPACTS COMMON TO ALL ALTERNATIVES	4-3

4.3	ALTERNATIVE 1: NO FURTHER ACTION	4-4

4.3.1	Effectiveness	4-4

4.3.2	Implementability	4-5

4.3.3	Cost	4-5

4.4	ALTERNATIVE 2: OFF-SITE DISPOSAL AT A LICENSED LOW-

LEVEL RADIOACTIVE WASTE FACILITY	4-5

4.4.1	Effectiveness	4-5

4.4.2	Implementability	4-7

4.4.3	Cost	4-8

4.5	ALTERNATIVE 3: EXCAVATION, CONSOLIDATION AND LONG-

TERM MANAGEMENT OF THE RADIOLOGICALLY
CONTAMINATED SOILS/DEBRIS AT A ABOVE-GROUND ON-SITE
REPOSITORY	4-8

4.5.1	Effectiveness	4-8

4.5.2	Implementability	4-10

4.5.3	Cost	4-11

4.6	ALTERNATIVE 4: CAPPING OF CONTAMINATED SOIL IN PLACE	4-11

4.6.1	Effectiveness	4-11

4.6.2	Implementability	4-12

4.6.3	Cost	4-12

5.0 COMPARATIVE ANALYSIS OF REMOVAL ACTION

ALTERNATIVES	5-1

5.1	EFFECTIVENESS	5-1

5.2	IMPLEMENTABILITY	5-2

5.3	COST-EFFECTIVENESS	5-3

6.0 RECOMMENDED ALTERNATIVE	6-1

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7.0 REFERENCES	7-1

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LIST OF FIGURES

Figure 1-1

Site Location Map

Figure 1-2

Site Area Map

Figure 1-3

Ambrosia Lake Geologic Cross-section Map

Figure 1-4

Ambrosia Lake Fault Zone Map

Figure 1-5

Typical Underground Uranium Mine Diagram

Figure 1-6

Land Ownership Map

Figure 1-7

Site Layout Map

Figure 1-8

Site Geology Map

Figure 1-9

Site Soils Map

Figure 1-10

Site Surface Drainage Map

Figure 1-11

ASPECT Aerial Gamma Survey Map

Figure 1-12

Gamma Scanning Survey Results Map

Figure 1-13

Estimated Ra-226 Concentration Map

Figure 1-14

Surface Soil Sample Location Map

Figure 1-15

Subsurface Soil Sample Location Map

Figure 1-16

Radon Sample Location Map

Figure 1-17

Agricultural Parameters Sample Location Map

Figure 2-1

Soil Removal Estimate Map

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LIST OF TABLES

Table ES-lRemoval Volume Estimates	ES-4

Table 1-1	Background Reference Area Summary of Field and Laboratory Measurements

Table 1-2	Summary of Surface Soil Sample Radium-226 Results

Table 1-3	Summary of Subsurface Soil Sample Radium-226 Results

Table 1-4	Summary of Surface Soil Sample Metals Results

Table 1-5	Summary of Radon Sample Results

Table 2-1	Removal Volume Estimates	2-9

Table 3-1	Location-Specific ARARs and TBCs for Non-Time Critical Removal Action

Table 3-2	Action-Specific ARARs and TBCs for Non-Time Critical Removal Action

Table 3-3	Off-Site Transportation and Disposal Pricing

Table 4-1	Summary of Analysis of Alternatives

Table 4-2	Estimated Risk of Fatalities and Greenhouse Gas Emissions Due to Off-Site Trucking

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LIST OF APPENDICES

Appendix A	Natural Resources Evaluation Report

Appendix B	Cultural Resources Survey Report

Appendix C	Eberline Analytical Services, Inc. Analytical Data Packages

Appendix D	Background ProUCL Statistical Results

Appendix E	Hall Environmental Analysis Laboratory Analytical Results Data Package

Appendix F	Accustar Analytical Results Data Package

Appendix G	Mine Shaft and Ventilation Hole Video Surveillance Logging Data

Appendix H	Revegetation Plan

Appendix I	Human Health and Ecological Risk Evaluation

Appendix J	PRG Calculator Output, DCGL and Ra-226 Risk Contribution Calculations, and
RESRAD Output

Appendix K	Cost Estimate Details

Appendix L	Long-Term Storage Facility (Repository) Radon Flux Calculations

Appendix M	Long-Term Storage Facility (Repository) Preliminary Design Drawings

Appendix N	Green Alternatives Assessment

Appendix O	TDD No. 0001/17-044

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ABBREVIATIONS AND ACRONYMS

(iR/hr	microroentgens per hour

ALSD	Ambrosia Lake Sub-District

ARARs	applicable or relevant and appropriate requirements

ASPECT	Airborne Spectral Photometric Environmental Collection Technology

ASTM	American Society for Testing and Materials International

AUM	abandoned uranium mine

bgs	below ground surface

Bi-214	Bismuth-214

BLM	Bureau of Land Management (of the U.S. Department of the Interior)

BRA	background reference area

BTV	background threshold value

CERCLA	Comprehensive Environmental Response, Compensation and Liability Act

CFR	Code of Federal Regulations

CC^e	carbon dioxide equivalent

COC	contaminant of concern

COPC	contaminant of potential concern

COPEC	contaminant of potential ecological concern

cpm	counts per minute

CY	cubic yards

DCGL	Derived Concentration Guideline Level

DCGLemc	Derived Concentration Guideline Level - elevated measurement comparison

DCGLw	Derived Concentration Guideline Level - wide area

DOD	Department of Defense

DOE	U.S. Department of Energy

DRS	Documented Release Sampling Report

East GSA	East Geographic Sub-Area

Eco-SSL	ecological soil screening level

EE/CA	Engineering Evaluation/Cost Analysis

NMEMNRD New Mexico Energy, Minerals & Natural Resource Department

EMB	Emergency Management Branch

EPA	United States Environmental Protection Agency

ESL	ecological screening level

ESRI	Environmental Systems Research Institute

GMB	Grants Mineral Belt

GMD	Grants Mining District

GPS	Global Positioning System

GSA	Geographic Sub-Area

HQ	hazard quotient

LANL	Los Alamos National Laboratory

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ABBREVIATIONS AND ACRONYMS (CONTINUED)

Marron

Marron and Associates

MARS SIM

Multi-Agency Radiation Site Survey and Investigation Manual

MCA

Multi-Channel Analyzer

mg/kg

milligram per kilogram

MTL

maximum tolerable limit

NA

not applicable

Nal

sodium iodide

NAPL

nonaqueous phase liquid

NAUM

Navajo Area Uranium Mines

NCP

National Contingency Plan

NMAC

New Mexico Administrative Code

NMED

New Mexico Environment Department

NMEMD

New Mexico Energy and Minerals Department

NMHED

New Mexico Health and Environment Department

NPDES

National Pollutant Discharge Elimination System

NPL

National Priorities List

NPV

net present value

NRC

Nuclear Regulatory Commission

NRCS

United States Department of Agriculture Natural Resource Conservation Service

NTCRA

Non Time-Critical Removal Action

O&M

operation and maintenance

OSHA

Occupational Safety and Health Administration

OSRTI

Office of Superfund Remediation and Technology Innovation

OSWER

Office of Solid Waste and Emergency Response

pCi/g

picocuries per gram

pCi/1

picocuries per liter

pCi/m2

picocuries per square meter

PRB

Prevention and Response Branch

PRG

Preliminary Remediation Goal

PRP

Potential Responsible Party

PUF

polyurethane foam

Ra-226

radium-226

RAML

Rio Algom Mining, LLC

RAO

Removal Action Objective

RCRA

Resource Conservation and Recovery Act

RESRAD

Residual Radiation

RSE

Removal Site Evaluation

RSL

Regional Screening Level

SEMS

Superfund Enterprise Management System

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ABBREVIATIONS AND ACRONYMS (CONTINUED)

SHPO

State Historic Preservation Office

SLO

State Land Office

START-3

Superfund Technical Assessment and Response Team

TAL

Target Analyte Metals

TBC

To-Be-Considered

TCRA

Time-Critical Removal Action

TDD

Technical Direction Document

Tl-206

thallium-206

Tl-207

thallium-207

TO

Task Order

U02

Uraninite

U.S.

United States

USi04

Coffinite

USDA

U.S. Department of Agriculture

USGS

United States Geographic Survey

U-235

Uranium-23 5

U-238

Uranium-23 8

UTL95-95

95% upper tolerance limit with 95% coverage

UMTRCA

Uranium Mill Tailings Radiation Control Act

VSP

Visual Sampling Plan

WESTON®

Weston Solutions, Inc.

WRCC

Western Regional Climate Center

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EXECUTIVE SUMMARY

Weston Solutions, Inc. (WESTON®), the Superfund Technical Assessment and Response Team
(START) Contractor (EPA Team), was originally tasked by the U.S. Environmental Protection
Agency (EPA) Region 6 Prevention and Response Branch (PRB) under EP-W-06-042, Task Order
(TO) Number 0041 (West Geographic Sub-Area [GSA]) to conduct a Removal Site Evaluation
(RSE) and an Engineering Evaluation/Cost Analysis (EE/CA) at the Tronox Settlement Navajo
Area Uranium Mines (NAUM) Section 10 Mine Site (the Site) located in the Ambrosia Lake Sub-
District (ALSD) of the Grants Mining District (GMD), and northwest of San Mateo in McKinley
County, New Mexico. The Site was originally included within the West GSA; however, because
it has a different owner currently than the West GSA Mines, the Site was later awarded a unique
tasking document. The performance period for this task order ended on 22 March 2017. New
Technical Direction Document (TDD) No. 0009/Weston-042-1 7-015 (West Geographic Sub-
Area) was issued under the EPA Region 8 Contract No. EP-S8-13-01 on 23 March 2017 to
continue RSE activities at the Site. The performance period for this TDD ended on 17 August
2017. New TDD No. 0001/17-044 was issued by the EPA Emergency Management Branch (EMB)
under the EPA Region 6 START-4 Contract No. EP-S5-17-02 on 18 August 2017 to continue
START activities specifically for the Section 10 Mine Site. The period of performance for this
TDD is currently scheduled to end on 2 July 2023.

The activities conducted under the TO and TDDs are associated with abandoned uranium mines
(AUMs), including surrounding properties, and are part of an ongoing program to assess and
remediate Tronox -elated AUMs within the GMD, specifically those within the ALSD and outside
of Navajo lands. A Site Location Map is provided as Figure 1-1. A Site Area Map, provided as
Figure 1-2, presents an overview map of the different AUM GSAs in the ALSD and highlights the
Section 10 Mine area of interest. The purpose of this EE/CA is to present the available data
collected relative to the Site, describe the Removal Action Objectives (RAOs), describe the
removal alternatives available to address contamination at the Site to meet the RAOs, and provide
an analysis of the alternatives.

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Background and Site Description

In November 2014, the United States (U.S.) District Court for the Southern District of New York
approved a settlement agreement to resolve fraudulent conveyance claims against Kerr-McGee
Corporation and related subsidiaries of Anadarko Petroleum Corporation. Among other
provisions, the settlement provides EPA funding for the assessment and cleanup of over fifty (54)
Tronox NAUM sites located in EPA Region 6 and EPA Region 9 jurisdictional areas. Twenty-one
of the 22 eligible mines are located within the ALSD; the other mine is located in the adjacent
Smith Lake Sub-District (SLSD). Of these 21 eligible mines within the ALSD, only 11 surface
operational areas are associated with these mines since several of the eligible mines operate
through a geographically central main shaft. All of these mining surface operational areas have
undergone some form of closure actions and removal of surface features. Some of these mines
were operated as "wet mines", where the underground workings were dewatered, and the collected
mine water was discharged to nearby surface drainage features such as creeks and arroyos. Little
environmental data currently exists on the Tronox NAUM Area Mines in general, or specifically,
regarding risks to the public health and/or the environment and/or any threat abatement actions
that may be necessary.

The EPA Region 6 Tronox NAUM Area comprises approximately 100 square miles within the
ALSD in McKinley County, New Mexico. The ALSD is located within the GMD, which is an area
of uranium mineralization occurrence approximately 100 miles long and 25 miles wide,
encompassing portions of McKinley, Cibola, Sandoval, and Bernalillo counties of New Mexico.
The Section 10 Mine Site is located in the ALSD approximately 20 miles north of Grants, Cibola
County, New Mexico, and 9 miles northwest of the intersection of New Mexico State Highways
509 and 605 (Figure 1-2).

The Section 10 Mine Site is composed of a former underground uranium mine that is located in
Section 10, Township 14 North, Range 10 West of the New Mexico Principal Baseline and
Meridian. The Site also includes related surface areas impacted by associated mining operations
from the Mine. The Section 10 Mine does not appear to have been a wet mine. Section 10 Mine
(Kermac Mine No. 10) drilling began in 1955 by Mid Continent and Dunn Bros, following claims
made by Stella Dysart at the ore body's eastern extent at the Dysart #1 Mine. Drilling continued

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until 1956 when Kerr-McGee (Kermac) obtained control of the property in 1956 and installed a
shaft (Holmquist, 1970). The mine went into production in 1957.

Kermac closed the mine in 1959 with plans for lessees Spahr and Allmon to take over operations.
Subsequent operations by the lessees closed again in 1962 before control reverted back to Stella
Dysart. Homestake-Sapin gained control in 1964 and shipped from protore stockpiles. By 1981,
Cobb Nuclear Corporation obtained mining claims over most of the southern half of Section 10,
which included the Section 10 Mine.

The Site is currently undeveloped, though livestock grazing occurs in many sections of the
Ambrosia Lake Valley. There are currently no residences in the former mining area of the Section
10 Mine Site, and it is highly unlikely that the property would be used for residential development
due to the remoteness of the area. Cattle ranching is likely to remain the future use of the site. A
rancher may be exposed to radiological contaminants through incidental ingestion of soil, external
radiation from contaminants, inhalation of fugitive dusts, and consumption of meat.

Section 10 Mine Site circa 1980
Nature and Extent of Contamination

The nature and extent of the contamination was defined through surface gamma scans and
subsurface soil sample collection. Based on the results of the risk assessment, the contaminant of
concern (COC) for the Section 10 Mine Site is radium-226 (Ra-226). Ra-226 is typically selected
as the radionuclide of interest at uranium mine sites for the following reasons: (a) it is found to be
a significant contributor of radiological risk to human health, (b) its decay products give off strong
gamma radiation that is easy and cost-effective to measure, (c) a cleanup standard is provided in
the State of New Mexico's Joint Guidance for the Cleanup and Reclamation of Existing Uranium

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Mining Operations in New Mexico (NMEMNRD et al, March 2016), and (d) Ra-226 is the
radionuclide for which historical cleanup limits have been specified.

The total surface area exceeding the scanning-equivalent action level was established to be
20 acres. The total volume of soil exceeding the action level was determined to be 39,058 cubic
yards (CY), consisting of a surface area of approximately 20 acres at a 1 foot depth and a waste
stockpile volume of approximately 7,291 CY.

Table ES-1
Removal Volume Estimate
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico



Surface Area

Volume

Zone

Square
Feet

Acres

Cubic
Yards

1 ft. Excavation Area

857,700

20

31,767

Waste Pile (Aboveground)

NA

NA

7,291

TOTAL

857,700

20

39,058

Removal Action Objectives

The main objective of this removal action is to mitigate actual or potential risks to human health
and/or the environment posed by excess radiological on-site contamination, and to the extent
feasible, reclaim the entire Site for the projected future land use - livestock grazing. The scope of
the response action will be to address excess radiological contamination in soil greater than the
action level of 6.8 picocuries per gram (pCi/g) for Ra-226, which is inclusive of the Ra-226
background concentration (1.9 pCi/g) and represents an excess target cancer risk of 1.3xl0"4. The
response action is intended to be the final action for the surface and near-surface contaminated
soils/debris at the Site and to contribute to any potential remedial actions that may be contemplated
for the Site through source control.

Potential Removal Action Alternatives

The following removal action alternatives were considered as part of this EE/CA. Each of the
alternatives was evaluated against the criteria of effectiveness, implementability, and cost.

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•	Alternative 1: No Further Action - included to satisfy the requirements of the National
Contingency Plan and to provide a basis for comparison of the remaining alternatives.

•	Alternative 2: Excavation and Off-Site Disposal of Contaminated Soils at a Licensed Low-
Level Radioactive Waste Facility - assumes that contaminated soils with concentrations of
Ra-226 greater than the action level would be excavated and disposed of off-site at a
licensed disposal facility permitted to receive the material. Three potential licensed
facilities that are authorized to accept low-level radioactive waste and/or naturally
occurring low-level radioactive soil with Ra-226 concentrations ranging from 2 pCi/g to
approximately 500 pCi/g were identified within the western United States.

•	Alternative 3: Excavation, Consolidation, and Long-Term Management of the
Radiologically Contaminated Soils/Debris at an Above-Ground, On-Site Repository -
assumes that radiologically contaminated soils/debris with concentrations of Ra-226
greater than the action level would be excavated, consolidated, and managed in perpetuity
at a non-commercial, newly created repository located within the site boundary. The
repository would include an engineered cover of the consolidated contaminated soils.

•	Alternative 4: Capping of Contaminated Soil in Place - assumes that contaminated soils
with concentrations of Ra-226 greater than the action level would be capped in place using
an engineered cover.

Summary of Comparative Analysis

Alternative 1, No Further Action, does not meet removal action objectives or protectiveness
standards and therefore is not effective. Alternative 2, Excavation and Off-Site Disposal of
Contaminated Soils at a Licensed Low-Level Radioactive Waste Facility, provides a high level of
long-term effectiveness; however, it has a medium level of short-term effectiveness since the
material would be transported off-site and hauled for long distances, increasing the risk of exposure
to the public and the environment. Alternative 3, Excavation, Consolidation and Long-Term
Management of the Radiologically Contaminated Soils/Debris at an Above-Ground On-Site
Repository, provides a medium level of long-term effectiveness to reduce the risk to humans and
the environment, while also providing a high level of short-term effectiveness, since none of the
material will need to be transported off-site. Although no permits are required for on-site action,
administrative feasibility for Alternative 3 is low due to the lack of a viable potential responsible
party (PRP) to conduct long-term operations and maintenance (O&M) of the repository.
Alternative 4, Capping of Contaminated Soil in Place, provides similar levels of short-term and
long-term effectiveness and low administrative feasibility as Alternative 3, also lacking a viable
potential responsible party (PRP) to conduct long-term O&M of the capped area.

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Although Alternatives 3 and 4 also share medium cost analysis rating, Alternative 3 is 37% more
cost-effective (i.e., less expensive) than Alternative 4. Alternative 2 is estimated to have a high
capital cost in comparison to Alternatives 3 and 4; therefore, although it is technically feasible,
Alternative 2 has a low-cost analysis rating. The excavation plan in Alternative 3 is straightforward
in nature, the repository design is based on industry standards, and nearby surface soils outside of
the contaminated area are readily available for the evapotranspiration cover; however, the
implementability of Alternative 3 is low due to the aforementioned administrative infeasibility
(lack of a PRP).

The technical implementability of Alternative 4 is considered medium due to the straightforward
nature of the capping plan and the evapotranspiration cover design based on industry standards;
however, the large volume of cap material would require the designation of a sizable off-site
borrow area. The administrative implementability of Alternative 4 would be low due to the
aforementioned administrative infeasibility and that subsurface contamination is not addressed by
the Multi-Agency Radiation Site Survey and Investigation Manual (MARSSIM), thus requiring a
unique, site-specific compliance plan.

Due to the non-effectiveness of Alternative 1 and the low implementability of Alternatives 3 and
4, Alternative 2 is identified as the recommended alternative.

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1.0 INTRODUCTION

Weston Solutions, Inc. (WESTON®), the Superfund Technical Assessment and Response Team
(START) Contractor (EPA Team), was originally tasked by the U.S. Environmental Protection
Agency (EPA) Region 6 Prevention and Response Branch (PRB) under EP-W-06-042, Task Order
(TO) Number 0041 (West Geographic Sub-Area [GSA]) to conduct a Removal Site Evaluation
(RSE) and an Engineering Evaluation/Cost Analysis (EE/CA) at the Tronox Settlement Navajo
Area Uranium Mines (NAUM) Section 10 Mine Site (the Site) located in the Ambrosia Lake Sub-
District (ALSD) of the Grants Mining District (GMD), and northwest of San Mateo in McKinley
County, New Mexico (Figure 1-1). The Site was originally included within the West GSA;
however, because it has a different owner currently than the West GSA Mines, the Site was later
awarded a unique tasking document. The performance period for this task order ended on 22
March 2017. New Technical Direction Document (TDD) No. 0009/Weston-042-1 7-015 (West
Geographic Sub-Area) was issued under the EPA Region 8 Contract No. EP-S8-13-01 on 23
March 2017 to continue RSE activities at the Site. The performance period for this TDD ended on
17 August 2017. New TDD No. 0001/17-044 was issued by the EPA Emergency Management
Branch (EMB) under the EPA Region 6 START-4 Contract No. EP-S5-17-02 on 18 August 2017
to continue START activities specifically for the Section 10 Mine Site. The period of performance
for this TDD is currently scheduled to end on 14 August 2020. The Section 10 Mine-specific TDD
is provided in Appendix O. The Superfund Enterprise Management System (SEMS) Identification
Number assigned to the Site is NMN000605371. This EE/CA will describe and summarize work
performed in support of the RSE and EE/CA field efforts and present alternative removal actions
and their evaluation to be completed as part of a Non Time-Critical Removal Action (NTCRA) at
the Site.

The activities conducted under the TO and TDDs are associated with abandoned uranium mines
(AUMs), including surrounding properties, and are part of an ongoing program to assess and
remediate Tronox-related AUMs within the GMD, specifically those within the ALSD and outside
of Navajo lands. A Site Area Map, provided as Figure 1-2, presents an overview map of the
different AUM GSAs in the ALSD and highlights the Section 10 Mine area of interest.

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1.1	PURPOSE AND SCOPE

The purpose of this EE/CA is to present the available data collected relative to the Site, describe
the Removal Action Objectives (RAOs), describe the removal alternatives available to address
contamination at the Site to meet the RAOs, and provide an analysis of the alternatives. This
EE/CA was conducted following the basic methodology outlined in 40 Code of Federal
Regulations (CFR) §300.415 and further discussed in the EE/CA guidance (EPA, 1993). The
report is compiled in accordance with the guidance and standards established under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and
guidance issued by the EPA, specifically Guidance for Conducting Non Time- Critical Removal
Actions (EPA/540-R-93-057, 1993); and A Guide to Developing and Documenting Cost Estimates
During the Feasibility Study (EPA Office of Solid Waste and Emergency Response [OSWER]
9355.0-75; July 2000). The report is divided into seven sections as described below.

•	Section 1: Introduction - Provides background information, summarizes the findings of
previous investigations and reports, summarizes the nature and extent of contamination,
and presents the results of human health and ecological risk assessments.

•	Section 2: Removal Action Objectives - Presents the RAOs, identifies the surface area and
volumes of contaminated media, and discusses the removal action schedule.

•	Section 3: Removal Action Alternatives - Lists applicable or relevant and appropriate
requirements (ARARs) and identifies and describes alternatives to address the removal
action goals.

•	Section 4: Analysis of Alternatives - Provides an individual analysis of the alternatives
using EPA evaluation criteria.

•	Section 5: Comparative Analysis of Removal Action Alternatives - Comparatively
analyzes the removal action alternatives.

•	Section 6: Recommended Alternative - Based on comparative analysis, recommends one
alternative from the listed removal action alternatives.

•	Section 7: References - Lists the references used in the development of this report.

1.2	SITE DESCRIPTION AND BACKGROUND

The EPA Region 6 Tronox NAUM Area comprises approximately 100 square miles within the
center of the Ambrosia Lake Sub-District (ALSD) of the Grants Mining District (GMD) in

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McKinley County, New Mexico. The following sections provide overviews of the GMD and
ALSD before providing a Site-specific description and background of the Section 10 Mine.

1.2.1 Grants Mining District

New Mexico has the second-largest identified uranium ore reserves of any state in the United
States after Wyoming (McLemore, 2007). Almost all of its uranium is found in the GMD (formerly
and occasionally still referred to by various entities as the Grants Mineral Belt [GMB]), an area
of uranium mineralization occurrence approximately 100 miles long and 25 miles wide
encompassing portions of McKinley, Cibola, Sandoval, and Bernalillo counties in the northwest
part of New Mexico. The GMD includes the Laguna and Marquez geographic sub-districts that
are wholly within EPA Region 6 jurisdiction and the ALSD that has shared EPA Region 6 and 9
jurisdictions. A Site Location Map is provided as Figure 1-1.

The GMD (hereafter to mean only those sub-districts wholly within EPA Region 6 jurisdiction or
the ALSD-shared jurisdiction areas) is within the Navajo and Datil sections of the Colorado
Plateau physiographic province. Characteristic land features include rugged mountains, broad flat
valleys, mesas, cuestas, rock terraces, steep escarpments, canyons, lava flows, volcanic cones,
buttes, and arroyos (EPA, 1975). The Continental Divide extends through the northwest corner of
the GMD. Thus, lying east of the Divide, streams and rivers in the GMD eventually flow into the
Rio Grande, one of the principal rivers of the western United States that runs through the length
of central New Mexico approximately 70 miles east of the center of the GMD. Nearly all of the
streams in the GMD are intermittent and flow only during periods of heavy precipitation (same).

The uranium ores in the GMD are found in the northward dipping limestone and sandstones that
were tilted as a result of the Zuni Uplift, which produced the Zuni Mountains that lie south and
generally parallel to the trend of the mineralized zone (Holmquist, 1970). The majority of the
uranium deposits in the GMD are in sandstone formations (McLemore, 2007). The first large
sandstone uranium deposit to be discovered in the GMD was found by Anaconda Company in the
early 1950's using aerial prospecting on the Laguna Reservation about 32 miles east of Grants,
New Mexico and about 8 miles north of Highway 66. This discovery, the Jackpile deposit,
probably influenced other large companies to investigate the Grants area for important deposits of
uranium (same).

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Upon the commercial discovery of uranium in New Mexico in 1950, the GMD was henceforth the
primary focus of uranium extraction and production activities in New Mexico from the 1950s until
the late 1990s. Several different companies moved into the region in the 1950s, particularly oil
companies. They included Anaconda Company, Phillips Petroleum Company, Rio de Oro
Uranium Mines, Inc., Kermac Nuclear Fuels Corporation (a cooperative of Kerr-McGee Oil
Industries, Anderson Development Corporation, and Pacific Uranium Mines, Inc.), Homestake
Mining Company, Sabre-Pinion Corporation, United Western Minerals Company, J. H. Whitney
and Company, White Weld & Co., San Jacinto Petroleum Corporation, Lisbon Uranium
Corporation, and Superior Oil Company (McLemore, 2007; TIME, 1957). Five uranium mills,
shown on Figure 1-1, operated in the GMD to process the ore into triuranium octoxide (U3O8),
commonly referred to as "yellowcake". Four of the mills were in the ALSD and one was located
in the Laguna Sub-District.

No uranium ore has been actively mined in the GMD since 1998, although Rio Algom continued
to recover uranium dissolved in water from its flooded underground mine workings in Ambrosia
Lake until 2002. The Navajo Nation, whose reservation contains much of the known ore deposits,
declared a moratorium on uranium mining in 2005 (McLemore, 2007).

The GMD contains 97 legacy uranium mines and five former uranium mill and tailing disposal
sites that were active during the Atomic Energy Commission uranium purchase years (1940s-
1970) and beyond until the 1990s. Over 52 million tons of uranium ore were extracted from these
mines, constituting approximately 68% of the total uranium ore mined in the United States (EPA,
2015a). In the GMD alone, over 300 mining permits were issued by the State of New Mexico on
lands consisting of public, tribal, and private property for mine exploration and mining operations.
The extraction of uranium-bearing ore occurred through open pits, from underground workings
that were extensively connected, and solution mining (same).

The State of New Mexico has specifically identified that the 97 legacy uranium mines require
assessment and possible cleanup. The mines had reportable ore production and surface expression
post mining (i.e., waste rock piles, vents/shafts, physical remnants, etc.) (same).

The EPA has identified four (4) categories with respect to entities that should be responsible for
addressing the legacy mines and operational impacts within the GMD.

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•	Mines associated with Jackpile National Priorities List (NPL) Site (Laguna Sub-District).

•	Mines covered by the Tronox settlement (ALSD).

•	Mines with potential responsible parties (PRP).

•	Mines without responsible parties (orphans).

Additionally, the Homestake Mining Mill NPL Site is located within the GMD near Milan, New
Mexico.

The Jackpile-Paguate mines (Figure 1-1) are located in the Laguna Sub-District on the Pueblo of
Laguna. The whole mine area was added to the NPL in December 2013 and will be addressed by
the EPA's Remedial Program. As stated previously, the EPA Region 6 Tronox NAUM Area lies
within ALSD. A description of the ALSD follows immediately below.

The progress of assessment and cleanup efforts of uranium mines, mills, residential areas, and
water supply sources throughout the GMD is tracked by EPA via 5-year plans located on the EPA
website at https://www.epa.gov/grants-mining-district/draft-2015-2020-grants-mining-district-
five-vear-plan.

1.2.2 Ambrosia Lake Sub-District

The ALSD is the largest of the sub-districts within the GMD, comprising approximately 760
square miles and stretching from Interstate Highway 40 to the south, New Mexico state highway
371 from Thoreau to Crownpoint to the west, a line 25 miles north of the Cibola County/ McKinley
County border to the north, and the western portion of the Cibola National Forest and
approximately 16 miles west of the McKinley County/Sandoval County border to the east (Figure
1-2). As referenced above, federal removal jurisdiction is held jointly within the ALSD by EPA
Regions 6 and 9. The western one-third of the ALSD is Navajo Nation (R9) or mixed ownership
and the remainder is private land under EPA Region 6 jurisdiction. The eastern half of the ALSD
lies almost wholly within the San Mateo Creek Watershed Basin.

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Geology and Hydrogeology

The ALSD is located in the southeast corner of the Navajo section of the Colorado Plateau
physiographic province. The geology is characterized by elongated domal uplifts, monoclines, and
broad structural platforms. The majority of the regional structure formed during late Cretaceous to
early the Tertiary period (Hilpert, 1963) and was probably accompanied by east-west directed
tension that produced north- and northwest-trending faults and joints (Santos, 1970). Uranium
deposits within the ALSD occur at several stratigraphic levels within the Westwater Canyon
Member of the Jurassic Morrison Formation.

The following description of the lithology and hydrology of Ambrosia Lake was taken from a 1977
report by the Los Alamos Scientific Laboratory on the geology and hydrology of Ambrosia Lake
(Purtymun et al, 1977). The description follows the order of oldest to youngest formation, i.e.,
rocks of the Permian, Triassic, Jurassic, and Cretaceous periods. Figure 1-3 illustrates the rock
formations of the ALSD. Figure 1-4 illustrates the major fault zones of the ALSD.

Rocks of Permian age are the Glorieta Sandstone and the overlying San Andres Limestone. The
Glorieta Sandstone is about 16 meters thick and the San Andres Limestone is about 34 meters in
thickness.

The rocks of the Triassic period are the Chinle Formation and the overlying Wingate Sandstone.
The lower part of the Chinle Formation is a silty sandstone; the middle part is a hard sandstone;
and the upper part is siltstone and mudstone. The Chinle Formation is about 443 meters thick. The
Wingate Sandstone is a cross-bedded sandstone with a regional thickness of about 18 meters.

Rocks of the Jurassic period overlying the Wingate Sandstone are the San Rafael Group and the
Morrison Formation. The San Rafael Group is composed of four members which in ascending
order, are the Entrada Sandstone, the Todilto Limestone, the Summerville Formation, and the Bluff
Sandstone. The Entrada Sandstone is about 30 to 40 meters thick. The Todilto Limestone thickness
ranges from 9 to 13 meters. Overlying the Todilto Formation is the Summerville Formation, a fine-
grained sandstone with a thickness of approximately 100 meters. The uppermost member of the
San Rafael Group is the Bluff Sandstone, whose thickness ranges from 30 to about 90 meters.

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The Morrison Formation, also of the Jurassic period, is composed of three members which, in
ascending order, are the Recapture Member, the Westwater Canyon Member and uppermost
Brushy Basin Member. The Recapture Member is a siltstone with a thickness from 29 to about 45
meters. The Westwater Canyon Member is a fine- to coarse-grained, poorly sorted sandstone. The
sandstone is cross-bedded and locally contains conglomerate lenses as well as clay chert pebbles
and inclusions of petrified wood fragments. The Westwater Canyon Member, whose thickness
ranges from 44 to about 60 meters, contains extensive deposits of uranium and vanadium ores at
several stratigraphic levels. Most of the uranium ores exist in the form of the minerals coffinite
(USi04) and uraninite (UO2) (Thomson, undated). It also contains trace amounts of molybdenum,
iron, and various other metals (Kerr-McGee, undated) and is also the principal aquifer of the
ALSD. The uppermost Brushy Basin Member is a mudstone with thicknesses from 29 to 52 meters.

Rocks of the Cretaceous period are, in ascending order, the Dakota Sandstone, Mancos Shale, and
Crevasse Canyon Formation. The Dakota Sandstone thickness ranges from 18 to 24 meters and
outcrops along the southwestern edge of Ambrosia Lake. The overlying Mancos Shale forms the
floor of the Ambrosia Lake Valley and, in places, is covered by a thin veneer of alluvium. The
Mancos Shale is a thick lithologic unit composed of calcareous, fissile clay of marine origin.
Interbedded with the shale are three sandstone beds, the Tres Hermanos, each generally less than
9 meters thick. The upper surface of the shale is cut away by erosion, with thicknesses ranging
from 52 to 158 meters. East of the San Mateo Fault (Figure 1-4), the shale is about 310 meters
thick on the downthrown side of the fault. The overlying Crevasse Canyon Formation is composed
of shale, clay stone, siltstone, minor seams of coal, and tan sandstone. The Formation outcrops in
the northeastern part of Ambrosia Lake. Quaternary alluvium occurs along the Arroyo del Puerto
and in low areas and depressions in the valley. The alluvium is derived from the Crevasse Canyon
Formation and the Mancos Shale and is composed of silts, sands, gravels, and a few cobbles and
boulders of sandstone. The alluvium may, in part, be worked by water and, in places, consists of
wind-laid sand. The thickness ranges from a veneer to as much as 30 meters.

Overall, the Ambrosia Lake Valley is underlain by sedimentary rocks to depths greater than 1000
meters. These rocks are part of the structural element known as the Chaco Slope, a part of the
southern extension of the San Juan Basin. The highlands south of the Chaco Slope, the Zuni uplift,
have flexed the sedimentary rocks so that the general regional dip of these units is northward and

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north-eastward across the Chaco Slope into the San Juan Basin. There is little, if any, structure in
the southern part of the Ambrosia Lake Valley except the general dip of the sedimentary beds to
the northeast at 1 to 3 degrees. The older rocks (Dakota Sandstone) outcrop on the southwestern
edge of the area, while the younger rocks (Crevasse Canyon Formation) outcrop to the northeast.
Two closely spaced, north-south trending normal faults in the central part of the area are
downthrown to the east. The largest fault, the San Mateo Fault, occurs along the eastern edge of
the area and is downthrown to the east about 150 meters.

Major drainage through the Ambrosia Lake Valley is the southeastern trending Arroyo del Puerto
that is a tributary of San Mateo Creek. The flow in Arroyo del Puerto is ephemeral but became a
perennial stream during the release of water pumped from the uranium mines in the area. The flow
extends to San Mateo Creek where it is lost to evaporation and infiltration into the underlying
rocks (Purtymun et al, 1977). The gradient on Arroyo del Puerto is low and the arroyo tends to
meander; thus, large areas of marsh grasses, sedges, and cattails occur along the channel.
Evapotranspiration reduces a large percentage of the flow during the summer months. Stream flow
losses into the Mancos Shale are probably quite small; however, losses are greater where the
channel is cut on sandstone units of the Mancos Shale or the Dakota Sandstone near the southern
border of the area. Minor amounts of recharge to these sandstones occur from stream flow into the
arroyo.

The principal aquifers in the GMD are the Glorieta Sandstone and San Andres Limestone of
Permian age, the Westwater Canyon Member of the Morrison Formation of the late Jurassic
period, the Dakota Sandstone of the Cretaceous period and alluvium and basalt of the Quaternary
period (John and West, 1963). The Westwater Canyon Member furnishes most of the water supply
in the ALSD. Contamination of regional private wells with uranium mining-related constituents
above drinking water standards has been documented (EPA, 2015a). Shallow alluvial aquifers are
also contaminated with uranium mining-related constituents (same; NMHED, 1986). Water from
the Westwater Canyon Member was pumped out to access the uranium for many mines in the
ALSD.

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Mining Practices

The following description of mining practices in the ALSD was taken from "An Overview of the
Uranium Industry" (NMEMD, 1979) and from "Uranium Mining and Processing" (Kerr-McGee,
undated). The uranium mines in the ALSD were conventional underground mines. A diagram of
a typical underground uranium mine operated by Kerr-McGee Corporation in the ALSD is
provided as Figure 1-5. Mine operations included vertical mine shafts sunk to the appropriate ore
depth and a station with ancillary drifts, pockets, trenches, and sumps. Shafts were typically around
15 feet in diameter and concrete-lined, with hoisting compartments through skips to bring ore and
waste rock to the surface and for the conveyance of miners and materials. Groundwater flowed to
the shaft and down to a collecting sump at the bottom of the shaft where it was pumped to the
surface.

Aboveground, the main pad area might include main and auxiliary buildings, a shaft-area pad with
a head frame up to 100-feet high, oil and fuel storage, a power facilities area, a concrete batch
plant, an ore storage pad, a materials storage yard, and a powder magazine. The main building
contained the hoist room, warehouse, maintenance shops, and administrative offices.

Mine development included horizontal drifts driven outward from the shaft and beneath the
elevation of the ore zones. The drifts were approximately 9 feet wide by 9 feet high and were
supported by rock bolts, wood and/or steel sets. Haulage drifts generally paralleled the long axes
of the ore bodies. Short drifts, called crosscuts, were driven as normal to the haulage drift as
required to reach the extremities of the ore bodies. As drifts extended further from the shaft,
ventilation holes of 36 to 72 inches in diameter were drilled to maintain air quality, typically
functioning as exhaust while the main shaft functioned as the fresh air intake. The ore bodies were
outlined by longhole drilling, which were probed to determine the location of the ore and to
dewater the ore bodies.

Extraction, "stoping", of an ore body began once development was complete. Generally, there
were three stoping methods employed: open stopes, room and pillar stopes, and square set stopes.
The selection for each ore body depended on the stability of the ground and the size and shape of
the ore body. Once mined, drifts were typically backfilled, sometimes with mill tailings to prevent
collapse.

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Mine water re-circulation, sometimes referred to as in-situ stope leaching or solution mining, was
commonly performed to ALSD mines (NMEMD, 1979). The process is described as follows: In
the early years of mining, when retreat began from a worked-out area, the roof collapsed, making
it difficult to continue ore recovery using traditional techniques. To further increase recovery, mine
owners drilled holes to the top of the collapsed zone and sprayed water through these holes onto
the low-grade shattered ore. Mine water is slightly alkaline, and a small amount of leaching occurs
as the water runs through the shattered zone into collection sumps. The enriched water was then
pumped to ion exchange plants where the uranium was removed from the water. The water was
then returned for further leaching. After a period of time, no further leaching can occur. The
shattered zone was then allowed to "sit" until further oxidation of the ore occurred through natural
processes, usually about two weeks (same).

Mine-related wastes from the uranium mines commonly consist of low-grade ore of insufficient
quality to process economically, overburden (waste rock) that was removed to access high-grade
ore, or residuals from mine dewatering activities. Most of the mines in the ALSD conducted
extensive dewatering to access ore below the water table. Most effluent from dewatering received
little or no treatment before discharge to the ground or surface drainages during the majority of the
mine operational period, causing perennial stream flows in major drainages that were otherwise
ephemeral. Treatment of pre-discharge mine waters to extract uranium (ion exchange plants) and
Ra-226 (settling ponds with bioremediation) was incorporated into most mine operations
beginning in the 1970s. Other environmental impacts may have been caused by erosion and
leaching of mine waste materials, some of which were deposited into arroyos where they remain
today, and by the reported operation of on-site heap-leach and stope-leaching operations.

Additionally, the mine water effluent infiltrated and recharged the shallow alluvium directly or through
impoundment infiltration and overflow. From 30 years of mining operations, approximately 80 billion
gallons of mine water was extracted from the subsurface and discharged to surface drainages, the
majority being discharged into the San Mateo Creek Basin (EPA, 2015a). The effluent discharges may
impact regional bedrock drinking water aquifers and shallow alluvial aquifers. These aquifers are
accessed by scattered private residences and nearby municipal or community water supply systems.
Moreover, extensive dewatering of underground workings during mine operations created a regionally
extensive cone of depression into which oxygenated groundwater currently is flowing. The oxygenated

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groundwater may dissolve and mobilize unmined uranium and associated constituents within the
aquifers (same).

Most of the uranium mine sites in the ALSD have undergone some form of surface reclamation,
although some mines still have physical hazards such as open adits, vent holes, and shafts, as well
as uncontrolled waste rock and ore piles on-site. Some reclamations occurred prior to the New
Mexico Mining Act of 1993 and all occurred prior to the promulgation of uranium mine cleanup
and reclamation guidelines by the state of New Mexico in 2016, which specifies a limit of 5.0
pCi/g Ra-226, averaged over the first 15 centimeters of soil below the surface, averaged over any
area of 100 square meters.

Four uranium mills operated in the ALSD (Figure 1-2). Milling activities occurred at the Phillips
Petroleum Mill from 1958 to 1982, at the Homestake Mill from 1957 to 1990, at the Anaconda-
Bluewater Mill from 1953 to 1982, and at the Rio Algom Mill from 1958 to 2002 (EPA, 2015a).
The Department of Energy (DOE), with Nuclear Regulatory Commission (NRC) oversight, is
responsible for long-term surveillance and maintenance duties at the Phillips Petroleum and
Anaconda-Bluewater Mills. The NRC, in coordination with the EPA and the New Mexico
Environment Department (NMED), currently regulates ongoing remedial activities at the
Homestake Mill Superfund site. The NRC also oversees reclamation in coordination with the
NMED at the Rio Algom Mill (same).

Mine Sites in the ALSD

In November 2014, the United States District Court for the Southern District of New York
approved a settlement agreement to resolve fraudulent conveyance claims against Kerr-McGee
Corporation and related subsidiaries of Anadarko Petroleum Corporation. Settlement proceeds
were distributed in January 2015, and the EPA received funding for the assessment and subsequent
cleanup of over fifty Tronox NAUM sites located in both EPA Region 6 and EPA Region 9
jurisdictional areas.

Twenty-two legacy uranium mine operations are eligible for Litigation Trust funding in the EPA
Region 6 Tronox NAUM. Twenty-one of the 22 eligible mines are located within the ALSD, the
other mine is located in the adjacent Smith Lake Sub-District (SLSD). Of the 21 eligible mines
within the ALSD, only 11 surface operational areas are associated with these mines due to several

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of the eligible mines being operated through a geographically central main shaft. All of these mines
have undergone some form of closure operations and removal of operational surface features.
Some of these mines were operated as "wet mines," where the underground workings were
dewatered, and the collected mine water discharged to nearby surface drainage features such as
creeks and arroyos. Little environmental data currently exists on the Tronox NAUM in general, or
specifically, regarding risks to public health, the environment and/or any threat abatement actions
that may be necessary. EPA Region 6 has been tasked to obtain the data required to evaluate the
risks posed by these legacy mine sites and conduct appropriate risk abatement activities.

The Tronox NAUM Area within the ALSD is divided into two stand-alone mine Sites, the Section
10 and Spencer (U.S. Department of the Interior's Bureau of Land Management [BLM]- led)
Mines, and three geographic sub-areas (GSAs), and the East (Sections 35 and 36 Mines), Central
(mines east of State Highway 509; Sections 17, 19, 30, and 33 Mines), and West (Sections 22, 24,
and 30W Mines) GSAs (Figure 1-2). The Tronox Sections 32 and 33 Mines site is located in the
SLSD (note that although the Site is located technically within the ALSD of the GMD, EPA
considers it more closely aligned with the SLSD and will therefore be considered within the SLSD
for the purposes of this EE/CA report). As more information is gathered about orphan mines and
mines with PRPs, further GSAs may be identified.

Land ownership within the Tronox NAUM Area varies predominantly by geographic section; that
is, the vast majority of the geographic sections have one landowner. The majority of land in each
of the areas referenced above is privately owned, with the East GSA also including lands owned
by the State of New Mexico, the Central GSA also including lands owned by the BLM, and the
BLM and the Spencer Mine also being located on land owned by the BLM. The Sections 32 and
33 Mines also include land owned by the Navajo Nation. Ownership of the Tronox NAUM Area
and surrounding lands is illustrated on Figure 1-6.

In addition to the Tronox sites, other mines sites in the ALSD include the Ann Lee Uranium Mine,
the John Bully Uranium Mine, the Sandstone Uranium Mine, and the Homestake-New Mexico
Partners Uranium Mine (Figure 1-2). The PRP for the Ann Lee, John Bully and the Sandstone
mines is United Nuclear, while Homestake Mining Company is the PRP for its namesake mine.

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The Section 10 Mine is the subject of this EE/CA; activities associated with the East, Central and
West GSAs as well as the Sections 32 and 33 Mines will be reported under separate EE/CAs.

1.2.3	Site Location

The Section 10 Mine Site is located in the ALSD approximately 20 miles north of Grants, Cibola
County, New Mexico, and 9 miles northwest of the intersection of New Mexico State Highways
509 and 605 (Figure 1-2). The Site area is shown on the Ambrosia Lake quadrangle United States
Geological Survey (USGS) Topographical Map. The Site is composed of a former underground
uranium mine that is located in Section 10, Township 14 North, Range 10 West of the New Mexico
Principal Baseline and Meridian. The Site also includes related surface areas impacted by
associated mining operations from the mine. A Site Layout Map is provided as Figure 1-7.

The Site area lies approximately 7,130 to 7,150 feet in elevation above mean sea level. It is located
immediately 1.5 miles east of Pistol Butte and 0.5 miles north of Loma de la Gloria. The Site
occurs within the Semiarid Tablelands ecoregion, which is characterized by dry plains, mesas,
valleys, and canyons formed from sedimentary rocks.

The Site is accessed through an un-named road west of New Mexico State Highway 509. The
road is in generally good condition but can become very muddy and rutted after rain or snow.

The Site is currently undeveloped, though livestock grazing occurs there. There are currently no
residences on the Site, and it is unlikely that the property would be used for residential
development due to the remoteness of the area.

1.2.4	Operational Status

Section 10 Mine (Kermac Mine No. 10) drilling began in 1955 by Mid Continent and Dunn Bros
following claims made by Stella Dysart at the ore body's eastern extent at the Dysart #1 Mine.
Drilling continued until 1956 when Kerr-McGee (Kermac) obtained control of the property in
1956 and installed a shaft (Holmquist, 1970).

The Section 10 Mine was reported by Holmquist to be 510-feet deep (Holmquist, 1970) and by
Anderson to be 520-feet deep (Anderson, 1981). The Site consists of a tri-compartment, vertical
shaft and headframe with an approximately 6-foot high, 36-inch wide vent shaft located 300 feet

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east-northeast of the shaft. The mine went into production in 1957 and produced uranium ore from
a cluster of deposits in the upper sands of the Westwater Canyon Member of the Morrison
Formation (Holmquist, 1970). Although, as noted previously, the Westwater Canyon Member
furnishes most of the water supply in the ALSD, the Section 10 Westwater Canyon Formation is
on the up-dip side on the east side of Ambrosia Lake; therefore, the Section 10 Mine does not
appear to have been a wet mine. Relatedly, no evidence was uncovered regarding the presence of
an ion exchange plant or settling ponds associated with the Site.

Kermac closed the mine in 1959 with plans for lessees Spahr and Allmon to take over operations.
Subsequent operations by the lessees drove an incline below the former bottom mine level and
discovered higher grade ore (.23%) than that discovered by Kermac (0.05%). The mine closed
again in 1962 before control reverted back to Stella Dysart. Homestake-Sapin gained control in
1964 and shipped from protore stockpiles. A total of 130,767 tons of 0.20% ore was produced
(Holmquist, 1970).

By 1981, Cobb Nuclear Corporation obtained mining claims over most of the southern half of
Section 10 which included the Section 10 Mine (Anderson, 1981). Plans were made to reopen the
mine if market conditions became favorable, but operations have not resumed as of the date of this
report. A June 2017 investigation of the Section 10 Mine as part of the RSE determined that the
total shaft has been altered to an approximate 291-foot depth either due to mine shaft collapse,
backfill, or other unknown activities. See section 1.4.2.5 for additional details about the June 2017
investigation.

For the Section 10 Mine, EPA was unable to determine precise locations where mine ore was
staged prior to milling. Ore from the mines was milled at the Rio Algom Uranium Mill (Figure 1-

2).

1.2.5 Structures, Topography, and Vegetation

The Section 10 Mine site has not undergone reclamation (i.e., under the New Mexico Mining Act
of 1993, whose release standard reads, "thepermit area will be reclaimed to a condition that allows
for re-establishment of a self-containing ecosystem appropriate for the life of the surrounding
areas following closure unless conflicting with the approved post-mining land use"). The
buildings and all aboveground structures except the head frame have been removed, but the shaft

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remains open. The open mine shaft is surrounded by a chain-link fence. Other features remaining
at the site include concrete slabs, piles of material presumed to be sub-economic ore (waste pile),
metal debris, two cattle ponds, and a vent hole with a 36-inch diameter steel casing (Figure 1-7).
The vent hole is covered with a steel plate that is not attached to the casing.

The Section 10 Mine Site occupies approximately 70 acres and lies approximately 6,920 to 7,200
feet in elevation above mean sea level. It is located east of Little Haystack Mountain and southwest
of San Mateo Mesa. The site area occurs within the Semiarid Tablelands ecoregion, which is
characterized by dry plains, mesas, valleys, and canyons formed from sedimentary rocks. It
supports arid and semi-arid grasslands, shrub/scrub zones, savannas, and woodlands. A detailed
description of site vegetation is presented in The Natural Resources Evaluation (January 2017)
performed by Marron and Associates (Marron) and is provided as Appendix A. The Natural
Resources Evaluation was conducted during the time that the Section 10 Mine Site was part of the
West GSA; therefore, the Evaluation covers the entirety of the West GSA and is not specific to
just the Site.

As discussed by Marron, the Site is located within primarily Desert Grassland and Great Basin
Desert Scrub vegetation communities. The grassland community most closely resembles the
Plains-Mesa Grassland community in structural components. In total, 104 species representing 34
families of vascular plants were identified on the West GSA Site, representing seven distinct
natural plant communities: Plains Mesa Grassland, Shrubby Grassland, Great Basin Desert Scrub,
Juniper Savannah, Coniferous Woodland, Arroyo Riparian, and Disclimax. Specific to Section 10,
Plains-Mesa Grassland is the largest plant community, supported over 40% absolute vegetation
cover, and was heavily dominated by blue grama (Bouteloua gracilis) and galleta (Pleurapis
jamesii). Great Basin Scrub communities, dominated by rabbitbrush, blue gramma, and galleta,
and the Arroyo Riparian community, consisting of vegetation within waterway channels and
dominated by rabbitbrush and western wheat grass, also occur within Section 10.

1.2.6 Geology, Hydrogeology, and Soils

The geology and hydrology of Section 10 was covered previously in Section 1.2.2 ALSD;
however, there is no surface expression of the Permian or Triassic periods formations in Section

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10 and mining activities were not conducted in these formations. A geologic map of the mine
vicinity is provided as Figure 1-8.

Soils at the study area consist of the following U.S. Department of Agriculture (USDA) Natural
Resources Conservation Service (NRCS 2016) map units listed by highest percent occurrence in
the study area: Sparank-San Mateo-Zia complex, 0-to-3% slopes (soil unit: 230); Marianolake-
Skyvillage complex, l-to-8% slopes (soil unit: 210); Uranium Mined Lands (Soil unit 265); and
the Querencia-Lavodnas association, 2-to-15% slopes. The study area soils are expected to be
comprised of sandy loam and silty clay loam surface textures, according to NRCS mapping. They
are generally well drained, not hydric, or slightly hydric, moderately susceptible to wind and water
erosion, and occur more than 200 centimeters from groundwater depth. For additional details about
Site soils, refer to Appendix A Natural Resources Evaluation Report. A Site Soils Map is provided
as Figure 1-9.

1.2.7	Hydrologic Setting

The Site is within the San Mateo Creek local watershed and in the Rio San Jose 8-digit Hydrologic
Unit Code 13020207, which occurs in the larger Middle Rio Grande drainage basin. Surface water
drainage flow from the Section 10 Mine occurs to the north through sheet flow to Martin Draw
(Figure 1-10). Martin Draw flows generally to the southeast into the Arroyo del Puerto. The
Arroyo del Puerto flows into San Mateo Creek approximately 9 miles south-southeast of the Site.
Martin Draw, the Arroyo del Puerto, and San Mateo Creek are intermittent streams in the vicinity
of the Mines.

1.2.8	Surrounding Land Use and Population

McKinley County, New Mexico has a total land area of approximately 5,455 square miles and a
population of 71,492 (2010 US Census; American Fact Finder, factfinder2.census.gov). The
closest community to the Site is San Mateo (Cibola County), which has a population of 161. The
Census Tracts immediately surrounding the Site (Census Tract 9440 and 9460) have populations
of 2,186 and 5,677 persons, respectively, with the majority of the population occurring on the
Navajo Nation.

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There are currently no residences located on or near the Site. The nearest residences are located in
Section 18 of T14N, R9W, approximately 3 miles east-southeast of the Site, and in Section 34 of
T14N, R10W, approximately 3.7 miles south of the Site.

Many sections of the Ambrosia Lake Valley are used for livestock grazing and cattle were noted
in Section 10. Hunting activities are popular in the area. Although public access to the Site is
moderately restricted through perimeter barbed wire fencing and locked gates, trespass hunting
activities are possible. It is presumed that hunting likely occurs on the Site, both with and without
permission.

1.2.9 Historical/Cultural Resources

In consideration of future corrective actions at the Site, a cultural resources survey was conducted
to meet the requirements of Section 106 of the National Historic Preservation Act. A team of
archaeologists conducted the survey over the Site between 10 October 2016 and 03 November
2016. The Cultural Resources Survey Report is provided as Appendix B. The survey included all
areas that were shown to be contaminated above the action level (discussed in Section 2.2.1), plus
an additional 50-foot buffer zone around the contaminated area.

The Cultural Resource Survey Report has been submitted to the State Historic Preservation Office
(SHPO) and the Trust Archeologist in the State Land Office (SLO) for review. EPA will also
extend an invitation for consultation to the Tribes that have identified an interest to the NM SHPO
in potential consultation on federal undertakings in McKinley County, New Mexico. Any further
actions required by the SHPO, the SLO, or from tribal consultation will be considered during final
alternative selection and included in final alternative design. A Cultural Resources Protection Plan
will be developed prior to the initiation of removal activities and will include protections for
historical/cultural resources documented during the survey, as applicable. The plan will include
mitigation requirements determined by the stakeholders, including the SHPO and Tribes. Removal
activities will be scheduled to provide adequate time to institute the mitigation activities to avoid
any disturbance to the Sites visually identified until clearance is provided to the EPA.

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1.2.10 Sensitive Ecosystems and Wildlife

As mentioned in Section 1.2.3, a natural resource survey was performed to identify protected
species and general wildlife habitat, and general vegetation and vegetative community types for
the Site area (Appendix A). Information gained during the survey was used during the completion
of an Ecological Risk Assessment (Section 1.5.3). Marron conducted the survey within the Site
boundary in September 2016 and October 2016. The Evaluation was conducted during the time
that the Section 10 Mine Site was part of the West GSA; therefore, the Evaluation covers the
entirety of the West GSA and is not specific to just the Site. The Site boundary, as outlined in
Section 2.3, was adjusted to include the extent of contamination based on the action level discussed
in Section 2.2.1.

At least 36 bird species and 11 mammal species, or signs of them, were either observed at the West
GSA site. Five reptiles were observed at the site. No amphibians were observed, but at least two
were expected. No designated or proposed critical habitat occurs within the site.

Overall, birds were not present in abundance, though it is expected that many more species would
be present during the spring migration and breeding season. A possible reason for the low number
of birds was lack of vertical structure, as there is hardly any vegetation present above knee height.
Common bird species included scaled quail, roadrunner, horned larks, vesper sparrow, western
meadowlark, chipping sparrow, Brewer's sparrow, wintering white-crowned sparrow, dark-eyed
junco, loggerhead shrike, golden eagle, northern harrier, western burrowing owl, American kestrel,
and prairie falcon. Red-tailed hawks were not observed but are most likely present on the Site.
The American kestrel, prairie falcon, and northern harrier are likely flyovers, as no suitable nesting
habitat for these species is present on Site.

Several big game and common wildlife species or their signs were observed including elk, mule
deer, mountain lion, and coyote. Neither bobcat, gray fox, nor their signs were observed but are
expected to be present on the Site. Burrowing mammals, such as the banner-tailed kangaroo rat,
Gunnerson's prairie dog, Ord's kangaroo rat, Botta's pocket gopher, cottontail rabbit, and the
black-tailed jackrabbit, or their signs, were observed on Site. Burrowing wildlife would be
affected adversely to varying degrees by the removal of vegetation and a 1-foot layer of soil during
a removal action.

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Six species of reptiles were observed during the Evaluation. Most common were the plateau striped
whiptail and the southwestern lizard. There were no amphibians present during the survey.

An Environmental Protection Plan will be developed prior to the initiation of removal activities
and will identify sensitive ecological habitats and species documented during the survey. Removal
activities may be scheduled to avoid certain critical periods of the year such as nesting or breeding
seasons. The areas of concern will be visually identified to avoid any disturbance until clearance
is provided to the EPA.

1.2.11 Regional Climate

Climate at the Site can be described as semi-arid although the mountainous terrain results in a large
variation of temperature and precipitation. Monthly climate data is available for the period from 1
April 1918 to 29 February 1988 from a meteorological data station (#297918) at San Mateo, New
Mexico. Winter temperatures range from 16 °F to 63 °F, averaging 49 °F during the day. Summer
temperatures range between 31 °F to 83 °F (Western Regional Climate Center [WRCC], 2015),
averaging 75 °F during the day.

There is considerable variation in monthly precipitation totals although most of the precipitation
in the Site area occurs during late summer thunderstorms. Monthly precipitation generally varies
between 0.28 inches (February) and 2.11 inches (August), with an annual average of 8.66 inches
(WRCC, 2015).

1.3	PREVIOUS REMOVAL ACTIONS

No removal actions have previously been performed at the Site. EPA has been unable to find any
record of reclamation activity at the Site pursuant to the Mining Act Reclamation Program under
the New Mexico Mining Act of 1993.

1.4	NATURE AND EXTENT OF SOIL CONTAMINATION

The nature and extent of the contamination was defined through surface gamma scans and surface
and subsurface soil sample collection as described in Sections 1.4.2.2 and 1.4.2.3. Based on the
results of the risk assessment (Section 1.5), the COC for the Section 10 Mine Site is Ra-226.

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1.4.1	Previous Investigations

A Pre-assessment Screen and Determination: Rio Algom Mines and Quivira Mill Site, McKinley
County, New Mexico, was performed by the New Mexico Office of Natural Resources Trustee in
September 2010. This report documents the pathways by which natural resources have been
adversely affected by a release from various Rio Algom Mining LLC (RAML) mines and mills in
McKinley County, including the Section 10 Mine (New Mexico Office of Natural Resources
Trustee, 2010).

In 2011, as part of the EPA San Mateo Creek Basin assessment activities, the EPA Airborne
Spectral Photometric Environmental Collection Technology (ASPECT) platform (airplane)
conducted an aerial gamma screening survey of the ALSD, including the Section 10 Mine Site
(Dynamac, 2011). The ASPECT survey indicated high levels of gamma radiation, ranging to
greater than 45 micro roentgens per hour (|iR/hr) (with a terrestrial background between 5 to 10 |iR/h)
at the Site. Results of the survey indicated that wastes from these mines have migrated off-site and
onto adjacent properties (Figure 1-11).

The EPA Region 6 EMB conducted a Documented Release Sampling Report (DRS) at the Section
10 Mine Site on 26 February 2013 that included collecting surface gamma radiation measurements
in addition to conducting sampling and performing chemical/radiological analyses of surface soil.
The specific sampling objectives for the DRS were to collect data that could be used to document
a potential release of hazardous substances to the environment and that may potentially warrant
further site investigation and/or reclamation. Based on the results of the DRS sampling event, soil
contamination attributable to the Site was documented. (Weston, 2013).

1.4.2	Current Investigations

EPA initiated an RSE of the Site, including the development of a background reference area
(BRA), completion of surface gamma surveys, collection of subsurface soil samples, and
completion of a subsurface geophysical investigation. The RSE determined the nature and extent
of contamination above an action level. The following sections describe the activities included in
each stage of the investigation. As discussed previously in Section 1.2.3, Section 1.2.4, Section
1.2.7, and Section 1.2.8, a natural resource evaluation and a cultural resource survey of the Site
were also performed.

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1.4.2.1 Background Reference Area Study

In order to provide a point of reference by which Site conditions can be compared to "pre-mining"
conditions, a background radiation level was established by the EPA. Site cleanup levels are
typically established as concentrations in excess of background levels that have been characterized
in carefully selected BRAs. Selection criteria for the BRA are provided in Section 4.5 of the Multi-
Agency Radiation Survey and Site Investigation Manual (MARSSIM) and include absence of
contamination, and similarity in physical, chemical, geological, radiological, and biological
characteristics to the contaminated areas being evaluated.

Several areas were evaluated for the Section 10 Mine to meet the MARSSIM guidelines. Gamma
scans were conducted in several locations to identify a potential BRA. Ultimately, an area up-
gradient of the Section 10 Mine with no known impact from mining activities (i.e., haul roads,
stockpiles, etc.) within Section 10 of Township 14 North, Range 10 West was selected
(approximately 2,500 feet southwest of the Section 10 Mine surface expression; see Figure 1-12).
The identified BRA exhibits similar physical, chemical, geological, radiological and biological
characteristics as the Site.

A square area of approximately 0.75 acres was selected within Section 10 to represent the BRA.
One-minute, stationary gamma measurements using a 2-inch by 2-inch sodium iodide (Nal)
detector were collected from 20 evenly spaced points within a rectangular-shaped grid in the BRA.
The starting point for the grid was randomly generated. Soil samples were co-located with the
stationary gamma measurements and submitted to Eberline Services, Inc. in Oak Ridge,
Tennessee, for gamma spectroscopy analysis.

EPA conducted radiation toxicity modeling using two different models that considered
contribution to human health impacts from all of the isotopes in the Uranium-238 (U-238) and
Uranium-235 (U-235) decay chains. Ra-226, a daughter product in the U-238 decay chain, was
determined to be the COC (see Section 2.2.1) for which a background value was calculated.

Statistical analysis of the background data set was performed using ProUCL 5.1 (EPA, 2015b).
The average (mean) concentration for Ra-226 in the 20 samples is 1.52 pCi/g, the median is
1.545 pCi/g (indicating lack of skewness), and the standard deviation is 0.146 pCi/g. The
coefficient of variation was 0.0963, indicating a homogeneous background data set in accordance

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with MARS SIM guidance. A goodness-of-fit test indicated that the data set was normally
distributed as well as gamma and log normally distributed. However, the normal distribution was
selected as the most appropriate model. Dixon's outlier test did not identify any outliers. A
histogram, box plot, and quantile-quantile plot were generated, and visual inspection indicated a
well-behaving data set without outliers that confirmed a normal distribution. Finally, a background
threshold value (BTV) was calculated at a 95% upper tolerance limit with 95% coverage (UTL95-
95), equaling 1.87 pCi/g Ra-226. This BTV represents the upper limit of the background data set
such that 95% of background values are less than 1.87 pCi/g with 95% confidence. The UTL95-
95 was selected as an appropriate and defensible BTV as recommended by EPA's ProUCL Version
5.1, User Guide, Statistical Software for Environmental Applications for Data Sets with and
without Nondetect Observations, EPA/600/R-07/041, October 2015 to reduce decision errors.

The average (mean) of the 20 1-minute gamma measurements is 16,258 cpm, the median is 16,335
cpm (again, indicating lack of skewness), and the standard deviation is 313 cpm. Again, using
ProUCL, a normal distribution was confirmed and a UTL95-95 of 17,009 cpm was calculated as
the BTV. A summary of background laboratory analytical results and field measurements is
provided in Table 1-1. The Eberline Analytical Services, Inc. Analytical Data Package is provided
as Appendix C. The background ProUCL statistical results are provided as Appendix D.

1.4.2.2 Surface Gamma Survey

As part of the RSE, the EPA determined the lateral extent of surface contamination at the Site by
conducting a gamma scanning survey in June 2016 using the following three basic data recording
techniques that all used a 2-inch by 2-inch Nal detector paired with a GPS.

•	Areas with fairly level topography and little vegetative obstructions were surveyed using
an array of five detectors mounted on a utility terrain vehicle, which was driven in transects
across the properties.

•	Areas with some topographical relief and vegetative obstructions were surveyed using a
single detector mounted on a cart that was pushed in transects across the properties.

•	Areas not conducive to using wheeled vehicles were surveyed using a single detector and
backpack-mounted GPS unit carried by site personnel over transects in a walkover survey.

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The distance between transects varied depending on whether the area being scanned was clearly
contaminated, not contaminated, or at the border of contamination and non-contamination based
on initial gamma measurements. Initial transects were approximately 200-feet apart until these
distinctions became apparent. Areas at the borders of contamination and non-contamination
received the most tightly spaced transects, ranging approximately 20-to-30 feet apart.
Non-contaminated and contaminated areas received successively less tightly spaced transects,
respectively. Maximum distances between transects in clearly contaminated areas ranged from
approximately 150 to 200 feet; distances between transects in non-contaminated areas were
approximately 100 feet. The survey was conducted throughout approximately 75% of the section
to verify that there was no spread of contamination in a non-contiguous manner by undocumented
mining activities.

The results of the gamma scanning survey were plotted in counts per minute (cpm) on a map using
color-coded icons to represent the detector measurements (Figure 1-12). Measurements were
displayed in six ranges of values, two of which were relative to the BTV and the action level.
Derivation of the action level in pCi/g and its conversion to cpm is described in detail in Section
2.2.1. The figure reflects areas below the BTV, areas of contamination above the BTV but below
the action level, and areas above the action level. The maximum surface gamma measurement was
575,483 cpm, approximately 34 times the BTV and 24 times the action level.

The results of the gamma scanning survey were then plotted similarly on a second map in pCi/g
using color-coded icons to represent the converted measurements (Figure 1-13). Scan values
greater than the BTV were converted to pCi/g similarly to the conversion of the action level in
pCi/g to cpm as described in Section 2.2.1.

1.4.2.3 Soil Sample Collection

Soil samples were collected and analyzed by gamma spectroscopy to confirm the gamma survey
measurements and to estimate the depth of radiological contamination. Soil samples were also
collected and analyzed for Target Analyte List (TAL) Metals plus uranium to determine if these
constituents posed a threat to human health and the environment.

EPA collected surface soil samples in Section 10 from June 2016 through February 2017 to verify
that radioactive contamination existed in areas of elevated gamma survey measurements. Ten

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surface soil grab samples were collected and analyzed via gamma spectroscopy, including two
samples upgradient of the mine, one sample downgradient of the mine, and seven samples from
the sub-economic ore pile. Sample locations are shown on Figure 1-14.

To determine vertical extent of radiological contamination, subsurface soil grab samples were
collected in November 2016. Sample locations were distributed throughout the surface-
contaminated areas using the Visual Sample Plan (VSP) program (Pacific Northwest National
Laboratory, Version 7.7). The samples were collected at a density of one sample for each 2 acres.
The samples were collected by digging a 1-foot-deep hole and collecting a sample from the bottom
of the hole using a bucket auger. A total of 11 subsurface samples including one duplicate, were
collected for gamma spectroscopy analysis. The sample locations are provided on Figure 1-15.

The soil samples were dried, ground/pulverized as necessary, and sieved, then analyzed in EPA's
field laboratory using gamma spectroscopy with an on-site Multi-Channel Analyzer (MCA) for
Ra-226. The MCA measured the gamma radiation emitted by Bismuth-214 (Bi-214) rather than
Ra-226, since Ra-226 does emit a strong gamma signal. Samples were held in a sealed Marinelli
jar for a minimum of 21 days to ensure that the Bi-214 and Ra-226 were in equilibrium before
being analyzed on the MCA. Seventeen samples were analyzed in the EPA field laboratory and
four were also submitted to Eberline Services, Inc. in Oak Ridge, Tennessee, for gamma
spectroscopy analysis, as verification of the on-site MCA results. The Eberline Analytical
Services, Inc. Analytical Data Package is provided as Appendix C.

Two surface soil grab samples collected upgradient of the mine and one surface soil grab sample
collected downgradient were all below the action level of 6.8 pCi/g Ra-226 (See Section 2.2.1 for
derivation of action level). Seven grab surface soil samples collected from the sub-economic ore
pile were all above the action level. All 10 subsurface soil samples and one field duplicate were
below the Action Level. Surface soil sample results were used in the human health and ecological
risk assessments (Section 1.5) and subsurface soil samples were used to determine an estimated
removal volume after an action level was developed for the Site (see Section 2.2.1).

Additionally, the EPA Team collected eight surface soil samples plus one duplicate for analysis of
Target Analyte List (TAL) Metals plus uranium (chemical toxicity). Samples were submitted to
Hall Environmental Analysis Laboratory in Albuquerque, New Mexico for analysis. The surface

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soil sample locations are shown on Figure 1-14. The metals analytical results were also used in the
human health and ecological risk assessments (Section 1.5). The Hall Laboratory analytical data
package is provided as Appendix E. All eight soil sample results plus one field duplicate for TAL
metals plus uranium were below the New Mexico Environment Department (NMED)
Industrial/Occupational Soil Screening Levels (Cancer Target Risk [TR]=lE-05, Non-Cancer
Total Hazard Quotient [THQ]=1) (NMED, 2019). The soil sample analytical results for gamma
spectroscopy are provided in Tables 1-2 and 1-3. The metals analytical results are provided in
Table 1-4.

1.4.2.4 Radon Monitoring

In order to ensure EPA worker health during RSE activities, the EPA collected seven radon
samples from within and near enclosed spaces (i.e. the mineshaft and a ventilation shaft) to
determine potential hazards to people working near the shafts. From 28 October 2016 through 3
November 2016, EPA collected two short-term (6-day) radon samples from inside of the mine
shaft. Both samples were lowered into the shaft on string. One sample was collected 50 feet below
ground surface (bgs) and one sample was collected 100 feet bgs.

From 29 June 2017 through 5 July of 2017, EPA collected short-term radon samples from
aboveground near the mine and ventilation shafts. One sample was collected on the ground at the
very edge of the mine shaft and two samples were collected from approximately 5 feet and 20 feet
from the mine shaft. At the ventilation shaft, EPA collected one sample from the partially-opened
ventilation shaft and one from 20 feet from the ventilation shaft. Samples were submitted to
Accustar Laboratory in Medway, Massachusetts, for analysis. The radon sample locations are
shown on Figure 1-16.

The two samples collected from inside of the mine shaft at depths of 50 feet and 100 feet were
both significantly above the 4 pCi/1 level recommended for indoor exposure (6,304.9 and 8,170.5
pCi/1, respectively) by EPA. Samples collected from the edge of the mine shaft and the ventilation
shaft were both above 4 pCi/1 (11.1 and 1,247.9 pCi/1, respectively). Samples collected 5 feet and
20 feet from the edge of the mine shaft and from 20 feet from the edge of the ventilation shaft were
all below 4 pCi/1. Results of the radon samples are presented in Table 1-5. The Accustar
Laboratory analytical report is provided in Appendix F.

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1.4.2.5	Mine Shaft Investigation

On 18 July 2017, the EPA Team subcontracted a well-logging company to investigate the Section
10 Mine shaft and the ventilation shaft. The well-loggers lowered a camera into the mine shaft
and reached "fill material" (soil) at 291 feet bgs. No side tunnels were noted at any point. The
mine was reported to be over 500 feet deep (Holmquist, 1970, and Anderson, 1981), which
suggests that either the mine was partially filled intentionally or there was collapse of materials
from the walls of the shaft.

The camera was lowered into the ventilation shaft and reached fill material at 351 feet bgs. The
vent casing appeared to continue into the fill material, suggesting that the vent hole casing
continued even deeper. The mine shaft and vent hole video surveillance logging report is presented
as Appendix G.

1.4.2.6	Reclamation Plan

A post-remedial reclamation plan will be developed for implementation upon completion of
remedial activities. The reclamation plan will be comprised of two parts, natural regrading and
revegetation.

Natural Regrading

Post-remedial natural regrading will seek to return the topography of the site to a pre-disturbed
(pre-mining) natural state. The regrading will provide erosion-resistant slopes and stream channels,
with an aim toward minimizing long-term operation and maintenance costs.

Currently the surface water drainage features on-site consist of sheet flow from the Section 10
Mine northward to Martin Draw (Figure 1-10). Martin Draw flows generally to the southeast into
the Arroyo del Puerto. The Arroyo del Puerto flows into San Mateo Creek approximately 9 miles
south-southeast of the Site. Martin Draw, the Arroyo del Puerto, and San Mateo Creek are
intermittent streams.

Conceptual Revegetation Plan

Based on the results of the site-specific natural resource evaluation (Appendix A) and the
associated soil and vegetation sample analytical results, Marron developed a draft conceptual

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revegetation plan for the Site assuming removal actions would be implemented (Appendix H). A
final revegetation plan will be developed by reviewing and updating the conceptual plan with
actual post-removal conditions before revegetation implementation. The assumed objectives
considered in developing the conceptual revegetation plan were grazing capacity, suitability for
wildlife use, and ecosystem sustainability. The conceptual revegetation plan was developed to
comply with the standards of:

•	NMED and NMEMNRD Joint Guidance for Cleanup and Reclamation of Existing
Uranium Mining Operations in New Mexico, March 2016 (Attachments 1 and 2).

•	New Mexico State Land Office Reclamation Plan for State Mineral Lease Rule 5 Template
(7-14-15).

As described in the plan, the Site was divided into two reclamation units for planting purposes:

•	Unit 1 - Plains Mesa Grassland (Loamy Soils)

•	Unit 2 - Great Basin Scrub/Rabbitbrush (Clay Loam Soils)

Units 1 and 2 would be grassland and scrub communities to provide habitat for keystone species
such as prairie dogs and associated animals such as burrowing owl. They also provide browse and
forage for elk and deer, graze for cattle, cover for a variety of small mammals and reptiles, and
nesting sites for small songbirds. All vegetation provides erosion control. Grasses provide a food
source for mammals and insects. Insects provide a food source for reptiles, mammals, and birds.

Potential enhancements to maximize water availability to vegetation, wildlife, or livestock, as well
as prevent seedbed loss and sedimentation due to sheet flow during large storm events, were
included in the revegetation plan. Post-remedial regrade discussed above may render these
enhancements unnecessary. A final determination will be made to include or exclude these
enhancements based on post-remedial conditions.

The conceptual revegetation plan details the proper times of the year for specific activities to
minimize the disturbance to wildlife and to maximize the potential for plants to become
established. The plan also specifies soil amendments and nutrients to prepare the soil for reseeding,
specific seed mixes to be used in each unit, mulching, and watering schedules.

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1.5 HUMAN HEALTH AND ECOLOGICAL RISK EVALUATION

Risk assessments were performed to evaluate the potential impacts of site-derived contaminants
on human health and the environment in the event that no cleanup action is taken. Results of the
human health and ecological risk assessments were used to determine whether residual levels of
contaminants in site media are protective of human health and the environment and may be left in
their current state, or if a cleanup action should be considered. Calculations and methodology used
in performing the human health and ecological risk assessments are described in Appendix I.

1.5.1	Screening to Identify Contaminants of Potential Concern

Analytical results of soil samples collected during the RSE at the Site served as input data for the
human health and ecological risk assessments (Weston, 2019). These samples were analyzed for
radioisotopes via gamma spectroscopy, and some samples were also analyzed for TAL Metals.
The metals analysis was performed to assess the actual or potential risk from sub-economic or
proto-ore, which was brought to surface during the mining operations but was not sent to the mill
for further processing. The analytical results used in the risk evaluations are summarized in
Appendix I, Tables 1-1 and 1-2. All the metals sampling results were screened against the EPA
(2019a) Regional Screening Levels (RSLs) (https://semspub.epa.gov/work/03/2229055.pdf)) and
the local background concentrations to determine the contaminants of potential concern (COPCs).
Table 1-2 summarizes the metals data screening process, showing contaminants that were
considered, the minimum and maximum concentrations detected, associated RSLs, and
background concentrations. It either identifies each contaminant as a COPC or explains why it was
screened from consideration. Aluminum, cobalt, iron, and manganese exceeded RSLs but did not
exceed background levels. Arsenic, selenium, uranium, and vanadium were identified as non-
radionuclide COPCs. All isotopes of the U-235 and U-238 decay chains were carried through a
risk assessment to determine if they should be identified as COCs to be addressed in a cleanup
action.

1.5.2	Human Health Risk Assessment

Cancer is the major effect of concern from radionuclides. The potential excess lifetime cancer risk
on human receptors from exposure to radium in soil was assessed for the Section 10 Mine Site.
Radionuclides in the soil may be absorbed by plants and consumed by livestock and humans.

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Persons working at the Site may be exposed to contaminated dust by inhalation of particulate
matter. Whole body (external) radiation may be experienced by people on or near the Site itself.

The Site is currently undeveloped, though livestock grazing is common in the area. There are
currently no residences in the former mining area of the Section 10 Mine Site, and it is highly
unlikely that the property would be used for residential development due to the remoteness of the
area. Cattle ranching is considered to remain the likely future use of the Site. A rancher may be
exposed to radiological contaminants through incidental ingestion of soil, external radiation from
contaminants, inhalation of fugitive dusts, and consumption of meat, and to non-radiological
contaminants through incidental ingestion of soil, dermal absorption of soil contaminants,
inhalation of fugitive dusts, and consumption of meat.

1.5.2.1 Human Health Risk Assessment Assumptions

The current and future use of the Site is cattle ranching. Risk estimates based on a ranching land-
use scenario were calculated for isotopes in the U-235 and U-238 decay chains (calculated from
measured Ra-226 concentrations in soil). Again, the ranching land-use scenario considers routes
of exposure from radioisotopes to be soil incidental ingestion, external radiation from
contaminants in soil, inhalation of fugitive dust, and consumption of site-grown beef. Note that a
radon inhalation pathway for outdoor radon is not addressed (as opposed to indoor radon, which
is) in EPA's guidance on conducting radiological risk assessments at CERCLA sites (EPA, 2014).
An EPA review of radon data collected at uranium mine and mill sites in the vicinity of the Site
verified that clean-air dilution of radon emissions from those sites rapidly reduces the airborne
concentrations to inconsequential levels (less than the EPA recommended limit for indoor
concentrations of 4 pCi/1) (RAML, 2016).

The risk characterization considered all isotopes of the U-235 and U-238 decay chains defined by
the EPA Preliminary Remediation Goal (PRG) Calculator for Radionuclides (EPA, 2019b). The
risk assessment identified Ra-226 as the most significant radiological human health COPC.
Radium-226 is typically selected as the radionuclide of interest at uranium mine sites for the
following reasons: (a) it is found to be a significant contributor of radiological risk to human health,

(b)	its decay products give off strong gamma radiation that is easy and cost-effective to measure,

(c)	a cleanup standard is provided in the State of New Mexico's Joint Guidance for the Cleanup

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and Reclamation of Existing Uranium Mining Operations in New Mexico (NMEMNRD et al,
March 2016), and (d) Ra-226 is the radionuclide for which historical cleanup limits have been
specified.

The risk characterization also considered cancer risk estimates and non-cancer hazard quotients
(HQs) for non-radionuclide COPCs. Additional human health risk assumptions and details about
the risk assessment process are presented in Appendix I.

1.5.2.2 Human Health Risk Estimates

The PRG Calculator was used to calculate risk estimates for a rancher potentially exposed to
radionuclides in soil, applying maximum and average (mean) Ra-226 concentrations to assess the
range of potential risk. EPA manages risk to achieve 10"6 to 10"4 overall excess cancer risks. As
shown in Table 1-1 (Appendix I), the current total cancer risk for isotopes of the U-235 and U-238
decay chains for the Section 10 Mine Site area exceeds the 10"4 excess cancer risk level. These
results indicate the need for a response action to control releases and prevent radionuclide
exposure. Note that these risk estimates also include contribution of background levels as
calculated from the Ra-226 BTV of 1.9 pCi/g (Appendix I, Table 1-1).

The RSL Calculator was used to develop the non-radionuclide risk estimates for the outdoor
ranching activities (Appendix I, Table 1-3). There is potential for noncancer health effects from
exposure to uranium. Additionally, arsenic yielded a potential cancer risk of lxlO"5. The elevated
non-radionuclide concentrations in soil were located in close proximity to the elevated
radionuclides. It is anticipated that site actions to address radionuclide exposure by human
receptors will be protective for exposure of human receptors to both radionuclides and non-
radionuclide chemicals.

1.5.3 Ecological Risk Evaluation

The Section 10 Mine Site is located in a remote area with the revegetated, previously disturbed
mine area potentially providing habitat for ecological receptors. Wildlife inhabiting the Site may
directly ingest radionuclides and chemicals, which may then be transported to organs or other sites
within the wildlife receptors. Radionuclides and chemicals in the soil may be absorbed by plants
consumed by wildlife. Radionuclides such as uranium and daughter progeny including radium may

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be inhaled on dust particles, creating alpha-particle-emitting sources in the lungs of wildlife
receptors. A screening level ecological risk assessment (i.e., Steps 1 and 2 of the EPA's 8-step
ecological risk assessment process [EPA, 1997a]) was performed to assess potential risk to
ecological receptors from both radionuclide and non-radionuclide chemical contaminants. The
results of the screening level ecological risk characterization are included in Appendix I, Table I-
4 (radionuclides) and Table 1-5 (metals). A refinement of conservative screening level assumptions
(i.e., Step 3a of the EPA's 8-step ecological risk assessment process [EPA, 2001]) was also
performed to consider how the risk estimates would change if more realistic assumptions were
used. The results of the refined ecological risk characterization are included in Appendix I, Table
1-6. The process and conclusions are described below.

1.5.3.1 Ecological Risk-Based Screening Values

Literature-based ecological screening benchmark values for direct contact and food-chain
evaluations are used to characterize potential ecological effects. The following sources were used
to identify proposed ecological screening benchmark values for radionuclides and non-
radionuclide chemicals:

•	EPA Ecological Soil Screening Levels (Eco-SSLs) (http://www.epa.gov/ecotox/ecossn

•	Los Alamos National Laboratory (LANL) ECORISK database, Release 4.1 (LANL, 2017).

The Eco-SSLs include values for plant, soil invertebrate, bird, and mammal exposure to metals
through direct contact and the food chain. The Eco-SSLs are based on no-effect toxicity values
to (1) ensure risks are not underestimated and (2) provide a defensible conclusion that negligible
ecological risk exists, or that certain contaminants and exposure pathways can be eliminated from
consideration (EPA, 1997).

The LANL ECORISK database includes ecological screening levels (ESLs) for avian, mammalian,
earthworm, and plant exposure models for radionuclides and non-radionuclide chemicals in soil.
The LANL ECORISK database provides both no-effect and low-effect ESLs. The no-effect ESL
is protective of wildlife populations and sensitive individuals because it represents an exposure
that is not associated with adverse impacts of low-level, long-term chemical effects (i.e., adverse
effects on ability of individuals to develop into viable organisms, search for mates, breed
successfully, and produce live and equally viable offspring). The low-effect ESL applies a lowest-

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observed-adverse-effect-level-based toxicity reference value that is the lowest chronic effect level
and is generally considered to be protective of wildlife populations (LANL, 2017).

1.5.3.2 Ecological Risk Estimates

Screening level risk characterization was performed using the hazard quotient (HQ) method to
compare maximum soil concentrations to Eco-SSLs and no-effect ESLs. An HQ of less than one
indicates that the concentration is unlikely to cause adverse ecological effects. An HQ greater than
one indicates that the potential for ecological risk is present and therefore the risk assessment
process should continue (EPA, 2005). The screening process considered the isotopes of the U-235
and U-238 decay chains, though ESLs were not available for all isotopes. The screening-level
ecological risk assessment indicates potential for risk to ecological receptors from Ra-226, Th-
230, aluminum, arsenic, barium, lead, mercury, selenium, uranium, and vanadium (Table 1-4 for
radionuclides and Table 1-5 for metals, Appendix I). Concentrations of aluminum, barium, and
lead were below background levels (Table 1-4, Appendix I); therefore, these three metals were not
considered to be contaminants of potential ecological concern (COPEC).

A screening-level ecological risk assessment uses conservative screening-level assumptions such
as 100% site use, 100% bioavailability, 100% diet consisting of the most contaminated dietary
media, and no-effect toxicity data to evaluate risk to populations of upper level organisms. Under
more realistic site use conditions, the potential risk to individual organisms would be reduced. The
representative average soil concentration and low-effect ecological screening values were used to
refine these risk estimates. The refined ecological risk assessment indicates potential for risk to
ecological receptors from exposure to Ra-226 (soil invertebrates only), selenium, and vanadium
(Appendix I, Table 1-6).

Locations where elevated levels of selenium and vanadium were measured are co-located with
locations of elevated Ra-226. ESLs for radionuclides are higher (less stringent) than the proposed
action level for protection of human health. Thus, it is anticipated that site actions to address
radionuclide exposure by human receptors will be protective for exposure of ecological receptors
to both radionuclides and non-radionuclide chemicals.

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1.5.4 Evaluation of Grazing of Forage by Domesticated Animals and Wildlife

EPA collected 22 vegetative metals uptake samples within the entire West GSA in order to
determine the current vegetative nutrient values and uptake of potential hazardous constituents
available to grazing animals (domesticated animals and wildlife). Two of the native plant
vegetation samples (P-ll and P-12) were collected from the Section 10 Mine. Tissue samples
were analyzed for nutrients (iron, zinc, copper, and manganese) and for toxicity metals
(molybdenum, uranium, vanadium, and selenium).

The results of the evaluation of the vegetative metals uptake samples are included in Table 1-7 and
sample locations are illustrated on Figure 1-17. Tissue concentrations were compared to maximum
tolerable limits (MTLs) developed by the National Research Council's Committee on Minerals
and Toxic Substances in Diets and Water for Animals (National Research Council, 2005). The
MTL is defined as "the dietary level that, when fed for a defined period of time, will not impair
animal health or performance." Tissue concentrations are also compared to concentrations of trace
elements in mature leaf tissue that are considered sufficient or normal and excessive or toxic
(Kabata-Pendias and Pendias, 1992). As shown in Table 1-7, nutrient concentrations are less than
MTLs for animals and within or less than sufficient/normal concentrations for plants, while the
P12 tissue sample for the toxic metal selenium exceeds thresholds for animals and plants. An
elevated selenium concentration (81 milligram per kilogram [mg/kg]) was measured in soil
collected from an area approximately northwest of the Kermac Mine where the P12 tissue sample
was collected. While selenium is a common micronutrient supplement for cattle and sheep, it can
be toxic at elevated concentrations. Native selenium has been found in the sandstone formations
in the GMB area (Brookins, 1982) and as an impurity, it may have been a waste metal in the
uranium mine wastes.

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2.0	REMOVAL ACTION OBJECTIVES

The first step in developing removal alternatives is to establish RAOs. These objectives are
typically based on anticipated land use, ARARs, and the findings of the human health and
ecological risk assessments. General response actions describing measures that will satisfy the
RAOs are then developed. This includes estimating the areas or volumes to which the response
actions may be applied.

The main objective of this removal action is to mitigate the actual or potential risks to human
health and or the environment posed by the excess radiological on-site contamination, and to the
extent feasible, reclaim the entire Site for the expected future land use - livestock grazing.
Removal action alternatives will address mine wastes and surface soils/debris that were
contaminated by mine wastes as part of mine operations. The risk posed by potential contaminant
migration to groundwater will be addressed by the EPA Region 6 Remedial section as part of a
San Mateo Creek Basin groundwater investigation; however, proposed actions are consistent with
and will contribute to any contemplated future remedial actions regarding groundwater through
source control by greatly reducing or eliminating the potential for contaminants to migrate from
the surface to groundwater. Removal action alternatives also do not address any potential
contamination from mill tailings directly, though indirect address may occur.

As stated in Section 1.5.2, there are currently no residences in the Section 10 Mine area of ALSD.
Due to the remoteness of the area, it is unlikely that the property will be used for residential
development after the radioactive contamination is removed from the soil. Many sections of the
Ambrosia Lake Valley are used for livestock grazing, although some sections are not currently
grazed due to the current radioactive contamination in the surface soil. Consequently, it is more
likely that the property will continue to be used for grazing than converted to future residential
use.

2.1	STATUTORY LIMIT

Pursuant to Section 104(c)(1), CERCLA places statutory limits of 2 million dollars and 12 months
on Fund-financed removal actions. The statutory limits do not apply to this action since the
selected action will be funded by proceeds of settlement from an enforcement action and not by
the Fund.

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2.2 REMOVAL ACTION SCOPE

The scope of the response action will be to address excess radiological contamination in surface
and subsurface soils/debris and is intended to be the final action for the soils at the Site. Options
to be analyzed include response actions that would allow unrestricted/uncontrolled grazing use
and associated ranching activities. Characterization of the Site identified the primary
environmental concern to be radiological contamination.

2.2.1 Action Level

In June 2014, EPA issued OSWER 9285.6-20, Radiation Risk Assessment at CERCLA Sites:
Q&A (EPA, 2014). According to this guidance, risks from radionuclide exposures at CERCLA
sites should be estimated in a manner analogous to that used for chemical contaminants. The
estimates of intake values for parameters associated with site-specific routes of exposure estimated
for the land use should be coupled with the appropriate slope factors for each radionuclide and
exposure pathway. The guidance further recommends the use of EPA's on-line PRG Calculator
for this assessment. When calculating radiological threat abatement levels, the total incremental
lifetime cancer risk attributed to radiation exposure is estimated as the sum of the risks from all
radionuclides in all exposure pathways. Accordingly, the EPA Team used the PRG Calculator and
coordinated with the national radiation expert in EPA's Office of Superfund Remediation and
Technology Innovation (OSRTI) to calculate a site-specific soil Derived Concentration Guideline
Level (DCGL).

The DCGL is a term referenced in MARSSIM, a document prepared collaboratively by four
Federal agencies having authority and control over radioactive materials: EPA, Nuclear
Regulatory Commission (NRC), Department of Energy (DOE), and Department of Defense
(DOD). The MARSSIM, published in 2000, provides a nationally consistent consensus approach
to conducting radiation surveys and investigations at potentially contaminated sites. In addition to
planning, conducting, and assessing radiological surveys of surface soils and building surfaces, the
document provides a decision-making process to determine if site conditions are in compliance
with dose-based or risk-based regulatory criteria. As defined by MARSSIM, the DCGL is a
radionuclide-specific soil concentration determined through pathway modeling that would result
in a risk equal to the release criterion above background. EPA used a cancer morbidity risk of
lxlO"4 as the release criterion above, or exclusive of, background.

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Four exposure pathways were considered to develop the DCGL: (1) incidental ingestion of soil;
(2) inhalation of soil particulates; (3) direct, external exposure to ionizing gamma radiation in soil;
and (4) meat (ranched beef) consumption. These four exposure pathways were considered to be
the only pathways applicable for the Site, taking into account its potential future land use of cattle
grazing and associated ranching activities. Note that a radon inhalation pathway for outdoor radon
is not addressed (as opposed to indoor radon, which is) in EPA's guidance on conducting
radiological risk assessments at CERCLA sites (EPA, 2014). An open mine shaft and an air-
ventilation vent hole do remain at the Site; however, any remedial/removal action plan
contemplated at the site by EPA will include closure of the open shaft and vent hole. Radon
samples were collected at the site for worker safety purposes and are reported in report section
1.4.2.4.

A combination of three land-use scenario templates in the PRG Calculator were used to develop
the DCGL: the "Composite Worker", to model Outdoor ranching activities; the "Indoor Worker",
to model ranching activities inside a Truck; and "Farmer", to model the consumption of site-raised
beef. Two cattle ranchers who operate on lands near the Site were interviewed to determine a
reasonable maximum amount of time a cattle rancher might spend on this activity. Consequently,
EPA used a value of 400 hours per year (1.6 hours per day [interview] for 250 days per year [PRG
Calculator default value for Composite and Indoor Worker]) for annual exposure frequency. EPA
used a value of 25 years for lifetime exposure duration, which is the PRG Calculator default value
for a Composite and Indoor Worker. Of the 1.6 hours per day spent on ranching activities, 50%
(0.8 hours) were determined to be spent outdoors and the remaining 0.8 hours were determined to
be spent inside a truck. This determination was made from Table 16-24 of the 2011 Exposure
Factors Handbook (Time Spent in Truck/day, Western Census Region, 95th percentile, revealing
a figure of approximately 50% of an 8-hour day) (EPA, 2011). A truck was estimated to provide
a gamma shielding factor of 0.7 (Appendix I, Attachment 2). EPA used PRG Calculator default
values representing a Composite Worker for soil ingestion and inhalation rates. PRG Calculator
default values represent reasonable maximum exposure to broad-based populations, typically 90
to 95 percentile values, which are well above the mean.

EPA used PRG Calculator default values for beef consumption (165.3 grams per day) for 350 days
per year. Cattle were considered to graze on-site % of the time annually, based on research citing

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that rangeland experts suggest only 25-to-50% of arid rangeland in fair to good condition should
be consumed or used by livestock in order to leave sufficient vegetation for regeneration and
wildlife use (Hurd et al, 2007). EPA considered that a rancher would consume 48% of beef from
on-site animals, based on the 50th percentile value for "percent of home-raised meat consumed by
Western households who farm" presented in Table 13-19 of EPA's 2011 Exposure Factors
Handbook (EPA, 2011). EPA used PRG Calculator Beef default values for fodder and soil intake
rates. The PRG Calculator-produced echo of input values is provided in Appendix J.

The radiological contaminants of concern include the entire U-238 decay chain up to, and
including, thallium-206 (Tl-206), of which Ra-226 is a member, and the entire U-235 decay chain
up to, and including, thallium-207 (Tl-207). It is assumed the U-238 and U-235 decay chains exist
in secular equilibrium (due to lack of ore processing at the site; see Section 1.2.4) and that the U-
235 concentration is 2.2% of the total uranium (U-238, U-235, and U-234) concentration (Argonne
National Laboratory, 2007). The PRG Calculator-produced output is provided in Appendix J.

The action level established for the Site for a ranching land-use scenario is 6.8 pCi/g for Ra-226,
reflecting a PRG Calculator-derived DCGL of 4.9 pCi/g above the Ra-226 BTV of 1.9 pCi/g. The
action-level calculations are presented in Appendix J. Although the cumulative DCGL of 4.9 pCi/g
represents the concentration of each radioisotope in the U-238 decay chain which together
represent a cancer morbidity risk of lin 10,000 persons (commonly referred to as a lxlO"4 risk),
the action level is established for Ra-226 because: (a) it was found to be a significant contributor
of radiological risk to human health (44% [Ra-226 plus short-lived daughter progeny through
polonium-214] (see Appendix J); (b) the U-238 decay chain is in equilibrium, with analysis of Ra-
226 (or specifically its short-lived daughter radioisotope Bi-214cost-effective due to its readily
identifiable gamma ray energy signature via gamma spectroscopy, (c) a cleanup standard is
provided in the State of New Mexico's Joint Guidance for the Cleanup and Reclamation of
Existing Uranium Mining Operations in New Mexico (NMEMNRD et al, March 2016), and (d)
Ra-226 is the radionuclide for which historical cleanup limits have been specified. Note that when
addressing contamination associated with Ra-226, contamination associated with the full U-238
and U-235 decay chains will also be addressed, as they are co-located with Ra-226.

An action level of 6.8 pCi/g represents a cancer risk of 1.4xl0"4, inclusive of background
conditions. This risk-based action level is proposed for the following reasons:

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•	It is within the risk range (10"6 to 10"4 overall excess cancer risks) cited in the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR 300.430(e) (2)(I)).
More specifically, it is less than the risk, 2xl0"4, that EPA has a history of accepting for
radionuclides at uranium mining-waste sites as protective, per discussion with OSRTI.

•	It is distinguishable from background and therefore measurable in the field.

•	It is above the analytical detection limit.

•	It meets the standard (5.0 pCi/g Ra-226 above background, averaged over the first 15
centimeters of soil below the surface, averaged over any area of 100 square meters) set
forth in the State of New Mexico's Joint Guidance for the Cleanup and Reclamation of
Existing Uranium Mining Operations in New Mexico (NMEMNRD, et al., March 2016).

Under a ranching land-use scenario and at the low end of the range within which EPA manages
risk (lxlO"6), a PRG Calculator-derived DCGL for Ra-226 equals 0.05 pCi/g. This concentration
is below the analytical detection limit of 0.1 pCi/g for Ra-226.

As surface soil contamination was measured during the RSE in part via gamma scanning, a
scanning-equivalent DCGL in cpm was calculated by the following analysis. Using Microshield®
gamma ray shielding and dose assessment software (Microshield version 6.02 [Grove, 2008]), the
exposure rate above an infinite plane of Ra-226 at 1.0 pCi/g was calculated to be 1.93 [xR/hr. From
Table 6.7 in MARSSIM, the response factor for a 2-inch by 2-inch Nal detector exposed to Ra-226
is 760 cpm/[xR/hr. Given a DCGL of 4.9 pCi/g, a 2-inch by 2-inch Nal gamma detector would
have a reading of 7,187 cpm above background. Adding this value to the BTV in cpm of 17,009,
a cpm-equivalent action level of 24,192 was calculated to correlate to the action level of 6.8 pCi/g.

As part of its ongoing mission, EPA Office of Superfund Remediation and Technology Innovation
(OSRTI) periodically updates the PRG calculator model to reflect new and updated science related
to radiological risk. These updates may or may not affect the existing risk calculation for a Site
which are based on Site specific conditions and exposure pathways. In July 2022, OSRTI released
an update of the PRG calculator model. EPA Region 6 reviewed and evaluated the updated PRG
calculator model utilizing Site specific data from Tronox Settlement NAUM Section 10 Mine
Site. These model results were compared with the May 2019 PRG calculator model output that
was used for this EE/CA. The two sets of model outputs were evaluated by EPA Region 6 technical
staff (including risk assessors) for statistically significant differences in the level of excess
radiological risk from Radium-226 posed to the public and/or the environment on this Site. The

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evaluation of the model results indicated that there was not a statistically significant difference in
the level of excess radiological risk from Radium-226 based on the current site conditions at the
Tronox Settlement NAUM Section 10 Mine Site (See Appendix J for details). Based on this
extensive review and comparison of the model results and the lack of additional excess radiological
risk protection, EPA Region 6 is continuing to utilize the results of the May 2019 PRG calculator,
and the associated risk assessment determination described above.

2.2.1.1 RESRAD Calculator

The OSWER 9285.6-20 guidance document states that although EPA recommends using the PRG
Calculator to model radionuclide risk to ensure consistency with CERCLA, the NCP and EPA's
Superfund guidance for remedial sites, an alternative model may be used if justification is
developed (EPA, 2014). Justification should include the model runs using both the recommended
EPA PRG Calculator and the alternative model. Pursuant to this goal as an independent check of
PRG Calculator results, EPA reviewed several available modeling programs to determine an
appropriate alternative model. While none of the models reviewed provided a direct excess risk
value, all the available models would calculate an excess dose value that could be converted to a
comparable excess risk value. EPA selected to also model excess radiological risk (converted
from excess dose) and calculated a soil action level for this Site using the RESRAD On-Site 7.2
software developed by Argonne National Laboratory. The RESRAD model is well established and
is generally viewed as the default go to model in the Health Physics community. PRG Calculator
input values, including default values, for all parameters across the four exposure pathways noted
previously as well as the U-238 and U-235 decay-chain contaminants of concern were replicated
in RESRAD to the maximum extent possible to comport with OSWER 9285.6-20 guidance. The
same four exposure pathways considered in the PRG Calculator, described in the preceding sub-
section, were duplicated in RESRAD.

The RESRAD model outcome of 8.4 pCi/g Ra-226, when added to the BTV of 1.9 pCi/g, results
in an action level of 10.3 pCi/g for Ra-226. The modeled run results indicated a significant
difference between the two models used. Differences in modeled run results are common due to
the way that each model addresses and weighs the various input parameters. EPA reviewed the
input parameters for accuracy in both models and found no input errors. EPA determined that the
action level derived by the PRG Calculator was appropriate and valid for this Site since the PRG

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Calculator was designed by EPA for the specific needs of the agency for the calculation of excess
radiological risk. The RESRAD output is provided in Appendix J for reference and comparison to
the PRG output.

2.2.2 Principal Threat Waste

The EPA Guidance on Principal Threat and Low-Level Threat Waste recommends treatment of
principal threat waste when practicable (EPA, 1991a). The guidance aligns with, and supports, the
NCP, promulgated on 8 March 1990, which states that EPA expects to use "treatment to address
the principal threats posed by a site, wherever practicable" (40 CFR Section 300.430(a)(l)(iii)).
The expectation is derived from the mandates of CERCLA § 121 and the guidance was developed
to communicate the types of remedies that the EPA generally anticipates to find appropriate for
specific types of wastes. It reflects EPA's belief that certain source materials are addressed best
through treatment because of technical limitations to the long-term reliability of containment
technologies or the serious consequences of exposure should a release occur.

The concept of principal threat waste and low-level threat waste as developed by EPA in the NCP
is to be applied on a site-specific basis when characterizing source material. Source material is
defined as that which includes or contains hazardous substances, pollutants or contaminants that
act as a reservoir for migration of contamination to ground water, to surface water, to air, or acts
as a source for direct exposure. Examples of source materials include drummed wastes,
contaminated soil and debris, "pools" of dense non-aqueous phase liquids (NAPLs) submerged
beneath ground water or in fractured bedrock, NAPLs floating on ground water, and contaminated
sediments and sludges. Principal threat wastes are in turn those source materials considered to be
highly toxic or highly mobile that generally cannot be reliably contained or would present a
significant risk to human health or the environment should exposure occur. They include liquids
and other highly mobile materials (e.g., solvents) or materials having high concentrations of toxic
compounds. No "threshold level" of toxicity/risk has been established to equate to "principal
threat"; however, where toxicity and mobility of source material combine to pose a potential risk
of 10"3 or greater, generally, treatment alternatives should be evaluated. In summary,
determinations as to whether a source material is a principal or low-level threat waste should be
based on the inherent toxicity as well as a consideration of the physical state of the material, the

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potential mobility of the wastes in the particular environmental setting, and the lability and
degradation products of the material.

These determinations serve as general guidelines and do not dictate the selection of a particular
remedial alternative. In fact, the preamble to the NCP (55 FR at 8703, March 8, 1990) states that
there may be situations where wastes identified as constituting a principal threat may be contained
rather than treated due to difficulties in treating the wastes. Specific situations that may limit the
use of treatment include:

•	Treatment technologies are not technically feasible or are not available within a reasonable
time frame.

•	The extraordinary volume of materials or complexity of the site make implementation of
treatment technologies impractical.

•	Implementation of a treatment-based remedy would result in greater overall risk to human
health and the environment due to risks posed to workers or the surrounding community
during implementation.

•	Severe effects across environmental media resulting from implementation would occur.
Aside from the expectation that treatment would be used to addressed principal threat waste when
practicable, the selection of an appropriate waste management strategy is determined solely
through the remedy selection process outlined in the NCP (i.e., all remedy selection decisions are
site-specific and must be based on a comparative analysis of the alternatives using the nine criteria
in accordance with the NCP). Independent of the expectation, selected remedies must be
protective, ARAR-compliant, and cost-effective, and must use permanent solutions or treatment
to the maximum extent practicable.

The purpose of the principal threat waste designation is to identify waste that warrants
consideration of treatment. EPA Region 6 is not making a principal threat waste determination for
mining waste at the Section 10 mine but has evaluated if treatment was the best alternative to
remediate the waste at the site. EPA Region 6 concludes that there is not a feasible treatment
method for Ra-226 in soil (see Section 3.1). EPA Region 6 is confident that a containment remedy
in a licensed off-site disposal facility is sufficient to abate the risks to human health and the
environment presented by the Site.

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2.3 SURFACE AREA AND VOLUME ESTIMATE OF CONTAMINATED MEDIA

The lateral and vertical extent of areas exceeding the action level were determined via gamma
scanning and soil sampling, respectively, then plotting the results geographically using
Environmental Systems Research Institute's (ESRI) ArcGIS ArcMap version 10.3. The lateral and
vertical extent of contamination that requires corrective action is based on comparisons to the
action level (24,192 cpm [lateral extent] and 6.8 pCi/g Ra-226 [vertical extent]). EPA added a
500-foot buffer around the outermost elevated sample, without extending beyond the lateral extent
of contamination, to demarcate the areal extent of vertical contamination above the RAL, given
the nature of soil sampling providing less than 100% assessment coverage.

The total surface area exceeding the action level was established to be 857,700 square feet (ft2) or
20 acres. The total volume of soil exceeding the action level was determined to be 39,058 CY,
consisting of a surface area of approximately 20 acres at a 1-foot depth and a waste stockpile
volume of approximately 7,291 CY. The areal extent of contamination and the associated removal-
volumetric calculations are illustrated in Figure 2-1 and in Table 2-1 below.

Table 2-1
Removal Volume Estimates
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico



Surface Area

Volume

Zone

Square Feet

Acres

Cubic
Yards

1 ft. Excavation Area

857,700

20

31,767

Waste Pile (Aboveground)

NA

NA

7,291

TOTAL

857,700

20

39,058

2.4 REMOVAL ACTION SCHEDULE

The NCP requires a public comment period of at least 30 days following release of the EE/CA
report by the EPA (40 CFR 300.415(n)(4)(iii)). The EPA will respond to significant comments
received during the public comment period and will publish an Action Memorandum following
the response to comments. Upon concurrence by representatives of EPA, the State of New Mexico,
and involved parties regarding the threat to public health and the environment and the proposed
alternative to resolve the threat, the EPA will begin removal operations within 6 to 9 months of
the signed memorandum. The removal start date will be contingent on multiple factors including

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weather, contract approval, and funding availability. The EPA will provide public notification of
the schedule for this process upon issuance of the Action Memorandum.

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3.0 REMOVAL ACTION ALTERNATIVES

EPA guidance for preparing EE/CAs suggests identifying and assessing a limited number of
alternatives appropriate for addressing the RAOs (EPA, 1993). Removal technologies applicable
to each alternative are identified and discussed with respect to their effectiveness and
implementability. Technologies that were initially considered but were screened as infeasible for
technical reasons are presented and discussed in Section 3.1 and a discussion of ARARs is
provided in Section 3.2. The applicable technologies are then assembled into removal alternatives
in Sections 3.4 through 3.7. Based on knowledge and experience with removal actions at similar
sites, the following four removal action alternatives were evaluated for the Section 10 Mine Site:

Alternative 1: No Further Action

Alternative 2: Excavation and Off-Site Disposal of Contaminated Soils at a Licensed
Low-Level Radioactive Waste Facility

Alternative 3: Excavation, Consolidation, and Long-Term Management of the
Radiologically Contaminated Soils/Debris at an Above-Ground On-Site
Repository

Alternative 4: Capping of Contaminated Soil in Place

The alternatives have been developed to mitigate potential threats posed by controlling human
exposure to materials with concentrations of Ra-226 above the action level. These alternatives
were also developed based on federal guidance as described in Section 3.2. Section 4.0 and Section
5.0 evaluate the alternatives individually and comparatively using the criteria established by the
EPA. Figure 2-1 illustrates the excavation areas and presents the volumes of contaminated soil that
would be transferred off-site for Alternative 2, or would be relocated to an on-site repository for
Alternative 3, or capped in place for Alternative 4. Table K-l in Appendix K summarizes the
alternatives, presenting the estimated costs and schedules for each. Several other alternatives were
considered but ruled out as not viable, as described below in Section 3.1.

The conceptual design assumptions used for each alternative are discussed in the following
sections. As described in Section 2.3, the area and depth estimates used to calculate the removal
action volumes were determined through Arc-GIS analysis based on plotting on-site gamma
scanning and soil sampling data. As additional site data are obtained, it is anticipated that the

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volume estimate would be refined. However, the EPA considers the volume estimates summarized
in Figure 2-1 to be sufficiently accurate for the purposes of comparing costs and conceptual designs
in this EE/CA.

3.1	ALTERNATIVES SCREENED FROM CONSIDERATION

The process of identifying and evaluating alternatives to meet the RAOs began with an initial
screening of alternatives to determine if any were considered to be technically or administratively
infeasible. The following alternatives were screened from consideration during the prescreening
process for the East GSA EE/CA (TDD 0001/17-040) (Weston, 2020), which also apply to the
Section 10 Mine Site. See Section 3.1 of the East GSA EE/CA for the detailed discussion and
reasoning for screening the following alternatives from consideration:

•	Institutional Controls

•	Vegetative Extraction (Phytoremediation)

•	Soil Washing

•	Soil Sorting

In addition to the above alternatives screened in the East GSA EE/CA (Weston 2020), specific to
the Section 10 Mine Site, the alternative of constructing a long-term, on-site, incised (below-
ground) repository was also screened from consideration.

• On-Site Incised (below-ground) Repository

Due to the unknown locations and conditions of historic subsurface mining facilities, deep
excavations at the Section 10 Mine Site are not recommended without first collecting additional
information. Due to the unknown extent of the engineering challenges that would be involved and
the costly and highly specialized underground mapping operation that would be undertaken to
collect such information of the existing underground facilities, this alternative was screened from
further consideration.

3.2	APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS)

This EE/CA was developed following the basic methodology outlined in 40 CFR §300.415 and
further discussed in the EE/CA Guidance (EPA, 1993). Section 121(d) of CERCLA requires that
response actions comply with state and federal ARARs unless a waiver is justified. ARARs are

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used to assist in determining the appropriate extent of site cleanup, to scope and formulate removal
action alternatives, and to govern the implementation of a selected response action (EPA, 1988
and 1989). The following sections provide a definition of ARARs and describe the ARARs that
are specific to the Site.

3.2.1 Terms and Definitions

The NCP provides that response actions must attain ARARs to the extent practicable, considering
the exigencies of the situation (40 CFR 300.415(j)). As discussed in the EPA Guidance on the
Consideration of ARARs during Removal Actions (EPA, 1991b), NTCRAs will generally, where
practicable, allow for greater compliance with ARARs than time-critical removal actions
(TCRAs).

In the course of conducting the EE/CA for the Site, ARARs as well as other "To Be Considered"
(TBC) criteria were identified from policy or guidance documents that may be pertinent to
evaluating and implementing removal options. ARARs and TBC criteria are defined as follows:

•	Applicable Requirements are cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under federal or state environmental laws
that specifically address a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance found at a CERCLA site.

•	Relevant and Appropriate Requirements are cleanup standards, standards of control, and
other substantive requirements, criteria, or limitations promulgated under federal or state
environmental laws that, while not "applicable" to a hazardous substance, pollutant, con-
taminant, remedial action, location, or other circumstance at a CERCLA site, address
problems or situations sufficiently similar to those encountered at the CERCLA site and
are well-suited to the particular site.

•	TBC Criteria consist of advisories, criteria, or guidance that were developed by EPA, other
federal agencies, or states that may be useful in developing CERCLA remedies and include
non-promulgated guidance or advisories that are not legally binding and that do not have
the status of potential ARARs. TBCs generally fall within three categories: health effects
information with a high degree of credibility, technical information on how to perform or
evaluate site investigations or response actions, and policy.

The EPA has divided ARARs into two categories: location-specific, and action-specific. The
categories are described below:

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•	Location-Specific ARARs apply to the geographical or physical location of a site. These
requirements limit where and how the removal action can occur.

•	Action-Specific ARARs include performance, design, or other controls on the specific
activities to be performed as part of the removal action for a site.

ARARs and TBC criteria for the Section 10 Mine Site, along with a brief description of each, are
provided in Tables 3-1 and 3-2.

Tables 3-1 and 3-2 list the Federal and State of New Mexico action- and location-specific ARARs
and TBC requirements selected in the Action Memorandum for the NTCRA for the Site. There are
no chemical-specific ARARs selected for this Site. Cleanup standards were derived through the
EPA risk assessment process, in accordance with EPA guidance (EPA, 1997b; EPA, 1998; EPA,
2014).

The tables list ARARs and TBCs for the NTCRA selected for the Site to address surface
contamination from underground mining operations and related support activities. If unforeseen
situations arise or previously unknown hazardous substances are found during implementation of
the removal action to which additional legal standards may be germane, EPA will identify any
additional ARARs and/or TBCs promptly and secure compliance with the substantive
requirements in Site response activities.

The uranium, Ra-226, and related daughter progeny contamination in the soil/debris is from the
mining of uranium, which is a solid waste, but not a hazardous waste under the Resource
Conservation and Recovery Act (RCRA), because it is solid waste from the extraction,
beneficiation, and processing of ores and minerals within the meaning of 40 CFR § 261.4 (b)(7).
Since the materials are not a hazardous waste under RCRA, EPA does not consider RCRA
hazardous waste management requirements to be applicable, including without limitation the
waste analysis requirements found at 40 CFR §§ 261.20 and 261.30, the RCRA manifesting
requirements found at 40 CFR § 262.20, and the RCRA packaging and labeling requirements
found at 40 CFR § 262.30. Since the removal action involves no on-site storage of hazardous
wastes, storage requirements found at 40 CFR Part 265 are not ARARs.

Although the hazardous substances which are the subject of this removal action are solid waste
and not hazardous waste under RCRA, it is useful in this Site-specific situation for EPA to use

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certain RCRA procedures to control and track waste sent off-site. Accordingly, RCRA waste
analysis requirements found at 40 CFR §§ 261.20 and 261.30, RCRA manifesting requirements
found at 40 CFR § 262.20, and RCRA packaging and labeling requirements found at 40 CFR §
262.30 are deemed to be relevant and appropriate requirements and will be used for off-site
disposal of wastes and other contaminated material generated during this removal action. Because
on-site storage of repackaged hazardous wastes is not expected to exceed ninety (90) days, specific
storage requirements found at 40 CFR Part 265 are neither applicable nor relevant and appropriate
(See 40 CFR § 262.34).

3.2.2 Other Considerations and Assumptions

The following additional considerations and assumptions were made during the ARAR
identification process.

3.2.2.1	Occupational Safety and Health Administration

The Occupational Safety and Health Administration (OSHA) has promulgated standards for the
protection of workers who may be exposed to hazardous substances at RCRA or CERCLA sites
(29 CFR Parts 1910.120 and 1926.65). The EPA requires compliance with OSHA standards in the
NCP (40 CFR 300.150), but not through the ARAR process. Therefore, OSHA standards are not
considered ARARs. Since the requirements, standards, and regulations of OSHA are not ARARs
and cannot be waived, they will be complied with during the removal action.

3.2.2.2	Uranium Mill Tailings Radiation Control Act

Uranium Mill Tailings Radiation Control Act (UMTRCA) programs are categorized under Title I
and Title II. Title I addresses specific inactive uranium processing sites, and Title II addresses
active sites that are required to have a license from the NRC. Under UMTRCA, the EPA was
directed to devise standards for both the control and cleanup of excess radiation from uranium mill
tailings. The Section 10 Mine is not a listed site under Title I of UMTRCA, nor would Section 10
Mine wastes be classified under Title II. However, UMTRCA requirements may be ARARs
(relevant and appropriate) under certain circumstances, as reflected in Table 3-2.

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3.2.2.3 Multi-Agency Radiation Survey and Site Investigation Manual

The activities conducted as part of this removal action shall be conducted in a manner consistent
with MARS SIM specifications to facilitate implementation of a final status survey at the
completion of mitigation activities. MARSSIM is guidance, not a promulgated standard, and thus
is not an ARAR, though it may be applied as a TBC.

For the purposes of the final status survey, the DCGL referenced in MARSSIM will be equivalent
to 4.9 pCi/g of Ra-226, a value equivalent to the PRG Calculator result (i.e., the action level
exclusive of background; see section 2.2.1). The DCGL is a radionuclide-specific soil
concentration that would result in a risk equal to the release criterion (i.e., 4.9 pCi/g above
background). If radioactivity is relatively evenly distributed over a large area, MARSSIM
considers the average concentration over the entire area (termed DCGLw; meaning DCGL for a
wide area"). Thus, more specifically, the DCGLw will be equivalent to 4.9 pCi/g of Ra-226.

Concentrations greater than the DCGLw are allowed provided that the average concentration over
the survey area is less than the DCGLw. The MARSSIM approach allows for calculation of a
higher DCGL, for small areas of concentrated radioactivity within the 'wide area', based upon

"area weighting factors." This value is termed the DCGLemc ("emc" represents the elevated

measurement comparison). The DCGLemc is typically a multiple of the DCGLw and will differ

depending on the distance between sample points collected during the MARSSIM final status
survey (over-arching release criterion prescribed by MARSSIM) in each survey unit. This
approach accounts for the fact that the resident will receive a greater dose from a smaller area of
contaminated soil than from the more homogenously contaminated 'wide area', but because the

DCGLemc is not exceeded, the average dose to a receptor is still in compliance with the release

criterion, assuming the survey unit passes an appropriate statistical test. Calculations of DCGLemc
values will be calculated post-removal as part of final status surveys.

3.3 ENGINEERING AND LOGISTICAL CONCERNS APPLICABLE TO MOST
ALTERNATIVES

Alternatives 2 through 4 each require the following common components and activities:

• Plans and submittals

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•	Mobilization and site setup

•	Clearing and grubbing

•	Site security and access controls

•	Road and haul route improvements

•	Road and haul route maintenance

•	On-site traffic control

•	Air monitoring and dust control

•	Storm water management, erosion control, and maintenance

•	Site reclamation

The costs for these common activities are included in the estimated cost for each alternative
(Appendix K).

3.3.1 Plans and Submittals

Prior to mobilization activities, construction plans, drawings, and specifications would need to be
prepared for Alternatives 2 through 4. Work Plans and construction drawings and specifications
will consider information presented in the Natural Resource Evaluation (Appendix A) and Cultural
Resource Survey (Appendix B) as well as recommendations or requirements from the New Mexico
SHPO, New Mexico SLO, or tribal consultation.

Additional required plans would include, at a minimum, a Removal Action Work Plan to include
a Health and Safety Plan, Environmental Protection Plan, Quality Assurance Project Plan, Field
Sampling/Monitoring Plan, Site Access and Security Plan, Traffic Control Plan, Storm Water
Management and Erosion Control Plan, Cultural Resource Protection Plan, Dust Control Plan, and
Final Status Survey Plan.

The design process will also require an evaluation of the potential environmental footprint of the
project, prepared in accordance with the EPA guidance document Methodology for Understanding
and Reducing a Project's Environmental Footprint (EPA, 2012) and the ASTM International
Standard Guide for Greener Cleanups, E2983-16el (ASTM, 2016).

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3.3.2	Mobilization and Site Setup

A gamma activity survey in conjunction with soil sampling has been completed to delineate the
areas to be excavated. Temporary on-site facilities for project management and project controls
would be mobilized to the Site for the duration of the project. Temporary on-site facilities would
be constructed for decontamination of personnel and equipment (e.g., tools, salvageable
equipment, passenger vehicles and heavy equipment). Aboveground electrical lines cross the site.
A subsurface utility survey is necessary to identify and/or verify the location of buried utilities.
Areas scheduled for utility surveys would include excavation, borrow and transfer areas, heavy
equipment traversing paths, areas slated for drainage way improvements, and areas where material
may be stockpiled.

To prepare the Site for implementation of Alternatives 2, 3, and 4, the ecological and cultural
resource surveys of the repository area would be reviewed prior to mobilization. If necessary,
additional surveys would be performed by EPA-approved biologists or archeologists. Based on
the information gathered in the survey completed and for the purposes of this EE/CA, and
consistent with other CERCLA actions taken in this area, it is assumed that cultural resources can
be avoided or protected during site work activities.

As stated in Section 1.2.10, an Environmental Protection Plan will be developed prior to the
initiation of removal activities and will identify sensitive ecological habitats and species
documented during the survey. Removal activities may be scheduled to avoid certain critical
periods of the year such as nesting or breeding seasons.

3.3.3	Site Security and Access Control

Security would be maintained during all non-working hours while site work is occurring. The Site
Manager and the Health and Safety Officer would be responsible for personnel while they are on
the Site. To restrict access, the Site would remain completely fenced throughout the duration of
construction activities occurring using Alternatives 2, 3, and 4, along with appropriate signage
designating potential hazards and contacts to obtain additional information. Temporary fencing
would be used whenever the permanent fence must be removed for construction access. Alternate
entrances that may be required for portions of the work would be secured when not in use.

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The EPA and its authorized representatives, including its contractors, would have access to the
Site at all times. A Site Access and Security Plan would describe the activities used to monitor and
control access to the Site during implementation of the response actions using Alternatives 2, 3,
and 4 and the periods of work performance.

3.3.4	Road and Haul Route Improvements

Currently, there is a basic network of roads present on the Site that were used for mining and/or
mining related operations in the past. Prior to any work occurring, the current road network will
be evaluated to determine the feasibility of using the roads in their current condition for
Alternatives 2, 3, and 4. If the existing road network requires improvement, appropriate
improvements will be made to sustain the anticipated removal activities on the Site.

All roads for long-term use during the removal action will have appropriately sized gravel
surfacing, which would need to be maintained for the duration of the removal action. Without
surfacing, many of the Site roads would become unusable during precipitation events due to the
high clay content of the soils composing those roads.

3.3.5	Road and Haul Route Maintenance

The alternatives being considered (2, 3, and 4) require haul traffic both on-site and off-site for a
few months to achieve completion. During transport, traffic controls would be necessary for on-
site and off-site haulage. A Traffic Control Plan will be developed and followed throughout the
removal action operations.

It is possible that rail transportation may be an alternative for off-site disposal of the materials at a
licensed low-level radioactive waste facility (Alternative 2); however, the cost estimate in this
report assumed truck transport of the materials to an approved disposal facility. Table 3-3 presents
cost estimates of different transportation options at these facilities.

Off-road haul routes would be maintained so that dust, debris, or mud are not created, and so that
these items are not tracked onto paved surfaces. Earthen haul routes would be shaped or otherwise
improved so that they are free draining and would not easily erode. Signs and barriers would be
provided, if necessary, to contain traffic along the designated routes.

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3.3.6	Air Monitoring and Dust Control

As part of the Site Sampling and Analysis Plan, specific methods and procedures would be
included for air quality monitoring, collecting, analyzing, and evaluating air samples within and at
the perimeter of work zones as described for Alternatives 2, 3, and 4. Prior to commencing
dust generating activities in the contaminated excavation areas, perimeter work zone samples
would be collected to establish background alpha and beta activity concentrations in ambient air.
The background air samples would be used to establish the COPC activity concentrations that are
naturally occurring in the air and are unrelated to the removal activities occurring at the Site.
Perimeter and work zone air monitoring stations would be positioned and operated to monitor
emissions during grubbing, excavation, stockpiling, loading of bulk-carriers, stockpile
management, and site reclamation.

The Dust Control Plan, referenced in Section 3.3.1, will detail how air monitoring results and dust
suppression measures would be implemented to document that potential off-site migration of
contaminants at unacceptable radiological activity concentrations does not occur, to maintain
compliant air quality conditions and a safe working environment, and to protect the health of
workers, the general public, and the environment during removal operations using Alternatives 2,
3, and 4. Dust controls would also be used to minimize fugitive dust generated from soil imported
from off-site borrow sources. Perimeter air monitoring would be performed during earthmoving
activities associated with site reclamation. Frequent water or water/tackifier solution spraying
would be used during soil moving activities at the Site and during construction and material-
placement work at the repository, if selected. Appropriate Stop Work protocols will be
incorporated in the Dust Control Plan for seasonal high-wind events when dust suppression using
watering or a water/tackifier solution is ineffective.

For costing purposes, it was assumed that water for dust control would be obtained and hauled
from Grants, New Mexico, and stored on-site in mobile water tank trailer towers.

3.3.7	Stormwater Management, Erosion Control, and Maintenance

As described above, the Site is located in an arid to semi-arid area of New Mexico. While
thunderstorms and significant moisture events are generally confined to the monsoon season,
significant snow events can occur, along with flash flooding events. Stormwater management and

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erosion control are of significant concern based on the size and the extent of the excavation
activities associated with Alternatives 2, 3, and 4 of this removal action. As referenced in Section
3.3.1, a Stormwater Management and Erosion Control Plan will be prepared to address stormwater
management and erosion control procedures during the duration of the removal activities on this
Site.

Excavated areas would be graded and re-contoured to reduce overland and low-energy
concentrated flow rates and patterns. A natural regrading design would seek to integrate the post-
removal reclaimed area topography and existing drainage patterns to facilitate the development of
a stable land surface for the development of a viable post-removal ecosystem. All removal related
activities at the Site must be evaluated for potential impacts on federally listed species and critical
habitat for certification to meet the substantive requirements of the Notice of Intent, under the
National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit. Once
the Site has been stabilized, monitoring of construction stormwater runoff would cease and post-
removal site controls would be initiated. The cost estimates include provisions for ongoing cover
maintenance, and fence inspection and repair at the final repository for Alternative 3.

3.3.8 Site Reclamation

Prior to initiation of reclamation activities, topographical and meteorological data for the Site
would be collected to produce a conceptual plan for reclamation. The plan would strive to return
the topography of the Site to pre-mining conditions, which would provide a stable land surface,
reduced erosion effects, and a sustainable ecosystem. The plan would also provide strategies for
using on-site fill materials to reduce costs associated with importing backfill. The plan would be
available for review by stakeholders prior to commencement of activities.

Grading where excavation of mine or mine-related waste materials has occurred using Alternative
3 would be performed to aid in erosion control (i.e., a slope of 4H:1V or flatter) where erodible
soils are present. Re-contouring of the Site would include filling excavations to restore natural
drainage conditions. On-site, clean backfill soil may be used for re-contouring the landscape. The
material would be compacted, and in-place soil density and moisture testing would be performed
to ensure a minimum of 85% relative compaction is achieved. Revegetation of excavated
contaminated areas would be completed to reduce erosion potential while improving grazing

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suitability and wildlife habitat. Areas to be revegetated will require tilling and soil amendments
following re-contouring efforts. As summarized in Section 1.4.2.6, a conceptual revegetation plan
was developed for the Section 10 Mine Site. The conceptual revegetation plan is included in
Appendix H.

Vegetation establishment would help to minimize erosion and increase the durability of the cover
of the repository. Vegetation should attempt to emulate the local ecological conditions including
structure, function, diversity, and dynamics of native plant communities in the area. A diverse
mixture of native and naturalized plants would maximize water efficiency of water usage and
remain more resilient given variable and unpredictable changes in the environment resulting from
pathogen and pest outbreaks, disturbances (e.g., grazing, fire, etc.), and climatic fluctuations.
Therefore, the vegetation plan for the repository cover would include species that are sustainable,
once established, under typical climate and resource use patterns.

3.4 ALTERNATIVE 1: NO FURTHER ACTION

Under Alternative 1, no new treatment, containment, or removal action would occur at the Section
10 Mine Site. The no-action alternative has been included as a requirement in Section 300.430(e)
of the NCP and to provide a basis for the comparison of the remaining alternatives.

3.4.1	Site Work Activities

This alternative would include no new site work activities. Impacted materials would be left in
place. The current site conditions such as slope, surface treatment, and aspect that have been graded
would not be modified. Since the current site conditions do not provide a radon or gamma radiation
barrier, future site visitors may be exposed to radiation hazards. The potential for contact with
eroded radioactive material or exposure to fugitive dust may also occur due to the lack of
stabilization measures.

3.4.2	Post-Excavation and Site Reclamation Activities

Since there would be no new work activities at the Site under this alternative, there would be no
site reclamation.

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3.4.3	Site Controls and Security

The public and livestock are currently restricted access to the Section 10 Mine Site by chain-link
fence around the mine shaft and a cattle guard. However, the fence can be damaged or bypassed,
presenting a potential exposure to gamma radiation, fugitive dust, and radon emissions for
unauthorized personnel.

3.4.4	Stormwater and Erosion Control

No new stormwater or erosion control activities would be implemented under Alternative 1.

3.4.5	Operation and Maintenance Activities

The Site would require operation and maintenance (O&M) to ensure that the current level of
protectiveness provided by the existing fencing is maintained. Existing storm water and erosion
controls would be maintained as necessary.

3.5 ALTERNATIVE 2: EXCAVATION AND OFF-SITE DISPOSAL OF

CONTAMINATED SOILS AT A LICENSED LOW-LEVEL RADIOACTIVE
WASTE FACILITY

Alternative 2 assumes that contaminated soils with concentrations greater than the action level of
6.8 pCi/g Ra-226 would be excavated and disposed of off-site at a licensed disposal facility
permitted to receive the material, or at a processing mill that would reprocess and then dispose of
the soil.

Work recently completed by EPA identified three licensed disposal facilities within the western
United States that are authorized to accept low-level radioactive waste and/or naturally occurring
low-level radioactive soil with Ra-226 concentrations ranging from 2 pCi/g to approximately
500 pCi/g:

•	Clean Harbors, Deer Trail, Colorado

•	U.S. Ecology, Beatty, Nevada

•	U.S. Ecology, Grand View, Idaho

Transportation and disposal pricing from January 2022 was used (See Table 3-3). This information
was used to develop the detailed cost estimates included in Appendix K. The estimate assumes a

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transportation and disposal rate of $146.90/ton, which includes the pricing to transport, process,
and dispose of the material at the Clean Harbors Landfill in Deer Trail, Colorado.

3.5.1	Off-Site Rule

Alternative 2 would require compliance with the Off-Site Rule of CERCLA. In general, the Off-
Site Rule requires that facilities that accept contaminated or hazardous substances from a CERCLA
site must be in compliance with all applicable regulations and laws (i.e., they must be approved to
take those wastes and be in compliance with the applicable federal, state, and local requirements
to do so). A licensed disposal facility for Alternative 2 would have existing approval under the
Off-Site Rule.

3.5.2	Site Work Activities

The initial site removal work includes clearing and grubbing to remove organic debris. Stormwater
controls would be implemented during these activities and continued throughout the excavation
and backfill process. Contaminated soil would be excavated by a combination of heavy mining
equipment including scrapers, bulldozers, graders, excavators, front-end loaders, and haul trucks.
Contaminated soil would be loaded onto haul trucks for transport directly to the final disposal
facility. Alternatively, transportation by rail or a combination of trucking and rail may be an option.
Material would need to be trucked from the Site to Milan, New Mexico, where a transfer station
would need to be established. The material could then be loaded to rail cars and shipped to the
selected disposal facility.

In addition to the site removal work, an existing steel headworks structure will be demolished and
disposed of and an existing vertical adit shaft and vertical vent shaft will be plugged using
polyurethane foam (PUF). Figures M-2 and M-3 (Appendix M) illustrate example typical details
of adit and vent shaft closures, respectively.

Contaminated areas of the Section 10 Mine Site as shown in Figure 2-1 would be excavated. The
on-site excavation and trucking activities are estimated to take 7 months, with planning expected
to take an additional 3 months before construction mobilization, for a total removal time of 10
months before completion.

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Traffic controls would be in place in order to maintain safe driving conditions due to equipment
and vehicles entering and leaving the site. During the course of the removal action it is estimated
that approximately 2,710 truckloads (assuming 45,000 pounds/load for highway legal trucks)
would be required to remove material from the Site at a rate of 150 trucks per day. As an
alternative, rail transport from the Site might be evaluated to minimize transportation costs, as
there is a rail line approximately 0.5 miles east of the Site. The largest equipment that can
reasonably be used on the Site, with quick travel times, and that would cause minimal damage to
access routes, should be considered to maximize efficiency. Under this alternative, it was assumed
that the majority of traffic would use the existing and upgraded access roads to move the material.

3.5.3	Post-Excavation and Site Reclamation Activities

Concurrent with the excavation activities, confirmation testing of the bottom and side soils in each
excavated area would help determine the remaining vertical and lateral extent of contamination.
Excavation would continue until the action level is met.

After the mine and mine-related waste are removed from the Section 10 Mine Site, the area would
be reclaimed for livestock grazing and wildlife habitat. Clean fill soil and rock used to construct
and repair roads, or used as general fill or rock armoring, would be obtained from segregated
overburden (if feasible) or a borrow area located off-site. Excavated areas would be recontoured
and possibly backfilled with on-site, clean soil as required to restore grades and promote positive
drainage. At least 6 inches of the topsoil would be tilled and enriched with soil amendments to
serve as growing media. Revegetation efforts would follow the final Revegetation Plan developed
from the draft conceptual Revegetation Plan (Appendix H) and modified for final post removal
conditions. Progressive revegetation would occur for disturbed and reclaimed areas after
completion of removal activities in each removal unit.

3.5.4	Site Controls and Security

During the Alternative 2 removal and reclamation activities, Site access would be restricted by a
newly installed fence. Domestic livestock would not be allowed to enter the Site until reclaimed.
Once vegetation is re-established and the Site has stabilized, perimeter fencing may be removed.
Reclamation activities may take 5 years or more before adequate vegetation is re-established in
place and final stabilization is achieved.

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3.5.5	Stormwater and Erosion Control

Stormwater management and erosion control are of significant concern based on the size and the
extent of the excavation activities associated with Alternative 2. As referenced in Section 3.3.1
and 3.3.7 above, a Stormwater Management and Erosion Control Plan would be prepared to
address stormwater management and erosion control procedures during the duration of the removal
activities on this Site. The Site would be returned to a sustainable topography with natural features
to reduce the risk of erosion.

Excavated areas would be graded and recontoured to reduce overland and low-energy concentrated
flow rates and patterns. The natural regrading design integrates the post-removal reclaimed area
topography and existing drainage patterns to facilitate the development of a stable land surface for
the development of a viable post removal ecosystem. All removal related activities at the Site must
be evaluated for potential impacts on federally listed species and critical habitat for certification
to meet the substantive requirements of the Notice of Intent, under the NPDES Multi-Sector
General Permit. Once the Site has been stabilized, monitoring of construction stormwater runoff
would cease and post removal site controls would be initiated.

Recontouring of the Site would include filling excavations to restore natural drainage conditions.
On-site, clean backfill soil may be used for recontouring the landscape. The material would be
compacted, and in-place soil density and moisture testing would be performed to ensure a
minimum of 85% relative compaction is achieved. Revegetation and reclamation activities
described above would further contribute to stormwater and erosion control once the removal
action is complete.

3.5.6	Operation and Maintenance Activities

Operation and maintenance of the Site during the removal and reclamation activities would be the
responsibility of the EPA. After completion of reclamation activities, O&M would be conveyed to
the State of New Mexico at a date to be determined. Monitoring and maintenance of revegetation
efforts would occur for an estimated 12 years following revegetation (Appendix H).

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3.6 ALTERNATIVE 3: EXCAVATION, CONSOLIDATION AND LONG-TERM
MANAGEMENT OF THE RADIOLOGICALLY CONTAMINATED
SOILS/DEBRIS AT A ABOVE-GROUND ON-SITE REPOSITORY

In Alternative 3, contaminated mine and mine-related materials greater than the action level of 6.8
pCi/g Ra-226 would be excavated, transported, and consolidated into a non-commercial, newly
created repository located on the Section 10 Mine Site.

3.6.1	Engineering Design

Alternative 3 uses an engineered cover as part of the removal solution. The conceptual model used
for the capping options included in the cost analysis for this alternative is described below. Figure
M-l (Appendix M) illustrates the final grading plan of the proposed design of a 40,000 CY,
8.7-acre repository.

Regarding the remediation of mine wastes, Title I UMTRCA standards (Subpart A of 40 CFR

192.02	(a) and (d) and 40 CFR Part 61), which are ARARs (relevant and appropriate [see Table 3-
2]), offer the following guidance. Remediation should:

•	Be designed to be effective for up to 1,000 years to the extent reasonably achievable, but
for up to 200 years at a minimum.

•	Provide reasonable assurance that releases of radon-222 will not exceed an average release
rate of 20 picocuries per square meter per second (pCi/m2-s).

Several critical factors were considered in designing a cover. These design elements are discussed
briefly below, and assumptions are made in order to prepare the cost analysis for the alternative.
These assumptions may change upon further investigation of the Site. Ultimately the containment
design would be based on comprehensive planning and site-specific risk analysis.

•	Longevity of the Cover - The engineered cover would be designed to be effective for up
to 1,000 years to the extent reasonably achievable, for up to 200 years at a minimum; this
lifespan is highly dependent upon continuing maintenance of the cover and would require
long-term monitoring. The net present value (NPV) for the long-term inspections and
maintenance of the cover for 100 years is included in the cost estimate.

•	Protection from Radon Emanation - The final cap thickness for Alternative 3 would be
determined based on NRC guidance and using Regulatory Guide 3.64, Calculation of
Radon Flux Attenuation by Earthen Uranium Mill Tailings Covers (NRC, 1989).

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Preliminary calculations were performed for this report following 40 CFR Part 61 limiting
the release rate of radon-222 through the cover to 20 pCi/m2-s (Appendix L), which
resulted in a cap thickness of 3 feet.

•	Water Infiltration - The cover must protect the contaminated soils and reduce leachate
development by minimizing the infiltration of water from precipitation. The cover design
would incorporate drainage features and use evapotranspiration to limit water infiltration.

•	Erosion Control - Cap shaping, sloping, and proper drainage patterns are also important
to ensure stability of the final consolidated material. The current area has had problems
with erosion of cover soils. For this reason, the cost estimates presented for this alternative
uses a maximum 20H:1V slope ratio (5% grade) and incorporate drainage features. Water
diversion, velocity breaks, rock intermixed with the surface layer, and placement of rip rap
or other protective lining in concentrated flow areas are expected to be the most effective
surficial erosion mitigation measures. The repository would be positioned at a sufficient
distance from any surface water features to be protective of surface waters. Similarly,
information obtained during the ecological and cultural resource surveys would be
considered in the repository location placement.

•	Cover Design - The cost estimate uses an evapotranspiration cover assumed design with
a 3-foot-thick radon barrier comprised of a 2-foot layer of native soil or borrow material
and overlain by a 1-foot-thick layer of soil, mixed with both rock and organic material,
which would be used on the top of the radon cover to promote revegetation and control
erosion.

Although the final design may vary, the major cost factors—thickness of cover and source
of material—would likely not be significantly different from the cost estimate assumptions.
Final design parameters for the consolidation repository would be determined by EPA in
consultation with the State of New Mexico and other key stakeholders as necessary. All
engineering and design parameters for the proposed repository are consistent with the
Uranium Mill Tailings Radiation Control Act, 42 U.S.C. §§7918; 2022, 40 CFR
§§192.02(a) and (d); and 2022, 10 CFR Part 40, Appendix A. Criteria 1, 4, 6(1), 6(3), 6(5)
and 6(7) (ARARs [relevant and appropriate]) and the Joint Guidance for the Cleanup and
Reclamation of Existing Uranium Mining Operations in New Mexico (March 2016) (TBC).

3.6.2 Site Work Activities

The initial Section 10 Mine Site removal work includes clearing and grubbing and removal of
organic debris. Stormwater controls would be implemented during these activities and continued
throughout the excavation and site restoration process. Contaminated soil would be excavated by
a combination of heavy mining equipment including scrapers, bulldozers, graders, excavators,
front-end loaders, and haul trucks. Since the repository is located within the contamination area,

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contaminated soil would be transported directly to the final disposal facility by the excavation
equipment rather than haul trucks. Areas excavated would include impacted areas as shown in
Figure 2-1.

During the removal action, it is estimated that approximately 1,000 truckloads (assuming 34 CY
capacity off-road haul trucks) would be required to transport clean fill material from the borrow
site to the repository site. The largest equipment that can reasonably be used on-site, with quick
travel times, and that would cause minimal damage to access routes should be considered to
maximize efficiency. Under this alternative, the majority of traffic would use the existing and
upgraded access roads. The preferred route would be developed in consultation with Tronox during
the design phase.

In addition to the site removal work, an existing steel headworks structure will be demolished and
disposed and an existing vertical adit shaft and vertical vent shaft will be plugged using PUF.
Figures M-2 and M-3 (Appendix M) illustrate example typical details of adit and vent shaft
closures, respectively.

The on-site excavation and trucking activities are estimated to take approximately 7 months, with
planning expected to take an additional 3 months before construction mobilization, for a total
implementation time of 8 months before completion.

3.6.3	Post-Excavation and Site Reclamation Activities

Post-excavation and site reclamation activities are consistent between Alternative 3 and those
described for Alternative 2 in Section 3.5.3.

3.6.4	Site Controls and Security

During the Alternative 3 removal and reclamation activities, Site access would be restricted by a
fence. Domestic livestock would not be allowed to enter the Site until reclaimed. Once vegetation
is re-established and the Site has stabilized, perimeter fencing may be removed. Reclamation
activities may take 5 years or more before adequate vegetation has been re-established and final
stabilization is achieved.

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3.6.5	Stormwater and Erosion Control

As for Alternative 2, stormwater management and erosion control are of significant concern based
on the size and the extent of the excavation activities associated with Alternative 3. Controls for
Alternative 3 would be consistent with those previously described for Alternative 2 (Section 3.5.5).

3.6.6	Operation and Maintenance Activities

Operation and maintenance of the Site during the removal and reclamation activities would be the
responsibility of the EPA. After completion of reclamation activities, O&M would be conveyed to
Tronox at a date to be determined. Tronox is expected to inspect and maintain storm water and
erosion control features for perpetuity. Monitoring and maintenance of revegetation efforts would
occur for an estimated 12 years following revegetation (Appendix H). The repository
grades/slopes, cap condition, cap vegetation, erosion control measures, access roads, fencing, and
other site operation and maintenance would require more frequent inspections and a higher level
of scrutiny than the other reclaimed and revegetated areas of the Section 10 Mine Site. The cap
would be inspected for differential settling, erosional rilling and gullying, wildlife damage,
unauthorized access, and revegetation success. Repairs and maintenance would be completed
accordingly.

3.7 ALTERNATIVE 4: CAPPING OF CONTAMINATED SOIL IN PLACE

In Alternative 4, contaminated mine and mine-related materials greater than the action level of 6.8
pCi/g Ra-226 would be capped in place at the Section 10 Mine Site. This alternative would involve
excavating clean material from onsite or importing the material from another location. This
alternative envisions ultimately a future land-use of cattle ranching across the capped site, which
would require cap thickness(es) able to attenuate risk emanating from all ranching routes of
exposure (i.e., direct external gamma, inhalation of soil particulates, incidental ingestion of soil,
and beef consumption). Varying surface and subsurface Ra-226 concentrations across the Site
would require the development of statistical units for which varying cap thicknesses would be
calculated, based on an appropriate Ra-226 concentration (e.g. the 95UCL mean or the maximum
single-point concentration) and subsequent risk modeling with the PRG Calculator. Alternatively,
an 'over-design', one-size cap thickness can be considered for the entire site, calculated to
attenuate the risk from a ranching scenario using the appropriate Ra-226 concentration of the most

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elevated statistical unit. For the purposes of comparing remedial alternatives in this EE/CA, the
latter cap-design approach was used and a cap thickness of 3 feet was calculated to attenuate the
risk of a Ra-226 concentration of 57 pCi/g for a ranching scenario.

In order to cover 20-contaminated acres with a 3-foot cover, approximately 106,000 CY of cover
material would be required. The above value of cover material has an added 10% contingency
amount, taking into account the topography of the large area.

3.7.1 Engineering Design

Alternative 4 uses an engineered cover as the removal solution. The conceptual model used for the
capping-in-place alternative included in the cost analysis is described below. The excavation area
shown on Figure 2-1 illustrates the area that would be capped in place.

Several critical factors were considered in designing a cover. These design elements are discussed
briefly below, and assumptions are made in order to prepare the cost analysis for the alternative.
These assumptions may change upon further investigation of the Site. Ultimately the containment
design would be based on comprehensive planning and site-specific risk analysis.

•	Longevity of the Cover - The engineered cover would be designed similar to what is
outlined for Alternative 3 in Section 3.6.1.

•	Protection from All Routes of Exposure for a Ranching Scenario - The final cap
thickness(es) for Alternative 4 would be based on risk modeling of a ranching scenario via
the PRG Calculator.

•	Water Infiltration - The assumptions used for water infiltration were similar to those for
Alternative 3 in Section 3.6.1.

•	Erosion Control - Cap shaping, sloping, and proper drainage patterns are important to
ensure stability of the final capped material. The current area has had problems with erosion
of cover soils. For this reason, the cost estimate presented for this alternative assumes that
transitions from the capped area to existing grades would be achieved with slopes no
greater than 4H:1V. Water diversion, velocity breaks, rock intermixed with the surface
layer, and placement of rip rap or other protective lining in concentrated flow areas are
expected to be the most effective surficial erosion mitigation measures. Surface water
features such as arroyos will have to be studied to determine how capping in place will
affect storm water drainage in these areas. In addition to studying the areas being capped,
the borrow area where fill material will be taken for the cap would have to be designed to
control drainage patters and erosion due to stormwater events.

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• Cover Design - The cost estimate uses assumptions similar to those for Alternative 3 in
Section 3.6.1. Although the final design may vary, the major cost factors—thickness of
cover and source of material—would likely not be significantly different from the cost
estimate assumptions. Final design parameters for the consolidation repository would be
determined by EPA in consultation with the State of New Mexico and other key
stakeholders as necessary.

3.7.2 Site Work Activities

The initial Section 10 Mine Site removal work includes clearing and grubbing and removal of
organic debris. Stormwater controls would be implemented during these activities and continued
throughout the excavation and site restoration process. Clean fill material would be excavated from
the designated borrow area and transported and placed on top of contaminated soil. The fill
material would be compacted and seeded. The earthwork would be accomplished using a
combination of heavy mining equipment including scrapers, bulldozers, graders, excavators, front-
end loaders, and haul trucks.

During the course of the removal action it is estimated that approximately 3,800 truckloads
(assuming 34 CY capacity off-road haul trucks) would be required to transport clean fill material.
The largest equipment that can reasonably be used on-site, with quick travel times, and that would
cause minimal damage to access routes should be considered to maximize efficiency. Under this
alternative, the majority of traffic would use the existing and upgraded access roads to move
capping material to the Site. The preferred route would be developed in consultation with Tronox
during the design phase.

In addition to the site removal work, an existing steel headworks structure will be demolished and
disposed of and an existing vertical adit shaft and a vertical vent shaft will be plugged using PUF.
Figures M-2 and M-3 (Appendix M) illustrate example typical details of adit and vent shaft
closures, respectively.

Excavation, placing of fill material, and trucking activities for Alternative 4 are estimated to take
approximately 9 months, with planning expected to take an additional 3 months before
construction mobilization, for a total implementation time of 1 year before completion.

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3.7.3	Post-Excavation and Site Reclamation Activities

Site reclamation activities are consistent between Alternative 4 and those described for Alternative
2 in Section 3.5.3.

3.7.4	Site Controls and Security

Site controls and security would be consistent between Alternative 4 and those described for
Alternative 3 in Section 3.6.4.

3.7.5	Stormwater and Erosion Control

As with Alternative 2, storm water management and erosion control are of significant concern
based on the size and the extent of the excavation activities associated with Alternative 4. Controls
for Alternative 4 would be consistent with those previously described for Alternative 2 in Section
3.5.5.

3.7.6	Operation and Maintenance Activities

Operation and maintenance of the Site would be consistent between Alternative 4 and those
described for Alternative 3 in Section 3.6.6.

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4.0	ANALYSIS OF ALTERNATIVES

The detailed analysis of alternatives is intended to provide the relevant information required to
select a preferred remedy. Each alternative was evaluated based on effectiveness,
implementability, and cost, as set forth in the NCP and EPA guidance on conducting an EE/CA
for a removal action (EPA, 1993). A summary of the analyses of the individual alternatives is
included as Table 4-1.

4.1	ALTERNATIVE ANALYSIS APPROACH
4.1.1 Effectiveness

Effectiveness refers to the ability of an alternative to meet the RAOs. The following criteria are
used to evaluate effectiveness:

Overall Protection of Human Health and the Environment - This criterion provides a final
check to assess whether each alternative provides adequate protection of human health and the
environment. The assessment of overall protection draws on the evaluation of the other criteria,
especially long-term effectiveness and permanence, short-term effectiveness, and compliance with
ARARs.

Evaluation of the overall protectiveness of an alternative would focus on whether a specific
alternative achieves adequate protection and would describe how site risks posed through each
pathway addressed by the EE/CA are eliminated, reduced, or controlled through treatment,
engineering, or institutional controls. This evaluation would allow for consideration of whether an
alternative poses any unacceptable short-term or cross-media impacts.

Long-Term Effectiveness and Permanence - This criterion evaluates results of the removal
action in terms of the risk remaining at the Site after response objectives have been met. The
primary focus of this evaluation would be the extent and effectiveness of the controls that may be
required to manage the risk posed by treatment residuals and/or untreated materials remaining at
the Site.

Short-Term Effectiveness - This criterion evaluates the effects that the alternative would have
on human health and the environment during its construction and implementation phase. It

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includes both radiation exposure risks to the contaminated soils and risks to the workers and
communities from construction work and traffic during implementation and the time necessary to
complete the action.

Compliance with ARARs - This criterion is used to determine whether each alternative would
meet the identified ARARs. The detailed analyses would summarize which requirements are
applicable or relevant and appropriate to an alternative and describe how the alternative meets
these requirements.

4.1.2	Implementability

This criterion evaluates the technical and administrative feasibility of implementing an alternative
and the availability of various services and materials required to construct and provide O&M. The
following criteria are used to evaluate implementability:

•	Technical feasibility

•	Administrative feasibility

•	Availability of services and materials

Also considered is the reliability of the technology, the ability to monitor the effectiveness of the
remedy, and the ease of undertaking additional remedial actions, if necessary.

4.1.3	Cost

Cost estimates were prepared for Alternatives 2, 3, and 4 to compare the alternatives and support
remedy selection. The types of costs that were assessed in accordance with 40 CFR 300.430
(e)(9)(iii)(G) include the following: (1) capital costs, including both direct and indirect costs; (2)
annual operations and maintenance costs; and (3) net present value (NPV) of capital and O&M
costs. Capital costs were included as 2016 dollars. In accordance with EPA guidance, the cost
estimates were prepared to provide accuracy in the range of 50% greater to 30% lower than actual
costs.

An NPV analysis relates costs that occur over different time periods to present costs by discounting
all future costs to the present value. This allows the cost of removal alternatives to be compared
on the basis of a single figure that represents the capital required in 2022 dollars to construct,

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operate, and maintain the removal alternative throughout its planned life. The NPV calculations
were based on a discount rate of 7% (EPA, 2000), which represents the average rate of return on
private investment, before taxes and after inflation. Cost estimate details are located in Appendix
K.

The scope and costs presented for the various alternatives are based on the best available
information regarding current site conditions and readily available information on the applicability
and effectiveness of the selected removal actions. However, uncertainties and data gaps remain
because the site characterization was based on a limited number of samples, observations, and
analyses. In preparing the cost estimates, conservative assumptions have been used and an overall
contingency has been added to each alternative to account for these uncertainties. Changes in the
cost elements are likely as new information is available and site conditions change during the
removal action design. Cost assumptions are included in Appendix K.

Actual costs may vary from these estimates depending on variations in actual site conditions from
those estimated, such as weather conditions; inflation; actual fuel costs; actual insurance and
bonding costs; the availability and market costs of materials, equipment, and labor; changes in
regulatory requirements; and other factors that are difficult to estimate or control.

4.2 UNAVOIDABLE IMPACTS COMMON TO ALL ALTERNATIVES

Except for Alternative 1 (No Further Action), each of the removal action alternatives would result
in an overall improvement to the local environment. However, for Alternatives 2, 3, and 4, it is
important to note that there would be some unavoidable impacts. These include:

•	Short-term inconvenience to local populations using New Mexico Highways 509 and 605;
general disturbance from heavy equipment activity for the assumed construction periods;
and increased truck traffic in the area.

•	Disruption of cattle grazing and wildlife access to the removal action areas due to the
construction activities and for vegetation re-establishment.

•	Long-term O&M activities are required for maintenance of the cover, stormwater diversion
measures, revegetation efforts, and fencing.

•	Increased risks of traffic fatalities due to off-site trucking of material (Table 4-2).

•	Increase in greenhouse gas emissions due to off-site and on-site trucking of contaminated
material and clean fill material (Table 4-2).

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4.3 ALTERNATIVE 1: NO FURTHER ACTION

The No Further Action alternative does not provide protection to human or environmental
exposure, nor is it considered a permanent remedy because it does not reduce the concentration,
volume, or mobility of the hazardous substances on the Site. The No Further Action alternative
has been included as a requirement of the NCP and to provide a basis for the comparison of the
remaining alternatives. No new activities would occur at the Site under this alternative; however,
implementation of Alternative 1, No Further Action, would require the following O&M steps to
maintain the existing level of protection:

•	Erosion and stormwater control maintenance.

•	Fencing maintenance and repair.

4.3.1 Effectiveness

This alternative would not minimize the potential exposure to, or transport of, contaminated soils
from the Section 10 Mine Site. This alternative would not provide control through treatment of
soils with concentrations of Ra-226 above the action level or reduce volume or mobility of
contaminants and thus would not reduce risks to human health or the environment. The resultant
risks associated with the No Further Action Alternative would be similar to those that existed at
the time of the RSE. Therefore, increased protection of human health and the environment would
not be achieved under the alternative.

Surface water discharge from the Site would have continued potential to transport contaminated
soils to the downstream watershed. Site workers and visitors would continue to be potentially
exposed to windborne and waterborne contaminants. The Site would continue to be unacceptable
for livestock grazing use.

Other than routine storm water pollution prevention plan maintenance, no controls or long-term
measures would be implemented to control contaminated soils at the Site under the No Further
Action Alternative; therefore, this alternative offers no long-term or short-term effectiveness in
reducing potential risks to human and ecological receptors.

The effectiveness of the No Further Action Alternative is considered low for achieving the removal
action goals.

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4.3.2	Implementability

This alternative is easily implemented because there are no construction or permitting
considerations. EPA guidance requires that the reliability of the technology be considered along
with feasibility. Since No Further Action is inherently an unreliable remedy, this criterion is rated
low.

4.3.3	Cost

The total cost of Alternative 1 is estimated to be $561,000 (Appendix K [Tables K-l and K-2]).
There are no new direct or indirect capital costs, and annual O&M costs are estimated at $18,901
per year. Because the overall effectiveness of Alternative 1 is low, the cost analysis rating of
Alternative 1 is low.

4.4 ALTERNATIVE 2: OFF-SITE DISPOSAL AT A LICENSED LOW-LEVEL
RADIOACTIVE WASTE FACILITY

Implementation of Alternative 2, excavation and off-site disposal of all materials, would require
the following steps:

•	Excavation of all excess radiologically contaminated materials on the Site (Figure 2-1).

•	Off-site disposal of excavated contaminated materials.

•	Site reclamation with erosion and stormwater controls, recontouring and revegetation.
4.4.1 Effectiveness

Alternative 2 would provide a high level of protection of human health and the environment. All
soils above the action level would be excavated within the Site boundary and removed for off-site
transportation and disposal at a licensed low-level radioactive waste facility. This alternative
would significantly minimize potential exposure to contaminated soils from the Site. This
alternative would provide control of mobility and a reduction in risk to human health and the
environment at the Site. Potential exposures during excavation, transport, and at the final disposal
site would be managed through engineering controls.

Federal and state ARARs would be met for the Site under Alternative 2 (see Tables 3-1 and 3-2).
Location-specific requirements would include regulations addressing cultural resources; human
remains, funerary and sacred objects, and objects of cultural patrimony for Native Americans; and

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migratory birds, threatened or endangered indigenous wildlife species to the state, and endangered
plant species. Action-specific ARARs and TBCs for this alternative include protection of surface
water quality through control of run-off from construction activity, protection of air quality via
fugitive dust control, protection of the public, and the environment from low-level radioactivity,
and standards for post-removal reclamation. Rules and regulations on manifesting and the on-site
and off-site transport of hazardous materials would also be action-specific ARARs for
implementation of Alternative 2. Federal requirements for hazardous waste disposal would be
ARARs if the removal action encounters wastes subject to these requirements.

Short-term effectiveness under Alternative 2 is medium because of the disturbance of the entire
contaminated area and the large amount of trucking to transport the entire volume of material. The
primary considerations for short-term effectiveness are protection of the community, workers, and
environmental impacts during and after implementation. Alternative 2 involves excavation,
material transfer, stockpile development/management, loading of bulk carriers, and site restoration
activities. Heavy construction equipment would be used to clear and grub, excavate, transfer, load,
and grade impacted materials. Potential exposure and protection procedures for workers engaged
in these activities would be addressed in detail under a Site Health and Safety Plan. During
excavation and material handling activities, measures would be taken to reduce fugitive dust
emissions and associated impacts to workers. Water would be obtained from Grants, New Mexico,
for dust control, and workers in the controlled area would don the appropriate safety equipment
and implement safety practices such as air monitoring. Work areas would be secured (e.g., marked
or fenced) to ensure access by authorized personnel only.

Bulk carriers hauling the removal-action-derived contaminated materials off-site would be
covered, secured, and weighed to document compliance with total and axle load limits. Truck
traffic would be coordinated under an Off-Site Transportation Plan for routes, times of operation,
and on-site traffic rules. Emergency spill containment and cleanup contingencies would also be
included in the transportation plan to address material spills. Due to the large number of truckloads
(approximately 2,700 loads of contaminated soil leaving the Site) and the long drive to the disposal
facility (up to 5 hours one-way), it is estimated that the time period of implementation of
Alternative 2 would be 7 months, following 3 months of planning and permitting. This alternative
also has the highest amount of trucking and heavy equipment use in vehicle hours; therefore, it has

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the highest potential for additional vehicular accidents and for increased wear and tear on
infrastructure, it produces the highest amount of air pollution (from particulate matter in vehicle
exhaust), and it uses the greatest amount of fossil fuels. A risk of 0.04 additional fatalities and
5,308 metric tons of greenhouse gas emissions, calculated as a carbon dioxide equivalent (CChe),
are estimated due to the increased truck traffic (see Table 4-2).

Long-term effectiveness of this alternative is high. Since all contaminated soils would be
excavated and removed from the Site, potential exposure reductions to those accessing the Site
would be permanent. Alternative 2 is expected to effectively mitigate the long-term effects on
potential on-site human and ecological receptors.

4.4.2 Implementability

Alternative 2 rates medium in technical and administrative implementability since it is technically
feasible and would use conventional techniques, materials, or labor for the excavation and
associated activities. The Site is readily accessible. Excavation would be scheduled and performed
to maximize direct loading and ensure worker and public safety. Engineering controls for fugitive
dust and site monitoring would be used to control potential exposures to sensitive receptors.
Profiling and manifesting of the material would be done in coordination with the transporters and
off-site disposal facility. Rail shipment is a possibility; a transload facility to transfer material from
trucks to railcars could be established as close as 0.5 miles from the Site. The cost of setting up
the facility, stationing an excavator with scaling bucket, maintaining a water supply for dust
control, providing security at the Site, and scheduling would need to be evaluated against the cost
of trucking.

Alternative 2 would be administratively feasible since shipping of contaminated material is fairly
common and would only require scheduling and obtaining the necessary permits. All contaminated
soil is anticipated to be accepted by permitted facilities, although due to the large quantity of
material to be disposed off-site, it is possible that one facility may not ultimately be able to accept
all the material.

The excavation of contaminated material would be accomplished using a variety of conventional
equipment. Heavy construction equipment needed for this project such as scrapers, excavators,
dozers, loaders, and compactors and/or bulk carriers are commercially available. Working space

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is available for establishing temporary construction office trailers. Electricity is already available
at the Site and portable sanitary services and refuse disposal are locally available. Construction
materials for the site reclamation activities (localized drainage structures, erosion control,
recontouring, and seeding), and an off-site laboratory for sample analysis are commercially
available.

Trained and experienced labor is available for site work activities. Special certifications and
training requirements are commercially available. Health and safety training to comply with
OSHA regulations, including radiation and hazardous material handling training, is available.

Water for dust control can be obtained and hauled from Grants, New Mexico, and stored on-site
in mobile water tank trailer towers.

4.4.3 Cost

The total cost of Alternative 2 is estimated to be $30,055,000 (Appendix K [Tables K-l and K-3).
The long-term effectiveness and permanence is high while the short-term effectiveness is medium.
Because the cost is very high, the cost analysis rating of Alternative 2 is low.

4.5 ALTERNATIVE 3: EXCAVATION, CONSOLIDATION AND LONG-TERM
MANAGEMENT OF THE RADIOLOGICALLY CONTAMINATED
SOILS/DEBRIS AT A ABOVE-GROUND ON-SITE REPOSITORY

Implementation of Alternative 3, constructing a capped repository located on the Site, would
require the following steps:

•	Design, siting, and construction of an aboveground repository.

•	Excavation of all excess radiologically contaminated materials on the Site (Figure 2-1).

•	Transportation to and placement of contaminated materials in the constructed repository.

•	Construction of an engineered, clean-soil cap over the repository.

•	Site reclamation with erosion and stormwater controls, recontouring, and revegetation.

4.5.1 Effectiveness

Alternative 3 would protect human health and the environment as all contaminated soils would be
placed in a covered repository. These activities would prevent direct contact between these soils

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and humans and the environment in the future. Long-term maintenance of the cover and
stormwater infrastructure would be necessary.

The repository design would include a cover to fully contain and isolate contaminated soils.
Stormwater controls would be included in the design so that surface water would be diverted from
the area. The cover is a physical barrier that offers protection from water infiltration to the
contaminated soils, protects groundwater resources, and provides adequate shielding from ionizing
radiation to protect human health and the environment.

The removal action would provide compliance with location-specific and action-specific ARARs
and TBCs (see Tables 3-1 and 3-2). Location-specific requirements would include regulations
addressing cultural resources; human remains, funerary and sacred objects, and objects of cultural
patrimony for Native Americans; and migratory birds, threatened or endangered indigenous
wildlife species to the state, and endangered plant species. A Cultural Resources Protection Plan
would be developed for monitoring protocols during the work activities and would include a
review and evaluation of potential impacts to historic properties and locations. Natural resource
(e.g., biological and botanical) surveys have been conducted at the Site and information from these
surveys would be included in the Environmental Protection Plan. The plan would include a review
and evaluation of potential impacts on government-protected species and critical habitats.
Action -specific ARARs and TBCs for this alternative include protection of surface water quality
through control of run-off from construction activity; protection of air quality via fugitive dust
control; protection of the public and the environment from low-level radioactivity; standards for
post-removal reclamation; and repository design, construction, performance, and revegetation.

Short-term effectiveness under Alternative 3 is high. The primary considerations in the rating for
short-term effectiveness are protection of the community, workers, and environmental impacts
during and after implementation. Alternative 3 involves excavation, material transfer, stockpile
development/management, and site reclamation activities. Heavy equipment would be used to
clear and grub, excavate, transfer, load, and grade impacted materials. Potential exposure and
protection procedures for workers engaged in these activities would be addressed in detail under a
site safety and health plan. During excavation and material handling activities, measures would be
taken to reduce fugitive dust emissions and associated impacts to workers. Water would be
available on-site for dust control, and workers in the controlled area would don the appropriate

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safety equipment and implement safety practices such as air monitoring. Work areas would be
secured (e.g., marked or fenced) to control access by authorized personnel only.

On-site truck traffic would be coordinated under the previously referenced Traffic Control Plan
for the Site. On-site truck accidental spill containment and cleanup procedures would be included
in the aforementioned plan. It is estimated that the time period of implementation of Alternative 3
would be approximately 6 months, following 3 months of planning and permitting. Minimal risk
of additional fatalities and 72 metric tons of C02e emissions are estimated due to the increased
truck traffic (see Table 4-2).

The long-term effectiveness of Alternative 3 is medium because it is dependent on the future
maintenance activities at the repository. If properly maintained, the cover, repository, and
diversion structures would minimize water infiltration and the cap would prohibit human or animal
disturbance to the contaminated soils.

4.5.2 Implementability

Alternative 3 rates high in regard to technical implementability. It is technically feasible and would
require conventional techniques, materials, and labor for the excavation and associated activities
since the sites are readily accessible. Excavation would be scheduled and performed to maximize
direct loading and ensure worker and public safety. Engineering controls for fugitive dust and site
monitoring would be used to control potential exposure to human and environmental receptors.

Alternative 3 is administratively feasible. The contaminated soils may be transported within the
site boundary, which would include the repository. Transportation permits would not be necessary.
Construction of an engineered cover would not require permitting because contaminated soils are
considered low-level radioactive materials and are not a RCRA hazardous waste. In addition,
permits are not required for on-site CERCLA actions. On-site CERCLA actions must comply with
the substantive requirements of any state or local permit, but not the administrative requirements.

The excavation of contaminated material would be accomplished using a variety of conventional
equipment. Heavy mining equipment needed for this project, such as scrapers, excavators, dozers,
loaders, and compactors and/or bulk carriers, are commercially available. Working space is
available for establishing temporary construction office trailers. Electricity is already available at

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the Site and portable sanitary services and refuse disposal are locally available. Construction
materials for the cover and site restoration activities (recontouring and seeding) and an off-site
laboratory for sample analysis are commercially available. During non-construction periods, best
management practices would be employed in accordance with stormwater control plans to help
secure the Site during extreme storm events to protect human health and wildlife. On-site water
would be required for construction water and is readily accessible. It would need to be treated and
stored on-site in a water farm.

Trained and experienced labor is available for site work activities. Special certifications and
training requirements are commercially available. Health and safety training to comply with
OSHA regulations, including radiation and hazardous material handling training, is available.

4.5.3 Cost

The total cost of Alternative 3 is estimated to be $15,424,000 (Appendix K [Tables K-l and K-4]).
The long-term effectiveness is medium, and the short-term effectiveness is high. The cost is also
medium, so the cost analysis rating of Alternative 3 is medium.

4.6 ALTERNATIVE 4: CAPPING OF CONTAMINATED SOIL IN PLACE

Implementation of Alternative 4, capping in place, would require the following steps:

•	Design, siting, and construction of an aboveground cap.

•	Excavation and transportation of clean-soil cap material.

•	Construction of an engineered, clean-soil cap over the contaminated area.

•	Site reclamation with erosion and stormwater controls, recontouring, and revegetation.

4.6.1 Effectiveness

The effectiveness of Alternative 4 would be consistent with that for Alternative 3 as described in
Section 4.5.1. It is estimated that the time period of implementation of Alternative 4 would be
approximately 9 months, following 3 months of planning and permitting. Minimal risk of
additional fatalities and 268 metric tons of C02e emissions are estimated due to the increased truck
traffic (see Table 4-2).

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4.6.2	Implementability

The implementability of Alternative 4 would be medium. Alternative 4 is readily implementable
and technically feasible, but administrative implementability is medium as MARSSIM does not
address subsurface contamination; thus, Alternative 4 would require a site-specific, unique
compliance standard.

4.6.3	Cost

The total cost of Alternative 4 is estimated to be approximately $24,565,000 (Appendix K [Tables
K-l and K-5). The long-term effectiveness is medium, and the short-term effectiveness is high.
The cost is also medium, so the cost analysis rating of Alternative 4 is medium.

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5.0	COMPARATIVE ANALYSIS OF REMOVAL ACTION
ALTERNATIVES

This Section of the EE/CA provides a comparison of the four removal action alternatives and
options as described in Section 3 using the analyses presented in Section 4. Alternatives screened
from further consideration are not compared. In addition, and based on EPA guidance, there are
five core (key) elements in "greener cleanup activities" that should be considered throughout the
remedy selection process (EPA, 2016). These key elements include: (a) minimizing total energy
use and increasing the percentage of renewable energy; (b) minimizing air pollutants and
greenhouse gas emissions; (c) minimizing water use and negative impacts on water resources; (d)
protecting ecosystem services; and (e) improving materials management and waste reduction
efforts by reducing, reusing, or recycling whenever feasible (EPA, 2012). This analysis compares
the effects each removal action alternative, described in Section 3.0, has on the five key "green"
elements. Each of the five elements was qualitatively scored for each alternative (1, 2, 3, and 4)
using a numerical ranking system 1-4, with a 1 being best and a 4 being worst (i.e., low scores are
greener cleanup alternatives). The alternative's Greener Cleanup Assessment Score was derived
from the sum of the five scores for that alternative. The results of this assessment are summarized
in Appendix N.

5.1	EFFECTIVENESS

Alternative 1: No Further Action does not protect human health of ranchers or recreational visitors
(hunters) to the Site or protect the environment. The effectiveness of this alternative is low.
Alternative 2: Off-Site Disposal, Alternative 3: Above-Ground Repository Construction, and
Alternative 4: Capping of Contaminated Soil in Place each provide for protection of human health
and the environment to ranchers and hunters for the Site and are individually rated high. The Site
would be suitable for unrestricted grazing use under Alternatives 2, 3, and 4. Any chance for
exposure would occur prior to and during removal activities. Grazing and open space use may or
may not be limited based on erosion and vegetation performance and cover maintenance
requirements.

Alternatives 2, 3, and 4comply with the ARARs and are equal under this criterion. Alternative 1
retains the greatest chance for contaminant mobility and would rank below the other alternatives.

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The short-term effectiveness is considered medium for Alternative 2 and high for Alternatives 3
and 4. Alternatives 3 and 4 require excavation or capping of the entire contaminated soil area;
however, Alternative 2 requires a large transportation effort to remove all contaminated soil off-
site. Alternatives 3 and 4 do not require off-site transport of the material, but contaminated soil
would need to be transported to the on-site repository for Alternative 3. Alternatives 2, 3, and 4
would have a potential impact to workers and on-site visitors during construction activities. The
number of trucks required to transport the contaminated soil to an off-site disposal facility would
increase risk of traffic accidents and increase the carbon footprint for Alternative 2, whereas
Alternatives 3 and 4 would introduce much lower risks for traffic accidents and greenhouse gas
emissions.

Under each of the action alternatives, engineering controls would prevent off-site impacts from
materials such as windborne dust. Alternative 1 has the lowest short-term and long-term
effectiveness and is not considered a permanent solution and is ranked low. Alternative 2, ranked
high, provides better long-term effectiveness and permanence because the materials would be
managed by a third party in a location with contaminated materials from other sites. Alternatives
3 and 4 were rated medium for long-term effectiveness and permanence. Although materials would
be managed in an engineered repository or capped area, maintenance of the cover would be
required.

5.2 IMPLEMENTABILITY

Implementation of Alternative 1, No Further Action, is ranked low because no action is taken.
Alternative 2 is technically feasible to implement and would use conventional techniques,
materials, and labor for the excavation and associated activities. However, Alternative 2 requires
a large amount of off-site trucking, and providing enough trucks each day to maintain production
levels may be difficult to schedule and obtain. Alternative 2 is ranked medium for
implementability.

Alternatives 3 and 4 are easily implemented as they are technically feasible and would use
conventional techniques, materials, or labor for the excavation and associated activities.
Alternative 3 is also administratively feasible since the material and the repository are on one
contiguous site. Alternative 4 is technically feasible but administratively would require a site-

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specific, unique compliance standard as MARSSIM does not address subsurface soils. Alternative
3 ranked high and Alternative 4 ranked medium for implementability.

All action alternatives require a large amount of water for dust control and revegetation efforts.
Water is available at Grants, New Mexico, and potentially closer to the project site. Additional
sources of water should be investigated during the planning phase.

5.3 COST-EFFECTIVENESS

Alternative 1 only involves O&M costs to maintain existing fencing and is the least expensive, but
also the least cost-effective option because it does not address risks posed by leaving contaminated
material in its current state. Alternative 2, removing the material from the Site and disposing of it
in a licensed low-level radioactive waste facility, has the highest long-term effectiveness; however,
because of the high cost associated with this alternative, it has a low-cost analysis rating compared
to Alternatives 3 and 4. Alternatives 2, 3, and 4 would allow unrestricted use of the Site. The most
cost-effective alternative is Alternative 3, which involves on-site consolidation of contaminated
materials. Use restrictions would be applicable at the repository site, but the Site would be restored
for controlled and restricted access for perpetuity under the stipulations of a federal enforcement
document.

Section 10 Mine EE/CA

5-3

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

6.0 RECOMMENDED ALTERNATIVE

The alternatives evaluated for potential response actions at the Section 10 Mine Site are:
Alternative 1: No Further Action

Alternative 2: Excavation and Off-Site Disposal of Contaminated Soils at a Licensed
Low-Level Radioactive Waste Facility

Alternative3: Excavation, Consolidation and Long-Term Management of the
Radiologically Contaminated Soils/Debris at a Non-Incised On-Site
Repository

Alternative 4: Capping of Contaminated Soil in Place

Laboratory data for soil samples collected during the RSE, as well as gamma surveys, indicate that
approximately 20 acres of the Section 10 Mine Site surface soils (ranging from 0 to 1 foot deep)
exceed the established action level, for a total volume of approximately 39,000 CY (Figure 2-1).
Removing the material exceeding the action level will reduce human and ecological exposure to
the contaminants and will reduce potential release and/or migration of these contaminants to
downstream areas.

Alternative 1, No Further Action, is not protective, and therefore is not effective. Alternative 2,
Excavation and Off-Site Disposal, provides a high level of long-term effectiveness; however, it
has a medium level of short-term effectiveness since the material would be transported off-site and
hauled for long distances, increasing the risk of exposure to the public and the environment.
Alternative 2 is also estimated to have a high capital cost in comparison to Alternatives 3 and 4;
therefore, although it is technically feasible, Alternative 2 has a low-cost analysis rating.

Alternative 3, Excavation, Consolidation and Long-term Management of the Radiologically
Contaminated Soils/Debris at a Non-Incised On-Site Repository, provides a medium level of long-
term effectiveness to reduce the risk to humans and the environment, while also providing a high
level of short-term effectiveness since none of the material would need to be transported off-site.
Implementability of Alternative 3 is considered to be low; although the excavation plan and the
repository design based on industry standards are straightforward in nature, the Site lacks a viable
PRP to conduct long-term O&M of the repository and is therefore infeasible. Alternative 3 capital
costs are estimated to be moderate in comparison to Alternative 2.

Section 10 Mine EE/CA

6-1

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

Alternative 4, Capping of Contaminated Soils in Place provides a medium level of long-term
effectiveness to reduce the risk to humans and the environment, while also providing a high level
of short-term effectiveness since none of the material would need to be transported off-site.
Implementability of Alternative 4 is considered to be low due to the lack of excavation; lack of
repository siting; importation of cover material for the evapotranspiration cover; the inability to
accept additional programmatic materials; the need for a site-specific, unique compliance standard
for subsurface soils; and the lack of a viable PRP to conduct long-term 0& M of the capped area.
The lack of a viable PRP to conduct long-term O&M of the capped area makes the
implementability of Alternative 4 infeasible. Capital costs associated with Alternative 4 are
moderate in comparison to Alternative 2, but approximately 63% higher than Alternative 3.

Due to the non-effectiveness of Alternative 1 and the infeasibility of both Alternatives 3 and 4,
Alternative 2 is identified as the recommended alternative.

Section 10 Mine EE/CA

6-2

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

7.0 REFERENCES

Anderson, Orin, J., 1981. Abandoned or Inactive Mines in New Mexico. New Mexico Bureau of
Mines and Mineral Resources; Open File Report 148.

Argonne National Laboratory (ANL). March 2007. Radiological and Chemical Fact Sheets to
Support Health Risk Analyses for Contaminated Areas.
https://www.remm.nlm.sov/ANL ContaminantFactSheetsAll 070418.pdf

ASTM 2016. Standard Guide for Greener Cleanups. ASTM International, West Conshohocken,
PA, May 2016

Brookins, D.G. 1982. Geochemistry of clay minerals for uranium exploration in the Grants
Mineral Belt, New Mexico. Mineral. Deposits 17, 37-53.

Dynamac Corporation (Dynamac). 2011. Aerial Radiological Surveys Ambrosia Lake Uranium
Mines, Ambrosia, NM. United State Environmental Protection Agency Office of Emergency
Management, National Decontamination Team. August.

Grove. 2008. Microshield® - Microshield comprehensive photon/gamma ray shielding and dose
assessment software. Version 6.02. Grove Software, Inc. Lynchburg, VA.

Hilpert, Lowell S. 1963. Regional and Local Stratigraphy of Uranium-Bearing Rocks, Geology
and Technology of the Grants Uranium Region. New Mexico Bureau of Mines & Mineral
Resources, Memoir 15, compiled by Vincent C. Kelley.

Holmquist, Ray J. 1970. The Discovery and Development of Uranium in the Grants Mineral Belt,
New Mexico. U.S. Atomic Energy Commission. Grand Junction, Colorado. June.

Hurd, Brian H.; Torell, Allen L. and McDaniel, Kirk C. 2007. Perspectives on Rangeland
Management: Stocking Rates, Seasonal Forecasts, and the Value of Weather Information to New
Mexico Ranchers. New Mexico State University. Agricultural Experiment Station. Research
Report 759. December 2007.

John, Edward C. and West, S.W. 1963. Ground Water in the Grants District, Geology and
Technology of the Grants Uranium Region. New Mexico Bureau of Mines & Mineral Resources,
Memoir 15, compiled by Vincent C. Kelley.

Kabata-Pendias, Alina and Henryk Pendias. 1992. Trace Elements in Soils and Plants. 2nd Edition.
CRC Press. Boca Raton, FL.

Kerr-McGee Corporation. Undated. Uranium Mining and Processing. Kerr McGee Litho P-739-
7M.

Los Alamos National Laboratory (LANL). September 2017. ECORISK Database (Release 4.1),
LA-UR-17-26376, Los Alamos National Laboratory, Los Alamos, NM.

Section 10 Mine EE/CA

7-1

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

REFERENCES (CONTINUED)

McLemore, V. 2007. Uranium Resources in New Mexico. New Mexico Bureau of Geology and
Mineral Resources. SME Annual Meeting. February.

National Research Council. 2005. Mineral Tolerance of Animals: Second Revised Edition. The
National Academies Press. Washington, D.C.

Natural Resource Conservation Service (NRCS). 2016. Soil Mapper.
http://websoilsurvev.sc.egov.usda.gov/App/HomePage.htm

New Mexico Energy and Mineral Department (NMEMD). 1979. An Overview of the New Mexico
Uranium Industry. January.

New Mexico Energy, Minerals & Natural Resource Department (NMEMNRD) and New Mexico
Environment Department. 2016. Joint Guidance for the Cleanup and Reclamation of Existing
Uranium Mining Operations in New Mexico. March.

New Mexico Environment Department (NMED). February 2019. Risk Assessment Guidance for

Site Investigation and Remediation, Volume 1, Soil Screening Guidance for Human Health Risk
Assessments. Table A-1.

NMED. 2017. Risk Assessment Guidance for Site Investigations and Remediation. Volume II -
Soil Screening Guidance for Ecological Risk Assessments. March 2017

NMHED. 1986. Impacts of Uranium Mining on Surface and Shallow Groundwaters - Grants
Mineral Belt, New Mexico. Environmental Improvement Division. EID/GWH-86/2. September.

New Mexico Office of Natural Resources Trustee, September 2010. Preassessment Screen and
Determination: Rio Algom Mines and QuiviraMill Site, McKinley County, New Mexico.

Pacific Northwest National Laboratory. Visual Sample Plan version 7.7. http://vsp.pnnl.gov/

Purtymun, W. D., Weinke, Caroline L., and Dreesen, David R. 1977. Geology and Hydrology in
the Vicinity of the Inactive Uranium Mill Tailings Pile, Ambrosia Lake, New Mexico. Los Alamos
Scientific Laboratory. Los Alamos, New Mexico. LA-6839-MS. June

Rio Algom Mining LLC (RAML). 2016. Semi-annual Effluent Report-lst Half 2016. License
SUA-1473, Docket No. 40-8905. Submitted to U.S. Nuclear Regulatory Commission, Office of
Nuclear Material Safety and Safeguards, Materials Decommissioning Branch. August 29.

Santos, Elmer S. 1970. Stratigraphy of the Morrison Formation and Structure of the Ambrosia
Lake District, New Mexico, Contributions to Economic Geology, Geological Survey Bulletin
1272-E, Ore-bearing strata and tectonic features in a major uranium-mining district in
northwestern New Mexico. U.S. Geological Survey.

Section 10 Mine EE/CA

7-2

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

REFERENCES (CONTINUED)

Thomson, Bruce. Undated. Uranium Mining and Milling in New Mexico: Past Activities and
Environmental Challenges. Civil Engineering and Water Resources, University of New Mexico.

TIME. 1957. Atomic Energy: Uranium Jackpot. September 30.

U.S. Environmental Protection Agency (EPA). 1975. Water Quality Impacts of Uranium Mining
and Milling Activities in the Grants Mineral Belt, New Mexico. Region VI, Dallas, Texas. EPA
906/9-75-002. September.

EPA. 1988. CERCLA Compliance with Other Laws Manual: Interim Final. EPA/540/G-89/006.
Dated August 1988.

EPA. 1989. CERCLA Compliance with Other Laws Manual: Part II. Clean Air Act and Other
Environmental and State Requirements. EPA/540/G-89/009. Dated August 1989.

EPA. 1991a. A Guide to Principal Threat and Low-Level Threat Wastes, OSWER 9380.3-06FS,
November.

EPA. 1991b. Superfund Removal Procedures, Guidance on the Consideration of ARARS During
Removal Actions. OSWER 9360.3-02, August.

EPA. 1993. Guidance for Conducting Non Time-Critical Removal Actions. EPA/540/R-93/057,
Office of Solid Waste and Emergency Response [OSWER] Directive 9355.3-01. August 1993.

EPA. 1997a. ERA Guidance for Superfund: Process for Designing and Conducting ERAs. Interim
Final. Washington, DC. EPA/540/R-97/006. June.

EPA. 1997b. Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination,
Office of Solid Waste and Emergency Response. OSWER Directive No. 9200.4-18 August.

EPA. 1998. Use of Soil Cleanup Criteria in 40 CFR Part 192 as Remediation Goals for CERCLA
Sites. Office of Solid Waste and Emergency Response. OSWER Directive No. 9200.4-25. February.

EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.
Office of Solid Waste and Emergency Response. OSWER Publication 9355.0-75. July.

EPA. 2001. The Role of Screening-Level Risk Assessments and Refining Contaminants of
Concern in Baseline Ecological Risk Assessments. Office of Solid Waste and Emergency
Response. OSWER, EPA 540/F-01/014. June.

EPA. 2005. Guidance for Developing Ecological Soil Screening Levels. Office of Solid Waste
and Emergency Response. OSWER Directive 9285.7-55. November 2003, Revised February
2005. http://www.epa.gov/ecotox/ecossl/index.html; Last updated October 20, 2010.

EPA. 2009. Principles for Greener Cleanups. August 27.

Section 10 Mine EE/CA

7-3

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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EE/CA for Tronox Settlement Navajo Area Uranium Mines, Section 10 Mine, McKinley County, New Mexico

REFERENCES (CONTINUED)

EPA. 2011. Exposure Factors Handbook: 2011 Edition. EPA/600/R-09/052F. September 2011.

EPA. 2012. Methodology for Understanding and Reducing a Project's Environmental Footprint,
EPA 542-R-12-002. Office of Solid Waste and Emergency Response, February 2012.

EPA, 2014. Radiation Risk Assessment at CERCLA Sites: Q&A. OSWER Directive 92856.6-20.
June.

EPA. 2015a. Draft Grants Mining District, New Mexico - 2015-2020 Five-Year Plan to Assess
and Address Health and Environmental Impacts of Uranium Mining and Milling.
https://www.epa.gOv/grants-mining-district/draft-2015-2020-grants-mining-district-five-vear-
plan. Last Update 09 October.

EPA. 2015b. ProUCL Version 5.1, User Guide, Statistical Software for Environmental
Applications for Data Sets with and without Nondetect Observations, EPA/600/R-07/041, October
2015.

EPA. 2016. Memorandum: Consideration of Greener Cleanup Activities in the Superfund
Cleanup Process. August 2.

EPA. 2019a. Regional Screening Level Table and User's Guide (November 2019). Final. Oak
Ridge National Laboratory, https://www.epa.gov/risk/regional-screening-levels-rsls-generic-
tables

EPA. 2019b. Preliminary Remediation Goals for Radionuclides, PRG Calculator and User's
Guide, https://epa-prgs.ornl.gov/radionuclides/. Accessed November 2019.

U.S. Nuclear Regulatory Commission (NRC), 1989. Calculation of Radon Flux Attenuation by
Earthen Uranium Mill Tailings Covers. Regulatory Guide, Office of Nuclear Regulatory Research,
Regulatory Guide 3.64 (Task WM 503-4). June 1989.

Western Regional Climate Center (WRCC), 2015, Period of Record Monthly Climate Summary
4/1/1918 to 2/29/1988. http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl7nmsanm

WESTON. 2013. Documented Release Sampling Report for Section 10 Uranium Mine, Grants,
McKinley County, New Mexico. Prepared for USEPA. September 2013.

WESTON. 2019. Removal Site Evaluation Reportfor Tronox Navajo Area Uranium Mines Section
10 Mine, McKinley County, New Mexico. Prepared for USEPA. September 2019.

WESTON. 2020. Draft Engineering Evaluation/Cost Analysis, Tronox Settlement Navajo Area
Uranium Mines East Geographic Sub-Area of the Ambrosia Lake Sub-District, Grants Mining
District, McKinley County, New Mexico. Prepared for USEPA. January 2020

Section 10 Mine EE/CA

7-4

TDD No. 0001/17-044
SEMS Nos. NMN000605371


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FIGURES


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This page intentionally left blank.


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McKinley
County

Crownpoint

Sandoval
County

Former Rio Aigom
Uranium Mill

Section
32 Mine

Former Phillips
Petroleum
Uranium IVIill

United Nuclear
Corporation
Mill-Northeast Church
Rock (UNC-NECRjj
Superfund site, 30 miles
west of ALSD,

Section
33 Mine

i ihoreau

Tronox Mines1

Former Homestake
Uranium Mill

Former Anaconda
Bluewater Uranium Mill

\Bernalil
\Courit

Grants

Former L-Bar
Uranium Mill

Jackpile-Paguate
Superfund Site

MAP INSET

Valencia
County

f
i



L	

I I

LEGEND

~ Ambrosia Lake Sub-District ~ Uranium
of the Grants Mining District

~ Laguna Sub-District of the
Grants Mining District

aMarquez Sub-District of
the Grants Mining District

West GSA Mines Site

Central GSA Mines Site

East GSA Mines Site

Section 10 Mine Site

Site

County Boundary
Continental Divide
Tronox Surface Expression

SSiD:A6PK

SEMS: NMN000605371

TDD: 0001/17-044

SOURCE: ESRI ONLINE IMAGERY

7.5

Miles

15

New Mexico

INI



am I USEPA REGION 6

^ PRC^

FIGURE 1-1

SITE LOCATION MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO

20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-1 - Site Location Map.mxd 11:30:38 AM 2/7£020 GRANTSGIS


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Prewitt

Former Rio Algom
Uranium Mill

-Sandstone Mine
John Bully Mine

Spencer Mine

McKinley
" "CTBoIa

Smith Lake

Uhoreau

Homestake-New
Mexico Partners
Mine (Section 32)

- Ann Lee Mine

Former Phillips Petroleum
Uranium Mill

Former Anaconda
Blue water Uranium Mill

Former Homestake
Uranium Mill

ii

OKOU I

UtmjN

i-'-.r

I Sec. 10 Mine

Sec. 17 Mine

Sec. 24 Mine
Sec. 22 Mine

Sec. 19 Mine

I— Sec. 33 Mine

MAP INSET

- Sec. 35 Mine

Sec. 30 W Mine

Sec. 30 Mine

— Sec. 36 Mine

Grants

LEGEND



Ambrosia Lake Sub-District

~

San Mateo Creek Basin

~

West GSA Mines Site

Central GSA Mines Site

~

East GSA Mines Site

•

Section 10 Mine Site



Former Rio Algom Uranium
Mill Evaporation Ponds

Tronox Surface Expression

Non-Tronox Surface
Expression (SEMS Site)

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

New Mexico

ami USEPA REGION 6



FIGURE 1-2
SITE AREA MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSO
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE
FEB 2020

PROJECT NO

20600.012.001.1044

SCALE
AS SHOWN

¦Crown point

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-2- Site Area Map.mxd 11:32:25 AM 21712020 GRANTSGIS


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s.w.

N.E.

GROUNDWATER
RECHARGE
IN OUTCROP AREAS





~^c0s

— ^£5 Aver,



JShy

r^sr.

e4s//v

WATer

r£ca

Rcany(
:apturs

^ BLUFp

O/v

SAM

^4/v

-4$.,

c^e"CG/?°ap
GtO/?/c„. L'M&

*£ta

Sa"°sto°^

GENERALIZED CROSS-SECTION OF AMBROSIA LAKE AREA

New Mexico

TDD: 0001/17-044

SEMS ID: NMN000605371

SOURCE: Los Alamos Scientific Laboratory,

1977. "Geology and Hydrology in the Vicinity of the Inactive Uranium

Mill Tailings Pile, Ambrosia Lake, New Mexico"

2?	'' \ 7-.

w

^ PRo-retf^

USEPA REGION 6

FIGURE 1-3

AMBROSIA LAKE GEOLOGIC

CROSS-SECTION
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-3 - Ambrosia Lake Geologic Cross-section.mxd 11:33:46 AM 2/7£020 GRANTSGIS


-------
TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

Section 10 Mine

Legend

Ambrosia Lake Sub-District
West GSA Mines Site
Fault Line
~ Section 10 Mine

NS>

hflgi USEPAREGION 6

Note:

-	Fault iines sourced from Green, GN, and Jones
G.E., 1997, The Digital Geologic Map of New
Mexico in ARC/INFO Format: U.S. Geological
Survey Open-File Report 97-0052, 9p.;
http://pubs.usgs.gov/of/1992/ofr-92-0052.

-	GIS metadata sourced from https://pubs.usgs.
gov/of/2005/1351/documents/NMmetadata.htm

FIGURE 1-4

AMBROSIA LAKE FAULT ZONE MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSO
GMD, MCKINLEY COUNTY, NEW MEXICO

20600.012.001.1044

AS SHOWN

FEB 2020




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FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-5 - Typical Underground Uranium Mine Diagram.mxd 11:40:18 AM 2/7£020 GRANTSGIS


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LEGEND

Land Ownership
BLM

Forest Service
Navajo Allotment
Private
State

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

' Section Boundary
Section 10 Mine Site
West GSA Mines Site
Central GSA Mines Site
East GSA Mines Site
B Tronox Surface Expression

New Mexico

N

I USEPA REGION 6

^ PRC

FIGURE 1-6

LAND OWNERSHIP MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

DEC 2017

PROJECT NO

20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-6- Land Ownership Map.mxd 12:02:13 PM 2/7£020 GRANTSGIS


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c

c

I

New Mexico

Legend

Vent Hole Location

Shaft Opening & Head Frame

Cattle Pond

Concrete Slab, Metal, & Fencing
Section 10 Mine Site
Sub-Economic Material Piie
Section Boundary

N

400
Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY



USEPA REGION 6

FIGURE 1-7

SITE LAYOUT MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSO
GMD, MCKINLEY COUNTY. NEW MEXICO

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE	&&&&&	1


-------
LEGEND

Tronox Surface Expression
Section 10 Mine Site

Jnrstr»p
Private



Qt

Qal

Qc

SE J

% s

0	-
-------
Legend (Soil Type)

¦ Hospah-Skyvillage-Rock outcrop
complex, 2 to 35 percent slopes

~ Marianolake-Skyvillage complex,
1 to 8 percent slopes

~ Penistaja-Tlntero complex, 1 to
10 percent slopes

~ Querencia-Lavodnas
association, 2 to 15 percent
slopes

Rock outcrop-Westmion-
I Skyvillage complex, 30 to 80
percent slopes

Sparank-San Mateo-Zia
complex, 0 to 3 percent slopes

Uranium mined lands







02



I

I
I

I

I



\







New Mexico

LEGEND

~ Tronox Surface Expression

i	J Section Boundary

1 1 Section 10 Mine Site

Feet

1,600



TDD: 0001/17-044
SEMS ID: NMN000605371

SOURCE: ESRI ONLINE IMAGERY; USDASoil Survey Geographic
(SSURGO) Database (https://websoilsurvey.sc.egov.usda.gov/App/
WebSoilSurvey.aspx)

hjggi USEPAREGION 6

FIGURE 1-9

SITE SOILS MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO



PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-9 - Site Soils Map.mxd 12:06:11 PM 2/7/2020 GRANTSGIS


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FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-10 - Site Surface Drainage Map.mxd 12:06:58 PM 2/7/2020 GRANTSGIS

New Mexico

Legend

~ Tronox Surface Expression
— Flow Direction
Surface Drainage
Section 10 Mine Site

hjggi USEPA REGION 6

^ PRore^

FIGURE 1-10

SITE SURFACE DRAINAGE MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY


-------
New Mexico

Legend

Central GSA Mines Site

East GSA Mines Site
Section 10 Mine Site
Section Boundary

~	Non-Tronox Surface Expression

~	Tronox Surface Expression
Exposure Rate
(mlcroR/hr)

< 5.0000
I 15.0000: 10.000
10.000: 15.000
15.000: 20.000
20.000 : 25.000
25.000: 30.000
I 30.000: 35.000
I [ 35.000 : 40.000
I ,40.000:45.000
^¦>•45.000

Note:

-	Dynamac Corporation, 2011. Aerial Radiological Surveys,
Ambrosia Lake Uranium Mines, Ambrosia, New Mexcio,
2011. EPA Emergency Management National
Decontamination Team.

-	Data collected August 22-25, 2011

Sec. 38 Mine

Miles

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

USEPA REGION 6

FIGURE 1-11

ASPECT AERIAL GAMMA SURVEY MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

PROJECT NO

SCALE

AS SHOWN

file	i i f ^	.'y *


-------
Note:

-	Removal Action Level = 24,192 CPM.

-	Theoretical 24,192 CPM Removal Action Level = BTV in CPM (17,009) +DCGL (4.897 pCi/g)
converted to CPM as follows: DCGL x 1.93 pR/hr per pCi/g Ra-226 (Microshield® output)

x 760 cpm per pR/hr Ra-226 for 2x2 Nal detector (MARSSIM Table 6.7). BTV = Background
Threshold Value; DCGL = Derived Concentration Guideline Level using EPA's online risk
calculator 'PRG Calculator for Radionuclides'.

-	Gamma scan data collected June 2016.

-	Measurements collected using a Ludlum Model 2221 ratemeter paired with a Model 44-10 2x2 Nal
detector.

New Mexico

LEGEND

© Background Reference Area
~ Tronox Surface Expression
Section 10 Mine Site
i_ _ J Section Boundary
Gamma Scan Results
In Counts Per Minute (CPM)
0-17,009

(Background Threshold Value)

17,010-24,192
(Removal Action Level)

24,193-28,934
28,935 - 43,602

•	43,603 - 58,270

•	58,271 - 575.483

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY



2g J USEPA REGION 6



FIGURE 1-12

GAMMA SCANNING SURVEY RESULTS MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

bection 1U
Mine





:	Q:	£0* I	¦MBsswfe-Maj %% V:


-------
Note:

-	Data Collected June 2016.

-	Measurements collected using a Ludlum Model 2221 ratemeter paired with a Model 44-10 2x2 Nal
detector.

-	Gamma scan values in cpm greater than the BTV of 17,009 cpm were converted to pCi/g Ra-226 by
the following analysis: Using Microshield®, the exposure rate above an infinite plane of

Ra-226 at 1.0 pCi/g was calculated to be 1.93 pR/hr. From MARSSIM Table 6.7, the response
factor for a 2-inch x 2-inch Nal detector exposed to Ra-226 is 760 cpm per pR/hr.

-	The BTV in pCi/g of 1.9 is the UTL95-95 of the Background soil sample data set.

-	Removal Action Level of 6.8 pCi/g = BTV of 1.9 + Derived Concentration Guideline Level (DCGL)
of 4.9 pCi/g Ra-226 derived from PRG Calculator.

New Mexico



LEGEND

© Background Reference Area
~ Tronox Surface Expression
Section 10 Mine Site
i_ _ | Section Boundary
Gamma Scan Results
In Picocuries Per Gram (pCi/g)

0-1.9 (Background Threshold Value)

•	2.0 - 6.8 (Removal Action Level)
6.9-10

10.1 -20

•	20.1-30

•	30.1 +

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

S I - - - -I o

USEPA REGION 6

FIGURE 1-13

ESTIMATED Ra-226 CONCENTRATION MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-13 - Estimated Ra-226 Concentration Map.mxd 12:13:27 PM 2/7/2020 GRANTSGIS


-------
'V



B> Jj



10-10-31-170202

" 53 Si

|gl 10-06-31-181031-M
10-7-31-170202 ^ 10-9-31-170202 *

u

.%<3

10-6-31-170202

15 '

10-8-31-170202

10-5-31-170202 10-05-31 -181031-MP
01	A 10-05-32-181031;Ml ,

10-02-31-160628

Ekj



~ * * jS

< KB

* ¦

10-01-31-160628

B

10-08-31-181031-M

10-07-31-181031-M

Vt

©•

!

ectiori 10 Mine

1-181031-M	'

~

10-01-31-161101-M

10-04-31-160628

10-03-31-160628



»!?¦

	

10-04-31-1 81031-M

•	I

I

:
i

10-02-31-181 031^mPP
© ¦

i
"
i
i
i
i
i
i
•

:

I

;

25

•, *
¦ "~L - - *

# V



New Mexico

LEGEND

Soil Sample Analyzed
for TAL Metals

® Surface (0"-6") Sample Location

~ Tronox Surface Expression

_ J Section Boundary

NOTE:

- Soil samples collected 0-1 ft.
below ground surface.

1,000

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

ar i

USEPA REGION 6

FIGURE 1-14

SURFACE SOIL SAMPLE LOCATION MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY. NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE	'	Stiffen S I	Uin " ! 12


-------
10-04-2-31-161112
10-04-2-32-161112
10-05-2-31-161112-

10-06-2-31-161112

10-03-2-31-161112 —i
10-07-2-31-161112# ® ©

10-10^1-161112—
10-08-2-31-161112
Section 10 Mine

10-02-2-31 -161112 —^ / J

10-01-2-31-161112 —' I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I



w-*, %

I

i

New Mexico

LEGEND

~ Tronox Surface Expression
i_ _ J Section Boundary
Subsurface (12" -18")

Soil Sample Concentration

# <6.8 pCi/g (Proposed Action Level)

NOTE:

- Subsurface soil samples were collected
May-August 2016

1,000

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

g MJH *£

iasi

USEPA REGION 6

FIGURE 1-15

SUBSURFACE SOIL SAMPLE

LOCATION MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY. NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN




-------
FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-16 - Radon Sample Location Map.mxd 12:20:00 PM 2/7/2020 GRANTSGIS


-------
"V

Sec. 10 Mine —

P12-161101 D
S12-161101 ©

P11-161101 ®
S11-161101



' ••

New Mexico

LEGEND

Tronox Surface Expression

~

Soil arid Vegetation
Sample Location

1,000

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

S i - - - J o

USEPA REGION 6

FIGURE 1-17

SOIL AND VEGETATION
SAMPLE LOCATION MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE. ALSD
GMD, MCKINLEY COUNTY NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECA Maps\Figure 1-17 - Soil and Vegetation Sample Location Map.mxd 12:20:58 PM 2/7/2020 GRANTSGIS


-------
| Zone

SA (Acres) SA (ft2)

Volume (ft3)

Volume (yd3)

1ft. Excavation Area

19.7

857,699.8

857,699.8

31,766.7

Sub-economic Material Pile

n/a

n/a

196,869.0

7,291.4

TOTAL

19.7

857,699.8

1,054,568.8

39,058.1

THEORETICAL ESTIMATES

Section 10
14N 10W

©





y//-

Kh

*• * 9K

NOTES

-1 ft. removal depth is based on gamma scan readings from the surface.

-	Theoretical 24,192 CPM Removal Action Level = BTV in CPM (17,009) + DCGL (4.897 pCi/g) converted to CPM as follows: DCGL x 1.93 pR/hr per pCi/g Ra-226 (Microshield® output) x 760 cpm per (jR/hr Ra-226 for 2x2
Nal detector (MARSSIM Table 6.7). BTV = Background Threshold Value; DCGL = Derived Concentration Guideline Level using EPA's online risk calculator 'PRG Calculator for Radionuclides'.

-	2 ft. removal depth is based on laboratory analysis of soil samples. No depth samples were greater than the Removal Action Level; therefore, there is only a 0-1 ft. removal depth.

-	Soil samples were collected November 2016.

-Areas inside the removal footprints are mine impacted.

Legend

© Background Reference Area
~ Tronox Surface Expression
Section 10 Mine Site
l _ Section Boudary
V//\ Sub Economic Material Pile
Soil Sample (2 ft. depth)

Concentration (pCi/g Ra-226)

® <6.8 (Removal Action Level)

Depth of Excavation Area

0-1 ft. (Theoretical 24,192 CPM Removal
Action Level)

IM

600

1,200

Feet

TDD: 0001/17-044
SEMS ID: NMN000605371
SOURCE: ESRI ONLINE IMAGERY

.LiJy.

m

USEPA REGION 6

FIGURE 2-1

SOIL REMOVAL ESTIMATE MAP
TRONOX SETTLEMENT NAUM
SECTION 10 MINE SITE, ALSD
GMD, MCKINLEY COUNTY, NEW MEXICO

DATE

FEB 2020

PROJECT NO
20600.012.001.1044

SCALE
AS SHOWN

FILE: Z:\TRONOX-WEST-GSA_GIS\mxd\Misc\EECA\Section 10 EECAMaps\Figure 2-1 - Soil Removal Estimate Map.mxd 12:24:36 PM 2/7/2020 GRANTSGIS


-------
TABLES


-------
This page intentionally left blank.


-------
Table 1-1

Background Reference Area Summary of Field and Laboratory Measurements
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico



1Ludlum 2"x2" Nal





One-Minute

Laboratory Gamma



Stationary

Spectroscopy Result



Measurement

Radium-226



(counts per minute

(picocuries per gram

Sample ID

[cpm])

[pCi/g])

10-01-61-160714

16,361

1.43

10-02-61-160714

16,232

1.73

10-03-61-160714

16,312

1.36

10-04-61-160714

16,238

1.45

10-05-61-160714

16,358

1.57

10-06-61-160714

16,363

1.44

10-07-61-160714

16,415

1.55

10-08-61-160714

16,541

1.40

10-09-61-160714

16,362

1.44

10-10-61-160714

16,581

1.56

10-11-61-160714

16,739

1.61

10-12-61-160714

16,464

1.58

10-13-61-160714

16,680

1.27

10-14-61-160714

16,302

1.53

10-15-61-160714

16,055

1.71

10-16-61-160714

16,127

1.54

10-17-61-160714

15,816

1.71

10-18-61-160714

15,781

1.78

10-19-61-160714

15,941

1.59

10-20-61-160714

15,497

1.22

Mean

16,258

1.5

Standard Deviation

306

0.15

Coefficient of Variance

0.02

0.1

^Dne-minute stationary gamma measurements were collected with a
Ludlum Model 2221 Rate Meter attached to a Model 44-10 Sodium
Iodide (Nal) 2-inch by 2-inch Scintillator Probe.

USEPA REGION 6

lof 1

TDD


-------
Table 1-2

Summary of Surface Soil Sample Radium-226 Results
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Sample ID12

Latitude

Longitude

Collection
Method

Sample Type

Radium-226
(picocuries per gram [pCi/g])6

Figure
Depicting
Sample
Location

Field Laboratory

Multichannel
Analyzer (MCA)34

Off-site
Commercial
Laboratory5

10-01-31-160628

35.461000

-107.877000

Grab

Field Sample

n/a

1.46

1-14

10-02-31-160628

35.457000

-107.877000

Grab

Field Sample

n/a

14.7

1-14

10-03-31-160628

35.451000

-107.879000

Grab

Field Sample

n/a

0.924

1-14

10-04-31-160628

35.451000

-107.882000

Grab

Field Sample

n/a

1.37

1-14

10-05-31-170202

35.457203

-107.877198

Grab

Field Sample

21.8

n/a

1-14

10-06-31-170202

35.457429

-107.877129

Grab

Field Sample

51.6

n/a

1-14

10-07-31-170202

35.457608

-107.877137

Grab

Field Sample

18.1

n/a

1-14

10-08-31-170202

35.457540

-107.876961

Grab

Field Sample

20.1

n/a

1-14

10-09-31-170202

35.457639

-107.877001

Grab

Field Sample

125.2

n/a

1-14

10-10-31-170202

35.457775

-107.876974

Grab

Field Sample

82.8

n/a

1-14

1	All samples collected from 0-6 inches below ground surface.

2	First two digits of the sample number indicate the section from which they were collected.

3	MCA and offsite laboratory both analyzed for Bismuth-214. Samples were held for 21 days before
analysis so that Bismuth-214 was in equilibrium with Radium-226.

4	n/a denotes that the sample was not analyzed with the MCA.

5	n/a denotes that the sample was not sent for offsite laboratory analysis.

6	Sample results above the 6.8 pCi/g Removal Action Level (RAL) are shaded in gray.



Q , USEPA REGION 6

1 of 1	TDD No. 0001/17-044


-------
Table 1-3

Summary of Subsurface Soil Sample Radium-226 Results
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Sample ID12

Latitude

Longitude

Collection
Method

Sample Type

Radium-226
(picocuries per gram [pCi/g])

Figure
Depicting
Sample
Location

Field Laboratory

Multichannel
Analyzer (MCA)34

Off-site
Commercial
Laboratory5

10-01-2-31-161112

35.455244

-107.875290

Grab

Field Sample

2.1

n/a

1-15

10-02-2-31-161112

35.456115

-107.875321

Grab

Field Sample

3.3

n/a

1-15

10-03-2-31-161112

35.456985

-107.875352

Grab

Field Sample

4.6

n/a

1-15

10-04-2-31-161112

35.457856

-107.875383

Grab

Field Sample

3.3

n/a

1-15

10-04-2-32-161112

35.457856

-107.875383

Grab

Field Duplicate

3.3

n/a

1-15

10-05-2-31-161112

35.457830

-107.876447

Grab

Field Sample

3.4

n/a

1-15

10-06-2-31-161112

35.457805

-107.877511

Grab

Field Sample

2.5

n/a

1-15

10-07-2-31-161112

35.456935

-107.877480

Grab

Field Sample

2.9

n/a

1-15

10-08-2-31-161112

35.456064

-107.877449

Grab

Field Sample

1.9

n/a

1-15

10-09-2-31-161112

35.456089

-107.876385

Grab

Field Sample

2.6

n/a

1-15

10-10-2-31-161112

35.456960

-107.876416

Grab

Field Sample

3.3

n/a

1-15

1	All samples collected from 12-18 inches below ground surface.

2	First two digits of the sample number indicate the section from which they were collected.

3	MCA and offsite laboratory both analyzed for Bismuth-214. Samples were held for 21 days before
analysis so that Bismuth-214 was in equilibrium with Radium-226.

4	No sample results are above the 6.8 pCi/g Removal Action Level (RAL).

5	n/a denotes that the sample was not sent for offsite laboratory analysis.

US EPA REGION 6

lof 1

TDD No.


-------
Table 1-4

Summary of Surface Soil Sample Metals Results
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Values in milligrams per kilogram (mg/kg)

Analyte!

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Nickel

Potassium

Silver

Sodium

Thallium

Mercury

Selenium

Vanadium

Zinc

Uranium

State Screening Level2

1,290,000

519

35.9

255,000

2,580

1,110

32,400,000

505

388

51,900

908,000

800

5,680,000

160,000

25,700

76,200,000

6,490

37,300,000

13

112

6,490

6,530

389,000

3,880

State Background3

54423

1

5.9

727

1

n/a

35808

55.5

8.8

21

20898

18.1

n/a

366.8

27.9

n/a

n/a

n/a

n/a

n/a

1

71.4

44.3

n/a

Sample Number4



10-01-31-161101-M

6100

nd6

5.6

100

0.38

0.18

17000

3.4

2.2

19

12000

12

4200

140

3.5

1700

ND

47

ND

ND

82

160

38

73

10-02-31-181031-M

11000

ND

3.5

190

0.55

ND

12000

5.2

3.2

3

12000

5.7

3200

200

5.7

2300

ND

150

ND

0.014

ND

14

25

ND

10-03-31-181031-M

12000

ND

ND

77

0.62

ND

3300

7

4.7

6.2

13000

14

2900

210

7.1

3900

ND

180

ND

0.017

ND

38

38

ND

10-04-31-181031-M

10000

ND

4.2

73

0.61

ND

9500

5.3

2.7

3.2

10000

8.2

4100

140

4.8

2700

ND

150

ND

0.026

15

77

24

6.2

10-05-31-181031-M

14000

ND

ND

110

0.91

ND

10000

2.2

3

6.3

12000

6.8

3300

240

3.9

3400

ND

490

ND

0.028

87

110

26

70

10-05-32-181031-M

15000

ND

ND

100

0.97

ND

10000

2.5

3.1

6.4

12000

6.5

3700

260

4.1

3700

ND

560

ND

0.033

77

120

29

67

10-06-31-181031-M

6000

ND

20

210

0.56

ND

4100

ND

1.8

ND

10000

8.7

1700

140

1.6

880

ND

150

ND

0.12

86

250

17

310

10-07-31-181031-M

17000

ND

7.1

75

0.8

ND

5300

9.7

5.3

7.8

16000

5.4

4200

190

9.2

4700

ND

190

ND

0.022

ND

26

44

ND

10-08-31-181031-M

22000

ND

ND

88

1

ND

6800

13

6.1

9.5

19000

5.5

5300

240

11

5800

ND

210

ND

0.019

ND

34

53

ND

1	Analytes are from the Targeted Analyte List (https://www.epa.gov/sites/production/files/2015-10/documents/ism23a-c.pdf) plus Uranium.

2	NM-specific screening levels from: NMED Industrial/ Occupational Soil Screening Levels (Cancer Target Risk [TR]=lE-05, Non-Cancer Total Hazard Quotient [THQ]=1), June 2019 (https://www.env.nm.gov/hazardous-waste/guidance-documents/).

3	NM-specific background values were obtained from: https://www.epa.gov/chemical-research/guidance-developing-ecological-soil-screening-levels.

4	First two digits of the sample number indicate the section from which the sample was collected.

5	n/a indicates that the NM-specific screening level or NM-specific background is not available for that element.

6	ND indicates that the analyte was not detected.

USEPA REGION 6

lof 1

TDD No. 0001/17-044


-------
Table 1-5
Summary of Radon Sample Results
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Sample
number

Date placed

Date
collected

Description of location

Radon-222 picocuries
per liter (pCi/IJi

Figure
Depicting
Sample
Location

SEC10A

10/28/2016

11/3/2016

Inside mine shaft, 50' deep

6,304.9

1-16

SEC10B

10/28/2016

11/3/2016

Inside mine shaft, 100' deep

8,170.5

1-16

SEC10C

6/29/2017

7/5/2017

Edge of mine shaft

11.1

1-16

SEC10D

6/29/2017

7/5/2017

5' from edge of mine shaft

0.7

1-16

SEC10E

6/29/2017

7/5/2017

20' from edge of mine shaft

0.9

1-16

SEC10F

6/29/2017

7/5/2017

Top of ventilation shaft

1,247.9

1-16

SEC10G

6/29/2017

7/5/2017

20' from ventilation shaft

2.1

1-16

•fThe EPA and Centers for Disease Control (CDC) acceptable exposure level for indoor radon exposure is 4
picocuries per liter (pCi/l). There is no recommended exposure level for outdoor radon.

US EPA REGION 6

lof 1

TDD No. 0001/17-044


-------
Table 3-1

Location-Specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

C ulfinal Resources

Presence of

archaeological

resources1

"Under section 6(a) of the Act, no person may
excavate, remove, damage, or otherwise alter or
deface, or attempt to excavate, remove, damage, or
otherwise alter or deface any archaeological
resource1 located on public lands or Indian lands
unless such activity is pursuant to a permit issued
under § 7.8 or exempted by § 7.5(b) of this part."

Action that would affect
archaeological resources1 on
public lands or Indian lands
- Relevant and
Appropriate to response on
private land.

43 C.F.R. § 7.4(a);
Regulation under 16
U.S.C. §470ee (a)

Archaeological
Resources Protection Act
(1979)

1 Archaeological resource means any material remains of human life or activities which are at least 100 years of age, and which are of archaeological interest. 40
C.F.R. § 7.3(a).

USEPA REGION 8

1 of9	TDD No. 0001/17-044


-------
Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Presence of

archaeological

resources

"No permit shall be required under this part for any
person conducting activities on the public lands
under other permits, leases, licenses, or entitlements
for use, when those activities are exclusively for
purposes other than the excavation and/or removal
of archaeological resources, even though those
activities might incidentally result in the
disturbance of archaeological resources. General
earth-moving excavation conducted under a permit
or other authorization shall not be construed to
mean excavation and/or removal as used in this
part."

[NOTE: Although obtaining a permit is an
administrative requirement, stopping work and
notifying the State Historic Preservation Officer
prior to excavating and/or removal of
archaeological resources inadvertently
discovered is recommended. J

Excavation activities that
inadvertently discover
archaeological resources on
public lands or Indian lands
- Relevant and
Appropriate to response on
private land.

43 C.F.R. § 7.5.(b)(1)
Permit requirements and
exceptions

(Regulation under
Archaeological
Resources Protection Act
(1979))

USEPA REGION 8

2 of 9	TDD No. 0001/17-044


-------
Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Presence of human
remains, funerary
objects, sacred
objects, or objects of
cultural patrimony
for Native
Americans

"Discovery. Any person who knows or has reason
to know that he or she has discovered inadvertently
human remains, funerary objects, sacred objects, or
objects of cultural patrimony on Federal or tribal
lands after November 16, 1990, must provide
immediate telephone notification of the inadvertent
discovery, with written confirmation, to the
responsible Federal agency official with respect to
Federal lands, and, with respect to tribal lands, to
the responsible Indian tribe official. The
requirements of these regulations regarding
inadvertent discoveries apply whether or not an
inadvertent discovery is duly reported. If written
confirmation is provided by certified mail, the
return receipt constitutes evidence of the receipt of
the written notification by the Federal agency
official or Indian tribe official."

[NOTE: Although notification is an
administrative requirement, EPA must notify the
County Medical Examiner of the inadvertent
discovery of human remains in accordance with
New Mexico law. The State Historic
Preservation Officer and State Archaeologist
should be notified of cultural artifact
discoveries.]

Any person who knows or
has reason to know that he or
she has discovered
inadvertently human
remains, funerary objects,
sacred objects, or objects of
cultural patrimony on
Federal or tribal lands after
November 16, 1990 -
Relevant and appropriate
to response on private land.

43 C.F.R. § 10.4(b)

Discovery

(Regulation under the
Native American Graves
Protection and
Repatriation Act)

USEPA REGION 8

3 of 9	TDD No. 0001/17-044


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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Presence of human
remains, funerary
objects, sacred
objects, or objects of
cultural patrimony
for Native
Americans

"Ceasing activity. If the inadvertent discovery
occurred in connection with an on-going activity on
Federal or tribal lands, the person, in addition to
providing the notice described above, must stop the
activity in the area of the inadvertent discovery and
make a reasonable effort to protect the human
remains, funerary objects, sacred objects, or objects
of cultural patrimony discovered inadvertently."
[NOTE: Although notification is an administrative
requirement, EPA must cease any on-going
response activity in the area of discovery, and
notify the County Medical Examiner of the
inadvertent discovery of human remains in
accordance with New Mexico law. The State
Historic Preservation Officer and State
Archaeologist should be notified of cultural artifact
discoveries.]

Excavation activities that
inadvertently discover such
resources on federal lands
(or under federal control) or
tribal lands after November
16, 1999 - Relevant and
appropriate to response on
private land.

43 C.F.R. § 10.4(c)
Ceasing activity

(Regulation under the
Native American Graves
Protection and
Repatriation Act)

USEPA REGION 8

4 of 9	TDD No. 0001/17-044


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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Excavation of an
archaeological site2

"It is unlawful for any person or his agent or
employee to excavate with the use of mechanical
earth moving equipment an archaeological site for
the purpose of collecting or removing objects of
antiquity when the archaeological site2 is located on
private land in this state, unless the person has first
obtained a permit issued pursuant to the provisions
of this section for the excavation." [Contact State
Historic Preservation Officer and State
Archaeologist]

Discovery of material
evidence of the past life and
culture of human beings on
private land (excluding sites
of burial of human beings) -
Applicable if an
archaeological site is
discovered in the course of
excavations for site
response.

New Mexico Cultural
Properties Act, Section
18-6-11

2 As used in this section, an "archaeological site" means a location where there exists material evidence of the past life and culture of human beings in this state
but excludes the sites of burial of human beings.

USEPA REGION 8

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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Excavation of
unmarked human
burial3'4

"A. Each human burial in the state interred in any
unmarked burial ground is accorded the protection
of law and shall receive appropriate and respectful
treatment and disposition.

B. A person who knowingly, willfully and
intentionally excavates, removes, disturbs or
destroys any human burial3 buried, entombed or
sepulchered in any unmarked burial ground4 in the
state, or any person who knowingly, willfully and
intentionally procures or employs any other person
to excavate, remove, disturb or destroy any human
burial buried, entombed or sepulchered in any
unmarked burial ground in the state, except by
authority of a permit issued by the state medical
investigator or by the committee with the
concurrence of the state archaeologist and state
historic preservation officer, is guilty of a fourth
degree felony and shall be punished by a fine not to
exceed five thousand dollars ($5,000) or by
imprisonment for a definite term of eighteen
months, or both.

Discovery of unmarked
human burial may be
Relevant and Appropriate

if an unmarked human burial
is discovered in the course of
excavations for site
response.

New Mexico Cultural
Properties Act, Section
18-6-11.2(A)-(C)

3 "Human burial" means a human body or human skeletal remains and includes any funerary object, material object or artifact buried, entombed or sepulchered
with that human body or skeletal remains.

4"Unmarked burial ground" means a location where there exists a burial or burials of any human being which is not visibly marked on the surface of the ground
in any manner traditionally or customarily used for marking burials and includes any funerary object, material object or artifact associated with the burial or
burials.

l'^ j USEPA REGION 8

6 of 9	TDD No. 0001/17-044


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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Discovery of
unmarked human
burial

C. Any person who discovers a human burial in any
unmarked burial ground shall cease any activity that
may disturb that burial or any object or artifact
associated with that burial and shall notify the local
law enforcement agency having jurisdiction in the
area. The local law enforcement agency shall notify
the state medical investigator and the state historic
preservation officer."

Discovery of a human burial
in an unmarked burial
ground. Applicable if a
human burial is discovered
in the course of excavation
for site response.

New Mexico Cultural
Properties Act, Section
18-6-11.2



Wildlife. Threatened or Endangered Species

Presence of
Migratory birds
listed in 50 C.F.R.
§10.13

"No person may take, possess, import, export,
transport, sell, purchase, barter, or offer for sale,
purchase, or barter, any migratory bird, or the parts,
nests, or eggs of such bird except as may be
permitted under the terms of a valid permit issued
pursuant to the provisions of this part and part 13 of
this chapter, or as permitted by regulations in this
part, or part 20 of this subchapter (the hunting
regulations)."

Action that has potential
impacts on, or is likely to
result in a 'take' (as defined
in 50 C.F.R. § 10.12) of
migratory birds -
Applicable

Migratory Bird Treaty
Act, 16 U.S.C. §703(a)
50 C.F.R. § 21.11

USEPA REGION 8

7 of 9	TDD No. 0001/17-044


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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Presence species of
wildlife indigenous
to the state that are
determined to be
threatened or
endangered within
the state

"Except as otherwise provided in the Wildlife
Conservation Act [17-2-37 NMSA 1978], it is
unlawful for any person to take, possess, transport,
export, process, sell or offer for sale or ship any
species of wildlife appearing on any of the
following lists:

(1)	the list of wildlife indigenous to the state
determined to be endangered within the state as
set forth by regulations of the commission; and

(2)	the United States lists of endangered native
and foreign fish and wildlife as set forth in
Section 4 of the Endangered Species Act of
1973 as endangered or threatened species, but
only to the extent that those lists are adopted for
this purpose by regulations of the commission;
provided that any species of wildlife appearing
on any of the lists set forth in this subsection,
transported into the state from another state or
from a point outside the territorial limits of the
United States and which is destined for a point
beyond the state, may be transported across the
state without restriction in accordance with the
terms of any federal permit or permit issued
under the laws or regulations of another state or
otherwise in accordance with the laws of
another state."

Action that has potential
impacts on, or is likely to
result in a 'take' of listed
wildlife species -
Applicable

NM Stat. §17-2-41 (C)
Endangered species.

USEPA REGION 8

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Table 3-1 (Continued)

Location-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Location-Specific AUAUs and TIK's

Location
Characteristics

Requirements

Prerequisite

Citation(s)

Presence of New
Mexico State
Endangered Plant
Species

"The taking of plants listed in Section 9 of this Part,
LIST OF NEW MEXICO STATE ENDANGERED
PLANT SPECIES, other than taking under valid
permit issued by the State Forester, is hereby
prohibited.

Actions that have potential
impacts on, or are likely to
result in a 'take'5 of listed
plant species - Applicable

NMAC 19.21.2.15 A.

ARAR = applicable or relevant and appropriate requirement
C.F.R. = Code of Federal Regulations
NM = New Mexico

NMAC = New Mexico Administrative Code

NMSA = New Mexico Statutes Annotated

Stat = statute

TBC = To be considered

U.S.C. = United States Code

5 "Taking" means the removal, with the intent to possess, transport, export, sell, or offer for sale any of the plants listed in Section 9 of this Part, from the places
in the state of New Mexico where they naturally grow. [NMAC 19.21.2.7 C.]

USEPA REGION 8

9 of 9	TDD No. 0001/17-044


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Table 3-2

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation

Urosion and Sediment Control. Control of Radioactive Materials. Reclamation

Protection of
Surface Water
Quality: Control
of stormwater
runoff from
construction
activity

"2.2 EROSION AND SEDIMENT CONTROL
REQUIREMENTS You must implement erosion and sediment
controls in accordance with the following requirements to minimize
the discharge of pollutants in stormwater from construction
activities.

2.2.1 Provide and maintain natural buffers and/or equivalent
erosion and sediment controls for discharges to any receiving
waters that is located within 50 feet of the site's earth disturbances.
Compliance Alternatives. For any discharges to receiving waters
located within 50 feet of your site's earth disturbances, you must
comply with one of the following alternatives: Provide and
maintain a 50-foot undisturbed natural buffer; or Provide and
maintain an undisturbed natural buffer that is less than 50 feet and
is supplemented by erosion and sediment controls that achieve, in
combination, the sediment load reduction equivalent to a 50-foot
undisturbed natural buffer; or If infeasible to provide and maintain
an undisturbed natural buffer of any size, implement erosion and
sediment controls to achieve the sediment load reduction equivalent
to a 50-foot undisturbed natural buffer. See Appendix F, Part F.2
for additional conditions applicable to each compliance alternative.
Exceptions. See Appendix F, Part F.2 for exceptions to the
compliance alternatives."

To be considered by

operators of construction
activities if there are
discharges to Waters of the
United States (WOTUS)
during on-site excavation,
waste consolidation, and
repository construction.

EPA National Pollutant
Discharge Elimination
System (NPDES) 2022
Construction General
Permit (CGP) for
Stormwater Discharges
from Construction
Activities

Part 2. Technology-
Based Effluent
Limitations. Section 2.2.
Erosion and Sediment
Control Requirements,
Subsection 2.2.1.

40 C.F.R. §§ 122.26(a)
and (b), Permit
Applications and
Special NPDES
Program Requirements,
Stormwater Discharges

l'^ j USEPA REGION 8

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation

Radiation
Standards:
Repository Design
and Construction

"Control of residual radioactive materials and their listed
constituents shall be designed to:

(a) Be effective for up to one thousand years, to the extent

reasonably achievable, and, in any case, for at least 200 years,
and....

(d) Each site on which disposal occurs shall be designed and
stabilized in a manner that minimizes the need for future
maintenance."

Relevant and appropriate

to design and construction of
on-site mine waste
repository.

NOTE: These standards
apply to UMTRCA Title I
sites for disposal of uranium
mill tailings left after
uranium ore has been
processed to extract
uranium, resulting in a
different type of waste than
contaminated soil and waste
rock from underground
mining.

Uranium Mill Tailings
Radiation Control Act,
42 U.S.C. §§7918 and
2022, 40 CFR
§§ 192.02(a) and (d)

^ US EPA REGION 6

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TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC ARARs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation

Radiation
Standards:
Repository Design
and Construction

In selecting and designing uranium mill tailings disposal sites,
certain criteria must be considered, including remoteness,
hydrologic and topographic features, potential for erosion and
vegetation. Disposal sites must be covered by an earthen cap, or
approved alternative, that meets certain control requirements,
including limiting the release of radon-222 to the atmosphere.

When the final radon barrier is placed in phases, verification of the
radon-222 release rate must be completed for each portion of the
final radon barrier as it is emplaced. Waste or rock with elevated
levels of radium must not be placed near the surface of disposal
sites. Disposal sites must be closed in a manner that, to the extent
necessary, controls, minimizes, or eliminates post-closure escape of
non-radiological hazardous constituents, leachate, contaminated
rainwater, or waste decomposition products to the ground or surface
waters or atmosphere.

NOTE: Full text of criteria attached at bottom of table.

Relevant and appropriate

to design and construction of
on-site mine waste
repository.

NOTE: These standards
apply to UMTRCA Title I
sites for disposal of uranium
mill tailings left after
uranium ore has been
processed to extract
uranium, resulting in a
different type of waste than
contaminated soil and waste
rock from underground
mining.

Uranium Mill Tailings
Radiation Control Act,
42 U.S.C. §§7918 and
2022, 10 CFRPart 40,
Appendix A. Criteria 1,
4, 6(1), 6(3), 6(5) and
6(7).

Protection of Air
Quality: Fugitive
Dust Control

"20.2.23.109 GENERAL PROVISIONS: No person subject to
this part, shall cause or allow visible emissions from fugitive dust
sources that:

A.	pose a threat to public health;

B.	interfere with public welfare, including animal or plant injury or
damage, visibility or the reasonable use of property.

20.2.23.110 EMISSION LIMITATIONS:

A. No person shall cause or allow visible emissions from the
following fugitive dust sources subject to this part to traverse any

Applicable to control of
fugitive dust from on-site
excavation, waste
consolidation, and repository
construction.

20.2.23 NMAC,
Fugitive Dust Control

^ US EPA REGION 6

3 of 20

TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



exterior property line of the property on which the source is located
for more than a total of five minutes in any consecutive 60 minutes:

(1)	construction or other activity, disturbed surface areas and
inactive disturbed surface areas;

(2)	bulk material handling; or (3) bulk material storage.

B.	Compliance with this condition shall be determined by a visible
emissions test conducted in accordance with reference method 22 in
40 CFR Subpart 60, Appendix A.

C.	Alternative test methods to determine compliance including
opacity observations, visible crust determinations and vegetation
cover determinations, may be approved by the department on a
case-by-case basis.

20.2.23.111 CONTROL MEASURES FOR FUGITIVE DUST
SOURCES AND IMPLEMENTATION: Every person subject to
this part shall utilize one or more control measures included in
20.2.23.111 NMAC or one or more other control measure(s) for
fugitive dust sources under their control as necessary to meet the
requirements of 20.2.23.110 NMAC.

A.	Implementation. Control measures must be implemented
before, after, and during any dust-generating operation, including
during weekends, after work hours and on holidays.

B.	Disturbed surface areas and inactive disturbed surface areas.

Control measures include:

(1) scheduling or phasing of active operations to include
consideration of such factors as time of year and prevailing wind
direction;





^ US EPA REGION 6

4 of 20

TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



(2)	limiting disturbance of natural vegetation;

(3)	application and maintenance of mulch, dust suppressants or
other control measures in accordance with manufacturer's
specifications;

(4)	geotextiles, plastic covers, or erosion control mats or blankets;

(5)	wind fencing;

(6)	landscaping to include xeriscaping, reseeding and conventional
techniques;

(7)	installing permanent perimeter and interior walls;

(8)	restricting public access and use by fencing and signage;

(9)	paving or application of gravel sufficient to prevent fugitive
dust emissions;

(10)	prevention, clean up and removal of track-out material;

(11)	restricting vehicle speed;

(12)	substitution of conveyor systems for haul trucks and covering
of conveyor systems when conveyed loads are subject to wind
erosion; and

(13)	cessation of operations."





Radiation

Protection

Standards:

Radioactive

Material

"Concentrations of radioactive material, which may be released to
the general environment in ground water, surface water, air, soil,
plants or animals, shall not result in an annual dose exceeding an
equivalent of 25 millirems (250 microsieverts) to the whole body,
75 millirems (750 microsieverts) to the thyroid and 25 millirems
(250 microsieverts) to any other organ of any member of the public.
Reasonable effort should be made to maintain releases of

Relevant and Appropriate

to exposure of any member
of the public to radionuclide
contamination.

20.3.13.1317 NMAC,
Protection of the
General Population
from Release of
Radioactivity.

^ US EPA REGION 6

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TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC ARARs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



radioactivity in effluents to the general environment as low as
reasonably achievable."





Radiation
Protection
Standards: Land
Disposal of
Radioactive
Material

"Concentrations of radioactive material which may be released to
the general environment in groundwater, surface water, air, soil,
plants, or animals must not result in an annual dose exceeding an
equivalent of 25 millirems to the whole body, 75 millirems to the
thyroid, and 25 millirems to any other organ of any member of the
public. Reasonable effort should be made to maintain releases of
radioactivity in effluents to the general environment as low as is
reasonably achievable."

Land disposal of radioactive
waste licensed by NRC.
Relevant and appropriate

to exposure of any member
of the public to radionuclide
contamination.

10C.F.R. §61.41,
Protection of the
General Population
from Release of
Radioactivity.

Repository cap

performance

standard

The NESHAP standard for radon-222 emission from uranium
mill tailings piles contained in 40 CFR 40.61 is 20 pCi/m"2 s"1
cover design criteria.

NOTE: OSRTI requested that the cap performance standard also
be evaluated using risk assessment, not just ARARs.

Relevant and appropriate

to limiting radon emissions

from the repository cap once

constructed.

NOTE: See above re:

distinction between uranium

mine and uranium mill

waste.

40 CFR Part 61,
National Emission
Standardsfor
Hazardous Air
Pollutants (NESHAPs).

Response Action

"A. The permit area will be reclaimed to a condition that allows for
re-establishment of a self-sustaining ecosystem appropriate for the
life zone of the surrounding areas following closure unless
conflicting with the approved post-mining land use."

NOTE: Actions required to meet this substantive standard will be
included in Site-specific SOW and Work Plans under CERCLA, not
in closure plan required of state-licensedfacilities.

Post-mining reclamation of
existing, non-coal mining
operations. Relevant and
appropriate to reclamation
of areas disturbed by
excavation necessary to meet
health-based cleanup

19.10.5.507(A) NMAC,
Performance and
Reclamation Standards
and Requirements for
Non-Coal Mining,
Existing Mining

^ US EPA REGION 6

6 of 20	TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation





standards.

Operations

Mining

"New discrete processing, leaching, excavation, storage or stockpile
units located within the permit area of an existing mining
operation.. .must also comply with the standards and requirements
set forth below. Site-specific characteristics, including the existing
mining operation, must be considered in applying the standards and
requirements....

C.	Site Stabilization and Surface Configuration The permit area
shall be stabilized, to the extent practicable, to minimize future
impact to the environment and protect air and water resources. The
final surface configuration of the disturbed area shall be suitable for
achieving a self-sustaining ecosystem or approved post-mining land
use.

D.	Erosion Control Reclamation of disturbed lands must result in a
condition that controls erosion. Revegetated lands must not
contribute suspended solids above background levels to intermittent
and perennial streams....

New Mexico Mining Act
standards for reclamation
plans for new non-coal
mining units may be
relevant and appropriate to
reclamation of on-site areas
disturbed by excavation
necessary to conduct Site
response (excavate
contaminated soils to meet
health-based cleanup
standards; construct mine
waste repository; control
erosion, etc.).

19.10.5.508 (C) and

(D) NMAC, Regulation
of Non-Coal Mining,
New Units

On-Site
Repository
construction and
capping.

3.1 Preferred Methodology The preferred reclamation method is
physical removal of all radiologically contaminated materials above
background value from the site, with disposal of this material to a
monitored disposal facility. This preferred methodology likely
provides a final site reclamation solution to the responsible party
for unrestricted public use to the site. However, the Agencies
recognize that attainment of this standard could require the removal

To be considered - applies
to reclamation by responsible
parties of radionuclide
contamination at legacy
uranium mines in New
Mexico, specific to design
and construction of on-site

MMD & NMED Joint
Guidance for the
Cleanup and
Reclamation of Existing
Uranium Mining
Operations in New

^ US EPA REGION 6

7 of 20	TDD No. 0001/17-044


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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



of a significant volume of materials that probably would include a
considerable amount of soils comprising natural background. Such
removal activity to an appropriate and monitored repository
potentially could incur high reclamation costs, adverse
environmental impacts, and unacceptable safety threat to on-site
reclamation workers.

3.2 Alternative Methodology. Under certain circumstances,
reclamation plans could include disposal of unprocessed ore or
contaminated waste materials into an abandoned underground mine,
particularly in mines where unsaturated conditions are likely to
persist. Alternatively, the responsible party may provide a plan to
construct an on-site, incised disposal repository using an
appropriately engineered cover with shallow slopes. Reclamation
using this alternative methodology should employ a modified store-
and-release cover (also called an evapotranspiration cover). Any
engineered elements of the reclamation plan (e.g., site or waste
impoundment cover system, site drainage channels, etc.) should
provide long-term protectiveness while minimizing maintenance
requirements. The durability of engineered solutions should be
documented by an engineering analysis that incorporates site and
regionally appropriate values for relevant climatic factors (e.g.,
precipitation and wind speed distribution)."

NOTE: Actions required to meet the substantive standards will be
included in Site-specific SOW and Work Plans under CERCLA, not
in the closure/closeout plan required of state-licensedfacilities.

repository.

Mexico (March 2016).
Section 3.0-3.2

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico



ACTION—SPKCINC AUAUs and 1

IK s



Media/Activity

Requirement

Prerequisite

Citation

On-Site
Repository
construction,
capping, and
revegetation.

"4.0 Reclamation Considerations. The type, quality, and thickness
of cover system material chosen will be a critical component of
successful reclamation. The thickness of the material chosen will
also be a critical component. Because of the long half-life of
radioactive materials that may be found at the site, reclamation
must take into account Best Management Practices to address
erosion and stability. Cover material must be of sufficient thickness
and texture to remain in place, and not allow for the re-exposure of
buried TENORM material. While the use of rock armoring has very
good anti-erosion characteristics, the extreme coarseness of the
material does not allow sufficient vegetative growth for the creation
of a self-sustaining ecosystem. Similarly, clays may be added to the
cover design to help in the suppression of gamma activity and radon
gas emissions. However excessive clay is generally not suitable as a
vegetative growth media. To address the need to limit erosion over
long periods of time, the Agencies advocate establishing incised
repositories onsite for disposal of TENORM materials, and capping
the repositories with shallow sloping rock/soil covers. Reclamation
should be performed using a modified store-and-release cover (also
called an evapotranspiration cover) using an overall coarser soil for
erosional resistance combined with additional use of rock armoring
in areas that may be more susceptible to erosion. Re-establishment
of various vegetation such as native grasses and forbs on the cover
will also reduce erosion over time. Post-reclamation hydrology
must be addressed during reclamation in a way that supports
positive drainage away from contaminated areas, minimizes erosion
and prevents re-exposure of buried materials. Another option in

To be considered - applies

to reclamation by responsible
parties of radionuclide
contamination at legacy
uranium mines in New
Mexico, specific
considerations for aspects of
the response.

MMD & NMED Joint
Guidance for the
Cleanup and
Reclamation of Existing
Uranium Mining
Operations in New
Mexico (March 2016,
Section 4.0.

( w J

US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



addressing contaminated material may be to place unprocessed ore
or waste material back into the underground mine, where the
workings are dry. Various materials can be applied as an erosion
control cap to prevent loss of cover from rain and wind erosion.
Since each mining and reclamation project will have unique
characteristics and physical properties, reclamation designs will
have to be evaluated on a case-by-case basis."

NOTE: Actions required to meet the substantive standards will be
included in Site-specific SOW and Work Plans under CERCLA, not
in the closure/closeout plan required of state-licensedfacilities.





On-Site
Repository
construction,
capping, and
revegetation.

"5.4 Reclamation Work Plan Following the submittal of the
characterization report, a site reclamation work plan should be
prepared and should propose a cleanup methodology pursuant to
Sections 2 and 3 of this guidance document.... If the responsible
party proposes to implement an alternative cleanup methodology,
the composition of proposed cover materials should achieve the
specified reclamation radiation performance criterion. The design
should also incorporate features such that the cover will both be
resistant to erosion and degradation without maintenance for the
long-term and reduce infiltration of precipitation to the maximum
extent practicable. Proposed activities under the reclamation work
plan also should include establishment of permanent markers to
delineate the boundaries of the reclaimed mine site area. Finally,
the reclamation work plan also should include a post-reclamation
radiation assessment and sampling program to document attainment
of reclamation goals. The reclamation work plan should also

To be considered - applies

to reclamation by responsible
parties of radionuclide
contamination at legacy
uranium mines in New
Mexico, specifically on
standards to be addressed by
response work, monitoring
future land use, and
recording institutional
controls in public records.

MMD & NMED Joint
Guidance for the
Cleanup and
Reclamation of Existing
Uranium Mining
Operations in New
Mexico (March 2016),
Section 5.4.

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



include a site management plan that provides an anticipated
maintenance schedule or inspection schedule for the site. Because
institutional controls on land usage are not legally enforceable in
New Mexico, the site management plan should also include
reporting of known or reasonably foreseeable changes in land use at
the reclaimed site."

NOTE: Actions required to meet the substantive standards will be
included in Site-specific SOW and Work Plans under CERCLA, not
in the closure/closeout plan required of state-licensedfacilities.





On-Site
Repository
construction,
capping, and
revegetation.

"5.5 Reclamation Summary Report A final reclamation report
should compile a record of all post-reclamation data, engineering
calculations, engineering drawings, and activities that were
conducted during reclamation, and include a tabulation of the
permanent marker locations that delineate the reclaimed mine site
area. As appropriate, this report should be provided to the surface
landowner and recorded with the appropriate county jurisdiction to
establish a permanent record."

NOTE: Reporting is generally considered an administrative, not a
substantive requirement, outside the definition of an ARAR. The
action of recording the report in the appropriate county jurisdiction
to put the public on notice of the completed action is considered
substantive as it will also inform site-specific institutional controls.
Actions required to meet the substantive standards will be included
in Site-specific SOW and Work Plans under CERCLA, not in the
closure/closeout plan required of state-licensedfacilities.

To be considered - applies

to reclamation by responsible
parties of radionuclide
contamination at legacy
uranium mines in New
Mexico, specifically on
recording institutional
controls in public record.

MMD & NMED Joint
Guidance for the
Cleanup and
Reclamation of Existing
Uranium Mining
Operations in New
Mexico (March 2016),
Section 5.5

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation

RCRA Waste

Analysis

Requirements

Subpart C—Characteristics of Hazardous Waste § 261.20 General,
(a) A solid waste, as defined in §261.2, which is not excluded from
regulation as a hazardous waste under §261.4(b), is a hazardous
waste if it exhibits any of the characteristics identified in this
subpart. [Comment: §262.11 of this chapter sets forth the
generator's responsibility to determine whether his waste exhibits
one or more of the characteristics identified in this subpart] (b) A
hazardous waste which is identified by a characteristic in this
subpart is assigned every EPA Hazardous Waste Number that is
applicable as set forth in this subpart. This number must be used in
complying with the notification requirements of section 3010 of the
Act and all applicable recordkeeping and reporting requirements
under parts 262 through 265, 268, and 270 of this chapter, (c) For
purposes of this subpart, the Administrator will consider a sample
obtained using any of the applicable sampling methods specified in
appendix I to be a representative sample within the meaning of part
260 of this chapter. [Comment: Since the appendix I sampling
methods are not being formally adopted by the Administrator, a
person who desires to employ an alternative sampling method is not
required to demonstrate the equivalency of his method under the
procedures set forth in §§260.20 and 260.21.]

Subpart D—Lists of Hazardous Wastes § 261.30 General, (a) A
solid waste is a hazardous waste if it is listed in this subpart, unless
it has been excluded from this list under §§260.20 and 260.22. (b)
The Administrator will indicate his basis for listing the classes or
types of wastes listed in this subpart by employing one or more of
the following Hazard Codes: Ignitable Waste	(I)

Relevant and Appropriate -

the hazardous substances
which are the subject of this
removal action are solid
waste and not hazardous
waste under RCRA because
they are solid waste from the
extraction, beneficiation, and
processing of ores and
minerals, according to 40
CFR § 261.4(b)(7); however,
it is useful in this Site-
specific situation for EPA to
use certain RCRA
procedures to control and
track waste sent off-site.
These procedures will be
used for off-site disposal of
wastes and other
contaminated material
generated during this
removal action.

40 CFR §§261.20 and
261.30

\ USEPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



Corrosive Waste	(C) Reactive Waste

	(R) Toxicity Characteristic Waste ... (E) Acute

Hazardous Waste	(H) Toxic Waste	(T)

Appendix VII identifies the constituent which caused the
Administrator to list the waste as a Toxicity Characteristic Waste
(E) or Toxic Waste (T) in §§261.31 and 261.32. (c) Each hazardous
waste listed in this subpart is assigned an EPA Hazardous Waste
Number which precedes the name of the waste. This number must
be used in complying with the notification requirements of Section
3010 of the Act and certain recordkeeping and reporting
requirements under parts 262 through 265, 267, 268, and 270 of this
chapter, (d) The following hazardous wastes listed in §261.31 are
subject to the exclusion limits for acutely hazardous wastes
established in §261.5: EPA Hazardous Wastes Nos. F020, F021,
F022, F023, F026 and F027.





RCRA

Manifesting

Requirements

Subpart B—The Manifest § 262.20 General requirements, (a)(1) A
generator who transports or offers for transport a hazardous waste
for offsite treatment, storage, or disposal, or a treatment, storage,
and disposal facility who offers for transport a rejected hazardous
waste load, must prepare a Manifest (OMB Control number 2050-
0039) on EPA Form 8700-22, and, if necessary, EPA Form 8700-
22A, according to the instructions included in the appendix to this
part. (2) The revised manifest form and procedures in 40 CFR
260.10, 261.7, 262.20, 262.21, 262.27, 262.32, 262.34, 262.54,
262.60, and the appendix to part 262, shall not apply until
September 5, 2006. The manifest form and procedures in 40 CFR

Relevant and Appropriate -

the hazardous substances
which are the subject of this
removal action are solid
waste and not hazardous
waste under RCRA because
they are solid waste from the
extraction, beneficiation, and
processing of ores and
minerals, according to 40
CFR § 261.4(b)(7); however,

40 CFR § 262.20 and §
262.21

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



260.10, 261.7, 262.20, 262.21, 262.32, 262.34, 262.54, 262.60, and
the appendix to part 262, contained in the 40 CFR, parts 260 to 265,
edition revised as of July 1, 2004, shall be applicable until
September 5, 2006. (b) A generator must designate on the manifest
one facility which is permitted to handle the waste described on the
manifest, (c) A generator may also designate on the manifest one
alternate facility which is permitted to handle his waste in the event
an emergency prevents delivery of the waste to the primary
designated facility, (d) If the transporter is unable to deliver the
hazardous waste to the designated facility or the alternate facility,
the generator must either designate another facility or instruct the
transporter to return the waste, (e) The requirements of this subpart
do not apply to hazardous waste produced by generators of greater
than 100 kg but less than 1000 kg in a calendar month where: (1)
The waste is reclaimed under a contractual agreement pursuant to
which: (i) The type of waste and frequency of shipments are
specified in the agreement; (ii) The vehicle used to transport the
waste to the recycling facility and to deliver regenerated material
back to the generator is owned and operated by the reclaimer of the
waste; and (2) The generator maintains a copy of the reclamation
agreement in his files for a period of at least three years after
termination or expiration of the agreement, (f) The requirements of
this subpart and §262.32(b) do not apply to the transport of
hazardous wastes on a public or private right-of-way within or
along the border of contiguous property under the control of the
same person, even if such contiguous property is divided by a
public or private right-of-way. Notwithstanding 40 CFR 263.10(a),

it is useful in this Site-
specific situation for EPA to
use certain RCRA
procedures to control and
track waste sent off-site.
These procedures will be
used for off-site disposal of
wastes and other
contaminated material
generated during this
removal action.



^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKC'INC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation



the generator or transporter must comply with the requirements for
transporters set forth in 40 CFR 263.30 and 263.31 in the event of a
discharge of hazardous waste on a public or private right-of-way.

§ 262.21 (a) thru (m) Manifest tracking numbers, manifest printing,
and obtaining manifests.





RCRA Packaging
and Labeling
Requirements

Subpart C—Pre-Transport Requirements § 262.30 Packaging.
Before transporting hazardous waste or offering hazardous waste
for transportation off-site, a generator must package the waste in
accordance with the applicable Department of Transportation
regulations on packaging under 49 CFR parts 173, 178, and 179. §
262.31 Labeling. Before transporting or offering hazardous waste
for transportation offsite, a generator must label each package in
accordance with the applicable Department of Transportation
regulations on hazardous materials under 49 CFR part 172.

Relevant and Appropriate -

the hazardous substances
which are the subject of this
removal action are solid
waste and not hazardous
waste under RCRA because
they are solid waste from the
extraction, beneficiation, and
processing of ores and
minerals, according to 40
CFR § 261.4(b)(7); however,
it is useful in this Site-
specific situation for EPA to
use certain RCRA
procedures to control and
track waste sent off-site.
These procedures will be
used for off-site disposal of
wastes and other
contaminated material
generated during this

40 CFR § 262.30 and §
262.31

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

ACTION—SPKCINC AUAUs and 1 IK s

Media/Activity

Requirement

Prerequisite

Citation





removal action.



ARAR = Applicable or Relevant and Appropriate Requirement
CFR = Code of Federal Regulations
CAA = Clean Air Act
CWA = Clean Water Act

MMD = New Mexico Energy, Minerals & Natural Resources

Department, Mining and Minerals Division

NMED = New Mexico Environment Department

NM = State of New Mexico

NMAC = New Mexico Administrative Code

RCRA = Resource Conservation and Recovery Act
TBC = To Be Considered

UMTRCA = Uranium Mill Tailings Radiation Control Act
USC = United States Code

Full Text of Uranium Mill Tailings Radiation Control Act, 42 U.S.C. §§7918 and 2022,10 CFR Part 40,
Appendix A. Criteria 1, 4, 6(1), 6(3), 6(5) and 6(7).

Criterion 1 - The general goal or broad objective in siting and design decisions is permanent isolation of tailings and associated
contaminants by minimizing disturbance and dispersion by natural forces, and to do so without ongoing maintenance. For practical
reasons, specific siting decisions and design standards must involve finite times (e.g., the longevity design standard in Criterion 6).
The following site features which will contribute to such a goal or objective must be considered in selecting among alternative
tailings disposal sites or judging the adequacy of existing tailings sites:

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

Remoteness from populated areas;

Hydrologic and other natural conditions as they contribute to continued immobilization and isolation of contaminants from
groundwater sources; and

Potential for minimizing erosion, disturbance, and dispersion by natural forces over the long term.

The site selection process must be an optimization to the maximum extent reasonably achievable in terms of these features.

In the selection of disposal sites, primary emphasis must be given to isolation of tailings or wastes, a matter having long-term impacts,
as opposed to consideration only of short-term convenience or benefits, such as minimization of transportation or land acquisition
costs. While isolation of tailings will be a function of both site and engineering design, overriding consideration must be given to
siting features given the long-term nature of the tailings hazards.

Tailings should be disposed of in a manner that no active maintenance is required to preserve conditions of the site.

Criterion 4 - The following site and design criteria must be adhered to whether tailings or wastes are disposed of above or below
grade.

(a)	Upstream rainfall catchment areas must be minimized to decrease erosion potential and the size of the floods which could
erode or wash out sections of the tailings disposal area.

(b)	Topographic features should provide good wind protection.

(c)	Embankment and cover slopes must be relatively flat after final stabilization to minimize erosion potential and to provide
conservative factors of safety assuring long-term stability. The broad objective should be to contour final slopes to grades which
are as close as possible to those which would be provided if tailings were disposed of below grade; this could, for example, lead to
slopes of about 10 horizontal to 1 vertical (lOh: lv) or less steep. In general, slopes should not be steeper than about 5h: lv. Where
steeper slopes are proposed, reasons why a slope less steep than 5h:lv would be impracticable should be provided, and
compensating factors and conditions which make such slopes acceptable should be identified.

US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

(d) A full self-sustaining vegetative cover must be established or rock cover employed to reduce wind and water erosion to
negligible levels.

Where a full vegetative cover is not likely to be self-sustaining due to climatic or other conditions, such as in semi-arid and arid
regions, rock cover must be employed on slopes of the impoundment system. The NRC will consider relaxing this requirement for
extremely gentle slopes such as those which may exist on the top of the pile.

The following factors must be considered in establishing the final rock cover design to avoid displacement of rock particles by human
and animal traffic or by natural process, and to preclude undercutting and piping:

Shape, size, composition, and gradation of rock particles (excepting bedding material average particles size must be at least cobble
size or greater);

Rock cover thickness and zoning of particles by size; and
Steepness of underlying slopes.

Individual rock fragments must be dense, sound, and resistant to abrasion, and must be free from cracks, seams, and other defects that
would tend to unduly increase their destruction by water and frost actions. Weak, friable, or laminated aggregate may not be used.

Rock covering of slopes may be unnecessary where top covers are very thick (on the order of 10 m or greater); impoundment slopes
are very gentle (on the order of 10 h:lv or less); bulk cover materials have inherently favorable erosion resistance characteristics; and,
there is negligible drainage catchment area upstream of the pile and good wind protection as described in points (a) and (b) of this
Criterion.

Furthermore, all impoundment surfaces must be contoured to avoid areas of concentrated surface runoff or abrupt or sharp changes in
slope gradient. In addition to rock cover on slopes, areas toward which surface runoff might be directed must be well protected with
substantial rock cover (rip rap). In addition to providing for stability of the impoundment system itself, overall stability, erosion
potential, and geomorphology of surrounding terrain must be evaluated to assure that there are not ongoing or potential processes,
such as gully erosion, which would lead to impoundment instability.

^ US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

(e)	The impoundment may not be located near a capable fault that could cause a maximum credible earthquake larger than that
which the impoundment could reasonably be expected to withstand. As used in this criterion, the term "capable fault" has the same
meaning as defined in section 111(g) of appendix A of 10 CFR part 100. The term "maximum credible earthquake" means that
earthquake which would cause the maximum vibratory ground motion based upon an evaluation of earthquake potential
considering the regional and local geology and seismology and specific characteristics of local subsurface material.

(f)	The impoundment, where feasible, should be designed to incorporate features which will promote deposition. For example,
design features which promote deposition of sediment suspended in any runoff which flows into the impoundment area might be
utilized; the object of such a design feature would be to enhance the thickness of cover over time.

(1) In disposing of waste byproduct material, licensees shall place an earthen cover (or approved alternative) over tailings or
wastes at the end of milling operations and shall close the waste disposal area in accordance with a design111 which provides
reasonable assurance of control of radiological hazards to

(i)	be effective for 1,000 years, to the extent reasonably achievable, and, in any case, for at least 200 years, and

(ii)	limit releases of radon-222 from uranium byproduct materials, and radon-220 from thorium byproduct materials, to the
atmosphere so as not to exceed an average release rate of 20 picocuries per square meter per second (pCi/m2 s) to the extent
practicable throughout the effective design life determined pursuant to (l)(i) of this Criterion. In computing required tailings
cover thicknesses, moisture in soils in excess of amounts found normally in similar soils in similar circumstances may not be
considered. Direct gamma exposure from the tailings or wastes should be reduced to background levels. The effects of any thin
synthetic layer may not be taken into account in determining the calculated radon exhalation level. If non-soil materials are
proposed as cover materials, it must be demonstrated that these materials will not crack or degrade by differential settlement,
weathering, or other mechanism, over long-term intervals....

(3) When phased emplacement of the final radon barrier is included in the applicable reclamation plan, the verification of radon-
222 release rates required in paragraph (2) of this criterion must be conducted for each portion of the pile or impoundment as the
final radon barrier for that portion is emplaced....

Criterion 6 -

US EPA REGION 6

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Table 3-2 (Continued)

Action-specific ARARs and TBCs for Non-Time-Critical Removal Action
Tronox Navajo Area Uranium Mines, Section 10 Mine Site
McKinley County, New Mexico

(5) Near surface cover materials {i.e., within the top three meters) may not include waste or rock that contains elevated levels of
radium; soils used for near surface cover must be essentially the same, as far as radioactivity is concerned, as that of surrounding
surface soils. This is to ensure that surface radon exhalation is not significantly above background because of the cover material

(7) The licensee shall also address the non-radiological hazards associated with the wastes in planning and implementing
closure. The licensee shall ensure that disposal areas are closed in a manner that minimizes the need for further maintenance. To
the extent necessary to prevent threats to human health and the environment, the licensee shall control, minimize, or eliminate
post-closure escape of non-radiological hazardous constituents, leachate, contaminated rainwater, or waste decomposition
products to the ground or surface waters or to the atmosphere.

itself....

I US EPA REGION 6

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Table 3-3

Off-Site Transportation and Disposal Pricing
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Company

Landfill/Mill

Miles
(one-way)

Transportation
Costs ($/ton)

Disposal/Processing
Costs ($/ton)

2022 Total
Costs ($/ton)

Comments

Clean Harbors

Truck from Grants, NM
Direct Landfill Disposal

Deer Trail, CO

550

$62.15

$75.00

$137.15

Transportation cost based on
budgetary quote of $5,500 per truck

US Ecology

Truck from Grants, NM
Direct Landfill Disposal

Truck from Grants, NM
Direct Landfill Disposal

Beatty, NV
Grand View, ID

610
870

$237.30
$333.35

Included in
Transportation Costs

$237.30
$333.35

Rail transport is possible but costing
would require additional effort





Historical Cost Indices



January 2022

January 2019

Time Factor

261.6

232.2

1.13

Notes:

1)	Assumed 45,000 pounds per truck load

2)	May need to address questions such as the need for prevailing wage payment for transportation and other contract requirements that could increase costs.

3)	Budgetary quotes were received from US Ecology and Clean Harbors in December 2019.

4)	A price of $130/ton was used in the EE/CA cost estimate, which should allow processing and transport by truck to the Deer Trails Landfill (shown in bold).

5)	Prices adjusted from 2019 to 2022 using Historical Cost Indices from RS Means.

US EPA REGION 6

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Table 4-1
Summary of Analysis of Alternatives
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Removal Alternative

Evaluation Criteria

Protection of Human
Health and the
Environment

Compliance
with ARARs

Short-Term
Effectiveness

Long-Term
Effectiveness and
Permanence

Implementability

Cost
Effectiveness

Alternative"!: No Further
Action

Low - No additional
protection provided.

Not
Applicable

Low - No action.

Low - Does not

provide any
effectiveness or
permanence.

Low - No action.

Low - No action.

Alternative 2:
Excavation and Off-Site

Disposal of
Contaminated Soils at a
Licensed Low-Level
Radioactive Waste
Facility

High - Protection
provided by waste
being placed in an off-
site engineered
repository.

High -
Complies with
ARARs.

Medium -
Disturbance of the
entire waste area
during excavation,

large off-site
transport effort, and
longer time to
implement.

High - Waste is
managed with other

waste at a
processing facility
or landfill permitted
to receive the
waste.

Medium - Readily
implementable.
Administratively and
technically feasible;
however, the large
amount of trucks
needed to maintain
production levels may
be difficult to
schedule.

Low

Alternative 3:
Excavation and
Disposal of
Contaminated Soil at a
Non-Incised On-Site
Repository

High - Protection
provided by waste
being placed in an on-
site engineered
repository.
Maintenance of cap
will be required.

High -
Complies with
ARARs.

High - Disturbance
of the entire waste
area during
excavation,
however all
transport effort is on
site.

Medium - Waste is
managed in an
engineered
repository.
Maintenance of the
cover is required.

Low - Readily
implementable.
Technically feasible,
but administratively
infeasible due to lack
of viable PRP to
conduct long-term
operations and
maintenance.

Medium

Alternative 4: Capping
of Contaminated Soil in
Place

High - Protection
provided by waste
being placed in an on-
site engineered
repository.
Maintenance of cap
will be required.

High -
Complies with
ARARs.

High - Disturbance
of the entire waste
area during
excavation,
however all
transport effort is on
site.

Medium - Waste is
managed beneath
an engineered cap.
Maintenance of the
cover is required.

Low - Readily
implementable.
Technically feasible

but subsurface
contamination is not
addressed by
MARSSIM.
Administratively
infeasible due to lack
of viable PRP to
conduct long-term
operations and
maintenance.

Medium

US EPA REGION §

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Table 4-2

Estimated Risk of Fatalities and Greenhouse Gas Emissions Due to Off-Site Trucking
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico



Truckloads of Waste

Miles Round Trip to
Transport Waste

Truckloads of Fill

Miles Round Trip to
Transport Fill

Total Miles

Estimated Fatalities
due to Off-Site
Trucking1

Estimated
Greenhouse Gas
Emissions due to Off-
Site Trucking 2 (metric
tons C02e)

Alternative 1, No Further Action

0

0

0

0

0

0.00

0

Alternative 2, Excavation and Off-Site Processing and
Disposal of Contaminated Soils at Licensed Low-Level
Radioactive Waste Facility (Clean Harbors, Deer Trail, CO)

2,708

1,100

100

40

2,982,800

0.04

5,308

Alternative 3, Excavation and Disposal of Contaminated Soil
at a Non-Incised, On-Site Repository

0

0

1,008

40

40,320

0.00

72

Alternative 4, Capping of Contaminated Soil in Place

0

0

3,758

40

150,320

0.00

268

Notes:

C02e= Carbon Dioxide Equivalent

1. A rate of 1.51 fatalities per 100 million large truck miles traveled was calculated as shown below using data (2010 - 2019) from the National Center for Statistics and Analysis. (2021, May). Large trucks: 2014 data. (Traffic Safety Facts. Report No. DOT HS 813 110). Washington, DC:
National Highway Traffic Safety Administration (https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/813110).

Fatality Rate per

People Killed in Crashes Large-Truck Miles	100 Million Large-Truck-

Involving Large Trucks	Traveled (millions)	Miles Traveled

2010

3,686

286,527

1.29

2011

3,781

267,594

1.41

2012

3,944

269,207

1.47

2013

3,981

275,017

1.45

2014

3,903

279,132

1.40

2015

4,095

279,844

1.46

2016

4,678

287,895

1.62

2017

4,906

297,593

1.65

2018

5,006

304,864

1.64

2019

5,005

300,050

1.67

Average from 2010 - 2019	1.51 fatalities per 100 million miles traveled

2. Metric tons of C02e per large truck mile traveled was calculated as shown below using data and methods from the EPA GHG Equivalencies Calculator - Calculations and References (https://www.epa.gov/energy/ghg-equivalencies-calculator-calculations-and-references). Carbon
dioxide emissions per gallon of diesel fuel was obtained from the US Energy Information Administration Frequently Asked Questions (http://www.eia.gov/tools/faqs/faq.cfm?id=307&t=ll). Mileage for Combination Trucks (Classification Types 8-13) was obtained from the FHWA
Highway Statistics Table VM-1 based on 2012 and 2013 data (https://www.fhwa.dot.gov/policyinformation/statistics/2013/vml.cfm).

	22.44 lb C02/gallon diesel fuel X	1 C02e X	1	=	0.001780	metric tons C02e	

2,205 lb C02/metric ton C02	0.986 C02	5.8 miles/gallon	miles traveled

USEPA REGION 6

lof 1

TDD No. 0001/17-044


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APPENDIX A
NATURAL RESOURCES EVALUATION REPORT


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This page intentionally left blank.


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Natural Resources Evaluation

Tronox Navajo Area Uranium Mines
Western Geographic Sub Area

McKinley County, New Mexico

Prepared for

US Evi rem mental Protection Agency Region 6
Weston Solutions

cf

Qr
or
<

^dP£SOq,

January 2017


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CONTENTS

INTRODUCTION	1

Proposed Action	1

Methods	1

EXISTING CONDITIONS/PRELIMINARY RECOMMENDATIONS	2

Topography and Climate	2

Soils/Soil Chemistry and Fertility	2

Vegetation	3

Vegetation Summary	3

Historical Photo Comparison	4

Vegetation Transects and Community Discussion	4

New Mexico Noxious Weeds	9

Wildlife	9

Wildlife Summary	9

Wildlife Discussion	10

Grazing/Rangeland Value	14

Federal and State Listed and Otherwise Protected Species	14

Critical Habitat	15

Listed or Otherwise Protected Species Eliminated from Further Analysis	15

Listed or Otherwise Protected Species Evaluated Further	16

Migratory Birds	17

Other Listed Species	17

BLM Sensitive Species	18

New Mexico Heritage Critically Imperiled Species	19

Watershed	20

Waterways	20

Wetlands	20

Watershed Impacts/Recommendations	21

REVEGETATION/SOIL AMMEDMENT SUMMARY	21

SUMMARY OF RECOMMENDATIONS	22

PHOTOS	24

REFERENCES	31

1 :


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APPENDIX A. FIGURES 1-4

APPENDIX B. SOIL CHARACTERISITCS, VEGETATION TRANSECTS, SAMPLES
APPENDIX C. SPECIES LISTS, LOCATIONS


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INTRODUCTION

The US Environmental Protection Agency (USEPA) proposes to initiate mine waste removal on several
former uranium mine sites to reestablish pre-mine habitats and promote restoration to a sustainable arid
grassland ecology. The sites are located within the Ambrosia Lake Sub-District (ALSD) area of the Grants
Mining District of the Western Geographic Sub Area within McKinley County, New Mexico (Figure la in
Appendix D). The reclamation study area consists of former underground uranium mines (Kermac #10,
#23, Mine #24, Homestake Sapin #25) and associated lands. For the purposes of this report, the study
area totals approximately 2,300 acres. It is located in Township 14 North, Range 10 West Sections 10, 11,
15, 22, 23, 24, 25, 26, and Range 9 West; Section 30 30. It appears on the Ambrosia Lake and Goat
Mountain, New Mexico US Geological Survey 7.5-minute quadrangle maps (Figure la). The area is eligible
for abatement activities subject to the Tronox Navajo Area Uranium Mine (NAUM) settlement, and this
study area has been identified as the West Geographic Sub Area.

The Tronox NAUM Area comprises approximately 100 square miles within the ALSD in McKinley County,
New Mexico. The ALSD is located within an area of uranium mineralization that extends approximately
100-miles long and 25-miles wide encompassing portions of McKinley, Cibola, Sandoval, and Bernalillo
counties of New Mexico. The study area is located approximately 17 miles north of Grants, and 5.0 miles
from the intersection of New Mexico State Highways 509 and 605 (Figure la).

Proposed Action

The USEPA proposes to excavate at least 12 inches of top soils throughout the site once reclamation areas
are identified based on soils and vegetation sampling for uranium levels. Scraped areas would be
revegetated and recontoured to restore, to the extent feasible, pre-mining site conditions. Several million
cubic yards of soils (potentially ranging from 1 to 3 feet of removal) over the study area surface could be
removed and disposed of at an approved site outside the study area.

Methods

Existing site conditions as they pertain to natural resources considerations relative to reclamation were
characterized by obtaining field observational data, documented physical site properties, literature review
information, and soil sampling results for the study area.

In-field and desktop investigations were performed. Existing soil and watershed conditions were identified
through a review of federal and state agency reports and webtools. Revegetation, and site
recommendations are tailored to site-specific conditions and based on recommendations from
agricultural and reclamation sources from the vicinity. Federal and state listed, as well as otherwise
protected species were identified through agency database query. Soil and vegetation samples were
collected by Weston Solutions and select results provided for use in generating recommendations for this
report.

Field surveys were performed to identify protected species, wildlife habitat, and vegetative community
types/percent cover and water resources. For the purposes of evaluating natural resources at the site,
approximately 17 percent of the study area (about 400 acres) was targeted for intensive ground surveys
(Figure lb). Other areas were assessed via reconnaissance as feasible, as many areas can be accessed via
vehicle. Field surveys were conducted during September and October of 2016. Full ground surveys were
completed within each survey polygon (Figure lb).


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Fifteen 50-meter long vegetation transects were identified via a random, then arbitrary method within
community. Each transect was read at 1 centimeter intervals to generate an estimate of cover by species
within each community. Along 13 of the 15 transects, vegetation clippings were obtained and soil samples
were taken from 12 inches deep (Weston Solutions 2016). A wildlife trail camera was placed at a pond
location. Wildlife or their sign were identified based on photos or observations, and identification of listed
species or habitat suitable for listed species was provided. Waterways and wetland areas as present within
surveyed areas were addressed. Reconnaissance surveys were completed to characterize those areas
outside the ground survey polygons.

Individuals certified with at a minimum 24-hour hazardous waste operations and emergency response
(HAZWOPER) level of training entered the site. No respiratory personal protective equipment use was
warranted based on low radioactivity levels present at the site.

EXISTING CONDITIONS/PRELIMINARY RECOMMENDATIONS

Topography and Climate

The study area occurs from approximately 6,920 to 7,200 feet in elevation above mean sea level. It is
located east of Little Haystack Mountain and southwest of San Mateo Mesa (Figure la).

Climate summaries for nearby San Mateo, New Mexico indicate that the area is semiarid with a total
average annual precipitation of 8.66 inches. Average monthly maximum temperatures range from 40.6
degrees Fahrenheit (°F) in January to 83.1°F in July. Average minimum monthly temperatures range from
16.0°F in January to 55.3°F in July with freezing being common from November through April. There is
generally a pronounced peak in rainfall during the monsoon months from July to October (Western
Regional Climate Summaries 2016.

Soils/Soil Chemistry and Fertility

Soils at the study area consists of the following US Department of Agriculture (USDA) Natural Resources
Conservation Service (NRCS 2015) map units listed by highest percent occurrence in the study area:
Penistaja-Tintero complex, 1 to 10 percent slopes (soil unit: 205); Marianolake-Skyvillage complex, 1 to 8
percent slopes (soil unit: 210); Hagerwest-Bond fine sandy loams, 1 to 8 percent slopes (soil unit: 220);
Sparank-San Mateo-Zia complex, 0 to 3 percent slopes (soil unit: 230); and Uranium Mined Lands (Soil unit
265).

The NRCS soil data were accessed for more detailed physical and chemical characteristics of area soils
(Appendix A). The study area soils are expected to be comprised of sandy loam and silty clay loam surface
textures, according to NRCS mapping. They are generally well drained; not hydric or slightly hydric;
moderately susceptible to wind and water erosion; and occur more than 200 centimeters from ground
water depth. They are rated "very limited" for ponded reservoirs due to seepage and slope; and have
limited water capacity. The soils at the study area are located more than 200 centimeters from any
restrictive layer (loss of water or air infiltration), except areas in the southern periphery (unit 220), which
are rated at 89 centimeters from such a layer. This is a favorable indicator for successful revegetation.

Soil chemistry and fertility parameters were obtained via laboratory analysis of samples collected from
the site (Weston 2016). Detailed results are provided in Appendix A. In general, analyses indicate that area
soils have low fertility; are low in boron, zinc, and phosphorus; high in calcium, magnesium, and sodium;


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and have a low carbon/nitrogen ratio. While NRCS rating identified an expected pH ranging from 7.7 to7.9
for the study area, the pH of soil samples ranged from 7.9 to 9.0 (Appendix B).

Vegetation

The study area occurs within the Semiarid Tablelands ecoregion (Griffith et al. 2006). This ecoregion is
characterized by dry plains, mesas, valleys, and canyons formed from sedimentary rocks. It supports arid
and semi-arid grasslands, shrub/scrub zones, savannas, and woodlands.

According to Dick-Peddie (1993) the study area occurs primarily within Desert Grassland and Great Basin
Desert Scrub vegetation communities. In the field, the grassland community most closely resembles the
Plains-Mesa Grassland community in structural components, and this is the nomenclature used. The
dominant component communities and associated species present at the study area are discussed in
detail below. Vegetation communities at the site were identified and mapped based on ground surveys
and reconnaissance (Figure 2). Surveys were conducted during late summer and early fall of 2016. In total,
104 species representing 34 families of vascular plants were identified at the study area (Appendix B).

Vegetation Summary

Approximately 2,258 acres within the 2,302-acre study area are estimated to be vegetated. The
unvegetated areas were occupied by rock-covered slopes, roads, or other human-made features. The
study area is generally flat and for the most part lacks microhabitat conditions associated with aspect or
slope. It is dominated by large expanses of a mixture of Great Basin Desert Shrub communities and Plains
Mesa Grassland. In some areas, these communities intermix forming an ecotone Shrubby Grassland
community dominated by grasses but often with a diffuse distribution of shrubs. Warm season grasses
dominate the grassland communities. Only 3 of the 21 species of grasses documented on the site [western
wheatgrass (Pascopyrum smithii), foxtail barley (Hordeum jubatum), and squirrel-tail (Elymus elymoides)]
were cold season species. Both the wheatgrass and foxtail barley were found principally in the riparian
areas, squirrel tail was scattered in the grasslands and in the riparian habitats.

Many factors (disturbance, soil texture, soil nutrient content, and aspect) influence vegetation
composition; however within the relatively flat study area, soil texture appears to be an important
determinant of community type. The distribution of the grassland communities closely overlaps the
location of the fine loamy Penistaja Series soils (Appendix B). Many Great Basin Desert Scrub communities
occurred on the clay loams or clay soils, of the Sparank-San Mateo-Zia Complex.

Woodland and savanna communities are uncommon in the study area and contribute less than 1 percent
of the total vegetation cover.

Arroyo riparian vegetation occurs within the channels and active floodplains of all ephemeral waterways
within the study area. All these drainages are historically tributaries of Arroyo del Puerto. The vegetation
within these drainages is codominated by a mixture of shrubs and grasses. Although widespread across
the study area, these Arroyo Riparian communities account for only about 1 to 2 percent of the total
vegetation cover.

In aggregate, the grassland, shrubland, savanna, woodland, and riparian vegetation types form 8 distinct
natural plant communities/series (Table 1). A disclimax (weedy vegetation) area occurs in the southeast
corner of the study area. The plant community series were identified following Dick-Peddie (1993), except
when no applicable series has been published and adapting was necessary.

3


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Historical Photo Comparison

A historic aerial photograph of the study area from 1954 was compared with current study area
conditions. Substantial changes in vegetation communities were noted. The Juniper Savanna habitat,
which currently just enters the western edge of the study area in Section 22, extended about % mile
eastward in 1954 into the northeast % of Section 22. Pronounced surface scraping visible on current aerial
photography suggests that these trees were removed by mining operations.

Coniferous woodland located in the southern portion of Section 22 has the exactly the same footprint in
1954 as currently observed. The only difference is that the tree density within this community has
increased since 1954.

Based on the density and extent of vegetation observed on the 1954 photographs, the historic waterway
system appears to have been much less incised, with water spilling across a broader floodplain than what
currently exists. Areas of channels that were incised in 1954 appear to have supported much denser
vegetation than currently exists. Finally, 5 stock ponds currently occur along the main channel of Arroyo
del Puerto extending from the western edge to the eastern edge of the study area. None of these ponds
were present in 1954.

Grasslands were far more abundant and contiguous in 1954. The large patch of grassland that currently
dominates Section 24 extended southward to cover most of Section 25 in 1954. Additionally, most of
Section 30 appears to have been covered by grassland. Both of these areas now support a
grass/rabbitbrush community.

Great Basin shrub communities appear to have been present in 1954. Shrubs appear to have dominated
the sheet-flow flood zones that parallel the arroyos. Shrub communities mixed with pockets of grassland
also covered Sections 23 and 26. Today these areas still support these communities, but the shrubs are
more abundant today and appear to dominate in areas that had been subject to surface disturbance.

To restore to 1954 conditions, grassland habitats would have to be expanded throughout much of the
study area and the waterways would have to be restored to a more free-flowing condition.

Vegetation Transects and Community Discussion

Percent cover and species composition data were collected from 1-centimeter intervals along 50-meter-
long vegetation transects (Table 1, Figure 2). Fifteen transects were used. The final placement of transects
was based on a stratified, arbitrary, random technique, with the general location of transects being
selected randomly, but the final placement being arbitrary to best reflect the typical vegetation structure
within the community.

An estimate of percent absolute cover was calculated for all species present within transects. The
compiled data from each transect is provided in Appendix B (accompanied by the soil sample number
collected from 13 or 15 transects). Table 2 presents a compilation by community type.

Some plant communities were so large that multiple transects were required. In communities where
multiple transects occurred, the data were combined. Five community types presented in Table 2 are the
results of combined transects. Communities are discussed in detail by type.


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Table 1 - Area of Dominant Plant Communities and Associated Transects

COMMUNITY TYPE

SERIES: PRINCIPAL COMPONENT VEGETATION

EST.
ACRES

TRANSECTS

Plains-Mesa Grassland

Blue Grama/Galleta

763.26

1, 2, 4, 12, 13

Shrubby Grassland
(Ecotone)

Blue Grama /Galleta/Saltbush

260.11

4,9

Great Basin Desert Scrub

Saltbush/Blue Grama/Galleta

565.7

9, 10, 11

Rabbitbrush/ Blue Grama/Galleta (Grassy
Rabbitbrush Scrub)

454.75

3, 15

Saltbush/Dropseed/Snakeweed/Annuals

130.78

5

Juniper Savanna

One-seed Juniper/Galleta

4.78

6

Coniferous Woodland

One-seed Juniper/Pinyon Pine/Bigelow Sage

0.90

7

Arroyo Riparian

Rabbitbrush/Saltbush/Galleta

33.09

8, 14

Disclimax

Summer Cypress (Invasive Weed)

45.30

None

Plains-Mesa Grassland

Plains-Mesa Grassland is the largest plant community in the study area, covering approximately 763 acres.
It is concentrated in Township 14 North, Range 10 West, in the center of Section 24; the northeast and
southeast corners of Section 25; the northwest corner of Section 26 and within Section 10. This
community supported over 40 percent absolute vegetation cover (Table 2), and was heavily dominated
by blue grama (Bouteloua gracilis) and galleta (Pleurapis jamesii). Together these 2 grasses accounted for
75 percent of the vegetative cover. Secondary grasses such as ring muhly (Muhlenbergia torreyi), Wright's
muhly (Muhlenbergia wrightii), and spike dropseed (Sporobolus contractus) were present, but appeared
infrequently and accounted for little more than 1.5 percent of the overall vegetative cover.

Shrubs appeared sporadically, with winterfat (Krascheninnikovia lanata) being the most common, and
four-wing saltbush (Atriplex canescens), and horsebush (Tetradymia canescens) being thinly distributed,
often in small localized enclaves. Ecologically this community type is important as nearly all the Gunnison's
prairie dog towns in the study area occur within Plains-Mesa Grassland, and concurrently the documented
western burrowing owls were within these prairie dog towns.

Shrubby Grassland (Ecotone)

The Shrubby Grassland Ecotone community occurs principally in the western third of the study area in
Section 22, with a smaller piece of this community occurring near the southeast corner of Section 30. At
both locations, this community occurs mostly within the overlap zone of Great Basin Shrub and Grassland
communities, and the vegetation is a mixture of both. This entire community is patchy in nature often
with small stands of grassland interrupted by enclaves of four-wing saltbush or other subshrubs.
Vegetative cover was over 40 percent with nearly half of this cover composed of blue grama and nearly a
quarter from four-wing saltbush. Portions of this community also support Gunnison's prairie dog colonies.

Great Basin Desert Scrub

Shrub communities dominate the Great Basin. Depending upon moisture, temperature, and soils, these
communities can vary in composition. Within the study area, 3 Great Basin Desert scrub communities
were defined, all of which had either four-wing-saltbush or rabbitbrush as their principal shrub
components, and all of which had substantial grass cover. The most abundant of these communities was
dominated by Saltbush/Blue Grama/Galleta. It covered over 500 acres and was found within the
southwest corner of Section 24; the southern portion of Section 23; the northern portion of Section 2;

ST (

1

*


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and the northwest corner of Section 25. The proportion of saltbush to grasses within this community
varied across the study area, but overall saltbush accounts for nearly half of the overall vegetative cover.
In addition to the native shrubs and grasses, the nonnative weed summer cypress (Bassia scoparia) also
was abundant, accounting for nearly a quarter of the total vegetative cover within this community.

The second most abundant of the Great Basin Scrub communities was dominated by rabbitbrush/blue
grama/galleta. This community is concentrated along the eastern edge of the study area within: Section
30 and Section 24. A portion also occurs within Sections 22 and 10. This community has nearly 60 percent
vegetative cover with a third of it from rabbitbrush and another third from blue grama. The remaining
third is composed principally of a mixture of grasses such as galleta, Wright's muhly, and dropseed
(Sporobolus) species. Along its margins, the shrub component of this community thins and intergrades
into Plains Mesa Grassland.

The last of these Great Basin Shrub communities is dominated by four-wing saltbush intermixed with
dropseed and snakeweed (Gutierrezia sarothrae). This community is confined to northwest corner of the
study area within Section 15. It has some of the lowest overall vegetative cover in the study area
(approximately 25.9 percent) and more than half of this cover is derived from annual weedy species.
Fourwing saltbush accounts for about a quarter of the cover and of all the remaining grasses -less than a
quarter. This site appears to have suffered substantial surface disturbance in the past and is not fully
recovered.

Juniper Savanna

The Juniper Savanna community is limited to the western edge of the study area within Section 22. It is
dominated by one-seed juniper (Juniperus monosperma) and covers less than 5 acres of the study area. It
had the lowest overall vegetative coverage (22.4 percent) of the communities. Grasses accounted for
more than half of this cover and Junipers about 3.6 percent. This community is located adjacent to the
most persistent water source and is heavily grazed. Although it occupies a small area relative to other
communities, it provides tree structure to the western half of the study area.

Coniferous Woodland

A tiny sliver of woodland community (less than an acre in size) extends into the study area within Section
22. Like the Juniper Savanna, this woodland habitat has low vegetative cover (27.12 percent) with nearly
half of the vegetative cover dominated by grasses. The pinyon (Pinus edulis) and one-seed juniper trees
account for less than a third of the cover. Although very small, the community is important in that it
provides the only trees in the southwestern portion of the study area.

Arroyo Riparian

A series of ephemeral waterways, all historic tributaries of Arroyo del Puerto, cross the study area. Many
convey surface water runoff as sheet flow that can spread across broad areas. Human intervention has
altered or curtailed the flows of these waterways. Berms have been installed across many segments of
Arroyo del Puerto interrupting stormwater surges and collecting the runoff in stock ponds. Approximately
33 acres of this Arroyo Riparian community type is spread out in linear form across approximately 4 miles
of the study area. With the exception of small segments of waterways in the sections 10 and 30, remaining
Arroyo Riparian habitat is confined to sections 22, 23, 25, and 26.

The Arroyo Riparian community consists of vegetation within waterway channels, as well as the various
ponds. The dominant vegetation within the active channels was consistent across all arroyo segments.
Usually it was dominated by rabbitbrush and western wheat grass. Together, these species account for

16

*


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more than 50 percent of the vegetative cover in the arroyos. In some locations, four-wing saltbush can be
locally abundant, but most remaining vegetative cover varies among a dozen species of grasses and herbs
such as gumweed (Grindelia nuda), galleta, and purple aster (Machaeranthera canescens).

Stock ponds along channels are dominated by weedy vegetation such as summer cypress with small
amounts of MacDougall verbena (Verbena Macdouglii) and western wheat grass often occurring along
the edge of the ponds. Satellite aerial photography from 1996 to 2014 and field observations suggest that
these ponds (with one exception) rarely have water present. The exception is a stock pond located in
Section 22. This pond is collecting runoff directly from nearby steep slopes. The dominant vegetation was
knotweed (Polygonum aviculare), spike rush (Eleocharis sp.), foxtail barley, marsh aster (Aster subulatus),
and curly dock (Rumex crispus). Nearly all these plants are wetland indicator species. Surface water was
present throughout September and most of October 2016 when the other ponds were dry.

Disclimax

An area of approximately 45 acres located in the southeast corner of the study area within Section 30 is
dominated by the invasive annual weed summer cypress. This annual weed can choke out other
vegetation leaving an unproductive habitat for wildlife. Since the overwhelming dominant within this area
was an annual invasive weed, vegetation cover data was not collected.

Table 2 - Species/Approximate Percent Cover at Vegetation Transects

VEGETATION COMMUNITY AND SERIES

PLANT SPECIES

TRANSECTS

PERCENT COVER

Plains Mesa Grassland



1,2,4,12,13





Bouteloua gracilis

26.57



Pleuraphis jamesii

5.5



Bassia scoparia

2.02



Salsola tragus

1.74



Krascheninnikovia lanata

1.27



Artemisia bigelovii

1.16



Muhlenbergia wrightii

1.02



At ripi ex canescens

0.97



Muhlenbergia torreyii

0.66



Tetradymia canescens

0.192



Sporobolus contractus

0.08



Gutierrezia sarothrae

0.05



Elymus elymoides

0.03





Total: 41.26



Shrubby Grassland (Ecotone)



4,9





At ri pi ex canescens

12.2



Bassia scoparia

4.81



Pleuraphis jamesii

3.40



Bouteloua gracilis

20.25



Muhlenbergia torreyi

1.47





Total: 42.13



Great Basin Desert Scrub -
(Saltbush/Blue Grama/Galleta)



9,10,11





At ri pi ex canescens

20.4


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VEGETATION COMMUNITY AND SERIES

PLANT SPECIES

TRANSECTS

¦

PERCENT COVER



Bassia scoparia



8.56



Bouteloua gracilis

8.3



Pleuraphis jamesii

2.16



Panicum obtusum

1.94



Elymus elymoides

1.64



Grindelia nuda

0.27



Pascopyrum smithii

0.26



Gutierrezia sarothrae

0.21



Scleropogon brevifolius

0.1



Sporobolus airoides

0.08





Total: 43.92



Great Basin Desert Scrub - (Rabbitbrush/
Blue Grama/Galleta (Grassy Rabbitbrush
Scrub)-



3,15





Bouteloua gracilis

22.69



Ericameria nauseosa

22.12



Pleuraphis jamesii

6.77



Grindelia nuda

2.22



Pascopyrum smithii

1.57



Muhlenbergia wrightii

1.39



Gutierrezia sarothrae

0.87



Bassia scoparia

0.83



Sporobolus airoides

0.63



Sporobolus contractus

0.03 1





Total: 59.12



Great Basin Desert Scrub-
(Saltbush/Dropseed/Snakeweed/Annuals)



5





Machaeranthera
canescens

8.38



Atriplex canescens

6.18



Salsola tragus

4.16



Gutierrezia sarothrae

2.24



Bassia scoparia

1.86



Pascopyrum smithii

1.42



Sporobolus contractus

1.70





Total: 25.94



Juniper Savanna



6





Pleuraphis jamesii

6.94



Sporobolus airoides

3.98



Juniperus monosperma

3.6



Atriplex canescens

2.52



Krascheninnikovia lanata

1.62



Gutierrezia sarothrae

1.36



Bouteloua gracilis

1.2



Aristida purpurea

0.9

1

* >4^^


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VEGETATION COMMUNITY AND SERIES

PLANT SPECIES

TRANSECTS

PERCENT COVER



Acnatherum hymenoides



0.3





Total: 22.42



Coniferous Woodland



7





Bouteloua gracilis

13.90



Juniperus monosperma

6.88



Artemisia bigelovii

4.58



Krascheninnikovia lanata

0.96



Pleuraphis jamesii

0.52



Erigeron sp

0.28





Total: 27.12



Arroyo Riparian



8,14





Ericameria nauseosa

14.06



Pascopyrum smithii

12.28



Grindelia nuda

6.58



Atriplex canescens

3.88



Pleuraphis jamesii

2.64



Bassia scoparia

2.13



Machaeranthera
canescens

1.94



Bouteloua gracilis

1.76



Sporobolus airoides

1.44



Bouteloua hirsuta

0.12



Gutierrezia sarothrae

0.11



Ambrosia acanthicarpa

0.06





Total: 47.00

New Mexico Noxious Weeds

The following three New Mexico Department of Agriculture Category C noxious weeds species were
observed in the study area: saltcedar, Russian olive, and Siberian elm. None of these occurred in
abundance. Siberian elms are mostly confined to the main paved access route that bisects the site.

Russian olive is represented by a handful of trees that are widely scattered. One salt cedar occurs at the
pond in Section 22 other diminutive specimens were observed along the waterways. No special treatment
of these weeds is recommended.

To prevent establishment of weeds during the revegetation process, it is recommended that the
contractor be required to wash all machinery prior to each site entry (if equipment is used at other sites
during the reclamation process) and upon leaving the site to reduce likelihood of transporting seeds into
and from the site. In addition, the application of mulch would reduce weedy species establishment.

Wildlife

Wildlife Summary

Several common species or their sign were observed within the study area. A list of species observed
onsite, as well as those expected to occur there based on other area surveys, is provided in Appendix B.


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Eleven species of mammals or their sign, including elk, mule deer, gophers, rabbits, kangaroo rats, prairie
dogs, mountain lion, and coyote were observed. Large prairie dog towns occur in and around the study
area. It is likely that bats roost within the cliff faces present nearby and hunt at stock ponds since the
presence of water would support insects. Migratory Myotis species would be expected to roost in cliffs
from March through October, and would be active at the ponds at night.

Thirty-six species of birds were observed, including residents such as: quail and roadrunner; songbirds
such as sparrows, juncos, towhee, and meadowlark; insect hunting species such as flycatchers, shrikes,
and phoebes; waterfowl and wading birds, and several birds of prey including hawks, falcons, eagles, and
owls. Many other species of songbirds and raptors are likely present in the area during migration and
nesting seasons.

Five reptiles were observed including three snakes and two lizards. Amphibians were not observed, but
at least two species are expected in the area.

It is recommended that nearby cliff and rock outcrop areas and pinyon/juniper woodlands be avoided
during proposed reclamation activities, which would harm these areas rather than improve them.
Avoidance of perch trees for raptors is also recommended. Prairie dogs colonies support burrowing owl
nests. Vegetation clearing, especially in areas that support owl burrows, should be limited to the late fall
and winter months (October to February).

Wildlife Discussion

In total, 53 vertebrate species were observed during the surveys of the study area (Appendix C), including
a wide range of birds with both upland and waterfowl species present. Based on the species list collected
on other surveys in the area, approximately 70 species of vertebrates could be present within the study
area. There are large populations of burrowing mammals present. Gunnison's prairie dog colonies cover
hundreds of acres within the area.

There are also some elk and mule deer, as well as large predators such as mountain lion and coyote
present, all of which are likely to leave the area during construction.

Birds

The survey was conducted late summer into the fall, and many more species, especially during spring
migration, are likely to occur in the study area during the breeding season. Overall, birds were not present
in great abundance. One possible reason for low bird population levels is the general lack of vertical
structure at the site. Aside from four-wing saltbush and rabbitbrush, hardly any shrubs above knee height
are present, excluding the small enclaves of juniper and pinyon trees along the extreme western end of
the study area. The remaining trees are principally Siberian elms along the main entrance road with a few
Russian olives and salt cedars.

Most birds observed occurred in small flocks within shrubby stands of four-wing saltbush and rabbitbrush,
or flyovers. Non-migratory resident birds, such as scaled quail (Callipepla squamata) and roadrunner
(Geococcyz californianus), were diffusely spread across the study area mostly in the shrub/grassland
ecotone areas.

Within the grassland habitats, birds represented by species such as horned larks (Eremophila alpestris),
vesper sparrow (Pooecetes gramineus), and the occasional western meadowlark (Sturnella neglecta).

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The brushy habitats supported a variety of sparrows including chipping sparrow (Spizella passerine),
Brewer's sparrow (Spizella breweri), wintering white-crowned sparrow (Zonotrichia leucophrys), dark-
eyed junco (Junco hyemalis), and loggerhead shrike (Lanius ludovicianus).

The greatest diversity of birds occurred at the stock pond located within Section 22. The presence of water
throughout September and October not only provided a water source for upland birds but also supported
the use of shore birds and waterfowl such as great-blue heron (Ardea Herodias), killdeer (Charadrius
vociferous), mallard (Anasplatyrhynchos), gadwall (Anasstrepera), northern shoveler (Anas clypeata), and
northern pintail (Anas acuta). More than half the birds observed in the study area occurred at or near the
wet stock pond, and the waterfowl and shorebirds were found only at this pond.

The following 5 bird-of-prey species were observed within the study area: golden eagle (Aquila
chrysaetos), northern harrier (Circus cyaneus), western burrowing owl (Athene cunicularia), American
kestrel (Falco sparverius), and prairie falcon (Falco mexicanus). One species that was expected, but not
observed, was red-tailed hawk (Buteo jamaicensis). However, based on other surveys of the general area,
this species is likely to be present. The American kestrel, prairie falcon, and northern harrier appeared to
be fly-overs. Aside from hunting, very little suitable habitat was observed in the survey area.

Golden eagles were observed onsite during every visit. At least 3 different golden eagles were present.
The large prairie dog colonies within the area provide an excellent prey base for this species, and on two
occasions golden eagles were observed perching on the Siberian elm trees along the main paved access
road at the eastern edge of the study area (figures 3a,3b). There is no suitable nesting habitat present for
golden eagle within or immediately adjacent to the study area, but suitable nesting habitat does occur on
east facing cliffs along the east side of Little Haystack Mountain located within Section 20; which is
approximately 1.5 miles west of the western edge of the study area, and Mesa Redonda, which is
approximately 1.9 miles to the west (Figure 3b). Multiple large whitewash areas that could be golden
eagle nest sites were observed along this cliff face.

Additional suitable nesting habitat for golden eagle was also observed on multiple cliff faces within
Sections 34, 35, and 36 of Township 15 North, Range 10 West, and within sections 1, 2, and 3 of Township
14 North, Range 10 West.

This habitat occurs between 1.5 and 2.0 miles north of the portion of the study area within Section 10.
Some whitewash was noted present these cliffs, but no specific areas appeared to support an active
golden eagle nest site. Golden eagles are reported to hunt on a daily basis in a 7-mile radius around their
nest sites and any potential golden eagle nesting habitat in the general area would be close enough for
their use of the study area, which supports a prey base.

Western burrowing owls are a ground-dwelling species that usually occupy burrows created by mammals
such as prairie dogs. During the nesting season, they can use several burrows, moving their young from
burrow to burrow, as they mature. These burrows are usually clustered in tight proximity and, for the
purpose of this report, clustered burrows (that were used by burrowing owls in 2016) are referred to as
activity areas. During the course of the survey, 6 of these burrowing-owl activity areas were identified
that in aggregate contained 16 burrows used by burrowing owl (Figure 2, Appendix C). During the survey,
western burrowing owls were observed within 3 of these activity areas. All the owls observed occurred
within Gunnison's prairie dog towns and nearly all of them occurred within the Plains Mesa Grassland
community type. The 3 western burrowing owls observed during the survey were located near burrows

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1, 2, and 9 (Appendix C). Since surveys were not completed for the entire area, it is likely that many
additional owls were present in the study area but were not identified.

Mammals

Eleven species of mammals were observed in the survey area, and based on surveys of nearby areas,
others would be expected. The larger mammals present included both herbivores and predators. At the
time of the survey, elk (Cervuus elaphus) were active in the western portion of the study area. Mule deer
(Odocoileus hemionus) tracks and droppings were observed along the western edge of the study area.
Tracks of both of these species were observed at the stock pond in Section 22. Elk were photographed on
a wildlife camera at this location. Both these species could occur anywhere within the study area.

There were no observations or sign of bobcat (Lynx rufus) or gray fox (Urocyon cinereoargenteus), but
both are expected in the general area. Mountain lion (Puma concolor) and coyote (Canis latrans) were
present. Tracks of a solitary (likely juvenile) mountain lion were observed at the stock pond within Section
22. A rancher, who uses the study area, stated that in 2016 a female mountain lion and 2 nearly adult
cubs were observed along the edge of savanna/woodlands on the west side of the study area in Section
22. Coyote observations and signs (scat and tracks) occurred in all plant communities within the study
area. Most large mammals (both herbivores and predators) are likely to leave the area when reclamation
begins and return when vegetation has developed sufficiently to provide cover and a prey base.

The presence of small burrowing mammals within the study area is important to the restoration process
in that they provide the potential for soil mixing deep below the surface. The most likely species to do this
within the study area are the banner-tailed kangaroo rat (Dipodomys spectabilis) and Gunnison's prairie
dog (Cynomys gunnisoni). Banner-tailed kangaroo rats were present, but sporadic in their distribution,
occurring primarily within the Plains Mesa Grassland and the Great Basin Desert Scrub - Rabbitbrush
Grassland habitat. Kangaroo rats are strictly nocturnal and are not easily observed.

Although their activity level drops in the winter, they have been reported to be active on warm days.
Banner-tailed kangaroo rats have complex burrow systems that can exceed 1 meter in depth (Gano and
States 1982) and extend outward for several meters from the center of the mound. The centralized mound
associated with the burrow system often exhibits substantial amounts of soils mixing from collapsed
burrows. Much of the burrow system for typical banner-tailed kangaroo rat mounds is likely to occur
below the 12-inch deep soil removal zone.

Many rats may survive the soil removal by remaining in their deep burrows. However, with the removal
of vegetative surface cover above the burrow, no surface food will be available for quite some time.
However, banner-tailed kangaroo rats often maintain multiple granaries in the lower parts of the burrow
systems. These granaries can have 2 to 8 pounds of grain stored in them. It is likely that after the soil
removal the banner-tailed kangaroo rats that survived the process will be able to persist for some time
on their stored grains and may be able to hang on long enough for the new growth from the seed material.

Gunnison's prairie dogs can have a much larger subsurface footprint than banner-tailed kangaroo rats.
Their burrow systems can be several meters deep and can extend outward more than 10 meters. The
deep and steeply aligned burrows of Gunnison's prairie dogs allow points for surface soils to be conveyed
downward, well below the surface. Gunnison's prairie dog burrow systems are much deeper than the
proposed soil removal level and active burrow systems are likely to persist through the soil removal

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process. However, unlike the banner-tailed kangaroo rat, Gunnison's prairie dogs do not maintain
granaries and may not survive the removal of vegetation. Gunnison's prairie dogs were widespread and
abundant, covering at least 473 acres or approximately 20 percent of the entire study area (Figure 3a).
Spot checks around the periphery of the area verified that the Gunnison's prairie dogs extend far beyond
the study limits and would likely return to the site when vegetation has reestablished. Prairie dogs are a
keystone species, providing habitat for a variety of other species such as the western burrowing owl,
reptiles, and other mammals. Their colonies within the study area are wholly confined to the grassland
habitats, concentrated in Sections 23, 24, 25, and 26.

Rough field estimates suggested that approximately 10 to 15 percent of the burrows within these colonies
were active at the time of the survey.

Other burrowing animals observed within the study area included Ord's kangaroo rat (Dipodomys ordii)
and Botta's pocket gopher (Thomomys bottae). Ord's kangaroo rats are much smaller than banner-tailed
kangaroo rats, and, consequently, their burrows are smaller (rarely over 3 inches in diameter). Although
their burrow systems may reach as deep as the banner-tailed kangaroo rat, there are fewer burrows
present. Ord's kangaroo rats were locally common in areas with firm soils within the grassland habitats
throughout the study area. The Ord's kangaroo rat burrows are small but deep enough to extend below
the soil removal zone, and many are likely to survive the soil removal process. Like the banner-tailed
kangaroo rat, they also maintain granaries.

Botta's pocket gopher appeared sporadically in the study area, mostly in areas of looser soil. Pocket
gophers generally have shallow burrows, which are usually less than 1 meter deep and often much more
shallow, are generally only 5- to 35-centimeters deep but can be upwards of 45 meters in length (Gano
and States 1982). It is likely that most Botta's pocket gopher burrows would be taken by the soil removal
process.

Both cottontail (Sylvilagus auduboni) and black-tailed jackrabbit (Lepus californicus) were present and
widespread but did not occur in great abundance. Their burrow systems are deep enough to be unaffected
by the proposed soil removal. Those near the periphery of the study area are likely to move into adjacent
vegetated habitats when surface clearing begins.

Reptiles and Amphibians

Six species of reptiles were observed within the study area. Most common were the plateau striped
whiptail (Aspidoscelis velox) and the southwestern lizard (Sceloporus cowlesi). The plateaus striped
whiptail was found within most egetation communities in the study area. A prairie rattlesnake (Crotalus
viridis) and bull snake (Pituophis catenifer) were also observed. The most uncommon reptile observation
was a wandering (western terrestrial) garter snake (Thamnophis elegans vagrans), which was observed
only at the stock pond within Section 22.

There were no amphibians present during the survey. However, the stock pond habitat is suitable for tiger
salamander (Ambystoma tigrinum), and it is likely that spadefoot toads (Spea multiplicata) could also be
present. The observed reptiles have the capacity to flee short-distances and many may move to the edge
of removal areas, but suitable habitat for their reoccupation of the site would not be available until
vegetation is reestablished.


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Grazing/Rangeland Value

The NRCS soil data were accessed for expected range production characteristics of area soils (Appendix
B). Range production ratings are given in pounds per acre per year. Ratings are provided for a normal year,
favorable year, and unfavorable year, respectively.

The most common soil unit present within the study area moderately well rated for range production:
Penistaja-Tintero complex, 1 to 10 percent slopes (soil unit: 205): 953, 1359, 547.

The second most common soil unit present within the study area is well rated for range production:
Sparank-San Mateo-Zia complex, 0 to 3 percent slopes (soil unit: 230): 2177, 3557, 1102.

The remaining soil units are rated as follows: Marianolake-Skyvillage complex, 1 to 8 percent (soil unit:
220): 813, 1200, 416; Hagerwest-Bond fine sandy loams, 1 to 8 percent slopes (soil unit: 230): 794, 1171,
407; Uranium mined lands (soil unit: 265) are not rated for range production.

According to NRCS Rangeland productivity and plant composition expectations for the study area soils,
blue grama and western wheatgrass would be expected to comprise approximately 40 percent of the
characteristic vegetative grass cover for based on soils and ecological identification. Field observations
generally support expectations for blue grama in terms of composition, but western wheatgrass
expectations are not supported. Generally, winterfat coverage is lower and rabbitbrush is higher than
expected. Overall, grass coverage is lower than expected, based on soils and ecological site identification.
Successful revegetation would be expected to increase range production at the site significantly in some
areas and result in little change in others.

It is recommended that a five-year target composition and percent cover be identified to determine
whether the effort is successful at meeting objectives. The site should be surveyed during the late summer
(September) of the third year after planting to determine percent cover, species composition, and wildlife
use as compared to the existing condition and to the objective condition.

Any deficiencies in meeting five-year objectives or alteration of five-year objectives could be identified at
that time. This should be repeated after the five-year term in September as well. Range production should
be estimated and evaluated during monitoring activities by a qualified range specialist to determine what
level of grazing may be appropriate after objectives are met, or in keeping with any modified objectives.

Elk, deer, and cattle were observed at the study area. Grazing activity is high in some areas, and in others
is low and has not reduced vegetative cover across the range. Coverage data from the vegetation transects
confirms this observation.

Federal and State Listed and Otherwise Protected Species

Federally listed and otherwise protected species were identified through a review of U.S. Fish and Wildlife
Service (USFWS); and State of New Mexico agency lists (New Mexico Department of Game and Fish
[NMDGF] and New Mexico Energy Mineral and Natural Resources Department [NMED] Forestry Division).
The USFWS maintains lists of federal endangered, threatened, proposed, and candidate species of plants
and animals. It also administers the Migratory Bird Treaty Act and Bald and Golden Eagle Protection acts.
The NMDGF maintains lists of state endangered and threatened animals. The NMED Forestry Division
maintains a list of state endangered plant species. Species lists are provided in Appendix C.


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The potential for the proposed soil removal and revegetation to result in effects/impacts to species in
McKinley County appearing on at least one of the previously cited agency lists was evaluated. Nine federal
and state listed species were eliminated from consideration and 3 were evaluated further.

Critical Habitat

No designated or proposed critical habitat occurs within the study area. The CP-2 unit of designated
critical habitat for the Mexican spotted owl is located approximately 12 miles southeast of the study area
within the Cibola National Forest (USFWS 2016b).

Listed or Otherwise Protected Species Eliminated from Further Analysis

The project would result in no effect/impact to the following eliminated species, for which, no suitable
habitat is present in the study area and none appears to be present within the action area (Table 3).

Table 3- Protected Species Eliminated from Further Analysis

Group

Name

Status

Habitat

Rationale for
Removal

Plants





Zuni fleabane (Erigeron rhizomatus)

USFWS E
EMNRD E

Sparsely vegetated slopes in
pinyon-juniper woodlands
on Chinle/Baca formation
soils

No suitable
habitat



Goodding's onion (Allium gooddingii)

EMNRD E

Forested slopes above
7,500 feet in elevation

No suitable
habitat

Parish's alkali grass (Puccinellia
parishii)

EMNRD E

Alkaline seeps and wetlands

No suitable
habitat

Fishes





Zuni blue-head sucker (Catostomus
discobolus Yarrowi)

USFWS E
NMDGF E

Perennial waterways in the
Rio Nutria watershed

No suitable
habitat

Group

.... Rationale for
Name Status Habitat

Removal

Birds





Southwestern willow flycatcher
(Empidonax traillii extimus)

USFWS E
NMDGF E

Nests in dense willow and
cottonwood riparian
woodlands

No suitable
habitat



Mexican spotted owl (Strix
occidentalis lucida)

USFWS T

Nests in old growth conifer
habitat

No suitable
habitat



Yellow-billed cuckoo (Coccyzus
americanus)

USFWS T
NMDGF S

Nests in canopy cover of
riparian woodlands

No suitable
habitat



Bald eagle (Haliaeetus leucocephalus
alascanus)

BGEPA
NMDGF T

Nests along large lakes and
rivers, winters in riparian
areas

No suitable
habitat



Least tern (Sternula antillarum)

NMDGF E

Nest in depressions in sand
or gravel bars near water

No suitable
habitat



Costa's hummingbird (Calypte costae)

NMDGF T

Nests in Hidalgo County,
rare as a vagrant in other
parts of state

No suitable
habitat

E- Endangered, T- Threatened, BGEPA-Bald and Golden Eagle Protection Act


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Listed or Otherwise Protected Species Evaluated Further

Potential project-related impacts to 3 listed species that may occur within the study area or immediately
adjacent areas are evaluated further (Table 4).

Table 4 -Listed and Otherwise Protected Species with Potential to occur at the Study Area

Group

Name

Status

Habitat

Birds



Golden eagle (Aquila chrysaetos)

BGEPA

Nest in arid remote cliff habitats



Peregrine falcons (Falco peregrinus
anatum/ tundrius)

NMDGFT

Steep mountain or shoreline cliffs near water



Gray vireo (Vireo vicinior)

NMDGFT

Sloped undeveloped Pinyon/Juniper woodlands

T- Threatened, BGEPA - Bald and Golden Eagle Protection Act

Birds

Golden eagle (Aquila chrysaetos) - Golden eagles are protected under the Bald and Golden Eagle
Protection Act from harm and harassment. This is a very large bird of prey with a wingspan of up to 71
inches. Their breeding range extends throughout Canada and much of the western United States. They
occur in open areas at lower to middle elevations throughout New Mexico. Preferred nesting sites are
cavities within ledges and cliffs of mountainsides, mesa escarpments, and canyon walls.

The cliffs that golden eagles typically use are greater than 30 meters in height, although they can use cliffs
of only 10 meters in height. The nesting cliffs are normally located directly adjacent to suitable foraging
habitats. In New Mexico, this species begins courtship and nest construction as early as February.

There are several rock outcrops, mesas, and cliffs located within the vicinity of the study area, and this
species is known to occur in the region. Telescopic observations of cliffs within the vicinity were conducted
to determine whether nests or sign were present. Several areas of whitewash on cliffs were observed.
However, the cliffs sufficient to provide nesting habitat for this species occur over 1 mile from the study
area.

This species was observed perching in elm trees located within the study area (Figures 3a and 3b) and
likely hunts there, as prairie dogs are abundant. It is recommended that removal activities avoid the perch
trees, or that artificial perches be installed to allow this species continued use of the site.

Gray vireo {Vireo vicinior) - This is a state threatened bird that is protected under the MBTA. It is found
through much of the western United States and northern Mexico. It normally occurs in open rolling
woodland, juniper savanna, and chaparral. It is found in arid lands, typically in pinyon-juniper habitat along
steep or rolling slopes. This vireo is an insectivore. In New Mexico, it is found during the months of April
through September when insects are most abundant.

No suitable nesting habitat for this species occurs within the study area, as small woodland parcels present
do not provide enough cover. However, suitable habitat occurs around much of the periphery of the study
boundary. This species likely nests in the vicinity, and it is possible that a territory occurs near the study.
If vegetation clearing is complete prior to the onset of the general migratory bird nest season (March 15
through September 30), individuals and nests would not be directly impacted.

However, potential indirect impacts associated with noise and activity during construction could not be
avoided once excavation and planting begins if the species is nesting within approximately 0.25 mile of

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construction activity. It is recommended that species-specific surveys for gray vireo be conducted (male
territorial calls played at intervals) during the nest season (May 15 to September 30) prior to the planned
fall/winter clearing to determine whether the species is nesting in the immediate area if reclamation will
occur within 0.25 miles of habitat.

If it does, the proximity of territories relative to the proposed work area should be estimated. Work
schedules can be sequenced in areas proximal to territories if needed to provide a buffer during the nest
season. The NMDGF does not currently provide a required buffer distance for avoiding indirect impacts
to this species. Marron recommends a 0.25-mile buffer. However, if the species is identified within the
area, the NMDGF should be contacted regarding specific avoidance requirements.

Peregrine falcons (Falco peregrinus anatum/tundrius) - Peregrine falcons are protected as a State of
New Mexico threatened species. These subspecies breed south of the Arctic tundra region of North
America, southward to Mexico. In New Mexico, they breed locally in mountainous areas and occur during
migration and winter essentially statewide, though primarily in the eastern plains (NMDGF 2015). They
summer and nest on tall, steep, rocky cliffs associated with forest or woodland in close proximity to water.
No suitable steep cliff habitat occurs within the study area, but the nearby cliff habitat suitable for eagles
could also provide nest sites for this species.

Migratory Birds

The Migratory Bird Treaty Act (16 United States Code (USC). 703-712), as amended, protects migratory
birds, their parts, eggs, and occupied nests from take, pursuit, import/export, hunting, and capture. A list
of birds protected under the Act is available in Title 50 of the Code of Federal Regulations (CFR) Section
10.13.

Suitable nesting habitat for area tree and ground-nesting birds occurs within and adjacent to the study
area. During fall 2016 surveys, occupied burrows, which were used as nest sites by western burrowing
owls, were present in abandoned prairie dogs towns. Several occupied burrows were observed. Since
ground surveys were not completed for the entire study area, existing nests may be present but were
unidentified. In addition, the construction of new nests prior to the onset of reclamation is likely.

It is recommended that vegetation clearing within the site be initiated and completed outside the general
migratory bird nesting season for the area (March 15 to September 30) to prevent destruction of occupied
nests.

Raptors such as hawks and owls that may nest in the area begin nesting earlier in the year (late January
to early March), but are most likely to use woodlands and cliffs, which would not be cleared or reclaimed
under the currently proposed action. If it is necessary to clear vegetation during the nesting season, a
preconstruction nest survey should be provided at least two weeks ahead of work to identify any occupied
nests within the area. If occupied nests would be removed, a USFWS permit would be required first.

Other Listed Species

The Bureau of Land Management (BLM) maintains a list of sensitive species for lands it manages and
evaluates proposed activities for consistency with the appropriate approved resource management plan.
The New Mexico Heritage Program list of critically imperiled species (SI) was reviewed for informational
purposes, as this is not a protected category.

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BLM Sensitive Species

Table 5 - BLM Sensitive Species Verified in the Farmington District

Group

Name

Habitat

Plants

Brack's fishhook cactus

Nacimiento formation soils in San
Juan County



Aztec gilia

Nacimiento formation soils in San
Juan County



San Juan milk weed

San Juan County



Mancos saltbush

Mancos clay in San Juan County

Mammals

"Gunnison's prairie dog

Grasslands



Spotted bat

Cliffs near open water



Townsend's big eared bat

Caves, mine shafts

Birds

Yellow-billed cuckoo

Riparian woodlands



Bald eagle

Nests near large water bodies



"Western burrowing owl

Grasslands/prairie dog burrows



Southwestern willow flycatcher

Riparian woodlands



Pinyon jay

Pinyon woodland/mixed conifer



Bendire's thrasher

Desert canyons/scrub

Amphibians

Northern leopard frog

Wetland/spring/riparian

Fishes

Zuni blue head sucker

Aquatic, Rio Nutria area



Flannelmouth sucker

Aquatic, San Juan Basin

*Present in study area

Western burrowing owl (Athene cunicularia hypugaea) — This owl is protected under the Migratory Bird
Treaty Act and is a BLM sensitive species. It occurs on plains, treeless valleys, and mesas and prefers empty
prairie dog or other rodent burrows that it can use for nesting and shelter, but can excavate its own
burrows if needed. This species is found throughout the mid and lower elevations of New Mexico. It
inhabits bare ground near areas such as golf courses and airports; open desert of yucca, cactus, and
mesquite; and grassland-juniper habitats. Occupied nesting habitat for this species occurs within the study
area.

Occupied burrows used as nest sites by western burrowing owls are present in abandoned prairie dogs
towns. Several occupied burrows were observed, and many others are likely present within unsurveyed
areas. This species tends toward a moderate to high nest site fidelity, and pairs are likely to attempt to
nest in the same location during future years. The following measures are recommended to prevent direct
impacts and reduce indirect impacts to this species:

Timing restrictions for vegetation clearing are recommended to avoid direct impacts to this species (avoid
clearing during the general nest season of March 15 through September 30).

During the later summer prior to the onset of removal activities, a survey of all areas, which may support
owl nests located within the final removal zone, should be provided. To the extent feasible, all occupied
burrows (or clusters of burrows, likely used by a single pair) should be identified. Where a cluster of
burrows that was occupied is removed, it is recommended that 2 artificial burrows be installed to offset
the loss of nesting habitat in the area. Artificial burrows could be removed (outside nesting season) once
the area is revegetated and supports prairie dogs again, potentially during final reclamation closeout
activities.

# !

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Gunnison's prairie dog (Cynomys gunnisoni) - This BLM sensitive species occurs in southeastern Utah,
southwestern Colorado, northwestern New Mexico and northern Arizona where they occur primarily on
lower elevation, warm and dry plains and plateaus. They are approximately 12 to 14 inches and weigh
from 1.5 to 2.5 lbs. Their coats are yellow-toned buff merged with black-colored hairs. Gunnison's prairie
dogs typically inhabit large colonies of up to several hundred individuals that are divided into smaller
territories occupied by communal groups or solitary individuals. They are a diurnal species that mates
from mid-March until mid-May and produces 4 to 5 pups per year. They occur in high desert, grasslands,
meadows and even floodplain often found among shrubs such as rabbitbrush, sagebrush, and saltbush.
They are very susceptible to plague, pest control measures, and protracted drought.

Gunnison's prairie dogs were widespread and abundant in the study area, and active colonies cover at
least 473 acres or approximately 20 percent of the entire study area (Figure 3a) and adjacent areas.

Active burrow systems are likely to persist through the soil removal process, but Gunnison's prairie dogs
do not maintain granaries and may not remain in the study area after the removal of vegetation. Once
vegetation is successfully established, they would likely return. If large numbers of individuals flee the
removal and migrate to adjacent areas, the adjacent populations may experience food shortage and other
pressures associated with an increased density and reduced resources. It may be possible to relocate
individuals occupying the study area to suitable but unoccupied areas within the vicinity, if such areas are
available; or, to temporarily provide grain drops to support them within the study area while vegetation
establishes. Either of these activities should be included in monitoring activities to determine whether
successful. It is recommended that the USEPA coordinate with the BLM prior to undertaking removal to
obtain specific information regarding these populations.

Spotted bat (Euderma maculatum)/ Townsend's big-ear bat (Corynorhinus townsendii) - Spotted bats
are BLM sensitive and protected as a threatened species by the State of New Mexico. Townsend's big-ear
bat is a BLM-sensitive species. These bats are cliff and cave dwellers whose diurnal roosts are the cracks
and crevices, but are also known to roost in human-made structures. No suitable caves, cliffs or canyons
occur within the study area. These species may roost within nearby cliff habitats and could hunt at the
pond in Section 22 when it supports insects. The activity is not likely to impact bats if the pond is avoided,
or if other suitable hunting habitats are available within the vicinity.

New Mexico Heritage Critically Imperiled Species

New Mexico Heritage ranks native species into several categories. Heritage categories are not associated
with a legal protective mechanism. Critically imperiled ranked species for McKinley County are provided
in Table 5. Most are waterfowl that would be transients within the study area, if they were present.
Several are federally listed species for the County. The Northern leopard frog could occur within study
area stock ponds if they were nearly perennially wet, but current conditions are not likely suitable to
support frogs.


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Table 5 - New Mexico Heritage Critically Imperiled (SI) Species for McKinley County

Group

Name

Habitat

Birds

Ring-necked duck

Lacustrine/riparian



Little blue heron

Lacustrine/riparian



Bald eagle

Nests near large water bodies



Least tern

Lacustrine/riparian



Southwestern willow flycatcher

Riparian woodlands



Marsh wren

Lacustrine/riparian



Costa's hummingbird

Desert canyons/stream edges

Amphibians

Northern leopard frog

Wetland/spring/riparian

Fishes

Zuni blue head sucker

Aquatic, Rio Nutria area

Watershed

The study area occurs within the San Mateo Creek local watershed and in the Rio San Jose 8-digit
Hydrologic Unit Code 13020207, which occurs in the larger Middle Rio Grande drainage Basin.

Waterways

The study area occurs along and north of the Arroyo del Puerto, which is tributary to San Mateo Creek.
Martin Draw passes through the northern study area parcel. Waterways in the vicinity are poorly defined
and segmented. They do not currently appear to connect to San Mateo Creek, which confluences with the
Arroyo del Puerto south of the study area.

Several unnamed small and partially defined waterways were also observed during field surveys, but they
lose bed and bank features downslope/downstream, or end in stock ponds or sheet flow.

A historical 1954 aerial photograph of the area pre-mine development was obtained (Figure 4, Appendix
A). The image indicates that area surface flows were more regular (possibly near perennial in some
segments), channels were more organized and sinuous, and a riparian corridor was present along
stretches of both Martin Draw and the Arroyo del Puerto. In 1954 a branch of Arroyo del Puerto extended
into and across the northern third of Section 22.

A clearly defined channel also existed in the extreme southwest corner of Section 24. A less defined series
of channels and a large sheet flow area was evident along the eastern edge of Section 24.

Wetlands

One wetland was observed in the study area. It occurs in association with the stock pond located in Section
22. This pond maintained some surface water throughout the late summer and early fall of 2016. It was
dominated by a mixture of wetland indicator plants that included obligate, facultative wetland and
facultative species. Based on the persistence of surface water, the dominance of wetland plant species,
and the reduced soils noted in the bottom of the pond, this site appears to meet wetland criteria.
However, it is not located within a regulated water. Shrubby wetland vegetation (such as coyote willow
and Russian olive) appears occasionally in small pockets within portions of the Arroyo del Puerto drainage
system, none of these areas meet hydrology or soil criteria for a wetland.

There are a number of small stock ponds scattered along, and within, the channel of Arroyo del Puerto
that do occasionally collect water. Most support the weedy annual summer cypress. Summer cypress is a


-------
wetland indicator, but it is also a fast growing weed that can persist on very little water. Most of these
stock ponds do not appear to collect water frequently enough or long enough to qualify as wetland.

Watershed Impacts/Recommendations

Watershed impacts resulting from uranium mining activities area are well documented, and identification
and reclamation of legacy uranium mine surface and ground water quality are ongoing in the Ambrosia
Lake Sub-District. No water quality analysis was completed for this report. The successful removal of
uranium contaminated soils and revegetation of the site would be expected to reduce surface water
contact with uranium, which is expected to improve water quality.

Small arroyos that pass through study area do not support wetlands or a riparian corridor and appear to
convey insufficient flows to justify augmentation. It is recommended that existing arroyos remain
unaltered during reclamation. Alteration is likely to result in sediment being transported to downstream
areas and is not likely to result in improvement to the area habitat.

However, it is recommended that a hydrologic analysis be conducted prior to finalizing a revegetation
plan to determine whether flows in local arroyos are sufficient to warrant extending them into large
reclaimed grassland areas or implementing some other augmentation to improve the watershed.

Several stock pond features are present at the study area. One of these in Section 22 retains sufficient
flows to support wetland vegetation. It is recommended that stock pond features remain unscraped, as
feasible, as they pool water for wildlife and plant use after storm events. Additionally, the vegetation
present around the pond could be augmented to provide improved riparian habitat and tree canopy for
area birds. Tree shading would also reduce evaporation and improve growing conditions for plants. The
increase in cover would improve wildlife habitat.

REVEGETATION/SOIL AMMEDMENT SUMMARY

The revegetation strategy of the removal area, once identified, will be based on an ecological approach
that would attempt to restore arid grassland conditions to sustain native animal and plant communities
and enhance wildlife use of the area.

A Draft Revegtation Plan for the proposed removal area will be prepared prior to the identification of the
final removal area for review by cooperating agencies. The following summarizes the elements expected
to be addressed in the Draft Revegetation Plan.

Revegetation and Seed Mix Recommendations

Information used to develop the re-vegetation strategy will obtained from the following sources:

1.	Historic aerial photographs that predate the uranium mining activities within the study area will
be reviewed.

2.	Additional ground surveys will be conducted. Vegetation-covered transects will be identified and
surveyed to provide reference sites documenting the dominant perennial vegetation composition
and cover within each plant community on the site.


-------
3.	Survey findings from nearby areas will be reviewed and un-mined adjacent habitats will be
surveyed briefly for comparison, if authorization for entry is obtained.

4.	Data from previous and ongoing mining and reclamation actions in the area will be reviewed

The recommended seed mix and application rate will be determined based on the updated location of the
removal area.

Recommendations for planting of cover crops, mulching, watering, and amending soils, as well as special
planting recommendations for pond areas will also be provided.

Recommendations for amending soils are expected to address the following soil issues: Carbon/nitrogen
ratio, texture, and water holding capacity.

The addition of traditional organic soil amendments such as sawdust, bark, compost, and manure; as well
as the addition of humate, and their potential application rates at the site will be addressed.

SUMMARY OF RECOMMENDATIONS

The following summarizes measures that are recommended to preserve existing resources/features or
improve the study area. Other measures directly related to reclamation activities will be provided in a
draft revegetation plan for the removal zone.

•	Avoid cliffs and slopes located adjacent to the study area, which provide bird nesting and bat
roosting habitat.

•	Avoid juniper and pinyon pine trees when removing vegetation.

•	Clear vegetation during the fall and winter months outside the general nesting season for
migratory birds.

•	Provide a species-specific survey for gray vireo to determine whether they are nesting within 0.25
mile of the study area if areas within this distance of suitable pinyon/juniper habitat will be
included in reclamation.

•	Replace lost burrow clusters occupied by western burrowing owls with artificial nest boxes (2 per
cluster).

•	Conduct a hydrological analysis of the removal area, once identified, to determine whether
sufficient surface flows are present to warrant arroyo extension or other improvement.

•	Provide relocation or grain drops to allow small mammals to become re-established while
vegetation becomes established, in coordination with the BLM.

•	Provide removal site monitoring during September at 3 and 5 years post planting to compare
observations with project objectives relative to plant species composition, percent cover, wildlife
use, and range production.


-------
• Avoid existing ponds or excavate new ponds in downslope areas to collect surface flows that
would promote wildlife use of the area.

• Plant species such as cottonwood to provide cover and habitat structure to the wetted pond.

16053


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PHOTOS

Photo A - Plains Mesa Grassland Vegetation

Photo B - Shrubby Grassland Vegetation


-------
Photo C - Great Basin Desert Scrub Vegetation

Photo D - Great Basin Desert Scrub Vegetation - Saltbush/Dropseed/Snakeweed/Annuals


-------
Photo E - Great Basin Desert Scrub Vegetation - Rabbitbrush/Biue Grama/Galleta

Photo F - Arroyo Riparian Vegetation


-------
Photo G - Juniper Savanna Vegetation

Photo H - Coniferous Woodland Vegetation


-------


tsiS

09-27-2016 20:51:35

Photo G - Elk at Stock Pond

Bushnell	09-29-201e 11:42:27

Photo H - Great Blue Heron at Stock Pond


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Photo I - Prairie Dog at Grassland Colony

Photo J - Western Terrestrial Garter Snake



29


-------
Photo K - Golden Eagle Leaving Perch Tree

Whitewash on Cliffs West of Study Area


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REFERENCES

Barclay, J.H.

2008. A Simple Artificial Burrow Design for Burrowing Owls. Journal of Raptor Research. 42 (1) 53-57.
Dick-Peddie, W. A.

1993. New Mexico vegetation: past, present, and future. Albuquerque: University of New Mexico Press.
Findley, J. S., Harris, A. H., Wilson, D. E., & Jones, C.

1975. Mammals of New Mexico. Albuquerque: University of New Mexico Press.

Gano, K.A. and J. B. States

1982. Habitat requirements and burrowing depths of rodents in relation to shallow waste burial sites.
PNL-4140, Pacific Northwest Laboratory, Richland, Washington.

Griffith, G.E., J.M. Omernik, M.M. McGraw, G.Z. Jacobi, C.M. Canavan, T.S. Schrader, D. Mercer, R. Hill
and B.C. Moran. 2006. Ecoregions of New Mexico (color poster with map, descriptive text, summary
tables, and photographs): Reston Virginia, U.S. Geological Survey (Map scale 1:1,400,000). Website:
www.epa.gov/wed/pages/ecoregions.htm.

New Mexico Department of Game and Fish.

2016. Bison-M Database. Santa Fe, NM: NMDGF. Website: http://www.bison-m.org/

New Mexico Environment Department. Ground Water Quality Bureau Superfund Oversight Section.
2008. Preliminary Assessment Report; San Mateo Creek Legacy Uranium Sites. Cerclis ID NMN00060664,
McKinley and Cibola Counties,New Mexico.

New Mexico Energy, Minerals & Natural Resources Department, Forestry Division (NMED).

2016. New Mexico Endangered Plants.

New Mexico Energy, Minerals & Natural Resources Department, Mining Division.

2014 Guidance for Meeting Radiation Criteria Levels and Reclamation at New Uranium Mining

Operations. Title 19, Chapter 10, Part3, and Part 6 (Draft).

New Mexico Mining Commission

2013. Petition to Amend 19.10.3 NMAC (Minimal Impact Rule) and Request for Hearing.

Website: http://www.emnrd.state.nm.us/MMD/NMMC/documents/NMMiningCommissionPetitionl3-

l.pdf

New Mexico Water Quality Control Commission. New Mexico Environment Department Surface Water
Quality Bureau.

2014-2016. State of New Mexico Clean Water Act Section 303(d)/Section 305(b) Integrated Report.
Sublette, J. E., M. D. Hatch, and M. Sublette.

1990. The fishes of New Mexico. University of New Mexico Press, Albuquerque, New Mexico.


-------
US Department of Agriculture Natural Resources Conservation Service.

2007.	Plant Guide. Website: http://plants.usda.gov/plantguide/

US Department of Agriculture. National Resources Conservation Service.

2016. Web Soil Survey. Website: http://websoilsurvev.sc.egov.usda.gov/App/HomePage.htm

US Army Corps of Engineers.

2008.	A field guide to the identification of the ordinary high water mark (OHWM) in the arid west region
of the western United States. U.S. Army Corps of Engineers Environmental Laboratory.

US Department of the Interior. Bureau of Land Management. Bureau of Indian Affairs.

1985. Jackpile Paguate Uranium Mine Reclamation Project, Environmental Impact Statement.

US Department of the Interior. Bureau of Land management.

2011.	Sensitive Species Lists for Plants and Animals. Verified Species in the Farmington Field Office
District.

US Department of the Interior, Bureau of Land Management.

1992. Solid Minerals Reclamation Handbook. Non-coal Leasable minerals, locatable minerals, salable
minerals. BLM Handbook H-3042-1.

US Environmental Protection Agency.

2010. Assessment of Health and Environmental Impacts of Uranium Mining and Milling. Five Year Plan,
Grants Mining District.

US Fish and Wildlife Service.

2016 (a). Official List of Resources for the Study Area. Website: http://www.fws.gov/ipac/.

US Fish and Wildlife Service.

2016 (b). Critical Habitat Mapper. Website: http://criticalhabitat.fws.gov.

US Geological Survey. Langman, J.B., Sprague, J.E., and Durall, R.A.

2012.	Geologic Framework, Regional Aquifer Properties (1940s-2009), and Spring, Creek, and Seep
Properties (2009-10) of the Upper San Mateo Creek Basin near Mount Taylor, New Mexico. Scientific
Investigations Report 2012-5019.

Western Regional Climate Center

2016. Western U.S. Historical Summaries (Individual Stations).

Website: http://www.wrcc.dri.edu/CLIMATEDATA.html


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APPENDIX A

Figures 1-4


-------

-------
	

&
£ -

Vf 2) w

jfc

r i\»

x

¦M "\

'.R

'•w£.. •&«&£$»& ¦ ¦*
I Hsesfc	•¦'-.'

! ¦

' f1: w$kj-y

San Juan Rio Arriba JTaost Colfax

~gr^.Mj") Harding

J|ys-Project AreaXjJ



Study Area
Ground Survey Area
o Transect Endpoints



Goat Mountain, NM &	T 14N, R 10W & 9W;

Ambrosia Lake, NM Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
USGS 7.5' Quadrangles McKinley County, New Mexico

Figure 1b

Survey Area Map

0.5

0.35

0.7

Kilometers
1.4
Miles

N

A

1:33,000

USEPA Tronox Mines, McKinley County, New Mexico


-------
Colfax

Rio Arriba



f Harding

p» Project Area \

Bernalillo	1	1	J"* Qua*

f""\—^-*—3	I Guadalupe

Torrance 	TJ"L_J-r

--^i	[	I I Cu

I		 DeBaca I	

McKinle

Cibola

Roosevelt

Catron

Lincoln



Grant

Otero



%- "	.-.i-V .

Vegetation Communities

Arroyo Riparian	Juniper Savanna

Disclimax Annual Vegetation	Grassy Rabbitbrush Scrub

Coniferous Woodland

Saltbush/Galleta/Grama Grass Scrub

Plains-Mesa Grassland

Shrubby Grassland Ecotone

Saltbush/Dropseed Scrubland

.



Figure 2
Vegetation
Communities

Study Area
¦ Soil Sample Location

Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

T 14N, R 10W& 9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico

N

0.5

0.35

0.7

I Kilometers
1.4
Miles

A

1:34,000

USEPA Tronox Mines, McKinley County, New Mexico


-------
Colfax

Rio Arriba



f Harding

p» Project Area \

Bernalillo	1	1	I"* Qua*

f""\—^-*—3	I Guadalupe

Torrance 	TJ"L_J-r

--^i	[	I I Cu

I		 DeBaca I	

McKinle

Cibola

Roosevelt

Catron

Lincoln



Grant

Otero



'egetation Communities

Juniper Savanna
Coniferous Woodland

Arroyo Riparian



Figure 3a

Resources

Study Area
Prairie Dog Colony
Burrowing Owl Area
Exclusion Area
Wetland

Perch Trees
Stream or River

T 14N, R 10W& 9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
Bernalillo County, New Mexico

Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

0.5

0.35

0.7

I Kilometers
1.4
Miles

N

A

USEPA Tronox Western GSA Mines, McKinley County, New Mexico


-------
San Juan

Rio Arriba

Colfax



/Harding

Project Area \

Bernalillo—I		| Qua-,

h i |i 1	I Guadalupe^

Valencia Torrance 	

f	I ICu

1	I 1 DeBaca I I—

McKinle

Cibola

Roosevelt

Socorro

Catron

Lincoln

Chaves



Grant

Otero

Dona,
Ana



Hidalgo

'Oitwter



IMaaaWasiefn

Study Area
Prairie Dog Colony
" Potential Eagle Nest Area
~ Perch Trees

,<^SSOC/

Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

T 14N, R 10W& 9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
Bernalillo County, New Mexico

Figure 3b
Golden Eagle
Resources

Kilometers

Miles 1:50,000

IISEPA Tronox Western GSA Mines, McKinley County, New Mexico


-------


11; T14N.R10W

12; T14N.R10W

Colfax

Rio Arriba



f Harding

p» Project Area \

Bernalillo	1	1	I"* Qua*

f""\—^-*—3	I Guadalupe

Torrance 	TJ"L_J-r

*—-»1	[	I I Cu

I		 DeBaca I	

McKinle

Cibola

Roosevelt

Catron

Lincoln



Grant

Otero



Figure 4
Project Area
1954 Aerial Photo

Study Area	Goat Mountain, NM &	T 14N, R 10W & 9W;

' *	Ambrosia Lake, NM Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30

USGS 7.5' Quadrangles McKinley County, New Mexico

0	0.5	1	2

Kilometers

0	0.4	0.8	1.6

Miles

N

A

USEPA Tronox Western GSA Mines, McKinley County, New Mexico


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APPENDIX B

Soil Characteristics
Soil and Plant Sampling Results
Vegetation Sampling Results
Vegetation Transect Tables


-------
Soil Map—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

238000

¦ , J__

239000

	I

240000

I

241000

I.

3

D	

as

as
a®

as

as
as

as

r

—- %¦{ . ,
.<• '"k; '

-A"1:

m

m

m
m

m



m

as

243000

, I

mi



as

as

as

m

n 293



D as

as

"

m

—

f;"'







¥\

: m

®k alms



I

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") sheet.

A

500

1000

2000

=i Meters
3000

^i Pqq^

0	2000	4000	8000	12000*

Map projection: WabMercator toner coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

USDA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 1 of 3


-------
Soil Map—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

Area of Interest (AOI)

Area of interest (AOi)

Soils

Soil Map Unit Polygons
Soil Map Unit Lines
|U Soil Map Unit Points
Special Point Features



Blowout



Borrow Pit

m

Clay Spot

0

Closed Depression

X

Gravel Pit

A

Gravelly Spot

II

Landfill

4

Lava Flow

.j...

Marsh or swamp



Mine or Quarry



Miscellaneous Water



Perennial Water



Rock Outcrop



Saline Spot



Sandy Spot



Severely Eroded Spot



Sinkhole

*

Slide or Slip

0

Sodic Spot

a

Spoil Area

0

Stony Spot

til

Very Stony Spot

t

Wet Spot



Other



Special Line Features

Water Features

Streams and Canals

Transportation

Rails

«*iwn Interstate Highways
US Routes
Major Roads
Local Roads

Background

Aerial Photography

MAP INFORMATION

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG 3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

USDA Natural Resources
1 Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Soil Map—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San
Juan Counties

4 mines

Map Unit Legend

McKinley County Area. New Mexico. McKinley County and Parts of Cibola and San Juan Counties (NM692)

Map Unit Symbol

Map Unit Name

Acres in AOI

Percent of AOI

205

Penistaja-Tintero complex, 1 to
10 percent slopes

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8 percent
slopes

20.1

0.9%

220

Hagerwest-Bond fine sandy
loams, 1 to 8 percent slopes

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3 percent
slopes

787.0

34.2%

265

Uranium mined lands

285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

242000

243000

Depth to Any Soil Restrictive Layer—McKinley County Area, New Mexico, McKinley County and Parts of Cibola .

(4 mines)

§ 35° 28' 20" N

35° 23' 37" N

USDA Natural Resources	Web Soil Survey	11/7/2016

Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
Depth to Any Soil Restrictive Layer—McKiniey County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

Not rated or not available

The soil surveys that comprise your AOI were mapped at 1:24,000.

~

Area of Interest (AOI)

Water Features

Please rely on the bar scale on each map sheet for map

Soils



Streams and Canals

measurements.

Soil Rating Polygons

Transportation

Source of Map: Natural Resources Conservation Service

~

0-25

f-t-f. Rails

Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov

~

25-50

Interstate Highways

Coordinate System: Web Mercator (EPSG:3857)

~

50-100



Maps from the Web Soil Survey are based on the Web Mercator

US Routes

projection, which preserves direction and shape but distorts

~

100 -150

Major Roads

distance and area. A projection that preserves area, such as the

~

150-200

Albers equal-area conic projection, should be used if more accurate

Local Roads

calculations of distance or area are required.

~

> 200

Background

This product is generated from the USDA-NRCS certified data as of

~

Not rated or not available

Aerial Photography

the version date(s) listed below.

Soil Rating Lines

Soil Survey Area: McKinley County Area, New Mexico, McKinley

0-25
25 - 50
» 0 50-100

County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

100-150
150-200

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

> 200

n I Not rated or not available
Soil Rating Points

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

g 0-25



~ 25-50



~ 50-100



~ 100-150



g 150-200



g > 200



US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Depth to Any Soil Restrictive Layer—McKiniey County Area, New Mexico, McKinley County and
Parts of Cibola and San Juan Counties

4 mines

Depth to Any Soil Restrictive Layer

Depth to Any Soil Restrictive Layer— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and

Parts of Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (centimeters)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

>200

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

>200

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

89

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

>200

787.0

34.2%

265

Uranium mined lands

>200

285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

A "restrictive layer" is a nearly continuous layer that has one or more physical,
chemical, or thermal properties that significantly impede the movement of water
and air through the soil or that restrict roots or otherwise provide an unfavorable
root environment. Examples are bedrock, cemented layers, dense layers, and
frozen layers.

This theme presents the depth to any type of restrictive layer that is described for
each map unit. If more than one type of restrictive layer is described for an individual
soil type, the depth to the shallowest one is presented. If no restrictive layer is
described in a map unit, it is represented by the "> 200" depth class.

This attribute is actually recorded as three separate values in the database. A low
value and a high value indicate the range of this attribute for the soil component. A
"representative" value indicates the expected value of this attribute for the
component. For this soil property, only the representative value is used.

Rating Options

Units of Measure: centimeters
Aggregation Method: Dominant Component
Component Percent Cutoff: None Specified
Tie-break Rule: Lower
Interpret Nulls as Zero: No

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
242000

243000

35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

35° 23' 37" N

K Factor, Whole Soil—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan ... ?

(4 mines)	S

r-.
o

238000	239000	240000	241000	242000	243000

§ 35° 28' 20" N

USDA Natural Resources	Web Soil Survey	11/7/2016

" 1 Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
K Factor, Whole Soil—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons

~

.02

~

.05

~

.10

~

.15

~

.17

~

.20

~

.24

~

.28

~

.32

~

.37

~

.43

~

.49

~

.55

~

.64

~

Not

* '

.24



Streams and Canals

r- *

.28

Transportation

* *

.32

4-H

Rails

,i*Sl*

.37



Interstate Highways



.43



US Routes



.49
.55



Major Roads
Local Roads

* f

.64

Not rated or not available

Background

Aerial Photography

Soil Rating Points

¦ .02

Not rated or not available

Soil Rating Lines

.02

k-V .05

.10

*•<»* .15
» « .17
^ * .20

~
~
~
~
~
~
~
~
~
~
~

.05
.10
.15
.17
.20
.24
.28
.32
.37
.43
.49
.55
.64

Not rated or not available

Water Features

The soil surveys that comprise your AOI were mapped at
1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more
accurate calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as
of the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico,
McKinley County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales
1:50,000 or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov
7, 2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. Asa result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
K Factor, Whole Soil—McKinley County Area, New Mexico, McKinley County and Parts of Cibola
and San Juan Counties

4 mines

K Factor, Whole Soil

K Factor. Whole Soil— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts of Cibola

and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

.24

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

.28

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

.28

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

.37

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

Erosion factor K indicates the susceptibility of a soil to sheet and rill erosion by
water. Factor K is one of six factors used in the Universal Soil Loss Equation (USLE)
and the Revised Universal Soil Loss Equation (RUSLE) to predict the average
annual rate of soil loss by sheet and rill erosion in tons per acre per year. The
estimates are based primarily on percentage of silt, sand, and organic matter and
on soil structure and saturated hydraulic conductivity (Ksat). Values of K range from
0.02 to 0.69. Other factors being equal, the higher the value, the more susceptible
the soil is to sheet and rill erosion by water.

"Erosion factor Kw (whole soil)" indicates the erodibility of the whole soil. The
estimates are modified by the presence of rock fragments.

Rating Options

Aggregation Method: Dominant Condition
Component Percent Cutoff: None Specified
Tie-break Rule: Higher

Layer Options (Horizon Aggregation Method): Surface Layer (Not applicable)

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
242000

243000

35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

35° 23' 37" N

Wind Erodibility Index—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan ... ?

(4 mines)	S

r-.
o

238000	239000	240000	241000	242000	243000

§ 35° 28' 20" N

USDA Natural Resources	Web Soil Survey	11/7/2016

" 1 Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
Wind Erodibility Index—McKinley County Area, New Mexico, McKiniey County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons

250
310

Not rated or not available

~

0

Soil Rating Points



~

0

~

38







~

38

~

48







~

48

~

56







~

56

~

86







~

86

~

134







~

134

~

160







~

160

~

180







~

180

~

220







~

220

~

250







~

250

~

310







¦

310

~

Not rated or not available







~

Not rated or not available

>oil Rating Lines









Water Features



0











Streams and Canals

* *

38









Transportation

,»v*

48

i i i

Rails

* 0

56



Interstate Highways

* »

86



US Routes

* *

134



Major Roads

* 0

160



Local Roads



180

Background

.-V

220

¦

Aerial Photography

MAP INFORMATION

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Wind Erodibility Index—McKinley County Area, New Mexico, McKinley County and Parts of
Cibola and San Juan Counties

4 mines

Wind Erodibility Index

Wind Erodibility Index— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts of Cibola

and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (tons per acre
per year)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

86

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

86

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

86

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

86

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

The wind erodibility index is a numerical value indicating the susceptibility of soil to
wind erosion, or the tons per acre per year that can be expected to be lost to wind
erosion. There is a close correlation between wind erosion and the texture of the
surface layer, the size and durability of surface clods, rock fragments, organic
matter, and a calcareous reaction. Soil moisture and frozen soil layers also
influence wind erosion.

Rating Options

Units of Measure: tons per acre per year
Aggregation Method: Dominant Condition
Component Percent Cutoff: None Specified
Tie-break Rule: Higher

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
Soil Quality - Organic Matter—McKinley County Area, New Mexico, McKinley County and Parts
of Cibola and San Juan Counties

4 mines

Soil Quality - Organic Matter

Organic matter percent is the weight of decomposed plant and animal residue and
expressed as a weight percentage of the soil material less than 2 mm in diameter.

Significance

Organic matter influences the physical and chemical properties of soils far more
than the proportion to the small quantities present would suggest. The organic
fraction influences plant growth through its influence on soil properties. It
encourages granulation and good tilth, increases porosity and lowers bulk density,
promotes water infiltration, reduces plasticity and cohesion, and increases the
available water capacity. It has a high capacity to adsorb and exchange cations and
is important to pesticide binding. It furnishes energy to micro-organisms in the soil.
As it decomposes, it releases nitrogen, phosphorous, and sulfur. The distribution
of organic carbon according to depth indicates different episodes of soil deposition
or soil formation.

Soils that are very high in organic matter have poor engineering properties and
subside upon drying.

Measurement Laboratory measurements are made using a dry combustion method
to determine percent total carbon. For an estimate of organic carbon in calcareous
soils, the carbon present in carbonate compounds, such as CaC03, must be
calculated and then subtracted from the total carbon. This is done using the
equation: percent organic carbon = percent total carbon - [% less than 2mm CaC03
x0.12]. The results are given as the percent of organic carbon in dry soil. To convert
the figures for organic carbon to those for organic matter, multiply the organic
carbon percentage by 1.724. To convert the figures for organic matter to those for
organic carbon, divide the organic matter percentage by 1.724. The detailed
procedures are outlined in Soil Survey Investigations Report No. 42, Soil Survey
Laboratory Methods Manual, Version 4.0, November 2004, USDA, NRCS.

Estimates Color and feel are the major properties used to estimate the amount of
organic matter. Color comparisons in areas of similar materials can be made
against laboratory data so that a soil scientist can make estimates. In general, black
or dark colors indicate high amounts of organic matter. The contrast of color
between the A horizon and subsurface horizons is also a good indicator.

Total organic carbon (TOC) is the carbon (C) stored in soil organic matter (SOM).
Organic carbon (OC) enters the soil through the decomposition of plant and animal
residues, root exudates, living and dead microorganisms, and soil biota. SOM is
the organic fraction of soil exclusive of non-decomposed plantand animal residues.
Nevertheless, most analytical methods do not distinguish between decomposed
and non-decomposed residues. SOM is a heterogeneous, dynamic substance that
varies in particle size, C content, decomposition rate, and turnover time.

Soil organic carbon (SOC) is the main source of energy for soil microorganisms.
The ease and speed with which SOC becomes available is related to the SOM
fraction in which it resides. In this respect, SOC can be partitioned into fractions
based on the size and breakdown rates of the SOM in which it is contained (table
1). The first three fractions are part of the active pool of SOM. Carbon sources in
this pool are relatively easy to break down.

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 1 of 5


-------
Soil Quality - Organic Matter—McKinley County Area, New Mexico, McKinley County and Parts
of Cibola and San Juan Counties

4 mines

SOM contains approximately 58% C; therefore, a factor of 1.72 can be used to
convert OC to SOM. There is more inorganic C than TOC in calcareous soils. TOC
is expressed as percent C per 100 g of soil.

Factors Affecting

Inherent - Soil texture, climate, and time all affect SOC accumulation. Soils rich in
clay protect SOM from decomposition by stabilizing substances that bind to clay
surfaces. Aggregation, enabled by the presence of clay,also protects SOM from
microbial mineralization. Extractable aluminum and allophanes (present in volcanic
soils) can form stable compounds with SOM that resist microbial decomposition.
Warm temperatures decrease SOC content by increasing decomposition rates,
while high mean annual precipitation increases accumulation by stimulating the
production of plant biomass and associated SOC. With time, the breakdown of SOM
produces humus- carbon, which resists decomposition by microorganisms.

Carbon loss via soil erosion results in SOC variations along the slope gradient.
Level topography tends to have much more SOC than other slope classes. Both
elevation and topographic gradients to some extent control local climate, vegetation
distribution and soil properties, as well as associated biogeochemical processes,
including SOC dynamics. Microclimate cooling with elevation may favor SOC
accumulation. An analysis of factors affecting C in the conterminous United States
concluded that the effects of land use, topography (elevation and slope), and mean
annual precipitation on SOC are more obvious than that of mean annual
temperature. However, when other variables are highly restricted, there is clearly
a decline in SOC with increasing temperature.

Dynamic - Depending upon the rate of C mineralization, the amount and stage of
decomposition of plant residues and organic amendments added to soil controls
accrual of SOC. Turnover times for various organic materials shows that humus-
carbon mineralizes slowly and thus accumulates in the soil, whereas microbial
biomass C may disappear relatively quickly (table 1). Soil aggregates of different
sizes and stability are possible sites for physical protection of SOM from
decomposition and C mineralization. Soil disturbance and destruction of
aggregates may be the major factor responsible for increasing exposure of SOM
physically protected in aggregates to biodegradation.

Soil Organic Matter Fraction	Particle Size (mm)	Turnover Time (years)	

Description

plant residues	equal 2.0	less than 5	

recognizable plant shoots and roots

particulate organic matter	0.06 - 2.0	less than 100	

partially decomposed plant material, hyphae, seeds, etc

soil microbial biomass	variable	less than 3	

living pool of soil organic matter, particularly bacteria and fungi

humus	equal to 0.0053	100 to 5000	

ultimate stage of decomposition, dominated by stable compounds

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 5


-------
Soil Quality - Organic Matter—McKinley County Area, New Mexico, McKinley County and Parts
of Cibola and San Juan Counties

4 mines

Crop residues incorporated in or left on the soil surface reduce erosion and SOC
losses in sediment. Liming to increase the pH of acidic soil increases microbial
activity, organic matter decomposition, and C02 release. Diversity of the soil
microbial population also affects SOC. For example, while soil bacteria
aggressively participate in C loss by mineralization, some fungi, such as
mycorrhizae, are believed to slow the decay of SOM by aggregating it with clay and
minerals. SOM and SOC are more resistant inside aggregates than in free form.
Soil depth affects the distribution of SOC. Thus, plowed deep soils tend to
accumulate SOC in layers beneath the disturbed top soils because of restricted
mineralization rates.

Relationship to Soil Function

SOC is one of the most important constituents of the soil due to its capacity to affect
plant growth as both a source of energy and a trigger for nutrient availability through
mineralization. SOC fractions in the active pool, previously described, are the main
source of energy and nutrients for soil microorganisms. Humus participates in
aggregate stability, and nutrient and water holding capacity.

OC compounds, such as polysaccharides (sugars) bind mineral particles together
into microaggregates. Glomalin, a SOM substance that may account for20% of soil
carbon, glues aggregates together and stabilizes soil structure making soil resistant
to erosion, but porous enough to allow air, water and plant roots to move through
the soil. Organic acids (e.g., oxalic acid), commonly released from decomposing
organic residues and manures, prevents phosphorus fixation by clay minerals and
improve its plant availability, especially in subtropical and tropical soils. An increase
in SOM, and therefore total C, leads to greater biological diversity in the soil, thus
increasing biological control of plant diseases and pests. Data also reveals that
interaction between dissolved OC released from manure with pesticides may
increase or decrease pesticide movement through soil into groundwater.

Problems with Poor Carbon Levels

A direct effect of poor SOC is reduced microbial biomass, activity, and nutrient
mineralization due to a shortage of energy sources. In non-calcareous soils,
aggregate stability, infiltration, drainage, and airflow are reduced. Scarce SOC
results in less diversity in soil biota with a risk of the food chain equilibrium being
disrupted, which can cause disturbance in the soil environment (e.g., plant pest and
disease increase, accumulation of toxic substances).

Improving Carbon Levels

Compiled data shows that farming practices have resulted in the loss of an
estimated 4.4x109 tons of C from soils of the United States, most of which is OC.
To compensate forthese losses, practices such as no-till may increase SOC (figure
1). Other practices that increase SOC include continuous application of manure
and compost, and use of summer and/or winter cover crops. Burning, harvesting,
or otherwise removing residues decreases SOC.

Measuring Total Organic Carbon

Presently, no methods existto measure TOC in the field. Attempts have been made
to develop color charts that match color to TOC content, but the correlation is better
within soil landscapes and only for limited soils. Near infrared spectroscopy has
been attempted to measure C directly in the field, but it is expensive. Numerous
laboratory methods are available.

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 5


-------
Soil Quality - Organic Matter—McKinley County Area, New Mexico, McKinley County and Parts
of Cibola and San Juan Counties

4 mines

Reference:

United States Department of Agriculture, Natural Resources Conservation Service.
National soil survey handbook, title 430-VI. (http://soils.usda.gov)

Edwards JH, CW Wood, DL Thurlow, and ME Ruf. 1999. Tillage and crop rotation
effects on fertility status of a Hapludalf soil. Soil Sci. Soc. Am. J. 56:1577-1582.

Sikora LJ and DE Stott. 1996. Soil Organic Carbon and Nitrogen. In: Doran JW,
Jones AJ, editors. Methods for assessing soil quality. Madison, Wl. p 157-167.

Time needed: Laboratory methods are variable.

Report—Soil Quality - Organic Matter

Soil Quality - Organic Matter-McKinley County Area. New Mexico. McKinley County and Parts of Cibola and San Juan

Counties

Map symbol and soil name

Horizon Name

Depth
(inches)

Organic matter low
(Pet)

Organic matter RV
(Pet)

Organic matter
high (Pet)

205—Penistaja-Tintero
complex, 1 to 10 percent
slopes











Penistaja

A

0-3

1.0

1.5

2.0



Bt

3-19

0.5

0.8

1.0



Bk

19-65

0.5

0.8

1.0

Tintero

A

0-4

0.5

0.8

1.0



Bt

4-16

0.5

0.8

1.0



Bk1

16-48

0.5

0.8

1.0



Bk2

48-65

0.5

0.8

1.0

210—Marianolake-Skyvillage
complex, 1 to 8 percent
slopes











Marianolake

A

0-5

1.0

1.5

2.0



Bt

5-11

0.5

0.8

1.0



Btk

11-47

0.5

0.8

1.0



Bk

47-65

0.5

0.8

1.0

Skyvillage

A

0-2

0.5

0.8

1.0



Bw1

2-5

0.2

0.4

0.6



Bw2

5-9

0.2

0.4

0.6



Bk

9-15

0.2

0.4

0.6



2R

15-20

—

—

—

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 4 of 5


-------
Soil Quality - Organic Matter—McKinley County Area, New Mexico, McKinley County and Parts
of Cibola and San Juan Counties

4 mines

Soil Quality - Organic Matter-McKinley County Area. New Mexico. McKinley County and Parts of Cibola and San Juan

Counties

Map symbol and soil name

Horizon Name

Depth
(inches)

Organic matter low
(Pet)

Organic matter RV
(Pet)

Organic matter
high (Pet)

220—Hagerwest-Bond fine
sandy loams, 1 to 8 percent
slopes











Hagerwest

A

0-2

0.5

0.8

1.0



Bt

2-13

0.2

0.5

0.8



Bk1

13-19

0.2

0.5

0.8



Bk2

19-35

0.2

0.5

0.8



2R

35-40

—

—

—

Bond

A

0-2

1.0

1.5

2.0



Bt1

2-5

0.5

0.7

0.9



Bt2

5-14

0.5

0.7

0.9



R

14-20

—

—

—

230—Sparank-San Mateo-Zia
complex, 0 to 3 percent
slopes











Sparank

A

0-2

1.0

1.5

2.0



C1

2-25

0.5

0.8

1.0



C2

25-65

0.5

0.8

1.0

San mateo

A

0-2

1.0

1.5

2.0



C1

2-15

0.5

0.8

1.0



C2

15-30

0.5

0.8

1.0



C3

30-39

0.5

0.8

1.0



C4

39-45

0.5

0.8

1.0



C5

45-65

0.5

0.8

1.0

Zia

A

0-3

1.0

1.5

2.0



Bw

3-12

0.5

0.8

1.0



2C1

12-20

0.5

0.8

1.0



2C2

20-28

0.5

0.8

1.0



2C3

28-70

0.5

0.8

1.0

265—Uranium mined lands











Uranium mined lands

C

0-60

—

—

—

Data Source Information

Soil Survey Area: McKinley County Area, New Mexico, McKinley County and
Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 5 of 5


-------
Range Production (Favorable Year)—McKinley County Area, New Mexico, McKinley County and Parts of Cibola .

(4 mines)

238000

_ r,

239000

I

240000

_l_

241000

L

.

i&mm

a,

o jSWyr

r

3

D	 f

o 35° 28' 20" N

¦ '





.¦J&gp.
' PS M " ' l|M -Js: f-. . „

v " vf i' i * ¦

Jt ¦ 4Jk'~	• •- 
-------
Range Production (Favorable Year)—McKinley County Area, New Mexico, McKiniey County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons
~

~

~

<= 1171

>	1171 and <= 1200

>	1200 and <= 1359

Transportation
t-i-t Rails

Interstate Highways

US Routes
Major Roads
Local Roads

Background

Aerial Photography

~	> 1359 and <= 3557

~	Not rated or not available

Soil Rating Lines

<=1171

* t > 1171 and <= 1200

>	1200 and <= 1359

>	1359 and <=3557

h f Not rated or not available

Soil Rating Points

g <=1171

~	> 1171 and <= 1200

~	> 1200 and <= 1359
g	> 1359 and <=3557

~	Not rated or not available

Water Features

Streams and Canals

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Range Production (Favorable Year)—McKinley County Area, New Mexico, McKinley County and
Parts of Cibola and San Juan Counties

4 mines

Range Production (Favorable Year)

Range Production (Favorable Year)— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and

Parts of Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (pounds per
acre per year)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

1359

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

1200

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

1171

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

3557

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

Total range production is the amount of vegetation that can be expected to grow
annually in a well managed area that is supporting the potential natural plant
community. It includes all vegetation, whether or not it is palatable to grazing
animals. It includes the current year's growth of leaves, twigs, and fruits of woody
plants. It does not include the increase in stem diameter of trees and shrubs. It is
expressed in pounds per acre of air-dry vegetation. In a favorable year, the amount
and distribution of precipitation and the temperatures make growing conditions
substantially better than average. Yields are adjusted to a common percent of air-
dry moisture content.

In areas that have similar climate and topography, differences in the kind and
amount of vegetation produced on rangeland are closely related to the kind of soil.
Effective management is based on the relationship between the soils and
vegetation and water.

Rating Options

Units of Measure: pounds per acre per year
Aggregation Method: Weighted Average
Component Percent Cutoff: None Specified
Tie-break Rule: Higher
Interpret Nulls as Zero: Yes

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
242000

243000

35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

35° 23' 37" N

Range Production (Normal Year)—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and ... ?

(4 mines)	S

r-.
o

238000	239000	240000	241000	242000	243000

§ 35° 28' 20" N

USDA Natural Resources	Web Soil Survey	11/7/2016

" 1 Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
Range Production (Normal Year)—McKinley County Area, New Mexico, McKiniey County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons
~

~

~

US Routes
Major Roads
Local Roads

<= 794

> 794 and <=813
>813 and <= 953

Background

Aerial Photography

~	> 953 and <= 2177

~	Not rated or not available

Soil Rating Lines

<= 794

» » > 794 and <= 813
>813 and <=953
> 953 and <= 2177
h f Not rated or not available

Soil Rating Points

g <= 794

~	> 794 and <=813

~	>813 and <= 953
g > 953 and <= 2177

~	Not rated or not available

Water Features

Streams and Canals

Transportation
t-i-t Rails

Interstate Highways

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Range Production (Normal Year)—McKinley County Area, New Mexico, McKinley County and
Parts of Cibola and San Juan Counties

4 mines

Range Production (Normal Year)

Range Production (Normal Year)— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts

of Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (pounds per
acre per year)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

953

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

813

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

794

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

2177

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

Total range production is the amount of vegetation that can be expected to grow
annually in a well managed area that is supporting the potential natural plant
community. It includes all vegetation, whether or not it is palatable to grazing
animals. It includes the current year's growth of leaves, twigs, and fruits of woody
plants. It does not include the increase in stem diameter of trees and shrubs. It is
expressed in pounds per acre of air-dry vegetation. In a normal year, growing
conditions are about average. Yields are adjusted to a common percent of air-dry
moisture content.

In areas that have similar climate and topography, differences in the kind and
amount of vegetation produced on rangeland are closely related to the kind of soil.
Effective management is based on the relationship between the soils and
vegetation and water.

Rating Options

Units of Measure: pounds per acre per year
Aggregation Method: Weighted Average
Component Percent Cutoff: None Specified
Tie-break Rule: Higher
Interpret Nulls as Zero: Yes

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
242000

243000

Range Production (Unfavorable Year)—McKinley County Area, New Mexico, McKinley County and Parts of Cibola ...

(4 mines)

35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

35° 23' 37" N

239000	240000

241000	242000

243000

§ 35° 28' 20" N

238000

USDA Natural Resources	Web Soil Survey	11/7/2016

Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
Range Production (Unfavorable Year)—McKinley County Area, New Mexico, McKiniey County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons
~

~

~

US Routes
Major Roads
Local Roads

<= 407

>	407 and <= 416

>	416 and <= 547

Background

Aerial Photography

~	> 547 and <=1102

~	Not rated or not available

Soil Rating Lines

<= 407

» » > 407 and <= 416
>416 and <=547
,ii^ > 547 and <= 1102
h f Not rated or not available

Soil Rating Points

g <= 407

~	>407 and <=416

~	>416 and <=547
g	> 547 and <= 1102

~	Not rated or not available

Water Features

Streams and Canals

Transportation
t-i-t Rails

Interstate Highways

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Range Production (Unfavorable Year)—McKinley County Area, New Mexico, McKinley County
and Parts of Cibola and San Juan Counties

4 mines

Range Production (Unfavorable Year)

Range Production (Unfavorable Year)— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and

Parts of Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (pounds per
acre per year)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

547

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

416

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

407

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

1102

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

Total range production is the amount of vegetation that can be expected to grow
annually in a well managed area that is supporting the potential natural plant
community. It includes all vegetation, whether or not it is palatable to grazing
animals. It includes the current year's growth of leaves, twigs, and fruits of woody
plants. It does not include the increase in stem diameter of trees and shrubs. It is
expressed in pounds peracre of air-dry vegetation. In an unfavorable year, growing
conditions are well below average, generally because of low available soil moisture.
Yields are adjusted to a common percent of air-dry moisture content.

In areas that have similar climate and topography, differences in the kind and
amount of vegetation produced on rangeland are closely related to the kind of soil.
Effective management is based on the relationship between the soils and
vegetation and water.

Rating Options

Units of Measure: pounds per acre per year
Aggregation Method: Weighted Average
Component Percent Cutoff: None Specified
Tie-break Rule: Higher
Interpret Nulls as Zero: Yes

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
Ecological Site ID: NRCS Rangeland Site—McKinley County Area, New Mexico, McKinley County and Parts of.

(4 mines)

238000

_ r,

239000

I

240000

_l_

241000

L

8 35° 28' 20" N

; ' y
- - ; ¦ i J • . >S

¦ ¦*

;

lliS

35° 23' 37"N





i ¦

239000





240000

~
241000

I	I

242000	243000

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") sheet.

A

500

1000

2000

~ Meters

3000

^i poet

0	2000	4000	8000	12000

Map projection: WfebMercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

USDA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 1 of 3


-------
Ecological Site ID: NRCS Rangeland Site—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

Area of Interest (AOI)

Soils

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements

Soil Rating Polygons
|	\ R035XA112NM

|	I R035XA119NM

[ | Not rated or not available

Soil Rating Lines

R035XA112NM

R035XA119NM

» 0 Not rated or not available

Source of Map: Natural Resources Conservation Service

Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG 3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Rating Points

Q R035XA112NM

~ R035XA119NM

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

~ Not rated or not available

Water Features

Streams and Canals

Transportation
#-#-» Rails

Interstate Highways

US Routes

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

Major Roads



Local Roads



Background

Aerial Photography



Natural Resources	Web Soil Survey	11/7/2016

Conservation Service	National Cooperative Soil Survey	Page 2 of 3


-------
Ecological Site ID: NRCS Rangeland Site—McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties

4 mines

Ecological Site ID: NRCS Rangeland Site

Ecological Site ID: NRCS Rangeland Site— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County

and Parts of Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

R035XA112NM

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

R035XA112NM

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

R035XA112NM

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

R035XA119NM

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

An "ecological site ID" is the symbol assigned to a particular ecological site. An
"ecological site" is the product of all the environmental factors responsible for its
development. It has characteristic soils that have developed over time; a
characteristic hydrology, particularly infiltration and runoff, that has developed over
time; and a characteristic plant community (kind and amount of vegetation). The
vegetation, soils, and hydrology are all interrelated. Each is influenced by the others
and influences the development of the others. For example, the hydrology of the
site is influenced by development of the soil and plant community. The plant
community on an ecological site is typified by an association of species that differs
from that of other ecological sites in the kind and/or proportion of species or in total
production. Descriptions of ecological sites are provided in the Field Office
Technical Guide, which is available in local offices of the Natural Resources
Conservation Service.

Rating Options

Class: NRCS Rangeland Site
Aggregation Method: Dominant Condition
Component Percent Cutoff: None Specified
Tie-break Rule: Lower

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
Pond Reservoir Areas—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan .

(4 mines)

238000
'

. j f T"

239000

I

240000

_l_

241000

L

u

o 35° 28' 20" N

r
1

t	, : .i

f •***;• ¦ y i /

:.', « .-.'"V £ jfc>; '

r

238000

T

240000

I

242000

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") sheet.

~ Meters

A

500

1000

2000

3000

^i poet

0	2000	4000	8000	12000

Map projection: WfebMercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

USDA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 1 of 4


-------
Pond Reservoir Areas—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

Area of Interest (AOI)

Area of Interest (AOI)

Soils

Soil Rating Polygons
Very limited

~	Somewhat limited

~	Not limited

~	Not rated or not available

Soil Rating Lines

Very limited

0 0 Somewhat limited

Not limited
p* * Not rated or not available

Soil Rating Points

Very limited

~ Somewhat limited

U Not limited

Qj Not rated or not available

Water Features

Streams and Canals

Transportation

Rails

Interstate Highways
US Routes
Major Roads
Local Roads

Background

Aerial Photography

MAP INFORMATION

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG 3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

USDA Natural Resources
1 Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 4


-------
Pond Reservoir Areas—McKinley County Area, New Mexico, McKinley County and Parts of
Cibola and San Juan Counties

4 mines

Pond Reservoir Areas

Pond Reservoir Areas— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts of Cibola

and San Juan Counties (NM692)

Map unit
symbol

Map unit name

Rating

Component
name (percent)

Rating reasons
(numeric
values)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to
10 percent
slopes

Very limited

Penistaja (45%)

Seepage (1.00)

1,166.7

50.7%

Tintero (40%)

Seepage (1.00)

Slope (0.32)

210

Marianolake-
Skyvillage
complex, 1 to 8
percent slopes

Very limited

Marianolake
(50%)

Seepage (1.00)

20.1

0.9%

Slope (0.08)

Skyvillage (30%)

Depth to bedrock
(1.00)

Seepage (0.54)

Slope (0.08)

220

Hagerwest-Bond
fine sandy
loams, 1 to 8
percent slopes

Very limited

Hagerwest (50%)

Seepage (1.00)

41.3

1.8%

Depth to bedrock
(0.69)

Bond (35%)

Depth to bedrock
(1.00)

Slope (0.08)

230

Sparank-San
Mateo-Zia
complex, 0 to 3
percent slopes

Very limited

San Mateo (35%)

Seepage (1.00)

787.0

34.2%

Zia (20%)

Seepage (1.00)

Escawetter (1 %)

Seepage (1.00)

265

Uranium mined
lands

Not rated

Uranium mined
lands (95%)



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Pond Reservoir Areas— Summary by Rating Value

Rating

Acres in AOI

Percent of AOI

Very limited

2,015.1

87.6%

Null or Not Rated

285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 4


-------
Pond Reservoir Areas—McKinley County Area, New Mexico, McKinley County and Parts of
Cibola and San Juan Counties

4 mines

Description

Pond reservoir areas hold water behind a dam or embankment. Soils best suited
to this use have low seepage potential in the upper 60 inches. The seepage
potential is determined by the saturated hydraulic conductivity (Ksat) of the soil and
the depth to fractured bedrock or other permeable material. Excessive slope can
affect the storage capacity of the reservoir area.

The ratings are both verbal and numerical. Rating class terms indicate the extent
to which the soils are limited by all of the soil features that affect the specified use.
"Not limited" indicates that the soil has features that are very favorable for the
specified use. Good performance and very low maintenance can be expected.
"Somewhat limited" indicates that the soil has features that are moderately
favorable for the specified use. The limitations can be overcome or minimized by
special planning, design, or installation. Fair performance and moderate
maintenance can be expected. "Very limited" indicates that the soil has one or more
features that are unfavorable forthe specified use. The limitations generally cannot
be overcome without major soil reclamation, special design, or expensive
installation procedures. Poor performance and high maintenance can be expected.

Numerical ratings indicate the severity of individual limitations. The ratings are
shown as decimal fractions ranging from 0.01 to 1.00. They indicate gradations
between the point at which a soil feature has the greatest negative impact on the
use (1.00) and the point at which the soil feature is not a limitation (0.00).

The map unit components listed for each map unit in the accompanying Summary
by Map Unit table in Web Soil Survey or the Aggregation Report in Soil Data Viewer
are determined by the aggregation method chosen. An aggregated rating class is
shown for each map unit. The components listed for each map unit are only those
that have the same rating class as listed forthe map unit. The percent composition
of each component in a particular map unit is presented to help the user better
understand the percentage of each map unit that has the rating presented.

Other components with different ratings may be present in each map unit. The
ratings for all components, regardless of the map unit aggregated rating, can be
viewed by generating the equivalent report from the Soil Reports tab in Web Soil
Survey or from the Soil Data Mart site. Onsite investigation may be needed to
validate these interpretations and to confirm the identity of the soil on a given site.

Rating Options

Aggregation Method: Dominant Condition
Component Percent Cutoff: None Specified
Tie-break Rule: Higher

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 4 of 4


-------
242000

243000

35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

35° 23' 37" N

Hydric Rating by Map Unit—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San ... ?

(4 mines)	S

r-.
o

238000	239000	240000	241000	242000	243000

§ 35° 28' 20" N

USDA Natural Resources	Web Soil Survey	11/7/2016

" 1 Conservation Service	National Cooperative Soil Survey	Page 1 of 5


-------
Hydric Rating by Map Unit—McKiniey County Area, New Mexico, McKiniey County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

Area of Interest (AOI)

~ Area of Interest (AOI)

Soils

Soil Rating Polygons

~	Hydric (100%)

~	Hydric (66 to 99%)

~	Hydric (33 to 65%)

~	Hydric (1 to 32%)

~	Not Hydric (0%)

~	Not rated or not available
Soil Rating Lines

Transportation

Rails

Interstate Highways
US Routes
Major Roads
Local Roads

Background

Aerial Photography

Soil Rating Points

B Hydric (100%)

~	Hydric (66 to 99%)

~	Hydric (33 to 65%)

~	Hydric (1 to 32%)

~	Not Hydric (0%)

p	Not rated or not available

Water Features

Streams and Canals

MAP INFORMATION

The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.



Hydric (100%)

Soil Survey Area: McKiniey County Area, New Mexico, McKiniey



Hydric (66 to 99%)

County and Parts of Cibola and San Juan Counties





Survey Area Data: Version 11, Sep 26, 2014

H '

Hydric (33 to 65%)



Hydric (1 to 32%)

Soil map units are labeled (as space allows) for map scales 1:50,000

r* *

or larger.

.-V

Not Hydric (0%)

Date(s) aerial images were photographed: May 21, 2010—Nov 7,

K »

Not rated or not available

2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 5


-------
Hydric Rating by Map Unit—McKiniey County Area, New Mexico, McKiniey County and Parts of
Cibola and San Juan Counties

4 mines

Hydric Rating by Map Unit

Hydric Rating by Map Unit— Summary by Map Unit — McKiniey County Area. New Mexico. McKiniey County and Parts of

Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

0

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

0

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

0

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

1

787.0

34.2%

265

Uranium mined lands

0

285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 5


-------
Hydric Rating by Map Unit—McKiniey County Area, New Mexico, McKiniey County and Parts of
Cibola and San Juan Counties

4 mines

Description

This rating indicates the percentage of map units that meets the criteria for hydric
soils. Map units are composed of one or more map unit components or soil types,
each of which is rated as hydric soil or not hydric. Map units that are made up
dominantly of hydric soils may have small areas of minor nonhydric components in
the higher positions on the landform, and map units that are made up dominantly
of nonhydric soils may have small areas of minor hydric components in the lower
positions on the landform. Each map unit is rated based on its respective
components and the percentage of each component within the map unit.

The thematic map is color coded based on the composition of hydric components.
The five color classes are separated as 100 percent hydric components, 66 to 99
percent hydric components, 33 to 65 percent hydric components, 1 to 32 percent
hydric components, and less than one percent hydric components.

In Web Soil Survey, the Summary by Map Unit table that is displayed below the
map pane contains a column named 'Rating'. In this column the percentage of each
map unit that is classified as hydric is displayed.

Hydric soils are defined by the National Technical Committee for Hydric Soils
(NTCHS) as soils that formed under conditions of saturation, flooding, or ponding
long enough during the growing season to develop anaerobic conditions in the
upper part (Federal Register, 1994). Under natural conditions, these soils are either
saturated or inundated long enough during the growing season to support the
growth and reproduction of hydrophytic vegetation.

The NTCHS definition identifies general soil properties that are associated with
wetness. In order to determine whether a specific soil is a hydric soil or nonhydric
soil, however, more specific information, such as information about the depth and
duration of the water table, is needed. Thus, criteria that identify those estimated
soil properties unique to hydric soils have been established (Federal Register,
2002). These criteria are used to identify map unit components that normally are
associated with wetlands. The criteria used are selected estimated soil properties
that are described in "Soil Taxonomy" (Soil Survey Staff, 1999) and "Keys to Soil
Taxonomy" (Soil Survey Staff, 2006) and in the "Soil Survey Manual" (Soil Survey
Division Staff, 1993).

If soils are wet enough for a long enough period of time to be considered hydric,
they should exhibit certain properties that can be easily observed in the field. These
visible properties are indicators of hydric soils. The indicators used to make onsite
determinations of hydric soils are specified in "Field Indicators of Hydric Soils in the
United States" (Hurt and Vasilas, 2006).

References:

Federal Register. July 13, 1994. Changes in hydric soils of the United States.

Federal Register. September 18, 2002. Hydric soils of the United States.

Hurt, G.W., and L.M. Vasilas, editors. Version 6.0, 2006. Field indicators of hydric
soils in the United States.

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 4 of 5


-------
Hydric Rating by Map Unit—McKiniey County Area, New Mexico, McKiniey County and Parts of
Cibola and San Juan Counties

4 mines

Soil Survey Division Staff. 1993. Soil survey manual. Soil Conservation Service.
U.S. Department of Agriculture Handbook 18.

Soil Survey Staff. 1999. Soil taxonomy: A basic system of soil classification for
making and interpreting soil surveys. 2nd edition. Natural Resources Conservation
Service. U.S. Department of Agriculture Handbook 436.

Soil Survey Staff. 2006. Keys to soil taxonomy. 10th edition. U.S. Department of
Agriculture, Natural Resources Conservation Service.

Rating Options

Aggregation Method: Percent Present
Component Percent Cutoff: None Specified
Tie-break Rule: Lower

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 5 of 5


-------
Available Water Capacity—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San ... ?

(4 mines)	&

I

'iWif.

#p.

'¦ .	

*f'M "3- y... JSlSBt. J!wK ¦

¦ .iwSlll



i	i

242000	243000

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") sheet.

~ Meters

A

500

1000

2000

3000

^i poet

0	2000	4000	8000	12000

Map projection: WfebMercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 1 of 4


-------
Available Water Capacity—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND



MAP INFORMATION

Area of Interest (AOI)

Area of Interest (AOI)

Soils



The soil surveys that comprise your AOI were mapped at 1:24,000.

Please rely on the bar scale on each map sheet for map
measurements.

Soil Rating Polygons

| | <=0.14

| | >0.14 and <=0.18

Not rated or not available

Soil Rating Lines

<=0.14

> 0.14 and <= 0.18
h * Not rated or not available

Soil Rating Points

g <=0.14

g > 0.14 and <= 0.18



Source of Map: Natural Resources Conservation Service
Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov
Coordinate System: Web Mercator (EPSG:3857)

Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more accurate
calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below.

Soil Survey Area: McKinley County Area, New Mexico, McKinley
County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Not rated or not available

Water Features

Streams and Canals

Transportation
4-1-1. Rails

0^ Interstate Highways

US Routes



Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

Major Roads





Local Roads





Background

Aerial Photography





USDA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 4


-------
Available Water Capacity—McKinley County Area, New Mexico, McKinley County and Parts of
Cibola and San Juan Counties

4 mines

Available Water Capacity

Available Water Capacity— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts of

Cibola and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (centimeters per
centimeter)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

0.14

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

0.18

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

0.14

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

0.18

787.0

34.2%

265

Uranium mined lands



285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

Available water capacity (AWC) refers to the quantity of water that the soil is
capable of storing for use by plants. The capacity for water storage is given in
centimeters of water per centimeter of soil for each soil layer. The capacity varies,
depending on soil properties that affect retention of water. The most important
properties are the content of organic matter, soil texture, bulk density, and soil
structure, with corrections for salinity and rock fragments. Available water capacity
is an important factor in the choice of plants or crops to be grown and in the design
and management of irrigation systems. It is not an estimate of the quantity of water
actually available to plants at any given time.

Available water supply (AWS) is computed as AWC times the thickness of the soil.
For example, if AWC is 0.15 cm/cm, the available water supply for 25 centimeters
of soil would be 0.15 x 25, or 3.75 centimeters of water.

For each soil layer, AWC is recorded as three separate values in the database. A
low value and a high value indicate the range of this attribute forthe soil component.
A "representative" value indicates the expected value of this attribute forthe
component. For this soil property, only the representative value is used.

Rating Options

Units of Measure: centimeters per centimeter
Aggregation Method: Dominant Component
Component Percent Cutoff: None Specified

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 4


-------
Available Water Capacity—McKinley County Area, New Mexico, McKinley County and Parts of
Cibola and San Juan Counties

4 mines

Tie-break Rule: Higher
Interpret Nulls as Zero: No

Layer Options (Horizon Aggregation Method): Depth Range (Weighted Average)
Top Depth: 0
Bottom Depth: 36
Units of Measure: Inches

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 4 of 4


-------
35° 23' 37"N

Map Scale: 1:42,400 if printed on A portrait (8.5" x 11") shed;.

		.Mftere

500 1000	2000	3000

^—	.Feet

0	2000	4000	8000	12000

Map projection: V\feb Mercator Comer coordinates: WGS84 Edge tics: UTM Zone 13N WGS84

242000

243000

Depth to Water Table—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan .

(4 mines)

§ 35° 28' 20" N

35° 23' 37" N

USDA Natural Resources	Web Soil Survey	11/7/2016

Conservation Service	National Cooperative Soil Survey	Page 1 of 3


-------
Depth to Water Table—McKinley County Area, New Mexico, McKinley County and Parts of Cibola and San Juan Counties

(4 mines)

MAP LEGEND

MAP INFORMATION

Area of Interest (AOI)

Not rated or not available

The soil surveys that comprise your AOI were mapped at 1:24,000.

~

Area of Interest (AOI)

Water Features

Please rely on the bar scale on each map sheet for map

Soils



Streams and Canals

measurements.

Soil Rating Polygons

Transportation

Source of Map: Natural Resources Conservation Service

~

0-25

f-t-f. Rails

Web Soil Survey URL: http://websoilsurvey.nrcs.usda.gov

~

25-50

Interstate Highways

Coordinate System: Web Mercator (EPSG:3857)

~

50-100



Maps from the Web Soil Survey are based on the Web Mercator

US Routes

projection, which preserves direction and shape but distorts

~

100 -150

Major Roads

distance and area. A projection that preserves area, such as the

~

150-200

Albers equal-area conic projection, should be used if more accurate

Local Roads

calculations of distance or area are required.

~

> 200

Background

This product is generated from the USDA-NRCS certified data as of

~

Not rated or not available

Aerial Photography

the version date(s) listed below.

Soil Rating Lines

Soil Survey Area: McKinley County Area, New Mexico, McKinley

0-25
25 - 50
» 0 50-100

County and Parts of Cibola and San Juan Counties
Survey Area Data: Version 11, Sep 26, 2014

Soil map units are labeled (as space allows) for map scales 1:50,000
or larger.

100-150
150-200

Date(s) aerial images were photographed: May 21, 2010—Nov 7,
2010

> 200

n I Not rated or not available
Soil Rating Points

The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident.

g 0-25



~ 25-50



~ 50-100



~ 100-150



g 150-200



g > 200



US DA

Natural Resources
Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 2 of 3


-------
Depth to Water Table—McKinley County Area, New Mexico, McKinley County and Parts of Cibola
and San Juan Counties

4 mines

Depth to Water Table

Depth to Water Table— Summary by Map Unit — McKinley County Area. New Mexico. McKinley County and Parts of Cibola

and San Juan Counties (NM692)

Map unit symbol

Map unit name

Rating (centimeters)

Acres in AOI

Percent of AOI

205

Penistaja-Tintero
complex, 1 to 10
percent slopes

>200

1,166.7

50.7%

210

Marianolake-Skyvillage
complex, 1 to 8
percent slopes

>200

20.1

0.9%

220

Hagerwest-Bond fine
sandy loams, 1 to 8
percent slopes

>200

41.3

1.8%

230

Sparank-San Mateo-Zia
complex, 0 to 3
percent slopes

>200

787.0

34.2%

265

Uranium mined lands

>200

285.3

12.4%

Totals for Area of Interest

2,300.3

100.0%

Description

"Water table" refers to a saturated zone in the soil. It occurs during specified
months. Estimates of the upper limit are based mainly on observations of the water
table at selected sites and on evidence of a saturated zone, namely grayish colors
(redoximorphic features) in the soil. A saturated zone that lasts for less than a month
is not considered a water table.

This attribute is actually recorded as three separate values in the database. A low
value and a high value indicate the range of this attribute for the soil component. A
"representative" value indicates the expected value of this attribute for the
component. For this soil property, only the representative value is used.

Rating Options

Units of Measure: centimeters
Aggregation Method: Dominant Component
Component Percent Cutoff: None Specified
Tie-break Rule: Lower
Interpret Nulls as Zero: No
Beginning Month: J a n u a ry
Ending Month: December

USPA Natural Resources

Conservation Service

Web Soil Survey
National Cooperative Soil Survey

11/7/2016
Page 3 of 3


-------
| U.S. Fish and Wildlife Service

National Wetlands Inventory

tronox 4 mines

November 7, 2016

~ Estuarine arid Marine Deepwater	Freshwater Forested/Shrub Wetland	Other

Estuarine and Marine Wetland	Q Freshwater Pond Riverine

Freshwater Emergent Wetland	Lake

This map is for general reference only. The US Fish and Wildlife
Service is not responsible for the accuracy or currentness of the
base data shown on this map. All wetlands related data should
be used in accordance with the layer metadata found on the
Wetlands Mapper web site.

National Wetlands Inventory (NWI)
This page was produced by the NWI mapper


-------
IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248
Fax (602) 275-3836

Date: November BO, 2016
Submitted by: Weston Solutions
Report To: David Bordelon
Report #: 6654639
Date Received: November 21, 2016

SOIL ANALYSIS

* *

**

Sender
I.D.

Lab
No

Total
Carbon

%

Total
Nitrogen

%

C:N

Water Holding
Capacity - 0 Bar

%

WGSA-S01-160922

920

2.93

0.113

26:1

26.07

WGSA-S02-160922

921

1.175

0.093

13:1

26.92

WGSA-S03-160922

922

1.164

0.101

12:1

29.30

WGSA-S04-160922

923

0.932

0.041

23:1

20.27

WGSA-S05-160922

924

1.524

0.092

17:1

28.75

WGSA-S06-160926

925

4.138

0.088

47:1

26.46

WGSA-S07-160926

926

1.058

0.040

26:1

22.53

WGSA-S08-160926

927

1.683

0.051

33:1

26.09

WGSA-S09-160926

928

1.177

0.074

16:1

28.21

WGSA-S10-160926

929

1.67

0.044

38:1

27.46

WGSA-S11-161101

930

2.25

0.010

225:1

27.43

WGSA-S12-161101

931

0.809

0.001

809:1

22.31

WGSA-S13-161101

932

1.661

0.074

22:1

26.78

WGSA-S14-161101

933

1.219

0.110

11:1

33.66

WGSA-S15-161101

934

1.242

0.0418

30:1

32.69

WGSA-S16-161116

935

1.775

0.454

4:1

27.10

WGSA-S17-161116

936

1.338

0.065

21:1

31.85

WGSA-S18-161116

937

1.271

0.645

2:1

29.25

WGSA-S19-161116

938

1.79

0.044

41:1

28.42

WGSA-S20-161116

939

1.179

0.989

1:1

30.33

WGSA-S21-161116

940

1.491

0.039

38:1

17.33

WGSA-S22-161116

941

1.077

0.949

1:1

53.45

*AOAC Official Method 993.13
**ASTM D3152-72


-------
IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248
Fax (602) 275-3836

PLANT ANALYSIS

* *

Date: November 30, 2016
Submitted by: Weston Solutions
Report To: David Bordelon
Report #: 6654639
Date Received: November 21, 2016

Sender

Lab

Iron

Zinc

Copper

Manganese

Molybdenum

Uranium

Vanadium

Selenium

I.D.

No

PPm

PPm

PPm

PPm

PPm

PPm

PPm

PPm

WGSA-P01-160922

397

1320.4

63.1

3.8

20.4

1.07

<0.50

<0.04

<0.61

WGSA-P02-160922

398

394.0

40.3

7.1

27.7

0.81

<0.50

<0.04

<0.81

WGSA-P03-160922

399

198.5

17.2

3.5

38.8

0.46

8.95

<0.04

<1.41

WGSA-P04-160922

400

65.8

20.0

3.8

1.3

0.34

10.25

<0.04

1.25

WGSA-P05-160922

401

77.6

13.5

3.4

6.2

0.54

6.34

<0.04

<0.65

WGSA-P06-160926

402

160.0

16.3

4.7

1.2

0.90

12.33

<0.04

<0.65

WGSA-P07-160926

403

164.2

5.6

1.5

3.8

2.09

<0.50

<0.04

<0.65

WGSA-P08-160926

404

605.6

12.1

4.4

94.1

0.89

3.2

<0.04

<0.65

WGSA-P09-160926

405

98.5

25.0

4.3

31.3

87.61

0.64

<0.04

17.45

WGSA-P10-160926

406

213.1

16.3

5.6

39.4

3.44

<0.50

<0.04

<0.65

WGSA-P11-161101

407

275.1

23.9

3.5

22.6

1.47

<0.50

<0.04

<0.65

WGSA-P12-161101

408

157.8

40.4

6.4

8.2

1.98

4.63

<0.04

205.24

WGSA-P13-161101

409

583.8

14.8

4.5

64.0

0.83

4.93

<0.04

<0.65

WGSA-P14-161101

410

387.9

9.8

2.4

52.5

0.71

1.32

<0.04

<0.90

WGSA-P15-161101

411

255.5

8.9

1.5

15.8

0.56

<0.50

<0.04

<0.65

*EPA 3050B


-------
Date: November 30, 2016
Submitted by: Weston Solutions
Report To: David Bordelon
Report #: 6654639
Date Received: November 21, 2016

PLANT ANALYSIS





*

*

*

*

*

*

*

*

Sender

Lab

Iron

Zinc

Copper

Manganese

Molybdenum

Uranium

Vanadium

Selenium

I.D.

No

PPm

PPm

PPm

PPm

PPm

PPm

PPm

PPm

WGSA-P16-161116

412

260.9

10.6

4.9

56.7

0.98

1.4

<0.04

<0.65

WGSA-P17-161116

413

356.0

13.0

2.9

41.4

0.83

5.2

<0.04

<0.65

WGSA-P18-161116

414

633.8

10.5

3.2

60.8

1.07

11.9

<0.04

<0.65

WGSA-P19-161116

415

505.0

11.8

2.7

43.8

0.86

5.5

<0.04

<0.65

WGSA-P20-161116

416

760.2

17.3

5.4

53.6

2.30

7.5

<0.04

<0.65

WGSA-P21-161116

417

486.0

14.1

4.0

77.9

0.64

9.1

<0.04

<0.65

WGSA-P22-161116

418

220.1

9.9

2.4

44.9

0.57

6.5

<0.04

<0.65

IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248
Fax (602) 275-3836

*EPA 3050B


-------
IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248

SOIL ANALYSIS REPORT

Page 1

Today's Date:
Grower:
Submitted By:
Send Report To:
Report Number:
Crop:

Date Received:

11/30/2016
WGSA

David Bordelon
Weston Solutions
6654639
Native Plants
11/21/2016

VL= Very Low
L= Low
M= Medium
H = High
VH= Very High

Sender
Sample
Id

Depth

Lab#

PH

Calcium
(Ca)

PPM

Magnesium
(Mg)

PPM

Sodium
(Na)

PPM

Potash
(K)

PPM

Iron
(Fe)

PPM

Zinc
(Zn)

PPM

Manganese
(Mn)

PPM

Copper
(Cu)

PPM

Salinity
(EC x K)
dS/m

Nitrate
Nitrogen
(N03-N)
PPM

Phosphorus
(Bicarb -
Soluble P)
PPM

Computed
% Sodium

(ESP)

Sulfur
(S04-S)

PPM

Boron
(B)

PPM

Free
Lime
Level

S01-1609
22



920

9.0

6200 VH

430 VH

56 L

85 L

3.5 M

.12 VL

.34 VL

.15 L

.5 VL

9.1 L

5.9 L

.7

3.3 VL

.38 L

High

S02-1609
22



921

8.1

6100 VH

230 H

93 L

240 M

8.3 M

.22 L

1.5 M

.59 M

1.6 L

8.4 L

7.8 L

1.2

120 VH

.45 L

High

S03-1609
22



922

8.3

4200 H

410 VH

86 L

470 H

8.8 M

.14 VL

1.7 M

.74 M

.9 L

12.0 M

4.3 VL

1.4

3.9 VL

.39 L

Medium

S04-1609
22



923

8.7

1800 L

120 M

58 L

300 M

8.6 M

.46 L

1.6 M

.48 M

.4 VL

11.0 M

6.7 L

2.3

4.1 VL

.25 VL

Medium

S05-1609
22



924

8.5

6800 VH

400 VH

60 L

610 H

6.0 M

.34 L

1.6 M

.76 M

.9 L

10.0 L

7.1 L

.7

9.1 L

.43 L

High

S06-1609
26



925

7.9

33000 VH

290 H

120 M

290 M

2.8 M

.28 L

.91 L

.50 M

5.3 VH

12.0 M

4.8 VL

.3

1100 VH

.63 L

High

S07-1609
26



926

8.5

4600 H

210 M

53 L

140 L

5.6 M

.15 VL

1.4 M

.38 M

.9 L

8.6 L

5.3 L

.9

12 M

.22 VL

Medium

S08-1609
26



927

8.5

6800 VH

420 VH

60 L

390 M

6.1 M

.16 VL

1.8 M

.65 M

.7 L

11.0 M

6.2 L

.7

9.6 L

.28 VL

High

S09-1609
26



928

8.3

3400 M

220 M

52 L

310 M

16.0 M

2.9 M

3.9 M

2.3 H

.6 L

10.0 L

10.0 M

1.1

15 M

.24 VL

Medium

S10-1609
26



929

8.6

7000 VH

360 H

69 L

220 M

4.7 M

.16 VL

1.4 M

.50 M

.5 VL

8.9 L

5.8 L

.8

8.1 L

.21 VL

High

S11-1611
01



930

8.6

7200 VH

1000 VH

110 M

120 L

4.8 M

.07 VL

1.9 M

.20 L

1.0 L

9.1 L

4.3 VL

1.1

23 H

.38 L

High

S12-1611
01



931

8.6

1400 L

96 M

49 L

100 L

5.5 M

.34 L

1.1 M

.35 M

.3 VL

7.9 L

4.7 VL

2.6

5.1 VL

.10 VL

Low


-------
IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248

SOIL ANALYSIS REPORT	Page 2

Today's Date:

11/30/2016



Grower:

WGSA

VL= Very Low

Submitted By:

David Bordelon

L= Low

Send Report To:

Weston Solutions

M= Medium

Report Number:

6654639

H = High

Crop:

Native Plants

VH= Very High

Date Received:

11/21/2016



Sender
Sample
Id

Depth

Lab#

PH

Calcium
(Ca)

PPM

Magnesium
(Mg)

PPM

Sodium
(Na)

PPM

Potash
(K)

PPM

Iron
(Fe)

PPM

Zinc
(Zn)

PPM

Manganese
(Mn)

PPM

Copper
(Cu)

PPM

Salinity
(EC x K)
dS/m

Nitrate
Nitrogen
(N03-N)
PPM

Phosphorus
(Bicarb -
Soluble P)
PPM

Computed
% Sodium

(ESP)

Sulfur
(S04-S)

PPM

Boron
(B)

PPM

Free
Lime
Level

S13-1611
01



932

8.7

7400 VH

260 H

60 L

270 M

7.5 M

.08 VL

.90 L

.37 M

.5 VL

8.3 L

4.8 VL

.7

5.1 VL

.33 L

High

S14-1611
01



933

8.3

7800 VH

310 H

220 H

270 M

13.0 M

.31 L

2.1 M

.89 M

1.5 L

12.0 M

7.9 L

2.2

72 VH

.55 L

High

S15-1611
01



934

8.2

7100 VH

340 H

140 M

460 H

7.7 M

.32 L

2.4 M

1.0 H

1.8 L

17.0 M

9.2 L

1.5

110 VH

.43 L

High

S16-1611
16



935

8.6

7400 VH

370 H

49 L

150 M

4.5 M

.09 VL

1.2 M

.46 M

.5 VL

10.0 L

4.8 VL

.5

3.0 VL

.20 VL

High

S17-1611
16



936

8.4

5300 H

620 VH

74 L

920 VH

12.0 M

2.3 M

1.8 M

.55 M

1.4 L

8.7 L

5.9 L

.9

15 M

.42 L

Medium

S18-1611
16



937

8.4

7600 VH

520 VH

170 M

160 M

9.7 M

.92 M

2.0 M

.83 M

1.1 L

12.0 M

5.2 L

1.7

27 H

.68 L

High

S19-1611
16



938

8.2

7200 VH

330 H

94 L

440 H

5.4 M

.22 L

1.9 M

.77 M

1.7 L

44.0 H

6.2 L

1.0

54 VH

.40 L

High

S20-1611
16



939

7.9

7800 VH

330 H

230 H

210 M

7.8 M

.42 L

2.4 M

.93 M

5.3 VH

74.0 VH

7.8 L

2.3

500 VH

.53 L

High

S21-1611
16



940

8.1

6200 VH

310 H

100 L

120 L

6.1 M

.19 VL

1.4 M

.68 M

1.3 L

45.0 H

6.3 L

1.3

27 H

.50 L

Medium

S22-1611
16



941

8.2

6200 VH

450 VH

200 M

290 M

7.5 M

.15 VL

1.9 M

.87 M

1.7 L

30.0 H

5.1 L

2.4

57 VH

.49 L

Medium


-------
IAS Laboratories

2515 East University Drive
Phoenix, Arizona 85034
(602) 273-7248

SOIL ANALYSIS REPORT

Page 3

Today's Date:
Grower:
Submitted By:
Send Report To:
Report Number:
Crop:

Date Received:

11/30/2016
WGSA

David Bordelon
Weston Solutions
6654639
Native Plants
11/21/2016

VL= Very Low
L= Low
M= Medium
H = High
VH= Very High

Sender

Depth

Lab

Organic

Cation

Gypsum

Sand

Silt

Clay

SoilTexture

Sample



#

Matter

Exchange

Requirement









Number







Capacity

















%

MEQ/100G

Tons/Acre

%

%

%



301-160922



920







72

20

8

Sandy Loam

302-160922



921







40

20

40

Clay

303-160922



922







30

26

44

Clay

304-160922



923







74

10

16

Sandy Loam

305-160922



924







34

32

34

Clay Loam

306-160926



925







36

26

38

Clay Loam

307-160926



926







70

15

15

Sandy Loam

308-160926



927







44

30

26

Loam

309-160926



928







52

19

29

Sandy Clay Loam

310-160926



929







48

28

24

Sandy Clay Loam

311-161101



930







32

32

36

Clay Loam

312-161101



931







74

11

15

Sandy Loam

313-161101



932







56

24

20

Sandy Clay Loam

314-161101



933







14

30

56

Clay

315-161101



934







18

24

58

Clay

316-161116



935







46

31

23

Loam

317-161116



936







40

18

42

Clay

318-161116



937







28

22

50

Clay

319-161116



938







32

26

42

Clay

320-161116



939







22

28

50

Clay

321-161116



940







22

38

40

Clay

322-161116



941







36

20

44

Clay


-------
IAS Laboratories

2515 East University Drive	SOIL FERTILITY RECOMMENDATIONS

Phoenix, Arizona 85034

(602)273-7248	Lb/1000 Sq Ft

Grower: WGSA	Send To: Weston Solutions

Report No: 6654639	Date: 11/21/2016	Page: 4

AMENDMENTS

Sender
Number

Crop

Nitrogen
N

Phosphate
P205

Potash
K20

Magnesium
Mq

Sulfur
S

Iron
Fe

Zinc
Zn

Manganese
Mn

Copper
Cu

Boron
B

Elemental
Sulfur

Gypsum

Lime

Leaching of
Excess Salts

S01-160922

Nat

ve Plants

2a

2b

1 c







¦2 a

¦4 i

.02 i

.02 h

30*







S02-160922

Nat

ve Plants

2a

2b



3.5 d





.1 g





.02 h

5*







S03-160922

Nat

ve Plants

1 a

2.5 b









¦2 g





.02 h

10*







S04-160922

Nat

ve Plants

2a

2b









.1 g





.02 h

15*

50#





S05-160922

Nat

ve Plants

2a

2b









.1 g





.02 h

10*







S06-160926

Nat

ve Plants

1 a

2.5 b



5 d





.1 g

¦4 i



.02 h







Yes

S07-160926

Nat

ve Plants

2a

2b

1 c







¦2 g





.02 h

10*







S08-160926

Nat

ve Plants

2a

2b









¦2 g





.02 h

10*







S09-160926

Nat

ve Plants

2a

2b















.02 h

10*







S10-160926

Nat

ve Plants

2a

2b









¦2 g





.02 h

15*







S11-161101

Nat

ve Plants

2a

2.5 b

1 c







¦2 g



.02 i

.02 h

15*







S12-161101

Nat

ve Plants

2a

2.5 b

1 c







.1 g





.02 h

15*

50#





S13-161101

Nat

ve Plants

2a

2.5 b



5 d





¦2 g

¦4 i



.02 h

15*







S14-161101

Nat

ve Plants

1 a

2b



4 d





.1 g





.02 h

10*







S15-161101

Nat

ve Plants

1 a

2b



1 d





.1 g





.02 h

5*







S16-161116

Nat

ve Plants

2a

2.5 b









¦2 g





.02 h

15*







S17-161116

Nat

ve Plants

2a

2b











.1 i



.02 h

10*





Yes

S18-161116

Nat

ve Plants

1 a

2b















.02 h

10*







S19-161116

Nat

ve Plants



2b



2d





.1 g





.02 h

5*







S20-161116

Nat

ve Plants



2b



3d





.1 g





.02 h







Yes

S21-161116

Nat

ve Plants



2b

1 c







¦2 g





.02 h

5*







S22-161116

Nat

ve Plants



2b









¦2q





.02 h

5*







Native Plants

a)	Broadcast nitrogen and water then water the nitrogen into the soil.

b)	Broadcast phosphorus and till into soil where possible. Phosphorus works best when it is closest to the roots.

c)	Broadcast potassium and till into the soil. Then water the potassium into the ground.

d)	Apply magnesium to balance the salts and to increase the water holding capacity of the soil.

g)	Use zinc sulfate. Mix the zinc in water and then spray the zinc solution onto soil; then till,
j) Use manganese sulfate form. Best if mixed in water and sprayed on soil then tilled.

i) Copper sulfate can be used. Mix in water and spray on soil then till.

h)	Apply boron by dissolving it in water and they spray it over the soil. If you cannot find a boron fertilizer you can use 20 mule team borax located in the laundry


-------
SOIL FERTILITY RECOMMENDATIONS
Lb/1000 Sq Ft

Grower: WGSA	Send To: Weston Solutions

Report No: 6654639	Date: 11/21/2016	Page: 5

AMENDMENTS

Sender

Crop

Nitrogen

Phosphate

Potash

Magnesium

Sulfur

Iron

Zinc

Manganese

Copper

Boron

Elemental

Gypsum

Lime

Leaching of

Number



N

P205

K20

Mg

S

Fe

Zn

Mn

Cu

B

Sulfur





Excess Salts

isle. If you use borax, mix 1 tbsp into 5 gallons of water. Then apply 2 gallons of solution per 1000 sqft.

#) Apply gypsum to balance the salts and to increase the amount of oxygen in the soil to reduce root rot.

*) Incorporate elemental sulfur into the soil to reduce the soil pH. Disper/sul or SSP are sulfur products that should dissolve readily and can be used if you can't till. This sulfur application will also help increase
the overall concentration of the soil. Sulfur is needed for enzyme formation in nitrogen utilization.

N) Irrigate with extra water to reduce the overall salinity and potassium. Salinity at 5 dS/m is high enough to harm some native plants and potassium concentrations over 900 ppm can cause plant leaf margin to
yellow.


-------
Transect 1

Species

Begin End

Total



BASC

685

700

15

BASC

720

746

26

BASC

795

801

6

BASC

1108

1117

9

BASC

1340

1348

8

BASC

1370

1372

2

BASC

1386

1401

15

BASC

1403

1441

38

BASC

1510

1525

15

BASC

1548

1561

13

BASC

1578

1582

4

BASC

1603

1608

5

BASC

1658

1663

5

BASC

1683

1701

18

BASC

1718

1726

8

BASC

1895

1908

13

BASC

1925

1931

6

BASC

1948

1961

13

BASC

2236

2258

22

BASC

2268

2281

13

BASC

2345

2358

13

BASC

2534

2558

24

BASC

2562

2575

13

BASC

2588

2561

-27

BASC

2710

2718

8

BASC

2738

2751

13

BASC

2778

2792

14

BASC

2855

2868

13

Pleuraphis jamesii

607

12.14

Bassia scoparia

507

10.14

Bouteloua gracilis

446

8.92

Salsola tragus

436

8.72

Krashcinnokovia lanata

96

1.92

Muhlenbergia torreyi

18

0.36

Elymus elymoides

8

0.16

Sporobolus conctractus

3

0.06



2121

42.42


-------
BASC

2870

2882

12

BASC

2891

2901

10

BASC

4308

4321

13

BASC

4518

4531

13

BASC

4554

4561

7

BASC

4576

4591

15

BASC

4618

4621

3

BASC

4648

4650

2

BASC

4678

4681

3

BASC

4695

4702

7

BASC

4721

4730

9

BASC

4745

4754

9

BASC

4759

4771

12

BASC

4805

4820

15

BASC

4871

4891

20

BASC

4891

4902

11

BASC

4950

4958

8

BASC

4968

4981

13

BOGR

0

29

29

BOGR

36

45

9

BOGR

58

92

34

BOGR

151

175

24

BOGR

565

570

5

BOGR

576

581

5

BOGR

590

610

20

BOGR

618

635

17

BOGR

664

670

6

BOGR

2618

2628

10

BOGR

3118

3172

54

BOGR

3359

3381

22


-------
BOGR

3394

3423

29

BOGR

3431

3480

49

BOGR

3494

3518

24

BOGR

3561

3582

21

BOGR

3641

3670

29

BOGR

3959

4018

59

ELEL

4108

4116

8

KRLA

885

902

17

KRLA

1218

1252

34

KRLA

3173

3191

18

KRLA

3608

3635

27

MUTO

3191

3205

14

MUTO

4038

4042

4

PLJA

208

342

134

PLJA

348

394

46

PLJA

410

515

105

PLJA

548

552

4

PLJA

918

938

20

PLJA

3208

3354

146

PLJA

3590

3608

18

PLJA

3690

3743

53

PLJA

3772

3810

38

PLJA

3846

3889

43

SATR

1148

1167

19

SATR

1172

1181

9

SATR

1623

1640

17

SATR

1778

1791

13

SATR

1825

1836

11

SATR

1862

1878

16

SATR

2004

2008

4

446
8

96
18

607


-------
SATR

2071

2076

5

SATR

2082

2088

6

SATR

2140

2151

11

SATR

2172

2183

11

SATR

2188

2199

11

SATR

2291

2302

11

SATR

2378

2391

13

SATR

2401

2418

17

SATR

2450

2562

112

SATR

2501

2507

6

SATR

2826

2831

5

SATR

2845

2851

6

SATR

2911

2916

5

SATR

2921

2942

21

SATR

3049

3061

12

SATR

3108

3116

8

SATR

4156

4162

6

SATR

4202

4231

29

SATR

4275

4290

15

SATR

4358

4360

2

SATR

4371

4390

19

SATR

4475

4491

16

SPCO

1202

1205

3

2121


-------
Transect 2

Species

Begin End

Total



ARBI

331

362

31

ARBI

3559

3608

49

ARBI

3877

3894

17

ARBI

3829

3858

29

ARBI

3879

3901

22

ARBI

4208

4251

43

ARBI

4577

4610

33

ARBI

4690

4708

18

ARBI

4830

4855

25

ARBI

4928

4951

23

BOGR

72

93

21

BOGR

141

172

31

BOGR

228

231

3

BOGR

404

431

27

BOGR

451

481

30

BOGR

489

518

29

BOGR

541

544

3

BOGR

571

602

31

BOGR

611

628

17

BOGR

651

666

15

BOGR

789

825

36

BOGR

840

851

11

BOGR

861

908

47

BOGR

925

961

36

BOGR

979

991

12

BOGR

985

1002

17

BOGR

1025

1036

11

BOGR

1059

1130

71

BOGR

1145

1185

40

BOGR

1198

1229

31

Bouteloua gracilis

1505

30.1

Pleuraphis jamesii

311

6.22

Artemisia bigelovii

290

5.8

Krascheninnikovia lanata

128

2.52

Tetradymia canescns

48

0.96

Gutierrezia sarothrae

13

0.26



2295

45.86


-------
BOGR

1270

1285

15

BOGR

1310

1330

20

BOGR

1351

1368

17

BOGR

1442

1451

9

BOGR

1461

1503

42

BOGR

1531

1534

3

BOGR

1541

1549

8

BOGR

1570

1575

5

BOGR

1670

1681

11

BOGR

1685

1702

17

BOGR

1728

1775

47

BOGR

1790

1830

40

BOGR

1872

1885

13

BOGR

1919

1928

9

BOGR

2000

2019

19

BOGR

2035

2061

26

BOGR

2075

2090

15

BOGR

2160

2221

61

BOGR

2251

2308

57

BOGR

2325

2348

23

BOGR

2370

2388

18

BOGR

2392

2416

24

BOGR

2535

2542

7

BOGR

2553

2561

8

BOGR

2578

2611

33

BOGR

2622

2645

23

BOGR

2680

2702

22

BOGR

2711

2735

24

BOGR

2848

2892

44

BOGR

2908

2920

12

BOGR

2928

2993

65

BOGR

3018

3039

21


-------
BOGR

3060

3085

25

BOGR

3099

3115

16

BOGR

3128

3150

22

BOGR

3188

3225

37

BOGR

3208

3289

81

BOGR

3351

3380

29

BOGR

4511

4529

18

GUSA

2768

2781

13

KRLA

444

451

7

KRLA

768

775

7

KRLA

1630

1655

25

KRLA

2055

2108

53

KRLA

2240

2251

11

KRLA

2791

2810

19

KRLA

3005

3011

6

PLJA

0

48

48

PLJA

172

210

38

PLJA

266

296

30

PLJA

362

391

29

PLJA

681

732

51

PLJA

741

753

12

PLJA

1948

1958

10

PLJA

1978

1989

11

PLJA

2118

2148

30

PLJA

4051

4083

32

PLJA

4951

4971

20

TECA

4441

4489

48
2295

1505
13

128

311
48

45.90%

2295


-------
Transect 3

Species

Begin End

Total



PASM

3195

3241

46

PASM

3781

3870

89

PASM

4049

4071

22

BASC

4208

4218

10

BASC

4248

4261

13

BASC

4328

4355

27

BASC

4801

4803

2

BASC

4818

4831

13

BASC

4971

4989

18

BOGR

0

31

31

BOGR

51

141

90

BOGR

161

241

80

BOGR

481

510

29

BOGR

571

602

31

BOGR

710

731

21

BOGR

749

761

12

BOGR

820

851

31

BOGR

908

931

23

BOGR

951

985

34

BOGR

1185

1359

174

BOGR

1471

1545

74

BOGR

1555

1604

49

BOGR

1789

2048

259

BOGR

2760

2902

142

BOGR

3566

3780

214

BOGR

3971

3989

18

BOGR

4471

4478

7

BOGR

4506

4531

25

Pascopyrum smithii	157	3.14

Bassia scoparia	83	1.66


-------
BOGR

4571

4608

37



BOGR

4678

4701

23

1404

ERNA

291

410

119



ERNA

1604

1789

185



ERNA

2055

2071

16



ERNA

2079

2401

322



ERNA

2401

2491

90



ERNA

2630

2760

130



ERNA

2902

3141

239



ERNA

3285

3494

209

1310

GUSA

775

785

10



GUSA

1048

1061

13



GUSA

1071

1099

28



GUSA

1455

1471

16

67

PLJA

3850

3971

121



PLJA

4091

4172

81



PLJA

4720

4748

28



PLJA

4778

4801

23



PLJA

4861

4868

7



PLJA

4938

4971

33

293

SPAR

671

710

39



SPAR

3908

3932

24

63

SPCO

4638

4641

3

3







3380



3380

Bouteloua gracilis

1404	28.08

Ericameria nauseosa 1310	26.02

Gutierrezia sarothrae 67	1.34

Pleuraphis jamesii 293	5.86

Sporobolus airoides 63	1.26

Sporobolus contractus 3	0.06

3380	67.42


-------
Species

Begin End



ATCA

205

220

ATCA

335

351

ATCA

789

821

ATCA

1410

1421

ATCA

1938

1961

ATCA

2039

2096

ATCA

2415

2435

ATCA

3080

3131

ATCA

4248

4261

BOGR

235

246

BOGR

670

736

BOGR

765

795

BOGR

850

878

BOGR

970

990

BOGR

1010

1030

BOGR

1140

1180

BOGR

1190

1210

BOGR

1240

1290

BOGR

1345

1360

BOGR

1378

1410

BOGR

1440

1461

BOGR

1536

1575

BOGR

1592

1654

BOGR

1685

1710

BOGR

1725

1742

BOGR

1765

1778

BOGR

1800

1821

BOGR

1851

1872

Transect 4

238	4.76 Atriplex canescens

15

16

32

11

23

57

20

51

13

11

66

30

28

20

20

40

20

50

15

32

21

39

62

25

17

13

21

21


-------
BOGR

1901

1938

37

BOGR

1965

1983

18

BOGR

1998

2031

33

BOGR

2125

2155

30

BOGR

2175

2204

29

BOGR

2216

2245

29

BOGR

2312

2369

57

BOGR

2455

2481

26

BOGR

2501

2530

29

BOGR

2531

2592

61

BOGR

2661

2672

11

BOGR

2755

2778

23

BOGR

2829

2949

120

BOGR

2851

2872

21

BOGR

2901

2932

31

BOGR

2972

3039

67

BOGR

3138

3187

49

BOGR

3218

3331

113

BOGR

3380

3385

5

BOGR

3401

3448

47

BOGR

3529

3551

22

BOGR

3576

3600

24

BOGR

3660

3681

21

BOGR

3728

3735

7

BOGR

3890

3903

13

BOGR

3948

3963

15

BOGR

3976

4011

35

BOGR

4120

4131

11

BOGR

4176

4203

27

BOGR

4340

4349

9


-------
BOGR

4399

4425

26

BOGR

4430

4491

61

BOGR

4531

4578

47

BOGR

4889

4943

54

BOGR

4981

5000

19

MUTO

385

421

36

MUTO

485

510

25

MUTO

4589

4675

86

PLJA

4066

4081

15







2178

35.56 Bouteloua gracilis

2.94 Muhlenbergia torreyi
0.3 Pleuraphis jamesii


-------
Species

Begin End

Total



AGSM

2780

2790

10

AGSM

3035

3040

5

AGSM

4280

4310

30

AGSM

4320

4346

26

ATCA

229

265

36

ATCA

468

481

13

ATCA

1030

1135

105

ATCA

3130

3160

30

ATCA

3521

3541

20

ATCA

3550

3580

30

ATCA

3730

3805

75

BASC

295

301

6

BASC

742

751

9

BASC

3710

3726

16

BASC

3850

3896

46

BASC

4570

4580

10

BASC

4815

4821

6

GUSP

1735

1755

20

GUSP

1815

1851

36

GUSP

1855

1886

31

GUSP

2020

2025

5

GUSP

2065

2085

20

MACA

562

571

9

MACA

810

831

21

MACA

901

911

10

MACA

951

1022

71

MACA

1135

1221

86

MACA

1270

1305

35

Transect 5

71 1.42 Pascopyrum smithii

309 6.18 Atriplex canescens

93 1.86 Bassia scoparia

112 2.24 Gutierrezia sarothrae

419

8.38

308

6.18

208

4.16

112

2.24

93

1.86


-------
MACA

1320

1365

45

MACA

1481

1505

24

MACA

2580

2600

20

MACA

2755

2775

20

MACA

2815

2858

43

MACA

2870

2905

35

SATR

51

72

21

SATR

201

222

21

SATR

2325

2381

56

SATR

2410

2441

31

SATR

2675

2710

35

SATR

2980

3009

29

SATR

3490

3495

5

SATR

4900

4905

5

SATR

4948

4950

2

SATR

4970

4973

3

SPCO

1405

1445

40

SPCO

1660

1705

45
1297

71

1.42

85

1.7

1296	25.94

8.38 Machaeranthera canescens

4.16 Salsola tragus

1.7 Sporobolus contractus
25.9


-------
Species

Begin End

Total



ACHY

2825

2840

15

ARPU

2575

2587

12

ARPU

2615

2648

33

ATCA

3915

3980

65

ATCA

4079

4125

46

ATCA

4600

4615

15

BOGR

2210

2255

45

BOGR

2260

2275

15

GUSA

2170

2190

20

GUSA

3760

3790

30

GUSA

4125

4143

18

JUMO

1290

1460

170

JUMO

0

10

10

KRLA

1830

1855

25

KRLA

3018

3028

10

KRLA

3426

3430

4

KRLA

4570

4581

11

KRLA

4950

4981

31

PLJA

155

223

68

PLJA

750

760

10

PLJA

785

810

25

PLJA

830

845

15

PLJA

850

870

20

PLJA

928

930

2

PLJA

976

993

17

PLJA

1028

1040

12

PLJA

1126

1135

9

PLJA

1148

1170

22

Transect 6

15	0.3 Acnatherum hymenoides

45	0.9 Aristida purpurea

126	2.52 Atriplex canescens
60 1.2 Bouteloua gracilis

68	1.36 Gutierrezia sarothrae
180 3.6 Juniperus monosperma

81

1.62 Krascheninnikovia lanata


-------
PLJA

2970

2985

15



PLJA

3160

3180

20



PLJA

3190

3211

21



PLJA

3291

3311

20



PLJA

3340

3360

20



PLJA

3381

3410

29



PLJA

3510

3515

5



PLJA

4348

4365

17

347

SPAI

2277

2380

103



SPAI

2430

2461

31



SPAI

3850

3915

65

199







1121

22.42%

6.94 Pleruaphis jamesii

3.98 Sporobolus airoides
22.42


-------
Species

Begin End



ARBI

145

165

ARBI

675

715

ARBI

981

1002

ARBI

1490

1500

ARBI

1555

1570

ARBI

1860

1872

ARBI

2285

2296

ARBI

3285

3301

ARBI

3330

3351

ARBI

3495

3518

ARBI

3558

3562

ARBI

4365

4401

BOGR

20

38

BOGR

68

87

BOGR

265

279

BOGR

581

595

BOGR

805

845

BOGR

875

903

BOGR

1221

1243

BOGR

1389

1408

BOGR

1436

1489

BOGR

1930

1981

BOGR

1990

2011

BOGR

2246

2262

BOGR

2745

2791

BOGR

2802

2868

BOGR

2888

2972

BOGR

3149

3165

Transect 7

20
40

21

10

15
12

11

16

21
23

4

36	229	4.58 Artemisia bigelovii

18

19
14
14
40
28

22
19
53
51
21
16
46
66
84
16


-------
BOGR

4090

4096

6

BOGR

4288

4301

13

BOGR

4495

4508

13

BOGR

4538

4575

37

BOGR

4637

4667

30

BOGR

4775

4780

5

BOGR

4790

4810

20

BOGR

4840

4851

11

BOGR

4920

4926

6

BOGR

4979

5006

27

ERSP

3927

3941

14

JUMO

1605

1798

193

JUMO

2490

2641

151

KRLA

3210

3228

18

KRLA

4718

4748

30

PLJA

3691

3708

17

PLJA

3858

3867

9

1356
27.12%

695	13.9 Bouteloua gracilis

14	0.28 Erigeron species

344	6.88 Juniprus monosperma

48	0.96

Krascheninnikovia lanata
26	0.52 Pleuraphis jamesii

27.12


-------
Transect 8

Species

Begin

AMAC

1825

ATCA

25

BOGR

1980

BOGR

2051

BOGR

2265

BOGR

3430

BOGR

4590

BOHI

4246

ERNA

2018

ERNA

2330

ERNA

3280

ERNA

4080

ERNA

4640

ERNA

4730

ERNA

4889

ERNA

2140

ERNA

4460

GUSA

3890

PDA

141

PDA

1630

PDA

1751

PDA

4051

PDA

4331

GRNU

595

GRNU

920

GRNU

1058

GRNU

1179

SPAR

261

SPAR

458

Total

1831	6	6

111	86	86

2011	31

2114	63

2305	40

3450	20

4612	22	176

4258	12	12

2051	33

2501	171

3330	50

4240	160

4660	20

4841	111

5068	179

2240	100

4580	120	944

3901	11	11

238	97

1672	42

1814	63

4076	25

4368	37	264

831	236

951	31

1080	22
1182 3	292

331	70

532	74	144

1935 38.70%

0.12 Ambrosia acanthicarpa
1.72 Atriplex canescens

3.52 Bouteloua gracilis
0.24 Bouteloua hirsuta

18.88 Ericameria nauseousa
0.22 Gutierrezia sarothrae

5.28 Pleuraphis jamesii

5.84 Grindelia nuda

2.88 Sporobolus airoides
38.70%


-------
Species

Begin End



ATCA

183

210

ATCA

401

450

ATCA

1361

1558

ATCA

1610

1628

ATCA

1718

1737

ATCA

1888

2118

ATCA

2408

2438

ATCA

2567

2670

ATCA

3351

3441

ATCA

3678

3708

ATCA

3629

3691

ATCA

4378

4451

ATCA

4475

4482

ATCA

4951

5000

BASC

10

18

BASC

21

28

BASC

102

116

BASC

178

183

BASC

630

634

BASC

691

693

BASC

819

861

BASC

862

893

BASC

948

961

BASC

968

983

BASC

1032

1041

BASC

1053

1064

BASC

1096

1116

BASC

1131

1154

Transect 9

27
49
197

18

19
230

30
103
90

30
62
73

7

49	984	19.68 Atriplex canescens

8
7

14
5
4
2

42

31
13

15

9

11

20
23


-------
BASC

1171

1186

BASC

1202

1210

BASC

1230

1268

BASC

1294

1302

BASC

1660

1664

BASC

1668

1672

BASC

2148

2172

BASC

2185

2195

BASC

2538

2567

BASC

2828

2835

BASC

3160

3198

BASC

3221

3236

BASC

3245

3250

BASC

3268

3280

BASC

3468

3490

BASC

3930

3968

BOGR

2891

2895

BOGR

3761

3782

BOGR

4207

4291

BOGR

4305

4329

BOGR

4351

4376

BOGR

4608

4640

BOGR

4748

4781

BOGR

4918

4942

PLJA

456

468

PLJA

471

491

PLJA

502

515

PLJA

526

541

PLJA

718

730

PLJA

2951

2988

15
8
38
8
4

4
24
10
29

7
38
15

5

12
22

38	481	9.62 Bassia scoparia

4
21
84

24

25

32

33

24	247	4.94 Bouteloua gracil

12
20

13
15
12
37


-------
PLJA

3011

3046

35

PLJA

3548

3571

23

PLJA

3601

3634

33

PLJA

4025

4031

6

PLJA

4110

4160

50

PLJA

4188

4192

4

PLJA

4501

4533

32

PLJA

4856

4889

33







2037

6.5 Pleuraphis jamesii
40.74


-------
Species

Begin End



ATCA

270

310

ATCA

368

465

ATCA

670

740

ATCA

830

861

ATCA

2990

3068

ATCA

3660

3741

ATCA

3840

3905

BASC

501

512

BASC

541

548

BASC

563

572

BASC

898

914

BASC

941

952

BASC

1041

1058

BASC

1220

1225

BASC

1271

1288

BASC

1298

1321

BASC

1350

1385

BASC

1520

1551

BASC

1578

1592

BASC

1918

1928

BASC

1976

1981

BASC

2038

2051

BASC

2156

2172

BASC

2268

2302

BASC

2328

2339

BASC

2371

2378

BASC

2401

2408

BASC

2628

2639

Transect 10

40
97
70
31
78
81

65	462	9.24 Atriplex canescens

11
7
9

16
11

17
5

17
23
35
31
14

10
5

13
16
34

11
7
7

11


-------
BASC

2691

2699

8

BASC

2748

2759

11

BASC

2789

2792

3

BASC

2819

2830

11

BASC

2912

2918

6

BASC

3141

3162

21

BASC

3210

3258

48

BASC

3278

3291

13

BASC

3411

3418

7

BASC

3480

3519

39

BASC

3919

3941

22

BASC

4021

4041

20

BASC

4098

4105

7

BASC

4226

4251

25

BASC

4382

4414

32

BASC

4491

4503

12

BASC

4540

4603

63

BASC

4605

4631

26

BASC

4715

4748

33

BASC

4795

4835

40

BASC

4930

4940

10

BASC

4955

4960

5

BASC

4968

4999

31

ELEL

971

1026

55

ELEL

1060

1071

11

ELEL

1090

1218

128

ELEL

1658

1676

18

ELEL

2940

2948

8

ELEL

3445

3471

26

GRNU

740

781

41

1

16.06 Bassia scoparia

4.92 Elymus elymoides
0.82 Grindelia nuda


-------
PAOB

0

270

270





PAOB

321

342

21

291

5.82 Panicum obtusum

SCBR

865

881

16

16

0.32 Scleropogon brevifolius

SPAR

1769

1781

12

12

0.24 Sporobolus airoides







1871

37.42%

37.42


-------
Species

Begin End



ATCA

151

201

ATCA

929

962

ATCA

1048

1118

ATCA

1170

1291

ATCA

1331

1482

ATCA

1518

1621

ATCA

1735

1821

ATCA

1859

1898

ATCA

1972

2138

ATCA

2370

2460

ATCA

2630

2671

ATCA

2920

2975

ATCA

3080

3170

ATCA

3340

3480

ATCA

3810

3981

ATCA

4338

4480

ATCA

4725

4780

ATCA

4928

4940

BOGR

0

15

BOGR

41

130

BOGR

216

230

BOGR

270

318

BOGR

340

351

BOGR

392

411

BOGR

431

478

BOGR

501

545

BOGR

620

678

BOGR

715

775

Transect 11

50
33
70
121
151
103
86
39
166
90
41
55
90
140
171
142
55

12	1615	32.3 Atriplex canescens

15

89

14

48

11

19

47

44

58

60


-------
BOGR

778

792

14

BOGR

1291

1331

40

BOGR

1482

1518

36

BOGR

1621

1659

38

BOGR

1659

1735

76

BOGR

1821

1859

38

BOGR

1945

1972

27

BOGR

2151

2182

31

BOGR

2461

2485

24

BOGR

2505

2530

25

BOGR

2560

2601

41

BOGR

2690

2720

11

BOGR

2810

2830

3

BOGR

2871

2920

11

BOGR

3560

3581

21

BOGR

3659

3701

42

BOGR

3738

3770

32

BOGR

4021

4061

40

BOGR

4190

4210

20

BOGR

4301

4325

24

PASM

830

841

11

PASM

876

899

23

PASM

4890

4896

6

GUSA

2219

2251

32
2686

19.98 Bouteloua gracilis

0.8 Pascopyrum smith
0.64
53.72


-------
Transect 12

Species

Begin End

Total



BOGR

39

60

21

BOGR

100

111

11

BOGR

155

171

16

BOGR

211

230

19

BOGR

258

281

23

BOGR

299

315

16

BOGR

326

345

19

BOGR

371

392

21

BOGR

418

441

23

BOGR

531

548

17

BOGR

560

611

51

BOGR

650

669

19

BOGR

678

693

15

BOGR

736

791

55

BOGR

828

838

10

BOGR

847

891

44

BOGR

905

935

30

BOGR

971

1021

50

BOGR

1040

1071

31

BOGR

1028

1038

10

BOGR

1180

1248

68

BOGR

1271

1332

61

BOGR

1358

1378

20

BOGR

1399

1422

23

BOGR

1458

1471

13

BOGR

1525

1568

43

BOGR

1578

1602

24

BOGR

1661

1681

20

BOGR

1692

1740

48

BOGR

1745

1769

24


-------
BOGR

1791

1808

17

BOGR

1825

1838

13

BOGR

1848

1858

10

BOGR

1872

1893

21

BOGR

1935

1951

16

BOGR

1991

2018

27

BOGR

2056

2091

35

BOGR

2160

2181

21

BOGR

2221

2246

25

BOGR

2251

2281

30

BOGR

2360

2391

31

BOGR

2401

2408

7

BOGR

2470

2481

11

BOGR

2678

2681

3

BOGR

2665

2685

20

BOGR

3081

3102

21

BOGR

3189

3220

31

BOGR

3230

3241

11

BOGR

3360

3381

21

BOGR

3661

3692

31

BOGR

3775

3821

46

BOGR

3891

3950

59

BOGR

3950

3981

31

BOGR

3976

3981

5

BOGR

4010

4030

20

BOGR

4065

4071

6

BOGR

4108

4112

4

BOGR

4121

4131

10

BOGR

4193

4205

12

BOGR

4250

4271

21

BOGR

4302

4368

66

BOGR

4389

4415

26


-------
BOGR

4426

BOGR

4508

BOGR

4548

BOGR

4590

BOGR

4618

BOGR

4675

BOGR

4788

BOGR

4852

BOGR

4918

BOGR

4990

PDA

2515

PLJA

2770

PLJA

2825

PLJA

3134

PLJA

3408

PLJA

3528

PLJA

3585

PLJA

3701

PLJA

3860

PLJA

4718

PLJA

4958

35
10

8

12

13

16
33
21

17

10	1728
25

11
10

18
72
23

36
40
18
23

14	290
2018 40.36%

4461

4518

4556

4602

4631

4691

4821

4873

4935

5000

2540

2781

2835

3152

3480

3551

3621

3741

3878

4741

4972

34.56 Bouteloua gracilis

5.8 Pleuraphis jamesii
40.36


-------
Species

Begin End



ATCA

4780

4785

BOGR

0

20

BOGR

51

108

BOGR

190

210

BOGR

440

461

BOGR

480

491

BOGR

605

635

BOGR

870

901

BOGR

1360

1381

BOGR

1408

1426

BOGR

1610

1620

BOGR

1665

1671

BOGR

1730

1791

BOGR

1928

1938

BOGR

2015

2041

BOGR

2011

2022

BOGR

2151

2231

BOGR

2301

2348

BOGR

2410

2428

BOGR

2485

2496

BOGR

2520

2531

BOGR

2595

2631

BOGR

2670

2701

BOGR

2735

2761

BOGR

2880

2901

BOGR

3035

3065

BOGR

3108

3140

BOGR

3190

3231

Transect 13

5	5	0.1 Atriplex canescens
20

57

20

21
11

30

31
21
18
10

6
61

10
26

11
80
47
18
11
11
36

31
26
21
30

32
41


-------
BOGR

3310

3330

20

BOGR

3348

3361

13

BOGR

3395

3401

6

BOGR

3431

3442

11

BOGR

3520

3541

21

BOGR

3670

3691

21

BOGR

3765

3801

36

BOGR

3838

3851

13

BOGR

3920

3945

25

BOGR

3961

3988

27

BOGR

4008

4032

24

BOGR

4061

4082

21

BOGR

4102

4108

6

BOGR

4132

4199

67

BOGR

4266

4293

27

BOGR

4340

4362

22

BOGR

4398

4418

20

BOGR

4495

4472

-23

BOGR

4540

4561

21

BOGR

4620

4640

20

BOGR

4730

4742

12

BOGR

4960

5000

40

KRLA

21

33

12

KRLA

158

170

12

KRLA

308

336

28

KRLA

635

662

27

KRLA

1305

1308

3

KRLA

2578

2583

5

KRLA

3280

3288

8

MUWR

930

1105

175

1187	23.74 Bouteloua gracilis

95

1.9 Krascheninnikovia lanata


-------
MUWR

1180

1261

81

256

PLJA

780

791

11



PLJA

1958

2005

47



PLJA

2239

2301

62



PLJA

4502

4528

26



PLJA

535

541

6

152

SPCO

810

821

11



SPCO

2062

2070

8

19







1714

34.28%

1714

5.12 Muhlenbergia wrightii

3.04 Pleuraphis jamesii
0.38 Sporobolus contractus
34.28


-------
Species

Begin End

Total



ATCA

1080

1150

70

ATCA

1282

1341

59

ATCA

1405

1518

113

ATCA

1558

1618

60

BASC

1876

1948

72

BASC

3590

3641

51

BASC

3761

3782

21

BASC

4430

4438

8

BASC

4620

4671

51

BASC

4905

4910

5

BASC

4986

4991

5

ERNA

760

940

180

ERNA

1948

2230

282

GRNU

1806

1813

7

GRNU

2306

2331

25

GRNU

2458

2470

12

GRNU

2994

3011

17

GRNU

3036

3065

29

GRNU

3995

4205

210

GRNU

4365

4385

20

GRNU

4715

4761

46

MACA

1840

1861

21

MACA

3920

3931

11

MACA

3978

3983

5

MACA

4010

4033

23

MACA

4445

4495

50

MACA

4548

4565

17

MACA

4755

4822

67

Transect 14

302	6.04 Atriplex canescens

213	4.26 Bassia scoparia

462	9.24 Ericameria nauseosa

366	7.32 Grindelia nuda

194	3.88 Machaeranthera canescens


-------
PASM

940

1012

72

PASM

0

365

365

PASM

405

437

32

PASM

495

585

90

PASM

608

651

43

PASM

1672

1706

34

PASM

2245

2253

8

PASM

3328

3545

217

PASM

3685

3726

41

PASM

3735

3891

156

PASM

4033

4166

133

PASM

4221

4258

37







2765

2765

24.56 Pascopyrum smith
55.3


-------
Transect 15

Species

Begin End

Total





BOGR

2272

2291

19



BOGR

488

621

133



BOGR

641

689

48



BOGR

910

935

25



BOGR

1039

1278

239



BOGR

1589

1621

32



BOGR

1640

1841

201



BOGR

2031

2178

147



BOGR

4620

4641

21

865

ERNA

0

130

130



ERNA

196

357

161



ERNA

442

461

19



ERNA

935

1039

104



ERNA

1968

2031

63



ERNA

2667

2714

47



ERNA

3421

3538

117



ERNA

4105

4143

38



ERNA

4641

4735

94



ERNA

4871

5000

129

902

GRNU

3710

3831

121



GRNU

3865

3895

30



GRNU

3910

3981

71

222

GUSA

2935

2941

6



GUSA

3048

3062

14

20

MUWR

3640

3710

70



MUWR

4802

4871

69

139

PLJA

1480

1501

21



PLJA

2798

2942

144



PLJA

3038

3058

20



PLJA

3062

3261

199

384







2532

50.64%

17.3 Bouteloua gracilis

18.04 Ericameria nauseosa

4.44 Grindelia nuda

0.4 Gutierrezia sarothrae
2.78 Muhlenbergia wrightii

7.68 Pleuraphis jamesii
50.64


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APPENDIX C

USFWS County List
NMDGF County List
New Mexico Forestry State Endangered Plants List
New Mexico Noxious Weed List
New Mexico Heritage SI Species
BLM Sensitive Species
UTM Locations of Burrows Occupied by Western Burrowing Owl
Plant and Animals Observed or Likely to Occur within the Study Area


-------
Of f

"^Ch J. ^

United States Department of the Interior

FISH AND WILDLIFE SERVICE

New Mexico Ecological Services Field Office
2105 OSUNA ROAD NE
ALBUQUERQUE, NM 87113
PHONE: (505)346-2525 FAX: (505)346-2542
URL: www.fws.gov/southwest/es/NewMexico/;
www.fws.gov/southwest/es/ES_Lists_Main2.html

f	U.S.

FISH A WILDLIFE
SERVICE

Consultation Code: 02ENNM00-2017-SLI-0053
Event Code: 02ENNM00-2017-E-00059
Project Name: USEPA Tronox Mines

October 27, 2016

Subject: List of threatened and endangered species that may occur in your proposed project
location, and/or may be affected by your proposed project

To Whom It May Concern:

Thank you for your recent request for information on federally listed species and important
wildlife habitats that may occur in your project area. The U.S. Fish and Wildlife Service
(Service) has responsibility for certain species of New Mexico wildlife under the Endangered
Species Act (ESA) of 1973 as amended (16 USC 1531 et seq.), the Migratory Bird Treaty Act
(MBTA) as amended (16 USC 701-715), and the Bald and Golden Eagle Protection Act
(BGEPA) as amended (16 USC 668-668c). We are providing the following guidance to assist
you in determining which federally imperiled species may or may not occur within your project
area and to recommend some conservation measures that can be included in your project design.

FEDERALLY-LISTED SPECIES AND DESIGNATED CRITICAL HABITAT

Attached is a list of endangered, threatened, and proposed species that may occur in your project
area. Your project area may not necessarily include all or any of these species. Under the ESA,
it is the responsibility of the Federal action agency or its designated representative to determine
if a proposed action "may affect" endangered, threatened, or proposed species, or designated
critical habitat, and if so, to consult with the Service further. Similarly, it is the responsibility of
the Federal action agency or project proponent, not the Service, to make "no effect"
determinations. If you determine that your proposed action will have "no effect" on threatened
or endangered species or their respective critical habitat, you do not need to seek concurrence
with the Service. Nevertheless, it is a violation of Federal law to harm or harass any
federally-listed threatened or endangered fish or wildlife species without the appropriate permit.

If you determine that your proposed action may affect federally-listed species, consultation with
the Service will be necessary. Through the consultation process, we will analyze information


-------
contained in a biological assessment that you provide. If your proposed action is associated with
Federal funding or permitting, consultation will occur with the Federal agency under section
7(a)(2) of the ESA. Otherwise, an incidental take permit pursuant to section 10(a)(1)(B) of the
ESA (also known as a habitat conservation plan) is necessary to harm or harass federally listed
threatened or endangered fish or wildlife species. In either case, there is no mechanism for
authorizing incidental take "after-the-fact." For more information regarding formal consultation
and HCPs, please see the Service's Consultation Handbook and Habitat Conservation Plans at
www.fws.gov/endangered/esa-library/index. html#consultations.

The scope of federally listed species compliance not only includes direct effects, but also any
interrelated or interdependent project activities (e.g., equipment staging areas, offsite borrow
material areas, or utility relocations) and any indirect or cumulative effects that may occur in the
action area. The action area includes all areas to be affected, not merely the immediate area
involved in the action. Large projects may have effects outside the immediate area to species
not listed here that should be addressed. If your action area has suitable habitat for any of the
attached species, we recommend that species-specific surveys be conducted during the
flowering season for plants and at the appropriate time for wildlife to evaluate any possible
project-related impacts.

Candidate Species and Other Sensitive Species

A list of candidate and other sensitive species in your area is also attached. Candidate species
and other sensitive species are species that have no legal protection under the ESA, although we
recommend that candidate and other sensitive species be included in your surveys and
considered for planning purposes. The Service monitors the status of these species. If significant
declines occur, these species could potentially be listed. Therefore, actions that may contribute
to their decline should be avoided.

Lists of sensitive species including State-listed endangered and threatened species are compiled
by New Mexico state agencies. These lists, along with species information, can be found at the
following websites:

Biota Information System of New Mexico (BISON-M): www.bison-m.org

New Mexico State Forestry. The New Mexico Endangered Plant Program:
www. emnrd. state. nm .us/SFD/F ore stMgt/Endangered. html

New Mexico Rare Plant Technical Council, New Mexico Rare Plants: nmrareplants.unm.edu
Natural Heritage New Mexico, online species database: nhnm.unm.edu
WETLANDS AND FLOODPLAINS

Under Executive Orders 11988 and 11990, Federal agencies are required to minimize the
destruction, loss, or degradation of wetlands and floodplains, and preserve and enhance their
natural and beneficial values. These habitats should be conserved through avoidance, or
mitigated to ensure that there would be no net loss of wetlands function and value.

2


-------
We encourage you to use the National Wetland Inventory (NWI) maps in conjunction with
ground-truthing to identify wetlands occurring in your project area. The Service's NWI program
website, www.fws.gov/wetlands/Data/Mapper.html integrates digital map data with other
resource information. We also recommend you contact the U.S. Army Corps of Engineers for
permitting requirements under section 404 of the Clean Water Act if your proposed action could
impact floodplains or wetlands.

MIGRATORY BIRDS

The MBTA prohibits the taking of migratory birds, nests, and eggs, except as permitted by the
Service's Migratory Bird Office. To minimize the likelihood of adverse impacts to migratory
birds, we recommend construction activities occur outside the general bird nesting season from
March through August, or that areas proposed for construction during the nesting season be
surveyed, and when occupied, avoided until the young have fledged.

We recommend review of Birds of Conservation Concern at website

www.fws.gov/migratorybirds/CurrentBirdIssues/Management/BCC.html to fully evaluate the
effects to the birds at your site. This list identifies birds that are potentially threatened by
disturbance and construction.

BALD AND GOLDEN EAGLES

The bald eagle (Haliaeetus leucocephalus) was delisted under the ESA on August 9, 2007. Both
the bald eagle and golden eagle (Aquila chrysaetos) are still protected under the MBTA and
BGEPA. The BGEPA affords both eagles protection in addition to that provided by the MBTA,
in particular, by making it unlawful to "disturb" eagles. Under the BGEPA, the Service may
issue limited permits to incidentally "take" eagles (e.g., injury, interfering with normal breeding,
feeding, or sheltering behavior nest abandonment). For information on bald and golden eagle
management guidelines, we recommend you review information provided at
www.fws.gov/midwest/eagle/guidelines/bgepa.html.

On our web site www.fws.gov/southwest/es/NewMexico/SBC_intro.cfm, we have included
conservation measures that can minimize impacts to federally listed and other sensitive species.
These include measures for communication towers, power line safety for raptors, road and
highway improvements, spring developments and livestock watering facilities, wastewater
facilities, and trenching operations.

We also suggest you contact the New Mexico Department of Game and Fish, and the New
Mexico Energy, Minerals, and Natural Resources Department, Forestry Division for
information regarding State fish, wildlife, and plants.

Thank you for your concern for endangered and threatened species and New Mexico's wildlife
habitats. We appreciate your efforts to identify and avoid impacts to listed and sensitive species
in your project area. For further consultation on your proposed activity, please call
505-346-2525 or email nmesfo@fws.gov and reference your Service Consultation Tracking
Number.

Attachment

3


-------
4


-------
United States Department of Interior
Fish and Wildlife Service

Project name: USEPA Tronox Mines

Official Species List

Provided by:

New Mexico Ecological Services Field Office
2105 OSUNA ROAD NE
ALBUQUERQUE, NM 87113
(505) 346-2525

http://www.fws.gov/southwest/es/NewMexico/
http://www.fws.gov/southwest/es/ES_Lists_Main2.html

Consultation Code: 02ENNM00-2017-SLI-0053
Event Code: 02ENNM00-2017-E-00059

Project Type: LAND - RESTORATION / ENHANCEMENT

Project Name: USEPA Tronox Mines

Project Description: Mine cleanup and vegetation recovery

Please Note: The FWS office may have modified the Project Name and/or Project Description, so it
may be different from what was submitted in your previous request. If the Consultation Code
matches, the FWS considers this to be the same project. Contact the office in the 'Provided by'
section of your previous Official Species list if you have any questions or concerns.

http://ecos.fws.gov/ipac, 10/27/2016 01:21PM

1


-------
xr.s.

FISH A WILDLIFE
SERVICE



United States Department of Interior
Fish and Wildlife Service

Project name: USEPA Tronox Mines

Project Location Map:

€

Project Coordinates: The coordinates are too numerous to display here.
Project Counties: McKinley, NM

http://ecos.fws.gov/ipac. 10/27/2016 01:21 PM

2


-------
United States Department of Interior
Fish and Wildlife Service

Project name: USEPA Tronox Mines

Endangered Species Act Species List

There are a total of 5 threatened or endangered species on your species list. Species on this list should be considered in
an effects analysis for your project and could include species that exist in another geographic area. For example, certain
fish may appear on the species list because a project could affect downstream species. Critical habitats listed under the
Has Critical Habitat column may or may not lie within your project area. See the Critical habitats within your
project area section further below for critical habitat that lies within your project. Please contact the designated FWS
office if you have questions.

Birds

Status

Has Critical Habitat

Condition(s)

Mexican Spotted owl (Strix
occidentalis lucida)

Population: Wherever found

Threatened

Final designated



Southwestern Willow flycatcher

(Empidonax traillii extimus)

Population: Wherever found

Endangered

Final designated



Yellow-Billed Cuckoo (Coccyzus
americanus)

Population: Western U.S. DPS

Threatened

Proposed



Fishes

Zuni Bluehead Sucker (Catostomus
discobolus yarrowi)

Population: Wherever found

Endangered

Final designated



Flowering Plants

Zuni fleabane (Erigeron rhizomatus)

Population: Wherever found

Threatened





http://ecos.fws.gov/ipac, 10/27/2016 01:21PM

3


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4*35

Critical habitats that lie within your project area

There are no critical habitats within your project area.

http://ecos.fws.gov/ipac, 10/27/2016 01:21PM

4


-------
10/27/2016

BISON-M

Maintained by:

Biota Information System
(/New Mexico

NATURAL HERIIAGE

NW MtXICO

Disclai mei Policy

Database Query

Close Window

Print Page

County Name

McKinley

Your search terms were as follows:
Status

State NM: Endangered
State NM: Threatened

Taxonomic Group

Fish

8 species returned.

# Species Taxonomic Group

1	Birds

# Species

7

Export to Excel

Species
ID

Common Name

Scientific Name

Photo

USGS
Distribution Map

County

Status

040370

Bald Eagle

Haliaeetus leucocephalus

P

McKinley

State NM:
Threatened

040384

Peregrine Falcon

Falco peregrinus

no map

McKinley

State NM:
Threatened

040385

Arctic Peregrine Falcon

Falco peregrinus tundrius

no photo

no map

McKinley

State NM:
Threatened

042070

Least Tern

Sternula antillarum

~

McKinley

State NM:
Endangered

040925

Costa's Hummingbird

Calypte costae

P

McKinley

State NM:
Threatened

040521

Southwestern Willow
Flycatcher

Empidonax traillii extimus



no map

McKinley

State NM:
Endangered

042200

Gray Vireo

Vireo vicinior

P

McKinley

State NM:
Threatened

010496

Zuni Bluehead Sucker

Catostomus discobolus
yarrowi

no map

McKinley

State NM:
Endangered

http://bison-m.org/reports.aspx7rty pe=13&county=%27031 %27,&status=%27201 %27,%27202%27,


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10/27/2016	BISON-M

Close Window

http://bison-m.org/repo lis.aspx?rtype=13&county=%27031 %27,&status=%27201 %27,%27202%27,


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NEW MEXICO STATE ENDANGERED PLANT SPECIES (19.21.2.8 NMAC)

Detailed information and images of many of these and other rare plants can be found at the New
Mexico Rare Plants website (http//nmrareplants.unm.edu/index.html) (plants marked with an * are not
listed on the NMRPTC website)

Botanical Name

Common Name

New Mexico Counties

Aliciella formosa

Aztec gilia

San Juan

Allium gooddingii *

Goodding's onion

San Juan, McKinley, Catron,
Lincoln, Santa Fe

Amsonia tharpii

Tharp's bluestar

Eddy

Argemone pleiacantha subsp. pinnatisecta
(A. pinnatisecta)

Sacramento prickly poppy

Otero

Astragalus humillimus

Mancos milkvetch

San Juan

Cirsium vinaceum

Sacramento Mountains thistle

Otero

Cirsium wrightii

Wright's marsh thistle

Chaves, Grant, Guadalupe,
Otero, Sierra, Socorro

Cleome multicaulis (Peritoma multicaulis)

slender spiderflower

Grant, Hidalgo

Coryphantha scheeri var. scheeri

Scheer's pincushion cactus

Chavez, Eddy

Cylindropuntia viridiflora

Santa Fe cholla

Santa Fe

Cypripedium parviflorum var. pubescens *

golden lady's slipper

San Juan, Grant, San Miguel

Echinocereus fendleri var. kuenzleri

Kuenzler's hedgehog cactus

Chavez, Eddy, Lincoln, Otero

Erigeron hessii

Hess' fleabane

Catron

Erigeron rhizomatus

Zuni fleabane

Catron, McKinley, San Juan

Eriogonum gypsophilum

gypsum wild buckwheat

Eddy

Escobaria duncanii

Duncan's pincushion cactus

Sierra

Escobaria organensis

Organ Mountain pincushion
cactus

Dona Ana

Escobaria sneedii var. leei

Lee's pincushion cactus

Eddy


-------
Escobaria sneedii var. sneedii

Sneed's pincushion cactus

Dona Ana

Escobaria villardii

Villard's pincushion cactus

Dona Ana, Otero

Hedeoma todsenii

Todsen's pennyroyal

Otero, Sierra

Helianthus paradoxus

Pecos sunflower

Cibola, Valencia, Socorro,
Guadalupe, Chavez

Hexalectris nitida

shining coralroot

Eddy, Otero

Hexalectris spicata *

crested coralroot

Sierra, Otero, Hidalgo

Ipomopsis sancti-spiritus

Holy Ghost ipomopsis

San Miguel

Lepidospartum burgessii

gypsum scalebroom

Otero

Lilium philadelphicum *

wood lily

Otero, Los Alamos, Sandoval,
San Miguel, Santa Fe

Mammillaria wrightii var. wilcoxii *

Wilcox pincushion cactus

Hidalgo, Grant, Dona Ana, Luna

Opuntia arenaria

sand prickly pear

Dona Ana, Luna, Socorro

Pediocactus knowltonii

Knowlton's cactus

San Juan

Pediomelum pentaphyllum

Chihuahua scurfpea

Hidalgo

Peniocereus greggii

night-blooming cereus

Dona Ana, Grant, Hidalgo, Luna

Polygala rimulicola var. mescalerorum

San Andres milkwort

Dona Ana

Puccinellia parishii

Parish's alkali grass

Catron, Cibola, Grant, Hidalgo,
McKinley, Sandoval, San Juan

Sclerocactus cloveriae subsp. brackii

Brack's cactus

San Juan, Rio Arriba, Sandoval

Sclerocactus mesae-verdae

Mesa Verde cactus

San Juan

Spiranthes magnicamporum *

lady tresses orchid

Bernalillo, Santa Fe, Guadalupe,
Rio Arriba


-------
NM - BLM SPECIAL STATUS PLANT SPECIES LIST

UPDATED WITH ESA STATUS SPECIES 1/4/12	FIELD OFFICE OCCURRENCE - VERIFIED, HYPOTHETICAL, PERIPERAL (WITHIN OFFICE BDRY BUT NOT ON BLM)	STATUS

FAMILY

SPECIES

COMMON NAME

RIO PUERCO -
NM110

SOCORRO -
NM120

FARMINGTON -
NM210

TAOS - NM220

LAS
CRUCES-
NM030

ROSWELL -
NM510

CARLSBAD -
NM520

NATURES

ERVE
GLOBAL
RANK

NATURES
ERVE
STATE
RANK

FWS STATUS

STATE STATUS

USFS
STATUS

BLM SPECIAL STATUS
LIST

NYCTAGINACEAE

ABRONIA BIGELOVII

SAND VERBENA, GALISTEO

VERIFIED





PERIPHERAL







G3

S3

NONE

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

ACAROSPORACEAE

ACAROSPORA CLAUZADEANA

LICHEN, ACAROSPORA
CLAUZADEANA











VERIFIED



G1G2



PETITIONED / NEGATIVE 90 DAY FINDING



BLM SENSITIVE

POLEMONIACEAE

ALICIELLA FORMOSA

G1 LI A, AZTEC





VERIFIED









G2

S2

PETITIONED / NEGATIVE 90 DAY FINDIIS

ENDANGERED

NONE

BLM SENSITIVE

APOCYNACEAE

AMSONIA FUGATEI

AMSONIA, FUGATE'S



VERIFIED











G2

S2

SPECIES OF CONCERN

SPECIES OF CONCERN

NONE

BLM SENSITIVE

APOCYNACEAE

AMSONIA THARPII

BLUESTAR, THARP'S













VERIFIED

G1

SI

SPECIES OF CONCERN + PETITIONED -
POSITIVE 90 DAY FINDING

ENDANGERED

NONE

BLM SENSITIVE

NYCTAGINACEAE

ANULOCAUUS LEIOSOLENUS VAR. HOWARDII

RINGSTEM, HOWARD'S GYP









VERIFIED





G2T2

SNR

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

RANUNCULACEAE

AOUILEGIA CHRYSANTHA VAR. CHAPLINEI

COLUMBINE, CHAPLINE'S









VERIFIED



VERIFIED

G4T2

S2

NONE

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

ASCLEPIADACEAE

ASCLEPIAS SANJUANENSIS

MILKWEED, SAN JUAN





VERIFIED









GUQ

S3

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

FABACEAE

ASTRAGALUS COBRENSIS VAR. MAGUIREI

MILKVETCH, COPPERMINE









VERIFIED





G4T2

S2,S1?

SPECIES OF CONCERN

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

FABACEAE

ASTRAGALUS GYPSODES

MILKVETCH, GYPSUM













VERIFIED

G3

S3

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

FABACEAE

ASTRAGALUS KNIGHTII

MILKVETCH, KNIGHT'S

VERIFIED













NONE

NONE

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

FABACEAE

ASTRAGALUS RIPLEYI

MILKVETCH, RIPLEY

HYPOTHETICAL





VERIFIED







G3

S3?

SPECIES OF CONCERN

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

FABACEAE

DERMATOPHYLLUM GUADALUPENSE

MESCALBEAN, GUADALUPE









VERIFIED



VERIFIED

G1



PETITIONED / NEGATIVE 90 FINDING

SPECIES OF CONCERN



BLM SENSITIVE

CACTACEAE

ECHINOCEREUS X ROETTERI VAR. ROETTERI

CACTUS, ROETTER'S
HEDGEHOG









VERIFIED





NONE

NONE

NONE

NONE

NONE

BLM SENSITIVE

ASTERACEAE

ERIGERON ACOMANUS

FLEABANE, ACOMA

VERIFIED



HYPOTHETICAL









GNR

SNR

NONE

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

CACTACEAE

ESCOBARIA DUNCANII

CACTUS, DUNCAN'S
PINCUSHION









VERIFIED





G1G2

SI

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

CACTACEAE

ESCOBARIA VILLARDII

CACTUS, VILLARD'S
PINCUSHION









VERIFIED





G2

S2

SPECIES OF CONCERN

ENDANGERED

SENSITIVE

BLM SENSITIVE

ASTERACEAE

LEPIDOSPARTUM BURGESSII

SCALEBROOM, GYPSUM









VERIFIED





G2

SI

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

LIN ACE AE

LINUM ALLREDII

FLAX, ALLRED'S













VERIFIED

NONE

NONE

NONE

NONE

NONE

BLM SENSITIVE

LOASACEAE

MENTZELIA HUMILUS VAR. GUADALUPENSIS

STICKLEAF, GUADALUPE









VERIFIED





G4T2

SNR

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

CACTACEAE

OPUNTIA ARENARIA

PRICKLYPEAR, SAND









VERIFIED





G2

S2

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

CACTACEAE

OPUNTIA X VIRIDIFLORA

CHOLLA, SANTA FE







VERIFIED







G1G2

SI

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

FABACEAE

PEDIOMELUM PENTAPHYLLUM

SCURFPEA, CHIHUAHUA









VERIFIED





G1

SH,S1

SPECIES OF CONCERN + PETITIONED -
POSITIVE 90 DAY FINDING

ENDANGERED

SENSITIVE

BLM SENSITIVE

CACTACEAE

PENIOCEREUS GREGGII VAR GREGGII

CEREUS, NIGHT-BLOOMING









VERIFIED





G3G4T2

SI

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

SCROPHULARIACEAE

PENSTEMON ALAMOSENSIS

BEARDTONGUE, ALAMO









VERIFIED





G3

S3

SPECIES OF CONCERN

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

SCROPHULARIACEAE

PENSTEMON CARDINALIS SSP. REGALIS

PENSTEMON, GUADALUPE













VERIFIED

G3T2

S2

NONE

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

ASTERACEAE

PERITYLE CERNUA

CLIFF DAISY, NODDING









VERIFIED





G2

S2

SPECIES OF CONCERN

SPECIES OF CONCERN

NONE

BLM SENSITIVE

CHENOPODIACEAE

PROA TRIPLEX PLEIANTHA

SALTBUSH, MANCOS





VERIFIED









G3

S3?

SPECIES OF CONCERN

SPECIES OF CONCERN

NONE

BLM SENSITIVE

































POACEAE

PUCCINELLIA PARISHII

ALKALIGRASS, PARISH'S

VERIFIED

HYPOTHETICAL

HYPOTHETICAL



VERIFIED





G2

S2,S1

SPECIES OF CONCERN

ENDANGERED

SENSITIVE

BLM SENSITIVE

CACTACEAE

SCLEROCACTUS CLOVERAESSP. BRACKII

CACTUS, BRACK'S HARDWALL





VERIFIED









G3T1

SI

SPECIES OF CONCERN

ENDANGERED

NONE

BLM SENSITIVE

































CACTACEAE

SCLEROCACTUS PAPYRACANTHUS

CACTUS, GRAMA GRASS

VERIFIED

HYPOTHETICAL

HYPOTHETICAL

VERIFIED

VERIFIED

HYPOTHETICAL



G4

S2S3,S4

SPECIES OF CONCERN

NONE

NONE

BLM SENSITIVE

SCROPHULARIACEAE

SCROPHULARIA MACRANTHA

FIGWORT, MIMBRES









VERIFIED





G2

S2

SPECIES OF CONCERN

SPECIES OF CONCERN

SENSITIVE

BLM SENSITIVE

BRASSICACEAE

SIBARA GRISEA

THELYPODY, TEXAS; SIBARA,
GRAY









VERIFIED





G3

S3?

NONE

SPECIES OF CONCERN

NONE

BLM SENSITIVE

BRASSICACEAE

STREPTANTHUS PLATYCARPUS

JEWELFLOWER, BROADPOD













VERIFIED

G1?Q

SI?

PETITIONED / NEGATIVE 90 DAY FINDIIS

SPECIES OF CONCERN

NONE

BLM SENSITIVE

ASTERACEAE

TOWNSENDIA GYPSOPHILA

TOWNSEND DAISY, GYPSUM

VERIFIED













G2

S2

SPECIES OF CONCERN

SPECIES OF CONCERN

NONE

BLM SENSITIVE


-------
New Mexico BLM Sensitive Animal Species List (Final) - August 2011









































SPECIES

COMMON NAME

FARMINGTON -
LLNMF01000

TAOS - LLNMF02000

RIO PUERCO -
LLNMA01000

SOCORRO -
LLNMA02000

LAS CRUCES -
LLNML00000

ROSWELL -
LLNMP01000

CARLSBAD -
LLNMP02000







AMPHIBIANS (3)























Anaxyrus (Bufo) microscaphus

Southwestern Toad

NONE

NONE

PERIPHERAL

VERIFIED

VERIFIED

NONE

NONE







Lithobates (Rana) yavapaiensis

Lowland Leopard Frog

NONE

NONE

NONE

HYPOTHETICAL

VERIFIED

NONE

NONE







Lithobates (Rana) pipiens

Northern Leopard Frog



VERIFIED

VERIFIED

PERIPHERAL

NONE

NONE

NONE



















ARTHROPODS (2)























Lytta mirifica

Anthony Blister Beetle

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Ochlodes yuma anasazi

Yuma Skipper

NONE

VERIFIED

NONE

NONE

NONE

NONE

NONE







BIRDS (12)























Haliaeetus leucocephalus

Bald Eagle



VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED











Tympanuchus pallidicinctus

Lesser Prairie-chicken

NONE

PERIPHERAL

NONE

NONE

NONE

VERIFIED

VERIFIED







Coccyzus americanus occidentalis

Western Yellow-billed Cuckoo



VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED



















Athene cunicularia hypugaea

Western Burrowing Owl



VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED



















Gymnorhinus cyanocephalus

Pinon Jay



VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

PERIPHERAL



















Toxostoma bendirei

Bendire's Thrasher



PERIPHERAL

VERIFIED

VERIFIED

VERIFIED

PERIPHERAL

NONE



















Vireo bellii arizonae

Bell's Vireo

NONE

NONE

NONE

NONE

VERIFIED

PERIPHERAL

VERIFIED







Anthus spragueii

Sprague's Pipit

NONE

NONE

NONE

PERIPHERAL

VERIFIED

VERIFIED

VERIFIED







Ammodramus savannarum ammolegus

Arizona Grasshopper Sparrow

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Ammodramus bairdii

Baird's Sparrow

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Passerina ciris

Painted Bunting

NONE

NONE

NONE

NONE

VERIFIED

PERIPHERAL

VERIFIED







Calcarius ornatus

Chestnut-collared Longspur

PERIPHERAL

VERIFIED

NONE

VERIFIED

VERIFIED

VERIFIED

VERIFIED







CRUSTACEANS (5)























Streptocephalus thomasbowmani

Thomas Bowman's Fairy

NONE

NONE

NONE

NONE

NONE

NONE

NONE



Streptocephalus moorei

Moore's Fairy Shrimp

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Phallocryptus (Branchinella) sublettei

Sublette's Fairy Shrimp

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Eulimnadia follisimilis

Clam Shrimp

NONE

NONE

NONE

VERIFIED

NONE

VERIFIED

NONE







Lepidurus lemmoni

Lynch's Tadpole Shrimp

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







FISH (17)























Oncorhynchus clarki virginalis

Rio Grande Cutthroat Trout

NONE

PERIPHERAL

PERIPHERAL

PERIPHERAL

PERIPHERAL

PERIPHERAL

NONE







Agosia chrysogaster

Longfin Dace

NONE

NONE

NONE

PERIPHERAL

VERIFIED

NONE

NONE








-------
Astyanax mexicanus

Mexican Tetra

NONE

NONE

NONE

EXTIRPATED

EXTIRPATED

VERIFIED

VERIFIED







Catostomus discobolus discobolus

Bluehead Sucker

VERIFIED

HYPOTH ETHICAL

PERIPHERAL

PERIPHERAL

NONE

NONE

NONE







Catostomus latipinnis

Flannelmouth Sucker

VERIFIED

HYPOTH ETHICAL

NONE

NONE

HYPOTH ETHICAL

NONE

NONE







Catostomus plebeius

Rio Grande Sucker

NONE

VERIFIED

PERIPHERAL

PERIPHERAL

VERIFIED

PERIPHERAL

PERIPHERAL







Gila pandora

Rio Grande Chub

NONE

VERIFIED

PERIPHERAL

PERIPHERAL

PERIPHERAL

VERIFIED

VERIFIED







Ictiobus bubalus

Smallmouth Buffalo

NONE

HYPOTH ETHICAL

HISTORICAL

HISTORICAL

VERIFIED

HISTORICAL

VERIFIED







Macrhybopsis aestivalis aestivalis

Speckled Chub

NONE

PERIPHERAL

EXTIRPATED

EXTIRPATED

EXTIRPATED

VERIFIED

VERIFIED







Percina macrolepida

Bigscale Logperch

NONE

INTRODUCED

NONE

NONE

NONE

VERIFIED

VERIFIED







Phenacobius mirabilis

Suckermouth Minnow

NONE

VERIFIED

NONE

NONE

NONE

VERIFIED

NONE







Catostomus clarki

Desert Sucker

NONE

NONE

NONE

PERIPHERAL

NONE

NONE

NONE







Catostomus insignis

Sonora Sucker

NONE

NONE

NONE

PERIPHERAL

VERIFIED

NONE

NONE







Cycleptus elongatus

Blue Sucker

NONE

EXTIRPATED

EXTIRPATED

EXTIRPATED

EXTIRPATED

PERIPHERAL

VERIFIED







Cyprinodon pecosensis

Pecos Pupfish

NONE

NONE

NONE

NONE

NONE

VERIFIED

VERIFIED







Etheostoma lepidum

Greenthroat Darter

NONE

NONE

NONE

NONE

NONE

VERIFIED

VERIFIED







Gila robusta

Roundtail Chub

HYPOTH ETHICAL

HYPOTH ETHICAL

PERIPHERAL

PERIPHERAL

VERIFIED

NONE

NONE







Ictalurus lupus

Headwater Catfish

NONE

NONE

NONE

NONE

NONE

VERIFIED

VERIFIED







Macrhybopsis tetranema

Peppered Chub

NONE

PERIPHERAL

NONE

NONE

NONE

NONE

NONE







Moxostoma congestum

Gray Redhorse

NONE

HISTORICAL

HISTORICAL

HISTORICAL

PERIPHERAL

HISTORICAL

VERIFIED







Notropis jemezanus

Rio Grande Shiner

NONE

EXTIRPATED

PERIPHERAL

EXTIRPATED

EXTIRPATED

VERIFIED

VERIFIED







MAMMALS (12)























Choeronycteris mexicana

Mexican Long-tongued Bat

NONE

NONE

NONE

NONE

VERIFIED

NONE

PERIPHERAL







Lasiurus xanthinus

Western Yellow Bat

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Lasiurus blossevillii

Western Red Bat

NONE

NONE

NONE

VERIFIED

VERIFIED

PERIPHERAL

NONE







Euderma maculatum

Spotted Bat

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

PERIPHERAL







Idionycteris phyllotis

Allen's Lappet-browed Bat

NONE

NONE

PERIPHERAL

VERIFIED

VERIFIED

NONE

NONE







Corynorhinus townsendii

Townsend's Big-eared Bat

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED

VERIFIED







Lepus callotis

White-sided Jack Rabbit

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Cynomys ludovicianus

Black-tailed Prairie Dog

NONE

VERIFIED

PERIPHERAL

PERIPHERAL

VERIFIED

VERIFIED

VERIFIED







Cynomys gunnisoni

Gunnison's Prairie Dog

VERIFIED

VERIFIED

VERIFIED

VERIFIED

NONE

NONE

NONE







Thomomys bottae (umbrinus) paguatae

Cebolleta Pocket Gopher

PERIPHERAL

NONE

VERIFIED

PERIPHERAL

NONE

NONE

NONE







Zapus hudsonius luteus

Meadow (New Mexico)

PERIPHERAL

HYPOTH ETHICAL

HYPOTH ETHICAL

HYPOTH ETHICAL

HYPOTH ETHICAL

NONE

NONE







Nasua narica

White-nosed Coati

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







MOLLUSCS (1)
























-------
Popenaias popeii

Texas Hornshell

NONE

NONE

NONE

NONE

NONE

NONE

VERIFIED







REPTILES (7)























Heloderma suspectum suspectum

Reticulate Gila Monster

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Sceloporus arenicolus

Sand Dune Lizard

NONE

NONE

NONE

NONE

NONE

VERIFIED

VERIFIED







Aspidoscelis dixoni

Gray-checkered Whiptail

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Thamnophis eques megalops

Mexican Garter Snake

NONE

NONE

NONE

NONE

VERIFIED

NONE

NONE







Thamnophis rufipunctatus

Narrow-headed Garter Snake

NONE

NONE

NONE

PERIPHERAL

VERIFIED

NONE

NONE







Trachemys gaigeae gaigeae

Big Bend Slider

NONE

NONE

NONE

VERIFIED

VERIFIED

NONE

NONE







Pseudemys gorzugi

Western River Cooter

NONE

NONE

NONE

NONE

NONE

VERIFIED

VERIFIED




















































































































































































































































































































































































































































































































































-------
New Mexico Department of Agriculture

Office of the Director/Secretary
MSC 3189

New Mexico State University
P.O. Box 30005
Las Cruces, NM 88003-8005
575-646-3007

October 19, 2016

MEMORANDUM

TO:	General Public

FROM: Director/Secretary Jeff Witte

SUBJECT: New Mexico Noxious Weed List Update

The Director of the New Mexico Department of Agriculture has selected the following plant
species (see attached New Mexico Noxious Weed List) to be targeted as noxious weeds for
control or eradication pursuant to the Noxious Weed Management Act of 1998.

Petitions to add new plant species to the state noxious weed list were solicited and received by
the New Mexico Department of Agriculture (NMDA) from Cooperative Weed Management
Areas, individuals, agencies, and organizations. The petitions were reviewed by the New Mexico
Weed List Advisory Committee using ecological, distribution, impact, and legal status criteria
within the State of New Mexico and adjoining states and countries. Based on their extensive
knowledge and experience, experts from the New Mexico State University Plant Sciences
Department added several species as well.

This list does not include every plant species with the potential to negatively impact the state's
environment or economy. Landowners and land managers are encouraged to recognize plant
species listed on the federal noxious weed list and other western states' noxious weed lists as
potentially having negative impacts and to manage them accordingly.

NM

STATE

UNIVERSITY


-------
New Mexico Noxious Weed List

Updated September 2016

Class A Species

Class A species are currently not present in New Mexico, or have limited distribution. Preventing new
infestations of these species and eradicating existing infestations is the highest priority.

Common Name

Scientific Name

Alfombrilla
Black henbane
Brazillian egeria
Camelthorn
Canada thistle
Dalmation toadflax
Diffuse knapweed
Dyer's woad
Giant salvinia
Hoary cress
Leafy spurge
Oxeye daisy
Purple loosestrife
Purple starthistle
Ravenna grass
Scentless chamomile
Scotch thistle
Spotted knapweed
Yellow starthistle
Yellow toadflax

Drymaria arenariodes
Hyoscyamus niger
Egeria densa
Alhagi psuedalhagi
Cirsium arvense
Linaria dalmatica
Centaurea diffusa
Isatis tinctoria
Salvinia molesta
Cardaria spp.

Euphorbia esula
Leucanthemum vulgare
Lythrum salicaria
Centaurea calcitrapa
Saccharum ravennae
Matricaria perforata
Onopordum acanthium
Centaurea biebersteinii
Centaurea solstitialis
Linaria vulgaris

Class B Species

Class B Species are limited to portions of the state. In areas with severe infestations, management
should be designed to contain the infestation and stop any further spread.

Common Name

Scientific Name

African rue

Bull thistle

Chicory

Halogeton

Malta starthistle

Perennial pepperweed

Poison hemlock

Peganum harmala
Cirsium vulgare
Cichorium intybus
Halogeton glomeratus
Centaurea melitensis
Lepidium latifolium
Conium maculatum


-------
Quackgrass
Russian knapweed
Spiny cocklebur
Teasel

Elytrigia repens
Acroptilon repens
Xanthium spinosum
Dipsacus full on um

Class C Species

Class C species are wide-spread in the state. Management decisions for these species should be
determined at the local level, based on feasibility of control and level of infestation.

Common Name	Scientific Name

Cheatgrass
Curlyleaf pondweed
Eurasian watermilfoil
Giant cane
Hyd ri lla

Jointed goatgrass
Musk thistle
Parrotfeather
Russian olive
Salt cedar
Siberian elm
Tree of heaven

Bromus tectorum
Potamogeton crispus
Myriophyllum spicatum
Arundo donax
Hydrilla verticllata
Aegilops cylindrica
Carduus nutans
Myriophyllum aquaticum
Elaeagnus angustifolia
Tamarix spp.

Ulmus pumila
Ailanthus altissima

Watch List Species

Watch List species are species of concern in the state. These species have the potential to become problematic.
More data is needed to determine if these species should be listed. When these species are encountered
please document their location and contact appropriate authorities.

Common Name

Scientific Name

Crimson fountaingrass
Meadow knapweed
Myrtle spurge
Pampas grass
Sahara mustard
Syrian beancaper
Wall rocket

Pennisetum setaceum
Centaurea pratensis
Euphorbia myrsinites
Cortaderia sellonana
Brassica tournefortii
Zygophyllum fabago L
Diplotaxis tenuifolia


-------
Locations of Western Burrowing Owl Burrows within the Survey Area

BURROW #

UTM EAST ZONE 13 NAD 83

UTM NORTH ZONE 13 NAD 83

1

241505.7297

3922980.38

2

241472.6848

3923157.886

3

241487.4199

3923139.379

4

241513.5852

3923151.711

5

241623.2205

3923441.085

6

241633.8896

3923442.272

7

241665.5226

3923447.213

8

241692.4228

3923426.135

9

241841.9656

3923108.906

10

241838.1861

3923103.704

11

241826.4991

3923102.94

12

237973.95

3924292.401

13

237974.4592

3924350.441

14

239533.3621

3923386.432

15

239521.6627

3923361.00

16

239515.1164

3923356.98


-------
Animals Observed or Expected to Occur at the Study Area

BIRDS

Family Anatidae: Ducks, Geese, Swans

Gadwall (Anas strepera)

Mallard (Anasplatyrhynchos)

Northern shoveler (Anas clypeata)

Northern pintail (Anas acuta)

Family Odontophoridae: New World Quail

Scaled quail (Callipepla squamata)

Family Columbidae: Pigeons, Doves

Mourning dove (Zenaida macroura)

Family Cuculidae: Cuckoos, Roadrunners, Anis

Greater roadrunner (Geococcyz californianus)

Family Charadriidae: Plovers

Killdeer (Charadrius vociferous)

Family Ardeidae: Bitterns, Herons

Great blue heron (Ardea herodias)

Family Cathartidae: American Vultures

Turkey vulture (Cathartes aura)

Family Accipitridae: Kites, Eagles, Hawks

Golden eagle (Aquila chrysaetos)

Northern harrier (Circus cyaneus)

Family Strigidae: Typical Owls

Burrowing owl (Athene cunicularia)

Family Picidae: Woodpeckers

Northern flicker (Colaptes auratus)

Family Falconidae: Caracaras, Falcons

American kestrel (Falco sparverius)

Prairie falcon (Falco mexicanus)

Family Tyrannidae: Tyrant Flycatchers

Say's phoebe (Sayornis saya)

Ash-throated flycatcher (Myiarchus cinerascens)
Western kingbird (Tyrannus verticalis)

Cassin's kingbird (Tyrannus vociferans)


-------
Family Laniidae: Shrikes

Loggerhead shrike (Lanius ludovicianus)

Family Corvidae: Jays, Magpies, Crows

Common raven (Corvus corax)

American crow (Corvus brachyrhynchos)

Family Alaudidae: Larks

Horned Lark (Eremophila alpestris)

Family Hirundinidae: Swallows

Cliff swallow (Petrochelidon pyrrhonota)

Family Mimidae: Mockingbirds, Thrashers

Northern mockingbird (Mimus polyglottos)

Family Fringillidae: Finches

House finch (Haemorhous mexicanus)

Family Emberizidae: Sparrows

Abert's towhee (Melozone aberti)

Chipping sparrow (Spizella passerine)

Lark sparrow (Chondestes grammacus)

Vesper sparrow (Pooecetes gramineus)

Brewer's sparrow (Spizella breweri)

Sage sparrow (Amphispiza belli)

White-crowned sparrow (Zonotrichia leucophrys)
Dark-eyed junco (Junco hyemalis)

Family Icteridae: Blackbirds, Orioles

Western Meadowlark (Sturnella neglecta)

REPTILES
Crotaphytidae

Aspidoscelis velox (Plateau striped whiptail)
Phrynosomatidae

Scleoporus cowlesi (Southwestern lizard)

Phrynosoma hernandesi (Greater Short-horned lizard)

Colubridae

Thamnophis elegans vagrans (Wandering Garter Snake)
Pituophis catenifer (Bull snake)

Viperidae

Crotalus viridis (Prairie rattlesnake)


-------
MAMMALS

CAN I DAE

Canis latrans (Coyote) Tracks Scat
FELIDAE

Puma concolor (Mountain lion) (Tracks)

CRICETIDAE

*Neotoma sp. (Woodrat) N. albigula or N. Stephensi
GEOMYIDAE

*Thomomys bottae (Botta's pocket gopher)
HETEROMYIDAE

*Dipodomys ordii (Ord's kangaroo rat)

*Dipodomys spetabilis (Banner-tailed kangaroo rat)

LEPORIDAE

*Sylvilagus auduboni (desert cottontail)

*Lepus californicus (Black-tailed jackrabbit)

SCIURIDAE

*Cynomys gunnisoni (Gunnison's prairie dog)
CERVIDAE

*Cervus elaphus (Elk)

*Odocoileus hemionus (Mule deer)


-------
Animals Observed or Expected to Occur at the Study Area

BIRDS

Family Anatidae: Ducks, Geese, Swans

Gadwall (Anas strepera)

Mallard (Anasplatyrhynchos)

Northern shoveler (Anas clypeata)

Northern pintail (Anas acuta)

Family Odontophoridae: New World Quail

Scaled quail (Callipepla squamata)

Family Columbidae: Pigeons, Doves

Mourning dove (Zenaida macroura)

Family Cuculidae: Cuckoos, Roadrunners, Anis

Greater roadrunner (Geococcyz californianus)

Family Charadriidae: Plovers

Killdeer (Charadrius vociferous)

Family Ardeidae: Bitterns, Herons

Great blue heron (Ardea herodias)

Family Cathartidae: American Vultures

Turkey vulture (Cathartes aura)

Family Accipitridae: Kites, Eagles, Hawks

Golden eagle (Aquila chrysaetos)

Northern harrier (Circus cyaneus)

Family Strigidae: Typical Owls

Burrowing owl (Athene cunicularia)

Family Picidae: Woodpeckers

Northern flicker (Colaptes auratus)

Family Falconidae: Caracaras, Falcons

American kestrel (Falco sparverius)

Prairie falcon (Falco mexicanus)

Family Tyrannidae: Tyrant Flycatchers

Say's phoebe (Sayornis saya)

Ash-throated flycatcher (Myiarchus cinerascens)
Western kingbird (Tyrannus verticalis)

Cassin's kingbird (Tyrannus vociferans)


-------
Family Laniidae: Shrikes

Loggerhead shrike (Lanius ludovicianus)

Family Corvidae: Jays, Magpies, Crows

Common raven (Corvus corax)

American crow (Corvus brachyrhynchos)

Family Alaudidae: Larks

Horned Lark (Eremophila alpestris)

Family Hirundinidae: Swallows

Cliff swallow (Petrochelidon pyrrhonota)

Family Mimidae: Mockingbirds, Thrashers

Northern mockingbird (Mimus polyglottos)

Family Fringillidae: Finches

House finch (Haemorhous mexicanus)

Family Emberizidae: Sparrows

Abert's towhee (Melozone aberti)

Chipping sparrow (Spizella passerine)

Lark sparrow (Chondestes grammacus)

Vesper sparrow (Pooecetes gramineus)

Brewer's sparrow (Spizella breweri)

Sage sparrow (Amphispiza belli)

White-crowned sparrow (Zonotrichia leucophrys)
Dark-eyed junco (Junco hyemalis)

Family Icteridae: Blackbirds, Orioles

Western Meadowlark (Sturnella neglecta)

REPTILES
Crotaphytidae

Aspidoscelis velox (Plateau striped whiptail)
Phrynosomatidae

Scleoporus cowlesi (Southwestern lizard)

Phrynosoma hernandesi (Greater Short-horned lizard)

Colubridae

Thamnophis elegans vagrans (Wandering Garter Snake)
Pituophis catenifer (Bull snake)

Viperidae

Crotalus viridis (Prairie rattlesnake)


-------
MAMMALS

CAN I DAE

Canis latrans (Coyote) Tracks Scat
FELIDAE

Puma concolor (Mountain lion) (Tracks)

CRICETIDAE

*Neotoma sp. (Woodrat) N. albigula or N. Stephensi
GEOMYIDAE

*Thomomys bottae (Botta's pocket gopher)
HETEROMYIDAE

*Dipodomys ordii (Ord's kangaroo rat)

*Dipodomys spetabilis (Banner-tailed kangaroo rat)

LEPORIDAE

*Sylvilagus auduboni (desert cottontail)

*Lepus californicus (Black-tailed jackrabbit)

SCIURIDAE

*Cynomys gunnisoni (Gunnison's prairie dog)
CERVIDAE

*Cervus elaphus (Elk)

*Odocoileus hemionus (Mule deer)


-------
APPENDIX B
CULTURAL RESOURCES SURVEY REPORT


-------
Redacted due to sensitive cultural concerns by the Navajo Nation Tribal
Historical Preservation Officer and the New Mexico State Historical

Preservation Officer.


-------
APPENDIX C

EBERLINE ANALYTICAL SERVICES, INC. ANALYTICAL DATA PACKAGES


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This page intentionally left blank.


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BACKGROUND REFERENCE AREA SOIL SAMPLES


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Eberline Analytical

Final Report of Analysis

Report To:

Work Order Details:

David Bordelon

SDG:

16-08019

Weston Solutions, Inc.

Purchase Order:

0090911

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL

Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt
Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu

csu

MDA

Report
Units

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Actinium-228

LANL ER-130 Modified

1.93E+00

2.69E-01

2.86E-01

4.11 E-01

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Bismuth-214

LANL ER-130 Modified

1.69E+00

1.74E-01

1.95E-01

5.34E-02

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Potassium-40

LANL ER-130 Modified

2.52E+01

2.74E+00

3.03E+00

1.16E+00

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Protactinium-234m

LANL ER-130 Modified

5.87E+00

6.68E+00

6.68E+00

1.11 E+01

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Lead-212

LANL ER-130 Modified

2.32E+00

2.36E-01

2.64E-01

2.73E-01

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Lead-214

LANL ER-130 Modified

1.92E+00

1.74E-01

2.00E-01

2.39E-01

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Radium-226

LANL ER-130 Modified

1.69E+00

1.74E-01

1.95E-01

5.34E-02

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Thorium-234

LANL ER-130 Modified

1.29E+00

1.45E+00

1.45E+00

2.42E+00

pCi/g

16-08019-19

TRG

10-16-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Thallium-208

LANL ER-130 Modified

1.54E+00

2.05E-01

2.19E-01

1.46 E-01

pCi/g





























16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Actinium-228

LANL ER-130 Modified

1.75E+00

2.70E-01

2.84E-01

3.70E-01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Bismuth-214

LANL ER-130 Modified

1.58E+00

2.09E-01

2.25E-01

2.21 E-01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Potassium-40

LANL ER-130 Modified

2.41 E+01

2.79E+00

3.05E+00

1.06E+00

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Protactinium-234m

LANL ER-130 Modified

4.73E+00

6.29E+00

6.30E+00

1.05E+01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Lead-212

LANL ER-130 Modified

2.31 E-01

1.53E-01

1.53E-01

2.34E-01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Lead-214

LANL ER-130 Modified

1.62E+00

2.33E-01

2.48E-01

2.59E-01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Radium-226

LANL ER-130 Modified

1.58E+00

2.09E-01

2.25E-01

2.21 E-01

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Thorium-234

LANL ER-130 Modified

1.53E+00

1.77E+00

1.77E+00

2.96E+00

pCi/g

16-08019-20

TRG

10-17-61-160714

07/14/16 00:00

8/4/2016

8/29/2016

16-08019

Thallium-208

LANL ER-130 Modified

1.46E+00

2.03E-01

2.17E-01

2.05E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA= Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


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Page 1 of 4

Eberline Analytical

Final Report of Analysis

Report To:

Work Order Details:

David Bordelon

SDG:

16-08020

Weston Solutions, Inc.

Purchase Order:

0090911

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL

Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt
Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu

csu

MDA

Report
Units





Gamma Run 1























16-08020-01

LCS

KNOWN

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Cobalt-60

LANL ER-130 Modified

1.37E+02

5.48E+00





pCi/g

16-08020-01

LCS

KNOWN

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Cesium-137

LANL ER-130 Modified

8.69E+01

3.48E+00





pCi/g

16-08020-01

LCS

SPIKE

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Cobalt-60

LANL ER-130 Modified

1.43E+02

8.34E+00

1.11E+01

7.61 E-01

pCi/g

16-08020-01

LCS

SPIKE

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Cesium-137

LANL ER-130 Modified

9.08E+01

8.15E+00

9.39E+00

8.64E-01

pCi/g





























16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Actinium-228

LANL ER-130 Modified

8.83E-02

1.30E-01

1.30E-01

2.67E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Bismuth-214

LANL ER-130 Modified

5.38E-02

7.79E-02

7.80E-02

1.46E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Cesium-137

LANL ER-130 Modified

-2.21 E-02

4.50E-02

4.50E-02

6.90E-02

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Potassium-40

LANL ER-130 Modified

-2.37E-02

4.50E-01

4.50E-01

7.52E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Protactinium-234m

LANL ER-130 Modified

3.28E-01

3.75E+00

3.75E+00

6.93E+00

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Lead-212

LANL ER-130 Modified

5.40E-02

5.64E-02

5.65E-02

9.93E-02

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Lead-214

LANL ER-130 Modified

7.08E-02

8.09E-02

8.10E-02

1.45E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Radium-226

LANL ER-130 Modified

5.38E-02

7.79E-02

7.80E-02

1.46E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Thorium-234

LANL ER-130 Modified

2.69E-01

3.89E-01

3.89E-01

6.43E-01

pCi/g

16-08020-02

MBL

BLANK

08/04/16 00:00

8/4/2016

8/15/2016

16-08020

Thallium-208

LANL ER-130 Modified

-7.46E-03

1.31E-01

1.31E-01

2.14E-01

pCi/g





























16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Actinium-228

LANL ER-130 Modified

2.00E+00

2.99E-01

3.16E-01

5.27E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Bismuth-214

LANL ER-130 Modified

1.68E+00

2.20E-01

2.36E-01

2.89E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Cesium-137

LANL ER-130 Modified

4.45E-01

1.27E-01

1.29E-01

1.76E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Potassium-40

LANL ER-130 Modified

2.32E+01

2.79E+00

3.03E+00

1.28E+00

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Protactinium-234m

LANL ER-130 Modified

1.08E+01

8.88E+00

8.90E+00

1.43E+01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Lead-212

LANL ER-130 Modified

1.91E+00

2.14E-01

2.35E-01

3.24E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Lead-214

LANL ER-130 Modified

1.65E+00

1.95E-01

2.12E-01

3.15E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Radium-226

LANL ER-130 Modified

1.68E+00

2.20E-01

2.36E-01

2.89E-01

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Thorium-234

LANL ER-130 Modified

1.66E+00

1.87E+00

1.87E+00

3.12E+00

pCi/g

16-08020-03

DUP

10-18-61-160714

07/14/16 00:00

8/4/2016

8/15/2016

16-08020

Thallium-208

LANL ER-130 Modified

1.79E+00

2.56E-01

2.72E-01

1.55 E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA= Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
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Page 2 of 4







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Work Order Details:

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1 Analvtical

David Bordelon

SDG:

16-08020

M ^ 1



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Printed: 9/27/2019 9:08 PM

Page 3 of 4







Report To:

Work Order Details:

Ebei

rlinf

1 Analvtical

David Bordelon

SDG:

16-08020

M ^ 1



^ 1 1 W
-------
Printed: 9/27/2019 9:08 PM

Page 4 of 4







Report To:

Work Order Details:

Ebei

rlinf

1 Analvtical

David Bordelon

SDG:

16-08020

M ^ 1



^ 1 1 W
-------
SURFACE SOIL SAMPLES


-------
Printed: 2/7/2020 9:48 AM

Page 1 of 2







Report To:

Work Order Details:

Ebei

line

» Analvtical

David Bordelon

SDG:

16-07036







Weston Solutions

, Inc.





Purchase Order:

0090911

Final Report ot Analysis

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab

Sample

Client

Sample

j Receipt j

Analysis 1

Batch

Analyte

Method

Result

I CO I

csu

MDA |

Report

ID

Type

ID

Date

| Date |

Date |

ID

Units

16-07036-01

LCS

KNOWN

07/12/16 00:00

j 7/12/2016 j

8/3/2016 j

16-07036

Cobalt-60

LANL ER-130 Modified

1.37E+02

j 5.48E+00 j



|

pCi/g

16-07036-01

LCS

KNOWN

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Cesium-137

LANL ER-130 Modified

8 69E+01

3.48E+00 |





pCi/g

16-07036-01

LCS

SPIKE

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Cobalt-60

LANL ER-130 Modified

1 35E+02

7 83E+00

1 05E+01

1 09E+00

pCi/g

16-07036-01

LCS

SPIKE

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Cesium-137

LANL ER-130 Modified

8 93E+01

1 7.91 E+00

914E+00

1.29E+00 !

pCi/g

16-07036-02

MBL

BLANH

07/12/16 00:00

f 7/12/2016 |

s

8/3/2016 I

16-07036

Actinium-228

LANL ER-130 Modified

1.06E-01

f 1.44E-01 T

1.44E-01

2.90E-01 1

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

1 7/12/2016 1

8/3/2016 I

16-07036

Bismuth-214

LANL ER-130 Modified

9.61 E-03

E-02 1

8.99E-02

1.51 E-01 1

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

1 7/12/2016 1

8/3/2016 1

16-07036

Potassium-40

LANL ER-130 Modified

1.56E-01

E-01 !

2.45E-01

6.41 E-01 1

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

1 7/12/2016 1

8/3/2016 1

16-07036

Protactinium-234m

LANL ER-130 Modified

4.58E-01

I 5.87E+00 !

5.87E+00

8.79E+00 1

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Lead-212

LANL ER-130 Modified

2 51E-02

5 81 E-02

5 81 E-02

9 63E-02

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

7/12/2016

8/3/2016 j

16-07036

Lead-214

LANL ER-130 Modified

1.21E-01

1 1.01 E-01 j

1 01 E-01

1 62E-01

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Radium-226

LANL ER-130 Modified

9 61 E-03

8 99E-02

8 99E-02

1 51 E-01

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Thorium-234

LANL ER-130 Modified

3 35E-01

1 3.84E-01 J

3 85E-01

6 41 E-01

pCi/g

16-07036-02

MBL

BLANK

07/12/16 00:00

7/12/2016

8/3/2016

16-07036

Thallium-208

LANL ER-130 Modified

1 84E-01

E-01

1 77E-01

2 32E-01 1

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Actinium-228

LANL ER-130 Modified

1 62E+00

2 50E-01

2 63E-01

4.44E-01 J

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Bismuth-214

LANL ER-130 Modified

1 62E+00

2 03E-01

2 19E-01

2 15E-01

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Potassium-40

LANL ER-130 Modified

2 20E+01

2 51E+00

2 75E+00

9 02E-01

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Protactinium-234m

LANL ER-130 Modified

-2 09E-01

f 5.78E+00 |

5 78E+00

8 85E+00

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-212

LANL ER-130 Modified

2 02E+00

2 93E-01

3 11 E-01

2 18E-01

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-214

LANL ER-130 Modified

1 57E+00

2 21 E-01

2 35E-01

2 01 E-01

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Radium-226

LANL ER-130 Modified

1 62E+00

1 2.03E-01

2 19E-01

2 15E-01

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016 j

16-07036

Thorium-234

LANL ER-130 Modified

2 22E+00

j 1.30E+00 j

1 31E+00

213E+00

pCi/g

16-07036-03

DUP

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thallium-208

LANL ER-130 Modified

1 44E+00

I 2.02E-01 T

2 16E-01

1.41 E-01 I

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

j 7/12/2016 f

8/4/2016

16-07036

Actinium-228

LANL ER-130 Modified

1 84E+00

I Z63E"01 I

2 80E-01

3 27E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Bismuth-214

LANL ER-130 Modified

1 46E+00

E-01 i

2 29E-01

2 36E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Potassium-40

LANL ER-130 Modified

2 28E+01

2 57E+00

2 82E+00

7 21 E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Protactinium-234m

LANL ER-130 Modified

2 74E+00

5 47E+00

5 48E+00

8.99E+00 j

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-212

LANL ER-130 Modified

1 91E+00

2 81 E-01

2 98E-01

2 45E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-214

LANL ER-130 Modified

1 67E+00

2 34E-01

2 49E-01

2 34E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Radium-226

LANL ER-130 Modified

1 46E+00

I 2.17E-01 T

2 29E-01

2 36E-01

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thorium-234

LANL ER-130 Modified

1 26E+00

1 1.47E+00

1 47E+00

2 46E+00

pCi/g

16-07036-04

DO

10-01-31-160628

06/28/16 00:00

| 7/12/2016 |

8/4/2016 |

16-07036

Thallium-208

LANL ER-130 Modified

1.39E+00

| 2.02E-01 |

2.14E-01

8.54E-02 |

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

I 7/12/2016 |

8/4/2016 J

16-07036

Actinium-228

LANL ER-130 Modified

1.04E+00

I 5.10E-01 I

5.13E-01

8.87E-01 J

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 2/7/2020 9:48 AM

Page 2 of 2

Eberline Analytical

Final Report of Analysis

Report To:

Work Order Details:

David Bordelon

SDG:

16-07036

Weston Solutions, Inc.

Purchase Order:

0090911

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL

Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt
Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu

csu

MDA

Report
Units

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Bismuth-214

LANL ER-130 Modified

1.47E+01

1.17E+00

1.39E+00

8.08E-01

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Potassium-40

LANL ER-130 Modified

1.86E+01

3.54E+00

3.67E+00

3.55E+00

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Protactinium-234m

LANL ER-130 Modified

2.69E+01

2.36E+01

2.37E+01

3.90E+01

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-212

LANL ER-130 Modified

2.06E+00

4.06E-01

4.20E-01

5.88E-01

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-214

LANL ER-130 Modified

1.53E+01

1.37E+00

1.58E+00

9.01 E-01

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Radium-226

LANL ER-130 Modified

1.47E+01

1.17E+00

1.39E+00

8.08E-01

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thorium-234

LANL ER-130 Modified

8.24E+00

3.52E+00

3.54E+00

5.75E+00

pCi/g

16-07036-05

TRG

10-02-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thallium-208

LANL ER-130 Modified

4.70E-01

2.24E-01

2.25E-01

2.15E-01

pCi/g





























16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Actinium-228

LANL ER-130 Modified

1.04E+00

2.48E-01

2.54E-01

4.05E-01

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Bismuth-214

LANL ER-130 Modified

9.24E-01

1.64E-01

1.70E-01

2.12E-01

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Potassium-40

LANL ER-130 Modified

1.32E+01

1.84E+00

1.96E+00

1.07E+00

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Protactinium-234m

LANL ER-130 Modified

1.32E+00

5.87E+00

5.87E+00

9.48E+00

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-212

LANL ER-130 Modified

1.22E+00

1.50E-01

1.63E-01

2.55E-01

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-214

LANL ER-130 Modified

1.10E+00

1.75E-01

1.84E-01

2.69E-01

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Radium-226

LANL ER-130 Modified

9.24E-01

1.64E-01

1.70E-01

2.12E-01

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thorium-234

LANL ER-130 Modified

1.47E+00

1.35E+00

1.35E+00

1.83E+00

pCi/g

16-07036-06

TRG

10-03-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thallium-208

LANL ER-130 Modified

8.41 E-01

1.60E-01

1.66E-01

2.34E-01

pCi/g





























16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Actinium-228

LANL ER-130 Modified

1.83E+00

4.33E-01

4.43E-01

7.41 E-01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Bismuth-214

LANL ER-130 Modified

1.37E+00

3.14E-01

3.21 E-01

5.01 E-01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Potassium-40

LANL ER-130 Modified

1.95E+01

3.29E+00

3.44E+00

1.62E+00

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Protactinium-234m

LANL ER-130 Modified

1.65E+01

1.06E+01

1.06E+01

2.10E+01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-212

LANL ER-130 Modified

2.23E+00

4.05E-01

4.21 E-01

4.99E-01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Lead-214

LANL ER-130 Modified

1.57E+00

3.40E-01

3.49E-01

5.52E-01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Radium-226

LANL ER-130 Modified

1.37E+00

3.14E-01

3.21 E-01

5.01 E-01

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thorium-234

LANL ER-130 Modified

2.35E+00

1.43E+00

1.44E+00

2.25E+00

pCi/g

16-07036-07

TRG

10-04-31-160628

06/28/16 00:00

7/12/2016

8/4/2016

16-07036

Thallium-208

LANL ER-130 Modified

1.29E+00

3.74E-01

3.80E-01

6.40E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 2/7/2020 12:57 PM

Page 1 of 3







Report To:

Work Order Details:

Ebei

line

» Analvtical

Jeff Wright

SDG:

17-03072







Weston Solutions, Inc.

Purchase Order:

0090911

Final Report ot Analysis

13702 Coursey Blvd, Bldg 7, Suite A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab

Sample

Client

Sample

j Receipt j

Analysis

Batch

Analyte

Method

Result

I CO I

csu

MDA |

Report

ID

Type

ID

Date

| Date |

Date

ID

Units

17-03072-01

LCS

KNOWN

03/20/17 00:00

j 3/17/2017 j

3/20/2017

17-03072

Co bait-60

LANL ER-130 Modified

6.21 E+01

j 2.48E+00 j



j

pCi/g

17-03072-01

LCS

KNOWN

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

3 94E+01

1 58E+00





pCi/g

17-03072-01

LCS

SPIKE

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Cobalt-60

LANL ER-130 Modified

618E+01

I 3.71 E+00 f

4.88E+00

4 41E-01

pCi/g

17-03072-01

LCS

SPIKE

03/20/17 00:00

3/17/2017

I

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

3 89E+01

| 3.31 E+00 I

3.86E+00

4 87E-01

pCi/g

17-03072-02

MBL

BLANH

03/20/17 00:00

f 3/17/2017 f

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

6.23E-02

1 5.21 E-02 !

5.22E-02

-01 i

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

1 3/17/2017 1

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

2.31 E-02

! 4.71 E-02 1

4.71 E-02

7.93E-02 !

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

j 3/17/2017 I

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

1.67E-02

! 2.13E-02 !

2.13E-02

3 80E-02

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

f 3/17/2017 |

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

2.00E-01

1 2.15E-01 1

2.15E-01

4 98E-01

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

1.14E-01

2 97E+00

2.97E+00

4 57E+00

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

2.19E-02

| 2.34E-02 J

2.34E-02

3 97E-02

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

2 90E-02

I 3.53E-02 J

3.53E-02

1 00E-01

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

2 31 E-02

4 71 E-02

4.71 E-02

7 93E-02

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

j 3/17/2017 I

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

2 03E-01

1 70E-01

1.70E-01

2 82E-01

pCi/g

17-03072-02

MBL

BLANK

03/20/17 00:00

f 3/17/2017 |

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

-2 91 E-02

E-02

6.18E-02

8 26E-02

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

5 16E-01

2 57E-01

2 58E-01

5 82E-01

pCi/g

17-03072-03

DUP

10-05-31-17C

02/02/17 12:30

f 3/17/2017 T

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

2 32E+01

1 33E+00

1.78E+00

3 36E-01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

F 3/17/2017 j

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

-02

3 91 E-02

3.92E-02

1 15E-01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

2 08E+01

| 2.34E+00 I

2.58E+00

2 05E+00

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

4 09E+01

1 22E+01

1.24E+01

1 87E+01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

3 82E-01

1 45E-01

1.46E-01

4 42E-01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

2 36E+01

j 5.91 E+00 J

6.03E+00

4 51E-01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

2 32E+01

! 1.33E+00 !

1.78E+00

3 36E-01

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

417E+01

4 39E+00

4.88E+00

4 93E+00

pCi/g

17-03072-03

DUP

10-05-31-170202

02/02/17 12:30

| 3/17/2017 |

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

8.06E-01

I 6.68E-01 |

6.69E-01

2.23E-01 |

pCi/g

17-03072-04

O
Q

10-05-31-170202

02/02/17 12:30

I 3/17/2017 |

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

6.01E-01

! 3.55E-01 |

3.57E-01

6.64E-01 |

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

2.32E+01

1 35E+00

1.80E+00

4 06E-01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

-3 22E-01

I 9.73E-02 1

9.87E-02

1 15E-01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

1 97E+01

| 2.15E+00 1

2.38E+00

1 69E+00

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

4 81E+01

I 1.16E+01 j

1.18E+01

3 05E+01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

4 84E-01

J 1.72E-01 j

1.74E-01

4 34E-01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

2 41E+01

j 6.04E+00 |

6.17E+00

4 74E-01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

j 3/17/2017 I

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

2 32E+01

1 1.35E+00 [

1.80E+00

4 06E-01

pCi/g

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

f 3/17/2017 |

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

4 25E+01

4 23E+00

4.76E+00

4 39E+00

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 2/7/2020 12:57 PM

Page 2 of 3







Report To:

Work Order Details:

Ebei

rlinc

» Analvtical

Jeff Wright

SDG:

17-03072







Weston Solutions, Inc.

Purchase Order:

0090911

Final Report ot Analysis

13702 Coursey Blvd, Bldg 7, Suite A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab

Sample

Client

Sample

J Receipt

Analysis

Batch

Analyte

Method

Result

CU

CSU

MDA

Report

ID

Type

ID

Date

| Date

Date

ID

Units

17-03072-04

DO

10-05-31-170202

02/02/17 12:30

3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

4 07E-01

9 15E-02

9 38E-02

1.35E-02

pCi/g





























17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

7.26E-01

2.82E-01

2 85E-01

6.59E-01

pCi/g

17-03072-05

TRG

10-06-31-17C

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

5.60E+01

3 48E+00

4 51E+00

3.62E-01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

6 15E-03

3.85E-02

3 85E-02

1.18E-01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

2 00E+01

2 38E+00

2 59E+00

2.13E+00

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

5 96E+01

1.47E+01

1 50E+01

2.07E+01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Lead-210

LANL ER-130 Modified

1 97E+01

2 55E+00

2 55E+00

4.00E+00

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

-1 84E+01

2.32E+00

2 51E+00

2.59E-01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

5 45E+01

6.52E+00

7 09E+00

3.98E-01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

5 60E+01

3 48E+00

4 51E+00

3.62E-01

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

614E+01

5.80E+00

6 60E+00

5.73E+00

pCi/g

17-03072-05

TRG

10-06-31-170202

02/02/17 12:35

3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

6 45E-01

1 48E-01

1 52E-01

8.45E-02

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

2 89E-01

2 03E-01

2 03E-01

3.27E-01

pCi/g

17-03072-06

TRG

10-07-31-17C

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

1 86E+01

1 86E+00

2 09E+00

2.53E-01

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

2 07E-02

2.57E-02

2 57E-02

7.88E-02

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

1 93E+01

2 38E+00

2 58E+00

1.40E+00

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

2 35E+01

1 12E+01

1 13E+01

1.30E+01

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

8 74E-01

3 43E-01

3 46E-01

3.39E-01

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

1 82E+01

5 85E+00

5 92E+00

5.12E-01

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

1 86E+01

1 86E+00

2 09E+00

2.53E-01

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

3/17/2017

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

1 73E+01

2.19E+00

2 37E+00

2.90E+00

pCi/g

17-03072-06

TRG

10-07-31-170202

02/02/17 12:40

] 3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

3.97E-01

1.07E-01

1.09E-01

7.27E-02

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

I 3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

1.96E-01

4.72E-01

4.72E-01

6.46E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

219E+01

1 58E+00

1 94E+00

4.56E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

-1 41E-02

4 70E-02

4 70E-02

1.67E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

215E+01

312E+00

3 31E+00

2.66E+00

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

2 08E+01

1.38E+01

1 38E+01

2.25E+01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

9 57E-01

2.60E-01

2 64E-01

4.42E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

1 3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

2.15E+01

1.34E+00

1.73E+00

4.11E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

1 3/17/2017

3/20/2017 1

17-03072

Radium-226

LANL ER-130 Modified

2.19E+01

1.58E+00

1.94E+00

4.56E-01

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

1 3/17/2017

3/20/2017 1

17-03072

Thorium-234

LANL ER-130 Modified

1.12E+01

1.74E+00

1.83E+00

2.47E+00

pCi/g

17-03072-07

TRG

10-08-31-170202

02/02/17 12:45

1 3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

5.65E-01

3.49E-01

3.50E-01

3.37E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 2/7/2020 12:57 PM

Page 3 of 3







Report To:

Work Order Details:

Ebei

rlinc

» Analvtical

Jeff Wright

SDG:

17-03072







Weston Solutions, Inc.

Purchase Order:

0090911

Final Keport ot Analysis

13702 Coursey Blvd, Bldg 7, Suite A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab

Sample

Client

Sample

Receipt

Analysis

Batch

Analyte

Method

Result

CU

csu

MDA

Report

ID

Type

ID

Date

Date

Date

ID

Units

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

6.75E-01

4.85E-01

4.86E-01

9.16E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

1.40E+02

8.54E+00

1.12E+01

5.59E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

6.53E-02

5.97E-02

5.98E-02

1.80E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

2.31E+01

2.95E+00

3.18E+00

3.11 E+00

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

1.27E+02

2.61 E+01

2.69E+01

3.50E+01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

-4.40E+01

5.46E+00

5.91 E+00

4.06E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

1.35E+02

1.61 E+01

1.76E+01

6.34E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

1.40E+02

8.54E+00

1.12E+01

5.59E-01

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

1.24E+02

1.02E+01

1.20E+01

6.70E+00

pCi/g

17-03072-08

TRG

10-09-31-170202

02/02/17 12:50

3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

7.47E-01

1.82E-01

1.86E-01

1.72E-01

pCi/g





























17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Actinium-228

LANL ER-130 Modified

6.42E-01

3.86E-01

3.88E-01

6.17E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Bismuth-214

LANL ER-130 Modified

7.90E+01

7.81 E+00

8.80E+00

6.70E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Cesium-137

LANL ER-130 Modified

5.18E-03

5.05E-02

5.05E-02

1.56E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Potassium-40

LANL ER-130 Modified

2.19E+01

2.84E+00

3.06E+00

2.24E+00

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Protactinium-234m

LANL ER-130 Modified

5.65E+01

2.33E+01

2.35E+01

2.23E+01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Lead-210

LANL ER-130 Modified

5.79E+01

5.90E+00

5.90E+00

4.37E+00

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Lead-212

LANL ER-130 Modified

-1.54E+01

5.15E+00

5.21 E+00

3.04E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Lead-214

LANL ER-130 Modified

7.88E+01

2.52E+01

2.56E+01

8.06E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Radium-226

LANL ER-130 Modified

7.90E+01

7.81 E+00

8.80E+00

6.70E-01

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Thorium-234

LANL ER-130 Modified

5.99E+01

5.35E+00

6.17E+00

5.06E+00

pCi/g

17-03072-09

TRG

10-10-31-170202

02/02/17 12:55

3/17/2017

3/20/2017

17-03072

Thallium-208

LANL ER-130 Modified

4.51 E-01

1.29E-01

1.31 E-01

7.31 E-02

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


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SUBSURFACE SOIL SAMPLES


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Printed: 7/12/2019 11:10 AM

Page 1 of 4

Eberline Analytical

Final Report of Analysis

Report To:

Work Order Details:

David Bordelon

SDG:

17-01139

Weston Solutions, Inc.

Purchase Order:

0090911

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL

Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt
Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu

csu

MDA

Report
Units

17-01139-01

LCS

KNOWN

01/27/17 00:00

1/27/2017

1/31/2017

17-01139

Cobalt-60

LANL ER-130 Modified

6.21 E+01

2.48E+00





pCi/g

17-01139-01

LCS

KNOWN

01/27/17 00:00

1/27/2017

1/31/2017

17-01139

Cesium-137

LANL ER-130 Modified

3.94E+01

1.58E+00





pCi/g

17-01139-01

LCS

SPIKE

01/27/17 00:00

1/27/2017

1/31/2017

17-01139

Cobalt-60

LANL ER-130 Modified

6.14E+01

3.48E+00

4.69E+00

3.82E-01

pCi/g

17-01139-01

LCS

SPIKE

01/27/17 00:00

1/27/2017

1/31/2017

17-01139

Cesium-137

LANL ER-130 Modified

3.80E+01

3.31 E+00

3.84E+00

4.18E-01

pCi/g





























17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

8.14E-02

6.81 E-02

6.82E-02

1.45E-01

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

-1.81E-02

3.89E-02

3.89E-02

5.52E-02

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

0.00E+00

1.55E-01

1.55E-01

3.08E-01

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

1.17E+00

2.36E+00

2.36E+00

4.28E+00

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

-6.39E-03

2.53E-02

2.53E-02

3.67E-02

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1.83E-02

2.80E-02

2.80E-02

4.94E-02

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

-1.81E-02

3.89E-02

3.89E-02

5.52E-02

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1.61E-01

1.72E-01

1.72E-01

2.80E-01

pCi/g

17-01139-02

MBL

BLANK

01/27/17 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

5.28E-02

5.39E-02

5.40E-02

1.03E-01

pCi/g





























17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.49E+00

2.20E-01

2.33E-01

4.39E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1.09E+00

1.49E-01

1.59E-01

1.93E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

1.93E+01

2.52E+00

2.71 E+00

8.06E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

1.12E+00

5.89E+00

5.89E+00

8.43E+00

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1.29E+00

1.42E-01

1.57E-01

1.54E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1.06E+00

1.21E-01

1.32E-01

1.70E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1.09E+00

1.49E-01

1.59E-01

1.93E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

5.74E-01

5.80E-01

5.80E-01

8.50E-01

pCi/g

17-01139-03

DUP

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.30E+00

2.33E-01

2.42E-01

2.71 E-01

pCi/g





























17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.52E+00

1.98E-01

2.13E-01

3.42E-01

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1.10E+00

1.69E-01

1.78E-01

2.02E-01

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

1.81 E+01

2.42E+00

2.59E+00

1.01 E+00

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

7.83E-01

6.58E+00

6.58E+00

9.19E+00

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1.31E+00

1.47E-01

1.62E-01

1.66 E-01

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1.09E+00

1.12E-01

1.25E-01

1.61 E-01

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1.10E+00

1.69E-01

1.78E-01

2.02E-01

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1.83E+00

8.59E-01

8.64E-01

1.41 E+00

pCi/g

17-01139-04

DO

10-01-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.41E+00

2.59E-01

2.69E-01

3.17E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.62E+00

4.15E-01

4.23E-01

2.06E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1.31E+00

1.94E-01

2.05E-01

1.13E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 7/12/2019 11:10 AM

Page 2 of 4







Report To:

Work Order Details:

Ebei

"line

» Analvtical

David Bordelon

SDG:

17-01139













Weston Solutions, Inc.

Purchase Order:

0090911







Final Report of Analysis

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL











Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt

Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu |

CSU

MDA

Report

Units

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2.34E+01

2.74E+00 !

3.00E+00

9.07E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

5.47E+00

4.21 E+00 I

4.22E+00

6.21 E+00

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 91E+00

5 43E-01

5.52E-01

1.72E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 36E+00

4 42E-01

4.47E-01

1 39E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 31E+00

1 94E-01

2.05E-01

1 13E-01

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

5.92E+00

1.37E+00 I

1.40E+00

2.12E+00

pCi/g

17-01139-05

TRG

10-02-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.59E+00

3.23E-01 [

3.33E-01

1.11E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.59E+00

1.86E-01 J

2.03E-01

2.74E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

3 86E+00

3 15E-01 *

3.72E-01

1 66E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

1 99E+01

2 05E+00

2.29E+00

6 46E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

4 28E+00

3.59E+00 I

3.60E+00

5 85E+00

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 44E+00

1.79E-01 [

1.93E-01

1 30E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

3 52E+00

4 36E-01

4.72E-01

1 35E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

3 86E+00

3 15E-01

3.72E-01

1 66E-01

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

5 00E+00

1 08E+00

1.11 E+00

1 63E+00

pCi/g

17-01139-06

TRG

10-03-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1 50E+00

2 30E-01

2.42E-01

5 49E-02

pCi/g





























17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1 42E+00

3.66E-01 [

3.73E-01

3 45E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 32E+00

1 85E-01

1.97E-01

1 50E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

1 68E+01

2 03E+00

2.20E+00

7 34E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

1 35E+01

5 46E+00

5.51 E+00

1 05E+01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 27E+00

3 80E-01

3.86E-01

1 45E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 31E+00

4.28E-01 I

4.33E-01

1 35E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 32E+00

1.85E-01 [

1.97E-01

1 50E-01

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1 33E+01

1 69E+00

1.82E+00

219E+00

pCi/g

17-01139-07

TRG

10-04-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1 20E+00

2 44E-01

2.52E-01

1 02E-01

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1 85E+00

1 93E-01

2.15E-01

1 74E-01

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 31E+00

1 56E-01

1.70E-01

1 45E-01

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2 28E+01

2 33E+00

2.61 E+00

6 45E-01

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

1 69E+01

5 30E+00

5.37E+00

7 39E+00

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 53E+00

1.86E-01 f

2.02E-01

8 00E-02

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 35E+00

1.80E-01 [

1.93E-01

1 20E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 7/12/2019 11:10 AM

Page 3 of 4







Report To:

Work Order Details:

Ebei

"line

* Analvtical

David Bordelon

SDG:

17-01139







Weston Solutions, Inc.

Purchase Order:

0090911

Final Report of Analysis

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample

Type

Client
ID

Sample
Date

Receipt

Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu |

csu

MDA

Report
Units

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1.31E+00

1.56E-01 !

1.70E-01

1.45E-01

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1.08E+01

1.44E+00 I

1.54E+00

2.24E+00

pCi/g

17-01139-08

TRG

10-04-2-32-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.70E+00

2.35E-01 ,

2.50E-01

9.17E-02

pCi/g





























17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.86E+00

4.76E-01 I

4.85E-01

2.35E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 40E+00

1 95E-01

2.08E-01

1 67E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2 23E+01

2 63E+00

2.86E+00

8 85E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

3 05E+00

3 06E+00

3.07E+00

4 79E+00

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 98E+00

5 59E-01

5.68E-01

1 52E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 40E+00

4 57E-01

4.63E-01

1 56E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 40E+00

1 95E-01

2.08E-01

1 67E-01

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

2 60E+00

1.06E+00 I

1.07E+00

1 72E+00

pCi/g

17-01139-09

TRG

10-05-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1 63E+00

3.07E-01 [

3.18E-01

8 09E-02

pCi/g





























17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.47E+00

1.69E-01 J

1.85E-01

2 44E-01

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 10E+00

1 38E-01 *

1.49E-01

1 10E-01

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

1 97E+01

2 02E+00

2.26E+00

5 66E-01

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

2 37E+00

2.16E+00 I

2.16E+00

3 50E+00

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 20E+00

1.52E-01 [

1.64E-01

6 61E-02

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 09E+00

1 46E-01

1.56E-01

8 72E-02

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 10E+00

1 38E-01

1.49E-01

1 10E-01

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1 40E+00

8 05E-01

8.08E-01

1 32E+00

pCi/g

17-01139-10

TRG

10-06-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.33E+00

1.88E-01 I

2.00E-01

9.20E-02

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.53E+00

2.69E-01 I

2.80E-01

3.44E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 45E+00

2 31E-01

2.43E-01

1.72E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2 23E+01

217E+00

2.45E+00

7 71E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactimum-234m

LANL ER-130 Modified

2 28E+00

3 04E+00

3.04E+00

614E+00

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 67E+00

1 54E-01

1.76E-01

1 58E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 20E+00

3.48E-01 [

3.53E-01

1.64E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 45E+00

2 31E-01

2.43E-01

1 72E-01

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

1.68E+00

1.02E+00 !

1.02E+00

1.68E+00

pCi/g

17-01139-11

TRG

10-07-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.70E+00

7.83E-01 I

7.88E-01

2.26E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
Printed: 7/12/2019 11:10 AM

Page 4 of 4







Report To:

Work Order Details:

Ebei

"line

» Analvtical

David Bordelon

SDG:

17-01139







Weston Solutions, Inc.

Purchase Order:

0090911

Final Report of Analysis

13702 Coursey Blvd, #7A

Analysis Category:

ENVIRONMENTAL







Baton Rouge, LA 70817

Sample Matrix:

SO

Lab
ID

Sample
Type

Client
ID

Sample
Date

Receipt

Date

Analysis
Date

Batch
ID

Analyte

Method

Result

cu |

CSU

MDA

Report

Units

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.34E+00

1.95E-01 !

2.07E-01

3.68E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

9.77E-01

1.74E-01 I

1.81E-01

2.28E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2 45E+01

3 06E+00

3.31 E+00

6.84E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

0 00E+00

6 48E+00

6.48E+00

8 99E+00

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 30E+00

1 46E-01

1.60E-01

1 55E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

8.87E-01

1.18E-01 I

1.27E-01

1.94E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

9.77E-01

1.74E-01 !

1.81E-01

2.28E-01

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

2.27E+00

9.76E-01 !

9.83E-01

1.59E+00

pCi/g

17-01139-12

TRG

10-08-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1.14E+00

2.26E-01 !

2.34E-01

2.72E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1.43E+00

3.69E-01 I

3.76E-01

2.67E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1.07E+00

1.93E-01 I

2.00E-01

1.12E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2.19E+01

2.53E+00 !

2.77E+00

7.17E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

6 85E+00

4 24E+00

4.26E+00

571E+00

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 48E+00

4 26E-01

4.33E-01

1.19E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 14E+00

3 73E-01

3.78E-01

1 41E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 07E+00

1 93E-01

2.00E-01

1 12E-01

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

5 84E+00

1 13E+00

1.17E+00

1 68E+00

pCi/g

17-01139-13

TRG

10-09-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1 17E+00

2 35E-01

2.43E-01

1 34E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Actinium-228

LANL ER-130 Modified

1 46E+00

1 68E-01

1.84E-01

2 53E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Bismuth-214

LANL ER-130 Modified

1 69E+00

1 86E-01

2.06E-01

1 16E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Potassium-40

LANL ER-130 Modified

2 22E+01

2 25E+00

2.52E+00

4 95E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Protactinium-234m

LANL ER-130 Modified

216E+01

5 52E+00

5.63E+00

717E+00

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-212

LANL ER-130 Modified

1 36E+00

1 66E-01

1.80E-01

1 23E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Lead-214

LANL ER-130 Modified

1 69E+00

2 17E-01

2.34E-01

1 15E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Radium-226

LANL ER-130 Modified

1 69E+00

1 86E-01

2.06E-01

1 16E-01

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thorium-234

LANL ER-130 Modified

8 70E+00

1 35E+00

1.42E+00

2 23E+00

pCi/g

17-01139-14

TRG

10-10-2-31-161112

11/12/16 00:00

1/27/2017

1/30/2017

17-01139

Thallium-208

LANL ER-130 Modified

1 50E+00

2 10E-01

2.23E-01

1 20E-01

pCi/g

CU=Counting Uncertainty;CSU=Combined Standard Uncertainty (2-sigma);MDA=Minimal Detected Activity;LCS=Laboratory Control Sample; MBL=Blank; DUP=Duplicate; TRG=Normal Sample; DO=Duplicate Original


-------
APPENDIX D
BACKGROUND PROUCL STATISTICAL RESULTS


-------
This page intentionally left blank.


-------
Section 10
Background Ra-226 BTV_UTL95-95

User Selected Options

Date/Time of Computation
From File
Full Precision
Confidence Coefficient
Coverage

New or Future K Observations
Number of Bootstrap Operations

Background Statistics for Uncensored Full Data Sets

ProllCL 5.15/16/2019 8:19:18 AM

WorkSheet.xls

OFF

95%

95%

1

2000

CO

General Statistics

Total Number of Observations

20

Number of Distinct Observations

Minimum

1.22

First Quartile

Second Largest

1.73

Median

Maximum

1.73

Third Quartile

Mean

1.52

SD

Coefficient of Variation

0.0963

Skewness

Mean of logged Data

0.414

SD of logged Data

Critical Values for Background Threshold Values (BTVs)

Tolerance Factor K (For UTL)

2.396

d2max (for USL)



Normal GOF Test



Shapiro Wilk Test Statistic

0.954

Shapiro Wilk GOF Test

5% Shapiro Wilk Critical Value

0.905

Data appear Normal at 5% Significance Level

Lilliefors Test Statistic 0.129
5% Lilliefors Critical Value 0.192

Lilliefors GOF Test

Data appear Normal at 5% Significance Level

16
1.43
1.545
1.595
0.146
-0.32
0.0985

Data appear Normal at 5% Significance Level

Background Statistics Assuming Normal Distribution

95% UTL with 95% Coverage 1.87
95% UPL (t) 1.779
95% USL 1.894

90% Percentile (z)
95% Percentile (z)
99% Percentile (z)

1.707

1.76

1.86

A-D Test Statistic
5% A-D Critical Value
K-S Test Statistic
5% K-S Critical Value

Gamma GOF Test

0.358	Anderson-Darling Gamma GOF Test

0.74	Detected data appear Gamma Distributed at 5% Significance Level

0.141	Kolmogorov-Smimov Gamma GOF Test

0.193 Detected data appear Gamma Distributed at 5% Significance Level

Detected data appear Gamma Distributed at 5% Significance Level

Gamma Statistics

khat(MLE) 110.3
Theta hat (MLE) 0.0138
nuhat(MLE) 4412
MLE Mean (bias corrected) 1.52

k star (bias corrected MLE) 93.8
Theta star (bias corrected MLE) 0.0162

nu star (bias corrected)	3752
MLE Sd (bias corrected) 0.157


-------
Section 10

Background Ra-226 BTV_UTL95-95 (continued)

Background Statistics Assuming Gamma Distribution

95% Wilson Hilferty (WH) Approx. Gamma UPL	1.793

95% Hawkins Wixley (HW) Approx. Gamma UPL	1.795

95% WH Approx. Gamma UTL with 95% Coverage	1.898

95% HW Approx. Gamma UTL with 95% Coverage	1.902

95% WH USL	1.926

90% Percentile
95% Percentile
99% Percentile

1.724
1.786
1.908

95% HW USL 1.931

Shapiro Wilk Test Statistic
5% Shapiro Wilk Critical Value
Lilliefors Test Statistic
5% Lilliefors Critical Value

Lognormal GOF Test

0.946
0.905
0.146
0.192

Shapiro Wilk Lognormal GOF Test

Data appear Lognormal at 5% Significance Level
Lilliefors Lognormal GOF Test

Data appear Lognormal at 5% Significance Level

Data appear Lognormal at 5% Significance Level

Background Statistics assuming Lognormal Distribution

95% UTL with 95% Coverage 1.915
95% UPL (t) 1.801
95% USL 1.946

90% Percentile (z)
95% Percentile (z)
99% Percentile (z)

1.716
1.779
1.902

Nonparametric Distribution Free Background Statistics
Data appear Normal at 5% Significance Level

Nonparametric Upper Limits for Background Threshold Values

Order of Statistic, r	20

Approx, f used to compute achieved CC	1.053

95% Percentile Bootstrap UTL with 95% Coverage	1.73

95% UPL	1.73

90% Chebyshev UPL	1.969

95% Chebyshev UPL	2.173

95% USL	1.73

95% UTL with 95% Coverage	1.73

Approximate Actual Confidence Coefficient achieved by UTL	0.642

Approximate Sample Size needed to achieve specified CC	59

95% BCA Bootstrap UTL with 95% Coverage	1.73

90% Percentile	1.712

95% Percentile	1.73

99% Percentile	1.73

Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.

The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.


-------
Section 10

Background Gamma Count BTV_UTL95-95

User Selected Options

Date/Time of Computation
From File
Full Precision
Confidence Coefficient
Coverage

New or Future K Observations
Number of Bootstrap Operations

Background Statistics for Uncensored Full Data Sets

ProllCL 5.15/16/2019 8:30:02 AM

WorkSheet.xls

OFF

95%

95%

1

2000

CO

General Statistics

Total Number of Observations 20
Minimum 15497
Second Largest 16680
Maximum 16739
Mean 16258
Coefficient of Variation 0.0193
Mean of logged Data 9.696

Number of Distinct Observations 20

First Quartile	16109

Median	16335

Third Quartile	16425

SD	313.4
Skewness -0.794
SD of logged Data 0.0194

Critical Values for Background Threshold Values (BTVs)

Tolerance Factor K (For UTL) 2.396

d2max (for USL) 2.557

Shapiro Wilk Test Statistic
5% Shapiro Wilk Critical Value
Lilliefors Test Statistic
5% Lilliefors Critical Value

Normal GOF Test

0.946
0.905
0.167
0.192

Shapiro Wilk GOF Test

Data appear Normal at 5% Significance Level
Lilliefors GOF Test

Data appear Normal at 5% Significance Level

Data appear Normal at 5% Significance Level

Background Statistics Assuming Normal Distribution

95% UTL with 95% Coverage 17009
95% UPL (t) 16813
95% USL 17059

90% Percentile (z) 16659
95% Percentile (z) 16773
99% Percentile (z) 16987

A-D Test Statistic
5% A-D Critical Value
K-S Test Statistic
5% K-S Critical Value

Gamma GOF Test

0.441	Anderson-Darling Gamma GOF Test

0.74	Detected data appear Gamma Distributed at 5% Significance Level

0.16	Kolmogorov-Smirnov Gamma GOF Test

0.193 Detected data appear Gamma Distributed at 5% Significance Level

Detected data appear Gamma Distributed at 5% Significance Level

Gamma Statistics

khat(MLE) 2806
Theta hat (MLE) 5.795
nu hat (MLE) 112220
MLE Mean (bias corrected) 16258

k star (bias corrected MLE)	2385
Theta star (bias corrected MLE) 6.817

nu star (bias corrected)	95389
MLE Sd (bias corrected) 332.9


-------
Section 10

Background Gamma Count BTV_UTL95-95 (cont'd)

Background Statistics Assuming Gamma Distribution

95% Wilson Hilferty (WH) Approx. Gamma UPL 16820
95% Hawkins Wixley (HW) Approx. Gamma UPL 16821
95% WH Approx. Gamma UTL with 95% Coverage 17022
95% HW Approx. Gamma UTL with 95% Coverage 17024

95% WH USL 17074

90% Percentile	16686

95% Percentile	16809

99% Percentile	17042

95% HW USL	17076

Shapiro Wilk Test Statistic
5% Shapiro Wilk Critical Value
Lilliefors Test Statistic
5% Lilliefors Critical Value

Lognormal GOF Test

0.942
0.905
0.171
0.192

Shapiro Wilk Lognormal GOF Test

Data appear Lognormal at 5% Significance Level
Lilliefors Lognormal GOF Test

Data appear Lognormal at 5% Significance Level

Data appear Lognormal at 5% Significance Level

Background Statistics assuming Lognormal Distribution

95% UTL with 95% Coverage 17029
95% UPL (t) 16824
95% USL 17082

90% Percentile (z) 16664
95% Percentile (z) 16782
99% Percentile (z) 17006

Nonparametric Distribution Free Background Statistics
Data appear Normal at 5% Significance Level

Nonparametric Upper Limits for Background Threshold Values

Order of Statistic, r	20

Approx, f used to compute achieved CC	1.053

95% Percentile Bootstrap UTL with 95% Coverage	16739

95% UPL	16736

90% Chebyshev UPL	17221

95% Chebyshev UPL	17658

95% USL	16739

95% UTL with 95% Coverage 16739
Approximate Actual Confidence Coefficient achieved by UTL 0.642
Approximate Sample Size needed to achieve specified CC 59
95% BCA Bootstrap UTL with 95% Coverage 16739
90% Percentile 16591
95% Percentile 16683
99% Percentile 16728

Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.

The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.


-------
APPENDIX E

HALL ENVIRONMENTAL ANALYSIS LABORATORY
ANALYTICAL RESULTS DATA PACKAGE


-------
This page intentionally left blank.


-------
Analytical Report
Lab Order 1811683

Hall Environmental Analysis Laboratory, Inc.	Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-02-31-181031 -M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-001	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed Batch

EPA METHOD 7471: MERCURY











Analyst: rde

Mercury

ND

0.032

mg/Kg

1

11/27/2018 4:45:44 PM 41736

EPA METHOD 6010B: SOIL METALS











Analyst: ELS

Aluminum

11000

300

mg/Kg

100

11/15/2018 2:20:27 PM 41542

Antimony



4.9

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Arsenic

ND

4.9

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Barium

190

0.20

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Beryllium

0.55

0.30

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Cadmium

ND

0.20

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Calcium

12000

120

mg/Kg

5

11/16/2018 9:28:04 AM 41542

Chromium

5.2

0.59

mg/Kg

2

11/16/2018 11:00:24 AM 41542

Cobalt

3.2

0.59

mg/Kg

2

11/30/2018 3:05:09 PM 41542

Copper

3.0

0.59

mg/Kg

2

11/16/2018 11:00:24 AM 41542

Iron

12000

250

mg/Kg

100

11/15/2018 2:20:27 PM 41542

Lead

5.7

0.49

mg/Kg

2

11/16/2018 11:00:24 AM 41542

Magnesium

3200

120

mg/Kg

5

11/16/2018 9:28:04 AM 41542

Manganese

200

0.20

mg/Kg

2

11/16/2018 11:00:24 AM 41542

Nickel

5.7

0.99

mg/Kg

2

11/30/2018 3:05:09 PM 41542

Potassium

2300

250

mg/Kg

5

11/16/2018 9:28:04 AM 41542

Selenium

ND

4.9

mg/Kg

2

11/16/2018 11:00:24 AM41542

Silver

-wtrvJSL.

0.49

mg/Kg

2

11/16/2018 11:00:24 AM41542

Sodium

150

120

mg/Kg

5

11/16/2018 9:28:04 AM 41542

Thallium

-ND UTL-

4.9

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Uranium

-N6 9.9

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Vanadium

14

4.9

mg/Kg

2

11/16/2018 11

00:24 AM 41542

Zinc

25

4.9

mg/Kg

2

11/30/2018 3:05:09 PM 41542

4^

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg J 0f 14
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report
Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-03-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-002	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result



PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY











Analyst: rde

Mercury

ND



0.032

mg/Kg

1

11/27/2018 4:50:53 PM

41736

EPA METHOD 6010B: SOIL METALS











Analyst:

ELS

Aluminum

12000

U

300

mg/Kg

100

11/15/2018 2:22:24 PM

41542

Antimony

-WD

12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Arsenic

ND



12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Barium

77



0.49

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Beryllium

ND



0.74

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Cadmium

ND



0.49

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Calcium

3300



120

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Chromium

7.0



1.5

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Cobalt

4.7



1.5

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Copper

6.2



1.5

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Iron

13000



250

mg/Kg

100

11/15/2018 2:22:24 PM

41542

Lead

14



1.2

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Magnesium

2900



120

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Manganese

210



0.49

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Nickel

7.1



2.5

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Potassium

3900



250

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Selenium

ND



12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Silver

-NB- U3L

1.2

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Sodium

180



120

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Thallium

-NO UH— 12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Uranium

MB

VXTt—' 25

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Vanadium

38



12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Zinc

38



12

mg/Kg

5

11/16/2018 9:42:04 AM

41542

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg 2 0f 14
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report
Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-04-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-003	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed Batch

EPA METHOD 7471: MERCURY









Analyst: rde

Mercury

ND

0.032

mg/Kg

1

11/27/2018 4:52:36 PM 41736

EPA METHOD 6010B: SOIL METALS









Analyst: ELS

Aluminum

10000

300

mg/Kg

100

11/15/2018 2:24:21 PM 41542

Antimony

-Ntf VJ3L-,

4.9

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Arsenic

ND

4.9

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Barium

73

0.20

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Beryllium

0.61

0.30

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Cadmium

ND

0.20

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Calcium

9500

120

mg/Kg

5

11/16/2018 9:43:54 AM 41542

Chromium

5.3

0.59

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Cobalt

2.7

0.59

mg/Kg

2

11/30/2018 3:11:21 PM 41542

Copper

3.2

0.59

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Iron

10000

250

mg/Kg

100

11/15/2018 2:24:21 PM 41542

Lead

8.2

0.49

mg/Kg

2

11/16/2018 11:09:53 AM41542

Magnesium

4100

120

mg/Kg

5

11/16/2018 9:43:54 AM 41542

Manganese

140

0.20

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Nickel

4.8

0.98

mg/Kg

2

11/30/2018 3:11:21 PM 41542

Potassium

2700

250

mg/Kg

5

11/16/2018 9:43:54 AM 41542

Selenium

15

4.9

mg/Kg

2

11/30/2018 3:11:21 PM 41542

Silver

-NB UtjU

0.49

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Sodium

150

120

mg/Kg

5

11/16/2018 9:43:54 AM 41542

Thallium

-NET OT<~

4.9

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Uranium

we

9.8

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Vanadium

77

4.9

mg/Kg

2

11/16/2018 11:09:53 AM 41542

Zinc

24

4.9

mg/Kg

2

11/30/2018 3:11:21 PM 41542

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg 3 0f 14
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Qualitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report

Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-05-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-004	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY









Analyst:

rde

Mercury

ND

0.033

mg/Kg

1

11/27/2018 4:54:20 PM

41736

EPA METHOD 6010B: SOIL METALS









Analyst:

ELS

Aluminum

14000

290

mg/Kg

100

11/15/2018 2:26:18 PM

41542

Antimony

-N0

12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Arsenic

ND

12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Barium

110

0.49

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Beryllium

0.91

0.73

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Cadmium

ND

0.49

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Calcium

10000

120

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Chromium

2.2

1.5

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Cobalt

3.0

1.5

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Copper

6.3

1.5

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Iron

12000

240

mg/Kg

100

11/15/2018 2:26:18 PM

41542

Lead

6.8

1.2

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Magnesium

3300

120

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Manganese

240

0.49

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Nickel

3.9

2.4

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Potassium

3400

240

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Selenium

87

12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Silver

-NB 03" t-

1.2

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Sodium

490

120

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Thallium



12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Uranium

70 „TL-

24

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Vanadium

110

12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Zinc

26

12

mg/Kg

5

11/16/2018 9:45:45 AM

41542

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers: *

D
H

ND
PQL
S

Value exceeds Maximum Contaminant Level.

Sample Diluted Due to Matrix

Holding times for preparation or analysis exceeded

Not Detected at the Reporting Limit

Practical Quanitative Limit

% Recovery outside of range due to dilution or matrix

B	Analyte detected in the associated Method Blank

E	Value above quantitation range

J	Analyte detected below quantitation limits pag£ 4 0f 14

P	Sample pH Not In Range
RL Reporting Detection Limit

W	Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report
Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-05-32-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-005	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY









Analyst:

rde

Mercury

ND

0.033

mg/Kg

1

11/27/2018 4:56:04 PM

41736

EPA METHOD 601 OB: SOIL METALS









Analyst:

ELS

Aluminum

15000

300

mg/Kg

100

11/15/2018 2:34:53 PM

41542

Antimony

J4B vAL~

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Arsenic

ND

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Barium

100

0.49

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Beryllium

0.97

0.74

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Cadmium

ND

0.49

mg/Kg

5

11/16/2018 9:47.36 AM

41542

Calcium

10000

120

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Chromium

2.5

1.5

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Cobalt

3.1

1.5

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Copper

6.4

1.5

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Iron

12000

250

mg/Kg

100

11/15/2018 2:34:53 PM

41542

Lead

6.5

1.2

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Magnesium

3700

120

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Manganese

260

0.49

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Nickel

4.1

2.5

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Potassium

3700

250

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Selenium

77

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Silver

-N© —•

1.2

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Sodium

560

120

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Thallium

-NB \Jdi_

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Uranium

67 OHL.

25

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Vanadium

120

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Zinc

29

12

mg/Kg

5

11/16/2018 9:47:36 AM

41542

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg 5 0f ]4
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report

Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-06-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-006	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY









Analyst:

rde

Mercury

0.12

0.033

mg/Kg

1

11/27/2018 5:01:23 PM

41736

EPA METHOD 6010B: SOIL METALS









Analyst:

ELS

Aluminum

6000

290

mg/Kg

100

11/15/2018 2:36:52 PM

41542

Antimony

JMS-US*—

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Arsenic

20

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Barium

210

0.48

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Beryllium

ND

0.73

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Cadmium

ND

0.48

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Calcium

4100

120

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Chromium

ND

1.5

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Cobalt

1.8

1.5

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Copper

ND

1.5

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Iron

10000

240

mg/Kg

100

11/15/2018 2:36:52 PM

41542

Lead

8.7

1.2

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Magnesium

1700

120

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Manganese

140

0.48

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Nickel

ND

2.4

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Potassium

880

240

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Selenium

86

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Silver

-NTJ U3—

1.2

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Sodium

150

120

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Thallium

-NB O-T*—

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Uranium

310 3L

24

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Vanadium

250

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

Zinc

17

12

mg/Kg

5

11/16/2018 9:49:28 AM

41542

\°\
^u>V

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.
Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg g 0f 14
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report

Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-07-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-007	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY









Analyst:

rde

Mercury

ND

0.033

mg/Kg

1

11/27/2018 5:03:09 PM

41736

EPA METHOD 6010B: SOIL METALS









Analyst:

ELS

Aluminum

17000

290

mg/Kg

100

11/15/2018 2:38:50 PM

41542

Antimony

ND

12

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Arsenic

juer

SJ5S-* 12

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Barium

75

0.48

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Beryllium

0.80

0.73

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Cadmium

ND

0.48

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Calcium

5300

120

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Chromium

9.7

1.5

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Cobalt

5.3

1.5

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Copper

7.8

1.5

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Iron

16000

240

mg/Kg

100

11/15/2018 2:38:50 PM

41542

Lead

5.4

1.2

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Magnesium

4200

120

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Manganese

190

0.48

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Nickel

9.2

2.4

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Potassium

4700

240

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Selenium

ND

12

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Silver

-N6~

liQi— 1.2

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Sodium

190

120

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Thallium

-Ntr

UTL, 12

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Uranium

WB-

OCT l—¦ 24

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Vanadium

26

12

mg/Kg

5

11/16/2018 9:51:13 AM

41542

Zinc

44

12

mg/Kg

5

11/16/2018 9:51:13 AM

41542



V

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

Qualifiers: *	Value exceeds Maximum Contaminant Level.

D	Sample Diluted Due to Matrix

H	Holding times for preparation or analysis exceeded

ND	Not Detected at the Reporting Limit

PQL	Practical Quanitative Limit

S	% Recovery outside of range due to dilution or matrix

B	Analyte detected in the associated Method Blank

E	Value above quantitation range

J	Analyte detected below quantitation limits,

P	Sample pH Not In Range

RL	Reporting Detection Limit

W	Sample container temperature is out of limit as specified

'Page 7 of 14


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report
Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 10-08-31-181031-M

Project: 1 Weston 04217013 181108 002	Collection Date: 10/31/2018

Lab ID: 1811683-008	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed

Batch

EPA METHOD 7471: MERCURY









Analyst:

rde

Mercury

ND

0.032

mg/Kg

1

11/27/2018 5:04:56 PM

41736

EPA METHOD 6010B: SOIL METALS









Analyst:

ELS

Aluminum

22000

300

mg/Kg

100

11/15/2018 2:40:47 PM

41542

Antimony



12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Arsenic

ND

12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Barium

88

0.49

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Beryllium

1.0

0.74

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Cadmium

ND

0.49

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Calcium

6800

120

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Chromium

13

1.5

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Cobalt

6.1

1.5

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Copper

9.5

1.5

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Iron

19000

250

mg/Kg

100

11/15/2018 2:40:47 PM

41542

Lead

5.5

1.2

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Magnesium

5300

120

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Manganese

240

0.49

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Nickel

11

2.5

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Potassium

5800

250

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Selenium

ND

12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Silver

-NB vJCSl—

1.2

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Sodium

210

120

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Thallium

-ND VHTl—

12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Uranium

•ND \XSi—

—' 25

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Vanadium

34

12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Zinc

53

12

mg/Kg

5

11/16/2018 9:53:04 AM

41542

Refer to the QC Summary report and sample login checklist for flagged QC data and preservation information.

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg 8 0f 14
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
Hall Environmental Analysis Laboratory, Inc.

Analytical Report
Lab Order 1811683
Date Reported: 12/17/2018

CLIENT: Weston Solutions, Inc.	Client Sample ID: 23-02-31-181101-M

Project: 1 Weston 04217013 181108 002	Collection Date: 11/1/2018

Lab ID: 1811683-009	Matrix: SOIL	Received Date: 11/9/2018 8:40:00 AM

Analyses

Result

PQL

Qual Units

DF Date Analyzed Batch

EPA METHOD 7471: MERCURY









Analyst: rde

Mercury

ND

0.032

mg/Kg

1

11/27/2018 5:06:42 PM 41736

EPA METHOD 6010B: SOIL METALS









Analyst: ELS

Aluminum

15000

290

mg/Kg

100

11/15/2018 2:42:44 PM 41542

Antimony

ND -VV

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Arsenic

ND

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Barium

81

0.49

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Beryllium

0.78

0.74

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Cadmium

ND

0.49

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Calcium

12000

120

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Chromium

8.7

1.5

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Cobalt

5.2

1.5

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Copper

6.6

1.5

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Iron

17000

250

mg/Kg

100

11/15/2018 2:42:44 PM 41542

Lead

5.7

1.2

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Magnesium

3500

120

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Manganese

170

0.49

mg/Kg

5

11/16/2018 10:01:22 AM41542

Nickel

9.6

2.5

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Potassium

3500

250

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Selenium

ND

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Silver

-NIT UJ5—

1.2

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Sodium

200

120

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Thallium

DTI—

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Uranium

nb~ ugrc.

25

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Vanadium

42

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

Zinc

41

12

mg/Kg

5

11/16/2018 10:01:22 AM 41542

\&\

Refer to the QC Summaty report and sample login checklist for flagged QC data and preservation information.
Qualifiers:

*

Value exceeds Maximum Contaminant Level.

B

Analyte detected in the associated Method Blank

D

Sample Diluted Due to Matrix

E

Value above quantitation range

H

Holding times for preparation or analysis exceeded

J

Analyte detected below quantitation limits pagg 9 0f ]4
Sample pH Not In Range

ND

Not Detected at the Reporting Limit

P

PQL

Practical Quanitative Limit

RL

Reporting Detection Limit

S

% Recovery outside of range due to dilution or matrix

W

Sample container temperature is out of limit as specified


-------
DATA QUALITY ASSURANCE REVIEW

SITE NAME Tronox Section 10 Mine	

WORK ORDER NUMBER 20600.012.001.1044.06 TDD NUMBER 0001/17-044
PROJECT NUMBER	SDG NUMBER	1811683

Weston Solutions, Inc. (WESTON®) has completed a QA review for Work Order Number
20600.012.001.1044.06, SDG No. 1811683, Tronox Section 10 Mine. Nine samples were analyzed for Target
Analyte List (TAL) metals plus uranium by Hall Environmental Analysis Laboratory, Inc. Sample numbers are
listed below.

SAMPLE NUMBERS

10-02-31-181031-M	10-03-31-181031-M	10-04-31-181031-M

10-05-31-181031-M	10-05-32-181031-M	10-06-31-181031-M

10-07-31-181031-M	10-08-31-181031-M	23-02-31-181101-M

This data package was validated to determine if Quality Control (QC) specifications were achieved, following
USEPA National Functional Guidelines for Organic Superfund Methods Data Review (January, 2017), USEPA
National Functional Guidelines for Inorganic Superfund Data Review (January, 2017), USEPA Contract
Laboratory Program National Functional Guidelines for High Resolution Superfund Methods Data Review
(April, 2016), Quality Assurance/Quality Control Guidance for Removal Activities (September, 2011), and/or
the Regional Protocol for Holding Times, Blanks, and VOA Preservation (April 13, 1989). Specific data
qualifications are listed in the following discussion.

REVIEWER Gloria J. Switalski

DATE June 20, 2019


-------
Data Qualifiers

Data Qualifier Definitions were supplied by the Office of Solid Waste and Emergency Response
(September 1989) and are included in the Functional Guidelines. Data qualifiers may be combined (UJ,
QJ) with the corresponding combination of meanings. Additional qualifiers may be added to provide
additional, more specific information (JL, UB, QJK), modifying the meaning of the primary qualifier.
Additional qualifiers utilized by WESTON are H, L, K, B, and Q.

U - The material was analyzed for, but was not detected. The associated numerical value is the
sample quantitation or detection limit, which has been adjusted for sample weight/sample volume,
extraction volume, percent solids, sample dilution or other analysis specific parameters.

An additional qualifier, "B", may be appended to indicate that while the analyte was detected in the
sample, the presence of the analyte may be attributable to blank contamination and the analyte is
therefore considered undetected with the sample detection or quantitation limit for the analyte being
elevated.

J - The analyte was analyzed for, but the associated numerical value may not be consistent with the
amount actually present in the environmental sample or may not be consistent with the sample
detection or quantitation limit. The value is an estimated quantity. The data should be seriously
considered for decision-making and are usable for many purposes.

An additional qualifier will be appended to the "J" qualifier that indicates the bias in the reported
results:

L Low bias

H High bias

K Unknown bias

Q The reported concentration is less than the sample quantitation limit for the specific analyte
in the sample.

The L and H qualifier will only be employed when a single qualification is required. When more
than one quality control parameter affects the analytical result and a conflict results in assigning a
bias, the result will be flagged JK.

R - Quality Control indicates that data are unusable for all purposes. The analyte was analyzed for,
but the presence or absence of the analyte has not been verified. Resampling and reanalysis are
necessary for verification to confirm or deny the presence of an analyte.

N - The analysis indicates the presence of an analyte for which there is presumptive evidence to
make a "tentative identification."


-------
METALS DATA EVALUATION

1.	Analytical Method:

Samples were prepared and analyzed for metals and mercury using the procedures specified in SW-846
Methods 6010B and 7471.

2.	Holding Times:

All samples met established holding time criteria of 180 days for ICP metals and 28 days for mercury.
No qualifications are placed on the data.

3.	Initial Calibration:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.

4.	Continuing Calibration:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.

5.	CRDL Standard:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.

6.	Blanks:

A.	Laboratory Blanks:

Target analytes were not detected in the method blanks at concentrations that warrant blank action. No
qualifications are placed on the data.

B.	Field Blanks:

No field blank samples were submitted with this analytical package. No qualifications are placed on the
data.

7.	ICP Interference Check:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.


-------
8. Laboratory Control Sample (LCS):

The laboratory analyzed LCS and recoveries for these analyses were within the control limits provided.
No qualifications are placed on the data.

9. Duplicate Sample Analysis:

A. Laboratory Duplicate Analysis:

Sample 10-02-31-181031-M underwent matrix spike/matrix spike duplicate analysis for the soil matrix
for ICP metals and mercury. QC criteria are that the relative percent difference (RPD) values for the
duplicate sample analysis be less than 20% for aqueous samples and less than 35% for soil samples for
concentrations greater than five times the practical quantitation limit (PQL). For sample concentrations
less than five times the PQL, the QC criteria are that the absolute difference between the samples is less
than the PQL for the aqueous matrix or less than two times the PQL for the soil matrix. All QC criteria
were met with the following exception:

SAMPLE ID

ANALYTE

RPD

CONTROL LIMITS

QUALIFIER FLAG

10-02-31-181031-M

Thallium

37.3

35

None, samples ND

B. Field Duplicate Analysis:

The following sample pair was submitted as field duplicates for the soil matrix for ICP metals and
mercury: 10-05-31-181031-M/10-05-32-181031-M. The RPD values for the field duplicate sample
analysis were within the QC criteria of less than 30% for aqueous samples and less than 50% for soil
samples for concentrations greater than five times the PQL. For sample concentrations less than five times
the PQL, the absolute difference between the samples is less than two times the PQL for aqueous samples
or less than 3.5 times the PQL for the soil samples. All QC criteria were met. No qualifications are placed
on the data.

10. Matrix Spikes/Matrix Spike Duplicates (MS/MSD):

Sample 10-02-31-181031-M underwent MS/MSD analysis for the soil matrix for ICP metals and
mercury. Recoveries of the following spiked analytes were outside of the control limits provided:

SAMPLE ID

ANALYTE

%R/%R

CONTROL LIMITS

QUALIFIER FLAG

10-02-31-181031-M

Calcium

-65.6/-8.11

75-125%

None, sample cone >4X



Antimony

14.1/13.2



UJL



Barium

43.4/OK



None, sample cone >4X



Manganese

-76.9/-20.0



None, sample cone >4X



Silver

73.5/OK



UJL



Thallium

29.2/42.6



UJL



Uranium

42.3/38.2



JL/UJL

11. ICP Serial Dilution:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.


-------
12. Sample Quantitation and Reporting Limits:

Level 4 data validation is not being performed on this data set at this time. In the event that level 4
validation is performed, this validation report will be revised to include the level 4 findings. No
qualifications are placed on the data.

All ICP metals analytes in all samples were analyzed at a 2, 5, or 100-fold dilution. PQL for these
analytes in these samples were elevated as a result of the dilutions performed.

13.	Laboratory Contact

No laboratory contact was required.

14.	Overall Assessment:

Antimony, silver, thallium, and uranium results in all soil samples were estimated due to low MS and/or
MSD recoveries.

The analytical data is acceptable for use with the qualifications listed above.


-------
APPENDIX F

ACCUSTAR ANALYTICAL RESULTS DATA PACKAGE


-------
This page intentionally left blank.


-------
AccuStar

Laboraloire Proiospkumol D'analyae du Radon Depum 1BS4

Radon in Air

NELAC NY 11769
NRPP 101193 AL
NRSB ARL0017

Laboratory Report for:

EPA Method #402-R-92-004
Charcoal Canister
NRPP Device Code 2014, 1165
NRSB Device Code 10313, 10335

Property Tested: Project# 1-WESTON-0642-1707

Weston Solutions Inc.-K. Warr
5599 San Felipe Suite 700
Houston TX 77056

Site #T00005100801

Log

Number

Device
Number

Test Exposure Duration:



Area Tested

Result (pCi/L)

2132878

589850

06/29/2017 10:55 am

07/05/2017

1:45 pm

SEC10-C

11.1

2132879

589851

06/29/2017 1

1:00 am

07/05/2017

1:45 pm

SEC10-D

0.7

2132880

589852

06/29/2017 1

1:15 am

07/05/2017

1:45 pm

SEC10-E

0.9

2132881

589853

06/29/2017 1

1:20 am

07/05/2017

1:50 pm

SEC10-F

1247.9

2132882

589854

06/29/2017 1

1:21 am

07/05/2017

1:50 pm

SEC10-G

2.1

Comment: Weston Solutions Inc.-K. Warr was e-mailed a copy of this report.

Distributed by: Weston Solutions Inc.-K. Warr

Date Received: 07/07/2017 Date Logged: 07/07/2017 Date Analyzed: 07/07/2017 Date Reported: 07/07/2017

Report Reviewed By: tY^'ol.O.	Report Approved By:

Disclaimer:	Shawn Price, Director oVTaboraWry Operations, AccuStar Labs

The uncertainty of this radon measurement is -+/-10 %. Factors contributing to uncertainty include statistical variations, daily and seasonal variations in radon
concentrations, sample collection techniques and operation of the dwelling. Interference with test conditions may influence the test results.

This report may only be transferred to a third party in its entirety. Analytical results relate to the samples AS RECEIVED BY THE LABORATORY. Results
shown on this report represent levels of radon gas measured between the dates shown in the room or area of the site identified above as "Property Tested".
Incorrect information will affect results. The results may not be construed as either predictive or supportive of measurements conducted in any area of this
structure at any other time. AccuStar Labs, its employees and agents are not responsible for the consequences of any action taken or not taken based upon the
results reported or any verbal or written interpretation of the results.

Rev 1703

11 Awl Street Medway MA 02053 888-480-8812 FAX 508-533-8831

Page 1 of 1


-------
AccuStar

Profv**>arM ffotiufr Lttcintnry Semeal Sfrx* JP&4

Radon in Air

NELAC NY 11769
NRPP 101193 AL
NRSB ARL0017

Laboratory Report for:

EPA Method #402-R-92-004
Charcoal Canister
NRPP Device Code 2014
NRSB Device Code 10313

Property Tested: Project# 0642-161104-0001

Weston Solutions Inc.-K. Warr
5599 San Felipe Suite 700
Houston TX 77056

Site #T00005100801
Not Indicated 539424 539425

Log	Device	_

Number	Number Test Exposure Duration:	Area Tested	Result (pCi/L)

2007334	539424	10/28/2016 12:15 pm 11/03/2016 12:00 pm	SEC10-A	6304.9

2007335	539441	10/28/2016 12:15 pm 11/03/2016 12:00 pm	SEC10-B	8170.5

2007336	539425	10/28/2016 11:15 am 11/03/2016 11:15am	SEC23-A	44.0

Comment: Weston Solutions Inc.-K. Warr was e-mailed a copy of this report.

Distributed by: Weston Solutions Inc.-K. Warr

Date Received: 11/07/2016 Date Logged: 11/07/2016 Date Analyzed: 11/07/2016 Date Reported: 11/07/2016

Report Reviewed By:	Report Approved By: __

Disclaimer:	Carolyn D. Koke, President, AccuStar Labs

The uncertainty of this radon measurement is -+/-10 %. Factors contributing to uncertainty include statistical variations, daily and seasonal variations in radon
concentrations, sample collection techniques and operation of the dwelling. Interference with test conditions may influence the test results.

This report may only be transferred to a third party in its entirety. Analytical results relate to the samples AS RECEIVED BY THE LABORATORY. Results
shown on this report represent levels of radon gas measured between the dates shown in the room or area of the site identified above as "Property Tested".
Incorrect information will affect results. The results may not be construed as either predictive or supportive of measurements conducted in any area of this
structure at any other time. AccuStar Labs, its employees and agents are not responsible for the consequences of any action taken or not taken based upon the
results reported or any verbal or written interpretation of the results.

Rev 1512

11 Awl Street Medway MA 02053 888-480-8812 FAX 508-533-8831

Page 1 of 1


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APPENDIX G

MINE SHAFT AND VENTILATION HOLE VIDEO
SURVEILLANCE LOGGING DATA


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This page intentionally left blank.


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Southwest Exploration	Southwest Exploration Services, LLC

So ryiCgSj LLC		25811 S.Ariz, Avenue Chandler, AZ. 85248

borehole geophysics & video services	Phone: (480) 926-4558 Fax: (480) 926-4579 Web: www.swexp.com

Client:

Weston Solutons

Address: 13702 Cours©¥ Blvd. Bide? 7	

City:	Baton Rouge		State: LA Zip: 70817

Survey Date July 18, 2017	

Invoice:	3018	Run

Well Name: Section 10 well

Requested By: Weston Solutions
Copy To Weston Solutions	

P.O.:

Well Owner:

Camera: Mine Camera

Reason For Survey: General Inspection	

Location: Ambrosia Lake I Graants New Mexico

Zero Datum: Ground Level

Depth: 600 Ft Vehicle: 7S0

Field: Ambrosia Lake

Csg. I.D.@ Surface 120 In.
Operator: Don Eekman

I.D. Reference: Well Records Casing Buildup: None
Lat.: 	Long.:	Sec:	

Twp:

Rge

Wellbore Snapshots

True Depths:

(SideScan-Feet)

WELLBORE I CASING INFORMATION

12.8 Ft (Ssa Oiher Suits) 0024 8' R (Sea Other Sitto)

Due to a lack of centralization, camera swung side to side all through

I

survey

Metal pipe against corner of shaft, starts at surface. Appears to be attached at surface only.
Surface vault appears to be stable and intact

24.8'

Open hole begins. Several large undercut sections visible.
Stability of formation unknown.

120'

Formation appears to be competent

130.1'

Bottom of metal pipe.

176'

Inspected one of several distinctive foramtion layers. Several low to

291.4'

high angle fractures were observed below 120 ft.

Bottom fill PVC pipe seen in corner of shaft. appx. 1 ft. exposed

Recorded from bottom to surface.

0028.6' Ft (See Olhef Skto) 0084.3' Ft t'Soc- Other Suio)

0124.3' Ft (See Olh-;

0291.2* Ft tSae Oiher Stele]

Notes:

Page Number: 1


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12 WELLBORE SHAPSHOTS

12,8 Ft (Enlargement

0028.6'Ft (Enlargement)

Section 10 well

Page No. 2


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it

Southwest Exploration	Southwest Exploration Services, LLC

-' u'	 - 		25811 S. Arizs. Avenue Chandler, AZ. 85248

borehole geophysics & video sendees	phone; (48()) 926^558 Fax: (480) 92M579 Web: ^.swexpxom

Client:	Weston Solutions	Survey Date: July 18, 2017

Address: 13702 Coursey Blvd, Bldg. 7	Invoice	8019		Run

City:	Banton Rouge	State: LA Zip: 70817	Well Name: Section 10 Survey

Requested By: Weston Solutions	P.O.:	Well Owner:	

Copy To Weston Solutions		Camera: Mine Camera	

Reason For Survey: General Inspection	Zero Datum: Ground Level'	

Location: Ambroisa Lake / Grants New Mexico	Depth: 800 Ft Vehicle: 750

Field: Ambrosia Lake	

Csg. I.D.@ Surface 36 In. I.D. Reference: Well Records Casing Buildup: Light, Increasing W/ Depth	

Operator: Don Eckman	Lai:	Long.	Sec:	Twp:	Rge:	

Wellbore Snapshots

True Depths:
(SideScan-Fest)

WELLBORE / CASING INFORMATION

OOSrBTIiSiBOiiiwSijia)

0080.1* Ft (S&fc OlfT-Bi Sidy)



Zeroed side view at ground level. 4.7 ft. of casing is above



ground level.



Due to casing size could not centralize camera in hole.

21.8'

Casing joint. During survey all seen joints look to be in goog condition.

01192' Ft (Sen Olher Side)







At this point casing seems to reduce to undetermined size.

54'

Start of minor scaling.

61.6'

Well appears to become deviated causing camera to trail down low





side of hole This was an issue in getting camera to rotate

m



approiately

79,4'

Possible hole in casing. Water seems to be seeping from hole.



Scaling increases, and continues to increase with depth.







198'

Casing may be deformed due to side loading

206'

Again casing appears to be deformed.

243'

Issue with camera rotating aginst casing.

351.6'

Bottom fill. Casing seems to continue into fill

020*1 7' Ft Qlhof Stdo)





r





Recored back up to 78.4 ft









mm
§

OW^RtSBj^jho^A)
[t!	_j3

















Notes:

Page Number: 1


-------
0061.6' Ft [Enlargement

0243.5' Ft (Enlargement)

12 WELLBORE SHAPSHOTS

0080.1'Ft (Enlargement

0198.6' Ft (Enlargement

0345.8' Ft (Enlargement

0084.5' Ft (Enlargement)

0204.7' Ft (Enlargement)

Section 10 Survey

Page No. 2


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APPENDIX H
RE VEGETATION PLAN


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This page intentionally left blank.


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Draft Revegetation Plan

Tronox Navajo Area Uranium Mines
Western Geographic Sub Area

McKinley County, New Mexico



r*;	. ^t*V*if t—	»- ./ -

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Prepared for

US Evironmerital Protection Agency Region 6
Weston Solutions

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February 2017


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CONTENTS

1- INTRODUCTION.................................................................................................................................1

Geographical Description of Removal Area	1

Summary of Site Conditions	2

2	- RECLAMATION GOALS /PERFORMANCE	4

Reclamation Units	4

Unit Performance Goals and Standards	4

3	- RECLAMATION/REVESTA.TION WORK PLAN	7

Revegetation Schedule	8

Soil Preparation	9

Seed Mix Specifications	17

4- PERFORMANCE MONITORING........................................................................................................... 21

Monitoring Plan	21

5 - ADAPTIVE MANAGEMENT PLAN.......................................................................................................24

Parties Responsible for Adaptive Management	24

Potential Challenges	24

Procedures for Modifying Performance Standards and Timeframe	27

6- REFERENCES....................................................................................................................................28

APPENDIX A......................................................................................................................................... 31

APPENDIX B .........................................................................................................................................32


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1 - INTRODUCTION

The US Environmental Protection Agency (USEPA) proposes to initiate a mine waste removal on
approximately 1,860 acres consisting of several former uranium mine sites and associated lands to
reestablish pre-mine arid grassland and scrub habitats. The removal areas are located within the Ambrosia
Lake Sub-District (ALSD) area of the Grants Mining District of the Western Geographic Sub Area within
McKinley County, New Mexico (Figure la in Appendix D). The reclamation study area consists of former
underground uranium mines (Kermac #10, #23, Mine #24, Homestake Sapin #25) and associated lands. For
the purposes of this report, the study area totals approximately 2,300 acres and the current removal area
of approximately 1,860 acres occurs within its boundaries. However, the final removal area will be
determined once ongoing analyses are evaluated.

The area is eligible for abatement activities subject to the Tronox Navajo Area Uranium Mine (NAUM)
settlement, and has been identified as the West Geographic Sub Area.

The USEPA proposes to excavate at least 12 inches of top soils throughout the removal area and dispose of
them at a nearby previously disturbed location, then revegetate and re-contour the site to restore, to the
extent feasible, pre-mining conditions.

Reveaetation Objectives

The USEPA identified the following re-vegetation objectives:

•	Restore Grazing/Forage to Pre-mine Condition

•	Restore Suitability for Wildlife Use

•	Sustainability

Reveaetation Standards

This plan has been developed to comply with the following standards:

•	New Mexico Environment Department and New Mexico Energy, Minerals,
and Natural Resources Department Mining and Minerals Division Joint
Guidance for the cleanup and reclamation of existing uranium mines in
New Mexico, March 2016 (Attachments 1 and 2).

•	New Mexico State Land Office Reclamation Plan for State Mineral Lease
Rule 5 Template (7-14-15).

Geographical Description of Removal Area

The removal area is located within the ALSD in McKinley County, New Mexico. The ALSD is located within an
area of uranium mineralization that extends approximately 100 miles long and 25 miles wide encompassing
portions of McKinley, Cibola, Sandoval, and Bernalillo counties of New Mexico. The study area occurs from
approximately 6,920 to 7,200 feet in elevation above mean sea level. It is located east of Little Haystack
Mountain and southwest of San Mateo Mesa (Figure la).

Removal Area Location

The WGSA removal area consists of approximately 1,860-acres of former underground uranium mines and
associated lands selected for remediation within a larger study area of 2,300 acres (Figures la-lc in
Appendix A). The site is located in the ALSD, McKinley County, New Mexico approximately 17 miles
northwest of Grants, New Mexico and 5.0 miles northwest of the intersection of New Mexico State
Highways 509 and 605 (Figure lb).

1


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In relation to regional population centers, the site is located approximately 70 air miles and 100 road miles
west/northwest of Albuquerque, New Mexico; 340 air miles and 540 road miles from Denver Colorado; and
approximately 280 air miles and 360 road miles northeast of Phoenix, Arizona.

The removal are is located in Township 14 North, Range 10 West Sections 10, 11, 15, 22, 23, 24, 25, 26, and
Range 9 West; Section 30. It appears on the Ambrosia Lake and Goat Mountain, New Mexico US Geological
Survey 7.5-minute quadrangle maps (Figure la). The geographic center of the site is located at
approximately Universal Trans Mercator (UTM) Z13S, North American Datum (NAD) 83 240566 3923265
(Latitude 35.419035 degrees north/Longitude 107.85731366044111 degrees west).

Site Access/Constraints

The total distance from Interstate 40 (1-40) to the site is approximately 19 miles. The site is accessed
directly from the New Mexico 509 roadway (NM 509). This is a secondary two-lane (11-foot wide lanes)
with unpaved shoulders and 3-foot wide paved taper. NM 509 is accessed via the New Mexico 605 roadway
(NM 605) approximately 5 miles south of the entrance to the site.

NM 605 has a similar typical section. NM 605 extends approximately 13.5 miles southward to its junction
with historic U.S. 66, in Milan, New Mexico. It is a four-lane divided roadway with a median, 12-foot wide
lanes, and 8-foot wide exterior paved shoulders. It is located 0.2 mile from Interstate 40 (1-40). No
constraining bridges or underpasses occur between 1-40 and the entrance to the site.

Access to the site from the north is available via NM 509 approximately 30 miles to its junction with the
Navajo 9 roadway, another secondary roadway with 11-foot wide lanes, but with 6 foot paved shoulders.
The Navajo 9 junction with NM 371 (also a 2 lane roadway with 6-shoulder facility) occurs approximately 20
Miles to the west. NM 371 meets 1-40 approximately 28.5 miles south. There are no constraining bridges or
underpasses. The total distance from the site access road to 1-25 via the north route is approximately 83
miles.

East of the junction with NM 509, Navajo 9 becomes NM 197. It terminates at US Highway 550 near Cuba,
New Mexico, approximately 64.5 miles from the junction of NM 509. The total distance from the turnoff to
the site to Cuba, New Mexico is approximately 95 miles. No low bridges or underpasses appear to be
present.

Land Ownership

Land ownership is private and Bureau of Land Management (BLM). Land ownership is depicted on figure 1
(Appendix A).

Summary of Site Conditions

The removal area occurs within theSemiarid Tablelands ecoregion (Griffith et al. 2006). This ecoregion is
characterized by dry plains, mesas, valleys, and canyons formed from sedimentary rocks. It supports
grasslands, savannas, woodlands, and desert scrub communities (Dick-Peddie 1993).

Vegetation

The study area supports Plains-Mesa Grassland, Great Basin Desert Scrub, Arroyo Riparian vegetation
communities, as well as a small area of Juniper Savanna. Plains-Mesa Grassland vegetation occurs in in the
center of Section 24; the northeast and southeast corners of Section 25; the northwest corner of Section
26, and Section 10, and within Section 30.

2


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It is dominated by blue grama (Bouteloua gracilis) and galleta (Pleurapis jamesii) grass, which account for
most vegetative cover. Associate grasses such as ring muhly (Muhlenbergia torreyi), spike muhly
(Muhlenbergia wrightii), spike dropseed (Sporobolus contractus) and several shrubs such as winterfat
(Krascheninnikovia lanata), four-wing saltbush (Atriplex canescens), and horsebush (Tetradymia canescens)
are also present.

Two scrub communities are present. The largest is a four-wing saltbush community dominated by four-wing
saltbush (Atriplex canescens), blue grama, galleta, alkali sacaton (Sporobolus airoides), and snakeweed
(Gutierrezia sarothrae). This community is located within the southwest corner of Section 24; the southern
portion of Section 23; the northern portion of Section 26; and the northwest corner of Section 25. A
rabbitbrush scrub community dominated by rubber rabbitbrush (Ericameria nauseosa), blue grama and
galleta is located within Section 22, the east side of Section 24; the center of Section 25, the east side of
Section 10. A small area also occurs within the northwest corner of Section 30.

The Arroyo Riparian community is confined to a few ephemeral waterways dominated by rabbitbrush,
western wheat grass, galleta, gumweed (Graindelia nuda), and hoary purple aster (Machaeranthera
canescens). With the exception of small segments of waterways in the Section 30, Arroyo Riparian habitat is
confined to sections 22, 23, 25, and 26.

Juniper Savanna is dominated by one-seed juniper (Juniperus monosperma) and at one location in section
22.

Existing Soils

Soils at the study area consists of the following US Department of Agriculture (USDA) Natural Resources
Conservation Service (NRCS 2015) map units listed by highest percent occurrence in the study area:
Penistaja-Tintero complex, 1 to 10 percent slopes (soil unit: 205); Marianolake-Skyvillage complex, 1 to 8
percent slopes (soil unit: 210); Hagerwest-Bond fine sandy loams, 1 to 8 percent slopes (soil unit: 220);
Sparank-San Mateo-Zia complex, 0 to 3 percent slopes (soil unit: 230); and Uranium Mined Lands (Soil unit
265).

Area soils are generally well drained; not hydric or slightly hydric; moderately susceptible to wind and water
erosion; and occur more than 200 centimeters from ground water depth. Soil chemistry and fertility
parameters were obtained via laboratory analysis of samples collected from the site (Weston 2016).
Detailed results are provided in Appendix A. In general, analyses indicate that area soils have low fertility;
are low in boron, zinc, and phosphorus; high in calcium, magnesium, and sodium; and have a low
carbon/nitrogen ratio. The pH of soil sampled throughout the area range from 7.9 to 9.0.

Special Features

One special feature is present at the site:

¦	Pond wetland (augmented with planting)

Restricted Areas

The following areas must be avoided (Figure lc):

¦	Eagle perch trees (sections 24 and 30)

¦	Groups of juniper trees/juniper savanna area (north section 22)

¦	Coniferous woodland area (south section 22, not within the current removal area)

3


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Ecological Function

Grassland and grassland/shrub communities provide habitat for keystone species such as prairie dogs and
associated animals, such as burrowing owl. They also provide browse and forage for elk, deer, and graze
for cattle; cover for a variety of small mammals and reptiles; and nest sites for small songbirds. The savanna
area provides some small mammal habitat and potential nest sites for birds, including raptors. Trees
provide perch sites for raptors, and vertical structure for songbirds.

A pond feature retains stormwater flows near the western edge of the removal area, which supports tree
canopy, food crop, and wetland vegetation growth and provides water for wildlife, including waterfowl and
important predators.

All vegetation provides erosion control. Grasses provide a food source for mammals and insects. Insects
provide a food source for reptiles, mammals and birds. An arroyo conveys stormwater flows through the
site.

2 - RECLAMATION GOALS /PERFORMANCE
Reclamation Units

The removal area has been divided into four reclamation units for planting purposes. Each unit is associated
with specific soil preparation and seeding methodology. Unit boundaries were defined based on existing
vegetation, soils characteristics, 2016 soil sampling data and historic aerial photography. Some portions of
the study area are not included in the removal area. As a result, disjunct parcels occur within units. All units
with the exception of Unit 4 are associated with one soil treatment and planting schedule. The two
components of Unit 4 (4a and 4b) are treated differently both in preparation and planting.

Reclamation Unit Boundaries

Reclamation units are identified in Figure 2. The reclamation units are:

•	Unit 1 - Plains Mesa Grassland (loam soils)

•	Unit 2 - Great Basin Scrub/Rabbitbrush (clay loam soils)

•	Unit 3 - Great Basin Scrub/Four-wing saltbush Scrub (clay soils)

•	Units 4a/b - Arroyo /Pond Wetland (clay soils)

Defining points along the boundaries of reclamation units (or center point for disconnected units/unit
portions) are provided in Figure 2 and associated with UTM coordinates provided in Table A1 (Appendix A).

Unit Performance Goals and Standards

The general objective for reclamation units is to meet or exceed the percent cover observed during field
evaluations. The minimum percent cover is based on observations of existing conditions, which were
evaluated by community type. Some areas will be avoided for removal and some communities are
combined for revegetation purposes to reduce the number of units and complexity of reclamation.

Unit 1-Plains Mesa Grassland

This is a large grassland community with low shrub cover. The objective for this unit is to meet a minimum
total 37 percent cover comprised of mostly of grasses, equal or greater than the current percent cover, and
reflect the general species composition of the area (Table 2.1).

4


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Table 2.1 - Target Range for Percent Cover by Species: Unit 1

Species

Range Percent Cover

Blue grama (Bouteloua gracilis)



Galleta (Pleuraphis jamesii)

Spike muhly (Muhlenbergia wrightii)

Western wheat grass (Pascopyrum smithii)

Spike dropseed (Sporobolus contractus)

Subtotal

35-40%

Winterfat (Krascheninnkovia lanata)



Subtotal

2-5%

Total

37 -45%

Unit 2-Great Basin Scrub/Rabbitbrush

This is principally a shrub community that provides at least 25 percent ground cover of grasses. The
objective for this unit is to meet a minimum total of 50 percent overall cover; nearly half of shrubs with a
ground cover of grasses equal to or greater than the current percent cover, and reflect the general species
composition of the area (Table 2.2).

Table 2.2 - Target Range for Percent Cover by Species: Unit 2

Species

Percent Cover Range

Blue grama Bouteloua gracilis)



Galleta (Pleuraphis jamesii)

Western wheat grass (Pascopyrum smithii)

Alkali sacaton (Sporobolus airoides)

Spike muhly (Muhlenbergia wrightii)



Subtotal - Grasses

25-30%

Rubber rabbitbrush Ericameria nauseosa)



Subtotal - Shrubs

25-30%

Total

50-60%

Unit 3- Great Basin Scrub-Saltbush

This is a shrub community dominated by four-wing saltbush with a limited ground cover of grasses. The
objective for this unit is to meet a minimum total 30 percent cover comprised of grasses and shrubs, equal
to or greater than the current percent cover, and reflect the general species composition of the area (Table
2.3).

Table 2.3 - Target Range for Percent Cover by Species: Unit 3

Species

Range Percent Cover

Galleta (Pleuraphis jamesii)



Western wheat grass (Pascopyrum smithii)

Blue grama Bouteloua gracilis)

Alkali sacaton (Sporobolus airoides)

Vine mesquite (Panicum obtusum)

Spike dropseed (Sporobolus contractus)

Hoary tansyaster (Macheranthera canescens)



Subtotal - Grasses and Forbes

15-20%

Four-wing saltbush (Atriplex canescens)



Subtotal - Shrubs

15-20%

Total

30-40%

5


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Unit 4a- Arroyo

This unit is confined to an arroyo system located along the southern site boundary. Vegetation is comprised
of forbs, shrubs and grasses. The objective for this unit is to meet a minimum total 40 percent cover, equal
to or greater than the current percent cover, and reflect the general species composition of the area (Table
2.4).

Table 2.4 - Target Range for Percent Cover by Species: Unit 4a

Species

Range Percent Cover

Galleta (Pleuraphisjamesii)



Western wheat grass (Pascopyrum smithii)

Blue grama Bouteloua gracilis)

Alkali sacaton (Sporobolus airoides)

Common sunflower (Helianthus annuus)



Hoary tansy aster (Machaeranthera canescens)



Subtotal - Grasses and Forbes

25-30%

Four-wing saltbush (Atriplex canescens)



Rubber rabbitbrush Ericameria nauseosa)

Subtotal - Shrubs

15-20%

Total

40-50%

Unit 4b- Pond Wetland

This unit consists of an existing stock tank and immediately surrounding area located along the western
edge of the site within Section 22. Stormwater runoff from surrounding slopes and arroyos collects in the
pond with sufficient frequency to sustain wetland vegetation. The objective for this unit is to increase
shrub, tree and ground cover. No existing wetland vegetation would be removed. Trees and shrubs would
be planted, and the 4a seed mix would be raked into surrounding soils (Table 2.5).

Table 2.5 - Target Range for Percent Cover by Species: Unit 4b

Species

Range Percent Cover

Coyote willow (Salix exigua)



Torrey wolfberry (Lycium torreyi)

Subtotal - Shrubs

15-20%

Rio Grande cottonwood [Populus deltoides)



Subtotal - Trees

5-10%

Total

20-30%

Ecological Function

Unit 1 - Grassland communities are to provide burrow systems and nesting habitat for keystone species
such as Gunnison's prairie dogs and nesting habitat for burrowing owl; as well as some browse/forage for
elk, deer, and graze for cattle; cover for a variety of small mammals and reptiles; and nest sites for small
songbirds. Grasses provide a food source for mammals and insects. Insects provide a food source for
reptiles, mammals and birds.

Unit 2- Grassy shrublands dominated by rabbitbrush are to provide structure for nesting birds and small
wildlife. The grassy groundcover provides habitat for small colonial mammals and forage for elk as well as
graze for cattle. The larger open areas along the edges of this unit may also provide habitat for prairie
dogs.

6


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Unit 3 - The four-wing saltbush and limited grassland community is to provide cover and habitat for small
mammals and nesting habitat for small songbirds and predatory birds, particularly species such as the
loggerhead shrike and sparrows; as well as and provide forage for elk, livestock and cover to small
mammals.

Unit 4a - Arroyo riparian communities are to provide shade, food and cover to wildlife and livestock as well
as nest sites to birds. Arroyos will direct and slow stormwater flows as well as prevent seedbed loss and
sedimentation due to sheetflow during large storm events.

Unit 4b- pond wetland is to be planted to add vertical structure, increase shade and cover; provide a wider
range of water and food resources to birds, reptiles, insects, mammals, and amphibians. If a permanent
water source feature (windmill) is successfully added, a constant water source, perennial wetland function
(such as sediment catchment and surface water quality improvement), and aquatic habitat once present in
the vicinity, but not currently available, would be restored.

3 - RECLAMATION/REVEGTATION WORK PLAN

Due to the size of the reclamation area, it may be necessary to complete revegetation by reclamation unit
over a period of several years. Reclamation tasks shall be completed for each reclamation unit in the order
provided in Table 3.1. Seasonal limitations associated with each task, if any, are identified by color coding
(green-suitable, red- unsuitable) in the schedule below.

Work Schedule: Task Order by Monthly Task Suitability

Task Order

OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

Install BMPs

























Clear/Grub*

























Remove Soil

























Grade

























Constructed Features

























Soil Preparation

























Stabilizing Cover Crop

























Seeding/Planting

























Irrigation

























Vegetation Monitoring

























Unsuitable - Suitable

*Avoid nesting season or provide preconstruction surveys

Staging Areas /Limitations

Materials used in Reclamation Unit 4b will include live plants. The staging area for this unit is be located
close enough to a water source to allow for watering the material awaiting planting, but not within a
potential flood area.

¦	No staging area will be placed within a restricted location.

¦	The contractor will site staging areas more than 200 feet from the arroyo/pond banks.

¦	All staging areas will be graded/vegetated according to their assigned reclamation unit
specifications prior to completion of work.

7


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Availability of Water and Limitations of Use

Water piped through the site is expected to be available for use in watering the site to establish vegetation.
This water is expected to be available for 5 growing seasons of reclamation effort. Water needed for dust
control during excavation and grading, as well as irrigation, is also expected to be available from this
source.

Revegetation Schedule

The revegetation schedule is dependent upon the seeding and planting schedule, which will occur in the
fall. Soil preparation and soil amendment predate the planting and must be completed sequentially prior to
fall seeding and planting.

Clearing and Grubbing

Once restricted areas have been identified, the removal of shrubs and other vegetation may proceed.
Because of sensitivity of nesting birds, this operation should be completed outside the nesting season
(March to September). If it cannot be completed outside the nesting season, a detailed survey of every the
clearing zone for active bird nests must be completed prior to the onset of clearing and grubbing.

Constructed Features

Constructed features will include installation of protective fencing and planting protections at the Unit 4b
pond wetland, as well as the construction of a windmill to provide a small but continuous source of water
at the wetland, if this option is feasible (depending upon depth to water). In addition, artificial burrows
may be installed in several locations within Unit 1 (Figure 3c) to temporarily replace lost nest sites for
western burrowing owls.

Soil Preparation—Fertilizers. Micronutrients and Soil Amendments

Soil preparation would occur upon completion of clearing, grubbing, and soil removal within the
reclamation area. Since it appears that the soil removal will consist of a protracted series of events, the soil
preparation may occur sequentially as tracts of land are cleared and excavated. The pace of soil preparation
will be dependent upon the rate of soil removal. However, within each calendar year applications of
fertilizers, micronutrients, and amendments must be completed by the middle of September.

Seeding. Planting. Cover Crop and Mulching

Seeding and planting is recommended for the fall when seeds/plants are dormant. The cover crop would be
planted at the same time, as it is included in the seed mix. Mulching would occur immediately after
seeding. However, clearing and excavation processes will be ongoing year round leaving open areas that
could be vulnerable to erosion. A sterile interim-cover crop is recommended to stabilize these areas until
the site is ready for fall planting. Water would be broadcast to establish cover crops. The cover crop would
be mowed in the fall and disked into the soil prior to seeding.

Watering

If an interim cover crop is used, then watering would likely be required to establish and maintain it. Since
the primary reclamation plants will be seeded in the fall, they should germinate from winter and early
spring moisture. Precipitation events should be monitored during the growing season and, if a drought
develops, watering should be implemented as described in the revegetation section.

Grading Plan and Constructed Features

There are no specific grading requirements or constructed features within Units 2 or 3.

8


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Re-contouring of the Unit 4a arroyo channel after excavating to reflect pre-removal ratios is recommended.
The purpose is to maintain the flow along the channel once removal is complete to avoid overbank sheet
flows that could result in scouring or sedimentation in seeded areas, as well as restore original function.

Unit 1 constructed features would consist of installing artificial burrows in created soil berms to provide
suitable nest sites for western burrowing owls while pre-reclamation conditions re-develop (Figure 3c).

Unit 4b constructed features are to provide protection to plantings to allow vegetation to establish, and a
permanent source of water to a localized area (If windmill is installed). No grading of this area is
recommended. Once removal is complete, small drainages on slopes surrounding this unit are expected to
reestablish without grading.

Soil Preparation

Upon completion of excavation, soil should be graded and smoothed to remove high or low spots created
by excavation that might impede soil preparation or the seeding process. Access to the soil preparation
areas will be available via temporary roads created during the excavation. Staging areas will be those used
during the excavation process.

Once the surface soil is removed the entire site should be evaluated to determine whether special
equipment may be necessary to prepare the soil for planting. Large portions of the study area have clay or
clay loam soils at the 12-inch deep soil removal level. The tilling process to incorporate soil amendments
may be difficult in clay soil, particularly if the soil is wet.

Soil analysis from the study area indicated carbon to nitrogen (C/N) ratios ranged from as low as 1:1 to a
high as 809:1. Even in areas where the ratio was close to a desirable 30:1, the actual carbon and nitrogen
levels were low. A ratio of 30:1 promotes rapid composting. Researchers report optimum values ranging
from 20 to 31:1 (Whatcom 2016). Because nitrogen levels are low throughout most of the removal area,
these levels must first be adjusted; then soil amendments added to balance the C/N ratio to a desirable
level of 30:1.

Discussion of Soil Amendment Sources

Traditional organic soil amendments include sawdust, bark, and manure. Other potential sources of
amendments are compost and humate, both of which are available locally. The following is a discussion of
each of these products and their potential application rates at the site (Potential sources are provided in
Appendix B).

Humate

Humate is a naturally occurring material composed of highly weathered organic compounds including salts
of humic, ulmic, and fulvic acids. It is used principally as a soil amendment in agriculture. Humate, when
used as a soil amendment or conditioner, has many useful properties which include: an increase in root
density, an increase in soil depth, retention of soil moisture, increase in soil aeration, and a decrease in soil
density.

By whole rock analysis, humate contains 80 percent organic material (most of which is carbon) and 20
percent inorganic material. Humate contains 2 to 5 percent nitrogen. New Mexico humate also contains
gypsum (CaS04), pyrite (FeS2), and siderite (FeC03), sources of calcium, sulfur, and iron (Sandia National
Laboratories 2012, 2013).

9


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The application of humate can raise the C/N ratio, increase the available nitrogen, and increase the
available micronutrients. One of these micronutrients is Boron, which was low within most samples in the
removal area.

Recent studies (Lodhi et. al. 2013) indicate that the C/N ratio within humates generally ranges from 30.92
to 44.16. New Mexico material near Cuba was found to have a C/N ratio of 30 to 40:1. Nitrogen content
within state humates ranges from 1 to 5 percent (Peace 2016).

Based on a desired C/N ratio of 30:1, and that the soil amendment is to be applied to the top 6 inches of
soil, the recommended application of humate was calculated. To calculate the proper amount of humate to
add to the soil to reach a C/N ratio of 30:1, the existing level of nitrogen was used as the starting point. The
existing levels of nitrogen vary widely across the site. Four of the 22 samples had medium levels of
nitrogen present. The higher the levels of existing nitrogen, the more humate will need to be added to
reach the C/N ratio of 30:1.

When humate is used, specific standards should be applied to the material. Accepted industry standards set
a minimum of 70 percent humic substances (i.e. humic, fulvic and ulmic acids). Humate comes out of the
ground at approximately 22 percent moisture content. Exposed to the dry southwest atmosphere is loses
moisture rapidly. When used as a soil amendment no specific moisture content is needed, but from the
economic standpoint as far as weight it should not me more than 22 percent moisture.

Run of mine material excavated from the mine varies in particle size from ablation (almost powder) to 90
millimeters (mm) in size. As the material dries it breaks down into smaller particle sizes. Smaller particles
are released into the soil quicker than larger particles. Particles 1-2 millimeters in size fast-release in a few
weeks to a month or two. Particles can be screened to calibrate the size. However, using runoff mine
material provides a wider range of particle sizes from the powder that would release into the soil very
quickly to pieces over in inch in size that would be much slower release. The run of mine material may be
most suitable for the reclamation process as it provides a slow release of material over time.

Table 3.1 presents the existing nitrogen in ppm for 22 samples collected, as well as the volume of humate in
pounds that would need to be added to elevate the C/N ratio to 30:1. Fifty percent of samples indicated
medium, high or very high nitrogen levels. Nearly all of these were samples taken within Unit 3. Conversely,
most of the samples taken from Units 1 and 2 indicate low levels of nitrogen. These account for the higher
levels of humate recommended for Samples S019-S022. The soil samples are taken at point locations and
as they represent a localized area they can as a single point be high or low.

To adjust for individual variation in points the soil sample data for the points within each of the planting
units were averaged. There are currently at least three humate mines in New Mexico that are providing
commercial sources of humate and are located approximately 2 to 2.5 hours driving time from the study
area (Appendix B).

Table 3.1 - Application Rates of Humate to Adjust C/N at Sample Sites

Soil Sample

Nitrate Nitrogen PPM

Pounds/Humate to achieve 30:1 C/N

S01-1609

9.1

764

S02-1609

8.4

705

S03-1609

12

1008

S04-1609

11

924

S05-1609

10

840

S06-1609

12

1008

10


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Soil Sample

Nitrate Nitrogen PPM

Pounds/Humate to achieve 30:1 C/N

S07-1609

8.6

722

S08-1609

11

924

S09-1609

10

840

SO 10-1609

8.9

747

SOU-1611

9.1

764

S012-1611

7.9

663

S013-1611

8.3

697

SO 14-1611

12

1008

S015-1611

17

1428

S016-1611

10

840

S017-1611

8.7

730

SO 18-1611

12

1008

S019-1611

44

3696

S020-1611

74

6216

S021-1611

45

3780

S022-1611

30

2520

Sawdust

Sawdust is a common amendment used to improve C/N ratio, which varies depending upon weathering.
Nearly all the sawdust available in New Mexico is from pine trees. Fresh pine sawdust (2 months) can have
a C/N ratio of 625:1) (Whatcom 2016). Applications of amendments with such a high C/N ratio would
probably require the application of additional nitrogen at a rate of 5 to 10 pounds per ton of fresh sawdust.
However the C/N ratio in sawdust weather for 3 years declines to about 142:1. Uncomposted sawdust is
slow to break down and can tie up nitrogen (CSU Extension 2016). If uncomposted sawdust is used, the C/N
ratio must be determined prior to application to determine whether additional nitrogen is needed.

US Forest Service studies (Koll et. al 2010) found applications rates of 7.6 tons of pine sawdust per acre
provided amendment properties similar to peat and hardwood sawdust. On average, dry sawdust weighs
approximately 353 pounds per cubic yard. Recommended application rates of dry, weathered sawdust are
7 to 10 tons or 40 to 55 cubic yards per acre. Although there are numerous lumberyards in New Mexico,
state directories currently only list four active sawmill operations (Appendix B).

Manure

Manure is a byproduct of diary operations and feed yards. Composted dairy manure C/N ratios vary. If
manure is a selected soil amendment, the use of dry composted dairy manure and testing of sources is
recommended to allow accurate calculation of application rates. Application rates vary from 30 to 100 cubic
yards per acre, with 50 cubic yards per acre being typical. Dry manure contains about 2.5 cubic yards per
ton. Studies in Vermont (Magdoff and Van Es 2009) found that within heavy clay soils, organic matter levels
were only maintained at rates equal to 20 tons or more of manure per acre, which would be approximately
50 cubic yards per acre. There are many dairy manure sources in New Mexico (Appendix B).

Compost

Composted material is available at a variety of locations in New Mexico. Most offer municipal yard waste,
which includes leaves, brush, and grass clippings. Fresh yard trimmings can contain 1.2 to 2.3 percent
nitrogen, 0.2 to 0.3 percent phosphorus, 0.5-1.0 percent potassium, 50-60 percent organic matter. Because
of the uncertainty of the origin of the source material for the compost, rates of application can vary from 40
to 270 cubic yards per acre with a typical rate of application of 50 cubic yards per acre.

11


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Many municipal compost sources are vegetative-product based, but incorporate bio-solids, feed, and stable
beddings, which can increase levels of nitrogen and may have lower the C/N ratio. If compost is derived
principally from wood and brush cuttings, it may have a substantially higher C/N ratio and may require the
application of nitrogen.

Typically, composted material is applied at a rate of 40 to 50 cubic yards per acre, but this may vary
depending upon the material. Particle size of the compost material can also vary. Active compost facilities
nearest to the site are listed in Appendix B.

Recommended Amendment Procedure

The recommended source of carbon for amending removal area soils is humate sourced from New Mexico.
Based on soil sample analysis, nitrogen is low at about half of sampling locations. Boron, Zinc, Sulfur and
Phosphate were low at nearly all locations. The pH is high in all of the reclamation units, and more than half
of samples ranged from 8.5-9.0. The removal area average pH is 8.4. Sulfur will be added to the soil to
adjust the pH.

The rate of application of nitrogen, micronutrients, and amendments will vary slightly between the
reclamation units. The application rates of nitrogen and micronutrients were adjusted to account for the
use of humate as the primary carbon soil amendment (If humate is not the selected carbon source, these
rates must be adjusted). Table 3.2 provides the application rates per unit. Unit 4b is excluded as it will be
planted but not cleared or graded. Humate contains nitrogen and many micronutrients needed in the
removal area soils. However, the addition of sulfur, zinc, boron, nitrogen and phosphorus is recommended.

The soils should be amended according to the following order to ensure efficacy:

1.	Add humate, run of mine (minimum 70 percent humic substances/ 22 percent moisture) plus
Sulfur in the form of S-granules at 90 percent purity and approximately 0.3 centimeters (cm)
particle size.

2.	Zinc and Boron can be mixed in water then sprayed onto prepared soils and allowed to dry
prior to application of next in sequence.

3.	Nitrogen in ammonium and nitrate form (UN 32 16 percent Urea, 8 percent nitrate) plus
Phosphorus in the form of rock phosphate applied together and tilled to six inches.

Carbon

Humate should be acquired from New Mexico sources for which the micronutrient composition is known. If
other sources are used, then a chemical analysis should be completed on micronutrient content, and
adjustments to the application rate of fertilizers and micronutrients may be required (minimum 70 percent
humic substances [humic, fulvic and ulmic acids], with no more than 22 percent moisture content).
Screened or run of mine material would be acceptable, but run of mine material provides a slow release of
material over time most suitable for reclamation.

Humate is to be broadcast and tilled/disked into soil to a depth of 6 inches. If humate is unavailable, use of
dry, composted dairy manure is recommended. Final application rates to be determined after testing.
Spread with a manure spreader and disk/till into the soil to a depth of 6 inches.

12


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Table 3.2 - Pounds per Acre Application of Soil Amendments within Reclamation Units

Reclamation Unit

Nitrogen

Phosphorus

Zinc

Boron

Sulfur

Humate

1

70

100

8

1

500

800-1000

2

70

100

8

1

550

1000-1300

3

10

100

8

1

350

1800-2200

4a

50

100

8

1

500

800-1000

Nitrogen and Micronutrients

Sulfur in the form of S-granules at 90 percent purity and approximately 0.3 centimeters (cm) particle size
should be used.

Zinc sulfate should be mixed into water and the subsequent zinc solution should be sprayed onto the soil
and tilled in.

Boron fertilizer should be dissolved in water and sprayed onto the soil. If boron fertilizer cannot be found
than 20 Mule Team Borax can be utilized by mixing ltbsp into 5 gallons of water and applying spray
applying 85 gallons per acre.

Nitrogen will all be added in solid form and should be broadcast across the reclamation units and
subsequently tilled into the soil to a depth of 6 inches. After the application of nitrogen, the site should be
watered to prevent the formation of hot spots in the soil.

Rock Phosphorus and elemental sulfur should be broadcast and tilled into the soil.

Seeding and Planting

It is recommended that seeding and planting not occur less than 4 weeks after the application of
humate/sulfur to ensure a stable soil pH. Seventeen vascular plant species were selected for revegetation,
including warm and cold season grasses, riparian and upland shrubs, and a riparian tree. Table 3.3 provides
a list of plant species recommended for the revegetation of the removal area, and summary of specific soil
needs and seasonal attributes for each species.

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Table 3.3 - Revegetation Species

Species

Season

Soil Type

Sodium/pH
Tolerance

Precip.
Needs
(inches)

Flowering

Rhizomes

GRASSES



Galleta

(Pleuraphis jamesii)

Warm

All

Tolerant

5-16

Summer

Yes

Blue Grama
(Bouteloua gracilis)

Warm

Clay

Moderate
pH 6.5 to 8.3

12-14

Summer

Short

Spike dropseed
Sporobolus contractus)

Warm

Sandy

Fairly Tolerant

8-10

Summer

No

Alkali sacaton
(Sporobolus airoides)

Warm

Clay

Tolerant of

Saline
pH 6.5 to 8.6

6-10

Summer

No

Vine mesquite
Panicum obtusum)

Warm

Clay

pH 4.8-7.0

8

Summer

Stolon-
iferous

Western Wheatgrass
(Pascopyrum smithii)

Cool

Fine/heavy
well drained

Tolerant

10 to 12
best @12-
20 seeded

Seeds in
June

Yes

Bottlebrush squirreltail
(Elymus elymoides)

Cool

Fine texture to
coarse/ gravelly

Tolerant
Moderately
saline

8-10

Spring-
Summer

No

Spike muhly
(Muhlenbergia wrightii)

Warm

Fine to coarse

Moderate

12-16 or
lower

Summer

No

SHRUBS



Winterfat

(Krascheninnikovia lanata)

NA

All Soils

Fairly Tolerant

5-20

Spring - Fall

No

Four-wing saltbush
(Atriplex canescens)

NA

Calcareous soils

Very Tolerant

8-15

Summer

No

Rubber rabbitbrush
(Ericameria nauseosa)

NA

Medium to
coarse

Moderate
pH 5.4 to 8.2

6-18

Fall-winter

No

Coyote willow
(Salix exigua)

NA

Sand, loam or
clay

Moderate
pH 7.0-7.6 or
ranging

persistent

Spring

A root
sprouts

Torrey wolfberry
(Lycium torreyi)

NA

Alkali soils

Tolerant
Alkaline

8-15

April-
October

No

TREES



Cottonwood
(Populus deltoides ssp.
wisiizeni)

NA

Most soils

Tolerant

6-15

Spring

No

FORBS



Hoary tansyaster
(Macheranthera
canescens)

NA

Wide range

pH6.0-8.4
Alkaline/saline

8-15

Summer

No

Common sunflower
(Helianthus annuus)

NA

Wide range

5.5-8.0

8-15

Summer

No

COVER CROP



Quickguard (Sterile
Triticate)

Cool

Wide range

Tolerant

1-10

Sterile

No

14


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Seed Application Methods and Times

Due to the types and sizes of seeds being used, seeding will require both drilling and broadcast methods.
There are no restrictions as to the sourcing of the seeds, but all seeds should be certified weed-free and
should be from regional southwestern or Great Basin area suppliers. Specific varieties have been
recommended for several grass species. The seeding specifications apply to all reclamation units. Unless
otherwise noted in the contract, the prescribed mix and rate will be uniformly applied over each
reclamation unit. Prior to shipping, the seed mix should be divided by the seed supplier into those that are
to be drilled, and those to be broadcast.

The seedbed will be prepared to a depth of 6 inches by tilling with a disc, harrow, or chiseling tool. All
competitive vegetation will be uprooted during seedbed preparation, and the soil will be uniformly worked
to a surface free of clods, large stones, or other foreign material that would interfere with seeding
equipment. The extent of seedbed preparation will not exceed the area detailed in the plans. On slopes of
3:1 or less, a combination of drill seeding and broadcast seeding will be used.

Drill seeders must be capable of handling a variety of different seed textures. Drill rows will be no greater
than 12 inches on center. All drilling will be completed parallel to the contour of the land where practical.
Seed will be drilled to a depth of 0.25 to 0.50 inches.

Steeper slopes (greater than 3:1) will be broadcast seeded. Broadcast seeding will also be used for certain
tiny seeds that need to be planted at shallow depths or those with fluffy seed coats. Broadcast seeding can
be accomplished with hand held spreader, all-terrain-vehicle mounted, tractor-mounted, or other methods
acceptable to the USEPA and capable of spreading seed uniformly may be used. The volume of seeds
should be doubled for those species that are specified for drilling but need to be broadcast on steep slopes.

Vehicles and other equipment unrelated to the seeding process will not travel over seeded areas. If rain or
some other event prevents seeding to the proper depth, the contractor will again prepare the seedbed. The
contractor will protect and care for seeded areas until final acceptance of the work and will repair all
damage to seeded areas caused by pedestrian or vehicular traffic.

Each bag of seed will be sealed and labeled by the seed provider in accordance with federal and New
Mexico Department of Agriculture labeling laws. The seed analysis will be no older than live (5 months) for
seed shipped interstate and no older than 9 months for seed shipped intrastate. Additionally, the
contractor will furnish documentation as to origin and pure live-seed content as determined by a certified
testing laboratory. Pure, live seed shall be defined as percent purity times percent germination including
dormant seed, divided by 100.

Areas will be seeded at the onset of the dormant period in the fall, from the middle of September until the
beginning of summer. The recommended cover crop (Quickguard Sterile Triticate) will be incorporated into
the seed mix. Fall planting is recommended in order to minimize the failure of seeding due to sporadic or
insufficient precipitation. Planting into the dormant season allows the seeds to take advantage of the
winter moisture. However, if sufficient irrigation water is available to establish and maintain seeded
material, seeding may be completed throughout the growing season into the fall.

Mulching

Barley straw mulch will be applied at a rate of 2,000 to 3,000 pounds of air-dry straw per acre and crimped.
Rotted or moldy straw will not be used. Mulching will not be permitted when wind velocity exceeds 15
miles per hour. The mulch shall be spread uniformly over the area either by hand or with a mechanical
mulch spreader. When spread by hand, the bales of mulch shall be torn apart and fluffed before spreading.

15


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Planted Material

All planted material must be acquired from local or regional sources so material is naturalized to the area
climate. It is recommended that acquired plant material be in 1 gallon stem pots 4x4x14 inches deep, or
some similar container. Care must be taken when transporting material to ensure that the root balls are not
desiccated in the process. Once the material arrives at the site, it should be inspected to ensure it is healthy
and meets the pot specification requirements. If the material must be stored prior to planting, it should be
placed in a shaded area and should be inspected on a daily basis and watered as needed.

Fall planting is recommended, and the material should be going into fall dormancy at the time of planting.
The leaves on the planted material should be falling or already have fallen at the time of planting.

Potted material should be planted to the top of the surface layer in the pot and immediately watered after
installation. A log will be kept identifying the height of shrubs, and both height and stem diameter at the
base of the planted trees will be recorded when they are planted. This information will serve as a baseline
for future monitoring.

During the first month after installation in the planted areas, it should be inspected on a weekly basis by the
revegetation manager to make sure there is no damage from wildlife.

Some potted material (cottonwood) will be eaten by elk and mule deer if not protected. Protection cages
will be installed around each planted cottonwood tree (Figure 3b). Cages will be constructed by placing
three T-posts (each 8-feet long) in a triangular position around each tree, approximately 18 inches from the
trunk. Chicken wire will be wrapped around the T-posts from the ground to the top of the 8-foot T-posts.
This wire will be left in place until the trees are 4 to 8 inches in diameter at which time the bark should be
thick enough that wildlife or livestock would not affect their growth.

Watering

If seeding occurs in the fall (including the cover crop), the seeded material is not to be watered. The seeds
will be planted while dormant, and under normal winter conditions, will receive sufficient moisture to
germinate the following spring. Water may be necessary during the following growing season if drought
conditions develop. The seeded areas should be inspected at least twice weekly in the spring and early
summer.

If drought occurs when seedlings are establishing, intense watering may be necessary until the root systems
develop. This may require watering lightly several times a week (soaking down to at least 1 inch). If drought
persists through the summer, water should be applied to the maturing vegetation weekly at the rate of the
expected monthly annual precipitation for the area (based on climate history data).

The establishment of a cover crop as an erosion control measure during the spring or summer will require
intensive water. If the area is not mulched, water would need to be applied every day for the first 15 days
such that the soil at a depth of 1 inch will hold water consistently. If the site is mulched and crimped, then
water can be applied every 2 to 3 days for 15 days when the seeds should have germinated, and the
seedlings develop root systems.

Since piped water is expected to be available, it is recommended that the contractor develop a rotation
watering system using trucks or install a temporary sprinkler system at seeded areas to increase the
likelihood of successful vegetation establishment.

16


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Rooted material should be watered when planted, and for weekly for several weeks after planting.
However, since this material will be planted during the dormant season, it should require only periodic
watering in the winter during dry periods (once bi-weekly) to prevent the root balls from drying out. Water
should be applied on a weekly basis during the following spring until the plants are established. If drought
conditions occur during the growing season, then watering may be needed every few days.

Seed Mix Specifications

Unit 1

Unit 1 covers approximately 644 acres. The seed mix for this unit is designed to produce a grassland
community with scattered low growing shrubs such as winterfat. This grassland community would
intergrade into surrounding shrub communities around the periphery forming an ecotone shrub/grassland
mixture. The seed mixture was adjusted to account for the clay and clay loam soils found in the 12 inch
deep soils samples found within Unit 1. The surface soils on which the existing grassland communities occur
within Unit 1 are a mixture of sandy loams and loams. Species such as blue grama favor these coarser well
drained soils and may not thrive as well on the clay soils located at 12 inches below the surface. However,
galleta can thrive in both loamy and clay soils. Because of its wider range of soil texture tolerance a higher
percentage of galleta was included in the seed mix than would normally be applied to reestablish the blue
grama/galleta community. Although western wheatgrass was sporadic in the existing grasslands it was
added to the mixture because it adds a cool season grass component.

Unit 1 components will require 9.41 pounds of native seed and 10 pounds of cover crop seed per acre
(Table 3.4). Approximately 0.51 pounds of this seed mix consists of either tiny seeds or fluffy seeds for
which general broadcast seeding is recommended either by equipment or by hand. The remaining 8.9
pounds of native seed and the 10 pounds of cover crop seed will be installed via drilling. The Unit 1 areas
are generally flat to slightly rolling, but none have grades likely to exceed 3:1 slopes.

Table 3.4- Unit 1 Seed Mix

Species

Lbs/acre (pis)

Seeds /lb

Pls/sq foot

Depth (inches)

Variety

DRILLED SEED











Blue grama (Bouteloua gracilis)

2.0

711,000

32.6

% to %

-

Galleta (Pleuraphis jamesii)

4.0

160,000

14.6

% to %

Viva

Spike muhly (Muhlenbergia wrightii)

0.4

1,635,000

15.0

1/4 to 1/2

El Vado

Western wheat grass (Pascopyrum
smithii)

2.5

110,000

6.3

1/4 to 1/2

Arriba

Total Natives

8.9



68.5





Cover Crop

10.0

13,000

3.0

% to %

Quickquard

Total Drilled

18.9



71.5





BROADCAST SEED











Spike dropseed (Sporobolus
contractus)

0.01

2,885,000

0.6

Surface to %

-

Winterfat (Krascheninnkovia lanata)

0.50

111,000

1.2

Surface to %

-

Total Broadcast

0.51



1.8





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Unit 2

Units 2 covers approximately 384 acres. The seed mix for this unit is designed to produce a shrub/grassland
community dominated by rabbitbrush intermixed with grasses. Blue grama is the most common extant
grass within all of the Unit 2 areas and is associated with galleta which is generally only about a / of the
cover of blue grama. Because some of the soil samples collected in Unit 2 were clay the percentage of
galleta in the seed mixed was upped in the same manner described for Unit 1. Western wheatgrass is
uncommon within all of the Unit 2 areas, but was noted in the shade of the rabbitbrush shrubs and within
low areas where stormwater would briefly accumulate. It is anticipated that it will develop around the
rabbitbrush. The Unit 2 planting areas will require 10.35 pounds of native seed and 10.0 pounds of cover
crop seed per acre (Table 3.5). Approximately 0.6 pounds of this seed mix consists of either tiny seeds or
fluffy seeds for which general broadcast seeding is recommended either by equipment or by hand. The
remaining 9.75 pounds of native seed and the 10 pounds of cover crop seed will be installed via drilling.
Most the Unit 2 areas are flat and slopes greater than 3:1 are not expected.

Table 3.5 - Unit 2 Seed Mix

Species

Lbs/Acre (PLS)

Seeds/ Lb

PLS/Sq Foot

Depth (inches)

Variety

DRILLED SEED











Blue grama (Bouteloua gracilis)

2.0

711,000

32.6

% to %

-

Galleta (Pleuraphis jamesii)

4

160,000

14.6

% to %

Viva

Western wheat grass (Pascopyrum

3

110,000

7.5

% to %

Arriba

smithii)











Spike muhly (Muhlenbergia wrightii)

0.25

1,635,000

9.3

% to %

El Vado

Bottlebrush Squirreltail (Elymus

0.5

192,000

2.2

% to %

-

elymoides)











Total Natives

9.75



66.2





Cover Crop

10

13,000

3.0

!
-------
Approximately 0.36 pounds of this seed mix consists of either tiny seeds or fluffy seeds for which general
broadcast seeding is recommended either by equipment or by hand. The remaining 9.25 pounds of native
seed and the 10 pounds of cover crop seed will be installed via drilling. Unit 3 is flat; there should be no
slopes steeper than 3:1.

Table 3.6 -Unit 3 Seed Mix

Species

Lbs/Acre (PLS)

Seeds/Lb

PLS/Sq Foot

Depth (inches)

Variety

DRILLED SEED











Galleta (Pleuraphis jamesii)

4

160,000

14.6

% to %

Viva

Blue grama (Bouteloua gracilis)

2.0

711,000

32.6

% to %

-

Western wheat grass (Pascopyrum
smithii)

1.5

110,000

3.8

% to %

Arriba

Vine mesquite (Panicum obtusum)

0.25

145,000

0.8

% to %

-

Four-wing saltbush (Atriplex
canescens)

1.5

70,000

2.4

% to %

De-winged

Total Natives

9.25



54.2





Cover Crop

10

13,000

3.0

% to %

Quickquard

Total Drilled

19.25



57.2





BROADCAST SEED











Alkali sacaton (Sporobolus airoides)

0.25

1,750,000

10.0

Surface to %

-

Spike dropseed (Sporobolus
contractus)

0.01

2,885,000

0.6

Surface to %

-

Hoary tansyaster (Macheranthera
canescens)

0.1

1,066,900

2.0

Surface to %

-

Total Broadcast

0.36



12.6





Unit 4a

Units 4a consists of arroyo riparian habitat within the study area and covers about 28 acres in long thin
segments. Within these areas rabbitbrush and western wheat grass often dominate, many times associated
with four-wing saltbush, galleta and to a lesser degree alkali sacaton, blue grama and hoary tansyaster. A
seed mix has been developed to mimic the current vegetation within these ephemeral waterways.
Segments of Unit 4 that require revegetation will require 9.05 pounds of native seed and 10 pounds of
cover crop seed per acre (Table 3.7). Approximately 0.7 pounds of the native seed mix consists of either
tiny seeds or fluffy seeds for which general broadcast seeding is recommended either by equipment or by
hand. The remaining 8.35 pounds of native seed and the 10 pounds of cover crop seed will be installed via
drilling. By definition these waterways have bed and bank structure, often with steep slopes that may
require broadcast seeding. Most of the channel bottoms are flat enough to use equipment for seeding.

Table 3.7 -Unit 4a Seed Mix

Species

Lbs/Acre (PLS)

Seeds/ Lb

PLS/ Sq Foot

Depth (inches)

Variety

DRILLED SEED











Four-wing saltbush (Atriplex

0.25

70,000

0.4

% to %

De-winged

canescens)











Galleta (Pleuraphis jamesii)

2

160,000

7.3

% to %

Viva

Western wheat grass (Pascopyrum

4

110,000

10.1

% to %

Arriba

smithii)











Blue grama (Bouteloua gracilis)

2.0

711,000

32.6

% to %

-

Common sunflower (Helianthus

0.1

60,000

0.1

% to %

Wild Seed

annuus)











19


-------
Species

Lbs/ Acre (PLS)

Seeds/ Lb

PLS/ Sq Foot

Depth (inches)

Variety

Total Natives

8.35



50.5





Cover Crop

10

13,000

3.0

% to %

Quickquard

Total Drilled

18.25



53.5





BROADCAST SEED











Rubber rabbitbrush (Ericameria

0.35

330000

2.6

Surface to %

-

nauseosa)











Alkali sacaton (Sporobolus airoides)

0.25

1,750,000

10.0

Surface to %

-

Hoary tansyaster (Macheranthera

0.1

1,066,900

2.4

Surface to %

-

canescens)











Total Broadcast

0.7



15.0





Unit 4b

Unit 4b consists of a stock pond wetland area nearly 2 acres in area. It was the only pond in the study area
that provided pooled surface water during 2016. Water collects from ephemeral runoff from nearby slopes.
The presence of wetland vegetation indicates that water is fairly persistent at the site. The proposed
revegetation of this area would consist of augmenting existing conditions to provide a permanent to semi-
permanent watering hole such as those historically present in the area.

Seeded Material would consist only of common sunflower. This would provide a food source for insects
during spring and summer, and birds in the fall. Seeds would be raked into bare ground around the pond to
a depth of 025-0.5 inches. Planted material would consist of rooted shrubs and trees to augment the
herbaceous wetland vegetation that is already present. Cottonwood, coyote willow and Torrey wolfberry
are recommended.

Each species should be placed in designated bank locations (Figures 3a and 3b). The cottonwood trees will
be planted with the root crown set at the edge of the maximum pool size. Coyote willow will be planted in
two bands along much of the pond edge. One band being set just below the maximum pool line within the
edge of the water, and the other just above the edge of the water; and spaced approximately 5 feet apart
within these bands A cluster of coyote willows with 3-4 rows present will be planted in a grid along the
west-central edge of the pond as indicated on. Torrey wolf berry will be planted along the upland slopes
just above the southern edge of the ponded area, just above the maximum pool size. It can be planted
anywhere from one row to three rows wide depending upon the slope. They should be planted
approximately 5 feet apart along this slope. The exact placement of the planted shrubby material will be
determined when more topographic data is available for the site.

Planted material is vulnerable to damage from livestock. Once planted, Unit 4b will be fenced for 5-years to
allow for the establishment of woody vegetation. The fence should consist of three-strand class 1, 12 Vz
gauge, 2-point barbed wire strung on 5 foot tall studded T-posts. The wire should be strung around the
periphery of Unit 4b except to provide an invagination in the wire perimeter has been left to allow wildlife
and cattle to the deepest part of the stock pond.

Table 3.8a -Unit 4b Seed

Species

Lbs/Acre (PLS)

Seeds/Lb

PLS/Sq Foot

Depth (inches)

Variety

Raked Seed











Common sunflower (Helianthus
annuus)

0.5

60,000

0.3

% to %

Wild Seed

20


-------
Table 3.8b -Unit 4b Planted Material

Species

Quantity

Type

Specification

Plantings



Cottonwood

(Populus deltoides ssp. wislizeni)

26

Tree

1 gallon stem pots 4x4x14 inches deep

Coyote willow
(Salix exigua)

270

Tall shrub

1 gallon stem pots 4x4x14 inches deep

Torrey wolfberry
(Lycium torreyi)

70

Low shrub

1 gallon stem pots 4x4x14 inches deep

Retain Existing Vegetation

Areas meeting the following criteria are to retain existing vegetation. No earthwork is to be completed in
these areas.

¦	Avoidance areas Identified on Figure 2

¦	Slopes steeper than 2:1

¦	Arroyo bottom when slopes steeper than 3:1

4- PERFORMANCE MONITORING
Monitoring Plan

Monitoring Period

The USEPA proposes to provide annual monitoring during the growing season beginning at 2 years post
seeding/planting for a period of 12 years from seeding - per reclamation unit. Performance standards are
based on achieving or surpassing existing conditions with regard to percent cover and species composition.
Conditions have naturalized since the mine ceased operations. No formal reference plots were available
outside the site, but nearby areas were observed to estimate cover and species composition for informal
comparison.

Assessment Methods

The following assessment methods are proposed in order to evaluate revegetation success prior to final
abandonment/closeout:

¦	Percent foliar cover (line transect)

Twenty-five permanent 100 meter transects would be established on the reclamation site to be distributed
over the reclamation units relative to unit size and complexity. For each of the reclamation units, the
proposed number of transects and performance goals are provided below (Tables 4.1- 4.4):

Unit 1: 8 Transects

The objective for this unit is to meet a minimum total 37 percent cover comprised of grasses and shrubs
equal or increase the current percent cover, and reflect the general species composition of the area.

Table 4.1

Vegetative Type

Percent Cover

Subtotal - Grasses

35-40%

Subtotal - Shrubs

2-5%

Total

37 -45%

21


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Unit 2: 6 Transects

The objective for this unit is to meet a minimum total 50 percent cover comprised of grasses/forbs and
shrubs equal or increase the current percent cover, and reflect the general species composition of the area.

Table 4.2

Vegetative type

Percent Cover

Subtotal - Grasses

25-35%

Subtotal - Shrubs

25-30%

Total

50 -60%

Unit 3: 7 Transects

The objective for this unit is to meet a minimum total 30 percent cover comprised of grasses and shrubs
equal or increase the current percent cover, and reflect the general species composition of the area.

Table 4.3

Vegetative type

Percent Cover

Subtotal - Grasses/Forbs

15-20%

Subtotal - Shrubs

15-20%

Total

30-40%

Unit 4a: 3 Transects

The objective for this unit is to meet a minimum total 45 percent cover comprised of grasses and shrubs eto
qual or increase the current percent cover, and reflect the general species composition of the area.

Table 4.4

Vegetative Type

Percent Cover

Subtotal - Grasses

25-30%

Subtotal - Shrubs

15 -20%

Total

40 -50%

Unit 4b: 1 Transect

The objective for this unit is to meet a minimum total 40 percent cover comprised of grasses and
shrubs/trees equal or increase the current percent cover, and reflect the general species composition of the
area.

Table 4.5

Vegetative Type

Percent Cover

Subtotal - Shrubs

15-20%

Subtotal - Trees

5 -10%

Total

20 -30%

22


-------
¦	Photo point monitoring

At least 25 permanent photo points, each located at an endpoint of a line transect (at least one per
reclamation unit/subunit) will be established to provide qualitative documentation of revegetation success.

¦	Species List

A complete species list for plants observed within the line transects and within a 25-foot area on either side
(50 foot swath) will be provided for each transect. New species or species absent relative to previous
monitoring years will be identified and total number of plant species observed provided.

Timeline

The target timeline for meeting performance standards is at or before the end of the of the 12 year
monitoring period.

Ecological Function Indicators

During the monitoring period, field visits to the site will include documentation of the presence or absence
of qualitative indicators that the site is providing the desired ecological function.

Unit 1

¦	Presence of Prairie dog colonies and burrowing owls

¦	Evidence of small mammal use (burrows, trails, scat)

¦	Presence of Insects

Units 2 and 3

¦	Growth of shrubs (stem diameter, height)

¦	Browse/forage activity by elk, deer

¦	Bird nests

¦	Presence of insects

Unit 4a

¦	Growth of grass and shrubs (stem diameter, height)

¦	Hydrology indicators such as sediment lines and debris

Unit 4b

¦	Survival of at least 50 percent trees and shrubs

¦	Growth of shrubs/trees (stem diameter, height)

¦	Evidence of wildlife use (tracks, observations, photo-documentation)

¦	Presence of persistent water (if windmill installed)

Sustainability

The following indicators of site sustainability will be provided in the monitoring report.

¦	Presence of prairie dogs and owls for 5 or more repeated years

¦	Growth of shrubs/trees (stem diameter, height)

¦	Size/vigor/condition of planted material

23


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5 - ADAPTIVE MANAGEMENT PLAN

Parties Responsible for Adaptive Management

The USEPA is the responsible party for implementing revegetation and subsequent monitoring. Long-term
maintenance requirements will be identified by USEPA in coordination with landowners and management
agencies.

Potential Challenges

At least five types of events that could reduce either the short-term or long-term success of revegetation
have been identified. These are: (1) site flooding leading to sedimentation; (2) site scouring leading to loss
of vegetation and soil; (3) protracted drought resulting in a loss of surface hydrology and loss of vegetation;
(4) infestation of invasive species supplanting desired species; and (5) over use by wildlife or livestock.
These events are described in more detail in the paragraphs that follow.

Flooding or Siltation of Planted Area

Flooding of the unit could lead to the deposition of fine silts and clays that bury emergent vegetation or the
deposition of sediment over seeded areas such that germinating seeds are not able to reach the surface.
The impacts of siltation are most damaging during the first season when seeds are germinating or seedlings
are growing (sediment deposits of 1-inch deep or more could affect seed germination or bury seedlings).

¦	Units 1, 2 and 3 have few drainages and a low potential for flooding.

¦	Unit 4 is historically an area that carries much of the area surface flow. During large flow
events, water could overtop the channel sheet flow.

¦	Unit 4 includes the arroyo and pond wetland. Large flow events could potentially bury the
constructed features at the wetland or cover planted and seeded material.

Action for Flooding, Siltation, and Sedimentation
Following large storm events, these actions are advised:

1.	The reclamation unit (in particular Units 4a and 4b) should be inspected immediately, and an
evaluation of the level of siltation should be completed. In Unit 4b, an examination of the
constructed features and planted material in should be completed.

2.	If siltation of at least 1 inch on seeded areas, or other damage is detected, the USEPA should be
contacted.

3.	If substantial amounts of sediment have been deposited on un-germinated seeds, or if seedlings
are buried, an evaluation of the extent of the damage should be completed. Small areas of damage
can be reseeded by hand. Large areas may require the use of equipment. Watering may be
necessary to re-establish the vegetation.

4.	If substantial sediment buildup occurs within the wetland pond Unit 4b, removal of material may be
necessary. Any planted material buried by silt may need to be replanted.

24


-------
Flood Scouring of Seeded areas. Planted Areas and Constructed Features

In the event of a large flow event within arroyos, scour could remove displace seeds, plants, or soil
amendments, fertilizers and micronutrients, and damage constructed features.

¦	Unit 4a is vulnerable to scour along its length during large flow events.

¦	Unit 4b is vulnerable to scour from storm events that could undermine constructed structures
or cut away the banks.

Action for Scouring from Flooding

1.	The reclamation units should be inspected immediately, and an evaluation extent of scouring and
cutting should be completed. These three observations should be documented:

a)	Determine whether the scouring was deeper than 1 inch of the surface, which would have
removed seeds or established vegetation.

b)	Determine whether the scouring was deeper than 6-inches, which would remove the soil
treated with amendments, fertilizers, or micronutrients.

c)	Determine whether the scouring was deeper than 6 inches below the surface, which would
alter the contours of the landscape. Within Unit 4a, a determination should be made as to
whether the constructed features are damaged.

2.	If substantial scour has occurred to planted areas or if constructed features have been damaged,
then the USEPA should be contacted.

3.	Shallow scours less than 1 inch that remove vegetation but do no impact the subsoil can be
mitigated by spreading a thin layer of soil over the area (approximately 1-inch) and reseeding and
mulching.

Scours to a depth of 6 inches will likely need localized recontouring followed by reapplication of
amendments, fertilizers, micronutrients, seeding, and mulching. Cuts deeper than 6 inches may
require regrading of a broader area to return the contours to the pre-flood conditions with the
ultimate response developed in coordination with the designing engineer and USEPA.

4.	Damage to the constructed features may require repair or design modifications. A certified
engineer in cooperation with the USEPA should complete any modification of the designs.

Drought

The proposed revegetation plan is designed to accommodate local average rainfall patterns, in particular
the summer monsoon season. The current drought status of the removal area is currently classified as not
in drought (National Drought Mitigation Center). An evaluation of area temperature averages and drought
status should be conducted prior to seeding or planting. Regular monitoring should occur during the
revegetation process along with inspection of seeded sites to determine whether supplemental watering is
required. The fall planting schedule was identified in anticipation of dry conditions. However, changing
short or long term climate patterns should be considered.

In all units drought could result in the failure of seeded material to germinate, the death of seedlings, or the
death/weakening of planted or established vegetation.

25


-------
Action for Drought

1.	Supplemental water is expected to be available. However, if not available, and weather monitoring
indicates that precipitation levels are below 50 percent of normal and are likely to continue, then
consideration should be given to postponing planting.

2.	If drought conditions develop after planting, weekly monitoring of the seeded and planted areas
should be implemented to look for signs of stress (withered leaves, brown leaves, yellowing).

3.	If supplemental water is available, it should be provided to the planted and seeded material.
Watering should reflect natural events of a good monsoon season (minimum of 0.5 inches per week
from July 1 through September 30). The reclamation area is so large that regular watering of the
entire area may be impractical. If full watering of the site is not possible, then a triage approach is
recommended.

a)	The planted wetland vegetation in Unit 4b is most vulnerable and should be watered first.

b)	Areas where seeded vegetation has rooted and is growing should be watered next, (replacing
established vegetation is more difficult than reseeding).

c)	Seeded areas that have germinated would be third in the list.

d)	Seeded areas that have not germinated should be watered last.

Invasive Species

Three New Mexico noxious weed species are currently present (Siberian elm, salt cedar, and Russian olive).

•	Siberian elm trees are scattered along the main paved access route into the site within Unit 2
(Section 30, T14N, R9W). One very large tree occurs in Unit 3 (S24, T14N, R10W), A few others
saplings were scattered across Unit 3, but are not expected to spread. Since these trees are known
perch sites for golden eagles they have been excluded from clearing.

•	One large salt cedar and some seedlings occur within Unit 4b (Section 22, T14N, R10W). Aside from
portions of Unit 4a the remainder of the site does not provide suitable conditions for this species to
spread.

•	Russian olive is very restricted to a few trees in the study area, occurring in a few low spots portions
of Unit 4a and Unit 2 in Section 30.

No specific removal plan is needed for the few scattered Class C species. With the exception of a single salt

cedar at the pond in Unit 4b, salt cedar and Russian olives will be removed by the clearing and grubbing.

Action for Invasive Species

1.	If the salt cedars present do sprout, they will be spot treated with spray on herbicide (Arsenal), or if
there is concern about killing desirable seeded vegetation, the top of each individual stem can be
cut off during the early spring and concentrated herbicide applied directly to the fresh cut with a
small paintbrush.

2.	Mechanical clearing of the few Russian olives present will occur during the grubbing process. No
other treatment is necessary.

26


-------
3. If patches of other species of weeds invade the site after the clearing, then grubbing and excavation
is recommended followed immediately by herbicide.

Overuse by Wildlife and Livestock

Livestock will be excluded from the site during the revegetation process and should not damage vegetation.
However, deer and elk occur in the area. Elk will graze on grasses once they sprout and it would be difficult
to exclude them from the seeded areas. Elk and deer will eat saplings of riparian woody species,
cottonwoods in particular.

¦	Unit 1 supports graze, some browse and limited cover for elk or deer, but supports prairie dogs and
associated burrowing owl nests.

¦	Unit 2 and 3 support browse, forage and some cover for elk and deer.

¦	Unit 4b provides water for wildlife.

Action for Overuse by Wildlife and Livestock

1.	Livestock should be excluded from the area until the native vegetation has become fully established
(5 years recommended).

2.	If deer or elk are damaging seeded areas, the New Mexico Department of Game and Fish (NMDGF)
should be contacted. NMDGF maintains a Wildlife Depredation and Nuisance Abatement Program
designed to reduce wildlife damage to property.

3.	Damage from browsing may occur to the planted vegetation in Unit 4a. Wire cages have been
recommended to avoid or reduce browsing. However, these cages can be damaged. Therefore,
they must be periodically inspected and repaired or replaced, as needed.

Procedures for Modifying Performance Standards and Timeframe

As reclamation proceeds, altering the work plan and performance standards may be required. Deviations
from expected performance will become evident during the annual monitoring of the site. The reclamation
management contractor and USEPA will be notified of a need to modify any of the following due to
availability of materials, natural events that alter the landscape/potential for success, or other events:

•	Soil amendments

•	Seed Mix

•	Planting Material

•	Constructed features

•	Performance goals

•	Performance standards

In coordination with state agency stakeholders, the USEPA will determine whether modifications are
acceptable and develop new standards if needed, which will be provided to the contractor as soon as
feasible for implementation.

27


-------
6- REFERENCES

AGGRAND Products

2010 Soil Fertility Guide. Website: https://www.aggrand.com/articles/g2792.pdf
Aqua-Flo Supply

2013 Improving Soil Fertility with Humate. Website: http://www.aquaflo.com/improving-soil-fertility-
with-humate/

2010 Cornell cover crop guide for oats. Cornell University. 2pp. Ver. 1.100716
Website: http://covercrops.cals.cornell.edu/pdf/oats.pdf

Bollen, W. B., and K. C. Lu.

1957 Effect of Douglas fir sawdust mulches and incorporations on soil microbial activities and plant
growth. Soil Sci. SOC.Am. Proc. 21(1):35-41.

Canadian Land Reclamation Association

2013 Proceedings of the 2013 Northern Latitudes Mining Reclamation Workshop and 38th Annual
Meeting of the Canadian Land Reclamation Association.

Cooperband, Leslie

2002 Building Soil Organic Matter with Organic Amendments. University of Wisconsin-Madison, Center
for Integrated Agricultural Systems.

Davis J.G. and D Whiting

2013 Choosing a Soil Amendment - 7.235. Colorado State University Extension

Website: http://extension.colostate.edu/topic-areas/yard-garden/choosing-a-soil-amendment/

Gano, K.A. and J. B. States

1982 Habitat requirements and burrowing depths of rodents in relation to shallow waste burial sites.
PNL-4140, Pacific Northwest Laboratory, Richland, Washington.

Gray, James R.

1973 Uses of sawdust and bark in New Mexico. New Mexico State University Library.

Website: http://contentdm.nmsu.edu/cdm/ref/collection/AgCircs/id/22367

Griffith, G.E., J.M. Omernik, M.M. McGraw, G.Z. Jacobi, C.M. Canavan, T.S. Schrader, D. Mercer, R. Hill, and
B.C. Moran.

2006 Ecoregions of New Mexico (color poster with map, descriptive text, summary tables, and
photographs): Reston Virginia, U.S. Geological Survey (Map scale 1:1,400,000). Website:
www.epa.gov/wed/pages/ecoregions.htm.

Koll, Paul, and Martin F. Jurgensen, R. Kasten Dumroese.

2010 Effects of Pine Sawdust, Hardwood Sawdust, and Peat on Bareroot Soil Properties. US Department
of Agriculture Forest Service Proceedings. RMRS-P-62 Website
http://www.fs.fed.us/rm/pubs/rmrs p062/rmrs p062 071 075.pd

28


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Johnson, David H. D.C. Gillis M. A. Gregg, J. L Rebholz, J.L. Lincer, and J. R. Belthoff

2010 Users Guide to the Installation of Artificial Burrows for Burrowing Owl. Global Owl Project.

Wdfw.wa.gove/publications/01100/wdfw01199.pdf.

Jordon, L.

2010	Burrowing Owl Artificial Burrow Installation. Thebirdersreport.com/conservation/burrowing-owl-
artificial-burrow-installation.

Menzel, S.

2014 An Assessment of Artificial Burrows for Burrowing Owls in Northern California. Master's Thesis
http://scholarworks.sjsu.edu/etd theses.

Larney, F. J. and Angers, D. A.

2012	The role of organic amendments in soil reclamation: A review. Agriculture and Agri-Food Canada.
Alberta, Canada. Website: https://www.researchgate.net/publication/271516678

The role of organic amendments in soil reclamation A review

Lidhi, A., Shermeen Tahir, et al.

2013	Characterization of Commercial Humic Acid Samples and Their Impact on Growth of Fungi and
Plants. Nuclear Institute for Agriculture and Biology, Faisalabad.

Magdoff, F., and H. Van Es

2009 Building soils for better crops. 3rd ed. Sustainable Agriculture Network Handbook Series Book 10.
National Agricultural Laboratory, Beltsville, MD.

Website:: http://www.sare.org/publications/bsbc/bsbc.pdf

Mahdy, Ahmed Mohamed

2011	Soil & Water Res., 6, 2011 (4): 205-216. Comparative Effects of Different Soil Amendments on
Amelioration of Saline-Sodic Soils.

Website: http://www.agriculturejournals.cz/publicFiles/51684.pdf
McGeehan, Steven L.

2012	Impact of Waste Materials and Organic Amendments on Soil Properties and Vegetative
Performance. Applied and Environmental Soil Science.

Website: http://www.hindawi.com/iournals/aess/2012/907831/

National Drought Mitigation Center.

2017 Website: http://droughtmonitor.unl.edu/Home/StateDroughtMonitor
National Resources Conservation Service

2016 Soil Mapper. Website http://websoilsurvev.sc.egov.usda.gov/App/HomePage.htm
New Mexico Administrative Code

2014	Guidance for Meeting Radiation Criteria Levels and Reclamation at New Uranium Mining
Operations. Title 19, Chapter 10, Part3, and Part 6 (Draft). Energy, Minerals & Natural Resources
Department Mining and Minerals Division.

29


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Norton, Jay

2009 BLRS Soils Workshop. Soil Fertility and Amendments for Rangeland Reclamation. Website:

http://www.uwvo.edu/soilfert/pubs/soil%20fertilitv%20and%20amendments%20for%20rangeland%20recl

amation.pdf

Olatuyl, S. O., L. A. Leskiw

2015	Evaluation of soil reclamation techniques at the Key Lake uranium mine. Canadian Journal for Soil
Science. Edmonton Alberta, Canada.

Olayinka, Akinyemi and Adewale Adebayo

1985 The effect of methods of application of sawdust on plant growth, plant nutrient uptake and soil
chemical properties. Plant and Soil. 86:1 pp47-56. Website: http://link.springer.com/article

Olenick, B.

1987 Reproductive success of Burrowing Owls using artificial nest burrows in southwestern
Idaho. Eyass 10:38.

Partners in Flight.

2016	Burrowing Owl Artificial Nest Box Project. Mirror-pole.com/burr_owl/bur_owll.htm.

Peace, Jerry. 2016. Personal communication.

Poulin, R. G.

2000 Burrowing Owl nest box: construction and installation procedures.Saskatchewan Environment and
Resource Management, Fish and Wildlife Branch. Regina, Saskatchewan, Canada.

Sandia National Laboratories

2012	Discussion and Evaluation of Humate. SAND Number: 2012-10401P.US Department of Energy. 8pp.

2013	Soil Remediation using Humate as a Prime Soil Conditioner. SAND Number: 2013-9397. US.
Department of Energy. 8pp.

Shomaker, John W., and William L Hiss

1974 Humate Mining in Northwestern New Mexico. New Mexico Geol. Soc. Guidebook, 25th Field Conf.,
Ghost Ranch (Central-Northern N.M.). Website:

https://nmgs.nmt.edu/publications/guidebooks/downloads/25/25 p0333 p0336.pdf
US Army Corps of Engineers.

2008 A field guide to the identification of the ordinary high water mark (OHWM) in the arid west region
of the western United States. U.S. Army Corps of Engineers Environmental Laboratory.

Wallace, Victoria

2016 Temporary grasses stabilize soil. Penton Media, Inc. Website: http://grounds-
mag.com/mag/grounds maintenance temporary grasses stabilize/

Washington State University Whatcom County Extension.

Compost Fundamentals Compost Needs (Materials & methods to ensure quality compost) Carbon-nitrogen
relationships. Website: http://whatcom.wsu.edu/ag/compost/fundamentals/needs carbon nitrogen.htm

30


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APPENDIX A
Figures
Exhibits


-------
San Juan

Rio Arriba

Colfax



Mora

McKinl

Bernalillo-

Cibola

Guadalupe

Vaknck Toirance

DeBaca

Roosevelt

Socorro

Catron

Lincoln

Chaves



Grant



Otero

Dona
Ana



Hidalgo

MrtC MS





Figure 1a
Project Location Map

Study Area
Removal Area
Land Ownership
BLM
Private

Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

0.5

T 14N, R 10W& 9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico

N

I Kilometers

0.425

0.85

1.7

A

I Miles 1:40,000

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


-------

-------
"Ambrosial

mkkim

6; T14N.R10W

23; T14N.R10W

24; T14N.R10W

19; T14N.R09W

26; T14N.R10W

34; T14N.R10VV

15: T14N.R10W

; T14N.R10W

10; T14N.R10W

36; T14N.R10W

31; T14N.R09W

22; T14N.R1QW

27; T14N4R10W0W

14; T14N.R10W

25; T14N.R10W

11: T14N.R10W

13; T14N.R10W

35; T14N.R10W

18; T14N.R09W



Figure 1c
Restricted Areas

Study Area
Avoidance Area
Perch Trees

0.5

0.375

T 14N, R 10W&9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
Bernalillo County, New Mexico
Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7,5' Quadrangles ^

0.75

I Kilometers

1.5
Miles

A

USEPA Tronox 4 Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


-------
23; T14N.R10W

25; T14N.R10W

Rio Arriba

Colfax

Alp*not . 	

Project Area

Mora \ Harding

McKinl

Bernalill(

Cibola

Guadalupe

Valenci

Torranc*

DeBac;

Catron



Grant

Otero





Figure 2
Reclamation Units

Study Area	Unit 3	T14N, R 10W& 9W;

Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
Removal Area	Unit 4a	McKinley County, New Mexico

Goat Mountain, NM &

Unit 1	Unit 4b

Ambrosia Lake, NM

ynjj 2	USGS 7.5' Quadrangles N

0.5	1	2

Kilometers

0.35	0.7	1.4

Miles 1:33,000

A

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


-------
Reclamation Unit ID Sites

Point ID

UTM

Id

Unit

Xcoord

Ycoord

1

1

240957.9511

3924853.883

2

2

241998.2174

3924908.09

3

1/2

241767.8827

3924373.994

4

2/3

240785.6605

3924408.067

5

1/2

242053.1848

3923414.875

6

2

242940.2208

3923391.416

7

1/2

243095.0539

3922161.973

8

1/2

242130.8447

3922479.85

9

1

241806.0655

3922723.421

10

1/3

241309.9847

3922967.686

11

1

241916.0932

3923286.668

12

3

240544.1856

3923524.701

13

3/4

240591.089

3922502.266

14

1/3

239652.3917

3923329.548

15

4

238948.8093

3923121.238

16

1/3

239271.2251

3923182.641

17

1

239394.4024

3923653.111

18

4

238612.9929

3923524.598

19

2

238473.5245

3923622.966

20

1/3

238609.294

3923990.372

21

1/3

238797.2529

3924102.122

22

4

237896.1325

3923840.168

23

2

237972.9668

3924053.499

24

2

237957.7633

3924244.364

25

2/3

238313.1746

3924319.88

26

4

238284.4983

3924489.196

27

3

238970.1908

3925112.158

28

3

239031.2442

3924534.651

29

3

237774.6162

3925087.572

30

1/4

241698.9222

3921853.037

31

1

242964.4419

3921774.241

32

1

239087.876

3927704.409

33

1

239060.8616

3927293.924

34

2

238942.932

3927486.505

35

4b

238252.5715

3924595.943


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I

N

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1:1,000

TUN, R 10W&9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico
Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

~ T

/

Potential Windmill Location

¦

§ 1 _ , _

IS* 9

Dirt Access Road

Figure 3a

Unit 4b Conceptual Planting Overview

Removal Area
Unit 4b

O

Salix exigua (Coyote Willow)
Lycium torreyi (Wolfberry)
Populus deltoides (Cottonwood)

Access Route to Water
for Cattle

3 Strand Barbed Wire Fence
Set on 5' Tall Studded T-Posts

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


-------
8'TallT-Posts

Wfcwen Wlire
or Chicken Wire-
Wrapped Arour»d
Posts

-—-

—

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--—-

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' Cottonwood
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Cottonwood Protection Cage

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(Salix exigua)N



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T-post y»T-post

Plan View of Cottonwood Protection Cage

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Figure 3b
Conceptual Planting Plan View
Unit 4b

T14N, R 10W&9W;

Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico
Goat Mountain, NM &

Ambrosia Lake, NM
USGS 7.5' Quadrangles	Scale:

"Fig not to scale

N

A

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


-------
in'

Ground Level



ik

Artificial Burrow

CO



V

Artificial Burrow 11

26'

PROFILE

60'

Artificial Burrow

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Figure 3c
Burrow Placement
Conceptual Plan

T 14N, R 10W&9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico
Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

N

A

Scale:
'Fig not to scale

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


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Figure 3d
Berm Locations

Study Area	Unit 3

Removal Area	Unit 4

Unit 1	~ Berm

Unit 2

o

0

T 14N, R 10W& 9W;
Sec. 10, 11. 15, 22, 23, 24, 25, 26,
McKinley County, New Mexico
Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

N

0.225

0.15

0.45

0.9

¦I Kilometers

0.3

0.6

A

I Miles 1:14,000

USEPA Tronox Western GSA Mines, McKinley County, New Mexico - Re-Vegetation


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nfi- T14NI R09W

11; T14N.R10W

12; T14N.R10W



14; T14N.R10W

13; T14N.R10W

28; T14N.R10W

27; T14N4R10W0W

25; T14N.R10W

34; T14N.R10W

35; T 14N.R10W

10; T14N.R10W

36; T14N.R10W

19; T14N.R09W

26; T14N.R10W

30; T14N.R09W

22; T14N.R10W

23; T14N.R10W

24; T14N.R10W

31: T14N.R09W

15; T14N.R10W

Bjtfc-l ¦ -



02; T 14N.R10W

18; T14N.R09W



Figure 4
Project Area
1954 Aerial Photo

Study Area
Removal Area

Goat Mountain, NM &
Ambrosia Lake, NM
USGS 7.5' Quadrangles

T 14N, R 10W& 9W;
Sec. 10, 11, 15, 22, 23, 24, 25, 26, 30
McKinley County, New Mexico

N

0.5

Kilometers

0.4

0.8

1.6

A

I Miles 1:35,000

USEPA Tronox Western GSA Mines, McKinley County, New Mexico


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APPENDIX B

Soil Amendment Sources **

(**Marron is not affiliated with any listed source. Inclusion of sources is for information

purposes and not
intended to provide an endorsement.)

32


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Appendix B


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Humate Sources

Menefee Mining Corporation

36 Duke City Rd,

Cuba, NM 87103
575-289-0259

Mesa Verde Resources

P.O. box 1368
Placitas, NM 87043
Contact: Bruce Reid
505-362-3777

Horizon Ag Products

23 Cubita Road, Cuba,

NM 87013. Sandoval County
Contact: Steve Brady
575-289-2565

Sawdust Sources

Olguin Sawmill

Taos, New Meixco-
Sawdust available 575-758-1506

El Molino Sawmill

Alto, NM
575-336-1237-

Boards, firewood, uncertain about sawdust

Spotted Owl Timber,

Santa Fe, NM 505-474-5326
Sawdust, mulch and landscaping material

Mt. Taylor Manufacturing LLC.

Milan, NM.

505-877-0890 Albuquerque,

Milan 505 287-9469

Possibly sawdust and compost from wood products
Dairy Manure Sources

De Smet Dairy and Creamery

2405 McNew Rd
Bosque Farms, NM 87068
(505) 916-0475

Old Windmill Dairy

52 Paso Ranch Rd
Estancia, NM 87016
(505) 384-0033

O


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asband Dairy

7116 Isleta Blvd SW
Albuquerque, NM 87105
(505) 873-2171

Mickey's Cash & Carry Dairy

5102 Coors Blvd SW
Albuquerque, NM 87105
(505) 873-0542

Edeal Dairy

147 Edeal Rd

Los Lunas, NM 87031

(505) 865-9517

Creamland Dairies

1201W Apache St
Farmington, NM, 87401
(505) 325-0281

Willard Dairy

190 Dairy Rd
Willard, NM 87063
(505) 384-0573

Pareo Farm Inc

PO Box 489,

Veguita, NM 87062
(505) 864-8103

Caballo Dairy

1 Caballo Alto Rd
Arrey, NM 87930
(575) 267-3061

Gonzalez Dairy Inc

14310 Stern Dr
Mesquite, NM 88048
(575) 233-4801

F&A Dairy Products, Inc.

355 Crawford Blvd
Las Cruces, NM 88007
(575) 647-1696

Las Uvas Valley Dairy

Las Uvas Diary Rd
Hatch, NM 87937
(575) 267-3037

o

I 3


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Compost Sources

Albuquerque/Bernalillo County Water Utility Authority, Soils Amendment Facility 7401 Access Road NW

Albuquerque, NM 87102

4201 2nd St. SW (waste water treatment plant)

Albuquerque, NM 87105

Contact: Joe Bailey, Supervisor

E-mail: jbailey@abcwua.org

Phone: 505-205-5721 or 505-873-6989

Feedstocks: 20% solids (municipal biosolids), waste horse stable bedding, pulverized green waste, bark fines and
chips

Quantity produced: 45,000 cu. yds. per year capacity.

Barela Landscaping

7713 Bates Rd. SE
Albuquerque, NM 87105
Contact: Eddie Barela, owner
E-mail: cb0513@myway.com
Phone: 505-877-8522

Feedstocks: yard trimmings, steer manure, dairy manure, chili peelings Quantity produced: 40,000 cu. yds. per year

Barela Timber management Co

Contact: Ralph Barela
viga@newmexico.com
699 Harlan Dr.

Las Vegas, NM 87701

Phone: 505-617-1966, 505-425-9479, 505-454-4311 60,000 cu. yds. Capacity
Compost, Colored Mulches, Aged Mulch, Vigas

Midwest Bio-Systems

3333 Majestic Ridge -207B

Las Cruces, NM 88011

Contact: Greg Berry

Phone: 575-521-3692 Fax 521-3699

E-mail: gberry@totacc.com

Applications: Composting systems, microbe applications and Aeromaster turning equipment, Compost and
balanced soil fertility consulting.

Mountain Rich Soils

HCR 74, Box 22612

El Prado, NM 87529

Contact: Dave West

Phone: 505-758-4150

Email: growfoodnow@tierralucero.org

Feedstocks: alfalfa, forest waste, manure, straw, humates, Production: approx. 10,000 cu. yds. per year

Sandoval County Landfill

Contact: Buster Roseberry
Phone: 505-269-6120


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E-mail: rmsanchez@sandovalcounty.com

Feedstocks: Green waste, cow manure, horse manure

Future feedstocks to include biosolids and municipal solid waste

Quantity Produced: to be determined

Application: county projects, general public

Santa Fe, City of

73 Paseo Real

Santa Fe, NM 87507

General Information 505-955-4650

Contact: Sherman Bilbo, Compost

Phone: 505-955-4681

E-mail: swbilbo@santafenm.gov

Website: www.santafenm.gov/compost

Feedstocks: wood chips, biosolids, horse stable bedding

Quantity produced: 30,000-35,000 Cubic Yards per year will eventually be produced .

The composting operation processes all biosolids with appropriate high-carbon feedstocks to produce a
marketable soil conditioner product. (Screened Compost $11.50/cubic yard; Unscreened Compost $9.00/cubic
yard; Compost Overs $6.00/cubic yard)

Santa Fe Solid Waste Management Agency Caja del Rio Landfill

149 Wildlife Way

Santa Fe, NM 87507 Contact: Randall Kippenbrock, Executive Director
E-mail: rkippenbrock@sfswma.org

Phone: 505-424-1850 ext. 100 or 505-820-0208 (Transfer Station)

Feedstocks: ground green waste and horse manure / stable bedding
Qty Produced: Actual 2004 = 10,000 Tons

Application: DOT Erosion Control Compost, currently some sales sold as mulch. If loaded, charge for compost is $6
/ cu. yd.; screened compost is $10 / cu. yd. Mulch $2 / cu. yd.

Soilutions, Inc.

P.O. Box 1479
Tijeras, NM 87059

9008 Bates Road, SE (no zip - Delivery address)

Albuquerque, NM

Contact: Jim Brooks, Misch Lehrer, Walter Dods
Phone: 505-877-0220 or 505-281-8425
E-mail: walter@soilutions.net

Feedstocks: Yard trimmings, selected animal manures, stall bedding, agricultural and food processing residuals
Quantity Produced: 5,000-10,000 cu. yds. annually

Products Available: Premium Compost, soil blends, mulches, NMDOT erosion control products, composting worms,
green waste, food waste and C&D recycling services

Comments: Company is actively pursuing nitrogen sources as well as distributorships in New Mexico.

Quantity Produced: 300,000+ cu. Yds. Per year
Types of equipment: extensive

Application: Wholesale, retail, golf courses and other turf grass applications, etc.


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APPENDIX I

HUMAN HEALTH AND ECOLOGICAL RISK EVALUATION


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This page intentionally left blank


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Appendix I

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

HUMAN HEALTH AND ECOLOGICAL RISK EVALUATION

Uranium mine wastes are known to contain elevated levels of radium-226 (Ra-226) and associated
progeny. Radium-226, a daughter product in the uranium-238 (U-238) decay chain, has been
found to be the predominant contributor of radiological risk to human health and is the
radionuclide for which historical cleanup limits have been specified at uranium mines.
Radium-226 has been identified as a human health contaminant of potential concern (COPC) at
the Section 10 Mine Site to be addressed as part of cleanup actions. Radium is formed when
uranium and thorium undergo natural decay in the environment. During the decay processes,
alpha, beta, and gamma radiation are released. Results of Site investigations have indicated the
need for a response action to control releases and prevent human exposure to radiation at the Site.
Table 1-1 summarizes the radionuclide analytical results and the human health risks associated
with Ra-226 and other isotopes of the Uranium-235 (U-235) and U-238 decay chains at the
Section 10 Mine Site, assuming no action is taken. EPA considered contributions to human health
and ecological risks from all of the isotopes in the U-238 and U-235 decay chains. Note that the
risk estimates presented in Table 1-1 also include contribution of the background level of Ra-226
(1.3 pCi/g). The estimated cancer risk associated with some of the waste soil currently present at
the Section 10 Mines Site exceeds the EPA 10"4 overall cancer risk threshold, and therefore it is
anticipated that action will be taken to reduce the human health risk.

Several other non-radionuclide metals were also identified as exceeding human health screening
levels and background (Table 1-2). Table 1-3 summarizes the human health risks associated with
non-radionuclide metals. Tables 1-4, 1-5 and 1-6 present the results of an ecological risk
assessment for the Section 10 Mines Site. Table 1-7 presents an evaluation of the grazing of forage
by domesticated animals and wildlife.

The following sections describe the risk assessment process. Based on this evaluation it is
concluded that Site actions are required to address radiological human health risks at the Section
10 Mines Site, and that actions taken to address radionuclides will be protective for
non-radionuclide chemical exposure and for exposure of ecological receptors.

US EPA REGION 8

1 of 17	TDD No. 0001/17-044


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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

1. Analytical Data Used in Risk Assessment Calculations

Analytical results of soil samples collected during the Removal Site Evaluation at the Section 10
Mine Site (WESTON, 2019) served as input data for the human health and ecological risk
assessments. These samples were analyzed for radioisotopes (i.e., Ra-226) via gamma
spectroscopy in the field using an on-site Multi-Channel Analyzer (MCA). Four of the surface
samples were also analyzed in an off-site laboratory as verification of the on-site MCA results.

Surface soil (0-6 inch below ground surface [bgs]) samples were collected to verify that
radioactive contamination existed in areas of elevated gamma. Ten surface soil samples were
collected from the Section 10 Mines Site. To determine vertical extent of contamination,
subsurface soil samples (12-18 inch bgs) were collected from "mine impact" (direct impact from
surface related mining operations) and "sheet flow" (mining operation surface water discharge)
areas throughout the surface-contaminated areas. The samples were collected in "mine areas" at
a density of one sample for each 2 acres. A total of 10 subsurface samples plus one field duplicate
were collected from the Section 10 Mine Site.

In October 2018, eight surface soil samples plus one duplicate were collected from the Section 10
Mine Site for analysis of TAL (EPA Method 6010B) metals. The metals analysis was performed
to evaluate if common mining-related heavy metals present a potential risk to human health or the
environment. A minimal number of samples were analyzed for TAL metals and uranium metals
due to consistent geochemistry and limited historical processing for metals other than uranium as
product. There is no history of non-uranium metals mining in the ALSD. The analytical results
used in the evaluations are summarized in Table 1-1 and Table 1-2.

Additionally, EPA collected two vegetative metals uptake samples in order to determine the
current vegetative nutrient values and uptake of potential hazardous constituents available to
grazing animals (domesticated animals and wildlife). The analytical results are presented in
Table 1-7. Native plant tissue samples were analyzed for nutrients (iron, zinc, copper, and
manganese) and for toxicity metals (molybdenum, uranium, vanadium, and selenium).

USEPA REGION 8

2 of 17	TDD No. 0001/17-044


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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

2. Screening to Identify Contaminants of Potential Concern

The non-radionuclide sampling results were screened against the November 2019 EPA [2019a]
residential Regional Screening Levels (RSLs) (https://semspub.epa.gov/work/03/2229055.pdf).
the New Mexico Environment Department (NMED, 2019) generic soil screening levels (SSLs)
for residential land use and the local background concentrations to identify human health non-
radionuclide COPCs. Table 1-2 summarizes this screening process, showing contaminants that
were considered, the minimum and maximum concentrations, associated RSLs and SSLs, and
background concentrations, and either identifies each contaminant as a COPC or explains why it
was screened from consideration. Screening levels were adjusted to a target cancer risk of 10"6
and a target hazard quotient of 0.1 to account for additive risk. Aluminum, arsenic, cobalt, iron,
manganese, selenium, uranium, and vanadium concentrations exceeded the most stringent of their
respective RSLs.

Site-specific background levels were not available. Background levels for the metals were
obtained from literature values for New Mexico (EPA, 2007) and the Western United States
(Shacklette and Boernren, 1984). These background levels are also considered in the risk
evaluation. Background information is important to risk managers because the Comprehensive
Environmental Response Compensation and Liability Act (CERCLA) program, generally, does
not clean up to concentrations below natural or anthropogenic background levels (EPA, 2002).
Aluminum, cobalt, iron and manganese concentrations do not exceed background levels. However
the following four metals exceed their background levels:

•	The maximum arsenic concentration (20 mg/kg) exceeds the mean concentration (5.9
mg/kg).

•	The maximum selenium concentration (87 mg/kg) exceeds the mean concentration (0.29
mg/kg)

•	The maximum uranium concentration (310 mg/kg) exceeds the mean concentration (2.5
mg/kg)

•	The maximum vanadium concentration (250 mg/kg) exceeds the mean concentration (71.4
mg/kg)

USEPA REGION 8

3 of 17	TDD No. 0001/17-044


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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

As shown in Table 1-2, arsenic, selenium, uranium and vanadium were identified as non-
radionuclide human health COPCs in soil. A streamlined risk assessment for these metals is
presented below.

3. Streamlined Human Health Risk Assessment

The results of the streamlined human health risk assessment are summarized in Table 1-1 for
radionuclides. Cancer is the major effect of concern from radionuclides. Radium is known to cause
bone, head, and nasal passage tumors in humans; and radon, via inhalation exposure, causes lung
cancer in humans. The potential excess lifetime cancer risk on human receptors from exposure to
Ra-226 and other isotopes of the U-235 and U-238 decay chains in soil was assessed for the
Section 10 Mine Site. Radionuclides in the soil may be absorbed by plants and consumed by
livestock and humans. Persons working at the Site may be exposed to contaminated dust by
inhalation of particulate matter. Whole body (external) radiation may be experienced by people
on or near the Site itself. Key assumptions used in the human health risk evaluation are described
below.

Many sections of the Ambrosia Lake valley are used for grazing cattle, although some sections
are not currently grazed due to the radioactive contamination in the surface soil. There are
currently no residences in the former mining area of the Section 10 Mine Site and it is unlikely
that the property would be used for residential development due to the remoteness of the area.
Cattle ranching is considered to remain as the future use of the site. A rancher may be exposed to
radiological contaminants through incidental ingestion of soil, external radiation from
contaminants, inhalation of fugitive dusts, and meat consumption taking into account the potential
future land use of grazing and associated ranching activities.

The indoor and outdoor radon inhalation pathway was not included in this assessment. The indoor
inhalation pathway was not considered because there are no occupied buildings on the site and no
future plans for site development. An EPA review of outdoor radon data collected at uranium
mine and mill sites (WESTON, 2012; Rio Algom Mining, 2016) in the vicinity of the Section 10
Mine site verified that clean-air dilution of radon emissions from those sites rapidly reduces the
airborne concentrations to inconsequential levels (i.e., less than the EPA recommended limit for
indoor concentrations of 4 pCi/L).

US EPA REGION 8

4 of 17

TDD No. 0001/17-044


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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

The risk to a rancher from potential exposure to isotopes of the U-235 and U-238 decay chains
was evaluated at the Section 10 Mines area. The EPA Preliminary Remediation Goal (PRG)
calculator (https://epa-prgs.ornl.gov/cgi-bin/radionuclides/rprg search) was used to calculate site-
specific risk estimates for exposure from soil incidental ingestion, external exposure, inhalation of
particulates (details are included in Attachment 1), and consumption of meat (i.e., beef). The risk
estimates considered the isotopes of the U-235 decay chain (i.e., Th-231, Pa-231, Ac-227, Th-
227, Fr-223, Ra-223, At-219, Rn-219, Bi-215, Po-215, Pb-211, Bi-211, Tl-207, Po-211, and stable
Pb-207) and the U-238 decay chain (i.e., Th-234, Pa-234m, U-234, Pa-234, Th-230, Ra-226, Rn-
222, Po-218, Pb-214, At-218, Bi-214, Rn-218, Po-214, Tl-210, Pb-210, Pb-210, Bi-210, Hg-206,
Po-210, Tl-206 and stable Pb-206) as being in secular equilibrium. The assumption of secular
equilibrium is that the parent is continually being renewed. The single isotopes of U-235 and U-
238 were selected, and the calculator identified all the daughters in the chain. The risk estimates
for each daughter are combined with the parent on a fractional basis. The fractional basis is
determined by branching fractions where a progeny may decay into more than one isotope. The
resulting risk estimate is now based on secular equilibrium of the full chain (EPA [2019] PRG
Calculator User's Guide (https://epa-prgs.ornl.gov/radionuclides/prg_guide.html).

A combination of three land-use scenario templates in the PRG Calculator were used to develop
the risk estimates: the "Composite Worker" to model outdoor ranching activities; the "Indoor
Worker" to model ranching activities inside a truck; and "Farmer" to model the consumption of
site-raised beef. A number of conservative default assumptions presented in the PRG and
calculators and literature sources were reviewed to develop conservative assumptions for
calculating risk estimates for the rancher. EPA derived PRG Calculator default values to represent
reasonable maximum exposure to broad-based populations, typically 90-95 percentile values,
which are well above the mean. These assumptions are described below.

¦	Ranching was assumed to occur on the site 5 days per week for 50 weeks per year for 25
years, which is the default exposure frequency and duration of an indoor worker and
composite worker (EPA, 2019b).

¦	Two cattle ranchers who operate on lands near the Site were interviewed to determine a
reasonable amount of time a cattle rancher might spend on this activity. Consequently,
EPA used a value of 400 hours per year (1.6 hours/day [interviews] for 250 days/year
[PRG Calculator default value for Composite and Indoor Worker]) for annual exposure

US EPA REGION 8

5 of 17

TDD No. 0001/17-044


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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

frequency. Half of this time was determined to be spent outdoors (0.8 hours; see
discussion below).

¦	Traveling in a vehicle will limit external exposure to radionuclides; a rancher was
assumed half of their exposure time (0.8 hours per day) in a truck (EPA, 2011,

Table 16-24: Time Spent in Truck, Doers. Western Census Region, 95 percentile;

235 minutes/day = 3.9 hours = approximately 50% of an 8-hour workday). A vehicle was
estimated to provide a gamma shielding factor of 0.7 by a Certified Health Physicist
conducting a reproducible field experiment (Attachment 2). No cover layer was assumed
for exposure outside a vehicle.

¦	A default composite worker soil intake rate of 100 milligrams per day (mg/day) (EPA,
2019b) was applied for a rancher.

¦	Inhalation rate of a rancher was assumed to be 60 cubic meters/day based on the PRG
Calculator default value for an outdoor worker (EPA, 2019b).

¦	Average body weights of 80 kilograms for an adult was assumed over the exposure
period (EPA, 2019b).

¦	Inhalation of chemicals adsorbed to respirable particles (particles less than or equal to 10
micrometers in diameter) was assessed using a default particulate emission factor (PEF)
equal to 2.57E+09 cubic meters per kilogram. The default PEF was derived using default
values adjusted to apply to the climate zone for Albuquerque, New Mexico and a
250-acre source size (approximately equivalent to one million square meters, the largest
Area Correction Factor choice in the PRG Calculator [the site equals approximately

5 million square meters]). The PEF equation relates the contaminant concentration in soil
with the concentration of respirable particles in the air due to fugitive dust emissions
from contaminated soils. The relationship is derived by Cowherd, et al. (Cowherd, 1985;
as cited by EPA, 2019b) for a rapid assessment procedure applicable to a typical
hazardous waste site, where the surface contamination provides a relatively continuous
and constant potential for emission over an extended period of time (i.e., years). This
represents an annual average emission rate based on wind erosion that should be
compared with chronic health criteria; it is not appropriate for evaluating the potential for
more acute exposures (EPA, 2019b).

¦	It is assumed that 48% of meat consumed by a rancher was home-produced (i.e., from on-
Site animals), which is based on the 50th percentile value for "percent of home-raised
meat consumed by Western households who farm" presented in Table 13-19 of EPA's
2011 Exposure Factors Handbook. Default home produced meat consumption rate of
165.3 grams/day for 350 days/year was assumed based on the default PRG Calculator
value for beef (EPA, 2019b). These values are an annual consumption rates so an
exposure frequency (EF) of 350 days/year was applied.

¦	Cattle were considered to graze on Site 33 percent of the time annually, based on research
citing that rangeland experts suggest only 25 to 50 percent of arid rangeland in fair to

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McKinley County, New Mexico

good condition should be consumed or utilized by livestock in order to leave sufficient
vegetation for re-generation (Hurd et al, 2007).

¦ Concentrations in beef were estimated from soil concentrations using radionuclide-
specific transfer factors incorporated in the PRG Calculator. The PRG Calculator default
mass loading factor of 0.25 was applied for all forage (EPA, 2019b). A forage intake rate
of 11.77 kg/day and a soil intake rate of 0.5 kg/day were applied (EPA, 2019b; PRG
Calculator default for beef) for cattle.

EPA manages risk to achieve 10"6 to 10"4 (1E-06 to 1E-04) overall excess cancer risks. EPA risk
assessment guidance suggests that the average of the concentration is regarded as a reasonable
estimate of the concentration likely to be contacted over time (EPA, 1989). Because of the
uncertainty associated with any estimate of the representative average, the 95th percentile upper
confidence limit (95UCL) on the arithmetic mean is generally used as the reasonable maximum
exposure concentration (EPA, 1989) [Attachment 3], Risk estimates were calculated using the
reasonable maximum exposure point concentration (EPC). The EPC is based on the lower of the
maximum detected and the 95% UCL on the mean. As shown in Table 1-1, total cancer risks for
the isotopes of the U-235 and U-238 decay chains (expressed as Ra-226 concentrations) for the
Section 10 Mine Site equaled or exceeded the 10"4 (1E-04) overall cancer risk threshold. The total
cancer risks in surface and subsurface soils were 6E-03 and 2E-04, respectively. These results
indicate the need for a response action to control releases and prevent radionuclide exposure. Note
that these risk estimates also include contribution of the background level of Ra-226 (1.9 pCi/g).

For the non-radionuclide COPCs (i.e., arsenic, selenium, uranium and vanadium), the USEPA RSL
calculator (https://epa-prgs.ornl.gov/cgi-bin/chemicals/csl_search) was used to develop site-
specific risk-based screening levels and to calculate cancer risk estimates, and non-cancer hazard
quotients (HQs) for exposure from soil incidental ingestion, dermal absorption and inhalation of
particulates. Of the non-radionuclide COPCs, only arsenic is considered to have carcinogenic
effects. Systemic, non-cancer effects are of concern for all the non-radionuclide COPCs. Dermal
contact with selenium, vanadium and uranium is not quantified because these metals are not
considered to be dermally absorbed through the skin and do not have EPA-recommended dermal
absorption factors. The "Composite Worker" land-use scenario template in the RSL Calculator
was used to develop the risk estimates for the outdoor ranching activities (details are included in
Attachment 1). External exposure is not an exposure route for non-radionuclides, so ranching
activities inside a truck are not evaluated for the non-radionuclides. In addition, risk-based

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Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

screening levels were developed for the home-grown meat exposure pathway for metals following
methods used for radionuclides in the PRG Calculator (details are included in Attachment 1). The
sum of ratios approach was used to estimate human health risk from beef consumption. For cancer
effects, the site-specific concentration is divided by its cancer-based screening level for residential
soil to meat consumption and this ratio is multiplied by 10"6 (1E-06) to calculate a cancer risk
estimate. Individual cancer risk estimates are summed to represent a total cancer risk. The site-
specific concentration is divided by its non-cancer-based screening level for residential soil to meat
consumption to calculate a HQ. The individual HQs for each scenario (ranching - inside a truck,
ranching-outdoors, and beef consumption) and for each COPC are summed to represent a total
non-cancer hazard index (HI). A HI of one or less is generally considered "safe." A ratio greater
than one suggests that, at a minimum, further evaluation (EPA, 2017a) is necessary.

As shown in Table 1-3, using maximum non-radionuclide chemical concentrations in soil, the total
non-radionuclide HI was 4. Uranium was the only individual non-radionuclide COPC to have an
HI greater than 1 (HI, 1.4). Arsenic, selenium, and vanadium had an HI less than one. For non-
cancer hazard estimates, dose additivity is most properly applied to compounds that induce the
same non-cancer effect. Segregation of HI by the major target tissue/organ effects should be
performed if the total HI for multiple contaminants exceeds one. The target system for uranium
(urinary) differs from the remaining COPCs - arsenic (cardiovascular, dermal), selenium (nervous,
hematologic, dermal), and vanadium (dermal). As the non-cancer hazard index for non-
radionuclide COPC exposure slightly exceeded the threshold of one, adverse non-cancer health
effects from exposure to uranium in soil at the Section 10 Mine Site are possible. The only non-
radionuclide carcinogenic COPC was arsenic. Cumulative cancer risks from arsenic using the
maximum detected concentration yielded a carcinogenic risk of 1E-05 (See Table 1-3). The
elevated arsenic concentration in surface soil (20 mg/kg at 10-06-31-181031-M) was located in
close proximity to the elevated radionuclides in surface soil. It is anticipated that site actions to
address radionuclide exposure by human receptors will be protective for exposure of human
receptors to both radionuclides and non-radionuclide chemicals.

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

4. Ecological Risk Evaluation

The Section 10 Mines Site is located in a remote area with the revegetated, previously disturbed
mine area potentially providing habitat for ecological receptors. Wildlife inhabiting the Site may
directly ingest radionuclides and chemicals, which may then be transported to organs or other
sites within the wildlife receptors. Radionuclides and chemicals in the soil may be absorbed by
plants consumed by wildlife. Radionuclides such as radium, radon, and daughter progeny may
be inhaled, creating alpha-particle-emitting sources in the lungs of wildlife receptors. A
screening level ecological risk assessment (i.e., Steps 1 and 2 of EPA's 8-step ecological risk
assessment process [EPA, 1997]) was performed to assess potential risk to ecological receptors
from both radionuclide and non-radionuclide chemical contaminants. The results of the
screening level ecological risk characterization are included in Table 1-3. A refinement of
conservative screening level assumptions (i.e., Step 3a of EPA's 8-step ecological risk
assessment process [EPA, 2001]) was also performed to consider how the risk estimates would
change if more realistic assumptions were used. The results of the refined ecological risk
characterization are included in Table 1-4.

4.1 Ecological Risk-Based Screening Values

Literature-based ecological screening benchmark values for direct contact and food-chain
evaluations are used to characterize potential ecological effects. The following sources were
used to identify proposed ecological screening benchmark values for radionuclides and
chemicals:

¦	EPA Ecological Soil Screening Levels (Eco-SSLs) (http://www.epa.gov/ecotox/ecossl)

¦	Los Alamos National Laboratory (LANL) ECORISK database, Release 4.1
(LANL, 2017).

¦	New Mexico Environment Department (NMED, 2017) Tier 1 ecological screening levels

The Eco-SSLs include values for plant, soil invertebrate, bird, and mammal exposure to metals
through direct contact and the food chain. Eco-SSLs are also available for protection of birds
and mammals from the three primary feeding groups (herbivores, insectivores, and carnivores).
The Eco-SSLs are based on no-effect toxicity values 1) to ensure risks are not underestimated,

(ESLs)

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Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

and 2) to provide a defensible conclusion that negligible ecological risk exist or that certain
contaminants and exposure pathways can be eliminated from consideration (EPA, 1997). The
Eco-SSLs are intended to be conservative screening values that can be used to eliminate
contaminants clearly not associated with unacceptable risks (EPA, 2005a - 2005h, 2006, and
2007b - 2007e).

The LANL EcoRisk database includes ecological screening levels (ESLs) for avian,
mammalian, earthworm, and plant exposure models for radionuclides and chemicals in soil. The
ESLs for soil-dwelling invertebrates and terrestrial plants are based on direct contact with soil
by plants and soil-dwelling organisms living in impacted soil. The ESLs for upper level wildlife
are based on incidental ingestion of soil while feeding, preening, or nesting on the ground, and
ingestion of food sources that have bio-accumulated contaminants. The wildlife functional
feeding guilds for birds and mammals used to develop ESLs include herbivores, insectivores,
and carnivores. The LANL EcoRisk database provides both no-effect and low-effect ESLs. The
no-effect ESL is based on a no-observed-adverse-effect-level (NOAEL)-based toxicity reference
value (TRV) that is protective of wildlife populations and sensitive individuals because it
represents an exposure that is not associated with adverse impacts of low-level, long-term
chemical effects (i.e., adverse effects on ability of individuals to develop into viable organisms,
search for mates, breed successfully, and produce live and equally viable offspring). The
NOAEL values are often extremely conservative and protective, and are designed to be an
indication of no impacts if not exceeded (LANL, 2017). The low-effect ESL applies a lowest-
observed-adverse-effect-level- based TRV that is the lowest chronic effect level and is generally
considered to be protective of wildlife populations.

The NMED has developed Tier 1 ESLs protective of plant community, deer mouse, horned lark,
Kit fox (evaluated at sites greater than 267 acres), Pronghorn (evaluated at sites greater than 342
acres), and Red-tailed hawk (evaluated at sites greater than 177 acres). The key receptors
selected as the representative species represent the primary producers as well as the three levels
of consumer (primary, secondary, and tertiary) for the most common receptors found at
hazardous waste sites in New Mexico. For plants, the Tier 1 screening level is based on an
effect concentration for plant communities. For wildlife receptors, the Tier 1 screening level is
based on NOAEL-based toxicity reference values (NMED, 2017).

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

4.2 Ecological Risk Estimates

Screening level risk characterization was performed using the hazard quotient (HQ) method to
compare maximum surface (0-6 in bgs) soil concentrations to Eco-SSLs and no-effect ESLs. An
HQ of less than 1 indicates that the concentration is unlikely to cause adverse ecological effects.
An HQ greater than 1 indicates that the potential for ecological risk is present and therefore the
risk assessment process should continue. An HQ of 1 is the condition where the exposure and
the dose associated with no adverse chronic effects are equal, indicating adverse effects at or
below this soil concentration are unlikely (EPA, 2005a). The screening process considered the
isotopes of the U-235 and U-238 decay chains, though ESLs were not available for all isotopes.
The screening-level ecological risk assessment indicates potential for risk to ecological receptors
from exposure to Ra-226, Th-230, aluminum, arsenic, barium, lead, mercury, selenium,
uranium and vanadium (Table 1-4 for radionuclides; Table 1-5 for metals). Concentrations of
aluminum, barium, and lead were below background levels (Table 1-6); these three metals are
not considered to be chemicals of potential ecological concern (COPEC).

A screening-level ecological risk assessment uses conservative screening-level assumptions such
as 100% site use, 100% bioavailability, 100% diet consists of the most contaminated dietary, and
no-effect toxicity data to evaluate risk to populations of upper level organisms. Under more
realistic site use conditions, the potential risk to individual organisms would be reduced. The
average soil concentration and low effect ecological screening values were used to refine these
risk estimates. In the refined ecological risk characterization (Table 1-6), risks were calculated
using a representative average exposure point concentration (i.e., 95% UCL on the mean). The
average surface soil concentration of Ra-226 exceeds the low effect ESL for soil invertebrates
(i.e., HQ>1), indicating potential risk to this receptor group. Maximum concentrations of
arsenic, lead and mercury do not exceed low-effect ESLs (i.e., HQ <1) for any receptor group,
indicating these metals are not considered to pose risk to populations of higher level organisms.
The maximum concentration of selenium exceeds low-effect ESLs for plants, soil invertebrates,
avian herbivores, insectivores and carnivores, and mammalian herbivores and insectivores (i.e.,
HQ>1). The maximum concentration of vanadium exceeds low-effect ESLs for plants, and avian
herbivores, insectivores and carnivores (i.e., HQ>1). Note that vanadium was not detected in
native plant tissue samples collected from the Section 10 Mine Site (Table 1-7), suggesting

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Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

limited bioavailability of vanadium. The refined ecological risk assessment indicates potential
for risk to ecological receptors from exposure to Ra-226 (soil invertebrates only), selenium, and
vanadium (Table 1-6). Locations where elevated levels of selenium and vanadium were measured
are co-located with locations of elevated Ra-226. ESLs for radionuclides are higher (less
stringent) than the proposed action level for protection of human health. Thus, it is anticipated
that site actions to address radionuclide exposure by human receptors will be protective for
exposure of ecological receptors to radionuclides. Selenium, molybdenum, and vanadium are
common metals in association with uranium in the Grants Mineral Belt deposits (Brookins,
1982). As an impurity, they may have been a waste metal in the uranium mine waste. Actions to
address uranium are also expected to be protective of ecological receptors.

5. Evaluation of Grazing of Forage by Domesticated Animals and

The results of the evaluation of the vegetative metals uptake samples are included in Table 1-7.
Twenty-two surface vegetation samples were collected to determine the current vegetative
nutrient values and uptake of potential hazardous constituents available to grazing animals
(domesticated animals and wildlife) within the entire West GSA (which included the Section 10
Mine at the time of collection) (WESTON, 2019). Two of the native plant vegetation samples
(P-l 1 and P-12) were collected from the Section 10 mine. Tissue concentrations were compared
to maximum tolerable limits (MTLs) developed by the National Research Council's Committee
on Minerals and Toxic Substances in Diets and Water for Animals (NRC, 2005), which are
defined as dietary level, that, when fed for a defined period of time, will not impair animal health
or performance. Tissue concentrations are also compared to concentrations of trace elements in
mature leaf tissue that are considered sufficient or normal and excessive or toxic (Kabata-
Pendias and Pendias, 1992). As shown in Table 1-6, nutrient concentrations are less than MTLs
for animals and within or less than sufficient/normal concentrations for plants while the P12
tissue sample for the toxic metal selenium exceeds thresholds for animals and plants. An
elevated selenium concentration (81 mg/kg) was measured in soil collected from an area
approximately northwest of the Kermac Mine where the P12 tissue sample was collected. While
selenium is a common micronutrient supplement for cattle and sheep, it can be toxic at elevated
concentrations. Native selenium has been found in the sandstone formations the Grants Mineral

Wildlife

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Appendix I (Continued)

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Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

belt area (Brookins, 1982) and as an impurity, it may have been a waste metal in the uranium
mine waste.

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

6. Appendix I References

Argonne National Laboratory (ANL). March 2007. Radiological and Chemical Fact Sheets to
Support Health Risk Analyses for Contaminated Areas.
https://www.remm.nlm.gov/ANL ContaminantFactSheets All 070418.pdf

Beyer, W. Nelson, Erin E. Connor, Sarah Gerould. 1994. Estimates of Soil Ingestion by
Wildlife. J. Wildl. Manage. 58(2):375-382.

Cowherd, C.C., et al. 1985. Rapid Assessment of Exposure to Particulate Emissions from Surface
Contamination. EPA/600/8-85/002. U.S. Environmental Protection Agency. Office of
Health and Environmental Assessment, Washington, DC. February.

Hurd, Brian H., Torell, Allen L. and McDaniel, Kirk C. 2007. Perspectives on Rangeland

Management: Stocking Rates, Seasonal Forecasts, and the Value of Weather Information
to New Mexico Ranchers. New Mexico State University, Agricultural Experiment
Station. Research Report 759. December 2007.

Kabata-Pendias, Alina and Henryk Pendias. 1992. Trace Elements in Soils and Plants. 2nd
Edition. CRC Press. Boca Raton, FL.

Los Alamos National Laboratory. September 2017. ECORISK Database (Release 4.1), LA-UR-
17-26376, Los Alamos National Laboratory, Los Alamos, NM.

Nagy KA (2001) Food requirements of wild animals: predictive equations for free-living

mammals, reptiles, and birds. Nutrition Abstracts and Reviews, Series B 71, 21R-31R.

National Research Council (NRC). 2005. Mineral Tolerance of Animal. 2nd Revised Edition.
The National Academies Press. Washington, D.C.

New Mexico Environment Department (NMED). 2019. Risk Assessment Guidance for Site

Investigations and Remediation. Volume I - Soil Screening Guidance for Human Health
Risk Assessment (March 2017 Revised). February 2019. (Revision 2, 6/19/19).

NMED. 2017. Risk Assessment Guidance for Site Investigations and Remediation. Volume II -
Soil Screening Guidance for Ecological Risk Assessments. March 2017.

Rio Algom Mining LLC (RAML). 2016. Semi-annual Effluent Report-1st Half 2016. License
SUA-1473, Docket No. 40-8905. Submitted to U.S. Nuclear Regulatory Commission,
Office of Nuclear Material Safety and Safeguards, Materials Decommissioning Branch.
August 29.

Shacklette, H.T. and J.G. Boernren. 1984. Element Concentrations in Soil and Other Surface
Materials of the Conterminous United States. USGS Professional Paper 1270)

U.S. Environmental Protection Agency (EPA). 1989. Risk Assessment Guidance for Superfund
Volume I - Human Health Evaluation Manual, Part A (RAGS). EPA/540/1-89/002.

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

EPA. 1997. ERA Guidance for Superfund: Process for Designing and Conducting ERAs. Interim
Final. Washington, DC. EPA/540/R-97/006. June.

EPA. 2001. "The Role of Screening-Level Risk Assessments and Refining Contaminants of
Concern in Baseline Ecological Risk Assessments." Office of Waste and Emergency
Response. Washington D.C. EPA 540/F-01/014. June.

EPA. 2002. Role of Background in the CERCLA Cleanup Program. Office of Emergency and
Remedial Response, Washington, DC. OSWER 9285.6-07P. April.

EPA. 2005a. Guidance for Developing Ecological Soil Screening Levels. Office of Solid Waste
and Emergency Response. OSWER Directive 9285.7-55. November 2003, Revised
February 2005. http://www.epa.gov/ecotox/ecossl/index.htmL; Last updated October 20,
2010.

EPA. 2005b. Ecological Soil Screening Level For Antimony, Interim Final. OSWER Directive
9285.7-61. February 2005.

EPA. 2005c. Ecological Soil Screening Level For Arsenic, Interim Final. OSWER Directive
9285.7-62 March 2005.

EPA. 2005d. Ecological Soil Screening Level For Barium, Interim Final. OSWER Directive
9285.7-63 February 2005.

EPA. 2005e. Ecological Soil Screening Level For Beryllium, Interim Final. OSWER Directive
9285.7-64. February 2005.

EPA. 2005f. Ecological Soil Screening Level For Cobalt, Interim Final. OSWER Directive
9285.7-67. March 2005.

EPA. 2005g. Ecological Soil Screening Level For Lead, Interim Final. OSWER Directive
9285.7-70 March 2005.

EPA. 2005h. Ecological Soil Screening Level For Vanadium, Interim Final. OSWER Directive
9285.7-75 April 2005.

EPA. 2006. Ecological Soil Screening Level For Silver, Interim Final. OSWER Directive
9285.7-77 September 2006.

EPA. 2007a. Ecological Soil Screening Level For Copper, Interim Final. OSWER Directive
9285.7-68. February 2007.

EPA. 2007b. Ecological Soil Screening Level For Manganese, Interim Final. OSWER Directive
9285.7-71 April 2007.

EPA. 2007c. Ecological Soil Screening Level For Nickel, Interim Final. OSWER Directive
9285.7-76. March 2007.

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

EPA. 2007d. Ecological Soil Screening Level For Selenium, Interim Final. OSWER Directive
9285.7-72 July 2007.

EPA. 2007e. Ecological Soil Screening Level For Zinc, Interim Final. OSWER Directive
9285.7-73. June 2007.

EPA, 2007f. Background Soil Concentration Database, EcoSSL Attachment 1-4, Guidance for
Developing Ecological Soil Screening Levels (Eco-SSLs), Review of Background
Concentrations for Metals, OSWER Directive 92857-55, Revised July 2007.
https://www.epa.gov/sites/production/files/2015-09/documents/ecossl attachment 1-
4.pdf.

EPA. 2008a. Technical Report on Technologically Enhanced Naturally Occurring Radioactive
Materials from Uranium Mining Volume 1: Mining and Reclamation Background, U.S.
Environmental Protection Agency Office of Radiation and Indoor Air Radiation
Protection Division. Previously published on-line and printed as Vol. 1 of EPA 402-R-
05-007, January 2006; Updated June 2007 and printed April 2008 as EPA 402-R-08-005
April.

EPA. 2008b. Ecological Soil Screening Level For Chromium, Interim Final. OSWER Directive
9285.7-66 April 2008.

EPA. 2011. Exposure Factors Handbook: 2011 Edition. EPA/600/R-09/052F. September 2011.

EPA, 2016. ProUCL, Version 5.1.00. Statistical Software for Environmental Applications for
Data Sets with and without Nondetect Observations. EPA/600/R-07/041. May 2016.
Available on line at: https://www.epa.gov/land-research/proucl-software

EPA. 2019a. Regional Screening Level Table and User's Guide (November 2019). Final. Oak
Ridge National Laboratory, https://www.epa.gov/risk/regional-screening-levels-rsls-
generic-tables

EPA. 2019b. Preliminary Remediation Goals for Radionuclides, PRG Calculator and User's
Guide, https://epa-prgs.ornl.gov/radionuclides/. Accessed November 2019.

Weston Solutions, Inc. (WESTON). 2012. Removal Assessment Report for Homestake Mining
Company, Grants, Cibola County, New Mexico. Prepared for USEPA. May 2012.

WESTON. 2019. Removal Site Evaluation Report for Tronox Navajo Area Uranium Mines,
Section 10 Mine, McKinley County, New Mexico. Prepared for EPA. September 2019.

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Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Appendix I List of Tables

Table 1-1 Summary of Radionuclide Risk Estimates for Section 10 Mine Soil
Table 1-2 Summary of Non-Radionuclide Analytical Results for Section 10 Mine Soil

Table 1-3 Summary of Non-Radionuclide Noncancer Hazard Index and Risks for Section 10
Mine Soil

Table 1-4 Screening Level Ecological Risk Characterization For Section 10 Mine Surface
Soil - Radionuclides

Table 1-5 Screening Level Ecological Risk Characterization For Section 10 Mine Surface
Soil - Metals

Table 1-6 Refined Ecological Risk Characterization For Section 10 Mine Soil

Table 1-7 Comparison of Plant Tissue Concentrations to Maximum Tolerable Limits for
Animals and Normal/Toxic Limits for Plants

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Appendix I Table I-1

Summary of Radionuclide Risk Estimates for Section 10 Mine Site Soils
Streamlined HHRA



Surface Soil

Subsurface Soil



95UCL Radium-226 EPC

95UCL Radium-226 EPC









Secular

Secular



Cancer Risk3

Secular

Secular



Equilibrium

Equilibrium





Equilibrium Risk

Equilibrium

Uranium

Risk for U-

Risk for U-

Uranium



for U-235*

Risk for U-238*

TOTAL

235"

238*

TOTAL

Section 10 (pCi/g)

4.55

101.1

105.6

0.156

3.46

3.61

Rancher - Soil Outdoors













Ingestion

1.56E-06

1.59E-04

1.61E-04

5.50E-08

5.45E-06

5.51E-06

Inhalation

6.95E-09

7.11E-08

7.81E-08

2.44E-10

2.43E-09

2.67E-09

External Exposure

6.06E-06

4.90E-04

4.96E-04

2.13E-07

1.68E-05

1.70E-05

Subtotal

7.63E-06

6.49E-04

6.57E-04

2.68E-07

2.23E-05

2.25E-05

Rancher - Soil Inside Truck













External Exposure

2.42E-06

1.96E-04

1.98E-04

8.52E-08

6.71E-06

6.80E-06

Subtotal

2.42E-06

1.96E-04

1.98E-04

8.52E-08

6.71E-06

6.80E-06

Rancher - Beef Consumption













Beef Consumption

2.09E-04

4.65E-03

4.86E-03

7.35E-06

1.59E-04

1.66E-04

TOTAL

2.19E-04

5.50E-03

6E-03

7.70E-06

1.88E-04

2E-04

Notes:

aCancer risk calculated using the U.S. EPA's on-line PRG Calculator (https://epa-prgs.ornl.gov/cgi-
bin/radionuclides/rprg_search). Output provided in Attachment 1. Concentrations also include
background contribution (1.3 pCi/g Ra-226).

*	assumes in secular equilibrium with radium-226 (no decay)

#	istope in U-235 decay chain; assume all isotopes in secular equilibrium (no decay); concentration
based 0.008163 times radium-226 concentration, where U-235 activity is approximately 2% of natural
uranium ((Human Health Fact Sheet, August 2005; Argonne Nat'l Laboratory; U-238, U-234, U-235)
and assuming secular equilibrium and solving for U-235 (i.e., 0.02 x [U-238 + U-234 + U-235]= U-235).
U total is simply referring to the concentrations of just U-235 in secular equilibrium plus U-238 in
secular equilibrium (which includes U-234 in decay chain, whose concentration is typically included
under the 'ordinary' definition of U total).

HHRA	human health risk assessment

pCi/g	picocuries per gram

PRG preliminary remediation goal

UCL	upper confidence limit

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Appendix I Table 1-2

Summary of Non-Radionuclide Analytical Results for Section 10 Mine Site Soils
Streamlined HHRA

Chemical name

Number
detected A

Number
analyzedA

Minimum
concentration

Maximum
concentration

Sample ID for maximum

EPA Residential
November 2019
Residential Regional
Screening Level3

NMED June 2019
Residential Soil
Screening Levelb

Mean
Backgroundc

COPC?

Non-Radionuclides





Aluminum

8

8

6,000

22,000

10-08-31 -181031 -M

7,700

7,800

54,423

No; ASL; BBC#

Antimony

0

8

ND

ND

—

3.1

3.1

1.0

ND

Arsenic

2

8

5.5

20

10-06-31 -181031 -M

0.68

0.71

5.9

Yes; ASL; ABC

Barium

8

8

73

210

10-06-31 -181031 -M

1,500

1,556

727

No

BSL

Beryllium

8

8

0.38

1

10-08-31 -181031 -M

16

16

1.0

No

BSL

Cadmium

1

8

0.18

0.18

10-01-31-161101-M

7.1

7.1

NA

No

BSL

Calcium

8

8

3,300

17,000

10-01-31-161101-M

-

1.30E+07 (NUT)

35,809

No

BSL

Chromium

7

8

2.5

13

10-08-31 -181031 -M

12,000

9.7

55.5

No

BSL

Cobalt

8

8

1.8

6.1

10-08-31 -181031 -M

2.3

2.3

8.8

No; ASL; BBC#

Copper

7

8

3

19

10-01-31-161101-M

310

313

21

No; BSL

Iron

8

8

10,000

19,000

10-08-31-181031-M

5,500

5,475

20,898

No; ASL; BBC#

Lead

8

8

5.40

14

10-03-31 -181031 -M

400

400

18.1

No; BSL

Magnesium

8

8

1,700

5,300

10-08-31-181031-M

-

3.39E+05 (NUT)

7400 d

No; BSL

Manganese

8

8

140

260

10-05-31-181031 -M*

180

1055

366.8

No; ASL; BBC#

Mercury$

7

8

0.014

0.12

10-06-31 -181031 -M

11

2.3

0.046 d

No

BSL

Nickel

8

8

1.6

11

10-08-31 -181031 -M

150

156

27.9

No

BSL

Potassium

8

8

880

5,800

10-08-31 -181031 -M

--

1.56E+07 (NUT)

18000 d

No

BSL

Silver

0

8

ND

ND

—

39

39

NA

ND

Sodium

8

8

47

560

10-05-31 -181031 -M*

--

7.82E+06 (NUT)

9700 d

No; BSL

Thallium

0

8

ND

ND

...

0.078

0.078

9.1 d

ND

Selenium

4

8

15

87

10-05-31-181031 -M*

39

39

0.29

Yes

ASL

ABC

Uranium

4

8

6.2

310

10-06-31 -181031 -M

16

23

2.5 d

Yes

ASL

ABC

Vanadium

8

8

14

250

10-06-31 -181031 -M

39

39

71.4

Yes

ASL

ABC

Zinc

8

8

17

53

10-08-31 -181031 -M

2,300

2346

44.3

No; BSL

All concentrations in mg/kg (ppm)

ASL - Above screening level

ABC - Above background concentration

BSL - Below screening level

BBC - Below background concentration

CO PC - chemical of potential concern

NUT - essential nutrient; resident value from NMED, 2019

a EPA Rresidential Regional Screening Level based on target risk of 10"6 and target hazard quotient of 0.1.

b NMED residential generic soil screening level based on target risk of 10"5 and target hazard quotient of 1, adjusted by a factor of 10 to account for additive risk.

c Average concentration, New Mexico, Background Soil Concentration Database, EcoSSL Attachment 1-4, Guidance for Developing Ecological Soil Screening Levels (Eco-SSLs), Review of Background Concentrations for Metals,
OSWER Directive 92857-55, Revised July 2007. https://www.epa.gov/sites/production/files/2015-09/documents/ecossl_attachment_1-4.pdf. Average for cadmium is value for "not specified".

d Mean for Western US (Shacklette, H.T. and J.G. Boemren. 1984. Element Concentrations in Soil and Other Surface Materials of the Counterminous United States. USGS Professional Paper 1270)

$ lowest value for elemental mercury and mercury salts

# maximum concentration is less than 2 times the mean background

A includes field duplicates, maximum value taken from duplicate and normal sample

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No. 0001/17-044


-------
Appendix I Table 1-3

Summary of Non-Radionuclide Noncancer Hazard Index and Risks for Section 10 Mine Soils
Streamlined HHRA

Non-radionuclide COPC

EPC*
(mg/kg)

Ranching - Outside
HQ

Site-
Raised
Beef HQ

Hazard Index

Arsenic

20

0.04

0.041

0.08

Selenium

87

0.01

0.065

0.08

Uranium

310

1.3

0.058

1.4

Vanadium

250

0.04

0.022

0.06

Hazard Index



1.4

0.2

1.6



Non-radionuclide COPC

EPC*
(mg/kg)

Ranching - Outside
Cancer Risk

Site-
Raised
Beef Risk

Carcinogenic Risk

Arsenic

20

6.7E-06

6.5E-06

1E-05

*EPC = Exposure point concentration set at maximum because arsenic, selenium, and uranium had 50% or less detections; vanadium had a
small sample size (n=8)

COPC chemical of potential concern

HHRA human health risk assessment

HQ hazard quotient

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No. 0001/17-044


-------
Appendix I Table 1-4

Screening Level Ecological Risk Characterization For Section 10 Mine Surface Soil - Radionuclides

COPEC



Range of Detected
Concentrations*

Location of
Maximum
Concentration

Background*'15

Plant

Soil invertebrates

Avian herbivore

Avian ground
insectivore

Avian carnivore

Mammalian herbivore

Mammalian ground
insectivore

Mammalian
carnivore

Frequency
of

Detection"

Minimum

(mg/kg)

Maximum
(mg/kg)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

EcoSSLd

HQ (max)

Surface Soil (0-6 in bgs)

Uranium 238 Decay Chain Isotopes



U-238**





125.2





400

0.3

1100

0.1

3300

0.0

4000

0.0

4200

0.0

2000

0.1

2100

0.1

2100

0.1

Th-234**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-234m**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-234**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



U-234**





125.2





440

0.3

2200

0.1

14000

0.0

69000

0.0

260000

0.0

36000

0.0

140000

0.0

110000

0.0

Th-230**





125.2





200

0.6

52

2

1200

0.1

2200

0.0

17000

0.0

9900

0.0

81000

0.0

68000

0.0

Radium 226 (pCi/g)*

10/10

0.924

125.2

10-09-31-170202

1.9

54

2

1.5

100

34

4

8.2

20

61

2

340

0.4

510

0.2

370

0.3

Rn-222**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-218**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-214**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



At-218**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-214**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Rn-218**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-214**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



TI-210**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-210**





125.2





3400

0.0

1200

0.1

6000

0.0

6200

0.0

8500

0.0

4400

0.0

4500

0.0

4400

0.0

Bi-210**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-210**





125.2





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Uranium 235 Decay Chain Isotopes

Uranium-23581





5.6



0.086

440

0.0

1600

0.0

6300

0.0

9500

0.0

10000

0.0

4700

0.0

5200

0.0

5200

0.0

Th-231





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-231





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Ac-227





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Th-227





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Fr-223





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Ra-223





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



At-219





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Rn-219





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-215





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-215





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-211





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-211





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



TI-207





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-211





5.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Subsurface Soil (12-18 in bgs)

Uranium 238 Decay Chain Isotopes



U-238**





4.6





400

0.0

1100

0.0

3300

0.0

4000

0.0

4200

0.0

2000

0.0

2100

0.0

2100

0.0

Th-234**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-234m**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-234**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



U-234**





4.6





440

0.0

2200

0.0

14000

0.0

69000

0.0

260000

0.0

36000

0.0

140000

0.0

110000

0.0

Th-230**





4.6





200

0.0

52

0.1

1200

0.0

2200

0.0

17000

0.0

9900

0.0

81000

0.0

68000

0.0

Radium 226 (pCi/g)*

11/11

1.9

4.6

10-03-2-31-161112

1.9

54

0.1

1.5

0.0

34

0.1

8.2

0.0

61

0.1

340

0.0

510

0.0

370

0.0

Rn-222**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-218**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-214**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



At-218**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-214**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Rn-218**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-214**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



TI-210**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-210**





4.6





3400

0.0

1200

0.0

6000

0.0

6200

0.0

8500

0.0

4400

0.0

4500

0.0

4400

0.0

Bi-210**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-210**





4.6





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Uranium 235 Decay Chain Isotopes

Uranium-23581





0.21



0.086

440

0.0

1600

0.0

6300

0.0

9500

0.0

10000

0.0

4700

0.0

5200

0.0

5200

0.0

Th-231





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pa-231





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Ac-227





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Th-227





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Fr-223





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Ra-223





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



At-219





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Rn-219





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-215





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-215





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Pb-211





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bi-211





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



TI-207





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Po-211





0.21





NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Bold values indicate concentrations that exceed ecological screening level or background; bold and shading indicates HQ exceeds unity (based on one significant figure).

#	includes duplicate sample

*	dataset includes minimum/maximimum of MCA and offsite laboratory results
COPEC = chemical of potential environmental concern

HQ = Hazard quotient = maximum concentration / screening level
max= maximum concentration
NSL - no screening level

a Background threshold value for radium-226 as reported in the East GSA Removal Site Evaluation Report (Weston, September 2019).

d LANL ESL Version 4.1; values for avian herbivore (American robin), avian insectivore (American robin), and avian intermediate carnivore (Amercian kestrel); mammalian herbivore (desert cottontail); mammalian insectivore (montane shrew) and mammalian top carnivore (red fox).

** isotope in U-238 decay chain; assumes in secular equilibrium with radium-226

& isotope in U-235 decay chain; assume all isotopes in secular equilibrium; concentration based 0.045 times radium-226 concentration, where U-235 activity is approximately 2.2% of natural uranium (U-238, U-234, U-235) and assuming secular equilibrium and solving for U-235 (i.e., 0.022 x [U-238 + U-234
+ U-235]= U-235) U total is simply referring to the concentrations of just U-235 in secular equilibrium plus U-238 in secular equilibrium (which includes U-234 in decay chain, whose concentration is typically included under the 'ordinary' definition of U total).

Section 10 Mine EE/CA Report - Appendix I	1 Of 1	TDD No. 0001/17-044


-------
Appendix I Table 1-5

Screening Level Ecological Risk Characterization For West Geographic Sub Area (GSA) Section 10 Mine Surface Soil - Metals

COPEC

Frequency
of

Detection*1

Range of Detected
Concentrations*

Location of Maximum
Concentration

Background3

Plant

Soil invertebrates

Avian herbivore

Avian ground
insectivore

Omnivore (Horned
Lark)

Avian carnivore

Top Carnivore (Red-tailed
hawk; 177 acres)

Mammalian herbivore

Mammalian ground
insectivore

Omniovore (Deer
mouse)

Mammalian
carnivore

Carnivore (Kit fox;
267 acres)

Herbivore (Longhorn
antelope; 342 acres)

Minimum
(mg/kg)

Maximum
(mg/kg)

EcoSSL0

HQ (max)

Tier 1
ESLd

HQ (max)

EcoSSL0

HQ (max)

EcoSSL0

HQ (max)

EcoSSL0

HQ (max)

Tier 1
ESLd

HQ (max)

EcoSSL0

HQ (max)

NMED Tier 1
ESLd

HQ (max)

EcoSSL0

HQ (max)

EcoSSL0

HQ (max)

Tier 1
ESLd

HQ (max)

EcoSSL0

HQ (max)

Tier 1
ESLd

HQ (max)

NMED Tier 1
ESLd

HQ (max)

Non-Radionuclides

Aluminum*

8/8

6,000

22,000

10-08-31-181031-M

54,423

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

520

42

NSL

-

4000

5.5

NSL

-

NSL

-

564

39

NSL

-

2500

8.8

NSL

-

Antimony®

0/8

ND

ND

—

1.0

11

-

11.4

-

78

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

10

-

0.27

-

0.536

-

4.9

-

2.380

-

NSL

-

Arsenic

2/8

5.5

20.0

10-06-31-181031-M

5.9

18

1.1

18

1.1

NSL

-

67

0.3

43

0.5

10.6

1.9

1100

0.02

81.5

0.2

170

0.1

46

0.4

9.5

2.1

170

0.1

42.0

0.5

36.1

0.6

Barium

8/8

73

210

10-06-31-181031-M

727

NSL

-

118

1.8

330

0.6

NSL

-

NSL

-

348

0.6

NSL

-

2680

0.1

3200

0.1

200

1.1

471

0.4

9100

0.02

2090

0.1

NSL

-

Beryllium

8/8

0.38

1.00

10-08-31-181031-M

1.0

NSL

-

2.5

0.4

40

0.03

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

21

0.05

34

0.03

4.8

0.2

90

0.01

21.5

0.05

NSL

-

Cadmium

1/8

0.18

0.18

10-01-31-161101-M

NA

32

0.006

32

0.006

140

0.001

28

0.006

0.77

0.2

7.0

0.03

630

0.0003

53.5

0.003

73

0.002

0.36

0.5

7.0

0.03

84

0.002

31.1

0.006

NSL

-

Calcium

8/8

3,300

17,000

10-01-31-161101-M

35,809

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

Chromium

7/8

2.5

13

10-08-31-181031-M

55.5

NSL

-

NSL

-

NSL

-

78

0.2

26

0.5

12.6

1.0

780

0.02

96.8

0.1

380

0.03

34

0.4

21.8

0.6

180

0.07

97.0

0.1

NSL

-

Cobalt

8/8

1.8

6.1

10-08-31-181031-M

8.8

13

0.5

13

0.5

NSL

-

270

0.02

120

0.05

36.0

0.2

1300

0.005

277

0.02

2100

0.003

230

0.03

66.6

0.09

470

0.01

296

0.02

58

0.1

Copper

7/8

3

19

10-01-31-161101-M

21

70

0.3

70

0.3

80

0.2

76

0.3

28

0.7

19.2

1.0

1600

0.01

147

0.1

1100

0.02

49

0.4

50.9

0.4

560

0.03

226

0.08

NSL

-

Iron

8/8

10,000

19,000

10-08-31-181031-M

20,898

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

NSL

-

Lead

8/8

5.4

14

10-03-31-181031-M

18.1

120

0.1

120

0.1

1700

0.01

46

0.3

11

1.3

7.7

1.8

510

0.03

59.3

0.2

1200

0.01

56

0.3

42.7

0.3

460

0.03

190

0.07

173

0.08

Magnesium

8/8

1,700

5,300

10-08-31-181031-M

7,400 b

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

Manganese

8/8

140

260

10-05-31-181031-M*

367

220

1.2

220

1.2

450

0.6

4300

0.1

4300

0.1

847

0.3

65000

0.004

6520

0.04

5300

0.05

4000

0.07

468

0.6

6200

0.04

2080

0.1

5770

0.05

Mercury

7/8

0.014

0.12

10-06-31-181031-M

0.046 b

34

0.004

34.9

0.003

0.05

2.4

0.067

1.8

0.013

9.2

0.1

1.3

0.058

2.1

0.692

0.2

23

0.005

1.7

0.07

12.8

0.009

76

0.002

57.0

0.002

NSL

-

Nickel

8/8

1.6

11

10-08-31-181031-M

27.9

38

0.3

38

0.3

280

0.04

210

0.05

NSL

-

31.7

0.3

2800

0.004

244

0.05

340

0.03

NSL

-

15.5

0.7

130

0.08

68.7

0.2

289

0.04

Potassium

8/8

880

5,800

10-08-31-181031-M

18,000 b

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

Silver

0/8

ND

ND

—

NA

560

-

560

-

NSL

-

69

-

4.2

-

10.4

-

930

-

73.5

-

1500

-

14

-

54.7

-

990

-

243

-

2.9

-

Sodium

8/8

47

560

10-05-31-181031-M*

9,700 b

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

NUT

-

Thallium®

0/8

ND

ND

...

9.1 b

0.05

-

0.05

-

NSL

-

6.9

-

4.5

-

1.66

-

48

-

12.7

-

1.2

-

0.42

-

0.065

-

5

-

0.29

-

NSL

-

Selenium

4/8

15

87

10-05-31-181031-M*

0.29

0.52

167

0.52

167

4.1

21

2.2

40

1.2

73

1.37

64

83

1.0

10.6

8.2

2.7

32

0.63

138

1.3

67

2.8

31

5.78

15

NSL

-

Uranium

4/8

6.2

310

10-06-31-181031-M

2.5 b

76

4

NSL

-

NSL

-

1500

0.2

1100

0.3

NSL

-

14000

0.02

NSL

-

1000

0.3

480

0.6

NSL

-

4800

0.1

NSL

-

NSL

-

Vanadium

8/8

14

250

10-06-31-181031-M

71.4

NSL

-

60

4.2

NSL

-

13

19

7.8

32

1.6

153

140

1.8

12.5

20

1300

0.2

280

0.9

37.8

6.6

580

0.4

168.0

1.5

289

0.9

Zinc

8/8

17

53

10-08-31-181031-M

44.3

160

0.3

160

0.3

120

0.4

950

0.06

46

1.2

313

0.2

30000

0.002

2410

0.02

6800

0.008

79

0.7

685

0.08

10000

0.005

3050

0.02

2890

0.02

Bold values indicate concentrations that exceed ecological screening level; bold and shading indicates HQ exceeds unity (based on one significant figure). Thick border around HQ>1 indicates maximum concentration also exceeds background.

CO PEC = chemical of potential environmental concern

HQ = Hazard quotient = maximum concentration / screening level

max= maximum concentration

NSL - no screening level

a Average concentration, New Mexico, Background Soil Concentration Database, EcoSSL Attachment 1-4, Guidance for Developing Ecological Soil Screening Levels (Eco-SSLs), Review of Background Concentrations for Metals, OSWER Directive 92857-55, Revised July 2007. https://www.epa.gov/sites/production/files/2015-09/documents/ecossl_attachment_1-4.pdf. Average for cadmium is value for
"not specified".

b mean for Western US (Shacklette, H.T. and J.G. Boernren. 1984. Element Concentrations in Soil and Other Surface Materials of the Counterminous United States. USGS Professional Paper 1270)

c EPA Ecological Soil Screening Levels (EcoSSL) http://www.epa.gov/chemical-research/interim-ecological-soil-screening-level-documents Last updated September 29, 2016. $ LANL (2017) ESL Version 4.1; values for avian herbivore (American robin), avian insectivore (American robin), and avian intermediate carnivore (Amercian kestrel); mammalian herbivore (desert cottontail); mammalian
insectivore (montane shrew) and mammalian top carnivore (red fox); ESL for plant for antimony

d NMED (2017). Risk Assessment Guidance for Site Investigations and Remediation. Volume II -Soil Screening Guidance for Ecological Risk Assessments. March 2017. Tier 1 ecological screening level (ESL).

A only analyzed in 2015 samples

#	includes duplicate sample

*	NMED ESLs are pH dependent; aluminum is identified as a COPC only at sites where the soil pH is less than 5.5 (U.S. EPA. Ecological Soil Screening Level for Aluminum, Interim Final. OSWER Directive 9285.7-6. November 2003).

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No. 0001/17-044


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Appendix I Table 1-6

Refined Ecological Risk Characterization For Section 10 Mine Surface Soil

COPEC

Maximum of
Detected
Concentrations
(mg/kg)

Background8'15

Plant

Soil invertebrates

Avian herbivore

Avian ground
insectivore

Avian carnivore

Mammalian
herbivore

Mammalian ground
insectivore

Mammalian
carnivore

Low
Effect
ESLd

Low
Effect HQ

Low Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Low
Effect
ESLd

Low
Effect HQ

Aluminum

22000

54,423

NSL



NSL



NSL



NSL



NSL



NSL



NSL



NSL



Arsenic

20.0

5.9

91

0.2

68

0.3

340

0.1

150

0.1

7400

0.003

27

0.7

31

0.6

1300

0.02

Barium

210.0

727

260

0.8

3200

0.07

1200

0.2

1400

0.2

44000

0.005

14000

0.02

10,000

0.02

190,000

0.001

Lead

14.0

18.1

570

0.02

8400

0.002

36

0.4

23

0.6

160

0.09

600

0.02

170

0.08

7000

0.002

Mercury

0.12

0.046

64

0.002

1

0.2

0.67

0.2

0.13

0.9

0.58

0.2

230

0.001

17

0.01

760

0.0002

Selenium

87

0.29

3

29

41

2.1

1.9

46

1.4

62

7.5

12

3.4

26

1

87

130

0.7

Uranium

310

2.5

250

1.2

NSL



15000

0.02

11000

0.03

140,000

0.002

2600

0.1

1200

0.3

12000

0.03

Vanadium

250

71.4

80

3.1

NSL



13

19

9.5

26

110

2.3

1500

0.2

610

0.4

6900

0.04

Surface Soil

Radium 226 (pCi/g)*

101.1

1.9

540

0.2

15

6.7

340

0.3

82

1.2

610

0.2

3400

0.0

5100

0.0

3700

0.0

Th-230 (pCi/g)**

101.1

1.9

2000

0.1

520

0.0

12000

0.0

22000

0.0

170000

0.0

210000

0.0

1100000

0.0

680000

0.0

Bold values indicate concentrations that exceed ecological screening level; bold and shading indicates HQ exceeds unity (based on one significant figure). Thick border around HQ>1 indicates maximum concentration also exceeds background.

COPEC = chemical of potential environmental concern

HQ = Hazard quotient = maximum concentration / screening level

NSL - no screening level

a Background threshold value for radium-226 as reported in the Section 10 Mine Removal Site Evaluation Report (Weston, September 2019).

b Average concentration, New Mexico, Background Soil Concentration Database, EcoSSL Attachment 1-4, Guidance for Developing Ecological Soil Screening Levels (Eco-
SSLs), Review of Background Concentrations for Metals, OSWER Directive 92857-55, Revised July 2007. https:/Mww.epa.gov/sites/production/files/2015-
09/documents/ecossl_attachment_1-4.pdf.

c mean for Western US (Shacklette, H.T. and J.G. Boernren. 1984. Element Concentrations in Soil and Other Surface Materials of the Counterminous United States. USGS Professional Paper 1270)
d LANL low effect ESL Version 4.1; values for avian herbivore (American robin), avian insectivore (American robin), and avian intermediate carnivore (Amercian kestrel); mammalian herbivore
(desert cottontail); mammalian insectivore (montane shrew) and mammalian top carnivore (red fox)

* 95% upper confidence limit (95UCL) concentration of radium-226
** istope in U-238 decay chain; assumes in secular equilibrium with radium-226

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No 0001/17-044


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Table 1-7

Comparison of Plant Tissue Concentrations to Maximum Tolerable Limits for Animals and Normal/Toxic Limits for Plants
Section 10 Mine

Plant Analysis

Iron

Zinc

Copper

Manganese

Molybdenum

Uranium

Vanadium

Selenium

Sample I.D.

ppm

ppm

ppm

ppm

ppm

ppm

ppm

ppm

WGSA-P11-161101

275.1

23.9

3.5

22.6

1.47

<0.50

<0.04

<0.65

WGSA-P12-161101

157.8

40.4

6.4

8.2

1.98

4.63

<0.04

205.24

Maximum Tolerable Limits (MTL) of Minerals in the Feed (mg/kg dry matter) d







Rodents

500

500

500

2000

7

100 - 400**

NA

5

Poultry

500

500

250

2000

100

NA

25 (<5 laying hens)

3

Swine

3000

1000

250

1000

150

NA

10

4

Horse

500

500

250

400

5*

NA

10

5

Cattle

500

500

40

2000

5*

NA

50

5

Sheep

500

300

15

2000

5*

NA

50

5

Trace Elements in Mature Leaf Tissue*** (ppm dry weight) b











Sufficient/Normal

NA

27-150

5-30

30 - 300

0.2-5

NA

0.2-1.5

0.01 -2

Toxic/Excessive

NA

100-400

20 -100

400- 1000

10-50

NA

5-10

5-30

Bold and shading indicates concentration exceeds lowest MTL for animals and/or is in toxic range for plants.

* toxicosis caused by <25 mg/kg is often associated with inadequate available copper; cattle show overt toxicosis when dietary molybdenum level is at 100 mg/kg or higher
regardless of dietary copper or sulfur levels.

**Maximum tolerable intake for domestic animals is probably between 100 and 400 mg/kg diet.

*** Values are not given for very sensitive or highly tolerant plant species.

a defined as dietary level, that, when fed for a defined period of time, will not impair animal health or performance.

ppm = parts per million = millgrams per kilogram (mg/kg)

References:

a National Research Council (NRC). 2005. Mineral Tolerance of Animal. 2nd Revised Edition. The National Academies Press. Washington, D.C.
b Kabata-Pendias, Alina and Henryk Pendias. 1992. Trace Elements in Soils and Plants. 2nd Edition. CRC Press. Boca Raton, FL.

Section 10 Mine EE/C A Report - Appendix I

1 Of 1

TDD No. 0001/17-044


-------
Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Attachment 1
PRG Calculator Input and Output


-------
Appendix I Attachment 1, Table A.1-1

Site-specific Equation Inputs for Soil Chemicals - Meat Consumption
Section 10 Mine

Intake Equation/Exposure Parameter

Rancher - Adult

Target Hazard Quotient (THQ, unitless)

Target Risk (TR, unitless)

Body Weight (BW, kg)

Exposure Frequency (EF, days/yr) - home grown meat
Exposure Duration (ED, yrs)

Averaging Time (ATnc)- noncarcinogens (yrs)
Averaging Time (ATc)- carcinogens (yrs)

Ingestion Rate (IRC, mg/day) - homegrown meat

Fraction ingested (Fl) - home grown meat

1

1E-06
80 a
350 a
25 a
ED a
70 a
165300 b

0.48 c

Fraction onsite

0.33 d

Meat Intake Factor - noncancer (MIF nc)

5.0E+02

Meat Intake Factor - cancer (MIF c)

1.41E-03

EXPOSURE ALGORITHMS for

SL meat-nc = THQ x AT nc x BW/ (EF x ED x 1/RfD x IR meat x Fl x 10"° kg/mg) = MIF nc
x 1 /RfD

SL meat-c = TR x AT c x BW / (EF x ED x SF x IR meat x Fl x 10"D kg/mg) = (MIF c /(Fl *
SF)

a - Default value (USEPA, 2014)
b - default value for beef (USEPA, 2019)
c- USEPA, 2011.
c- Hurd et al, 2007

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No. 0001/17-044


-------
Appendix I Attachment 1, Table A.1-2

Site-specific Screening Levels and Hazard Index for Soil-to-Meat Consumption
Section 10 Mine







Beef



Screening







Reference

Screening

Transfer



Level Soil to

Soil





Dose (mg/kg-

Level-Meat -

Coefficient

Soil-to-Dry

Meat -

Concentration

Noncancer Hazard

Chemical

day)

noncancer

(d ay/kg )a

Plant Uptake3

noncancer

(mg/kg)

Quotient

Arsenic

3.0E-04

0.31

2.0E-03

4.0E-02

488

20

0.041

Selenium

5.0E-03

5.21

1.5E-02

2.5E-02

1325

87

0.066

Uranium (Soluble Salts)

2.0E-04

0.21

2.0E-04

8.5E-03

5261

310

0.059

Vanadium

5.0E-03

5.21

2.5E-03

5.5E-03

11179

250

0.022



0.2







Beef













Screening

Transfer



Screening

Soil





Slope Factor

Level-Meat -

Coefficient

Soil-to-Dry

Level Soil to

Concentration



Chemical

(mg/kg-day)"1

cancer

(d ay/kg )a

Plant Uptake3

Meat - cancer

(mg/kg)

Cancer Risk

Arsenic

1.5E+00

0.00196

2.0E-03

4.0E-02

3.1

20

7E-06

a ORNL RAIS

SL meat-nc = THQ x AT nc x BW/ (EF x ED x 1/RfD x IR meat x Fl x 10"

6 kg/mg) = (MIFnc / Fl *1/RfD) * 1/ (1/RfD) = 500 / (0.48 x (1/RfD)

SL meat-c =TR x AT c x BW / (EF x ED x SF x IR meat x Fl x 10"6
kg/mg) = MIFc /SFxFI= 1.41E-3 / SF *0.48

SL-res-meat-nc-ing (mg/kg) = SL-meat-nc / {BTF x ([Forage Intake * PUFdry] + Soil intake)}
Hazard quotient (HQ) = Concentration/SL-nc

SL-res-meat-c-ing (mg/kg) = SL-meat-c/ {BTF x ([Forage Intake * PUFdry] + Soil intake)}
Risk = (Concentration/SL-c)*1 E-6

Forage intake = 11.77 kg/day *.33 (fraction onsite) = 3.8841 kg/day
Soil intake = 0.5 kg/day *.33 (fraction onsite) = 0.165 kg/day

Section 10 Mine EE/CA Report - Appendix I	1 Of 1	TDD No. 0001 /17-044


-------
Appendix I Attachment 1, TableA.1-3
Chemical-Specific Parameters
Section 10 Mine



Beef Transfer

Soil-to-

Soil-to-





Coefficient

Dry Plant

Wet Plant



ANALYSIS

(day/kg)

Uptake

Uptake

BTF, BV Dry and BV Wet Reference

Arsenic, Inorganic

0.002

0.04

0.01

Baes, C. F., Ill, Sharp, R. D., Sjoreen, A.
L., and Shor, R. W. 1984. A Review and
Analysis of Parameters for Assessing
Transport

Selenium

0.015

0.025

0.00625

Uranium (Soluble Salts)

0.0002

0.0085

0.002125

Vanadium and Compounds

0.0025

0.0055

0.001375

Source: ORNL RAIS

Section 10 Mine EE/CA Report - Appendix I

1 of 1

TDD No. 0001/17-044


-------
Site-specific

Composite Worker Soil Inputs - Secular Equilibrium





1

Variable

Default
Value

Form-input
Value



A (PEF Dispersion Constant)

16.2302

14.9421



B (PEF Dispersion Constant)

18.7762

17.9869



City (Climate Zone)

Default

Albuquerque, NM (3)



C (PEF Dispersion Constant)

216.108

205.1782

Section 10 Surface Soil

Cover thickness for GSF „ (gamma shielding factor) cm

0 cm

0 cm

F(x) (function dependent on U m/U,) unitless

0.194

0.0553



PEF (particulate emission factor) m 3/kg

1359344438

2573243853.79163



Q/C„_h (g/m2-s per kg/m3)

93.77

31.86507598808449



A (acres)

0.5

250



Site area for ACF (area correction factor) m 2

1000029 m2

1000029 m2



ED„ (exposure duration - composite worker) yr

25

25



EF„ (exposure frequency - composite worker) dayfyr

250

250



ET (exposure time - composite worker) hr/day

8

0.8



IRA, (inhalation rate - composite worker) m 3/day

60

60



IRS, (soil intake rate - composite worker) mg/day

100

100



t„ (time - composite worker) yr

25

25



TR (target cancer risk) unitless

1.0E-06

1.0E-04



U (mean annual wind speed) m/s

4.69

4.02



U, (equivalent threshold value)

11.32

11.32



V (fraction of vegetative cover) unitless

0.5

0.5



Output generated 15DEC2019:16:28:52






-------
Site-specific

Composite Worker PRGs for Soil - Secular Equilibrium

Total
PRG
TR=0.0001

(pCi/g)
5.97E+01
1.56E+01

Output generated 15DEC2019:16:28:52

Isotope

Secular Equilibrium PRG for U-235
Secular Equilibrium PRG for U-238

External

Ingestion	Inhalation	Exposure

PRG	PRG	PRG

TR=0.0001 TR=0.0001	TR=0.0001

(pCi/g)	(pCi/g)	(pCi/g)

2.91E+02	6.55E+04	7.51E+01

6.35E+01	1.42E+05	2.06E+01


-------
Site-specific

Composite Worker Risk for Soil - Secular Equilibrium

Isotope

External

Ingestion Inhalation Exposure
Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

1.56E-06 6.95E-09 6.06E-06

7.63E-06

*Secular Equilibrium Risk for U-238

1.59E-04 7.11E-08 4.90E-04

6.49E-04

*Total Risk

1.61E-04 7.80E-08 4.96E-04

6.57E-04



Output generated 15DEC2019:16:28:52


-------
Site-specific

Indoor Worker Soil Inputs - Secular Equilibrium





1

Variable

Default
Value

Form-input
Value



A (PEF Dispersion Constant)

16.2302

14.9421



B (PEF Dispersion Constant)

18.7762

17.9869



City (Climate Zone)

Default

Albuquerque, NM (3)



C (PEF Dispersion Constant)

216.108

205.1782



Cover thickness for GSF h (gamma shielding factor) cm

0 cm

0 cm

Section 10 Surface Soil

F(x) (function dependent on U m/U,) unitless

0.194

0.0553



PEF (particulate emission factor) m 3/kg

1359344438

6609630249.811598



Q/C„_h (g/m2-s per kg/m3)

93.77

81.84858572694108



A„ (acres)

0.5

0.5



Site area for ACF (area correction factor) m 2

1000029 m2

1000029 m2



ED,,, (exposure duration - indoor worker) yr

25

25



EF.„ (exposure frequency - indoor worker) dayfyr

250

250



ET„ (exposure time - indoor worker) hr/day

8

0.8



GSF; (indoor gamma shielding factor) unitless

0.4

0.7



IRA,, (inhalation rate - indoor worker) m 3/day

60

0



IRS (soil intake rate - indoor worker) mg/day

50

0



t„ (time - indoor worker) yr

25

25



TR (target cancer risk) unitless

1.0E-06

1.0E-04



U (mean annual wind speed) m/s

4.69

4.02



U, (equivalent threshold value)

11.32

11.32



V (fraction of vegetative cover) unitless

0.5

0.5



Output generated 15DEC2019:16:18:45






-------
Site-specific

Indoor Worker PRGs for Soil - Secular Equilibrium

Total
PRG
TR=0.0001

(pCi/g)
1.07E+02
2.95E+01

Output generated 15DEC2019:16:18:45

External

Ingestion	Inhalation	Exposure

PRG	PRG	PRG

TR=0.0001	TR=0.0001	TR=0.0001

Isotope (pCi/g)	(pCi/g)	(pCi/g)

Secular Equilibrium PRG for U-235 -	-	1.07E+02

Secular Equilibrium PRG for U-238 -	-	2.95E+01

2


-------
Site-specific

Indoor Worker Risk for Soil - Secular Equilibrium

Isotope

External

Ingestion Inhalation Exposure
Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 4.24E-06

4.24E-06

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 3.43E-04

3.43E-04

*Total Risk

0.00E+00 0.00E+00 3.47E-04

3.47E-04



Output generated 15DEC2019:16:18:45


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

1

Variable

A (PEF Dispersion Constant)

B (PEF Dispersion Constant)

City (Climate Zone)

C (PEF Dispersion Constant)

Cover thickness for GSF „ (gamma shielding factor) cm
Cover thickness for GSF h (gamma shielding factor) cm

CFfo		 (contaminated plant fraction) unitless

CF,ok ^ (contaminated apple fraction) unitless
CFfc„m,„_ (contaminated asparagus fraction) unitless
CFfoKhMf (beef contaminated fraction) unitless
CF^_ (contaminated berry fraction) unitless

CF,,,		 (contaminated broccoli fraction) unitless

CFfoK hM, (contaminated beet fraction) unitless
CFfomhh_ (contaminated cabbage fraction) unitless
CFf_raolmi„ (contaminated cereal grain fraction) unitless
CFfo_i(Kiic (contaminated citrus fraction) unitless
CFf_ (contaminated corn fraction) unitless
CF,__, (contaminated carrot fraction) unitless
CFfoK „,„imh=K (contaminated cucumber fraction) unitless
CFfoKHoi„, (dairy contaminated fraction) unitless
CFf_ (egg contaminated fraction) unitless
CF^ (fish contaminated fraction) unitless
CFfoK„m(milk (goat milk contaminated fraction) unitless
CF,_m(i_( (goat meat contaminated fraction) unitless
CFfcrJilli„ (contaminated lettuce fraction) unitless
CFfc,Jim,_ (contaminated lima bean fraction) unitless
CFfoK„kra (contaminated okra fraction) unitless
CFfoK„ni„„ (contaminated onion fraction) unitless
CF,__lw (poultry contaminated fraction unitless)

CFt	(contaminated peach fraction) unitless

CFfc,„M (contaminated pea fraction) unitless
CFfc,„M, (contaminated pear fraction) unitless

CF	(contaminated potato fraction) unitless

CF, (contaminated pumpkin fraction) unitless

far-pumpkin v	r r	/

Default

Form-input

Value

Value

16.2302

14.9421

18.7762

17.9869

Default

Albuquerque, NM (3)

216.108

205.1782

0 cm

0 cm

0 cm

0 cm

Section 10 Surface Soil

i.48

Output generated 15DEC2019:16:13:00


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

2



Default

Form-input

Variable

Value

Value

CFfc„.„ (contaminated rice fraction) unitless

1

1

CFfc„_ (sheep contaminated fraction) unitless

1

1

CFfc„_mill, (sheep milk contaminated fraction) unitless

1

1

CF^,(contaminated snap bean fraction) unitless

1

1

CF^,(contaminated strawberry fraction) unitless

1

1

CFf_iin= (swine contaminated fraction) unitless

1

1

CF,okJ_,„ (contaminated tomato fraction) unitless

1

1

ED,ok (exposure duration - farmer) yr

40

25

ED,ok o (exposure duration - farmer adult) yr

34

25

EDfo_ (exposure duration - farmer child) yr

6

0

EFfc„ (exposure frequency - farmer adult) day/yr

350

350

EFfc„ (exposure frequency - farmer child) day/yr

350

0

IFAP,ok oHi (age-adjusted apple ingestion factor) g

1182020

741125

IFASfoK oHi (age-adjusted asparagus ingestion factor) g

492870

343874.99999999994

IFB,ok oHi (age-adjusted beef ingestion factor) g

2098950

1446375

IFBEfoK oHi (age-adjusted berry ingestion factor) g

471450

309750

IFBR,ok oHi (age-adjusted broccoli ingestion factor) g

450310

308874.99999999994

IFBT,ok oHi (age-adjusted beet ingestion factor) g

411600

296625

IFCB,ok oHi (age-adjusted cabbage ingestion factor) g

1043980

749875

IFCG,ok oHi (age-adjusted cereal grain ingestion factor) g

1190210

1190210

IFCIfoK oHi (age-adjusted citrus ingestion factor) g

4090100

2707249.9999999995

IFCO,ok oHi (age-adjusted corn ingestion factor) g

1044470

717500

IFCR,ok oHi (age-adjusted carrot ingestion factor) g

318290

213500

IFCUfoK oHi (age-adjusted cucumber ingestion factor) g

688800

480375

IFD,ok oHi (age-adjusted dairy ingestion factor) g

10138030

5918500

IFEfoK oHi (age-adjusted egg ingestion factor) g

775810

521500

IFFIfoK oHi (age-adjusted fish ingestion factor) g

10018960

7278250

IFLEfoKoHi (age-adjusted lettuce ingestion factor) g

455070

328125

IFLIfoK oHi (age-adjusted lima bean ingestion factor) g

415870

295749.99999999994

IFOK,ok oHi (age-adjusted okra ingestion factor) g

370510

264250

IFONfoK oHi (age-adjusted onion ingestion factor) g

338800

238000

IFP,ok oHi (age-adjusted poultry ingestion factor) g

1376550

939750

IFPC,ok oHi (age-adjusted peach ingestion factor) g

1435420

902125

IFPEfar adj (age-adjusted pea ingestion factor) g

437500

277375

Output generated 15DEC2019:16:13:00


-------
Site-specific





3

Farmer Soil Inputs - Secular Equilibrium







Default

Form-input



Variable

Value

Value



IFPR„K ,Hi (age-adjusted pear ingestion factor) g

874300

524125



IFPT,_Hi (age-adjusted potato ingestion factor) g

1807750

1240750.0000000002



IFPUfoK oHi (age-adjusted pumpkin ingestion factor) g

866040

567000



IFRIfoK oHi (age-adjusted rice ingestion factor) g

1126230

774375



IFSNfoK oHi (age-adjusted snap bean ingestion factor) g

702730

474250



IFST,ok oHi (age-adjusted strawberry ingestion factor) g

535080

354375



IFSWfoK oHi (age-adjusted swine ingestion factor) g

1171520

809375



IFTOfoK oHi (age-adjusted tomato ingestion factor) g

1194270

824250



IRAP,_ (apple ingestion rate - farmer adult) g/day

84.7

84.7



IRAPfo_ (apple ingestion rate - farmer child) g/day

82.9

82.9



IRAS,ok o (asparagus ingestion rate - farmer adult) g/day

39.3

39.3



IRASfo_ (asparagus ingestion rate - farmer child) g/day

12.0

12.0



IRB,ok o (beef ingestion rate - farmer adult) g/day

165.3

165.3



IRBfo_ (beef ingestion rate - farmer child) g/day

62.8

0



IRBE,ok o (berry ingestion rate - farmer adult) g/day

35.4

35.4



IRBEfo_ (berry ingestion rate - farmer child) g/day

23.9

23.9



IRBR,ok o (broccoli ingestion rate - farmer adult) g/day

35.3

35.3



IRBRfo_ (broccoli ingestion rate - farmer child) g/day

14.4

14.4



IRBT,ok o (beet ingestion rate - farmer adult) g/day

33.9

33.9



IRBT,_ (beet ingestion rate - farmer child) g/day

3.9

3.9



IRCB,ok o (cabbage ingestion rate - farmer adult) g/day

85.7

85.7



IRCBfo_ (cabbage ingestion rate - farmer child) g/day

11.5

11.5



IRCG,ok o (cereal grain ingestion rate - farmer adult) g/day

91.9

91.9



IRCGfo_ (cereal grain ingestion rate - farmer child) g/day

46.0

46.0



IRCI,ok o (citrus ingestion rate - farmer adult) g/day

309.4

309.4



IRCIfo_ (citrus ingestion rate - farmer child) g/day

194.4

194.4



IRCO,ok o (corn ingestion rate - farmer adult) g/day

82.0

82.0



IRCOfo_ (corn ingestion rate - farmer child) g/day

32.7

32.7



IRCR,_ (carrot ingestion rate - farmer adult) g/day

24.4

24.4



IRCRfo_ (carrot ingestion rate - farmer child) g/day

13.3

13.3



IRCU,ok o (cucumber ingestion rate - farmer adult) g/day

54.9

54.9



IRCUfo_ (cucumber ingestion rate - farmer child) g/day

16.9

16.9



IRDfoK, (dairy ingestion rate - farmer adult) g/day

676.4

676.4



IRDfar c (dairy ingestion rate - farmer child) g/day

994.7

994.7



Output generated 15DEC2019:16:13:00






-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

4

Default	Form-input

Variable	Value	Value

IRE,ok o (egg ingestion rate - farmer adult) g/day	59.6	59.6

IREfo_ (egg ingestion rate - farmer child) g/day	31.7	31.7

IRFIfc„ (fish ingestion rate - farmer adult) g/day	831.8	831.8

IRFIfc„ (fish ingestion rate - farmer child) g/day	57.4	57.4

IRLE,ok o (lettuce ingestion rate - farmer adult) g/day	37.5	37.5

IRLEfo_ (lettuce ingestion rate - farmer child) g/day	4.2	4.2

IRLIf„, (lima bean ingestion rate - farmer adult) g/day	33.8	33.8

IRLIf,_ (lima bean ingestion rate - farmer child) g/day	6.5	6.5

IROK,ok o (okra ingestion rate - farmer adult) g/day	30.2	30.2

IROKfo_ (okra ingestion rate - farmer child) g/day	5.3	5.3

IRON,oko (onion ingestion rate-farmer adult) g/day	27.2	27.2

IRONfo_ (onion ingestion rate - farmer child) g/day	7.2	7.2

IRPfc„ (poultry ingestion rate - farmer adult) g/day	107.4	107.4

IRPfc„ (poultry ingestion rate - farmer child) g/day	46.9	46.9

IRPCfc„ (peach ingestion rate - farmer adult) g/day	103.1	103.1

IRPCfc„ (peach ingestion rate - farmer child) g/day	99.3	99.3

IRPEfc„ (pea ingestion rate - farmer adult) g/day	31.7	31.7

IRPEfc„ (pea ingestion rate - farmer child) g/day	28.7	28.7

IRPRfc„ (pear ingestion rate - farmer adult) g/day	59.9	59.9

IRPRfc„ (pear ingestion rate - farmer child) g/day	76.9	76.9

IRPTfc„ (potato ingestion rate - farmer adult) g/day	141.8	141.8

IRPTfc„ (potato ingestion rate - farmer child) g/day	57.3	57.3

IRPUfc„ (pumpkin ingestion rate -farmer adult) g/day	64.8	64.8

IRPUfc„ (pumpkin ingestion rate - farmer child) g/day	45.2	45.2

IRRL, (rice ingestion rate - farmer adult) g/day	88.5	88.5

IRRIfc„ (rice ingestion rate - farmer child) g/day	34.8	34.8

IRSNfc„ (snap bean ingestion rate - farmer adult) g/day	54.2	54.2

IRSNfc„ (snap bean ingestion rate - farmer child) g/day	27.5	27.5

IRSTfc„ (strawberry ingestion rate -farmer adult) g/day	40.5	40.5

IRSTfc„ (strawberry ingestion rate -farmer child) g/day	25.3	25.3

IRSWfc„ (swine ingestion rate - farmer adult) g/day	92.5	92.5

IRSWfc„ (swine ingestion rate - farmer child) g/day	33.7	33.7

IRTOfc„ (tomato ingestion rate - farmer adult) g/day	94.2	94.2

IRTOfarc (tomato ingestion rate-farmer child) g/day	34.9	34.9

Output generated 15DEC2019:16:13:00


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

5

Variable

MLFoml= (apple mass loading factor) unitless

MLF	(asparagus mass loading factor) unitless

MLFh=m, (berry mass loading factor) unitless
MLFhK_N (broccoli mass loading factor) unitless
MLFhM, (beet mass loading factor) unitless
MLF„hh_ (cabbage mass loading factor) unitless
MLF„„,,„in (cereal grain mass loading factor) unitless
MLF^kiic (citrus mass loading factor) unitless
MLF_ (corn mass loading factor) unitless
MLF_, (carrot mass loading factor) unitless
MLF„,„imh=K (cucumber mass loading factor) unitless
MLF,_ (lettuce mass loading factor) unitless
MLFlimoh_ (lima bean mass loading factor) unitless
MLF„,ko (okra mass loading factor) unitless
MLF„ni„„ (onion mass loading factor) unitless
MLF_„ (peach mass loading factor) unitless
MLF_ (pea mass loading factor) unitless
MLF_ (pear mass loading factor) unitless
MLF„„,o,„ (potato mass loading factor) unitless
MLF„iim„ki„ (pumpkin mass loading factor) unitless
MLFKi„ (rice mass loading factor) unitless
MLF_h_ (snap bean mass loading factor) unitless
MLFc(Koi,ih=m, (strawberry mass loading factor) unitless
MLF,_ (tomato mass loading factor) unitless
pm (density of milk) kg/L
tfc, (time - farmer) yr
TR (target cancer risk) unitless
F(x) (function dependent on U m/U,) unitless
PEF (particulate emission factor) m 3/kg
Q/C „inH (g/m2-s per kg/m3)

A„ (acres)

Slab size for ACF (area correction factor) m 2
ED,ok (exposure duration - farmer) yr
EDfar a (exposure duration - farmer adult) yr

Default

Form-input

Value

Value

0.000160

0.000160

0.0000790

0.0000790

0.000166

0.000166

0.00101

0.00101

0.000138

0.000138

0.000105

0.000105

0.250

0.250

0.000157

0.000157

0.000145

0.000145

0.0000970

0.0000970

0.0000400

0.0000400

0.0135

0.0135

0.00383

0.00383

0.0000800

0.0000800

0.0000970

0.0000970

0.000150

0.000150

0.000178

0.000178

0.000160

0.000160

0.000210

0.000210

0.0000580

0.0000580

0.250

0.250

0.00500

0.00500

0.0000800

0.0000800

0.00159

0.00159

1.03

1.03

40

25

1.0E-06

1.0E-04

0.194

0.0553

1359344438

6609630249.811598

93.77

81.84858572694108

0.5

0.5

1000029 m2

1000029 m2

40

25

34

25

Output generated 15DEC2019:16:13:00


-------
Site-specific





6

Farmer Soil Inputs - Secular Equilibrium







Default

Form-input



Variable

Value

Value



EDfo_ (exposure duration - farmer child) yr

6

0



EF,ok (exposure frequency) day/yr

350

350



EFfc„ (exposure frequency - farmer adult) day/yr

350

350



EFfc„ (exposure frequency - farmer child) day/yr

350

o



ET,ok (exposure time - farmer) hr/day

24

o



ETfc„ (exposure time - farmer adult) hr/day

24

o



ETfc„ (exposure time - farmer child) hr/day

24

o



ETfoKi (indoor exposure time fraction) hr/day

10.008

o



ETfc,_„ (outdoor exposure time fraction) hr/day

12.168

o



(animal on-site fraction) unitless

1

0.33



(animal on-site fraction) unitless

1

1



(animal on-site fraction) unitless

1

1



f (animal on-site fraction) unitless

1

1



		 (animal on-site fraction) unitless

1

1



f (animal on-site fraction) unitless

1

1



f(animal on-site fraction) unitless

1

1



(animal on-site fraction) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f Hoi„, (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



(fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



GSF; (gamma shielding factor - indoor)

0.4

o



IFAfoK oHi (age-adjusted soil inhalation factor) m 3

259000

o



IFS,ok oHi (age-adjusted soil ingestion factor) mg

1610000

o



IRAfc„ (inhalation rate - farmer adult) m 3/day

20

o



IRAfc„ (inhalation rate - farmer child) m 3/day

10

o



IRSfc„ (soil ingestion rate - farmer adult) mg/day

100

o



IRSfc„ (soil ingestion rate - farmer child) mg/day

200

o



MLF_„ira (pasture plant mass loading factor) unitless

0.25

0.25



Qp-beef (beef fodder intake rate) kg/day

11.77

11.77



Output generated 15DEC2019:16:13:00






-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

7



Default

Form-input

Variable

Value

Value

Q„ Hoi„, (dairy fodder intake rate) kg/day

20.3

20.3

Q	o(milk (goat milk fodder intake rate) kg/day

1.59

1.59

Q		 (goat fodder intake rate) kg/day

1.27

1.27

Q			 (poultry fodder intake rate) kg/day

0.2

0.2

(sheep fodder intake rate) kg/day

1.75

1.75

(sheep milk fodder intake rate) kg/day

3.15

3.15

Q„ (swine fodder intake rate) kg/day

4.7

4.7

(beef soil intake rate) kg/day

0.5

0.5

Q, Hoi„, (dairy soil intake rate) kg/day

0.4

0.4

(goat milk soil intake rate) kg/day

0.29

0.29

Q_ (goat soil intake rate) kg/day

0.23

0.23

(poultry soil intake rate) kg/day

0.022

0.022

Q„_ (sheep soil intake rate) kg/day

0.32

0.32

(sheep milk soil intake rate) kg/day

0.57

0.57

(swine soil intake rate) kg/day

0.37

0.37

tfc, (time - farmer) yr

40

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Output generated 15DEC2019:16:13:00


-------
Site-specific

Farmer PRGs for Soil - Secular Equilibrium

8

External	Produce	Beef

Ingestion Inhalation Exposure	Consumption	Consumption Total

PRG PRG PRG	PRG	PRG PRG

TR=0.0001 TR=0.0001 TR=0.0001	TR=0.0001	TR=0.0001 TR=0.0001

Isotope (pCi/g) (pCi/g) (pCi/g)	(pCi/g)	(pCi/g) (pCi/g)

Secular Equilibrium PRG for U-235	.	.	.	.	1.86E+02 1.86E+02

Secular Equilibrium PRG for U-238	...	.	9.57E+00 9.57E+00

Output generated 15DEC2019:16:13:00


-------
Site-specific

Farmer Risk for Soil

- Secular Equilibrium





Isotope

External Produce
Ingestion Inhalation Exposure Consumption
Risk Risk Risk Risk

Beef
Risk

Total
Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 0.00E+00

2.45E-06

2.45E-06

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 0.00E+00

1.06E-03

1.06E-03

*Total Risk

0.00E+00 0.00E+00 0.00E+00

1.06E-03

1.06E-03

Output generated 15DEC2019:16:13:00


-------
Site-specific

Composite Worker Soil Inputs - Secular Equilibrium

1



Default

Form-input

Variable

Value

Value

A (PEF Dispersion Constant)

16.2302

14.9421

B (PEF Dispersion Constant)

18.7762

17.9869

City (Climate Zone)

Default

Albuquerque, NM (3)

C (PEF Dispersion Constant)

216.108

205.1782

Cover thickness for GSF „ (gamma shielding factor) cm

0 cm

0 cm

F(x) (function dependent on U m/U,) unitless

0.194

0.0553

PEF (particulate emission factor) m 3/kg

1359344438

2573243853.79163

Q/C„_h (g/m2-s per kg/m3)

93.77

31.86507598808449

A (acres)

0.5

250

Site area for ACF (area correction factor) m 2

1000029 m2

1000029 m2

ED„ (exposure duration - composite worker) yr

25

25

EF„ (exposure frequency - composite worker) dayfyr

250

250

ET (exposure time - composite worker) hr/day

8

0.8

IRA, (inhalation rate - composite worker) m 3/day

60

60

IRS, (soil intake rate - composite worker) mg/day

100

100

t„ (time - composite worker) yr

25

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Section 10 Subsurface Soil

Output generated 15DEC2019:16:31:08


-------
Site-specific

Composite Worker PRGs for Soil - Secular Equilibrium

Total
PRG
TR=0.0001

(pCi/g)
5.97E+01
1.56E+01

Output generated 15DEC2019:16:31:08

Isotope

Secular Equilibrium PRG for U-235
Secular Equilibrium PRG for U-238

External

Ingestion	Inhalation	Exposure

PRG	PRG	PRG

TR=0.0001 TR=0.0001	TR=0.0001

(pCi/g)	(pCi/g)	(pCi/g)

2.91E+02	6.55E+04	7.51E+01

6.35E+01	1.42E+05	2.06E+01


-------
Site-specific	3

Composite Worker Risk for Soil - Secular Equilibrium

Isotope

External

Ingestion Inhalation Exposure
Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

5.36E-08 2.38E-10 2.08E-07

2.61E-07

*Secular Equilibrium Risk for U-238

5.45E-06 2.43E-09 1.68E-05

2.22E-05

*Total Risk

5.50E-06 2.67E-09 1.70E-05

2.25E-05



Output generated 15DEC2019:16:31:08


-------
Site-specific

Indoor Worker Soil Inputs - Secular Equilibrium

Default	Form-input

Variable	Value	Value

A (PEF Dispersion Constant)	16.2302	14.9421

B (PEF Dispersion Constant)	18.7762	17.9869

City (Climate Zone)	Default	Albuquerque, NM (3)

C (PEF Dispersion Constant)	216.108	205.1782

Cover thickness for GSF h (gamma shielding factor) cm 0 cm	0 cm

F(x) (function dependent on U m/U,) unitless	0.194	0.0553

PEF (particulate emission factor) m 3/kg	1359344438	6609630249.811598

Q/C,.linH (g/m2-s per kg/m3)	93.77	81.84858572694108

A„ (acres)	0.5	0.5

Site area for ACF (area correction factor) m 2	1000029 m 2	1000029 m 2

ED,,, (exposure duration - indoor worker) yr	25	25

EF.„ (exposure frequency - indoor worker) dayfyr	250	250

ET„ (exposure time - indoor worker) hr/day	8	0.8

GSF; (indoor gamma shielding factor) unitless	0.4	0.7

IRA,, (inhalation rate - indoor worker) m 3/day	60	0

IRS,,, (soil intake rate - indoor worker) mg/day	50	0

t„ (time - indoor worker) yr	25	25

TR (target cancer risk) unitless	1.0E-06	1.0E-04

Um (mean annual wind speed) m/s	4.69	4.02

U, (equivalent threshold value)	11.32	11.32

V (fraction of vegetative cover) unitless	0.5	0.5

Output generated 15DEC2019:16:23:11

Section 10 Subsurface Soil


-------
Site-specific

Indoor Worker PRGs for Soil - Secular Equilibrium

Total
PRG
TR=0.0001

(pCi/g)
1.07E+02
2.95E+01

Output generated 15DEC2019:16:23:11

External

Ingestion	Inhalation	Exposure

PRG	PRG	PRG

TR=0.0001	TR=0.0001	TR=0.0001

Isotope (pCi/g)	(pCi/g)	(pCi/g)

Secular Equilibrium PRG for U-235 -	-	1.07E+02

Secular Equilibrium PRG for U-238 -	-	2.95E+01

2


-------
Site-specific

Indoor Worker Risk for Soil - Secular Equilibrium

Isotope

External

Ingestion Inhalation Exposure
Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 1.45E-07

1.45E-07

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 1.17E-05

1.17E-05

*Total Risk

0.00E+00 0.00E+00 1.19E-05

1.19E-05



Output generated 15DEC2019:16:23:11


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

1

Variable

A (PEF Dispersion Constant)

B (PEF Dispersion Constant)

City (Climate Zone)

C (PEF Dispersion Constant)

Cover thickness for GSF „ (gamma shielding factor) cm
Cover thickness for GSF h (gamma shielding factor) cm

CFfo		 (contaminated plant fraction) unitless

CF,ok ^ (contaminated apple fraction) unitless
CFfc„m,„_ (contaminated asparagus fraction) unitless
CFfoKhMf (beef contaminated fraction) unitless
CF^_ (contaminated berry fraction) unitless

CF,,,		 (contaminated broccoli fraction) unitless

CFfoK hM, (contaminated beet fraction) unitless
CFfomhh_ (contaminated cabbage fraction) unitless
CFf_raolmi„ (contaminated cereal grain fraction) unitless
CFfo_i(Kiic (contaminated citrus fraction) unitless
CFf_ (contaminated corn fraction) unitless
CF,__, (contaminated carrot fraction) unitless
CFfoK „,„imh=K (contaminated cucumber fraction) unitless
CFfoKHoi„, (dairy contaminated fraction) unitless
CFf_ (egg contaminated fraction) unitless
CF^ (fish contaminated fraction) unitless
CFfoK„m(milk (goat milk contaminated fraction) unitless
CF,_m(i_( (goat meat contaminated fraction) unitless
CFfcrJilli„ (contaminated lettuce fraction) unitless
CFfc,Jim,_ (contaminated lima bean fraction) unitless
CFfoK„kra (contaminated okra fraction) unitless
CFfoK„ni„„ (contaminated onion fraction) unitless
CF,__lw (poultry contaminated fraction unitless)

CFt	(contaminated peach fraction) unitless

CFfc,„M (contaminated pea fraction) unitless
CFfc,„M, (contaminated pear fraction) unitless

CF	(contaminated potato fraction) unitless

CF, (contaminated pumpkin fraction) unitless

far-pumpkin v	r r	/

Default

Form-input

Value

Value

16.2302

14.9421

18.7762

17.9869

Default

Albuquerque, NM (3)

216.108

205.1782

0 cm

0 cm

0 cm

0 cm

Section 10 Subsurface Soil

i.48

Output generated 15DEC2019:16:16:14


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

2



Default

Form-input

Variable

Value

Value

CFfc„.„ (contaminated rice fraction) unitless

1

1

CFfc„_ (sheep contaminated fraction) unitless

1

1

CFfc„_mill, (sheep milk contaminated fraction) unitless

1

1

CFf_o„h_ (contaminated snap bean fraction) unitless

1

1

CF^,(contaminated strawberry fraction) unitless

1

1

CFf_iin= (swine contaminated fraction) unitless

1

1

CF,okJ_,„ (contaminated tomato fraction) unitless

1

1

ED,ok (exposure duration - farmer) yr

40

25

ED,ok o (exposure duration - farmer adult) yr

34

25

EDfo_ (exposure duration - farmer child) yr

6

0

EFfc„ (exposure frequency - farmer adult) day/yr

350

350

EFfc„ (exposure frequency - farmer child) day/yr

350

0

IFAP,ok oHi (age-adjusted apple ingestion factor) g

1182020

741125

IFASfoK oHi (age-adjusted asparagus ingestion factor) g

492870

343874.99999999994

IFB,ok oHi (age-adjusted beef ingestion factor) g

2098950

1446375

IFBEfoK oHi (age-adjusted berry ingestion factor) g

471450

309750

IFBR,ok oHi (age-adjusted broccoli ingestion factor) g

450310

308874.99999999994

IFBT,ok oHi (age-adjusted beet ingestion factor) g

411600

296625

IFCB,ok oHi (age-adjusted cabbage ingestion factor) g

1043980

749875

IFCG,ok oHi (age-adjusted cereal grain ingestion factor) g

1190210

1190210

IFCIfoK oHi (age-adjusted citrus ingestion factor) g

4090100

2707249.9999999995

IFCO,ok oHi (age-adjusted corn ingestion factor) g

1044470

717500

IFCR,ok oHi (age-adjusted carrot ingestion factor) g

318290

213500

IFCUfoK oHi (age-adjusted cucumber ingestion factor) g

688800

480375

IFD,ok oHi (age-adjusted dairy ingestion factor) g

10138030

5918500

IFEfoK oHi (age-adjusted egg ingestion factor) g

775810

521500

IFFIfoK oHi (age-adjusted fish ingestion factor) g

10018960

7278250

IFLEfoKoHi (age-adjusted lettuce ingestion factor) g

455070

328125

IFLIfoK oHi (age-adjusted lima bean ingestion factor) g

415870

295749.99999999994

IFOK,ok oHi (age-adjusted okra ingestion factor) g

370510

264250

IFONfoK oHi (age-adjusted onion ingestion factor) g

338800

238000

IFP,ok oHi (age-adjusted poultry ingestion factor) g

1376550

939750

IFPC,ok oHi (age-adjusted peach ingestion factor) g

1435420

902125

IFPEfar adj (age-adjusted pea ingestion factor) g

437500

277375

Output generated 15DEC2019:16:16:14


-------
Site-specific





3

Farmer Soil Inputs - Secular Equilibrium







Default

Form-input



Variable

Value

Value



IFPR„K ,Hi (age-adjusted pear ingestion factor) g

874300

524125



IFPT,_Hi (age-adjusted potato ingestion factor) g

1807750

1240750.0000000002



IFPUfoK oHi (age-adjusted pumpkin ingestion factor) g

866040

567000



IFRIfoK oHi (age-adjusted rice ingestion factor) g

1126230

774375



IFSNfoK oHi (age-adjusted snap bean ingestion factor) g

702730

474250



IFST,ok oHi (age-adjusted strawberry ingestion factor) g

535080

354375



IFSWfoK oHi (age-adjusted swine ingestion factor) g

1171520

809375



IFTOfoK oHi (age-adjusted tomato ingestion factor) g

1194270

824250



IRAP,_ (apple ingestion rate - farmer adult) g/day

84.7

84.7



IRAPfo_ (apple ingestion rate - farmer child) g/day

82.9

82.9



IRAS,ok o (asparagus ingestion rate - farmer adult) g/day

39.3

39.3



IRASfo_ (asparagus ingestion rate - farmer child) g/day

12.0

12.0



IRB,ok o (beef ingestion rate - farmer adult) g/day

165.3

165.3



IRBfo_ (beef ingestion rate - farmer child) g/day

62.8

0



IRBE,ok o (berry ingestion rate - farmer adult) g/day

35.4

35.4



IRBEfo_ (berry ingestion rate - farmer child) g/day

23.9

23.9



IRBR,ok o (broccoli ingestion rate - farmer adult) g/day

35.3

35.3



IRBRfo_ (broccoli ingestion rate - farmer child) g/day

14.4

14.4



IRBT,ok o (beet ingestion rate - farmer adult) g/day

33.9

33.9



IRBT,_ (beet ingestion rate - farmer child) g/day

3.9

3.9



IRCB,ok o (cabbage ingestion rate - farmer adult) g/day

85.7

85.7



IRCBfo_ (cabbage ingestion rate - farmer child) g/day

11.5

11.5



IRCG,ok o (cereal grain ingestion rate - farmer adult) g/day

91.9

91.9



IRCGfo_ (cereal grain ingestion rate - farmer child) g/day

46.0

46.0



IRCI,ok o (citrus ingestion rate - farmer adult) g/day

309.4

309.4



IRCIfo_ (citrus ingestion rate - farmer child) g/day

194.4

194.4



IRCO,ok o (corn ingestion rate - farmer adult) g/day

82.0

82.0



IRCOfo_ (corn ingestion rate - farmer child) g/day

32.7

32.7



IRCR,_ (carrot ingestion rate - farmer adult) g/day

24.4

24.4



IRCRfo_ (carrot ingestion rate - farmer child) g/day

13.3

13.3



IRCU,ok o (cucumber ingestion rate - farmer adult) g/day

54.9

54.9



IRCUfo_ (cucumber ingestion rate - farmer child) g/day

16.9

16.9



IRDfoK, (dairy ingestion rate - farmer adult) g/day

676.4

676.4



IRDfar c (dairy ingestion rate - farmer child) g/day

994.7

994.7



Output generated 15DEC2019:16:16:14






-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

4

Default	Form-input

Variable	Value	Value

IRE,ok o (egg ingestion rate - farmer adult) g/day	59.6	59.6

IREfo_ (egg ingestion rate - farmer child) g/day	31.7	31.7

IRFIfc„ (fish ingestion rate - farmer adult) g/day	831.8	831.8

IRFIfc„ (fish ingestion rate - farmer child) g/day	57.4	57.4

IRLE,ok o (lettuce ingestion rate - farmer adult) g/day	37.5	37.5

IRLEfo_ (lettuce ingestion rate - farmer child) g/day	4.2	4.2

IRLIf„, (lima bean ingestion rate - farmer adult) g/day	33.8	33.8

IRLIf,_ (lima bean ingestion rate - farmer child) g/day	6.5	6.5

IROK,ok o (okra ingestion rate - farmer adult) g/day	30.2	30.2

IROKfo_ (okra ingestion rate - farmer child) g/day	5.3	5.3

IRON,oko (onion ingestion rate-farmer adult) g/day	27.2	27.2

IRONfo_ (onion ingestion rate - farmer child) g/day	7.2	7.2

IRPfc„ (poultry ingestion rate - farmer adult) g/day	107.4	107.4

IRPfc„ (poultry ingestion rate - farmer child) g/day	46.9	46.9

IRPCfc„ (peach ingestion rate - farmer adult) g/day	103.1	103.1

IRPCfc„ (peach ingestion rate - farmer child) g/day	99.3	99.3

IRPEfc„ (pea ingestion rate - farmer adult) g/day	31.7	31.7

IRPEfc„ (pea ingestion rate - farmer child) g/day	28.7	28.7

IRPRfc„ (pear ingestion rate - farmer adult) g/day	59.9	59.9

IRPRfc„ (pear ingestion rate - farmer child) g/day	76.9	76.9

IRPTfc„ (potato ingestion rate - farmer adult) g/day	141.8	141.8

IRPTfc„ (potato ingestion rate - farmer child) g/day	57.3	57.3

IRPUfc„ (pumpkin ingestion rate -farmer adult) g/day	64.8	64.8

IRPUfc„ (pumpkin ingestion rate - farmer child) g/day	45.2	45.2

IRRL, (rice ingestion rate - farmer adult) g/day	88.5	88.5

IRRIfc„ (rice ingestion rate - farmer child) g/day	34.8	34.8

IRSNfc„ (snap bean ingestion rate - farmer adult) g/day	54.2	54.2

IRSNfc„ (snap bean ingestion rate - farmer child) g/day	27.5	27.5

IRSTfc„ (strawberry ingestion rate -farmer adult) g/day	40.5	40.5

IRSTfc„ (strawberry ingestion rate -farmer child) g/day	25.3	25.3

IRSWfc„ (swine ingestion rate - farmer adult) g/day	92.5	92.5

IRSWfc„ (swine ingestion rate - farmer child) g/day	33.7	33.7

IRTOfc„ (tomato ingestion rate - farmer adult) g/day	94.2	94.2

IRTOfarc (tomato ingestion rate-farmer child) g/day	34.9	34.9

Output generated 15DEC2019:16:16:14


-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

5

Variable

MLFoml= (apple mass loading factor) unitless

MLF	(asparagus mass loading factor) unitless

MLFh=m, (berry mass loading factor) unitless
MLFhK_N (broccoli mass loading factor) unitless
MLFhM, (beet mass loading factor) unitless
MLF„hh_ (cabbage mass loading factor) unitless
MLF„„,,„in (cereal grain mass loading factor) unitless
MLF^kiic (citrus mass loading factor) unitless
MLF_ (corn mass loading factor) unitless
MLF_, (carrot mass loading factor) unitless
MLF„,„imh=K (cucumber mass loading factor) unitless
MLF,_ (lettuce mass loading factor) unitless
MLFlimoh_ (lima bean mass loading factor) unitless
MLF„,ko (okra mass loading factor) unitless
MLF„ni„„ (onion mass loading factor) unitless
MLF_„ (peach mass loading factor) unitless
MLF_ (pea mass loading factor) unitless
MLF_ (pear mass loading factor) unitless
MLF„„,o,„ (potato mass loading factor) unitless
MLF„iim„ki„ (pumpkin mass loading factor) unitless
MLFKi„ (rice mass loading factor) unitless
MLF_h_ (snap bean mass loading factor) unitless
MLFc(Koi,ih=m, (strawberry mass loading factor) unitless
MLF,_ (tomato mass loading factor) unitless
pm (density of milk) kg/L
tfc, (time - farmer) yr
TR (target cancer risk) unitless
F(x) (function dependent on U m/U,) unitless
PEF (particulate emission factor) m 3/kg
Q/C „inH (g/m2-s per kg/m3)

A„ (acres)

Slab size for ACF (area correction factor) m 2
ED,ok (exposure duration - farmer) yr
EDfar a (exposure duration - farmer adult) yr

Default

Form-input

Value

Value

0.000160

0.000160

0.0000790

0.0000790

0.000166

0.000166

0.00101

0.00101

0.000138

0.000138

0.000105

0.000105

0.250

0.250

0.000157

0.000157

0.000145

0.000145

0.0000970

0.0000970

0.0000400

0.0000400

0.0135

0.0135

0.00383

0.00383

0.0000800

0.0000800

0.0000970

0.0000970

0.000150

0.000150

0.000178

0.000178

0.000160

0.000160

0.000210

0.000210

0.0000580

0.0000580

0.250

0.250

0.00500

0.00500

0.0000800

0.0000800

0.00159

0.00159

1.03

1.03

40

25

1.0E-06

1.0E-04

0.194

0.0553

1359344438

6609630249.811598

93.77

81.84858572694108

0.5

0.5

1000029 m2

1000029 m2

40

25

34

25

Output generated 15DEC2019:16:16:14


-------
Site-specific





6

Farmer Soil Inputs - Secular Equilibrium







Default

Form-input



Variable

Value

Value



EDfo_ (exposure duration - farmer child) yr

6

0



EF,ok (exposure frequency) day/yr

350

350



EFfc„ (exposure frequency - farmer adult) day/yr

350

350



EFfc„ (exposure frequency - farmer child) day/yr

350

o



ET,ok (exposure time - farmer) hr/day

24

o



ETfc„ (exposure time - farmer adult) hr/day

24

o



ETfc„ (exposure time - farmer child) hr/day

24

o



ETfoKi (indoor exposure time fraction) hr/day

10.008

o



ETfc,_„ (outdoor exposure time fraction) hr/day

12.168

o



(animal on-site fraction) unitless

1

0.33



(animal on-site fraction) unitless

1

1



(animal on-site fraction) unitless

1

1



f (animal on-site fraction) unitless

1

1



		 (animal on-site fraction) unitless

1

1



f (animal on-site fraction) unitless

1

1



f(animal on-site fraction) unitless

1

1



(animal on-site fraction) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f Hoi„, (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



(fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



f (fraction of year animal on site) unitless

1

1



GSF; (gamma shielding factor - indoor)

0.4

o



IFAfoK oHi (age-adjusted soil inhalation factor) m 3

259000

o



IFS,ok oHi (age-adjusted soil ingestion factor) mg

1610000

o



IRAfc„ (inhalation rate - farmer adult) m 3/day

20

o



IRAfc„ (inhalation rate - farmer child) m 3/day

10

o



IRSfc„ (soil ingestion rate - farmer adult) mg/day

100

o



IRSfc„ (soil ingestion rate - farmer child) mg/day

200

o



MLF_„ira (pasture plant mass loading factor) unitless

0.25

0.25



Qp-beef (beef fodder intake rate) kg/day

11.77

11.77



Output generated 15DEC2019:16:16:14






-------
Site-specific

Farmer Soil Inputs - Secular Equilibrium

7



Default

Form-input

Variable

Value

Value

Q„ Hoi„, (dairy fodder intake rate) kg/day

20.3

20.3

Q	o(milk (goat milk fodder intake rate) kg/day

1.59

1.59

Q		 (goat fodder intake rate) kg/day

1.27

1.27

Q			 (poultry fodder intake rate) kg/day

0.2

0.2

(sheep fodder intake rate) kg/day

1.75

1.75

(sheep milk fodder intake rate) kg/day

3.15

3.15

Q„ (swine fodder intake rate) kg/day

4.7

4.7

(beef soil intake rate) kg/day

0.5

0.5

Q, Hoi„, (dairy soil intake rate) kg/day

0.4

0.4

(goat milk soil intake rate) kg/day

0.29

0.29

Q_ (goat soil intake rate) kg/day

0.23

0.23

(poultry soil intake rate) kg/day

0.022

0.022

Q„_ (sheep soil intake rate) kg/day

0.32

0.32

(sheep milk soil intake rate) kg/day

0.57

0.57

(swine soil intake rate) kg/day

0.37

0.37

tfc, (time - farmer) yr

40

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Output generated 15DEC2019:16:16:14


-------
Site-specific

Farmer PRGs for Soil - Secular Equilibrium

8

External	Produce	Beef

Ingestion Inhalation Exposure	Consumption	Consumption Total

PRG PRG PRG	PRG	PRG PRG

TR=0.0001 TR=0.0001 TR=0.0001	TR=0.0001	TR=0.0001 TR=0.0001

Isotope (pCi/g) (pCi/g) (pCi/g)	(pCi/g)	(pCi/g) (pCi/g)

Secular Equilibrium PRG for U-235	.	.	.	.	1.86E+02 1.86E+02

Secular Equilibrium PRG for U-238	...	.	9.57E+00 9.57E+00

Output generated 15DEC2019:16:16:14


-------
Site-specific

Farmer Risk for Soil - Secular Equilibrium

Isotope

External Produce
Ingestion Inhalation Exposure Consumption
Risk Risk Risk Risk

Beef Total
Risk Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 0.00E+00

8.40E-08 8.40E-08

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 0.00E+00

3.62E-05 3.62E-05

*Total Risk

0.00E+00 0.00E+00 0.00E+00

3.62E-05 3.62E-05



Output generated 15DEC2019:16:16:14


-------
Site-specific

Composite Worker Equation Inputs for Soil

* Inputted values different from Composite Worker defaults are highlighted.



Composite





Worker





Soil





Default

Form-input

Variable

Value

Value

A (PEF Dispersion Constant)

16.2302

14.9421

A (VF Dispersion Constant)

11.911

14.9421

A (VF Dispersion Constant - Mass Limit)

11.911

11.911

B (PEF Dispersion Constant)

18.7762

17.9869

B (VF Dispersion Constant)

18.4385

17.9869

B (VF Dispersion Constant - Mass Limit)

18.4385

18.4385

CityDCC (Climate Zone) Selection

Default

Albuquerque, NM

Citywc (Climate Zone) Selection

Default

Albuquerque, NM

C (PEF Dispersion Constant)

216.108

205.1782

C (VF Dispersion Constant)

209.7845

205.1782

C (VF Dispersion Constant - Mass Limit)

209.7845

209.7845

foe (fraction organic carbon in soil) g/g

0.006

0.006

F(x) (function dependent on U m/U,) unitless

0.194

0.0553

n (total soil porosity) L _/L_a

0.43396

0.43396

ph (dry soil bulk density) g/cm 3

1.5

1.5

ph (dry soil bulk density - mass limit) g/cm 3

1.5

1.5

PEF (particulate emission factor) m 3/kg

1359344438

2573243853.7916

pc (soil particle density) g/cm 3

2.65

2.65

Q/C„_h (g/m2-s per kg/m3)

93.77

31.865075988084

Q/C (g/m2-s per kg/m3)

68.18

31.865075988084

Q/C (g/m2-s per kg/m3)

68.18

68.18

A„ (PEF acres)

0.5

250

A„ (VF acres)

0.5

250

A„ (VF mass-limit acres)

0.5

0.5

AF„ (skin adherence factor - composite worker) mg/cm

2 0.12

0.12

AT, (averaging time - composite worker)

365

365

BW„ (body weight - composite worker)

80

80

ED„ (exposure duration - composite worker) yr

25

25

EFw (exposure frequency - composite worker) dayfyr

250

250

Output generated 16DEC2019:15:54:11

Section 10 Soil Metals


-------
Site-specific

Composite Worker Equation Inputs for Soil

2

* Inputted values different from Composite Worker defaults are highlighted.



Composite





Worker





Soil





Default

Form-input

Variable

Value

Value

ET„ (exposure time - composite worker) hr

8

1.6

THQ (target hazard quotient) unitless

0.1

1

IR„ (soil ingestion rate - composite worker) mg/day

100

100

LT (lifetime) yr

70

70

SA„ (surface area - composite worker) cm 2/day

3527

3527

TR (target risk) unitless

1.0E-06

1.0E-06

T„ (groundwater temperature) Celsius

25

25

Theta, (air-filled soil porosity) L

0.28396

0.28396

Theta , (water-filled soil porosity) L

0.15

0.15

T (exposure interval) s

819936000

819936000

T (exposure interval) yr

26

26

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

VFm| (volitization factor - mass limit) m 3/kg





Output generated 16DEC2019:15:54:11


-------
Site-specific

Composite Worker Regional Screening Levels (RSL) for Soil

Key: I = IRIS; P = PPRTV; O = OPP; A = ATSDR; C = Cal EPA; X = PPRTV Screening Level; H = HEAST; D = DWSHA; W = TEF applied; E = RPF applied; G = see
user's guide; U = user provided; ca = cancer; nc = noncancer; * = where: nc SL < 100X ca SL; ** = where nc SL < 10X ca SL; SSL values are based on
DAF=1; max = ceiling limit exceeded; sat = Csat exceeded.

CAS Chemical	SFo	SFo IUR	IUR RfD	RfD RfC RfC

Chemical Number	Mutagen?	Volatile? Type	(mg/kg-day) 1 Ref (ug/m3)1	Ref (mg/kg-day)	Ref (mg/m3) Ref GIABS ABS RBA

Arsenic, Inorganic 7440-38-2	No	No Inorganics	1.50E+00 U 4.30E-03	U 3.00E-04 U 1.50E-05 U 1 0.03 0.6

Selenium 7782-49-2	No	No Inorganics	- -	5.00E-03 U 2.00E-02 U 1 - 1

Uranium NA	No	No Inorganics	- -	2.00E-04 U 4.00E-05 U 1 - 1

Vanadium and Compounds 7440-62-2	No	No Inorganics	- -	5.04E-03 U 1.00E-04 U 0.026 - 1

Soil
Saturation
Concentration
(mg/kg)

S K \

oc

(mg/L) (cm3/g)

Kd\
(cm3/g)

2.90E+01

5.00E+00

4.50E+02

1.00E+03

Henry's

Law
Constant l-T
Used in and
HLC	Calcs HLC

(atm-m 7mole) (unitless) Ref

Normal
Boiling
Point
BP

(K)

888.15
958.15
4093.15
3683.15

BP
Ref

U

U

u
u

Critical
Temperature
TC

(K)

1670
1770
13700
11300

TC Chemical D. \ D. \

ia	iw

Ref Type (cm2/s) (cm2/s)
U INORGANIC
U INORGANIC

U INORGANIC 7.49E-02 3.34E-05
U INORGANIC



Particulate



Ingestion

Dermal

Inhalation Carcinogenic

Ingestion

Dermal

Inhalation Noncarcinogenic





Emission

Volatilization

SL

SL

SL

SL

SL

SL

SL

SL

Screening

D„\

Factor

Factor

TR=1E-06

TR=1E-06

TR=1E-06

TR=1E-06

THQ=1

THQ=1

THQ=1

THI=1

Level

(cm 2/s)

(m3/kg)

(m3/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

(mg/kg)

-

2.57E+09

-

3.63E+00

1.72E+01

3.67E+04

3.00E+00

5.84E+02

2.76E+03

8.45E+05

4.82E+02

3.00E+00 ca

-

2.57E+09

-

-

-

-

-

5.84E+03

-

1.13E+09

5.84E+03

5.84E+03 nc

-

2.57E+09

-

-

-

-

-

2.34E+02

-

2.25E+06

2.34E+02

2.34E+02 nc

-

2.57E+09

-

-

-

-

-

5.89E+03

-

5.64E+06

5.88E+03

5.88E+03 nc

Output generated 16DEC2019:15:54:11


-------
Site-specific

Composite Worker Risk for Soil

4

Chemical

SF SF IUR IUR RfD

0 0

(mg/kg-day) 1 Ref (ug/m3)1 Ref (mg/kg-day)

RfD
Ref

RfC
(mg/m3)

RfC

Ref GIABS ABS RBA

Soil
Saturation
Concentration
(mg/kg)

S K \

oc

(mg/L) (cm3/g)

Kd\
(cm3/g)

Arsenic, Inorganic

1.50E+00 U 4.30E-03 U

3.00E-04

U

1.50E-05

U

1 0.03

0.6

-

-

-

2.90E+01

Selenium

-

5.00E-03

U

2.00E-02

U

1

1

-

-

-

5.00E+00

Uranium

-

2.00E-04

u

4.00E-05

u

1

1

-

-

-

4.50E+02

Vanadium and Compounds

-

5.04E-03

u

1.00E-04

u

0.026

1

-

-

-

1.00E+03

*Total Risk/Hi

¦

-



-



-

-

-

-

-

-

Henry's

Law	Normal

Constant	l-T Boiling	Critical Particulate

Used in	and Point	Temperature Emission

HLC Calcs	HLC BP	BP TC TC Chemical D \ D \ DA Factor

ia	iw	A

Chemical (atm-m 3/mole) (unitless)	Ref (K)	Ref (K) Ref Type (cm2/s) (cm2/s) (cm2/s) (m3/kg)

Arsenic, Inorganic

888.15

u

1670

U

INORGANIC

- 2.57E+09

Selenium

958.15

u

1770

u

INORGANIC

- 2.57E+09

Uranium

4093.15

u

13700

u

INORGANIC 7.49E-02 3.34E-05

- 2.57E+09

Vanadium and Compounds

3683.15

u

11300

u

INORGANIC

- 2.57E+09

*Total Risk/Hi

-H



-



-

-H

Chemical

Volatilization
Factor

(m3/kg)

Concentration
(mg/kg)

Ingestion
Risk

Dermal
Risk

Inhalation Carcinogenic
Risk Risk

Ingestion
HQ

Dermal
HQ

Inhalation Noncarcinogenic
HQ HI

Arsenic, Inorganic

-

2.00E+01

5.50E-06

1.16E-06

5.45E-10

6.67E-06

3.42E-02

7.25E-03

2.37E-05

4.15E-02

Selenium

-

8.70E+01

-

-

-

-

1.49E-02

-

7.72E-08

1.49E-02

Uranium

-

3.10E+02

-

-

-

-

1.33E+00

-

1.38E-04

1.33E+00

Vanadium and Compounds

-

2.50E+02

-

-

-

-

4.25E-02

-

4.44E-05

4.25E-02

*Total Risk/Hi

-

-

5.50E-06

1.16E-06

5.45E-10

6.67E-06

1.42E+00

7.25E-03

2.06E-04

1.43E+00

Output generated 16DEC2019:15:54:11


-------
Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Attachment 2
Recommended Shielding Factor for a Pick-up Truck


-------
MEMO

DATE:	September 26, 2016

TO:	Keith Delhomme

FROM:	Rick Haaker

^ f- M 	-*

SUBJECT:	Recommended shielding factor for a pick-up truck

Mr. Delhomme directed me to provide a gamma radiation transmission factor for a pick-up truck. A
transmission factor in this case may be thought of as the proportion of gamma radiation level measured
inside of the cab compared to the level at the same location in the absence of the truck, Equation 1.

Gamma radiation level inside of cab

Eq. 1: Transmission Factor =	-	-	-—		-	

Gamma radiation level if no truck is present

A 2010 extended cab Honda Ridgeline was chosen for the gamma radiation measurements. The Honda
extended cab Ridgeline is considered a comparatively small pickup, having a curb weight of
approximately 4,500 pounds. Radiation levels inside and outside a 2014 Toyota Corolla 4-door sedan
were also measured to give an estimate of the transmission factor for a rather light vehicle by modern
standards. The weights of some selected vehicles are provided in Table 1.

Table 1.

Vehicle

Weight, lbs1

2016 Ford F-250 Super Cab

6,200 to 7,460

2016 Ford F-350 Super Cab

6,298 to 7,508

2016 Ford F-450 Crew Cab

8,611

1983 Mazda B-2000 Pickup

2,5902

2014 Toyota Corolla 4-door sedan

~2,900 3

Measurement Method

Two gamma radiation intensities were measured in the front seats of each vehicle, one in the driver seat
and the other in the front passenger seat. The measurements were taken with a Ludlum 44-10 2-inch by
2-inch gamma scintillation detector coupled with a Ludlum 2221 ratemeter/scaler. In each case the
detector was held about 15 inches above the seat and about 12 inches toward the dashboard from the
seat back, as shown in Figure 1. Once the indoor measurements were made the vehicles were moved
and then the gamma radiation intensities were re-measured. The results are summarized in Table 2.

1	https://www.fleet.ford.com/truckbbas/topics/2016/16_SD_Pickups_SB_Updates.pdf

2	http://articles.mcall.com/1984-09-01/news/2429550_l_pickup-bed-small-pickup-mazda

3	https://en.wikipedia.org/wiki/Toyota_Corolla_(E170)


-------
Table 2. Gamma Transmission Factor

Vehicle

Transmission Factor

2010 Honda Ridgeline extended cab

0.71 (95% CI: 0.69-0.73)

2014 Toyota Corolla

0.74 (95% CI: 0.72-0.77)

The 95% confidence intervals overlap, thus the gamma radiation transmission results for a Honda
Ridgeline and a Toyota Corolla should not be considered significantly different. Most modern pickups
are heavier than a 2010 Honda Ridgeline and most likely allow less gamma radiation transmission into
the vehicle. Few ranchers are expected to work out of very small sedans or very old small foreign
pickups. A gamma radiation transmission value of 0.7 is recommended. Based on the measurements
taken, it is not likely to greatly overestimate or underestimate the true gamma transmission factor for
pickups.

The specific measurement data is provided in Table 3.

Vehicle

Inside the vehicle

Background after vehicle moved



(gross counts in 1 minute)

(gross counts in 1 minute)



Driver side

Passenger side

Driver side

Passenger side

Honda Ridgeline

10,541

10,732

14,861

15,089

Toyota Corolla

10,732

11,140

14,452

15,058

Ludlum 2221 # 183990 with Ludlum 44-10 #RN 19764, cal date June 9, 2016


-------
Appendix I (Continued)

Human Health and Ecological Risk Evaluation
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Attachment 3
ProUCL Output


-------
Appendix I, Attachment 3
Section 10 Mine
ProUCL Output

UCL Statistics for Uncensored Full Data Sets

User Selected Options
Date/Time of Computation ProUCL 5.111/14/2019 3:53:54 PM
From File SectionIO summary tv.xls
Full Precision OFF
Confidence Coefficient 95%

Number of Bootstrap Operations 2000

Ra-226 SS

Total Number of Observations

Minimum
Maximum
SD

Coefficient of Variation

General Statistics

10

0.924
125.2
41.08
1.215

Number of Distinct Observations	10

Number of Missing Observations	0

Mean	33.81

Median	19.1

Std. Error of Mean	12.99

Skewness	1.538

Shapiro WilkTest Statistic
5% Shapiro Wilk Critical Value
LillieforsTest Statistic
5% Lilliefors Critical Value

Normal GOF Test

0.794
0.842
0.315
0.262

Shapiro Wilk GOF Test

Data Not Normal at 5% Significance Level
Lilliefors GOF Test

Data Not Normal at 5% Significance Level

Data Not Normal at 5% Significance Level

Assuming Normal Distribution

95% Normal UCL

95% Student's-t UCL 57.62

95% UCLs (Adjusted for Skewness)

95% Adjusted-CLT UCL (Chen-1995) 61.92
95% Modified-t UCL (Johnson-1978) 58.67

A-D Test Statistic
5% A-D Critical Value
K-S Test Statistic
5% K-S Critical Value

Gamma GOF Test
0.369	Anderson-Darling Gamma GOF Test

0.767 Detected data appear Gamma Distributed at 5% Significance Level
0.186	Kolmogorov-Smimov Gamma GOF Test

0.278 Detected data appear Gamma Distributed at 5% Significance Level

Detected data appear Gamma Distributed at 5% Significance Level

khat(MLE)
Theta hat (MLE)
nu hat (MLE)
MLE Mean (bias corrected)

Gamma Statistics

0.63
53.65
12.6
33.81

Adjusted Level of Significance 0.0267

k star (bias corrected MLE)
Theta star (bias corrected MLE)
nu star (bias corrected)
MLE Sd (bias corrected)
Approximate Chi Square Value (0.05)
Adjusted Chi Square Value

0.508
66.58
10.16
47.44
4.039
3.396

Assuming Gamma Distribution

95% Approximate Gamma UCL (use when n>=50) 85	95% Adjusted Gamma UCL (use when n<50) 101.1

Lognormal GOF Test

Shapiro WilkTest Statistic 0.891	Shapiro Wilk Lognormal GOF Test

5% Shapiro Wilk Critical Value 0.842	Data appear Lognormal at 5% Significance Level

Lilliefors Test Statistic 0.232	Lilliefors Lognormal GOF Test

5% Lilliefors Critical Value 0.262	Data appear Lognormal at 5% Significance Level

Data appear Lognormal at 5% Significance Level

Minimum of Logged Data
Maximum of Logged Data

Lognormal Statistics

-0.079
4.83

Assuming Lognormal Distribution

95% H-UCL 1015
95% Chebyshev (MVUE) UCL 158.3
99% Chebyshev (MVUE) UCL 304

Mean of logged Data 2.547
SD of logged Data 1.76

90% Chebyshev (MVUE) UCL 122.9
97.5% Chebyshev (MVUE) UCL 207.5

Section 10 Mine EE/CA Report - Appendix I

1 of 3

TDD No. 0001/17-044


-------
Nonparametric Distribution Free UCL Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level

Nonparametric Distribution Free UCLs

95% CLT UCL

55.17

95% Jackknife

UCL

57.62

95% Standard Bootstrap UCL

54.4

95% Bootstrap-t

UCL

83.2

95% Hall's Bootstrap UCL

94.46

95% Percentile Bootstrap

UCL

53.97

95% BCA Bootstrap UCL

60.44







90% Chebyshev(Mean, Sd) UCL

72.78

95% Chebyshev(Mean, Sd)

UCL

90.43

97.5% Chebyshev(Mean, Sd) UCL

114.9

99% Chebyshev(Mean, Sd)

UCL

163.1

Suggested UCL to Use

95% Adjusted Gamma UCL 101.1

Note: Suggestions regarding the selection of a 95% UCL are provided to help the user to select the most appropriate 95% UCL.

Recommendations are based upon data size, data distribution, and skewness.

These recommendations are based upon the results of the simulation studies summarized in Singh, Maichle, and Lee (2006).
However, simulations results will not cover all Real World data sets; for additional insight the user may want to consult a statistician.

Ra-226 SB

Total Number of Observations

Minimum
Maximum
SD

Coefficient of Variation

General Statistics

10

1.95
4.643
0.79
0.264

Number of Distinct Observations	10

Number of Missing Observations	0

Mean	2.999

Median	3.129

Std. Error of Mean	0.25

Skewness	0.668

Shapiro Wilk Test Statistic
5% Shapiro Wilk Critical Value
LillieforsTest Statistic
5% Lilliefors Critical Value

Normal GOF Test

0.918
0.842
0.219
0.262

Shapiro Wilk GOF Test

Data appear Normal at 5% Significance Level
Lilliefors GOF Test

Data appear Normal at 5% Significance Level

Data appear Normal at 5% Significance Level

Assuming Normal Distribution

95% Normal UCL

95% Student's-t UCL 3.457

95% UCLs (Adjusted for Skewness)

95% Adjusted-CLT UCL (Chen-1995) 3.467
95% Modified-t UCL (Johnson-1978) 3.466

A-D Test Statistic
5% A-D Critical Value
K-S Test Statistic
5% K-S Critical Value

Gamma GOF Test
0.376	Anderson-Darling Gamma GOF Test

0.725 Detected data appear Gamma Distributed at 5% Significance Level
0.194	Kolmogorov-Smimov Gamma GOF Test

0.266 Detected data appear Gamma Distributed at 5% Significance Level

Detected data appear Gamma Distributed at 5% Significance Level

khat (MLE)
Theta hat (MLE)
nu hat (MLE)
MLE Mean (bias corrected)

Gamma Statistics

16.39
0.183
327.8
2.999

Adjusted Level of Significance 0.0267

k star (bias corrected M LE)	11.54

Theta star (bias corrected MLE)	0.26

nu star (bias corrected)	230.8

MLE Sd (bias corrected)	0.883

Approximate Chi Square Value (0.05)	196.7

Adjusted Chi Square Value	191.2

Assuming Gamma Distribution

95% Approximate Gamma UCL (use when n>=50)) 3.52	95% Adjusted Gamma UCL (use when n<50)

3.621

Shapiro Wilk Test Statistic
5% Shapiro Wilk Critical Value
Lilliefors Test Statistic
5% Lilliefors Critical Value

Lognormal GOF Test

0.94	Shapiro Wilk Lognormal GOF Test

0.842	Data appear Lognormal at 5% Significance Level

0.196	Lilliefors Lognormal GOF Test

0.262	Data appear Lognormal at 5% Significance Level

Data appear Lognormal at 5% Significance Level

Lognormal Statistics

Section 10 Mine EE/CA Report - Appendix I

2 of 3

TDD No. 0001/17-044


-------
Minimum of Logged Data 0.668	Mean of logged Data

Maximum of Logged Data 1.535	SD of logged Data

1.067
0.262

Assuming Lognormal Distribution

95% H-UCL 3.565	90% Chebyshev (MVUE) UCL 3.748

95% Chebyshev (MVUE) UCL 4.088	97.5% Chebyshev (MVUE) UCL 4.559

99% Chebyshev (MVUE) UCL 5.485

Nonparametric Distribution Free UCL Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level

Nonparametric Distribution Free UCLs

95% CLT UCL

3.41

95% Jackknife

UCL

3.457

95% Standard Bootstrap UCL

3.38

95% Bootstrap-t

UCL

3.516

95% Hall's Bootstrap UCL

3.576

95% Percentile Bootstrap

UCL

3.42

95% BCA Bootstrap UCL

3.432







90% Chebyshev(Mean, Sd) UCL

3.749

95% Chebyshev(Mean, Sd)

UCL

4.089

97.5% Chebyshev(Mean, Sd) UCL

4.56

99% Chebyshev(Mean, Sd)

UCL

5.486

Suggested UCL to Use

95% Student's-t UCL 3.457

Note: Suggestions regarding the selection of a 95% UCL are provided to help the user to select the most appropriate 95% UCL.

Recommendations are based upon data size, data distribution, and skewness.

These recommendations are based upon the results of the simulation studies summarized in Singh, Maichle, and Lee (2006).
However, simulations results will not cover all Real World data sets; for additional insight the user may want to consult a statistician.

Section 10 Mine EE/CA Report - Appendix I

3 of 3

TDD No. 0001/17-044


-------
APPENDIX J

PRG CALCULATOR OUT, DCGL AND RA-226 CONTRIBUTION CALCULATIONS,

AND RESRAD OUTPUT


-------
This page intentionally left blank.


-------
PRG Calculator Output


-------
Site-Specific	1

Composite Worker Soil Inputs - Secular Equilibrium

* Inputted values different from Composite Worker defaults are highlighted.



Composite





Worker





Soil





Default

Form-input

Variable

Value

Value

A (PEF Dispersion Constant)

16.2302

14.9421

B (PEF Dispersion Constant)

18.7762

17.9869

City (Climate Zone)

Default

Albuquerque, NM (3)

C (PEF Dispersion Constant)

216.108

205.1782

F(x) (function dependent on U m/U,) unitless

0.194

0.0553

PEF (particulate emission factor) m 3/kg

1359344438

2370938158.760359

Q/C„_h (g/m2-s per kg/m3)

93.77

29.359877603759233

A (acres)

0.5

500

ED„ (exposure duration - composite worker) yr

25

25

EF„ (exposure frequency - composite worker) dayfyr

250

250

ET (exposure time - composite worker) hr/day

8

0.8

IRA, (inhalation rate - composite worker) m 3/day

60

60

IRS, (soil intake rate - composite worker) mg/day

100

100

t„ (time - composite worker) yr

25

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker PRGs for Soil - Secular Equilibrium

2

External

Ingestion	Inhalation Exposure	Total

PRG	PRG	PRG	PRG

TR=0.0001	TR=0.0001 TR=0.0001	TR=0.0001

Isotope (pCi/g)	(pCi/g)	(pCi/g)	(pCi/g)

*Secular Equilibrium PRG for U-235 2.91E+02	6.03E+04	7.51E+01	5.97E+01

*Secular Equilibrium PRG for U-238 6.35E+01	1.31E+05	2.06E+01	1.56E+01

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Contribution PRGs for Soil - Secular Equilibrium

3











External



















Exposure

Adult

















Slope

Soil













ICRP

Inhalation

Factor

Ingestion

Particulate









Fractional

Lung

Slope

(risktyr

Slope

Emission









Contribution Absorption

Factor

per

Factor

Factor

Lambda

Halflife

Isotope

Parent

of Progeny

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(m3/kg)

(1/yr)

(yr)

*Secular Equilibrium PRG for U-235

U-235

-



-

-

-

-

-

-

Ac-227

U-235

1.00E+00

S

1.49E-07

1.98E-10

2.01E-10

2.37E+09

3.18E-02

2.18E+01

At-219

U-235

8.28E-07

-

0.00E+00

0.00E+00

0.00E+00

2.37E+09

3.90E+05

1.78E-06

Bi-211

U-235

1.00E+00

-

0.00E+00

1.90E-07

0.00E+00

2.37E+09

1.70E+05

4.07E-06

Bi-215

U-235

8.03E-07

-

0.00E+00

1.08E-06

0.00E+00

2.37E+09

4.79E+04

1.45E-05

Fr-223

U-235

1.38E-02

s

4.07E-11

1.35E-07

4.88E-12

2.37E+09

1.66E+04

4.19E-05

Pa-231

U-235

1.00E+00

F

7.62E-08

1.27E-07

1.54E-10

2.37E+09

2.12E-05

3.28E+04

Pb-211

U-235

1.00E+00

S

4.03E-11

2.91 E-07

2.63E-13

2.37E+09

1.01E+04

6.87E-05

Po-211

U-235

2.76E-03

-

0.00E+00

3.76E-08

0.00E+00

2.37E+09

4.24E+07

1.64E-08

Po-215

U-235

1.00E+00

-

0.00E+00

7.48E-10

0.00E+00

2.37E+09

1.23E+10

5.65E-11

Ra-223

U-235

1.00E+00

s

2.92E-08

4.55E-07

1.23E-10

2.37E+09

2.21E+01

3.13E-02

Rn-219

U-235

1.00E+00

-

0.00E+00

2.35E-07

0.00E+00

2.37E+09

5.52E+06

1.26E-07

Th-227

U-235

9.86E-01

s

3.50E-08

4.45E-07

2.06E-11

2.37E+09

1.35E+01

5.12E-02

Th-231

U-235

1.00E+00

s

1.50E-12

2.49E-08

9.07E-13

2.37E+09

2.38E+02

2.91 E-03

TI-207

U-235

9.97E-01

-

0.00E+00

1.59E-08

0.00E+00

2.37E+09

7.64E+04

9.08E-06

U-235

U-235

1.00E+00

s

2.50E-08

5.51 E-07

4.92E-11

2.37E+09

9.84E-10

7.04E+08

*Secular Equilibrium PRG for U-238

U-238

-



-

-

-

-

-

-

At-218

U-238

2.00E-04

-

0.00E+00

2.74E-11

0.00E+00

2.37E+09

1.46E+07

4.76E-08

Bi-210

U-238

1.00E+00

s

4.55E-10

2.77E-09

3.74E-12

2.37E+09

5.05E+01

1.37E-02

Bi-214

U-238

1.00E+00

s

6.18E-11

7.34E-06

1.47E-13

2.37E+09

1.83E+04

3.79E-05

Hg-206

U-238

1.90E-08

-

0.00E+00

4.83E-07

0.00E+00

2.37E+09

4.47E+04

1.55E-05

Pa-234

U-238

1.60E-03

s

1.20E-12

6.62E-06

9.66E-13

2.37E+09

9.06E+02

7.65E-04

Pa-234m

U-238

1.00E+00

-

0.00E+00

9.06E-08

0.00E+00

2.37E+09

3.11E+05

2.23E-06

Pb-210

U-238

1.00E+00

s

1.59E-08

1.48E-09

5.99E-10

2.37E+09

3.12E-02

2.22E+01

Pb-214

U-238

1.00E+00

s

7.77E-11

9.94E-07

2.21E-13

2.37E+09

1.36E+04

5.10E-05

Po-210

U-238

1.00E+00

s

1.45E-08

4.51 E-11

1.44E-09

2.37E+09

1.83E+00

3.79E-01

Po-214

U-238

1.00E+00

-

0.00E+00

3.85E-10

0.00E+00

2.37E+09

1.33E+11

5.21E-12

Po-218

U-238

1.00E+00

-

1.39E-11

6.84E-15

0.00E+00

2.37E+09

1.17E+05

5.90E-06

Ra-226

U-238

1.00E+00

s

2.82E-08

2.50E-08

2.95E-10

2.37E+09

4.33E-04

1.60E+03

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Contribution PRGs for Soil - Secular Equilibrium

4



1000029















m2

0 cm













Soil

Soil





External







Volume

Volume

Ingestion

Inhalation

Exposure

Total

Total



Area

Gamma

PRG

PRG

PRG

PRG

PRG



Correction Shielding

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

Isotope

Factor

Factor

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(mg/kg)

*Secular Equilibrium PRG for U-235

-

-

2.91E+02

6.03E+04

7.51 E+01

5.97E+01

-

Ac-227

1.00E+00

1.00E+00

7.95E+02

1.27E+05

8.83E+05

7.89E+02

1.75E-11

At-219

9.00E-01

1.00E+00

-

-

-

-

-

Bi-211

1.00E+00

1.00E+00

-

-

9.21 E+02

9.21 E+02

2.61E-18

Bi-215

1.00E+00

1.00E+00

-

-

2.01 E+08

2.01 E+08

4.32E-23

Fr-223

1.00E+00

1.00E+00

2.37E+06

3.38E+10

9.37E+04

9.02E+04

2.90E-19

Pa-231

1.00E+00

1.00E+00

1.04E+03

2.49E+05

1.38E+03

5.90E+02

3.59E-08

Pb-211

1.00E+00

1.00E+00

6.09E+05

4.70E+08

6.03E+02

6.02E+02

6.74E-17

Po-211

1.00E+00

1.00E+00

-

-

1.69E+06

1.69E+06

5.73E-24

Po-215

1.00E+00

1.00E+00

-

-

2.34E+05

2.34E+05

1.45E-25

Ra-223

1.00E+00

1.00E+00

1.30E+03

6.50E+05

3.85E+02

2.97E+02

6.59E-14

Rn-219

1.00E+00

1.00E+00

-

-

7.47E+02

7.47E+02

1.03E-19

Th-227

1.00E+00

1.00E+00

7.87E+03

5.49E+05

3.99E+02

3.80E+02

8.56E-14

Th-231

1.00E+00

1.00E+00

1.77E+05

1.26E+10

7.04E+03

6.77E+03

2.78E-16

TI-207

1.00E+00

1.00E+00

-

-

1.11E+04

1.11E+04

4.75E-19

U-235

1.00E+00

1.00E+00

3.25E+03

7.58E+05

3.18E+02

2.89E+02

1.60E-03

*Secular Equilibrium PRG for U-238

-

-

6.35E+01

1.31E+05

2.06E+01

1.56E+01

-

At-218

9.00E-01

1.00E+00

-

-

3.55E+10

3.55E+10

8.18E-28

Bi-210

1.00E+00

1.00E+00

4.28E+04

4.17E+07

6.33E+04

2.55E+04

3.16E-16

Bi-214

1.00E+00

1.00E+00

1.09E+06

3.07E+08

2.39E+01

2.39E+01

9.51 E-16

Hg-206

1.00E+00

1.00E+00

-

-

1.91E+10

1.91E+10

4.69E-25

Pa-234

1.00E+00

1.00E+00

1.04E+08

9.89E+12

1.65E+04

1.65E+04

3.03E-17

Pa-234m

1.00E+00

1.00E+00

-

-

1.93E+03

1.93E+03

7.54E-19

Pb-210

1.00E+00

1.00E+00

2.67E+02

1.19E+06

1.18E+05

2.66E+02

4.90E-11

Pb-214

1.00E+00

1.00E+00

7.26E+05

2.44E+08

1.76E+02

1.76E+02

1.73E-16

Po-210

1.00E+00

1.00E+00

1.11E+02

1.31E+06

3.89E+06

1.11E+02

2.00E-12

Po-214

1.00E+00

1.00E+00

-

-

4.55E+05

4.55E+05

6.86E-27

Po-218

9.00E-01

1.00E+00

-

1.36E+09

2.85E+10

1.30E+09

2.76E-24

Ra-226

1.00E+00

1.00E+00

5.43E+02

6.74E+05

7.01 E+03

5.04E+02

2.01 E-09

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Contribution PRGs for Soil - Secular Equilibriu

External

Exposure Adult













Slope

Soil















ICRP

Inhalation

Factor

Ingestion

Particulate











Fractional

Lung

Slope

(riskfyr

Slope

Emission











Contribution Absorption

Factor

per

Factor

Factor

Lambda

Halflife



Isotope

Parent

of Progeny

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(m3/kg)

(1/yr)

(yr)

Rn-218



U-238

2.00E-07

-

0.00E+00

3.39E-09

0.00E+00

2.37E+09

6.24E+08

1.11E-09

Rn-222



U-238

1.00E+00

-

2.28E-12

1.69E-09

0.00E+00

2.37E+09

6.62E+01

1.05E-02

Th-230



U-238

1.00E+00

F

3.41 E-08

8.45E-10

7.73E-11

2.37E+09

9.19E-06

7.54E+04

Th-234



U-238

1.00E+00

S

3.08E-11

1.77E-08

9.51 E-12

2.37E+09

1.05E+01

6.60E-02

TI-206



U-238

1.34E-06

-

0.00E+00

6.11E-09

0.00E+00

2.37E+09

8.67E+04

7.99E-06

TI-210



U-238

2.10E-04

-

0.00E+00

1.34E-05

0.00E+00

2.37E+09

2.80E+05

2.47E-06

U-234



U-238

1.00E+00

s

2.78E-08

2.53E-10

5.11 E-11

2.37E+09

2.82E-06

2.46E+05

U-238



U-238

1.00E+00

s

2.36E-08

1.24E-10

4.66E-11

2.37E+09

1.55E-10

4.47E+09

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Contribution PRGs for Soil - Secular Equilibrium

6





1000029

















m2

0 cm















Soil

Soil





External









Volume

Volume

Ingestion

Inhalation

Exposure

Total

Total





Area

Gamma

PRG

PRG

PRG

PRG

PRG





Correction

Shielding

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001



Isotope

Factor

Factor

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(mg/kg)

Rn-218



1.00E+00

1.00E+00

-

-

2.59E+11

2.59E+11

2.62E-30

Rn-222



1.00E+00

1.00E+00

-

8.32E+09

1.03E+05

1.03E+05

6.29E-17

Th-230



1.00E+00

1.00E+00

2.07E+03

5.57E+05

2.07E+05

2.04E+03

2.38E-08

Th-234



1.00E+00

1.00E+00

1.68E+04

6.16E+08

9.87E+03

6.22E+03

6.95E-15

TI-206



1.00E+00

1.00E+00

-

-

2.14E+10

2.14E+10

2.15E-25

TI-210



1.00E+00

1.00E+00

-

-

6.21 E+04

6.21 E+04

2.34E-20

U-234



1.00E+00

1.00E+00

3.13E+03

6.82E+05

6.91 E+05

3.11E+03

5.18E-08

U-238



1.00E+00

1.00E+00

3.43E+03

8.02E+05

1.42E+06

3.41 E+03

8.73E-04

Output generated 22MAY2019:10:31:51


-------
Site-Specific	1

Composite Worker Risk for Soil - Secular Equilibrium

Isotope

External

Ingestion Inhalation Exposure
Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

1.37E-08 6.63E-11 5.32E-08

6.70E-08

*Secular Equilibrium Risk for U-238

1.57E-06 7.63E-10 4.85E-06

6.42E-06

*Total Risk

1.59E-06 8.29E-10 4.90E-06

6.49E-06



Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Risk Contributions for Soil - Secular Equilibrium







External

















Exposure

Adult















Slope

Soil











ICRP

Inhalation

Factor

Ingestion



Particulate







Lung

Slope

(risktyr

Slope



Emission







Absorption

Factor

per

Factor

Concentration

Factor

Lambda

Halflife

Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

*Secular Equilibrium Risk for U-235 ... ....

Ac-227

S

1.49E-07

1.98E-10

2.01E-10

0.04

2.37E+09

3.18E-02

2.18E+01

At-219

-

0.00E+00

0.00E+00

0.00E+00

0.04

2.37E+09

3.90E+05

1.78E-06

Bi-211

-

0.00E+00

1.90E-07

0.00E+00

0.04

2.37E+09

1.70E+05

4.07E-06

Bi-215

-

0.00E+00

1.08E-06

0.00E+00

0.04

2.37E+09

4.79E+04

1.45E-05

Fr-223

s

4.07E-11

1.35E-07

4.88E-12

0.04

2.37E+09

1.66E+04

4.19E-05

Pa-231

F

7.62E-08

1.27E-07

1.54E-10

0.04

2.37E+09

2.12E-05

3.28E+04

Pb-211

S

4.03E-11

2.91 E-07

2.63E-13

0.04

2.37E+09

1.01E+04

6.87E-05

Po-211

-

0.00E+00

3.76E-08

0.00E+00

0.04

2.37E+09

4.24E+07

1.64E-08

Po-215

-

0.00E+00

7.48E-10

0.00E+00

0.04

2.37E+09

1.23E+10

5.65E-11

Ra-223

s

2.92E-08

4.55E-07

1.23E-10

0.04

2.37E+09

2.21E+01

3.13E-02

Rn-219

-

0.00E+00

2.35E-07

0.00E+00

0.04

2.37E+09

5.52E+06

1.26E-07

Th-227

s

3.50E-08

4.45E-07

2.06E-11

0.04

2.37E+09

1.35E+01

5.12E-02

Th-231

s

1.50E-12

2.49E-08

9.07E-13

0.04

2.37E+09

2.38E+02

2.91 E-03

TI-207

-

0.00E+00

1.59E-08

0.00E+00

0.04

2.37E+09

7.64E+04

9.08E-06

U-235

s

2.50E-08

5.51 E-07

4.92E-11

0.04

2.37E+09

9.84E-10

7.04E+08

*Secular Equilibrium Risk for U-238 ... ....

At-218

-

0.00E+00

2.74E-11

0.00E+00

1

2.37E+09

1.46E+07

4.76E-08

Bi-210

s

4.55E-10

2.77E-09

3.74E-12

1

2.37E+09

5.05E+01

1.37E-02

Bi-214

s

6.18E-11

7.34E-06

1.47E-13

1

2.37E+09

1.83E+04

3.79E-05

Hg-206

-

0.00E+00

4.83E-07

0.00E+00

1

2.37E+09

4.47E+04

1.55E-05

Pa-234

s

1.20E-12

6.62E-06

9.66E-13

1

2.37E+09

9.06E+02

7.65E-04

Pa-234m

-

0.00E+00

9.06E-08

0.00E+00

1

2.37E+09

3.11E+05

2.23E-06

Pb-210

s

1.59E-08

1.48E-09

5.99E-10

1

2.37E+09

3.12E-02

2.22E+01

Pb-214

s

7.77E-11

9.94E-07

2.21E-13

1

2.37E+09

1.36E+04

5.10E-05

Po-210

s

1.45E-08

4.51 E-11

1.44E-09

1

2.37E+09

1.83E+00

3.79E-01

Po-214

-

0.00E+00

3.85E-10

0.00E+00

1

2.37E+09

1.33E+11

5.21E-12

Po-218

-

1.39E-11

6.84E-15

0.00E+00

1

2.37E+09

1.17E+05

5.90E-06

Ra-226

s

2.82E-08

2.50E-08

2.95E-10

1

2.37E+09

4.33E-04

1.60E+03

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Risk Contributions for Soil - Secular Equilibrium

9

1000029

m2 0 cm
Soil Soil
Volume Volume External
Area Gamma Ingestion Inhalation Exposure External
Correction Shielding CDI CDI CDI Ingestion Inhalation Exposure Total
Factor Factor (pCi) (pCi) (pCi) Risk Risk Risk Risk

- 1.37E-08 6.63E-11 5.32E-08

6.70E-08

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 5.03E-09 3.15E-11 4.53E-12

5.07E-09

9.00E-01 1.00E+00 2.50E+01 2.11E-04 2.05E-02 0.00E+00 0.00E+00 0.00E+00

0.00E+00

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 4.35E-09

4.35E-09

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 1.99E-14

1.99E-14

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 1.68E-12 1.18E-16 4.27E-11

4.44E-11

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 3.86E-09 1.61E-11 2.91 E-09

6.78E-09

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 6.57E-12 8.51E-15 6.64E-09

6.64E-09

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 2.37E-12

2.37E-12

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 1.71E-11

1.71 E-11

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 3.08E-09 6.16E-12 1.04E-08

1.35E-08

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 5.36E-09

5.36E-09

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 5.08E-10 7.28E-12 1.00E-08

1.05E-08

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 2.27E-11 3.17E-16 5.68E-10

5.90E-10

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 0.00E+00 0.00E+00 3.62E-10

3.62E-10

1.00E+00 1.00E+00 2.50E+01 2.11E-04 2.28E-02 1.23E-09 5.27E-12 1.26E-08

1.38E-08

- 1.57E-06 7.63E-10 4.85E-06

6.42E-06

9.00E-01 1.00E+00 6.25E+02 5.27E-03 5.14E-01 0.00E+00 0.00E+00 2.82E-15

2.82E-15

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 2.34E-09 2.40E-12 1.58E-09

3.92E-09

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71E-01 9.20E-11 3.26E-13 4.19E-06

4.19E-06

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 0.00E+00 0.00E+00 5.24E-15

5.24E-15

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 9.66E-13 1.01E-17 6.05E-09

6.05E-09

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 0.00E+00 0.00E+00 5.17E-08

5.17E-08

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 3.75E-07 8.37E-11 8.46E-10

3.76E-07

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71E-01 1.38E-10 4.10E-13 5.67E-07

5.67E-07

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 8.97E-07 7.65E-11 2.57E-11

8.97E-07

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 0.00E+00 0.00E+00 2.20E-10

2.20E-10

9.00E-01 1.00E+00 6.25E+02 5.27E-03 5.14E-01 0.00E+00 7.33E-14 3.51 E-15

7.68E-14

1.00E+00 1.00E+00 6.25E+02 5.27E-03 5.71 E-01 1.84E-07 1.48E-10 1.43E-08

1.98E-07

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Risk Contributions for Soil - Secular Equilibrium

External

Exposure Adult









Slope

Soil













ICRP

Inhalation

Factor

Ingestion



Particulate









Lung

Slope

(riskfyr

Slope



Emission









Absorption

Factor

per

Factor

Concentration

Factor

Lambda

Halflife



Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

Rn-218



-

0.00E+00

3.39E-09

0.00E+00

1

2.37E+09

6.24E+08

1.11E-09

Rn-222



-

2.28E-12

1.69E-09

0.00E+00

1

2.37E+09

6.62E+01

1.05E-02

Th-230



F

3.41 E-08

8.45E-10

7.73E-11

1

2.37E+09

9.19E-06

7.54E+04

Th-234



S

3.08E-11

1.77E-08

9.51 E-12

1

2.37E+09

1.05E+01

6.60E-02

TI-206



-

0.00E+00

6.11E-09

0.00E+00

1

2.37E+09

8.67E+04

7.99E-06

TI-210



-

0.00E+00

1.34E-05

0.00E+00

1

2.37E+09

2.80E+05

2.47E-06

U-234



s

2.78E-08

2.53E-10

5.11 E-11

1

2.37E+09

2.82E-06

2.46E+05

U-230



s

2.36E-08

1.24E-10

4.66E-11

1

2.37E+09

1.55E-10

4.47E+09

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Composite Worker Individual Risk Contributions for Soil - Secular Equilibrium

1000029

m2	0 cm

Soil	Soil

Volume	Volume External

Area	Gamma Ingestion Inhalation Exposure	External

Correction Shielding

CDI

CDI

CDI

Ingestion Inhalation Exposure

Total

Factor

Factor

(pCi)

(pCi)

(pCi)

Risk

Risk

Risk

Risk

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

0.00E+00

0.00E+00

3.87E-16

3.87E-16

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

0.00E+00

1.20E-14

9.66E-10

9.66E-10

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

4.83E-08

1.80E-10

4.83E-10

4.90E-08

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

5.94E-09

1.62E-13

1.01 E-08

1.61 E-08

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

0.00E+00

0.00E+00

4.67E-15

4.67E-15

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

0.00E+00

0.00E+00

1.61E-09

1.61 E-09

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

3.19E-08

1.47E-10

1.45E-10

3.22E-08

1.00E+00

1.00E+00

6.25E+02

5.27E-03

5.71 E-01

2.91 E-08

1.25E-10

7.06E-11

2.93E-08

Output generated 22MAY2019:10:31:51


-------
Site-Specific

Indoor Worker Soil Inputs - Secular Equilibrium

* Inputted values different from Indoor Worker defaults are highlighted.



Indoor





Worker





Soil





Default

Form-input

Variable

Value

Value

A (PEF Dispersion Constant)

16.2302

14.9421

B (PEF Dispersion Constant)

18.7762

17.9869

City (Climate Zone)

Default

Albuquerque, NM (3)

C (PEF Dispersion Constant)

216.108

205.1782

F(x) (function dependent on U m/U,) unitless

0.194

0.0553

PEF (particulate emission factor) m 3/kg

1359344438

6609630249.811598

Q/C„_h (g/m2-s per kg/m3)

93.77

81.84858572694108

A„ (acres)

0.5

0.5

ED,,, (exposure duration - indoor worker) yr

25

25

EF.„ (exposure frequency - indoor worker) dayfyr

250

250

ET„ (exposure time - indoor worker) hr/day

8

0.8

GSF; (indoor gamma shielding factor) unitless

0.4

0.7

IRA,, (inhalation rate - indoor worker) m 3/day

60

0

IRS (soil intake rate - indoor worker) mg/day

50

0

t„ (time - indoor worker) yr

25

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Output generated 22MAY2019:10:38:56

1


-------
Site-Specific

Indoor Worker PRGs for Soil - Secular Equilibrium

2

External

Ingestion	Inhalation	Exposure	Total

PRG	PRG	PRG	PRG

TR=0.0001	TR=0.0001	TR=0.0001	TR=0.0001

Isotope (pCi/g)	(pCi/g)	(pCi/g)	(pCi/g)

*Secular Equilibrium PRG for U-235 -	-	1.07E+02	1.07E+02

*Secular Equilibrium PRG for U-238 -	-	2.95E+01	2.95E+01

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Contribution PRGs for Soil - Secular Equilibrium

3











External



















Exposure

Adult

















Slope

Soil













ICRP

Inhalation

Factor

Ingestion

Particulate









Fractional

Lung

Slope

(risktyr

Slope

Emission









Contribution Absorption

Factor

per

Factor

Factor

Lambda

Halflife

Isotope

Parent

of Progeny

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(m3/kg)

(1/yr)

(yr)

*Secular Equilibrium PRG for U-235

U-235

-



-

-

-

-

-

-

Ac-227

U-235

1.00E+00

S

1.49E-07

1.98E-10

2.01E-10

6.61 E+09

3.18E-02

2.18E+01

At-219

U-235

8.28E-07

-

0.00E+00

0.00E+00

0.00E+00

6.61 E+09

3.90E+05

1.78E-06

Bi-211

U-235

1.00E+00

-

0.00E+00

1.90E-07

0.00E+00

6.61 E+09

1.70E+05

4.07E-06

Bi-215

U-235

8.03E-07

-

0.00E+00

1.08E-06

0.00E+00

6.61 E+09

4.79E+04

1.45E-05

Fr-223

U-235

1.38E-02

s

4.07E-11

1.35E-07

4.88E-12

6.61 E+09

1.66E+04

4.19E-05

Pa-231

U-235

1.00E+00

F

7.62E-08

1.27E-07

1.54E-10

6.61 E+09

2.12E-05

3.28E+04

Pb-211

U-235

1.00E+00

S

4.03E-11

2.91 E-07

2.63E-13

6.61 E+09

1.01E+04

6.87E-05

Po-211

U-235

2.76E-03

-

0.00E+00

3.76E-08

0.00E+00

6.61 E+09

4.24E+07

1.64E-08

Po-215

U-235

1.00E+00

-

0.00E+00

7.48E-10

0.00E+00

6.61 E+09

1.23E+10

5.65E-11

Ra-223

U-235

1.00E+00

s

2.92E-08

4.55E-07

1.23E-10

6.61 E+09

2.21E+01

3.13E-02

Rn-219

U-235

1.00E+00

-

0.00E+00

2.35E-07

0.00E+00

6.61 E+09

5.52E+06

1.26E-07

Th-227

U-235

9.86E-01

s

3.50E-08

4.45E-07

2.06E-11

6.61 E+09

1.35E+01

5.12E-02

Th-231

U-235

1.00E+00

s

1.50E-12

2.49E-08

9.07E-13

6.61 E+09

2.38E+02

2.91 E-03

TI-207

U-235

9.97E-01

-

0.00E+00

1.59E-08

0.00E+00

6.61 E+09

7.64E+04

9.08E-06

U-235

U-235

1.00E+00

s

2.50E-08

5.51 E-07

4.92E-11

6.61 E+09

9.84E-10

7.04E+08

*Secular Equilibrium PRG for U-238

U-238

-



-

-

-

-

-

-

At-218

U-238

2.00E-04

-

0.00E+00

2.74E-11

0.00E+00

6.61 E+09

1.46E+07

4.76E-08

Bi-210

U-238

1.00E+00

s

4.55E-10

2.77E-09

3.74E-12

6.61 E+09

5.05E+01

1.37E-02

Bi-214

U-238

1.00E+00

s

6.18E-11

7.34E-06

1.47E-13

6.61 E+09

1.83E+04

3.79E-05

Hg-206

U-238

1.90E-08

-

0.00E+00

4.83E-07

0.00E+00

6.61 E+09

4.47E+04

1.55E-05

Pa-234

U-238

1.60E-03

s

1.20E-12

6.62E-06

9.66E-13

6.61 E+09

9.06E+02

7.65E-04

Pa-234m

U-238

1.00E+00

-

0.00E+00

9.06E-08

0.00E+00

6.61 E+09

3.11E+05

2.23E-06

Pb-210

U-238

1.00E+00

s

1.59E-08

1.48E-09

5.99E-10

6.61 E+09

3.12E-02

2.22E+01

Pb-214

U-238

1.00E+00

s

7.77E-11

9.94E-07

2.21E-13

6.61 E+09

1.36E+04

5.10E-05

Po-210

U-238

1.00E+00

s

1.45E-08

4.51 E-11

1.44E-09

6.61 E+09

1.83E+00

3.79E-01

Po-214

U-238

1.00E+00

-

0.00E+00

3.85E-10

0.00E+00

6.61 E+09

1.33E+11

5.21E-12

Po-218

U-238

1.00E+00

-

1.39E-11

6.84E-15

0.00E+00

6.61 E+09

1.17E+05

5.90E-06

Ra-226

U-238

1.00E+00

s

2.82E-08

2.50E-08

2.95E-10

6.61 E+09

4.33E-04

1.60E+03

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Contribution PRGs for Soil - Secular Equilibrium

1000029

m2	0 cm

Soil	Soil Total External

Volume	Volume Indoor Ingestion Inhalation Exposure Total Total

Area	Gamma GSF PRG PRG	PRG	PRG	PRG

Correction Shielding Soil TR=0.0001 TR=0.0001 TR=0.0001 TR=0.0001 TR=0.0001

Isotope

Factor

Factor

Volume (pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(mg/kg)

*Secular Equilibrium PRG for U-235

-

-

-

-

1.07E+02

1.07E+02

-

Ac-227

1.00E+00

1.00E+00

7.00E-01

-

1.26E+06

1.26E+06

1.10E-14

At-219

9.00E-01

1.00E+00

7.00E-01

-

-

-

-

Bi-211

1.00E+00

1.00E+00

7.00E-01

-

1.32E+03

1.32E+03

1.83E-18

Bi-215

1.00E+00

1.00E+00

7.00E-01

-

2.88E+08

2.88E+08

3.03E-23

Fr-223

1.00E+00

1.00E+00

7.00E-01

-

1.34E+05

1.34E+05

1.95E-19

Pa-231

1.00E+00

1.00E+00

7.00E-01

-

1.97E+03

1.97E+03

1.08E-08

Pb-211

1.00E+00

1.00E+00

7.00E-01

-

8.61 E+02

8.61 E+02

4.71 E-17

Po-211

1.00E+00

1.00E+00

7.00E-01

-

2.41 E+06

2.41 E+06

4.01 E-24

Po-215

1.00E+00

1.00E+00

7.00E-01

-

3.34E+05

3.34E+05

1.02E-25

Ra-223

1.00E+00

1.00E+00

7.00E-01

-

5.50E+02

5.50E+02

3.56E-14

Rn-219

1.00E+00

1.00E+00

7.00E-01

-

1.07E+03

1.07E+03

7.22E-20

Th-227

1.00E+00

1.00E+00

7.00E-01

-

5.70E+02

5.70E+02

5.70E-14

Th-231

1.00E+00

1.00E+00

7.00E-01

-

1.01E+04

1.01 E+04

1.87E-16

TI-207

1.00E+00

1.00E+00

7.00E-01

-

1.58E+04

1.58E+04

3.33E-19

U-235

1.00E+00

1.00E+00

7.00E-01

-

4.54E+02

4.54E+02

1.02E-03

*Secular Equilibrium PRG for U-238

-

-

-

-

2.95E+01

2.95E+01

-

At-218

9.00E-01

1.00E+00

7.00E-01

-

5.07E+10

5.07E+10

5.73E-28

Bi-210

1.00E+00

1.00E+00

7.00E-01

-

9.04E+04

9.04E+04

8.93E-17

Bi-214

1.00E+00

1.00E+00

7.00E-01

-

3.41 E+01

3.41 E+01

6.66E-16

Hg-206

1.00E+00

1.00E+00

7.00E-01

-

2.73E+10

2.73E+10

3.28E-25

Pa-234

1.00E+00

1.00E+00

7.00E-01

-

2.36E+04

2.36E+04

2.12E-17

Pa-234m

1.00E+00

1.00E+00

7.00E-01

-

2.76E+03

2.76E+03

5.28E-19

Pb-210

1.00E+00

1.00E+00

7.00E-01

-

1.69E+05

1.69E+05

7.73E-14

Pb-214

1.00E+00

1.00E+00

7.00E-01

-

2.52E+02

2.52E+02

1.21 E-16

Po-210

1.00E+00

1.00E+00

7.00E-01

-

5.55E+06

5.55E+06

4.01 E-17

Po-214

1.00E+00

1.00E+00

7.00E-01

-

6.50E+05

6.50E+05

4.81 E-27

Po-218

9.00E-01

1.00E+00

7.00E-01

-

4.06E+10

4.06E+10

8.86E-26

Ra-226

1.00E+00

1.00E+00

7.00E-01

-

1.00E+04

1.00E+04

1.01 E-10

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Contribution PRGs for Soil - Secular Equilibrium

External

Exposure Adult













Slope

Soil















ICRP

Inhalation

Factor

Ingestion

Particulate











Fractional

Lung

Slope

(riskfyr

Slope

Emission











Contribution Absorption

Factor

per

Factor

Factor

Lambda

Halflife



Isotope

Parent

of Progeny

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(m3/kg)

(1/yr)

(yr)

Rn-218



U-238

2.00E-07

-

0.00E+00

3.39E-09

0.00E+00

6.61 E+09

6.24E+08

1.11E-09

Rn-222



U-238

1.00E+00

-

2.28E-12

1.69E-09

0.00E+00

6.61 E+09

6.62E+01

1.05E-02

Th-230



U-238

1.00E+00

F

3.41 E-08

8.45E-10

7.73E-11

6.61 E+09

9.19E-06

7.54E+04

Th-234



U-238

1.00E+00

S

3.08E-11

1.77E-08

9.51 E-12

6.61 E+09

1.05E+01

6.60E-02

TI-206



U-238

1.34E-06

-

0.00E+00

6.11E-09

0.00E+00

6.61 E+09

8.67E+04

7.99E-06

TI-210



U-238

2.10E-04

-

0.00E+00

1.34E-05

0.00E+00

6.61 E+09

2.80E+05

2.47E-06

U-234



U-238

1.00E+00

s

2.78E-08

2.53E-10

5.11 E-11

6.61 E+09

2.82E-06

2.46E+05

U-238



U-238

1.00E+00

s

2.36E-08

1.24E-10

4.66E-11

6.61 E+09

1.55E-10

4.47E+09

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Contribution PRGs for Soil - Secular Equilibrium

6





1000029



















m2

0 cm

















Soil

Soil

Total





External









Volume

Volume

Indoor

Ingestion

Inhalation

Exposure

Total

Total





Area

Gamma

GSF

PRG

PRG

PRG

PRG

PRG





Correction

Shielding

Soil

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001



Isotope

Factor

Factor

Volume

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(mg/kg)

Rn-218



1.00E+00

1.00E+00

7.00E-01

-

-

3.70E+11

3.70E+11

1.83E-30

Rn-222



1.00E+00

1.00E+00

7.00E-01

-

-

1.48E+05

1.48E+05

4.40E-17

Th-230



1.00E+00

1.00E+00

7.00E-01

-

-

2.96E+05

2.96E+05

1.64E-10

Th-234



1.00E+00

1.00E+00

7.00E-01

-

-

1.41E+04

1.41 E+04

3.07E-15

TI-206



1.00E+00

1.00E+00

7.00E-01

-

-

3.06E+10

3.06E+10

1.51E-25

TI-210



1.00E+00

1.00E+00

7.00E-01

-

-

8.88E+04

8.88E+04

1.64E-20

U-234



1.00E+00

1.00E+00

7.00E-01

-

-

9.88E+05

9.88E+05

1.63E-10

U-238



1.00E+00

1.00E+00

7.00E-01

-

-

2.02E+06

2.02E+06

1.47E-06

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Risk for Soil - Secular Equilibrium

7

Isotope

External

Ingestion Inhalation Exposure Total
Risk Risk Risk Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 3.73E-08 3.73E-08

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 3.39E-06 3.39E-06

*Total Risk

0.00E+00 0.00E+00 3.43E-06 3.43E-06

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Risk Contributions for Soil - Secular Equilibrium







External

















Exposure

Adult















Slope

Soil











ICRP

Inhalation

Factor

Ingestion



Particulate







Lung

Slope

(risktyr

Slope



Emission







Absorption

Factor

per

Factor

Concentration

Factor

Lambda

Halflife

Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

*Secular Equilibrium Risk for U-235 ... ....

Ac-227

S

1.49E-07

1.98E-10

2.01E-10

0.04

6.61 E+09

3.18E-02

2.18E+01

At-219

-

0.00E+00

0.00E+00

0.00E+00

0.04

6.61 E+09

3.90E+05

1.78E-06

Bi-211

-

0.00E+00

1.90E-07

0.00E+00

0.04

6.61 E+09

1.70E+05

4.07E-06

Bi-215

-

0.00E+00

1.08E-06

0.00E+00

0.04

6.61 E+09

4.79E+04

1.45E-05

Fr-223

s

4.07E-11

1.35E-07

4.88E-12

0.04

6.61 E+09

1.66E+04

4.19E-05

Pa-231

F

7.62E-08

1.27E-07

1.54E-10

0.04

6.61 E+09

2.12E-05

3.28E+04

Pb-211

S

4.03E-11

2.91 E-07

2.63E-13

0.04

6.61 E+09

1.01E+04

6.87E-05

Po-211

-

0.00E+00

3.76E-08

0.00E+00

0.04

6.61 E+09

4.24E+07

1.64E-08

Po-215

-

0.00E+00

7.48E-10

0.00E+00

0.04

6.61 E+09

1.23E+10

5.65E-11

Ra-223

s

2.92E-08

4.55E-07

1.23E-10

0.04

6.61 E+09

2.21E+01

3.13E-02

Rn-219

-

0.00E+00

2.35E-07

0.00E+00

0.04

6.61 E+09

5.52E+06

1.26E-07

Th-227

s

3.50E-08

4.45E-07

2.06E-11

0.04

6.61 E+09

1.35E+01

5.12E-02

Th-231

s

1.50E-12

2.49E-08

9.07E-13

0.04

6.61 E+09

2.38E+02

2.91 E-03

TI-207

-

0.00E+00

1.59E-08

0.00E+00

0.04

6.61 E+09

7.64E+04

9.08E-06

U-235

s

2.50E-08

5.51 E-07

4.92E-11

0.04

6.61 E+09

9.84E-10

7.04E+08

*Secular Equilibrium Risk for U-238 ... ....

At-218

-

0.00E+00

2.74E-11

0.00E+00

1

6.61 E+09

1.46E+07

4.76E-08

Bi-210

s

4.55E-10

2.77E-09

3.74E-12

1

6.61 E+09

5.05E+01

1.37E-02

Bi-214

s

6.18E-11

7.34E-06

1.47E-13

1

6.61 E+09

1.83E+04

3.79E-05

Hg-206

-

0.00E+00

4.83E-07

0.00E+00

1

6.61 E+09

4.47E+04

1.55E-05

Pa-234

s

1.20E-12

6.62E-06

9.66E-13

1

6.61 E+09

9.06E+02

7.65E-04

Pa-234m

-

0.00E+00

9.06E-08

0.00E+00

1

6.61 E+09

3.11E+05

2.23E-06

Pb-210

s

1.59E-08

1.48E-09

5.99E-10

1

6.61 E+09

3.12E-02

2.22E+01

Pb-214

s

7.77E-11

9.94E-07

2.21E-13

1

6.61 E+09

1.36E+04

5.10E-05

Po-210

s

1.45E-08

4.51 E-11

1.44E-09

1

6.61 E+09

1.83E+00

3.79E-01

Po-214

-

0.00E+00

3.85E-10

0.00E+00

1

6.61 E+09

1.33E+11

5.21E-12

Po-218

-

1.39E-11

6.84E-15

0.00E+00

1

6.61 E+09

1.17E+05

5.90E-06

Ra-226

s

2.82E-08

2.50E-08

2.95E-10

1

6.61 E+09

4.33E-04

1.60E+03

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Risk Contributions for Soil - Secular Equilibrium

9

1000029

m2 0 cm
Soil Soil Total
Volume Volume Indoor External
Area Gamma GSF Ingestion Inhalation Exposure External
Correction Shielding Soil CDI CDI CDI Ingestion Inhalation Exposure Total
Factor Factor Volume (pCi) (pCi) (pCi) Risk Risk Risk Risk

- 0.00E+00 0.00E+00 3.73E-08

3.73E-08

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 3.17E-12

3.17E-12

9.00E-01 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.44E-02 0.00E+00 0.00E+00 0.00E+00

0.00E+00

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 3.04E-09

3.04E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 1.39E-14

1.39E-14

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 2.99E-11

2.99E-11

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 2.03E-09

2.03E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 4.65E-09

4.65E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 1.66E-12

1.66E-12

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 1.20E-11

1.20E-11

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 7.28E-09

7.28E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 3.75E-09

3.75E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 7.01 E-09

7.01 E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 3.97E-10

3.97E-10

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 2.53E-10

2.53E-10

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 1.60E-02 0.00E+00 0.00E+00 8.81 E-09

8.81 E-09

- 0.00E+00 0.00E+00 3.39E-06

3.39E-06

9.00E-01 1.00E+00 7.00E-01 0.00E+00 0.00E+00 3.60E-01 0.00E+00 0.00E+00 1.97E-15

1.97E-15

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 1.11 E-09

1.11 E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 2.93E-06

2.93E-06

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 3.67E-15

3.67E-15

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 4.23E-09

4.23E-09

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 3.62E-08

3.62E-08

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 5.92E-10

5.92E-10

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 3.97E-07

3.97E-07

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 1.80E-11

1.80E-11

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 1.54E-10

1.54E-10

9.00E-01 1.00E+00 7.00E-01 0.00E+00 0.00E+00 3.60E-01 0.00E+00 0.00E+00 2.46E-15

2.46E-15

1.00E+00 1.00E+00 7.00E-01 0.00E+00 0.00E+00 4.00E-01 0.00E+00 0.00E+00 9.98E-09

9.98E-09

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Risk Contributions for Soil - Secular Equilibrium

10

External









Exposure

Adult

















Slope

Soil













ICRP

Inhalation

Factor

Ingestion



Particulate









Lung

Slope

(risktyr

Slope



Emission









Absorption

Factor

per

Factor

Concentration

Factor

Lambda

Halflife



Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

Rn-218



-

0.00E+00

3.39E-09

0.00E+00

1

6.61 E+09

6.24E+08

1.11E-09

Rn-222



-

2.28E-12

1.69E-09

0.00E+00

1

6.61 E+09

6.62E+01

1.05E-02

Th-230



F

3.41 E-08

8.45E-10

7.73E-11

1

6.61 E+09

9.19E-06

7.54E+04

Th-234



S

3.08E-11

1.77E-08

9.51 E-12

1

6.61 E+09

1.05E+01

6.60E-02

TI-206



-

0.00E+00

6.11E-09

0.00E+00

1

6.61 E+09

8.67E+04

7.99E-06

TI-210



-

0.00E+00

1.34E-05

0.00E+00

1

6.61 E+09

2.80E+05

2.47E-06

U-234



s

2.78E-08

2.53E-10

5.11 E-11

1

6.61 E+09

2.82E-06

2.46E+05

U-238



s

2.36E-08

1.24E-10

4.66E-11

1

6.61 E+09

1.55E-10

4.47E+09

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Indoor Worker Individual Risk Contributions for Soil - Secular Equilibrium

1000029



















m2

0 cm

















Soil

Soil

Total















Volume

Volume

Indoor





External









Area

Gamma

GSF

Ingestion Inhalation Exposure





External



Correction Shielding

Soil

CDI

CDI

CDI

Ingestion Inhalation Exposure

Total

Factor

Factor

Volume

(pCi)

(pCi)

(pCi)

Risk

Risk

Risk

Risk

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

2.71E-16

2.71E-16

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

6.76E-10

6.76E-10

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

3.38E-10

3.38E-10

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

7.09E-09

7.09E-09

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

3.27E-15

3.27E-15

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

1.13E-09

1.13E-09

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

1.01E-10

1.01E-10

1.00E+00

1.00E+00

7.00E-01

0.00E+00

0.00E+00

4.00E-01

0.00E+00

0.00E+00

4.95E-11

4.95E-11

Output generated 22MAY2019:10:38:56


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

' Inputted values different from Farmer defaults are highlighted.

Variable

A (PEF Dispersion Constant)
B (PEF Dispersion Constant)

City (Climate Zone)

C (PEF Dispersion Constant)

CF„

CF„

CF„

CF„

CF,

Farmer

Soil
Default
Value

16.2302

18.7762

Default

216.108

Form-input
Value

Albuquerque, NM (3)

205.1782

(contaminated plant fraction) unitless
s (contaminated apple fraction) unitless

(contaminated asparagus fraction) unitless
(beef contaminated fraction) unitless
(contaminated berry fraction) unitless

CF,,,		 (contaminated broccoli fraction) unitless

CF,oK hM, (contaminated beet fraction) unitless
CF,omhh_ (contaminated cabbage fraction) unitless
CF(__lmi„ (contaminated cereal grain fraction) unitless
CF,o_i(Kiic (contaminated citrus fraction) unitless
CF,_ (contaminated corn fraction) unitless
CF_ (contaminated carrot fraction) unitless
CF,oK „ „imh=K (contaminated cucumber fraction) unitless
CF,oKHoi„, (dairy contaminated fraction) unitless
CF,_ (egg contaminated fraction) unitless
CF^,frh (fish contaminated fraction) unitless
CF,oK„m(milk (goat milk contaminated fraction) unitless
CF,_m(i_( (goat meat contaminated fraction) unitless
CF_ (contaminated lettuce fraction) unitless
CF,__ (contaminated lima bean fraction) unitless
CF,oK„kra (contaminated okra fraction) unitless
CF^, _ (contaminated onion fraction) unitless

CF_	(poultry contaminated fraction unitless)

CF,_h (contaminated peach fraction) unitless
CF_ (contaminated pea fraction) unitless
CFfar_pear (contaminated pear fraction) unitless

48

4.9421

7.9869

Output generated 22MAY2019:10:50:12

1


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

2

* Inputted values different from Farmer defaults are highlighted.



Farmer





Soil





Default

Form-input

Variable

Value

Value

CF	(contaminated potato fraction) unitless

1

1

CFfo	_ (contaminated pumpkin fraction) unitless

1

1

CFfc„.„ (contaminated rice fraction) unitless

1

1

CFfc„_ (sheep contaminated fraction) unitless

1

1

CFfc„_mill, (sheep milk contaminated fraction) unitless

1

1

CF^,(contaminated snap bean fraction) unitless

1

1

CF,„k(contaminated strawberry fraction) unitless

1

1

CFf_,„= (swine contaminated fraction) unitless

1

1

CF,okJ_,„ (contaminated tomato fraction) unitless

1

1

ED,ok (exposure duration - farmer) yr

40

25

ED,ok o (exposure duration - farmer adult) yr

34

25

EDfo_ (exposure duration - farmer child) yr

6

0

EFfc„ (exposure frequency - farmer adult) day/yr

350

350

EFfc„ (exposure frequency - farmer child) day/yr

350

350

IFAP,ok oHi (age-adjusted apple ingestion factor) g

1182020

741125

IFASfoK oHi (age-adjusted asparagus ingestion factor) g

492870

343874.99999999994

IFB,ok oHi (age-adjusted beef ingestion factor) g

2098950

1446375

IFBEfoK oHi (age-adjusted berry ingestion factor) g

471450

309750

IFBR,ok oHi (age-adjusted broccoli ingestion factor) g

450310

308874.99999999994

IFBT,ok oHi (age-adjusted beet ingestion factor) g

411600

296625

IFCB,ok oHi (age-adjusted cabbage ingestion factor) g

1043980

749875

IFCG,ok oHi (age-adjusted cereal grain ingestion factor) g

1190210

1190210

IFCIfoK oHi (age-adjusted citrus ingestion factor) g

4090100

2707249.9999999995

IFCO,ok oHi (age-adjusted corn ingestion factor) g

1044470

717500

IFCR,ok oHi (age-adjusted carrot ingestion factor) g

318290

213500

IFCUfoK oHi (age-adjusted cucumber ingestion factor) g

688800

480375

IFD,ok oHi (age-adjusted dairy ingestion factor) g

10138030

5918500

IFEfoK oHi (age-adjusted egg ingestion factor) g

775810

521500

IFFIfoK oHi (age-adjusted fish ingestion factor) g

10018960

7278250

IFLEfaradj (age-adjusted lettuce ingestion factor) g

455070

328125

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

3

* Inputted values different from Farmer defaults are highlighted.

Variable

IFLIfoK oHi (age-adjusted lima bean ingestion factor) g
IFOK,ok oHi (age-adjusted okra ingestion factor) g
IFONfoK oHi (age-adjusted onion ingestion factor) g
IFP,ok oHi (age-adjusted poultry ingestion factor) g
IFPC,ok oHi (age-adjusted peach ingestion factor) g
IFPEfoK oHi (age-adjusted pea ingestion factor) g
IFPR„K ,Hi (age-adjusted pear ingestion factor) g
IFPT,_Hi (age-adjusted potato ingestion factor) g
IFPUfoK oHi (age-adjusted pumpkin ingestion factor) g
IFRIfoK oHi (age-adjusted rice ingestion factor) g
IFSNfoK oHi (age-adjusted snap bean ingestion factor) g
IFST,ok oHi (age-adjusted strawberry ingestion factor) g
IFSWfoK oHi (age-adjusted swine ingestion factor) g
IFTOfoK oHi (age-adjusted tomato ingestion factor) g
IRAP,_ (apple ingestion rate - farmer adult) g/day
IRAPfo_ (apple ingestion rate - farmer child) g/day
IRAS,ok o (asparagus ingestion rate - farmer adult) g/day
IRASfo_ (asparagus ingestion rate - farmer child) g/day
IRB,ok o (beef ingestion rate - farmer adult) g/day
IRBfo_ (beef ingestion rate - farmer child) g/day
IRBE,ok o (berry ingestion rate - farmer adult) g/day
IRBEfo_ (berry ingestion rate - farmer child) g/day
IRBR,ok o (broccoli ingestion rate - farmer adult) g/day
IRBRfo_ (broccoli ingestion rate - farmer child) g/day
IRBT,ok o (beet ingestion rate - farmer adult) g/day
IRBT,_ (beet ingestion rate - farmer child) g/day
IRCB,ok o (cabbage ingestion rate - farmer adult) g/day
IRCBfo_ (cabbage ingestion rate - farmer child) g/day
IRCG,ok o (cereal grain ingestion rate - farmer adult) g/day
IRCGfar c (cereal grain ingestion rate - farmer child) g/day

Farmer



Soil



Default

Form-input

Value

Value

415870

295749.99999999994

370510

264250

338800

238000

1376550

939750

1435420

902125

437500

277375

874300

524125

1807750

1240750.0000000002

866040

567000

1126230

774375

702730

474250

535080

354375

1171520

809375

1194270

824250

84.7

84.7

82.9

82.9

39.3

39.3

12.0

12.0

165.3

165.3

62.8

0

35.4

35.4

23.9

23.9

35.3

35.3

14.4

14.4

33.9

33.9

3.9

3.9

85.7

85.7

11.5

11.5

91.9

91.9

46.0

46.0

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

4

* Inputted values different from Farmer defaults are highlighted.

Variable

IRCI,ok o (citrus ingestion rate - farmer adult) g/day
IRCIfo_ (citrus ingestion rate - farmer child) g/day
IRCO,ok o (corn ingestion rate - farmer adult) g/day
IRCOfo_ (corn ingestion rate - farmer child) g/day
IRCR,_ (carrot ingestion rate - farmer adult) g/day
IRCRfo_ (carrot ingestion rate - farmer child) g/day
IRCU,ok o (cucumber ingestion rate - farmer adult) g/day
IRCUfo_ (cucumber ingestion rate - farmer child) g/day
IRDfoK, (dairy ingestion rate - farmer adult) g/day
IRDfoK, (dairy ingestion rate - farmer child) g/day
IRE,ok o (egg ingestion rate - farmer adult) g/day
IREfo_ (egg ingestion rate - farmer child) g/day
IRFIfc„ (fish ingestion rate - farmer adult) g/day
IRFIfc„ (fish ingestion rate - farmer child) g/day
IRLE,ok o (lettuce ingestion rate - farmer adult) g/day
IRLEfo_ (lettuce ingestion rate - farmer child) g/day
IRLI„k, (lima bean ingestion rate - farmer adult) g/day
IRLIf,_ (lima bean ingestion rate - farmer child) g/day
IROK,ok o (okra ingestion rate - farmer adult) g/day
IROKfo_ (okra ingestion rate - farmer child) g/day
IRON,ok o (onion ingestion rate - farmer adult) g/day
IRONfo_ (onion ingestion rate - farmer child) g/day
IRPfc„ (poultry ingestion rate - farmer adult) g/day
IRPfc„ (poultry ingestion rate - farmer child) g/day
IRPCfc„ (peach ingestion rate - farmer adult) g/day
IRPCfc„ (peach ingestion rate - farmer child) g/day
IRPEfc„ (pea ingestion rate - farmer adult) g/day
IRPEfc„ (pea ingestion rate - farmer child) g/day
IRPRfc„ (pear ingestion rate - farmer adult) g/day
IRPRf^ c (pear ingestion rate - farmer child) g/day

Output generated 22MAY2019:10:50:12

Farmer
Soil

Default	Form-input

Value	Value

309.4

309.4

194.4

194.4

82.0

82.0

32.7

32.7

24.4

24.4

13.3

13.3

54.9

54.9

16.9

16.9

676.4

676.4

994.7

994.7

59.6

59.6

31.7

31.7

831.8

831.8

57.4

57.4

37.5

37.5

4.2

4.2

33.8

33.8

6.5

6.5

30.2

30.2

5.3

5.3

27.2

27.2

7.2

7.2

107.4

107.4

46.9

46.9

103.1

103.1

99.3

99.3

31.7

31.7

28.7

28.7

59.9

59.9

76.9

76.9


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

* Inputted values different from Farmer defaults are highlighted.



Farmer





Soil





Default

Form-input

Variable

Value

Value

IRPTfc„ (potato ingestion rate - farmer adult) g/day

141.8

141.8

IRPTf„, (potato ingestion rate - farmer child) g/day

57.3

57.3

IRPUfc„ (pumpkin ingestion rate - farmer adult) g/day

64.8

64.8

IRPUfc„ (pumpkin ingestion rate - farmer child) g/day

45.2

45.2

IRRL, (rice ingestion rate - farmer adult) g/day

88.5

88.5

IRRL, (rice ingestion rate - farmer child) g/day

34.8

34.8

IRSN,ok o (snap bean ingestion rate - farmer adult) g/day

54.2

54.2

IRSNfo_ (snap bean ingestion rate - farmer child) g/day

27.5

27.5

IRSTfc„ (strawberry ingestion rate - farmer adult) g/day

40.5

40.5

IRSTfc„ (strawberry ingestion rate - farmer child) g/day

25.3

25.3

IRSWfc„ (swine ingestion rate - farmer adult) g/day

92.5

92.5

IRSWfc„ (swine ingestion rate - farmer child) g/day

33.7

33.7

IRTOfc„ (tomato ingestion rate - farmer adult) g/day

94.2

94.2

IRTOfc„ (tomato ingestion rate - farmer child) g/day

34.9

34.9

MLFoml= (apple mass loading factor) unitless

0.000160

0.000160

MLF	(asparagus mass loading factor) unitless

0.0000790

0.0000790

MLFh=m, (berry mass loading factor) unitless

0.000166

0.000166

MLFhK_N (broccoli mass loading factor) unitless

0.00101

0.00101

MLFhM, (beet mass loading factor) unitless

0.000138

0.000138

MLF„hh_ (cabbage mass loading factor) unitless

0.000105

0.000105

MLF„„,,„in (cereal grain mass loading factor) unitless

0.250

0.250

MLF^kiic (citrus mass loading factor) unitless

0.000157

0.000157

MLF_ (corn mass loading factor) unitless

0.000145

0.000145

MLF_, (carrot mass loading factor) unitless

0.0000970

0.0000970

MLF„,„imh=K (cucumber mass loading factor) unitless

0.0000400

0.0000400

MLF,_ (lettuce mass loading factor) unitless

0.0135

0.0135

MLFlimoh_ (lima bean mass loading factor) unitless

0.00383

0.00383

MLF„,ko (okra mass loading factor) unitless

0.0000800

0.0000800

MLF„ni„„ (onion mass loading factor) unitless

0.0000970

0.0000970

MLFpeach (peach mass loading factor) unitless

0.000150

0.000150

Output generated 22MAY2019:10:50:12

5


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

6

* Inputted values different from Farmer defaults are highlighted.



Farmer





Soil





Default

Form-input

Variable

Value

Value

MLF_ (pea mass loading factor) unitless

0.000178

0.000178

MLF_ (pear mass loading factor) unitless

0.000160

0.000160

MLF„„,o,„ (potato mass loading factor) unitless

0.000210

0.000210

MLF„iim„ki„ (pumpkin mass loading factor) unitless

0.0000580

0.0000580

MLFKi„ (rice mass loading factor) unitless

0.250

0.250

MLF_h_ (snap bean mass loading factor) unitless

0.00500

0.00500

MLFc(Koi,ih=m, (strawberry mass loading factor) unitless

0.0000800

0.0000800

MLF,_ (tomato mass loading factor) unitless

0.00159

0.00159

pm (density of milk) kg/L

1.03

1.03

tfc, (time - farmer) yr

40

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

F(x) (function dependent on U m/U,) unitless

0.194

0.0553

PEF (particulate emission factor) m 3/kg

1359344438

2370938158.760359

Q/C„_h (g/m2-s per kg/m3)

93.77

29.359877603759233

A„ (acres)

0.5

500

ED,ok (exposure duration - farmer) yr

40

25

ED,oko (exposure duration - farmer adult) yr

34

25

ED, (exposure duration - farmer child) yr

6



EF,ok (exposure frequency) day/yr

350

350

EFfc„ (exposure frequency - farmer adult) day/yr

350

350

EFfc„ (exposure frequency - farmer child) day/yr

350

350

ET,ok (exposure time - farmer) hr/day

24

24

ETfc„ (exposure time - farmer adult) hr/day

24

24

ETfc„ (exposure time - farmer child) hr/day

24

24

ETfoKi (indoor exposure time fraction) hr/day

10.008

0

ET,_ (outdoor exposure time fraction) hr/day

12.168

0

f h f (animal on-site fraction) unitless

1

.33

(animal on-site fraction) unitless

1

1

(animal on-site fraction) unitless

1

1

f , (animal on-site fraction) unitless

p-goat N '

1

1

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

7

* Inputted values different from Farmer defaults are highlighted.



Farmer





Soil





Default

Form-input

Variable

Value

Value

		 (animal on-site fraction) unitless

1

1

f (animal on-site fraction) unitless

1

1

f(animal on-site fraction) unitless

1

1

(animal on-site fraction) unitless

1

1

f (fraction of year animal on site) unitless

1

1

f Hoi„, (fraction of year animal on site) unitless

1

1

f (fraction of year animal on site) unitless

1

1

f (fraction of year animal on site) unitless

1

1

f (fraction of year animal on site) unitless

1

1

(fraction of year animal on site) unitless

1

1

f (fraction of year animal on site) unitless

1

1

f (fraction of year animal on site) unitless

1

1

GSF; (gamma shielding factor - indoor)

0.4

0

IFAfoK oHi (age-adjusted soil inhalation factor) m 3

259000

0

IFS,ok oHi (age-adjusted soil ingestion factor) mg

1610000

0

IRA,ok o (inhalation rate - farmer adult) m 3/day

20

0

IRA,_ (inhalation rate - farmer child) m 3/day

10

0

IRS,ok o (soil ingestion rate - farmer adult) mg/day

100

0

IRSfo_ (soil ingestion rate - farmer child) mg/day

200

0

MLF„„,iira (pasture plant mass loading factor) unitless

0.25

0.25

(beef fodder intake rate) kg/day

11.77

11.77

Q„ Hoi„, (dairy fodder intake rate) kg/day

20.3

20.3

Q	o(milk (goat milk fodder intake rate) kg/day

1.59

1.59

Q		 (goat fodder intake rate) kg/day

1.27

1.27

Q			 (poultry fodder intake rate) kg/day

0.2

0.2

(sheep fodder intake rate) kg/day

1.75

1.75

(sheep milk fodder intake rate) kg/day

3.15

3.15

Q„ (swine fodder intake rate) kg/day

4.7

4.7

(beef soil intake rate) kg/day

0.5

0.5

Q (dairy soil intake rate) kg/day

0.4

0.4

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Soil Inputs - Secular Equilibrium

8

* Inputted values different from Farmer defaults are highlighted.



Farmer





Soil





Default

Form-input

Variable

Value

Value

(goat milk soil intake rate) kg/day

0.29

0.29

Q_ (goat soil intake rate) kg/day

0.23

0.23

(poultry soil intake rate) kg/day

0.022

0.022

Q„_ (sheep soil intake rate) kg/day

0.32

0.32

(sheep milk soil intake rate) kg/day

0.57

0.57

Q™,™ (swine soil intake rate) kg/day

0.37

0.37

tfc, (time - farmer) yr

40

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

Um (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer PRGs for Soil - Secular Equilibrium

External Produce	Beef

Inhalation Exposure Consumption Consumption

Isotope

*Secular Equilibrium PRG for U-235
*Secular Equilibrium PRG for U-238

Ingestion

PRG	PRG	PRG	PRG

TR=0.0001	TR=0.0001	TR=0.0001	TR=0.0001

(pCi/g)	(pCi/g)	(pCi/g)	(pCi/g)

PRG
TR=0.0001
(pCi/g)

1.86E+02

9.57E+00

Total
PRG
TR=0.0001

(pCi/g)
1.86E+02
9.57E+00

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Contribution PRGs for Soil - Secular Equilibrium

10

ICRP

Fractional Lung
Contribution Absorption

Isotope

*Secular Equilibrium

PRG for U-235

Ac-227

At-219

Bi-211

Bi-215

Fr-223

Pa-231

Pb-211

Po-211

Po-215

Ra-223

Rn-219

Th-227

Th-231

TI-207

U-235

*Secular Equilibrium

PRG for U-238

At-218

Bi-210

Bi-214

Hg-206

Pa-234

Pa-234m

Pb-210

Pb-214

Po-210

Parent of Progeny

U-235

Type

U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-235
U-238

U-238
U-238
U-238
U-238
U-238
U-238
U-238
U-238
U-238

1.00E+00
8.28E-07
1.00E+00
8.03E-07
1.38E-02
1.00E+00
1.00E+00
2.76E-03
1.00E+00
1.00E+00
1.00E+00
9.86E-01
1.00E+00
9.97E-01
1.00E+00

2.00E-04
1.00E+00
1.00E+00
1.90E-08
1.60E-03
1.00E+00
1.00E+00
1.00E+00
1.00E+00

S
F
S

S

s

s
s

s
s
s

Inhalation
Slope
Factor
(risk/pCi)

1.49E-07

0.00E+00

0.00E+00

0.00E+00

4.07E-11

7.62E-08

4.03E-11

0.00E+00

0.00E+00

2.92E-08

0.00E+00

3.50E-08

1.50E-12

0.00E+00

2.50E-08

0.00E+00

4.55E-10

6.18E-11

0.00E+00

1.20E-12

0.00E+00

1.59E-08

7.77E-11

1.45E-08

External
Exposure
Slope
Factor
(riskfyr

per
pCi/g)

1.98E-10
0.00E+00
1.90E-07
1.08E-06
1.35E-07
1.27E-07
2.91 E-07
3.76E-08
7.48E-10
4.55E-07
2.35E-07
4.45E-07
2.49E-08
1.59E-08
5.51 E-07

2.74E-11
2.77E-09
7.34E-06
4.83E-07
6.62E-06
9.06E-08
1.48E-09
9.94E-07
4.51 E-11

Food

Soil

Ingestion Ingestion

Slope
Factor

Slope
Factor

(risk/pCi) (risk/pCi)

2.45E-10
0.00E+00
0.00E+00
0.00E+00
1.01 E-11
2.26E-10
5.81 E-13
0.00E+00
0.00E+00
3.39E-10
0.00E+00
7.03E-11
3.22E-12
0.00E+00
9.44E-11

0.00E+00
1.30E-11
2.65E-13
0.00E+00
3.00E-12
0.00E+00
1.18E-09
4.85E-13
2.25E-09

2.90E-10
0.00E+00
0.00E+00
0.00E+00
1.69E-11
2.98E-10
9.55E-13
0.00E+00
0.00E+00
5.99E-10
0.00E+00
1.29E-10
5.96E-12
0.00E+00
1.48E-10

0.00E+00
2.40E-11
4.03E-13
0.00E+00
5.37E-12
0.00E+00
1.72E-09
7.92E-13
3.27E-09

Plant to

Beef
Transfer
Factor
(pCi/kg

per
pCi/d)

2.00E-05
1.00E-02
2.00E-03
2.00E-03
3.00E-02
5.00E-06
7.00E-04
5.00E-03
5.00E-03
1.70E-03
0.00E+00
2.30E-04
2.30E-04
2.00E-02
3.90E-04

1.00E-02
2.00E-03
2.00E-03
1.00E-02
5.00E-06
5.00E-06
7.00E-04
7.00E-04
5.00E-03

Particulate
Emission
Factor
(m3/kg)

1000029
m2
Soil
Volume
Area

0 cm
Soil
Volume
Gamma

2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09

2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09
2.37E+09

Lambda
(1/yr)

Halflife Correction Shielding
(yr) Factor Factor

3.18E-02
3.90E+05
1.70E+05
4.79E+04
1.66E+04
2.12E-05
1.01E+04
4.24E+07
1.23E+10
2.21E+01
5.52E+06
1.35E+01
2.38E+02
7.64E+04
9.84E-10

1.46E+07
5.05E+01
1.83E+04
4.47E+04
9.06E+02
3.11E+05
3.12E-02
1.36E+04
1.83E+00

2.18E+01

1.78E-06

4.07E-06

1.45E-05

4.19E-05

3.28E+04

6.87E-05

1.64E-08

5.65E-11

3.13E-02

1.26E-07

5.12E-02

2.91 E-03

9.08E-06

7.04E+08

4.76E-08
1.37E-02
3.79E-05
1.55E-05
7.65E-04
2.23E-06
2.22E+01
5.10E-05
3.79E-01

1.00E+00

9.00E-01

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

9.00E-01

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00

1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00

1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00
1.00E+00

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Contribution PRGs for Soil - Secular Equilibrium

11





Dry





















Soil-to-plant





















transfer





















factor



















Total

(pCi/g-fresh







External

Produce

Beef







Indoor

plant

Kd

Ingestion

Inhalation

Exposure

Consumption

Consumption

Total

Total



GSF

per

Distribution

PRG

PRG

PRG

PRG

PRG

PRG

PRG



Soil

pCi/g-dry

coefficient

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

TR=0.0001

Isotope

Volume

soil)

(L/kg)

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(pCi/g)

(mg/kg)

*Secular Equilibrium

-

-

-

-

-

-

-

1.86E+02

1.86E+02

-

PRG for U-235





















Ac-227

0.00E+00

1.00E-01

1.70E+03

-

-

-

-

1.93E+04

1.93E+04

7.19E-13

At-219

0.00E+00

9.00E-01

1.00E+01

-

-

-

-

-

-

-

Bi-211

0.00E+00

5.00E-01

4.80E+02

-

-

-

-

-

-

-

Bi-215

0.00E+00

5.00E-01

4.80E+02

-

-

-

-

-

-

-

Fr-223

0.00E+00

1.00E-01

2.50E+02

-

-

-

-

2.26E+04

2.26E+04

1.16E-18

Pa-231

0.00E+00

1.00E-01

2.00E+03

-

-

-

-

8.37E+04

8.37E+04

2.53E-10

Pb-211

0.00E+00

1.26E-02

1.50E+02

-

-

-

-

2.99E+05

2.99E+05

1.36E-19

Po-211

0.00E+00

2.76E-04

2.10E+02

-

-

-

-

-

-

-

Po-215

0.00E+00

2.76E-04

2.10E+02

-

-

-

-

-

-

-

Ra-223

0.00E+00

1.95E-02

1.00E+00

-

-

-

-

2.07E+02

2.07E+02

9.47E-14

Rn-219

0.00E+00

0.00E+00

0.00E+00

-

-

-

-

-

-

-

Th-227

0.00E+00

2.41 E-03

2.00E+01

-

-

-

-

7.89E+03

7.89E+03

4.12E-15

Th-231

0.00E+00

2.41 E-03

2.00E+01

-

-

-

-

1.70E+05

1.70E+05

1.11E-17

TI-207

0.00E+00

6.00E-01

1.50E+03

-

-

-

-

-

-

-

U-235

0.00E+00

7.13E-03

4.00E-01

-

-

-

-

3.36E+03

3.36E+03

1.38E-04

*Secular Equilibrium

-

-

-

-

-

-

-

9.57E+00

9.57E+00

-

PRG for U-238





















At-218

0.00E+00

9.00E-01

1.00E+01

-

-

-

-

-

-

-

Bi-210

0.00E+00

5.00E-01

4.80E+02

-

-

-

-

1.80E+03

1.80E+03

4.50E-15

Bi-214

0.00E+00

5.00E-01

4.80E+02

-

-

-

-

8.82E+04

8.82E+04

2.57E-19

Hg-206

0.00E+00

1.00E+00

6.30E+03

-

-

-

-

-

-

-

Pa-234

0.00E+00

1.00E-01

2.00E+03

-

-

-

-

3.94E+09

3.94E+09

1.27E-22

Pa-234m

0.00E+00

1.00E-01

2.00E+03

-

-

-

-

-

-

-

Pb-210

0.00E+00

1.26E-02

1.50E+02

-

-

-

-

1.48E+02

1.48E+02

8.85E-11

Pb-214

0.00E+00

1.26E-02

1.50E+02

-

-

-

-

3.58E+05

3.58E+05

8.53E-20

Po-210

0.00E+00

2.76E-04

2.10E+02

-

-

-

-

1.12E+01

1.12E+01

1.98E-11

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Contribution PRGs for Soil - Secular Equilibrium

12











External





Plant to







1000029













Exposure





Beef







m2

0 cm











Slope

Food

Soil

Transfer







Soil

Soil







ICRP

Inhalation

Factor

Ingestion

Ingestion

Factor

Particulate





Volume

Volume





Fractional

Lung

Slope

(risktyr

Slope

Slope

(pCi/kg

Emission





Area

Gamma





Contribution Absorption

Factor

per

Factor

Factor

per

Factor

Lambda

Halflife

Correction

Shielding

Isotope

Parent

of Progeny

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(risk/pCi)

pCi/d)

(m3/kg)

(1/yr)

(yr)

Factor

Factor

Po-214

U-238

1.00E+00

-

0.00E+00

3.85E-10

0.00E+00

0.00E+00

5.00E-03

2.37E+09

1.33E+11

5.21E-12

1.00E+00

1.00E+00

Po-218

U-238

1.00E+00

-

1.39E-11

6.84E-15

0.00E+00

0.00E+00

5.00E-03

2.37E+09

1.17E+05

5.90E-06

9.00E-01

1.00E+00

Ra-226

U-238

1.00E+00

S

2.82E-08

2.50E-08

5.14E-10

6.77E-10

1.70E-03

2.37E+09

4.33E-04

1.60E+03

1.00E+00

1.00E+00

Rn-218

U-238

2.00E-07

-

0.00E+00

3.39E-09

0.00E+00

0.00E+00

0.00E+00

2.37E+09

6.24E+08

1.11E-09

1.00E+00

1.00E+00

Rn-222

U-238

1.00E+00

-

2.28E-12

1.69E-09

0.00E+00

0.00E+00

0.00E+00

2.37E+09

6.62E+01

1.05E-02

1.00E+00

1.00E+00

Th-230

U-238

1.00E+00

F

3.41 E-08

8.45E-10

1.19E-10

1.66E-10

2.30E-04

2.37E+09

9.19E-06

7.54E+04

1.00E+00

1.00E+00

Th-234

U-238

1.00E+00

S

3.08E-11

1.77E-08

3.39E-11

6.25E-11

2.30E-04

2.37E+09

1.05E+01

6.60E-02

1.00E+00

1.00E+00

TI-206

U-238

1.34E-06

-

0.00E+00

6.11E-09

0.00E+00

0.00E+00

2.00E-02

2.37E+09

8.67E+04

7.99E-06

1.00E+00

1.00E+00

TI-210

U-238

2.10E-04

-

0.00E+00

1.34E-05

0.00E+00

0.00E+00

2.00E-02

2.37E+09

2.80E+05

2.47E-06

1.00E+00

1.00E+00

U-234

U-238

1.00E+00

s

2.78E-08

2.53E-10

9.55E-11

1.48E-10

3.90E-04

2.37E+09

2.82E-06

2.46E+05

1.00E+00

1.00E+00

U-238

U-238

1.00E+00

s

2.36E-08

1.24E-10

8.66E-11

1.34E-10

3.90E-04

2.37E+09

1.55E-10

4.47E+09

1.00E+00

1.00E+00

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Contribution PRGs for Soil - Secular Equilibrium





Dry







Soil-to-plant







transfer







factor





Total

(pCi/g-fresh





Indoor

plant

Kd



GSF

per

Distribution



Soil

pCi/g-dry

coefficient

Isotope

Volume

soil)

(L/kg)

Po-214

0.00E+00

2.76E-04

2.10E+02

Po-218

0.00E+00

2.76E-04

2.10E+02

Ra-226

0.00E+00

1.95E-02

1.00E+00

Rn-218

0.00E+00

0.00E+00

0.00E+00

Rn-222

0.00E+00

0.00E+00

0.00E+00

Th-230

0.00E+00

2.41 E-03

2.00E+01

Th-234

0.00E+00

2.41 E-03

2.00E+01

TI-206

0.00E+00

6.00E-01

1.50E+03

TI-210

0.00E+00

6.00E-01

1.50E+03

U-234

0.00E+00

7.13E-03

4.00E-01

U-238

0.00E+00

7.13E-03

4.00E-01

Ingestion	Inhalation

PRG	PRG
TR=0.0001 TR=0.0001

(pCi/g)	(pCi/g)

External Produce	Beef

Exposure Consumption Consumption

PRG
TR=0.0001
(pCi/g)

PRG
TR=0.0001
(pCi/g)

PRG
TR=0.0001
(pCi/g)

1.36E+02

4.59E+03
1.61E+04

3.32E+03
3.67E+03

Total	Total

PRG	PRG

TR=0.0001	TR=0.0001

(pCi/g)	(mg/kg)

1.36E+02

4.59E+03

1.61 E+04

3.32E+03

3.67E+03

7.45E-09

1.06E-08
2.68E-15

4.84E-08
8.12E-04

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Risk for Soil - Secular Equilibrium

Isotope

External Produce
Ingestion Inhalation Exposure Consumption Beef
Risk Risk Risk Risk Risk

Total
Risk

*Secular Equilibrium Risk for U-235

0.00E+00 0.00E+00 0.00E+00 - 2.15E-08

2.15E-08

*Secular Equilibrium Risk for U-238

0.00E+00 0.00E+00 0.00E+00 - 1.04E-05

1.04E-05

*Total Risk

0.00E+00 0.00E+00 0.00E+00 - 1.05E-05

1.05E-05



Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Risk Contributions for Soil - Secular Equilibrium

15







External





Plant to









1000029











Exposure





Beef









m2

0 cm









Slope

Food

Soil

Transfer









Soil

Soil

Total



ICRP

Inhalation

Factor

Ingestion

Ingestion

Factor



Particulate





Volume

Volume

Indoor



Lung

Slope

(risktyr

Slope

Slope

(pCi/kg



Emission





Area

Gamma

GSF



Absorption

Factor

per

Factor

Factor

per

Concentration

Factor

Lambda

Halflife

Correction

Shielding

Soil

Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(risk/pCi)

pCi/d)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

Factor

Factor

Volume

*Secular



-

-

-

-

-

-

-

-

-

-

-

-

Equilibrium Risk



























for U-235



























Ac-227

S

1.49E-07

1.98E-10

2.45E-10

2.90E-10

2.00E-05

0.04

2.37E+09

3.18E-02

2.18E+01

1.00E+00

1.00E+00

0.00E+00

At-219

-

0.00E+00

0.00E+00

0.00E+00

0.00E+00

1.00E-02

0.04

2.37E+09

3.90E+05

1.78E-06

9.00E-01

1.00E+00

0.00E+00

Bi-211

-

0.00E+00

1.90E-07

0.00E+00

0.00E+00

2.00E-03

0.04

2.37E+09

1.70E+05

4.07E-06

1.00E+00

1.00E+00

0.00E+00

Bi-215

-

0.00E+00

1.08E-06

0.00E+00

0.00E+00

2.00E-03

0.04

2.37E+09

4.79E+04

1.45E-05

1.00E+00

1.00E+00

0.00E+00

Fr-223

s

4.07E-11

1.35E-07

1.01E-11

1.69E-11

3.00E-02

0.04

2.37E+09

1.66E+04

4.19E-05

1.00E+00

1.00E+00

0.00E+00

Pa-231

F

7.62E-08

1.27E-07

2.26E-10

2.98E-10

5.00E-06

0.04

2.37E+09

2.12E-05

3.28E+04

1.00E+00

1.00E+00

0.00E+00

Pb-211

S

4.03E-11

2.91 E-07

5.81 E-13

9.55E-13

7.00E-04

0.04

2.37E+09

1.01E+04

6.87E-05

1.00E+00

1.00E+00

0.00E+00

Po-211

-

0.00E+00

3.76E-08

0.00E+00

0.00E+00

5.00E-03

0.04

2.37E+09

4.24E+07

1.64E-08

1.00E+00

1.00E+00

0.00E+00

Po-215

-

0.00E+00

7.48E-10

0.00E+00

0.00E+00

5.00E-03

0.04

2.37E+09

1.23E+10

5.65E-11

1.00E+00

1.00E+00

0.00E+00

Ra-223

s

2.92E-08

4.55E-07

3.39E-10

5.99E-10

1.70E-03

0.04

2.37E+09

2.21E+01

3.13E-02

1.00E+00

1.00E+00

0.00E+00

Rn-219

-

0.00E+00

2.35E-07

0.00E+00

0.00E+00

0.00E+00

0.04

2.37E+09

5.52E+06

1.26E-07

1.00E+00

1.00E+00

0.00E+00

Th-227

s

3.50E-08

4.45E-07

7.03E-11

1.29E-10

2.30E-04

0.04

2.37E+09

1.35E+01

5.12E-02

1.00E+00

1.00E+00

0.00E+00

Th-231

s

1.50E-12

2.49E-08

3.22E-12

5.96E-12

2.30E-04

0.04

2.37E+09

2.38E+02

2.91 E-03

1.00E+00

1.00E+00

0.00E+00

TI-207

-

0.00E+00

1.59E-08

0.00E+00

0.00E+00

2.00E-02

0.04

2.37E+09

7.64E+04

9.08E-06

1.00E+00

1.00E+00

0.00E+00

U-235

s

2.50E-08

5.51 E-07

9.44E-11

1.48E-10

3.90E-04

0.04

2.37E+09

9.84E-10

7.04E+08

1.00E+00

1.00E+00

0.00E+00

*Secular



-

-

-

-

-

-

-

-

-

-

-

-

Equilibrium Risk



























for U-238



























At-218

-

0.00E+00

2.74E-11

0.00E+00

0.00E+00

1.00E-02

1

2.37E+09

1.46E+07

4.76E-08

9.00E-01

1.00E+00

0.00E+00

Bi-210

s

4.55E-10

2.77E-09

1.30E-11

2.40E-11

2.00E-03

1

2.37E+09

5.05E+01

1.37E-02

1.00E+00

1.00E+00

0.00E+00

Bi-214

s

6.18E-11

7.34E-06

2.65E-13

4.03E-13

2.00E-03

1

2.37E+09

1.83E+04

3.79E-05

1.00E+00

1.00E+00

0.00E+00

Hg-206

-

0.00E+00

4.83E-07

0.00E+00

0.00E+00

1.00E-02

1

2.37E+09

4.47E+04

1.55E-05

1.00E+00

1.00E+00

0.00E+00

Pa-234

s

1.20E-12

6.62E-06

3.00E-12

5.37E-12

5.00E-06

1

2.37E+09

9.06E+02

7.65E-04

1.00E+00

1.00E+00

0.00E+00

Pa-234m

-

0.00E+00

9.06E-08

0.00E+00

0.00E+00

5.00E-06

1

2.37E+09

3.11E+05

2.23E-06

1.00E+00

1.00E+00

0.00E+00

Pb-210

s

1.59E-08

1.48E-09

1.18E-09

1.72E-09

7.00E-04

1

2.37E+09

3.12E-02

2.22E+01

1.00E+00

1.00E+00

0.00E+00

Output generated

22MAY2019:10:50:12
























-------
Site-Specific

Farmer Individual Risk Contributions for Soil - Secular Equilibrium

16

Dry
Soil-to-plant
transfer
factor
(pCi/g-fresh

plant	Kd	External Produce

per Distribution Ingestion Inhalation Exposure Consumption
pCi/g-dry coefficient CDI CDI	CDI	CDI

soil)	(L/kg) (pCi) (pCi) (pCi)	(pCi)

Beef	External Produce

CDI Ingestion Inhalation Exposure Consumption Beef Total
(pCi) Risk Risk Risk	Risk	Risk Risk















0.00E+00

0.00E+00

0.00E+00



2.15E-08

2.15E-08

1.00E-01

1.70E+03

0.00E+00

0.00E+00

0.00E+00

-

8.47E-01

0.00E+00

0.00E+00

0.00E+00

-

2.08E-10

2.08E-10

9.00E-01

1.00E+01

0.00E+00

0.00E+00

0.00E+00

-

1.29E+03

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

5.00E-01

4.80E+02

0.00E+00

0.00E+00

0.00E+00

-

1.71E+02

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

5.00E-01

4.80E+02

0.00E+00

0.00E+00

0.00E+00

-

1.71E+02

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

1.00E-01

2.50E+02

0.00E+00

0.00E+00

0.00E+00

-

1.27E+03

0.00E+00

0.00E+00

0.00E+00

-

1.77E-10

1.77E-10

1.00E-01

2.00E+03

0.00E+00

0.00E+00

0.00E+00

-

2.12E-01

0.00E+00

0.00E+00

0.00E+00

-

4.78E-11

4.78E-11

1.26E-02

1.50E+02

0.00E+00

0.00E+00

0.00E+00

-

2.30E+01

0.00E+00

0.00E+00

0.00E+00

-

1.34E-11

1.34E-11

2.76E-04

2.10E+02

0.00E+00

0.00E+00

0.00E+00

-

1.58E+02

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

2.76E-04

2.10E+02

0.00E+00

0.00E+00

0.00E+00

-

1.58E+02

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

1.95E-02

1.00E+00

0.00E+00

0.00E+00

0.00E+00

-

5.72E+01

0.00E+00

0.00E+00

0.00E+00

-

1.94E-08

1.94E-08

0.00E+00

0.00E+00

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

2.41 E-03

2.00E+01

0.00E+00

0.00E+00

0.00E+00

-

7.32E+00

0.00E+00

0.00E+00

0.00E+00

-

5.07E-10

5.07E-10

2.41 E-03

2.00E+01

0.00E+00

0.00E+00

0.00E+00

-

7.32E+00

0.00E+00

0.00E+00

0.00E+00

-

2.35E-11

2.35E-11

6.00E-01

1.50E+03

0.00E+00

0.00E+00

0.00E+00

-

1.93E+03

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

7.13E-03

4.00E-01

0.00E+00

0.00E+00

0.00E+00

-

1.26E+01

0.00E+00

0.00E+00

0.00E+00

-

1.19E-09

1.19E-09















0.00E+00

0.00E+00

0.00E+00



1.04E-05

1.04E-05

9.00E-01

1.00E+01

0.00E+00

0.00E+00

0.00E+00

-

3.22E+04

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

5.00E-01

4.80E+02

0.00E+00

0.00E+00

0.00E+00

-

4.27E+03

0.00E+00

0.00E+00

0.00E+00

-

5.57E-08

5.57E-08

5.00E-01

4.80E+02

0.00E+00

0.00E+00

0.00E+00

-

4.27E+03

0.00E+00

0.00E+00

0.00E+00

-

1.13E-09

1.13E-09

1.00E+00

6.30E+03

0.00E+00

0.00E+00

0.00E+00

-

3.49E+04

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

1.00E-01

2.00E+03

0.00E+00

0.00E+00

0.00E+00

-

5.29E+00

0.00E+00

0.00E+00

0.00E+00

-

2.54E-14

2.54E-14

1.00E-01

2.00E+03

0.00E+00

0.00E+00

0.00E+00

-

5.29E+00

0.00E+00

0.00E+00

0.00E+00

-

0.00E+00

0.00E+00

1.26E-02

1.50E+02

0.00E+00

0.00E+00

0.00E+00

-

5.76E+02

0.00E+00

0.00E+00

0.00E+00

-

6.78E-07

6.78E-07

Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Risk Contributions for Soil - Secular Equilibrium

17







External





Plant to









1000029











Exposure





Beef









m2

0 cm









Slope

Food

Soil

Transfer









Soil

Soil

Total



ICRP

Inhalation

Factor

Ingestion Ingestion

Factor



Particulate





Volume

Volume

Indoor



Lung

Slope

(risktyr

Slope

Slope

(pCi/kg



Emission





Area

Gamma

GSF



Absorption

Factor

per

Factor

Factor

per

Concentration

Factor

Lambda

Halflife

Correction Shielding

Soil

Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(risk/pCi)

pCi/d)

(pCi/g)

(m3/kg)

(1/yr)

(yr)

Factor

Factor

Volume

Pb-214

S

7.77E-11

9.94E-07

4.85E-13

7.92E-13

7.00E-04

1

2.37E+09

1.36E+04

5.10E-05

1.00E+00

1.00E+00

0.00E+00

Po-210

S

1.45E-08

4.51 E-11

2.25E-09

3.27E-09

5.00E-03

1

2.37E+09

1.83E+00

3.79E-01

1.00E+00

1.00E+00

0.00E+00

Po-214

-

0.00E+00

3.85E-10

0.00E+00

0.00E+00

5.00E-03

1

2.37E+09

1.33E+11

5.21E-12

1.00E+00

1.00E+00

0.00E+00

Po-218

-

1.39E-11

6.84E-15

0.00E+00

0.00E+00

5.00E-03

1

2.37E+09

1.17E+05

5.90E-06

9.00E-01

1.00E+00

0.00E+00

Ra-226

s

2.82E-08

2.50E-08

5.14E-10

6.77E-10

1.70E-03

1

2.37E+09

4.33E-04

1.60E+03

1.00E+00

1.00E+00

0.00E+00

Rn-218

-

0.00E+00

3.39E-09

0.00E+00

0.00E+00

0.00E+00

1

2.37E+09

6.24E+08

1.11E-09

1.00E+00

1.00E+00

0.00E+00

Rn-222

-

2.28E-12

1.69E-09

0.00E+00

0.00E+00

0.00E+00

1

2.37E+09

6.62E+01

1.05E-02

1.00E+00

1.00E+00

0.00E+00

Th-230

F

3.41 E-08

8.45E-10

1.19E-10

1.66E-10

2.30E-04

1

2.37E+09

9.19E-06

7.54E+04

1.00E+00

1.00E+00

0.00E+00

Th-234

S

3.08E-11

1.77E-08

3.39E-11

6.25E-11

2.30E-04

1

2.37E+09

1.05E+01

6.60E-02

1.00E+00

1.00E+00

0.00E+00

TI-206

-

0.00E+00

6.11E-09

0.00E+00

0.00E+00

2.00E-02

1

2.37E+09

8.67E+04

7.99E-06

1.00E+00

1.00E+00

0.00E+00

TI-210

-

0.00E+00

1.34E-05

0.00E+00

0.00E+00

2.00E-02

1

2.37E+09

2.80E+05

2.47E-06

1.00E+00

1.00E+00

0.00E+00

U-234

s

2.78E-08

2.53E-10

9.55E-11

1.48E-10

3.90E-04

1

2.37E+09

2.82E-06

2.46E+05

1.00E+00

1.00E+00

0.00E+00

U-238

s

2.36E-08

1.24E-10

8.66E-11

1.34E-10

3.90E-04

1

2.37E+09

1.55E-10

4.47E+09

1.00E+00

1.00E+00

0.00E+00



Output generated 22MAY2019:10:50:12


-------
Site-Specific

Farmer Individual Risk Contributions for Soil - Secular Equilibrium

Total
Risk
2.79E-10
8.89E-06
0.00E+00
0.00E+00
7.36E-07
0.00E+00
0.00E+00
2.18E-08
6.21 E-09
0.00E+00
0.00E+00
3.01 E-08
2.73E-08

Output generated 22MAY2019:10:50:12

Dry
Soil-to-plant
transfer
factor
(pCi/g-fresh
plant
per
pCi/g-dry

soil)
1.26E-02
2.76E-04
2.76E-04
2.76E-04
1.95E-02
0.00E+00
0.00E+00
2.41 E-03
2.41 E-03
6.00E-01
6.00E-01
7.13E-03
7.13E-03

Kd

Distribution
coefficient
(L/kg)

1.50E+02

2.10E+02

2.10E+02

2.10E+02

1.00E+00

0.00E+00

0.00E+00

2.00E+01

2.00E+01

1.50E+03

1.50E+03

4.00E-01

4.00E-01

Ingestion
CDI

(pCi)

0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00

Inhalation

CDI

(pCi)

0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00

External Produce
Exposure Consumption

CDI

(pCi)

0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00
0.00E+00

CDI

(pCi)

Beef	External	Produce

CDI Ingestion	Inhalation	Exposure Consumption Beef

(pCi) Risk	Risk	Risk	Risk Risk

5.76E+02 0.00E+00	0.00E+00	0.00E+00	- 2.79E-10

3.95E+03 0.00E+00	0.00E+00	0.00E+00	- 8.89E-06

3.95E+03 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

3.95E+03 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

1.43E+03 0.00E+00	0.00E+00	0.00E+00	- 7.36E-07

0.00E+00 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

0.00E+00 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

1.83E+02 0.00E+00	0.00E+00	0.00E+00	- 2.18E-08

1.83E+02 0.00E+00	0.00E+00	0.00E+00	- 6.21 E-09

4.81E+04 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

4.81E+04 0.00E+00	0.00E+00	0.00E+00	- 0.00E+00

3.15E+02 0.00E+00	0.00E+00	0.00E+00	- 3.01 E-08

3.15E+02 0.00E+00	0.00E+00	0.00E+00	- 2.73E-08


-------
DCGL and Ra-226 Risk Contribution Calculations


-------
Derived Concentration Guideline Level (DCGL)and
Percentage Ra-226 Risk Contribution Calculations
Using PRG Calculator Output



Indoor Worker
(Inside Truck)
Risk

Composite Worker

(Outdoor)

Risk

Farmer

(Beef Ingestion)
Risk

Total Risk

*Secular Equilibrium Risk for U-235
and U-238

3.43E-06

6.49 E-06

1.05 E-05

2.04E-05



Indoor Worker
(Inside Truck)
Risk

Composite Worker

(Outdoor)

Risk

Farmer

(Beef Ingestion)
Risk

Total Risk

Risk of Ra-226 through Po-214

3.34 E-06

4.96E-06

7.37E-07

9.03E-06

PRG Calculator- Derived DCGL (Derived Concentration Guideline Level) =
Target Cancer Risk (1E-04) -r Total Risk(2.04E-05) =	4.897 pCi/g

% Contribution of Ra-226 through Po-214 Risk to Total Risk = 44%


-------
PRG Calculator (Updated Peak Risk Option) Output
August 2022


-------
Site-specific

Composite Worker Soil Inputs

1

Variable

A (PEF Dispersion Constant)

B (PEF Dispersion Constant)

City (Climate Zone)

C (PEF Dispersion Constant)

Cover thickness for GSF „ (gamma shielding factor) cm
F(x) (function dependent on U „/U.) unitless
PEF (particulate emission factor) m 3/kg
Q/C,.,^ (g/m2-s per kg/m3)

A, (acres)

Site area for ACF (area correction factor) m 2
ED„, (exposure duration - composite worker) yr
EF,„ (exposure frequency - composite worker) day/yr
ET„ (exposure time - composite worker) hr/day
IRA, (inhalation rate - composite worker) m 3/day
IRS,„ (soil intake rate - composite worker) mg/day
t„ (time - composite worker) yr
TR (target cancer risk) unitless
U„ (mean annual wind speed) m/s
U, (equivalent threshold value)

V (fraction of vegetative cover) unitless

Composite



Worker



Soil



Default

Form-input

Value

Value

16.2302

14.9421

18.7762

17.9869

Default

Albuquerque, NM (3)

216.108

205.1782

0 cm

0 cm

0.194

0.0553

1359344438

2370938158.760359

93.77

29.359877603759234

0.5

500

1000000 m2

1000000 m2

25

25

250

250

8

0.8

60

60

100

100

25

25

1.0E-06

1.0E-04

4.69

4.02

11.32

11.32

0.5

0.5


-------
Composite Worker Parent Risk and CDI at Time=T 0
Soil (no decay)





External



1000000









Exposure

Adult

m2 0 cm

0 cm







Slope

Soil

Soil Soil

Soil



ICRP

Inhalation

Factor

Ingestion

Volume Volume

Volume

Infinite Soil

Lung

Slope

(risk/yr

Slope

Area Gamma

Gamma

Volume

Absorption

Factor

per

Factor Lambda Halflife

Correction Shielding

Shielding

Concentration

Isotope Type

(risk/pCi)

pCi/g)

(risk/pCi) (1/yr) (yr)

Factor Factor

Factor

(pCi/g)

U-235 S

2.50E-08

5.51 E-07

4.92E-11 9.84E-10 7.04E+08

1.00E+00 1.00E+00

1.00E+00

0.04



External











Ingestion Inhalation Exposure



External







CDI CDI

CDI

Ingestion

Inhalation Exposure Total







(pCi) (pCi)

(pCi)

Risk

Risk Risk Risk







2.50E+01 2.11E-04 2.28E-02 1.23E-09 5.27E-12 1.26E-08 1.38E-08


-------
Composite Worker Peak Risk Start Times (by route)
Soil

Peak Risk

Peak Risk Peak Risk Start Time
Start Time Start Time External
Ingestion Inhalation Exposure
(yrs) (yrs) (yrs)

4.482E+05 4.484E+05 4.454E+05

3


-------
Composite Worker Peak Risks
Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)







External











Ingestion

Inhalation

Exposure





External





Concentration

Concentration

Concentration

Ingestion Inhalation Exposure

Total

Isotope

(pCi/g)

(pCi/g)

(pCi/g)

Risk

Risk

Risk

Risk

U-235

4.00E-02

4.00E-02

4.00E-02

1.23E-09

5.27E-12

1.26E-08

1.38E-08

Th-231

4.00E-02

4.00E-02

4.00E-02

2.27E-11

3.17E-16

5.68E-10

5.90E-10

Pa-231

4.00E-02

4.00E-02

4.00E-02

3.86E-09

1.61E-11

2.90E-09

6.78E-09

Ac-227

4.00E-02

4.00E-02

4.00E-02

5.03E-09

3.15E-11

4.53E-12

5.07E-09

Th-227

3.94E-02

3.94E-02

3.94E-02

5.08E-10

7.28E-12

1.00E-08

1.05E-08

Fr-223

5.52E-04

5.52E-04

5.52E-04

1.68E-12

1.18E-16

4.27E-11

4.43E-11

Ra-223

4.00E-02

4.00E-02

4.00E-02

3.08E-09

6.15E-12

1.04E-08

1.35E-08

At-219

3.31 E-08

3.31 E-08

3.31 E-08

0.00E+00

0.00E+00

0.00E+00

0.00E+00

Rn-219

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

5.36E-09

5.36E-09

Bi-215

3.21 E-08

3.21 E-08

3.21 E-08

0.00E+00

0.00E+00

1.99E-14

1.99E-14

Po-215

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

1.71E-11

1.71E-11

Pb-211

4.00E-02

4.00E-02

4.00E-02

6.56E-12

8.50E-15

6.63E-09

6.64E-09

Bi-211

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

4.34E-09

4.34E-09

Po-211

1.10E-04

1.10E-04

1.10E-04

0.00E+00

0.00E+00

2.37E-12

2.37E-12

TI-207

3.99E-02

3.99E-02

3.99E-02

0.00E+00

0.00E+00

3.61 E-10

3.61 E-10

Total Risk

-

-

-

137E-08

6.63E-11

5.32E-08

6.70E-08




-------
Composite Worker Parent Risk and CDI at Time=T 0
Soil (no decay)





External





1000000









Exposure

Adult



m2 0 cm

0 cm







Slope

Soil



Soil Soil

Soil



ICRP

Inhalation

Factor

Ingestion



Volume Volume

Volume

Infinite Soil

Lung

Slope

(risk/yr

Slope



Area Gamma

Gamma

Volume

Absorption

Factor

per

Factor

Lambda Halflife

Correction Shielding

Shielding

Concentration

Isotope Type

(risk/pCi)

pCi/g)

(risk/pCi)

(1/yr) (yr)

Factor Factor

Factor

(pCi/g)

U-238 S

2.36E-08

1.24E-10

4.66E-11

1.55E-10 4.47E+09

1.00E+00 1.00E+00

1.00E+00

1



External













Ingestion Inhalation Exposure





External







CDI CDI

CDI

Ingestion

Inhalation Exposure Total







(pCi) (pCi)

(pCi)

Risk

Risk

Risk Risk







6.25E+02 5.27E-03 5.71 E-01 2.91 E-08 1.25E-10 7.06E-11 2.93E-08


-------
Composite Worker Peak Risk Start Times (by route)
Soil

Peak Risk

Peak Risk Peak Risk Start Time
Start Time Start Time External
Ingestion Inhalation Exposure
(yrs) (yrs) (yrs)

3.521 E+06 3.488E+06 3.523E+06

6


-------
Composite Worker Peak Risks
Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

7







External











Ingestion

Inhalation

Exposure





External





Concentration

Concentration

Concentration

Ingestion Inhalation Exposure

Total

Isotope

(pCi/g)

(pCi/g)

(pCi/g)

Risk

Risk

Risk

Risk

U-238

9.99E-01

9.99E-01

9.99E-01

2.91 E-08

1.25E-10

7.06E-11

2.93E-08

Th-234

9.99E-01

9.99E-01

9.99E-01

5.94E-09

1.62E-13

1.01 E-08

1.61 E-08

Pa-234

1.60E-03

1.60E-03

1.60E-03

9.65E-13

1.01E-17

6.04E-09

6.04E-09

Pa-234m

9.99E-01

9.99E-01

9.99E-01

0.00E+00

0.00E+00

5.17E-08

5.17E-08

U-234

9.99E-01

9.99E-01

9.99E-01

3.19E-08

1.47E-10

1.45E-10

3.22E-08

Th-230

9.99E-01

9.99E-01

9.99E-01

4.83E-08

1.80E-10

4.82E-10

4.90E-08

Ra-226

9.99E-01

9.99E-01

9.99E-01

1.84E-07

1.48E-10

1.43E-08

1.98E-07

Rn-222

9.99E-01

9.99E-01

9.99E-01

0.00E+00

1.20E-14

9.66E-10

9.66E-10

Po-218

9.99E-01

9.99E-01

9.99E-01

0.00E+00

7.32E-14

3.51 E-15

7.68E-14

At-218

2.00E-04

2.00E-04

2.00E-04

0.00E+00

0.00E+00

2.82E-15

2.82E-15

Rn-218

2.00E-07

2.00E-07

2.00E-07

0.00E+00

0.00E+00

3.86E-16

3.86E-16

Pb-214

9.99E-01

9.99E-01

9.99E-01

1.38E-10

4.09E-13

5.67E-07

5.67E-07

Bi-214

9.99E-01

9.99E-01

9.99E-01

9.20E-11

3.26E-13

4.19E-06

4.19E-06

Po-214

9.99E-01

9.99E-01

9.99E-01

0.00E+00

0.00E+00

2.20E-10

2.20E-10

TI-210

2.10E-04

2.10E-04

2.10E-04

0.00E+00

0.00E+00

1.61E-09

1.61E-09

Pb-210

9.99E-01

9.99E-01

9.99E-01

3.74E-07

8.36E-11

8.46E-10

3.75E-07

Bi-210

9.99E-01

9.99E-01

9.99E-01

2.33E-09

2.40E-12

1.58E-09

3.92E-09

Po-210

9.99E-01

9.99E-01

9.99E-01

8.97E-07

7.64E-11

2.57E-11

8.97E-07

Hg-206

1.90E-08

1.90E-08

1.90E-08

0.00E+00

0.00E+00

5.24E-15

5.24E-15

TI-206

1.34E-06

1.34E-06

1.34E-06

0.00E+00

0.00E+00

4.66E-15

4.66E-15

Total Risk

-

-

-

1.57E-06

7.63E-10

4.84E-06

6.42E-06




-------
Site-specific





1

Indoor Worker Soil Inputs







Indoor







Worker







Soil







Default

Form-input



Variable

Value

Value



A (PEF Dispersion Constant)

16.2302

14.9421



B (PEF Dispersion Constant)

18.7762

17.9869



City (Climate Zone)

Default

Albuquerque, NM (3)



C (PEF Dispersion Constant)

216.108

205.1782



Cover thickness for GSF k (gamma shielding factor) cm

0 cm

0 cm



F(x) (function dependent on U „/U.) unitless

0.194

0.0553



PEF (particulate emission factor) m 3/kg

1359344438

2370938158.760359



Q/C,.,^ (g/m2-s per kg/m3)

93.77

29.359877603759234



A, (acres)

0.5

500



Site area for ACF (area correction factor) m 2

1000000 m2

1000000 m2



ED,„ (exposure duration - indoor worker) yr

25

25



EF.„ (exposure frequency - indoor worker) day/yr

250

250



ET.„ (exposure time - indoor worker) hr/day

8

0.8



GSF. (indoor gamma shielding factor) unitless

0.4

0.7



IRA.., (inhalation rate - indoor worker) m 3/day

60

60



IRS,„ (soil intake rate - indoor worker) mg/day

50

50



t,„ (time - indoor worker) yr

25

25



TR (target cancer risk) unitless

1.0E-06

1.0E-04



U„ (mean annual wind speed) m/s

4.69

4.02



U, (equivalent threshold value)

11.32

11.32



V (fraction of vegetative cover) unitless

0.5

0.5










-------
Indoor Worker Parent Risk and CDI at Time=T 0
Soil (no decay)

2

ICRP	Inhalation
Lung Slope

Absorption	Factor

Isotope Type	(risk/pCi)

U-235	S	2.50E-08

External
Exposure
Slope
Factor
(risk/yr

per
pCi/g)
5.51 E-07

Adult
Soil
Ingestion
Slope
Factor
(risk/pCi)
4.92E-11

Lambda
(1/yr)

9.84E-10

Halflife
(yr)

7.04E+08

1000000

m2

m

Soil
Volume
Area
Correction

Factor
1.00E+00

Default

Soil
Volume
Gamma

0 cm
Soil
Volume
Gamma

Shielding Shielding
Factor Factor

1.00E+00 1.00E+00

Total
Indoor
GSF
Soil
Volume
7.00E-01

Infinite Soil
Volume
Concentration
(pCi/g)

0.04

External

Ingestion Inhalation Exposure	External

CDI CDI	CDI Ingestion Inhalation Exposure Total

(pCi) (pCi) (pCi) Risk Risk Risk Risk

1.25E+01 2.11E-04 1.60E-02 6.15E-10 5.27E-12 8.81 E-09 9.43E-09


-------
Indoor Worker Peak Risk Start Times (by route)
Soil

Peak Risk

Peak Risk Peak Risk Start Time
Start Time Start Time External
Ingestion Inhalation Exposure
(yrs) (yrs) (yrs)

4.482E+05 4.484E+05 4.454E+05

3


-------
Indoor Worker Peak Risks
Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)







External











Ingestion

Inhalation

Exposure





External





Concentration

Concentration

Concentration

Ingestion Inhalation Exposure

Total

Isotope

(pCi/g)

(pCi/g)

(pCi/g)

Risk

Risk

Risk

Risk

U-235

4.00E-02

4.00E-02

4.00E-02

6.15E-10

5.27E-12

8.80E-09

9.42E-09

Th-231

4.00E-02

4.00E-02

4.00E-02

1.13E-11

3.17E-16

3.97E-10

4.09E-10

Pa-231

4.00E-02

4.00E-02

4.00E-02

1.93E-09

1.61E-11

2.03E-09

3.98E-09

Ac-227

4.00E-02

4.00E-02

4.00E-02

2.51 E-09

3.15E-11

3.17E-12

2.55E-09

Th-227

3.94E-02

3.94E-02

3.94E-02

2.54E-10

7.28E-12

7.01 E-09

7.27E-09

Fr-223

5.52E-04

5.52E-04

5.52E-04

8.42E-13

1.18E-16

2.99E-11

3.07E-11

Ra-223

4.00E-02

4.00E-02

4.00E-02

1.54E-09

6.15E-12

7.27E-09

8.82E-09

At-219

3.31 E-08

3.31 E-08

3.31 E-08

0.00E+00

0.00E+00

0.00E+00

0.00E+00

Rn-219

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

3.75E-09

3.75E-09

Bi-215

3.21 E-08

3.21 E-08

3.21 E-08

0.00E+00

0.00E+00

1.39E-14

1.39E-14

Po-215

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

1.20E-11

1.20E-11

Pb-211

4.00E-02

4.00E-02

4.00E-02

3.28E-12

8.50E-15

4.64E-09

4.65E-09

Bi-211

4.00E-02

4.00E-02

4.00E-02

0.00E+00

0.00E+00

3.04E-09

3.04E-09

Po-211

1.10E-04

1.10E-04

1.10E-04

0.00E+00

0.00E+00

1.66E-12

1.66E-12

TI-207

3.99E-02

3.99E-02

3.99E-02

0.00E+00

0.00E+00

2.53E-10

2.53E-10

Total Risk

-

-

-

6.87E-09

6.63E-11

3.73E-08

4.42E-08




-------
Indoor Worker Parent Risk and CDI at Time=T 0
Soil (no decay)







External





1000000













Exposure

Adult



m2

Default 0 cm











Slope

Soil



Soil

Soil Soil

Total





ICRP

Inhalation

Factor

Ingestion



Volume

Volume Volume

Indoor

Infinite Soil



Lung

Slope

(risk/yr

Slope



Area

Gamma Gamma

GSF

Volume



Absorption

Factor

per

Factor

Lambda Halflife

Correction Shielding Shielding

Soil

Concentration

Isotope

Type

(risk/pCi)

pCi/g)

(risk/pCi)

(1/yr) (yr)

Factor

Factor Factor

Volume

(pCi/g)

U-238

S

2.36E-08

1.24E-10

4.66E-11

1.55E-10 4.47E+09

1.00E+00

1.00E+00 1.00E+00

7.00E-01

1

External

Ingestion Inhalation Exposure	External

CDI CDI	CDI Ingestion Inhalation Exposure Total

(pCi) (pCi) (pCi) Risk Risk Risk Risk

3.13E+02 5.27E-03 4.00E-01 1.46E-08 1.25E-10 4.95E-11 1.47E-08


-------
Indoor Worker Peak Risk Start Times (by route)
Soil

Peak Risk

Peak Risk Peak Risk Start Time
Start Time Start Time External
Ingestion Inhalation Exposure
(yrs) (yrs) (yrs)

3.521 E+06 3.488E+06 3.523E+06

6


-------
Indoor Worker Peak Risks
Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

7







External











Ingestion

Inhalation

Exposure





External





Concentration

Concentration

Concentration

Ingestion Inhalation Exposure

Total

Isotope

(pCi/g)

(pCi/g)

(pCi/g)

Risk

Risk

Risk

Risk

U-238

9.99E-01

9.99E-01

9.99E-01

1.46E-08

1.25E-10

4.94E-11

1.47E-08

Th-234

9.99E-01

9.99E-01

9.99E-01

2.97E-09

1.62E-13

7.09E-09

1.01E-08

Pa-234

1.60E-03

1.60E-03

1.60E-03

4.83E-13

1.01E-17

4.23E-09

4.23E-09

Pa-234m

9.99E-01

9.99E-01

9.99E-01

0.00E+00

0.00E+00

3.62E-08

3.62E-08

U-234

9.99E-01

9.99E-01

9.99E-01

1.59E-08

1.47E-10

1.01E-10

1.62E-08

Th-230

9.99E-01

9.99E-01

9.99E-01

2.42E-08

1.80E-10

3.38E-10

2.47E-08

Ra-226

9.99E-01

9.99E-01

9.99E-01

9.20E-08

1.48E-10

9.98E-09

1.02E-07

Rn-222

9.99E-01

9.99E-01

9.99E-01

0.00E+00

1.20E-14

6.76E-10

6.76E-10

Po-218

9.99E-01

9.99E-01

9.99E-01

0.00E+00

7.32E-14

2.46E-15

7.57E-14

At-218

2.00E-04

2.00E-04

2.00E-04

0.00E+00

0.00E+00

1.97E-15

1.97E-15

Rn-218

2.00E-07

2.00E-07

2.00E-07

0.00E+00

0.00E+00

2.70E-16

2.70E-16

Pb-214

9.99E-01

9.99E-01

9.99E-01

6.89E-11

4.09E-13

3.97E-07

3.97E-07

Bi-214

9.99E-01

9.99E-01

9.99E-01

4.60E-11

3.26E-13

2.93E-06

2.93E-06

Po-214

9.99E-01

9.99E-01

9.99E-01

0.00E+00

0.00E+00

1.54E-10

1.54E-10

TI-210

2.10E-04

2.10E-04

2.10E-04

0.00E+00

0.00E+00

1.13E-09

1.13E-09

Pb-210

9.99E-01

9.99E-01

9.99E-01

1.87E-07

8.36E-11

5.92E-10

1.88E-07

Bi-210

9.99E-01

9.99E-01

9.99E-01

1.17E-09

2.40E-12

1.11E-09

2.27E-09

Po-210

9.99E-01

9.99E-01

9.99E-01

4.48E-07

7.64E-11

1.80E-11

4.48E-07

Hg-206

1.90E-08

1.90E-08

1.90E-08

0.00E+00

0.00E+00

3.67E-15

3.67E-15

TI-206

1.34E-06

1.34E-06

1.34E-06

0.00E+00

0.00E+00

3.27E-15

3.27E-15

Total Risk

-

-

-

7.86E-07

7.63E-10

3.39E-06 4.18E-06




-------
Site-specific
Farmer Soil Inputs

1



Farmer





Soil





Default

Form-input

Variable

Value

Value

A (PEF Dispersion Constant)

16.2302

14.9421

B (PEF Dispersion Constant)

18.7762

17.9869

City (Climate Zone)

Default

Albuquerque, NM (3)

C (PEF Dispersion Constant)

216.108

205.1782

Cover thickness for GSF „ (gamma shielding factor) cm

0 cm

0 cm

Cover thickness for GSF k (gamma shielding factor) cm

0 cm

0 cm

CFfarjmli„ (contaminated plant fraction) unitless

1

1

CFfarl_, (beef contaminated fraction) unitless

1

.48

EDfar (exposure duration - farmer) yr

40

25

EDfar, (exposure duration - farmer adult) yr

34

25

EDfa (exposure duration - farmer child) yr

6



EFfar = (exposure frequency - farmer adult) day/yr

350

350

EFfa„ (exposure frequency - farmer child) day/yr

350

350

IFBfar =J. (age-adjusted beef ingestion fraction) g

3349850

2363375.0000000005

IRBfar = (beef ingestion rate - farmer adult) g/day

270.1

270.1

IRBfa„ (beef ingestion rate - farmer child) g/day

64.6

0

tfar (time - farmer) yr

40

25

TR (target cancer risk) unitless

1.0E-06

1.0E-04

F(x) (function dependent on U „/U.) unitless

0.194

0.0553

PEF (particulate emission factor) m 3/kg

1359344438

2370938158.760359

Q/C,.,^ (g/m2-s per kg/m3)

93.77

29.359877603759234

A, (acres)

0.5

500

Slab size for ACF (area correction factor) m 2

1000000 m2

1000000 m2

EDfar (exposure duration - farmer) yr

40



EDfa„ (exposure duration - farmer adult) yr

34

25

EDfa„ (exposure duration - farmer child) yr

6



EFfar (exposure frequency) day/yr

350

350

EFfar = (exposure frequency - farmer adult) day/yr

350

350

EFfa„ (exposure frequency - farmer child) day/yr

350

350

ETfar (exposure time - farmer) hr/day

24

24

ETfar = (exposure time - farmer adult) hr/day

24

24

ETfa„ (exposure time - farmer child) hr/day

24

24

ETfer. (indoor exposure time fraction) hr/day

10.008

10.008


-------
Site-specific
Farmer Soil Inputs

2



Farmer





Soil





Default

Form-input

Variable

Value

Value

ETfa„ (outdoor exposure time fraction) hr/day

12.168

12.168

(animal on-site fraction) unitless

1

1

f. (fraction of year animal on site) unitless

1

.375

GSF. (gamma shielding factor - indoor)

0.4

0

IFAfar=J. (age-adjusted soil inhalation factor) m 3

259000

0

IFSfar=J. (age-adjusted soil ingestion factor) mg

1610000

0

IRA^, (inhalation rate - farmer adult) m 3/day

20

0

IRA^„ (inhalation rate - farmer child) m 3/day

10

0

IRSfar, (soil ingestion rate - farmer adult) mg/day

100

0

IRSfa (soil ingestion rate - farmer child) mg/day

200

¦

(pasture plant mass loading factor) unitless

0.25

0.25

Q^», (beef fodder intake rate) kg/day

11.77

11.77

Q„ k„, (beef soil intake rate) kg/day

0.5

0.5

tfar (time - farmer) yr

40



TR (target cancer risk) unitless

1.0E-06

1.0E-04

Soil Type

Default

Default

U„ (mean annual wind speed) m/s

4.69

4.02

U, (equivalent threshold value)

11.32

11.32

V (fraction of vegetative cover) unitless

0.5

0.5


-------
Farmer Parent Risk and CDI at Time=T 0
Soil (no decay)

Dry
Soil-to-plant

External	1000000	transfer

Exposure m2 0 cm factor	Beef

Slope Food Soil Soil Soil (pCi/g-fresh	Transfer

ICRP Inhalation Factor Ingestion Ingestion Volume Volume Kj Particulate plant	Factor

Lung Slope (risk/yr Slope Slope Area Gamma Distribution Emission per	(pCi/kg

Absorption Factor per Factor Factor Lambda Halflife Correction Shielding coefficient Factor pCi/g-dry	per

Isotope Type (risk/pCi) pCi/g) (risk/pCi) (risk/pCi) (1/yr) (yr) Factor Factor (L/kg) (m-^/kg) soil)	pCi/d)

U-235 S 2.50E-08 5.51 E-07 9.44E-11 1.48E-10 9.84E-10 7.04E+08 1.00E+00 1.00E+00 4.00E-01 2.37E+09 7.13E-03	3.90E-04

Infinite Soil	External Produce	Beef

Volume	Ingestion Inhalation Exposure Consumption Consumption External Produce	Beef

Concentration	CDI CDI CDI CDI	CDI Ingestion	Inhalation Exposure Consumption Consumption Total

(pCi/g)	(pCi) (pCi) (pCi) (pCi) (pCi) Risk Risk Risk Risk	Risk	Risk

0.04	0.00E+00 0.00E+00 4.86E-01 - 2.89E+01 0.00E+00	0.00E+00 2.68E-07 -	2.73E-09 2.71 E-07


-------
Farmer Peak Risk Start Times (by route)
Soil

Peak Risk	Peak Risk

Start Time	Start Time
External Beef

Exposure	Ingestion

(yrs) (yrs)

4.454E+05	4.487E+05

4


-------
Farmer Peak Risks

Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

5

External	Produce	Finfish

Ingestion Inhalation Exposure	Ingestion	Ingestion

Concentration Concentration Concentration	Concentration	Concentration

Isotope (pCi/g) (pCi/g) (pCi/g)	(pCi/g)	(pCi/g)

U-235

4.00E-02

Th-231

4.00E-02

Pa-231

4.00E-02

Ac-227

4.00E-02

Th-227

3.94E-02

Fr-223

5.52E-04

Ra-223

4.00E-02

At-219

3.31 E-08

Rn-219

4.00E-02

Bi-215

3.21 E-08

Po-215

4.00E-02

Pb-211

4.00E-02

Bi-211

4.00E-02

Po-211

1.10E-04

TI-207

3.99E-02

Total Risk .....


-------
Farmer Peak Risks

Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

6

Beef

Ingestion
Concentration
(pCi/g)

External Produce Beef
Ingestion Inhalation Exposure Consumption Consumption
Risk Risk Risk Risk Risk

Total
Risk

4.00E-02

-

2.68E-07

-

2.73E-09

2.71 E-07

4.00E-02

-

1.21 E-08

-

5.41 E-11

1.21 E-08

4.00E-02

-

6.18E-08

-

1.05E-10

6.20E-08

4.00E-02

-

9.65E-11

-

4.55E-10

5.51 E-10

3.94E-02

-

2.13E-07

-

1.17E-09

2.14E-07

5.52E-04

-

9.08E-10

-

3.88E-10

1.30E-09

4.00E-02

-

2.21 E-07

-

4.41 E-08

2.65E-07

3.31 E-08

-

0.00E+00

-

0.00E+00

0.00E+00

4.00E-02

-

1.14E-07

-

0.00E+00

1.14E-07

3.21 E-08

-

4.23E-13

-

0.00E+00

4.23E-13

4.00E-02

-

3.64E-10

-

0.00E+00

3.64E-10

4.00E-02

-

1.41 E-07

-

3.06E-11

1.41 E-07

4.00E-02

-

9.25E-08

-

0.00E+00

9.25E-08

1.10E-04

-

5.04E-11

-

0.00E+00

5.04E-11

3.99E-02

-

7.70E-09

-

0.00E+00

7.70E-09

-

.

1.13E-06

-

4.90E-08

1.18E-06


-------
Farmer Parent Risk and CDI at Time=T 0
Soil (no decay)

Dry
Soil-to-plant

External	1000000	transfer

Exposure m2 0 cm factor	Beef

Slope Food Soil Soil Soil (pCi/g-fresh	Transfer

ICRP Inhalation Factor Ingestion Ingestion Volume Volume Kj Particulate plant	Factor

Lung Slope (risk/yr Slope Slope Area Gamma Distribution Emission per	(pCi/kg

Absorption Factor per Factor Factor Lambda Halflife Correction Shielding coefficient Factor pCi/g-dry	per

Isotope Type (risk/pCi) pCi/g) (risk/pCi) (risk/pCi) (1/yr) (yr) Factor Factor (L/kg) (m-^/kg) soil)	pCi/d)

U-238 S 2.36E-08 1.24E-10 8.66E-11 1.34E-10 1.55E-10 4.47E+09 1.00E+00 1.00E+00 4.00E-01 2.37E+09 7.13E-03	3.90E-04

Infinite Soil	External	Produce Beef

Volume	Ingestion Inhalation Exposure	Consumption Consumption

Concentration	CDI CDI CDI	CDI CDI

(pCi/g)	(pCi) (pCi) (pCi)	(pCi) (pCi)

1	0.00E+00 0.00E+00 1.22E+01	- 7.23E+02

External Produce	Beef

Ingestion Inhalation Exposure Consumption	Consumption	Total

Risk Risk Risk Risk	Risk	Risk

0.00E+00 0.00E+00 1.50E-09 -	6.26E-08	6.41 E-08


-------
Farmer Peak Risk Start Times (by route)
Soil

Peak Risk	Peak Risk

Start Time	Start Time
External Beef

Exposure	Ingestion

(yrs) (yrs)

3.523E+06	3.524E+06

8


-------
Farmer Peak Risks

Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

External	Produce	Finfish

Ingestion Inhalation Exposure	Ingestion	Ingestion

Concentration Concentration Concentration	Concentration	Concentration

Isotope (pCi/g) (pCi/g) (pCi/g)	(pCi/g)	(pCi/g)

U-238

9.99E-01

Th-234

9.99E-01

Pa-234

1.60E-03

Pa-234m

9.99E-01

U-234

9.99E-01

Th-230

9.99E-01

Ra-226

9.99E-01

Rn-222

9.99E-01

Po-218

9.99E-01

At-218

2.00E-04

Rn-218

2.00E-07

Pb-214

9.99E-01

Bi-214

9.99E-01

Po-214

9.99E-01

TI-210

2.10E-04

Pb-210

9.99E-01

Bi-210

9.99E-01

Po-210

9.99E-01

Hg-206

1.90E-08

TI-206

1.34E-06

Total Risk .....


-------
Farmer Peak Risks

Soil (complete chain decay)

using the peak risk time intervals from PRG calculations (by route)

10

Beef

Ingestion
Concentration
(pCi/g)

External Produce Beef
Ingestion Inhalation Exposure Consumption Consumption
Risk Risk Risk Risk Risk

Total
Risk

9.99E-01

-

1.50E-09

-

6.26E-08

6.41 E-08

9.99E-01

-

2.16E-07

-

1.43E-08

2.30E-07

1.60E-03

-

1.29E-07

-

5.57E-14

1.29E-07

9.99E-01

-

1.10E-06

-

0.00E+00

1.10E-06

9.99E-01

-

3.08E-09

-

6.90E-08

7.21 E-08

9.99E-01

-

1.03E-08

-

5.01 E-08

6.04E-08

9.99E-01

-

3.04E-07

-

1.67E-06

1.98E-06

9.99E-01

-

2.06E-08

-

0.00E+00

2.06E-08

9.99E-01

-

7.48E-14

-

0.00E+00

7.48E-14

2.00E-04

-

6.00E-14

-

0.00E+00

6.00E-14

2.00E-07

-

8.23E-15

-

0.00E+00

8.23E-15

9.99E-01

-

1.21E-05

-

6.38E-10

1.21E-05

9.99E-01

-

8.92E-05

-

2.29E-09

8.92E-05

9.99E-01

-

4.68E-09

-

0.00E+00

4.68E-09

2.10E-04

-

3.43E-08

-

0.00E+00

3.43E-08

9.99E-01

-

1.80E-08

-

1.55E-06

1.57E-06

9.99E-01

-

3.36E-08

-

1.13E-07

1.46E-07

9.99E-01

-

5.47E-10

-

1.23E-05

1.23E-05

1.90E-08

-

1.12E-13

-

0.00E+00

1.12E-13

1.34E-06

-

9.93E-14

-

0.00E+00

9.93E-14

-

-

1.03E-04

-

1.58E-05

1.19E-04


-------
DCGL Calculation (Updated Peak Risk Option)
August 2022


-------
Derived Concentration Guideline Level (DCGL)
Using PRG Calculator (Peak Risk Option) Output
August 2022



Composite Worker
(Outdoor Worker)
Risk

Indoor Worker
(Inside Truck)
Risk

Farmer
(Beef
Consumption)
Risk

Total Risk

Peak Risk for U-235
and U-238

6.49E-06

4.22E-06

1.58E-05

2.66E-05

PRG Calculator-Derived DCGL (Derived Concentration Guideline Level) =
Target Cancer Risk (1E-04) t Total Risk (2.66E-05) =
3.8	picocuries per gram (pCi/g)


-------
RESRAD Output


-------
RESRAD-ONSITE, Version 7.2	Limit = 30 days	06/06/2019 08:31 Page 1

Intrisk : RESRAD Tronox Ranching Scenario without Radon Inhalation
File	: C:\RESRAD_FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

Table of Contents

Part III: Intake Quantities and Health Risk Factors

Cancer Risk Slope Factors 		2

Risk Slope and ETFG for the Ground Pathway 		4

Amount of Intake Quantities and Excess Cancer Risks

Time= 0.000E+00 		5

Time= 1.000E+00 		8

Time= 3.000E+00 		11

Time= 1.000E+01 		14

Time= 3.000E+01 		17

Time= 1.000E+02 		20

Time= 3.000E+02 		23

Time= 1.000E+03 		26


-------
RESRAD-ONSITE, Version 7.2	Limit = 30 days	06/06/2019 08:31 Page 2

Intrisk : RESRAD Tronox Ranching Scenario

File : C:\RESRAD_FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

Cancer Risk Slope Factors Summary Table
Risk Library: DCFPAK3.02 Morbidity









| Current

| Base

| Parameter

Menu



Parameter

| Value
1

| Case*

| Name

Sf-1

Ground external

radiation

slope factors, 1/yr per (pCi/g):

1

1







Sf-1

Ac-227+D





| 1.63E-06

| 1.98E-10

| SLPF(

1,1)

Sf-1

Pa-231





| 1.27E-07

| 1.27E-07

| SLPF(

2,1)

Sf-1

Pb-210+D





| 4.25E-09

| 1.48E-09

| SLPF(

3,1)

Sf-1

Pb-210+Dl





| 1.72E-08

| 1.48E-09

| SLPF(

4,1)

Sf-1

Po-210





| 4.51E-11

| 4.51E-11

| SLPF(

5,1)

Sf-1

Ra-226+D





| 8.37E-06

| 2.50E-08

| SLPF(

6,1)

Sf-1

Th-230





| 8.45E-10

| 8.45E-10

| SLPF(

8,1)

Sf-1

U-234





| 2.53E-10

| 2.53E-10

| SLPF(

10,1)

Sf-1

U-235+D





| 5.76E-07

| 5.51E-07

| SLPF(

12,1)

Sf-1

U-238





| 1.24E-10

| 1.24E-10

| SLPF(

13,1)

Sf-1

U-238+D





| 1.19E-07

I

| 1.24E-10

| SLPF(

14,1)

Sf-2

Inhalation, slope factors

1/(pCi) :

1

1







Sf-2

Ac-227+D





| 2.13E-07

| 1.49E-07

| SLPF(

1,2)

Sf-2

Pa-231





| 7.62E-08

| 7.62E-08

| SLPF(

2,2)

Sf-2

Pb-210+D





| 1.63E-08

| 1.59E-08

| SLPF(

3,2)

Sf-2

Pb-210+Dl





| 1.63E-08

| 1.59E-08

| SLPF(

4,2)

Sf-2

Po-210





| 1.45E-08

| 1.45E-08

| SLPF(

5,2)

Sf-2

Ra-226+D





| 2.82E-08

| 2.81E-08

| SLPF(

6,2)

Sf-2

Th-230





| 3 . 41E-08

| 3 . 41E-08

| SLPF(

8,2)

Sf-2

U-234





| 2.78E-08

| 2.78E-08

| SLPF(

10,2)

Sf-2

U-235+D





| 2.50E-08

| 2.50E-08

| SLPF(

12,2)

Sf-2

U-238





| 2.36E-08

| 2.36E-08

| SLPF(

13,2)

Sf-2

U-238+D





| 2.37E-08

I

| 2.36E-08

| SLPF(

14,2)

Sf-3

Food ingestion,

slope factors, 1/(pCi):

1

1







Sf-3

Ac-227+D





| 6.54E-10

| 2.45E-10

| SLPF(

1,3)

Sf-3

Pa-231





| 2.26E-10

| 2.26E-10

| SLPF(

2,3)

Sf-3

Pb-210+D





| 1.19E-09

| 1.18E-09

| SLPF(

3,3)

Sf-3

Pb-210+Dl





| 1.19E-09

| 1.18E-09

| SLPF(

4,3)

Sf-3

Po-210





| 2.25E-09

| 2.25E-09

| SLPF(

5,3)

Sf-3

Ra-226+D





| 5.15E-10

| 5.14E-10

| SLPF(

6,3)

Sf-3

Th-230





| 1.19E-10

| 1.19E-10

| SLPF(

8,3)

Sf-3

U-234





| 9 .55E-11

| 9 .55E-11

| SLPF(

10,3)

Sf-3

U-235+D





| 9.76E-11

| 9.43E-11

| SLPF(

12,3)

Sf-3

U-238





| 8.66E-11

| 8.66E-11

| SLPF(

13,3)

Sf-3

U-238+D





| 1.21E-10
|

| 8.66E-11

| SLPF(

14,3)

Sf-3

Water ingestion

slope factors, 1/(pCi):

1

1







Sf-3

Ac-227+D





| 4.87E-10

| 2.01E-10

| SLPF(

1,4 )

Sf-3

Pa-231





| 1.72E-10

| 1.72E-10

| SLPF(

2,4 )

Sf-3

Pb-210+D





| 8.93E-10

| 8.84E-10

| SLPF(

3, 4 )

Sf-3

Pb-210+Dl





| 8.93E-10

| 8.84E-10

| SLPF(

4,4)

Sf-3

Po-210





| 1.78E-09

| 1.78E-09

| SLPF(

5, 4 )

Sf-3

Ra-226+D





| 3.85E-10

| 3.85E-10

| SLPF(

6, 4 )

Sf-3

Th-230





| 9.14E-11

| 9.14E-11

| SLPF(

8,4 )

Sf-3

U-234





| 7.07E-11

| 7.07E-11

| SLPF(

10, 4 )

Sf-3

U-235+D





| 7.17E-11

| 6 . 95E-11

| SLPF(

12,4 )

Sf-3

U-238





| 6.40E-11

| 6.40E-11

| SLPF(

13, 4 )


-------
RESRAD-ONSITE, Version 7.2	Limit = 30 days	06/06/2019 08:31 Page 3

Intrisk : RESRAD Tronox Ranching Scenario

File	: C:\RESRAD_FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

Cancer Risk Slope Factors Summary Table (continued)

Risk Library: DCFPAK3.02 Morbidity





| Current

| Base

| Parameter

Menu

Parameter

| Value
1

| Case*

| Name

Sf-3

U-238+D

1

| 8.71E-11
|

| 6.40E-11

| SLPF( 14,4)

Sf-3

Soil ingestion, slope factors, 1/(pCi):

1

1





Sf-3

Ac-227+D

| 6.54E-10

| 2.45E-10

| SLPF( 1,5)

Sf-3

Pa-231

| 2.26E-10

| 2.26E-10

| SLPF( 2,5)

Sf-3

Pb-210+D

| 1.19E-09

| 1.18E-09

| SLPF( 3,5)

Sf-3

Pb-210+Dl

| 1.19E-09

| 1.18E-09

| SLPF( 4,5)

Sf-3

Po-210

| 2.25E-09

| 2.25E-09

| SLPF( 5,5)

Sf-3

Ra-226+D

| 5.15E-10

| 5.14E-10

| SLPF( 6,5)

Sf-3

Th-230

| 1.19E-10

| 1.19E-10

| SLPF( 8,5)

Sf-3

U-234

| 9 .55E-11

| 9 .55E-11

| SLPF( 10,5)

Sf-3

U-235+D

| 9.76E-11

| 9.43E-11

| SLPF( 12,5)

Sf-3

U-238

| 8.66E-11

| 8.66E-11

| SLPF( 13,5)

Sf-3

U-238+D

| 1.21E-10

I

| 8.66E-11

| SLPF( 14,5)

Sf-Rn

Radon Inhalation slope factors, 1/ (pCi) :

1

1





Sf-Rn

Rn-222

| 1.80E-12

| 1.80E-12

| SLPFRN(1,1)

Sf-Rn

Po-218

| 3.70E-12

| 3.70E-12

| SLPFRN(1,2)

Sf-Rn

Pb-214

| 6.20E-12

| 6.20E-12

| SLPFRN(1,3)

Sf-Rn

Bi-214

| 1.50E-11

I

| 1.50E-11

| SLPFRN(1,4)

Sf-Rn

Radon K factors, (mrem/WLM):

1

1





Sf-Rn

Rn-222 Indoor

| 3 .88E + 02

| 3 .88E + 02

| KFACTR(1,1)

Sf-Rn

Rn-222 Outdoor

| 3 .88E + 02

| 3 .88E + 02

| KFACTR(1,2)

*Base Case means Default.Lib w/o Associate Nuclide contributions.


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RESRAD-ONSITE, Version 7.2	T1^ Limit = 30 days

Intrisk : RESRAD Tronox Ranching Scenario

File : C:\RESRAD FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

06/06/2019 08:31 Page

Risk Slope and Environmental Transport Factors for the Ground Pathway

Nuclide Slope(i)*	ETFG(i,t) At Time in Years (dimensionless)

(i)	t= 0.000E+00 1.000E+00 3.000E+00 1.000E+01 3.000E+01 1.000E+02 3.000E+02 1.000E+03

1.990E-10
2 . 7 4 0E-11
0 .000E+00
2 .770E-09
1.900E-07
7.340E-06
1.080E-06
1.350E-07
4.830E-07
1.270E-07
6.620E-06
9.060E-08
1.480E-09
2.910E-07
9.940E-07
4.510E-11
3.7 60E-08
3.850E-10
7.4 80E-10
6.840E-15
4.550E-07
2.500E-08
3.390E-09
2.350E-07
1.690E-09
4.4 50E-07
8.4 50E-10
2.4 90E-08
1.780E-08
6.110E-09
1.590E-08
1.340E-05
2.530E-10
5.510E-07
1.240E-10

3.876E-02
3.872E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.872E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.874E-02

3.87 6E-02
3.87 2E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.87 2E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.874E-02

3.876E-02
3.872E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.872E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.874E-02

3.87 6E-02
3.87 2E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.87 2E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.874E-02

3.876E-02
3.872E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.872E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.874E-02

3.87 6E-02
3.87 2E-02
0.000E+00
3.87 6E-02
3.87 6E-02
3.87 2E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3. 874E-02

3 .876E-02
3 .872E-02
0 .000E+00
3.87 6E-02
3.87 6E-02
3 .872E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3 .874E-02

3.87 6E-02
3.87 2E-02
0. 000E + 00
3.87 6E-02
3.87 6E-02
3.87 2E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3.87 6E-02
3. 874E-02

- Units are 1/yr per (pCi/g) at infinite depth and area. Multiplication by ETFG(i,t) converts to site conditions.


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RESRAD-ONSITE, Version 7.2	Limit = 30 days	06/06/2019 08:31 Page 5

Intrisk : RESRAD Tronox Ranching Scenario

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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 0.000E+00 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

6.976E-03
6.976E-03
6.976E-03
6.976E-03
6.976E-03
6.976E-03
6.976E-03
6.976E-03
6.976E-03

Milk

Soil

Fish

Plant

Milk

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

9.705E-02
2.831E+01
4.529E+00
2.345E+01
8.898E+00
4.691E-01
1.650E+00
1.650E+00
1.650E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.14 0E + 00

1.14 0E + 00
1.14 0E + 00
1.14 0E + 00
1.14 0E + 00
1.14 0E + 00
1.14 0E + 00
1.14 0E + 00
1.14 0E + 00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

1. 237E+00
2 . 945E+01
5.669E+00
2 . 459E+01
1. 004E+01
1. 609E+00
2 . 790E+00
2 . 790E+00
2 . 790E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn,i,t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 0.000E+00 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 0.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

1.445E-06

0

1210

3. 405E-08

0

0029

0.000E+00

0

0000

2 .223E-09

0.0002

0.000E+00

0

0000

1. 706E-08

0

0014

Pa-231

1.181E-07

0

0099

1. 275E-08

0

0011

0.000E+00

0

0000

1 .533E-07

0.0128

0. 000E + 00

0

0000

6.173E-09

0

0005

Pb-210

4.026E-09

0

0003

2 . 783E-09

0

0002

0.000E+00

0

0000

1 .321E-07

0.0111

0.000E+00

0

0000

3.313E-08

0

0028

Po-210

4.240E-11

0

0000

2 . 453E-09

0

0002

0.000E+00

0

0000

1 .233E-06

0.1032

0.000E+00

0

0000

6.22 9E-08

0

0052

Ra-226

7.863E-06

0

6583

4 . 779E-09

0

0004

0.000E+00

0

0000

1 .113E-07

0.0093

0.000E+00

0

0000

1. 425E-08

0

0012

Th-230

8.188E-10

0

0001

5. 941E-09

0

0005

0. 000E + 00

0

0000

1 .397E-09

0.0001

0. 000E + 00

0

0000

3.394E-09

0

0003

U-234

2.353E-10

0

0000

4 . 656E-09

0

0004

0.000E+00

0

0000

3 .779E-09

0.0003

0. 000E + 00

0

0000

2.611E-09

0

0002

U-235

5.355E-07

0

0448

4 .186E-09

0

0004

0. 000E + 00

0

0000

3 .8 62E-09

0.0003

0. 000E + 00

0

0000

2.668E-09

0

0002

U-238

1.108E-07

0

0093

3. 961E-09

0

0003

0.000E+00

0

0000

4 .771E-09

0.0004

0.000E+00

0

0000

3.296E-09

0

0003

Total

1.008E-05

0

8438

7 . 557E-08

0

0063

0.000E+00

0

0000

1.64 6E-06

0.1378

0. 000E + 00

0

0000

1.44 9E-07

0

0121


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 0.000E+00 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 498E-06

0

1255

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 903E-07

0

0243

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 721E-07

0

0144

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 298E-06

0

1086

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

7 . 993E-06

0

6692

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0

0010

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1.128E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

5. 4 62E-07

0

0457

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 228E-07

0

0103

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.194E-05

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 0.000E+00 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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RESRAD-ONSITE, Version 7.2	TH Limit = 30 days

Intrisk : RESRAD Tronox Ranching Scenario

File : C:\RESRAD FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

06/06/2019 08:31 Page 7

Total Excess Cancer Risk CNRS(i,p,t)*** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 0.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

9.967E-07

0

0835

2.34 9E-08

0

0020

0.000E+00

0

0000

0 .000E+00

0.0000

1.002E-09

0

0001

0.000E+00

0

0000

1.177E-08

0

0010

Pa-231

5.663E-07

0

0474

2.331E-08

0

0020

0.000E+00

0

0000

0 .000E+00

0.0000

1.54 5E-07

0

0129

0. 000E+00

0

0000

1.14 6E-08

0

0010

Pb-210

2.837E-09

0

0002

3.625E-09

0

0003

0.000E+00

0

0000

0 .000E+00

0.0000

9.37 5E-07

0

0785

0.000E+00

0

0000

6.588E-08

0

0055

Po-210

9.471E-13

0

0000

5.480E-11

0

0000

0.000E+00

0

0000

0 .000E+00

0.0000

2.865E-08

0

0024

0. 000E+00

0

0000

1. 392E-09

0

0001

Ra-226

7.821E-06

0

6548

6.303E-09

0

0005

0.000E+00

0

0000

0 .000E+00

0.0000

5.07 9E-07

0

0425

0.000E+00

0

0000

4 . 222E-08

0

0035

Th-230

4.366E-08

0

0037

5.973E-09

0

0005

0.000E+00

0

0000

0 .000E+00

0.0000

3.503E-09

0

0003

0. 000E+00

0

0000

3.578E-09

0

0003

U-234

2.38 6E-10

0

0000

4.656E-09

0

0004

0.000E+00

0

0000

0 .000E+00

0.0000

3.77 9E-09

0

0003

0.000E+00

0

0000

2. 611E-09

0

0002

U-235

5.356E-07

0

0448

4.191E-09

0

0004

0.000E+00

0

0000

0 .000E+00

0.0000

3.902E-09

0

0003

0. 000E+00

0

0000

2.671E-09

0

0002

U-238

1.108E-07

0

0093

3.962E-09

0

0003

0.000E+00

0

0000

0 .000E+00

0.0000

4 . 771E-09

0

0004

0.000E+00

0

0000

3. 296E-09

0

0003

Total

1.008E-05

0

8438

7.557E-08

0

0063

0.000E+00

0

0000

0 .000E+00

0.0000

1. 64 6E—0 6

0

1378

0. 000E+00

0

0000

1.44 9E-07

0

0121

Total Risk Across All Pathways = 1.19E-05. DCGL = Target Risk of 0.0001 - Total Risk of 1.19E-05 = 8.4 pCi/g

Total Excess Cancer Risk CNRS(i,p,t)*** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 0.000E+00 years

Water Dependent Pathways

Nuclide risk fract.

risk fract.

risk fract.

risk fract.

risk fract.

risk fract.

All pathways

risk fract.

Ac-227

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1. 033E-06

0

0865

Pa-231

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E+00

0

0000

7.556E-07

0

0633

Pb-210

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1.010E-06

0

0846

Po-210

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E+00

0

0000

3.010E-08

0

0025

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

8.377E-06

0

7014

Th-230

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E+00

0

0000

5.671E-08

0

0047

U-234

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1.128E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E+00

0

0000

5.4 64E-07

0

0458

U-238

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1. 228E-07

0

0103

0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 1.194E-05 1.0000

**CNRSI(i,p,t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 1.000E+00 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

6.919E-03
6.953E-03
6.964E-03
6.918E-03
6.959E-03
6.976E-03
6.953E-03
6.953E-03
6.953E-03

Milk

Soil

Fish

Plant

Milk

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.454E-01

2.822E+01
4.54 0E + 00
2.237E+01
8.879E+00
4.691E-01
1.645E+00
1.645E+00
1.645E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.131E+00

1.136E+00
1.138E+00
1.130E+00
1.137E+00
1.14 0E + 00
1.136E+00
1.136E+00
1.136E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

1. 276E+00
2 . 936E+01
5.678E+00
2 . 350E+01
1. 002E+01
1. 609E+00
2 . 781E+00
2 . 781E+00
2 . 781E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn,i,t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 1.000E+00 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

1.435E-06

0

1205

3.383E-08

0

0028

0.000E+00

0

0000

2 .213E-09

0.0002

0. 000E + 00

0

0000

1. 695E-08

0

0014

Pa-231

1.177E-07

0

0099

1. 271E-08

0

0011

0.000E+00

0

0000

1 .528E-07

0.0128

0. 000E + 00

0

0000

6.152E-09

0

0005

Pb-210

4.019E-09

0

0003

2 . 778E-09

0

0002

0.000E+00

0

0000

1 .319E-07

0.0111

0.000E+00

0

0000

3. 307E-08

0

0028

Po-210

4.231E-11

0

0000

2 . 448E-09

0

0002

0.000E+00

0

0000

1 .230E-06

0.1033

0.000E+00

0

0000

6. 217E-08

0

0052

Ra-226

7.844E-06

0

6587

4 . 768E-09

0

0004

0.000E+00

0

0000

1 .110E-07

0.0093

0.000E+00

0

0000

1. 422E-08

0

0012

Th-230

8.188E-10

0

0001

5. 941E-09

0

0005

0. 000E + 00

0

0000

1 .397E-09

0.0001

0.000E+00

0

0000

3. 394E-09

0

0003

U-234

2.345E-10

0

0000

4 . 640E-09

0

0004

0.000E+00

0

0000

3 .7 66E-09

0.0003

0. 000E + 00

0

0000

2 . 602E-09

0

0002

U-235

5.337E-07

0

0448

4 .172E-09

0

0004

0. 000E + 00

0

0000

3.84 9E-09

0.0003

0. 000E + 00

0

0000

2 . 659E-09

0

0002

U-238

1.104E-07

0

0093

3. 948E-09

0

0003

0.000E+00

0

0000

4 .755E-09

0.0004

0. 000E + 00

0

0000

3. 285E-09

0

0003

Total

1.005E-05

0

8437

7 . 524E-08

0

0063

0.000E+00

0

0000

1 . 642E-06

0.1379

0. 000E + 00

0

0000

1. 445E-07

0

0121


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+00 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 488E-06

0

1250

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 894E-07

0

0243

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 718E-07

0

0144

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 295E-06

0

1087

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

7 . 974E-06

0

6696

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0

0010

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1.124E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

5.44 4E-07

0

0457

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 224E-07

0

0103

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.191E-05

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 1.000E+00 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

9.57 6E-07

0

0804

2 . 257E-08

0

0019

0. 000E + 00

0

0000

0 .000E + 00

0.0000

9. 631E-10

0

0001

0. 000E + 00

0

0000

1.131E-08

0

0009

Pa-231

5.955E-07

0

0500

2 . 397E-08

0

0020

0.000E+00

0

0000

0 .000E + 00

0.0000

1.540E-07

0

0129

0. 000E + 00

0

0000

1.179E-08

0

0010

Pb-210

2.74 6E-09

0

0002

3.553E-09

0

0003

0. 000E + 00

0

0000

0 .000E + 00

0.0000

9. 305E-07

0

0781

0. 000E + 00

0

0000

6. 488E-08

0

0054

Po-210

1.495E-13

0

0000

8.652E-12

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

4 . 525E-09

0

0004

0. 000E + 00

0

0000

2 .197E-10

0

0000

Ra-226

7.799E-06

0

6549

6. 398E-09

0

0005

0.000E+00

0

0000

0 .000E + 00

0.0000

5.357E-07

0

0450

0. 000E + 00

0

0000

4 . 415E-08

0

0037

Th-230

4.704E-08

0

0040

5. 975E-09

0

0005

0.000E+00

0

0000

0 .000E + 00

0.0000

3.729E-09

0

0003

0. 000E + 00

0

0000

3. 597E-09

0

0003

U-234

2.382E-10

0

0000

4 . 641E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3.767E-09

0

0003

0. 000E + 00

0

0000

2 . 602E-09

0

0002

U-235

5.339E-07

0

0448

4 .178E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3. 893E-09

0

0003

0. 000E + 00

0

0000

2.662E-09

0

0002

U-238

1.104E-07

0

0093

3. 949E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

4.755E-09

0

0004

0. 000E + 00

0

0000

3. 285E-09

0

0003

Total

1.005E-05

0

8437

7 . 524E-08

0

0063

0. 000E + 00

0

0000

0 .000E+00

0.0000

1. 642E-06

0

1379

0. 000E + 00

0

0000

1. 445E-07

0

0121

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+00 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

9. 924E-07

0

0833

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

7 . 853E-07

0

0659

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 002E-06

0

0841

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

4 . 753E-09

0

0004

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

8.385E-06

0

7042

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

6. 034E-08

0

0051

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1.125E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

5.44 6E-07

0

0457

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 224E-07

0

0103

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.191E-05

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 3.000E+00 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

6.810E-03
6.907E-03
6.941E-03
6.88 6E-03
6.926E-03
6.976E-03
6.907E-03
6.907E-03
6.907E-03

Milk

Soil

Fish

Plant

Milk

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.435E-01

2.804E+01
4.524E+00
2.227E+01
8.837E+00
4.691E-01
1.634E+00
1.634E+00
1.634E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.113E+00

1.129E+00
1.134E+00
1.125E+00
1.132E+00
1.14 0E + 00
1.129E+00
1.129E+00
1.129E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

1.256E+00
2.916E+01
5.658E+00
2.339E+01
9. 969E+00
1. 609E+00
2 . 763E+00
2 . 763E+00
2 . 763E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn, i, t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 3.000E+00 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

1.417E-06

0

1197

3.339E-08

0

0028

0.000E+00

0

0000

2 .189E-09

0.0002

0.000E+00

0

0000

1.673E-08

0

0014

Pa-231

1.169E-07

0

0099

1.263E-08

0

0011

0.000E+00

0

0000

1 .518E-07

0.0128

0. 000E + 00

0

0000

6.112E-09

0

0005

Pb-210

4.003E-09

0

0003

2.768E-09

0

0002

0.000E+00

0

0000

1 .314E-07

0.0111

0.000E+00

0

0000

3. 294E-08

0

0028

Po-210

4.215E-11

0

0000

2.439E-09

0

0002

0.000E+00

0

0000

1 .225E-06

0.1035

0.000E+00

0

0000

6.193E-08

0

0052

Ra-226

7.807E-06

0

6594

4.745E-09

0

0004

0.000E+00

0

0000

1 .105E-07

0.0093

0.000E+00

0

0000

1. 415E-08

0

0012

Th-230

8.188E-10

0

0001

5.941E-09

0

0005

0. 000E + 00

0

0000

1 .397E-09

0.0001

0. 000E + 00

0

0000

3. 394E-09

0

0003

U-234

2.329E-10

0

0000

4.610E-09

0

0004

0.000E+00

0

0000

3 . 741E-09

0.0003

0. 000E + 00

0

0000

2 . 585E-09

0

0002

U-235

5.302E-07

0

0448

4.144E-09

0

0004

0. 000E + 00

0

0000

3 .824E-09

0.0003

0. 000E + 00

0

0000

2.642E-09

0

0002

U-238

1.097E-07

0

0093

3.922E-09

0

0003

0.000E+00

0

0000

4 . 724E-09

0.0004

0.000E+00

0

0000

3. 263E-09

0

0003

Total

9.98 6E-0 6

0

8435

7.459E-08

0

0063

0.000E+00

0

0000

1 . 635E-06

0.1381

0. 000E + 00

0

0000

1. 438E-07

0

0121


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+00 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 4 69E-06

0

1241

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 875E-07

0

0243

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 711E-07

0

0145

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 290E-06

0

1089

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

7 . 936E-06

0

6704

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0

0010

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1.117E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

5. 408E-07

0

0457

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 216E-07

0

0103

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.184E-05

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 3.000E+00 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+00 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

8.838E-07

0

0746

2 . 083E-08

0

0018

0. 000E + 00

0

0000

0 .000E + 00

0.0000

8.889E-10

0

0001

0. 000E + 00

0

0000

1. 044E-08

0

0009

Pa-231

6.49 9E-07

0

0549

2 . 519E-08

0

0021

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 531E-07

0

0129

0. 000E + 00

0

0000

1. 240E-08

0

0010

Pb-210

2.571E-09

0

0002

3. 335E-09

0

0003

0. 000E + 00

0

0000

0 .000E + 00

0.0000

8 . 754E-07

0

0739

0. 000E + 00

0

0000

6. 095E-08

0

0051

Po-210

3.727E-15

0

0000

2 .157E-13

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

1.128E-10

0

0000

0. 000E + 00

0

0000

5.47 6E-12

0

0000

Ra-226

7.756E-06

0

6551

6.577E-09

0

0006

0.000E+00

0

0000

0 .000E + 00

0.0000

5.890E-07

0

0497

0. 000E + 00

0

0000

4.782E-08

0

0040

Th-230

5.378E-08

0

0045

5.981E-09

0

0005

0.000E+00

0

0000

0 .000E + 00

0.0000

4 . 217E-09

0

0004

0. 000E + 00

0

0000

3. 637E-09

0

0003

U-234

2.376E-10

0

0000

4 . 610E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3.742E-09

0

0003

0. 000E + 00

0

0000

2 . 585E-09

0

0002

U-235

5.304E-07

0

0448

4 .151E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3.873E-09

0

0003

0. 000E + 00

0

0000

2.645E-09

0

0002

U-238

1.097E-07

0

0093

3. 922E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

4 . 724E-09

0

0004

0. 000E + 00

0

0000

3. 263E-09

0

0003

Total

9.98 6E-0 6

0

8435

7 . 459E-08

0

0063

0. 000E + 00

0

0000

0 .000E+00

0.0000

1. 635E-06

0

1381

0. 000E + 00

0

0000

1. 438E-07

0

0121

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+00 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

9.160E-07

0

0774

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

8 . 406E-07

0

0710

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

9. 423E-07

0

0796

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.185E-10

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

8 . 399E-06

0

7094

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

6. 761E-08

0

0057

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1.117E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

5. 410E-07

0

0457

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 216E-07

0

0103

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.184E-05

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 1.000E+01 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

6.470E-03
6.74 8E-03
6.854E-03
6.800E-03
6.813E-03
6.976E-03
6.74 8E-03
6.74 8E-03
6.74 8E-03

Milk

Soil

Fish

Plant

Milk

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.377E-01

2.739E+01
4.4 68E + 00
2.199E+01
8.692E+00
4.691E-01
1.596E+00
1.596E+00
1.596E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.057E+00
1.103E+00
1.120E+00
1.111E+00
1.113E+00
1.14 0E + 00
1.103E+00
1.103E+00
1.103E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

1.195E+00
2.84 9E+01
5.588E+00
2.310E+01
9. 805E+00
1. 609E+00
2 . 699E+00
2 . 699E+00
2 . 699E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn, i, t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 1.000E+01 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+01 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

1.358E-06

0

1170

3. 201E-08

0

0028

0.000E+00

0

0000

2 .113E-09

0.0002

0.000E+00

0

0000

1. 604E-08

0

0014

Pa-231

1.142E-07

0

0098

1. 234E-08

0

0011

0.000E+00

0

0000

1 .483E-07

0.0128

0. 000E + 00

0

0000

5.971E-09

0

0005

Pb-210

3.949E-09

0

0003

2 . 730E-09

0

0002

0.000E+00

0

0000

1 .296E-07

0.0112

0.000E+00

0

0000

3.24 9E-08

0

0028

Po-210

4.158E-11

0

0000

2 . 406E-09

0

0002

0.000E+00

0

0000

1 .209E-06

0.1041

0.000E+00

0

0000

6.109E-08

0

0053

Ra-226

7.680E-06

0

6616

4 . 668E-09

0

0004

0.000E+00

0

0000

1 .087E-07

0.0094

0.000E+00

0

0000

1. 392E-08

0

0012

Th-230

8.187E-10

0

0001

5. 941E-09

0

0005

0. 000E + 00

0

0000

1 .397E-09

0.0001

0. 000E + 00

0

0000

3. 394E-09

0

0003

U-234

2.276E-10

0

0000

4 . 504E-09

0

0004

0.000E+00

0

0000

3 . 656E-09

0.0003

0. 000E + 00

0

0000

2 . 525E-09

0

0002

U-235

5.180E-07

0

0446

4.049E-09

0

0003

0. 000E + 00

0

0000

3 .736E-09

0.0003

0. 000E + 00

0

0000

2.581E-09

0

0002

U-238

1.071E-07

0

0092

3. 832E-09

0

0003

0.000E+00

0

0000

4 . 615E-09

0.0004

0.000E+00

0

0000

3.188E-09

0

0003

Total

9.782E-06

0

8428

7 . 247E-08

0

0062

0.000E+00

0

0000

1 . 611E-06

0.1388

0. 000E + 00

0

0000

1. 412E-07

0

0122


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+01 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 408E-06

0

1213

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 809E-07

0

0242

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 688E-07

0

0145

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 272E-06

0

1096

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

7 . 807E-06

0

6726

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0

0010

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1.091E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

5. 284E-07

0

0455

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.188E-07

0

0102

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.161E-05

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 1.000E+01 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+01 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

6.676E-07

0

0575

1. 573E-08

0

0014

0. 000E + 00

0

0000

0 .000E + 00

0.0000

6. 714E-10

0

0001

0. 000E + 00

0

0000

7 . 883E-09

0

0007

Pa-231

8.04 6E-07

0

0693

2 . 860E-08

0

0025

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 497E-07

0

0129

0. 000E + 00

0

0000

1. 412E-08

0

0012

Pb-210

2.042E-09

0

0002

2.649E-09

0

0002

0. 000E + 00

0

0000

0 .000E + 00

0.0000

6.955E-07

0

0599

0. 000E + 00

0

0000

4 . 842E-08

0

0042

Po-210

9.114E-21

0

0000

5.27 4E-19

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

2 . 758E-16

0

0000

0. 000E + 00

0

0000

1.339E-17

0

0000

Ra-226

7.605E-06

0

6552

7 . 093E-09

0

0006

0.000E+00

0

0000

0 .000E + 00

0.0000

7 . 467E-07

0

0643

0. 000E + 00

0

0000

5. 867E-08

0

0051

Th-230

7.706E-08

0

0066

6. 001E-09

0

0005

0.000E+00

0

0000

0 .000E + 00

0.0000

6. 252E-09

0

0005

0. 000E + 00

0

0000

3.799E-09

0

0003

U-234

2.363E-10

0

0000

4 . 505E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3.656E-09

0

0003

0. 000E + 00

0

0000

2 . 526E-09

0

0002

U-235

5.183E-07

0

0447

4 . 060E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

3. 807E-09

0

0003

0. 000E + 00

0

0000

2 . 586E-09

0

0002

U-238

1.071E-07

0

0092

3. 832E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

4 . 615E-09

0

0004

0. 000E + 00

0

0000

3.188E-09

0

0003

Total

9.782E-06

0

8428

7 . 247E-08

0

0062

0. 000E + 00

0

0000

0 .000E+00

0.0000

1.611E-06

0

1388

0. 000E + 00

0

0000

1. 412E-07

0

0122

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+01 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

6.919E-07

0

0596

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

9.970E-07

0

0859

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

7 . 486E-07

0

0645

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

2 . 897E-16

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

8 . 418E-06

0

7252

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

9. 312E-08

0

0080

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1. 092E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

5. 287E-07

0

0456

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.188E-07

0

0102

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.161E-05

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 3.000E+01 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

5.74 9E-03
6.315E-03
6.588E-03
6.537E-03
6.49 9E-03
6.975E-03
6.315E-03
6.315E-03
6.315E-03

Milk

Soil

Fish

Plant

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

1.24 6E-01

2.563E+01
4.294E+00
2.114E+01
8.292E+00
4.690E-01
1.494E+00
1.494E+00
1.494E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

9.396E-01

1.032E+00
1.077E+00
1.068E+00
1.062E+00
1.14 0E + 00
1.032E+00
1.032E+00
1.032E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Milk

0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0.000E+00
0.000E+00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

1.064E+00
2.666E+01
5.371E+00
2 . 221E+01
9. 354E+00
1. 609E+00
2 . 526E+00
2 . 526E+00
2 . 526E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn, i, t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 3.000E+01 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+01 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

1.227E-06

0

1116

2 . 892E-08

0

0026

0.000E+00

0

0000

1 . 933E-09

0.0002

0. 000E + 00

0

0000

1.44 9E-08

0

0013

Pa-231

1.069E-07

0

0097

1.155E-08

0

0011

0.000E+00

0

0000

1 .388E-07

0.0126

0. 000E + 00

0

0000

5. 588E-09

0

0005

Pb-210

3.787E-09

0

0003

2 . 618E-09

0

0002

0.000E+00

0

0000

1 .243E-07

0.0113

0.000E+00

0

0000

3.116E-08

0

0028

Po-210

3.988E-11

0

0000

2 . 308E-09

0

0002

0.000E+00

0

0000

1 .159E-06

0.1054

0.000E+00

0

0000

5. 859E-08

0

0053

Ra-226

7.329E-06

0

6665

4 . 454E-09

0

0004

0.000E+00

0

0000

1 .037E-07

0.0094

0.000E+00

0

0000

1.328E-08

0

0012

Th-230

8.187E-10

0

0001

5. 941E-09

0

0005

0. 000E + 00

0

0000

1 .396E-09

0.0001

0.000E+00

0

0000

3. 394E-09

0

0003

U-234

2.130E-10

0

0000

4 . 215E-09

0

0004

0.000E+00

0

0000

3 .4 21E-09

0.0003

0. 000E + 00

0

0000

2.363E-09

0

0002

U-235

4.848E-07

0

0441

3.789E-09

0

0003

0. 000E + 00

0

0000

3 .4 96E-09

0.0003

0. 000E + 00

0

0000

2 . 415E-09

0

0002

U-238

1.003E-07

0

0091

3.586E-09

0

0003

0.000E+00

0

0000

4 .319E-09

0.0004

0. 000E + 00

0

0000

2 . 983E-09

0

0003

Total

9.253E-06

0

8415

6. 738E-08

0

0061

0.000E+00

0

0000

1 .541E-06

0.1401

0. 000E + 00

0

0000

1. 343E-07

0

0122


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+01 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 273E-06

0.1158

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2.628E-07

0.0239

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 619E-07

0.0147

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 220E-06

0.1110

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

7 . 450E-06

0.6776

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0.0011

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1.021E-08

0.0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

4 . 945E-07

0.0450

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.112E-07

0.0101

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.100E-05

1. 0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 3.000E+01 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+01 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

2.995E-07

0

0272

7 . 057E-09

0

0006

0. 000E + 00

0

0000

0 .000E + 00

0.0000

3.012E-10

0

0000

0. 000E + 00

0

0000

3.536E-09

0

0003

Pa-231

1.034E-06

0

0941

3. 339E-08

0

0030

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 403E-07

0

0128

0. 000E + 00

0

0000

1.653E-08

0

0015

Pb-210

1.058E-09

0

0001

1. 372E-09

0

0001

0. 000E + 00

0

0000

0 .000E + 00

0.0000

3. 603E-07

0

0328

0. 000E + 00

0

0000

2.509E-08

0

0023

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

Ra-226

7.191E-06

0

6540

7 . 881E-09

0

0007

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 014E-06

0

0923

0. 000E + 00

0

0000

7 . 695E-08

0

0070

Th-230

1.411E-07

0

0128

6. 065E-09

0

0006

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 404E-08

0

0013

0. 000E + 00

0

0000

4 . 397E-09

0

0004

U-234

2.406E-10

0

0000

4 . 216E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

3.423E-09

0

0003

0. 000E + 00

0

0000

2 . 364E-09

0

0002

U-235

4.854E-07

0

0441

3. 812E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

3. 621E-09

0

0003

0. 000E + 00

0

0000

2 . 426E-09

0

0002

U-238

1.003E-07

0

0091

3.587E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

4.319E-09

0

0004

0. 000E + 00

0

0000

2 . 984E-09

0

0003

Total

9.253E-06

0

8415

6. 738E-08

0

0061

0. 000E + 00

0

0000

0 .000E+00

0.0000

1. 541E-06

0

1401

0. 000E + 00

0

0000

1.343E-07

0

0122

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+01 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

3.104E-07

0

0282

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 224E-06

0

1114

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

3. 878E-07

0

0353

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

8 . 290E-06

0

7540

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 656E-07

0

0151

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

1. 024E-08

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

4 . 953E-07

0

0450

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.112E-07

0

0101

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.100E-05

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 1.000E+02 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

4.352E-03
5.006E-03
5.641E-03
5.598E-03
5.532E-03
6.973E-03
5.006E-03
5.006E-03
5.006E-03

Milk

Soil

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

9.58 9E-02
2.032E+01
3.677E+00
1.810E+01
7.058E+00
4.689E-01
1.184E+00
1.184E+00
1.184E+00

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

Fish

Plant

Milk

7	.112E-01

8	.180E-01
9. 218E-01
9.14 8E-01
9.041E-01
1.14 0E + 00
8 .180E-01
8 .180E-01
8 .180E-01

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0.000E+00
0.000E+00
0. 000E + 00
0. 000E + 00
0.000E+00
0. 000E + 00
0. 000E + 00
0.000E+00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0. 000E + 00
0. 000E + 00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

8 . 071E-01
2 .114E+01
4.599E+00
1. 902E+01
7 . 962E+00
1. 608E+00
2 . 002E+00
2.002E+00
2 . 002E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn,i,t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 1.000E+02 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+02 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

9.435E-07

0

1024

2 . 223E-08

0

0024

0.000E+00

0

0000

1 .503E-09

0.0002

0. 000E + 00

0

0000

1.114E-08

0

0012

Pa-231

8 . 474E-08

0

0092

9.152E-09

0

0010

0.000E+00

0

0000

1 .100E-07

0.0119

0. 000E + 00

0

0000

4 . 429E-09

0

0005

Pb-210

3. 238E-09

0

0004

2 . 238E-09

0

0002

0.000E+00

0

0000

1 .063E-07

0.0115

0. 000E + 00

0

0000

2 . 664E-08

0

0029

Po-210

3.40 9E-11

0

0000

1. 973E-09

0

0002

0.000E+00

0

0000

9 . 912E-07

0.1076

0.000E+00

0

0000

5. 010E-08

0

0054

Ra-226

6.244E-06

0

6775

3. 795E-09

0

0004

0.000E+00

0

0000

8 .835E-08

0.0096

0.000E+00

0

0000

1.132E-08

0

0012

Th-230

8.184E-10

0

0001

5. 939E-09

0

0006

0. 000E + 00

0

0000

1 .396E-09

0.0002

0.000E+00

0

0000

3. 393E-09

0

0004

U-234

1.688E-10

0

0000

3.341E-09

0

0004

0.000E+00

0

0000

2 .712E-09

0.0003

0. 000E + 00

0

0000

1. 873E-09

0

0002

U-235

3.84 3E-07

0

0417

3.004E-09

0

0003

0. 000E + 00

0

0000

2 .771E-09

0.0003

0. 000E + 00

0

0000

1.914E-09

0

0002

U-238

7.948E-08

0

0086

2 . 843E-09

0

0003

0.000E+00

0

0000

3 .4 23E-09

0.0004

0. 000E + 00

0

0000

2 . 365E-09

0

0003

Total

7.740E-06

0

8399

5. 452E-08

0

0059

0.000E+00

0

0000

1 .308E-06

0.1419

0. 000E + 00

0

0000

1.132E-07

0

0123


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+02 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

9.784E-07

0

1062

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 083E-07

0

0226

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.384E-07

0

0150

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

1. 043E-06

0

1132

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

6.348E-06

0

6888

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.155E-08

0

0013

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

8 . 094E-09

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

3. 920E-07

0

0425

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

8 . 811E-08

0

0096

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

9.216E-06

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 1.000E+02 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+02 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

1.811E-08

0

0020

4 . 267E-10

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

1. 821E-11

0

0000

0. 000E + 00

0

0000

2 .138E-10

0

0000

Pa-231

1.008E-06

0

1094

3. 090E-08

0

0034

0.000E+00

0

0000

0 .000E + 00

0.0000

1.112E-07

0

0121

0. 000E + 00

0

0000

1. 533E-08

0

0017

Pb-210

1.059E-10

0

0000

1. 373E-10

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

3. 605E-08

0

0039

0. 000E + 00

0

0000

2 . 510E-09

0

0003

Po-210

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

Ra-226

5.90 9E-0 6

0

6412

7 . 503E-09

0

0008

0.000E+00

0

0000

0 .000E + 00

0.0000

1.103E-06

0

1197

0. 000E + 00

0

0000

8 . 201E-08

0

0089

Th-230

3.38 9E-07

0

0368

6.29 9E-0 9

0

0007

0.000E+00

0

0000

0 .000E + 00

0.0000

4 . 781E-08

0

0052

0. 000E + 00

0

0000

6.919E-09

0

0008

U-234

3.32 6E-10

0

0000

3.345E-09

0

0004

0.000E+00

0

0000

0 .000E + 00

0.0000

2 . 731E-09

0

0003

0. 000E + 00

0

0000

1. 877E-09

0

0002

U-235

3.862E-07

0

0419

3. 065E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

3. 035E-09

0

0003

0. 000E + 00

0

0000

1. 945E-09

0

0002

U-238

7.948E-08

0

0086

2 . 844E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

3. 424E-09

0

0004

0. 000E + 00

0

0000

2 . 365E-09

0

0003

Total

7.740E-06

0

8399

5. 452E-08

0

0059

0. 000E + 00

0

0000

0 .000E+00

0.0000

1. 308E-06

0

1419

0. 000E + 00

0

0000

1.132E-07

0

0123

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+02 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

1. 877E-08

0

0020

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1.166E-06

0

1265

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

3. 880E-08

0

0042

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

7 .102E-06

0

7706

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

3. 999E-07

0

0434

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

8 . 285E-09

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

3. 942E-07

0

0428

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

8 . 811E-08

0

0096

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

9.216E-06

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 3.000E+02 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

2.232E-03
2.577E-03
3.660E-03
3.632E-03
3.618E-03
6.963E-03
2.577E-03
2.577E-03
2.577E-03

Milk

Soil

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

4.925E-02
1.04 6E + 01
2.386E+00
1.174E+01
4.615E+00
4.682E-01
6.097E-01
6.097E-01
6.097E-01

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

Fish

Plant

Milk

3. 647E-01
4 . 212E-01
5. 981E-01
5. 935E-01
5. 912E-01
1.138E + 00
4 . 212E-01
4 . 212E-01
4 . 212E-01

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

4.14 0E-01
1.088E+01
2.984E+00
1. 234E+01
5. 206E+00
1.60 6E+ 00
1.031E+00
1.031E+00
1.031E+00

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn,i,t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 3.000E+02 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+02 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

4.845E-07

0

0834

1.142E-08

0

0020

0.000E+00

0

0000

7 .725E-10

0.0001

0.000E+00

0

0000

5.721E-09

0

0010

Pa-231

4.363E-08

0

0075

4 . 712E-09

0

0008

0.000E+00

0

0000

5 . 664E-08

0.0098

0.000E+00

0

0000

2 . 281E-09

0

0004

Pb-210

2.107E-09

0

0004

1. 457E-09

0

0003

0.000E+00

0

0000

6 . 916E-08

0.0119

0. 000E + 00

0

0000

1. 734E-08

0

0030

Po-210

2.219E-11

0

0000

1. 284E-09

0

0002

0.000E+00

0

0000

6 .4 51E-07

0.1111

0. 000E + 00

0

0000

3. 260E-08

0

0056

Ra-226

4.098E-06

0

7056

2 . 491E-09

0

0004

0.000E+00

0

0000

5 .7 98E-08

0.0100

0. 000E + 00

0

0000

7 . 427E-09

0

0013

Th-230

8.172E-10

0

0001

5. 930E-09

0

0010

0. 000E + 00

0

0000

1 .394E-09

0.0002

0. 000E + 00

0

0000

3.388E-09

0

0006

U-234

8.692E-11

0

0000

1. 720E-09

0

0003

0.000E+00

0

0000

1 .396E-09

0.0002

0. 000E + 00

0

0000

9. 645E-10

0

0002

U-235

1.978E-07

0

0341

1.546E-09

0

0003

0. 000E + 00

0

0000

1 .427E-09

0.0002

0. 000E + 00

0

0000

9. 857E-10

0

0002

U-238

4.092E-08

0

0070

1. 464E-09

0

0003

0.000E+00

0

0000

1 .763E-09

0.0003

0. 000E + 00

0

0000

1. 218E-09

0

0002

Total

4.868E-06

0

8382

3. 202E-08

0

0055

0.000E+00

0

0000

8 .356E-07

0.1439

0. 000E + 00

0

0000

7 .192E-08

0

0124


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+02 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

5.025E-07

0

0865

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.073E-07

0

0185

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

9. 007E-08

0

0155

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

6. 790E-07

0

1169

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

4 .166E-06

0

7173

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.153E-08

0

0020

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

4 .168E-09

0

0007

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2.018E-07

0

0347

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

4 . 537E-08

0

0078

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

5. 807E-06

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 3.000E+02 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


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Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+02 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

5.976E-12

0

0000

1. 408E-13

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

6.010E-15

0

0000

0. 000E + 00

0

0000

7.056E-14

0

0000

Pa-231

5.250E-07

0

0904

1.603E-08

0

0028

0.000E+00

0

0000

0 .000E + 00

0.0000

5. 704E-08

0

0098

0. 000E + 00

0

0000

7.952E-09

0

0014

Pb-210

1.473E-13

0

0000

1.911E-13

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

5.017E-11

0

0000

0. 000E + 00

0

0000

3.493E-12

0

0000

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

Ra-226

3.371E-06

0

5804

4 . 361E-09

0

0008

0.000E+00

0

0000

0 .000E + 00

0.0000

6.507E-07

0

1120

0. 000E + 00

0

0000

4 . 826E-08

0

0083

Th-230

7.294E-07

0

1256

6.789E-09

0

0012

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 227E-07

0

0211

0. 000E + 00

0

0000

1. 247E-08

0

0021

U-234

9.42 0E-10

0

0002

1. 730E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

1.530E-09

0

0003

0. 000E + 00

0

0000

9.79 6E-10

0

0002

U-235

2.011E-07

0

0346

1.64 6E-0 9

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 805E-09

0

0003

0. 000E + 00

0

0000

1. 035E-09

0

0002

U-238

4.092E-08

0

0070

1.465E-09

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

1. 764E-09

0

0003

0. 000E + 00

0

0000

1. 218E-09

0

0002

Total

4.868E-06

0

8382

3.202E-08

0

0055

0. 000E + 00

0

0000

0 .000E+00

0.0000

8 . 356E-07

0

1439

0. 000E + 00

0

0000

7 .192E-08

0

0124

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 3.000E+02 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

6.193E-12

0

0000

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

6. 060E-07

0

1043

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

5. 400E-11

0

0000

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

4 . 074E-06

0

7015

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

8 . 714E-07

0

1500

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

5.182E-09

0

0009

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

2 . 055E-07

0

0354

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

4 . 537E-08

0

0078

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

5. 807E-06

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


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Amount of Intake Quantities QINT(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As pCi/yr at t= 1.000E+03 years

Water Independent Pathways (Inhalation w/o radon)

Water Dependent Pathways

Radio-

Nuclide Inhalation Plant

Ac-227

Pa-231

Pb-210

Po-210

Ra-226

Th-230

U-234

U-235

U-238

2.186E-04
2.524E-04
1.386E-03
1.375E-03
1.427E-03
6.911E-03
2.524E-04
2.524E-04
2.524E-04

Milk

Soil

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

4.824E-03

1.025E+00
9.039E-01
4.445E+00
1.820E+00
4.647E-01
5.971E-02
5.971E-02
5.971E-02

0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00
0.000E+00

Fish

Plant

Milk

3. 572E-02
4 .125E-02
2 . 266E-01
2 . 247E-01
2 . 332E-01
1.129E + 00
4 .125E-02
4 .125E-02
4 .125E-02

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0.000E+00
0.000E+00
0. 000E + 00
0.000E+00
0. 000E + 00
0.000E+00
0.000E+00
0. 000E + 00
0.000E+00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00
0. 000E + 00

0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00
0 .000E+00

Total
Ingestion*

4 . 055E-02
1. 066E+00
1.130E+00
4 . 670E+00
2 . 053E+00
1. 594E+00
1. 010E-01
1. 010E-01
1. 010E-01

Sum of all ingestion pathways, i.e. water independent plant, meat, milk, soil
and water-dependent water, fish, plant, meat, milk pathways

Amount of Intake Quantities QINT9(irn,i,t) and QINT9W(irn,i,t) for Inhalation of
Radon and its Decay Products as pCi/yr at t= 1.000E+03 years

Radionuclides

Radon		

Pathway	Rn-222	Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total

0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent

Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+03 years

Water Independent Pathways (Inhalation excludes radon)

und	Inhalation	Plant	Meat	Milk

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

risk fract.

Ac-227

4.74 6E-08

0

0230

1.118E-09

0

0005

0.000E+00

0

0000

7 .566E-11

0.0000

0.000E+00

0

0000

5. 604E-10

0

0003

Pa-231

4.273E-09

0

0021

4 . 615E-10

0

0002

0.000E+00

0

0000

5 .548E-09

0.0027

0.000E+00

0

0000

2 . 234E-10

0

0001

Pb-210

8.110E-10

0

0004

5. 606E-10

0

0003

0.000E+00

0

0000

2 . 662E-08

0.0129

0.000E+00

0

0000

6. 673E-09

0

0032

Po-210

8.533E-12

0

0000

4.938E-10

0

0002

0.000E+00

0

0000

2 .4 81E-07

0.1204

0. 000E + 00

0

0000

1. 254E-08

0

0061

Ra-226

1.642E-06

0

7968

9.979E-10

0

0005

0.000E+00

0

0000

2 .323E-08

0.0113

0. 000E + 00

0

0000

2 . 976E-09

0

0014

Th-230

8.111E-10

0

0004

5.88 6E-0 9

0

0029

0. 000E + 00

0

0000

1 .384E-09

0.0007

0.000E+00

0

0000

3. 362E-09

0

0016

U-234

8.513E-12

0

0000

1.685E-10

0

0001

0.000E+00

0

0000

1 .367E-10

0.0001

0. 000E + 00

0

0000

9.44 6E-11

0

0000

U-235

1.938E-08

0

0094

1.515E-10

0

0001

0. 000E + 00

0

0000

1 .398E-10

0.0001

0.000E+00

0

0000

9.654E-11

0

0000

U-238

4.008E-09

0

0019

1.433E-10

0

0001

0.000E+00

0

0000

1 .726E-10

0.0001

0.000E+00

0

0000

1.193E-10

0

0001

Total

1.719E-06

0

8340

9.981E-09

0

0048

0.000E+00

0

0000

3 .054E-07

0.1482

0.000E+00

0

0000

2.664E-08

0

0129


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Excess Cancer Risks CNRS(i,p,t) for Individual Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+03 years

Water Dependent Pathways

All Pathways**

risk fract.

Water

Radio- 	

Nuclide risk f

Fish

Plant

Milk

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

4 . 921E-08

0

0239

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.051E-08

0

0051

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

3. 4 67E-08

0

0168

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

2.611E-07

0

1267

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 669E-06

0

8100

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1.144E-08

0

0056

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

4.082E-10

0

0002

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

1. 977E-08

0

0096

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

4 . 443E-09

0

0022

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0 .000E + 00

0.0000

0.000E+00

0

0000

2 . 061E-06

1

0000

Sum of water independent ground, inhalation, plant, meat, milk, soil
and water dependent water, fish, plant, meat, milk pathways

Excess Cancer Risks CNRS9(irn,i,t) and CNRS9W(irn,i,t) for Inhalation of
Radon and its Decay Products at t= 1.000E+03 years

Radon
Pathway

Radionuclides

Rn-222

Po-218

Pb-214

Bi-214

Rn-220

Po-216

Pb-212

Bi-212

Water-ind. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00
Water-dep. 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Total	0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00

Water-ind. == Water-independent Water-dep. == Water-dependent


-------
RESRAD-ONSITE, Version 7.2	Limit = 30 days	06/06/2019 08:31 Page 28

Intrisk : RESRAD Tronox Ranching Scenario

File : C:\RESRAD_FAMILY\ONSITE\7.2\USERFILES\SITE23.RAD

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+03 years

Water Independent Pathways (Inhalation excludes radon)

Ground

Inhalation

Radon

Plant

Milk

Soil

Radio-
nuclide

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

risk

fract.

Ac-227

3.902E-24

0

0000

9.195E-2 6

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

3. 924E-27

0

0000

0. 000E + 00

0

0000

4.607E-26

0

0000

Pa-231

5.066E-08

0

0246

1.547E-09

0

0008

0.000E+00

0

0000

0 .000E + 00

0.0000

5.504E-09

0

0027

0. 000E + 00

0

0000

7.674E-10

0

0004

Pb-210

1.482E-23

0

0000

1.922E-23

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

5.046E-21

0

0000

0. 000E + 00

0

0000

3.513E-22

0

0000

Po-210

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0 .000E + 00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

Ra-226

4.725E-07

0

2293

6.114E-10

0

0003

0.000E+00

0

0000

0 .000E + 00

0.0000

9.122E-08

0

0443

0. 000E + 00

0

0000

6 . 7 6 6E-0 9

0

0033

Th-230

1.168E-06

0

5669

7.308E-09

0

0035

0.000E+00

0

0000

0 .000E + 00

0.0000

2 . 076E-07

0

1007

0. 000E + 00

0

0000

1. 874E-08

0

0091

U-234

2.805E-09

0

0014

1.871E-10

0

0001

0.000E+00

0

0000

0 .000E + 00

0.0000

6. 284E-10

0

0003

0. 000E + 00

0

0000

1. 396E-10

0

0001

U-235

2.045E-08

0

0099

1.843E-10

0

0001

0.000E+00

0

0000

0 .000E + 00

0.0000

2 . 589E-10

0

0001

0. 000E + 00

0

0000

1.128E-10

0

0001

U-238

4.010E-09

0

0019

1.438E-10

0

0001

0.000E+00

0

0000

0 .000E + 00

0.0000

1.733E-10

0

0001

0. 000E + 00

0

0000

1.196E-10

0

0001

Total

1.719E-06

0

8340

9.981E-09

0

0048

0. 000E + 00

0

0000

0 .000E+00

0.0000

3. 054E-07

0

1482

0. 000E + 00

0

0000

2 . 664E-08

0

0129

Total Excess Cancer Risk CNRS(i,p,t)* ** for Initially Existent Radionuclides (i) and Pathways (p)
and Fraction of Total Risk at t= 1.000E+03 years

Water Dependent Pathways

All pathways

Nuclide risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.	risk fract.

Ac-227

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

4.044E-24

0

0000

Pa-231

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

5.84 8E-08

0

0284

Pb-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

5. 431E-21

0

0000

Po-210

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

Ra-226

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

5. 711E-07

0

2772

Th-230

0.000E+00

0

0000

0. 000E + 00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

1. 402E-06

0

6803

U-234

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0.000E+00

0

0000

3.760E-09

0

0018

U-235

0.000E+00

0

0000

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0.0000

0. 000E + 00

0

0000

0.000E+00

0

0000

2 .100E-08

0

0102

U-238

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

4.446E-09

0

0022

Total

0.000E+00

0

0000

0. 000E + 00

0

0000

0.000E+00

0

0000

0.000E+00

0.0000

0.000E+00

0

0000

0. 000E + 00

0

0000

2 . 061E-06

1

0000

CNRSI (i, p, t) includes contribution from decay daughter radionuclides


-------
APPENDIX K
COST ESTIMATE DETAILS


-------
This page intentionally left blank.


-------
Appendix K
Cost Estimate Details
Table K-l

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

SUMMARY OF ALTERNATIVE COSTS

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Source: WESTON, 2022

ALTERNATIVE

DESCRIPTION

CAPITAL COST
(2022)

ANNUAL O&M COST

PRESENT WORTH
(2022)

PLANNING
DURATION

CONSTRUCTION
DURATION

TOTAL
DURATION

First 12 Years

All 99 Years

1

No Further Action

$

$ 36,624

$ 18,901

$ 561,000

-

-

-

2

Excavation and Off-Site Disposal of Contaminated Soil at
a Licensed Low-Level Radioactive Facility

$ 29,763,726

$ 36,624

$

$ 30,055,000

3 Months

7 Months

0.8 Years

3

Excavation and Disposal of Contaminated Soil at an On-
Site Repository

$ 14,426,964

$ 65,518

$ 33,348

$ 15,424,000

3 Months

6 Months

0.7 Years

4

Capping of Contaminated Soil in Place

$ 23,568,735

$ 65,518

$ 33,348

$ 24,565,000

3 Months

9 Months

1 Years

Key Assumptions:

1)	Planning duration (3 months) was provided by EPA based on an expectation that much of the planning work will be performed concurrently with initial construction efforts (such as clearing and grubbing).

2)	Durations assume construction will continue year-round.

Net present value was calcuated as follows:

NPV = Capital Cost + Annual Cost (Year 0 to 12) * P/A + Annual Cost (Years 12-99). Adjustments for future value at year 12 not included.

Net Present Value (NPV)

Real Discount Rate, i =	7.0%

Life cycle 1 (years), n	12

Uniform Series Present Worth Factor (P/A) =	7.94

Life cycle 2 (years) to year 99, n	87

Uniform Series Present Worth Factor (P/A) =	14.25

l'^l US EPA REGION 6

Page 1 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-2

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 1 - PRELIMINARY CONSTRUCTION COST ESTIMATE
No Further Action

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

lli'in lh'MTi|iiMni

(.>ii.iiini%

1 nil

1 Mil ( n\l

1- Ml'llsiini

Ill-ill liii.il

PRSC COSTS (O & M):











1 Additional Effort for First 12-years O&M











Quarterly Inspections (2 person crew, 1 day, 10 hrs/day)

80

HR

$95.68

$7,654.08



Mileage Albuquerque, NM to Site (round trip)

848

MI

$0.62

$525.76



Inspection Crew Per Diem

8

DAY

$155.00

$1,240.00



Assumed Annual Maintenance Costs (revegetation, watering, fence repairs)

1

LS

$20,000.00

$20,000.00



Preparation of Semi-annual Reports (Professional Engineer)

40

HR

$180.10

$7,203.84



Subtotal: Additional First 12-years Annual PRSC Costs:







$36,624



Present Value - O&M costs for 12 years (@-7% discount rate)









$290,890

2 99 Years O&M Costs











Annual Inspection (2 person crew, 2 days, lOhrs/day)

40

HR

$95.68

$3,827.04



Mileage Albuquerque, NM to Site (round trip)

212

MI

$0.62

$131.44



Inspection Crew Per Diem

4

DAY

$155.00

$620.00



Assumed Annual Maintenance Costs

1

LS

$10,000.00

$10,000.00



Preparation of Annual Report (Professional Engineer)

24

HR

$180.10

$4,322.30



Subtotal 99-years Annual PRSC Costs:







$18,901



Present Value - O&M costs for 99 years (@-7% discount rate)









$269,680

TOTAL ESTIMATED COST









$560,570

TOTAL ESTIMATED COST (rounded up to nearest $1,000)









S561,000

Notes:

No Further Action Annual Costs include maintenance of erosion and stormwater controls and fencing.

Abbreviations:

HR = hour	MI = mile	LS = lump sum

PRSC = post-removal site control



w j US EPA REGION 6

2 of 18	TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-3

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 2 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Excavation and Off-Site Disposal of Contaminated Soil at a Licensed Low-Level Radioactive Facility

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR / EPA
CONSTRUCTION CONTRACTOR

Item

Description

Quantity

Unit

Unit Cost

Extension

Item Total

Duration

CAPITAL COSTS:













1

1 Engineering Costs (Design Costs)















Project Manager

100

HR

$115.00

$11,500.00







Project Engineer

200

HR

$180.10

$36,019.20







Design Engineer

300

HR

$112.56

$33,768.00







CAD/GIS Operator

400

HR

$95.68

$38,270.40







Admin

100

HR

$100.00

$10,000.00







Expenses

1

LS

$5,000.00

$5,000.00



3.0



Subtotal Engineering Costs









$134,558

Months

2

Planning Documents (Work Plan, Health & Safety Plan, QA Plan, and SWPPP)















Project Manager

50

HR

$115.00

$5,750.00







Project Engineer

300

HR

$180.10

$54,028.80







CAD/GIS Operator

100

HR

$95.68

$9,567.60







Admin

50

HR

$100.00

$5,000.00







Expenses

1

LS

$1,000.00

$1,000.00



Concurrent with



Subtotal Planning Documents









$75,346

Item 1

3

Resource Surveys















Geotechnical Testing and Report

2

EA

$28,000.00

$56,000.00







Pre-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00







Post-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00



Concurrent with



Subtotal Resource Surveys









$64,064

Other Work

4

1 Mobilization/Demobilization

1

LS

$853,160.90

$853,160.90



0.5



Subtotal Mob/Demob









$853,161

Months

5

Improve/Blaze Access Roads















Gravel Road Surfacing (8" Depth)

11,734

SY

$4.06

$47,618.49







Dozer, D-9 (2)

2

DAY

$4,458.86

$8,917.72







Grader (1)

1

DAY

$1,884.66

$1,884.66







Backhoe Loader (2)

2

DAY

$1,423.67

$2,847.34







6000 Gal Water Truck (1)

1

DAY

$2,361.91

$2,361.91







Laborer (5)

25

HR

$71.19

$1,779.86



0.4



Subtotal Improve Access Road









$65,410

Months

6

Construction Water















Construction Water, including Hauling

1,266,000

GAL

$0.11

$132,930.00







Portable Water Tower Trailer, 10,000 gallons (2)

220

DAY

$1,741

$383,004.16



Concurrent with



Subtotal Construction Water









$515,934

Other Work

7

1 Clearing and Grubbing















Dozer, D-9 (2)

7

DAY

$4,458.86

$31,212.03







Crawler Loader (1)

4

DAY

$2,790.58

$11,162.31







Brush Chipper, 12"

4

DAY

$1,317.51

$5,270.05







6000 Gal Water Truck (1)

4

DAY

$2,361.91

$9,447.64







Laborer (5)

167

HR

$71.19

$11,889.43



0.2



Subtotal Clearing and Grubbing









$68,981

Months

8

1 Erosion and Sediment Control















Silt Fence

16,000

LF

$0.54

$8,644.61







Sediment Log, Filter Sock, 9"

4,000

LF

$4.20

$16,808.96







Loader, Skid Steer, 30 H.P. (1)

10

DAY

$1,351.41

$13,514.10







Flatbed Truck (1)

10

DAY

$1,267.94

$12,679.42







Laborer (5)

493

HR

$71.19

$35,098.74



Concurrent with



Subtotal Erosion and Sediment Control









$86,746

Other Work

9

Headworks Removal















Flatbed Truck (1)

2

DAY

$1,267.94

$2,535.88







Structural Steel Foreman (1)

20

HR

$105.30

$2,106.00







Structural Steel Worker (1)

20

HR

$101.81

$2,036.21







Truck Driver (1)

20

HR

$82.56

$1,651.26







Laborer (5)

100

HR

$71.19

$7,119.42



Concurrent with



Subtotal Headworks Removal









$15,449

Other Work

10

Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)















Dump Truck, 34 CY, Off-Road (1)

4

DAY

$2,940.28

$11,761.10







Backhoe Loader (2)

4

DAY

$2,610.55

$10,442.20







Pump, Concrete, Truck Mounted, 4" Line, 80' Boom (1)

1

DAY

$3,207.40

$3,207.40







Polyurethane Foam

32

CY

$390.00

$12,365.66







Laborer (5)

81

HR

$71.19

$5,766.73



0.2



Subtotal Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)









$43,543

Months

w USEPA REGION 6

Page 3 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-3 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 2 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Excavation and Off-Site Disposal of Contaminated Soil at a Licensed Low-Level Radioactive Facility

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR / EPA
CONSTRUCTION CONTRACTOR

11

On-Site Waste Consolidation and Stockpiling for Transport to OfFsite Facility















Backhoe Loader (2)

116

DAY

$2,610.55

$302,823.73







6000 Gal Water Truck (1)

58

DAY

$2,361.91

$136,990.82







Laborer (5)

1,445

HR

$71.19

$102,875.62



Concurrent with



Subtotal Waste Consolidation and Stockpiling









$542,690

Item 13

12

Transport and Disposal (Clean Harbors, Deer Trail, CO)















Backhoe Loader (2)

272

DAY

$3,207.40

$872,412.33



Total Number



Grader (1) (road maintenance)

136

DAY

$1,884.66

$256,314.27



of Off-Site



6000 Gal Water Truck (1)

136

DAY

$2,361.91

$321,219.85



Truck Loads



Transport Legal Load and Disposal Fee (estimated at 45,000 lbs/load)

60,930

TON

$62.15

$3,786,829.33



2,708



Truck Mobilization Fee (2708 trucks)

2,708

EA

$1,266.73

$3,430,304.84







Truck Tarp (2708 trucks)

2,708

EA

$118.65

$321,304.20







Disposal at Facility

60,930

TON

$84.75

$5,163,858.18



5.3



Subtotal Off-Site Transport and Disposal









$14,152,243

Months

13

Confirmation Sampling - will happen concurrently with field work















Develop Sampling and Analysis Plan (SAP)















Geologist

80

HR

$118.19

$9,455.04







Project Manager

20

HR

$115.00

$2,300.00







Admin

20

HR

$100.00

$2,000.00







Sampling















Sampling Team (two 2-person crews)

750

HR

$95.68

$71,757.00







Mileage Albuquerque, NM to Sites (1 round trip per week)

1,325

MI

$0.54

$715.50







Per Diem (2 people)

75

DAY

$142.00

$10,650.00







Gamma Scanning Equipment and Miscellaneous Field Supplies and Expenses

1

LS

$13,125.00

$13,125.00







Lab Analysis (15 samples per 2,000 m2 survey area = 30 samples per acre)

750

EA

$84.75

$63,562.50







Oversight during the Construction Duration















Project Manager

5,400

HR

$115.00

$621,000.00







Site Superintendent

5,400

HR

$100.00

$540,000.00







Radiation T echnician

5,400

HR

$135.00

$729,000.00







Field Technician

5,400

HR

$80.00

$432,000.00







Off-Site Office

7

MO

$700.00

$4,900.00







Reporting















Geologist/Project Scientist

120

HR

$118.19

$14,182.56







Project Manager

30

HR

$115.00

$3,450.00







Project Engineer

30

HR

$180.10

$5,402.88







Health Physicist

30

HR

$180.10

$5,402.88







CAD/GIS Operator

120

HR

$95.68

$11,481.12







Admin

30

HR

$100.00

$3,000.00







Copying

4

LS

$156.25

$625.00



Concurrent with



Subtotal Confirmation Sampling









$2,544,009

Other Work

14

Site Restoration (staging areas, general disturbance areas)















Tractor (2)

6

DAY

$1,529.30

$9,175.77







Grader(3)

11

DAY

$1,884.66

$20,731.30







Flat Bed Truck (1)

4

DAY

$1,267.94

$5,071.77







Power Mulcher (1)

2

DAY

$1,500.82

$3,001.65







6000 Gal Water Truck (2)

8

DAY

$2,361.91

$18,895.29







Laborer (5)

182

HR

$71.19

$12,957.34







Seed Mix

20

AC

$12.52

$250.44







Soil Amendments (Humate)

20

AC

$192.39

$3,847.78







Fertilizer

20

AC

$0.68

$13.60







Mulch

20

AC

$6.36

$127.30



0.2



Subtotal Site Restoration









$74,072

Months

15

Per Diem















Construction Crew Per Diem (40 people)

7,200

DAY

$142.00

$1,022,400.00



Concurrent with



Subtotal Construction Crew Per Diem









$1,022,400

Other Work

w USEPA REGION 6

Page 4 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-3 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 2 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Excavation and Off-Site Disposal of Contaminated Soil at a Licensed Low-Level Radioactive Facility

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR / EPA
CONSTRUCTION CONTRACTOR

16 Contractor Project Management













Project Manager

1,500

HR

$115.00

$172,500.00





Site Superintendent, H&S Officer, and QA/QC Officer

5,400

HR

$100.00

$540,000.00





Site Foreman (3)

5,400

HR

$29.27

$158,034.24





Field Accountant (1)

1,800

HR

$100.00

$180,000.00





Site Vehicles- 4WD Trucks (7)

7

MO

$5,402.88

$37,820.16





Mileage Albuquerque, NM to Site (106 mi/each way)

33,120

MI

$0.54

$17,884.80





Fuel for Vehicles

720

MO

$3,253.33

$2,342,400.00





Port-o-let Rental (4)

7

MO

$499.47

$3,496.26





Job Trailers (2)

7

MO

$294.16

$2,059.10





Storage Boxes (2)

7

MO

$103.26

$722.79





Field Office Lights/HVAC (1)

7

MO

$195.70

$1,369.93





T elephone/internet (1)

7

MO

$104.46

$731.19





Field Office Equipment

7

MO

$276.15

$1,933.03





Field Office Supplies

7

MO

$104.46

$731.19





Trash (2 dumpsters)

7

MO

$490.08

$3,430.54





Air Monitoring Equipment

7

MO

$9,914.21

$69,399.48





Truck Scales

7

MO

$339.00

$2,373.00



Concurrent with

Generator (1)

7

MO

$2,498.30

$17,488.10





Subtotal Contractor Project Management









$3,552,374

Other Work

SUBTOTAL CAPITAL COSTS:









$23,810,9S1

Project

17 Contingency - 25% (Items 1-17)



25%

X

$23,810,981

$5,952,745



TOTAL CAPITAL COSTS:









$29,763,726

3.0

PRSC COSTS (0 & Mi:











Months

18 Additional Effort for First 12-years O&M













Quarterly Inspections (2 person crew, 1 day, 10 hrs/day)

80

HR

$95.68

$7,654.08



Construction

Mileage Albuquerque, NM to Site (round trip)

848

MI

$0.62

$525.76



180

Inspection Crew Per Diem

8

DAY

$155.00

$1,240.00



Work Days

Preparation of Semi-annual Reports (Professional Engineer)

40

HR

$180.10

$7,203.84





Assumed Annual Maintenance Costs (revegetation, watering, fence repairs)

1

LS

$20,000.00

$20,000.00



7.0

Subtotal: Additional First 12-years Annual PRSC Costs:







$36,624



Months

Present Value - O&M costs for 12 years (@-7% discount rate)









$290,890



19 99 Years O&M Costs (No O&M beyond first 12-years)











TOTAL

Annual Inspection (2 person crew, 2 days, lOhrs/day)

0

HR

$95.68

$0.00





Mileage Albuquerque, NM to Site (round trip)

0

MI

$0.62

$0.00



252

Inspection Crew Per Diem

0

DAY

$155.00

$0.00



Work Days

Assumed Annual Maintenance Costs

0

LS

$10,000.00

$0.00





Preparation of Annual Report (Professional Engineer)

0

HR

$180.10

$0.00



9.8

Subtotal 99-years Annual PRSC Costs:







$0



Months

Present Value - O&M costs for 99 years (@-7% discount rate)









$0



TOTAL ESTIMATED COST

$30,054,616

TOTAL ESTIMA TED COST (rounded up to nearest $1,000)

$30,055,000

Key Assumptions:

1)	Labor factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

2)	Materials factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

3)	Equipment factor is based on the Gallup, New Mexico city cost index for Contractor Equipment (RSMeans, page 635).

4)	Costing assumes that the EPA will contract directly with a construction subcontractor/manager working out of the Grants, NM area.

5)	Mileage is estimated to be 106 miles one way from Albuquerque, NM to the field site

6)	Costs were developed assuming a 10-hour work day and 6 working days per week.

7)	Mobilization costs include transportation of needed equipment and personnel (e.g. heavy equipment, office trailers, and additional supplies/equipment).

Equipment rates are based on monthly rental rates from RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. All unit rates are marked up to include an
operator, labor or s are separate for ground support.

Unit costs and production rates are based on rates obtained fiom RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. Unit costs include materials,
equipment, and labor.

Per diem rates are based on the maximum Federal 2022 CONUS Per Diem Rates.

Present value of post removal site control (PRSC) costs assume quarterly SWPPP insepctions and an annual general inspection and report for the first 12 years. Costs also
assume minor fencing, revegetation, and water system repairs during each inspection.

Present Value Subtotal for PRSC costs assume a discount rate of 7.0%.

Costs for low level radiological waste transport and disposal were obtained fiom quotes fiom vendors in December 2019.

For detailed information on personnel and equipment rates, quantities, and cost adjustment factors, see Tables K-6 thru K-8.

The average density of all wastes were assumed to be 1.3 tons per cubic yard. A capacity of 45,000 lb/load was assumed, which is 22.5 tons/load. Loose cubic yards
assumed a 20% swell factor.

9)

10)

11)

12)

13)

14)

15)

Abbreviations:

CY = Cubic yards
LB = pound

MSF = thousand square feet
MI = Mile

CF = cubic foot
LF = linear feet
SF = square feet
PRSC = post-removal site control

EA = each
LS = Lump sum
SY = square yards

HR = hour
MO = Month
AC = Acre

w USEPA REGION 6

V®/	Page 5 of 18	TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-4

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 3 - PRELIMINARY CONSTRUCTION COST ESTIMATE
Excavation and Disposal of Contaminated Soil at an On-Site Repository

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

Mi-Hi D.mi i|iln>n

Oii.mliiv

1 nil

1 ml ( iivl

1 \lrllMMI

Ill-ill 1 "l.il

1 >111:ili«*ll

CAITTAI. COSTS:













ering Costs (Design Costs)













Project Manager

100

HR

$115.00

$11,500.00





Project Engineer

200

HR

$180.10

$36,019.20





Design Engineer

300

HR

$112.56

$33,768.00





CAD/GIS Operator

400

HR

$95.68

$38,270.40





Admin

100

HR

$100.00

$10,000.00





Expenses

1

LS

$5,000.00

$5,000.00



3.0

Subtotal Engineering Costs









$134,558

Months

Planning Documents (Work Plan, Health & Safety Plan, QA Plan, and SWPPP)













Project Manager

50

HR

$115.00

$5,750.00





Project Engineer

300

HR

$180.10

$54,028.80





CAD/GIS Operator

100

HR

$95.68

$9,567.60





Admin

50

HR

$100.00

$5,000.00





Expenses

1

LS

$1,000.00

$1,000.00



Concurrent with

Subtotal Planning Documents









$75,346

Item 1

3 Resource Surveys













Geotechnical Testing and Report

2

EA

$28,000.00

$56,000.00





Pre-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00





Post-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00



Concurrent with

Subtotal Resource Surveys









$64,064

Other Work

Mobilization/Demobilization

1

LS

$946,606.54

$946,606.54



0.5

Subtotal Mob/Demob









$946,607

Months

)rove/Blaze Access Roads













Gravel Road Surfacing (8" Depth)

11,734

SY

$4.06

$47,618.49





Dozer, D-9 (2)

2

DAY

$4,458.86

$8,917.72





Grader (1)

1

DAY

$1,884.66

$1,884.66





Backhoe Loader (2)

2

DAY

$1,423.67

$2,847.34





6000 Gal Water Truck (1)

1

DAY

$2,361.91

$2,361.91





Laborer (5)

25

HR

$71.19

$1,779.86



0.4

Subtotal Improve Access Road









$65,410

Months

istruction Water













Construction Water, including Hauling

811,000

GAL

$0.11

$85,155.00





Portable Water Tower Trailer, 10,000 gallons (2)

309

DAY

$1,740.93

$537,946.75



Concurrent with

Subtotal Construction Water









$623,102

Other Work

Clearing and Grubbing













Dozer, D-9 (2)

7

DAY

$4,458.86

$31,212.03





Crawler Loader (1)

4

DAY

$2,790.58

$11,162.31





Brush Chipper, 12"

4

DAY

$1,317.51

$5,270.05





6000 Gal Water Truck (1)

4

DAY

$2,361.91

$9,447.64





Laborer (5)

167

HR

$71.19

$11,889.43



0.2

Subtotal Clearing and Grubbing









$68,981

Months

Fence Construction / Repair













Fence Materials

2,640

LF

$23.95

$63,235.31





Flatbed Truck (1)

9

DAY

$1,267.94

$11,411.48





Manual Fence Post Auger (1)

9

DAY

$1,158.96

$10,430.62





Laborer (5)

440

HR

$82.56

$36,327.61



Concurrent with

Subtotal Fence Construction/Repair









$121,405

Other Work

'Sion and Sediment Control













Silt Fence

16,000

LF

$0.54

$8,644.61





Sediment Log, Filter Sock, 9"

4,000

LF

$4.20

$16,808.96





Loader, Skid Steer, 30 H.P. (1)

10

DAY

$1,351.41

$13,514.10





FlatbedTruck (1)

10

DAY

$1,267.94

$12,679.42





Laborer(5)

493

HR

$71.19

$35,098.74



Concurrent with

Subtotal Erosion and Sediment Control









$86,746

Other Work

Headworks Removal













FlatbedTruck (1)

2

DAY

$1,267.94

$2,535.88





Structural Steel Foreman (1)

20

HR

$105.30

$2,106.00





Structural Steel Worker (1)

20

HR

$101.81

$2,036.21





Truck Driver (1)

20

HR

$82.56

$1,651.26





Laborer(5)

100

HR

$71.19

$7,119.42



Concurrent with

Subtotal Headworks Removal









$15,449

Other Work

Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)













Dump Truck, 34 CY, Off-Road (1)

4

DAY

$2,940.28

$11,761.10





Backhoe Loader (1)

4

DAY

$2,610.55

$10,442.20





Pump, Concrete, Truck Mounted, 4" Line, 80' Boom (1)

1

DAY

$3,207.40

$3,207.40





Polyurethane Foam

32

CY

$390.00

$12,365.66





Laborer(5)

162

HR

$71.19

$11,533.46



0.2

Subtotal Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)









$49,310

Months

USEPA REGION 6

Page 6 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-4 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 3 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Excavation and Disposal of Contaminated Soil at an On-Site Repository

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR / EPA
CONSTRUCTION CONTRACTOR

12

Qn-Site Waste Consolidation and Stockpiling at Onsite Repository















Backhoe Loader (2)

75

DAY

$2,610.55

$195,791.21







6000 Gal Water Truck (1)

38

DAY

$2,361.91

$89,752.61







Laborer (5)

1,111

HR

$71.19

$79,096.76



1.5



Subtotal Waste Consolidation and Stockpiling









$364,641

Months

13

Excavation, Transportation, and Stockpile of Clean Cover Material















Excavator (1)

4

DAY

$4,913.37

$19,653.50







Loader (1)

19

DAY

$3,207.40

$60,940.57







Dozer, D-9 (1)

19

DAY

$4,458.86

$84,718.36



Number of Loads



Tractor Truck, 6x4 (450 HP) (6)

62

DAY

$1,796.76

$111,398.96



1,008



Dump Trailer Only (20 CY)

62

DAY

$155.14

$9,618.52







6000 Gal Water Truck (1)

19

DAY

$2,361.91

$44,876.30







Laborer (5)

741

HR

$71.19

$52,754.90



2.4



Excavation, Transportation, and Stockpile of Clean Cover Material









$383,961

Months

14

Construction of Waste Cell















Dozer, D-9 (2)

15

DAY

$4,458.86

$66,882.92







Grader (1)

11

DAY

$1,884.66

$20,731.30







Sheepsfoot Roller, Dozer Towed (1)

3

DAY

$1,884.66

$5,653.99







Smooth Drum Roller, Dozer Towed (1)

3

DAY

$1,854.50

$5,563.50







6000 Gal Water Truck (1)

8

DAY

$2,361.91

$18,895.29







Laborer (5)

215

HR

$71.19

$15,306.75







Compaction T esting

13

EA

$342.18

$4,281.04



Concurrent with



Subtotal Construction of Waste Cell









$137,315

Item 13

15

Construction of Clean Soil Cover















Dozer, D-9 (2)

17

DAY

$4,458.86

$75,800.64







Loader (1)

7

DAY

$3,207.40

$22,451.79







Grader (1)

11

DAY

$1,884.66

$20,731.30







Sheepsfoot Roller, Dozer Towed (1)

3

DAY

$1,884.66

$5,653.99







Smooth Drum Roller, Dozer Towed (1)

3

DAY

$1,854.50

$5,563.50







6000 Gal Water Truck (1)

9

DAY

$2,361.91

$21,257.20







Laborer (5)

327

HR

$71.19

$23,280.50







Compaction Testing

14

EA

$342.18

$4,884.14



0.5



Subtotal Construction of Clean Soil Cover









$179,623

Months

16

Confirmation Sampling - will happen concurrently with field work















Develop Sampling and Analysis Plan (SAP)















Geologist

80

HR

$118.19

$9,455.04







Project Manager

20

HR

$115.00

$2,300.00







Admin

20

HR

$100.00

$2,000.00







Sampling















Sampling Team (two 2-person crews)

300

HR

$95.68

$28,702.80







Mileage Albuquerque, NM to Sites (1 round trip per week)

265

MI

$0.54

$143.10







Per Diem (4 people)

30

DAY

$142.00

$4,260.00







Gamma Scanning Equipment and Miscellaneous Field Supplies and Expenses

1

LS

$2,625.00

$2,625.00







Lab Analysis (15 samples per 2,000 m2 survey area = 30 samples per acre)

600

EA

$84.75

$50,850.00







Oversight during the Construction Duration















Project Manager

4,700

HR

$115.00

$540,500.00







Site Superintendent

4,700

HR

$100.00

$470,000.00







Radiation T echnician

4,700

HR

$135.00

$634,500.00







Field Technician

4,700

HR

$80.00

$376,000.00







Off-Site Office

6

MO

$700.00

$4,200.00







Reporting















Geologist/Project Scientist

120

HR

$118.19

$14,182.56







Project Manager

30

HR

$115.00

$3,450.00







Project Engineer

30

HR

$180.10

$5,402.88







Health Physicist

30

HR

$180.10

$5,402.88







CAD/GIS Operator

120

HR

$95.68

$11,481.12







Admin

30

HR

$100.00

$3,000.00







Copying

4

LS

$31.25

$125.00



Concurrent with



Subtotal Confirmation Sampling









$2,168,580

Other Work

w USEPA REGION 6

Page 7 of 18	TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-4 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 3 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Excavation and Disposal of Contaminated Soil at an On-Site Repository

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR / EPA
CONSTRUCTION CONTRACTOR

17 Site Restoration (staging areas, general disturbance areas)













Tractor (2)

6

DAY

$1,529.30

$9,175.77





Grader(3)

11

DAY

$1,884.66

$20,731.30





Flat Bed Truck (1)

4

DAY

$1,267.94

$5,071.77





Power Mulcher (1)

2

DAY

$1,500.82

$3,001.65





6000 Gal Water Truck (2)

8

DAY

$2,361.91

$18,895.29





Laborer (5)

182

HR

$71.19

$12,957.34





Seed Mix

20

AC

$12.52

$250.44





Soil Amendments (Humate)

20

AC

$192.39

$3,847.78





Fertilizer

20

AC

$0.68

$13.60





Mulch

20

AC

$6.36

$127.30



0.2

Subtotal Site Restoration









$74,072

Months

18 Per Diem













Construction Crew Per Diem (40 people)

9,257

DAY

$142

$1,314,514



Concurrent with

Subtotal Construction Crew Per Diem









$1,314,514

Other Work

19 Contractor Project Management













Project Manager

1,500

HR

$115.00

$172,500.00





Site Superintendent, H&S Officer, and QA/QC Officer

5,600

HR

$100.00

$560,000.00





Site Foreman (3)

5,600

HR

$29.27

$163,887.36





Field Accountant (1)

3,700

HR

$100.00

$370,000.00





Site Vehicles- 4WD Trucks (7)

8

MO

$5,402.88

$43,223.04





Mileage Albuquerque, NM to Site (106 mi/each way)

33,782

MI

$0.54

$18,242.50





Fuel for Vehicles

734

MO

$3,253.33

$2,389,248.00





Port-o-let Rental (4)

8

MO

$499.47

$3,995.73





Job Trailers (2)

8

MO

$294.16

$2,353.25





Storage Boxes (2)

8

MO

$103.26

$826.04





Field Office Lights/HVAC (1)

8

MO

$195.70

$1,565.63





T elephone/internet (1)

8

MO

$104.46

$835.65





Field Office Equipment

8

MO

$276.15

$2,209.18





Field Office Supplies

8

MO

$104.46

$835.65





Trash (2 dumpsters)

8

MO

$490.08

$3,920.62





Air Monitoring Equipment

8

MO

$9,914.21

$79,313.70





Generator (1)

8

MO

$2,498.30

$19,986.40





Subtotal Contractor Project Management









$3,812,956

Other Work

SUBTOTAL CAPITAL COSTS:









$10,686,640

Project

21 Contingency - 25% (Items 1-19)



25%

X

$10,686,640

$2,671,660



22 Indirect Costs - 8% (Items 1-19, and 21)



8%

X

$13,358,300

$1,068,664

Planning

TOTAL CAPITAL COSTS:









$14,426,964

3.0

PRSC COSTS (O & Ml:











Months

23 Additional Effort for First 12-years O&M













Quarterly Inspections (2 person crew, 2 days, 10 hrs/day)

160

HR

$95.68

$15,308.16



Construction

Mileage Albuquerque, NM to Site (round trip)

848

MI

$0.62

$525.76



154

Inspection Crew Per Diem

16

DAY

$155.00

$2,480.00



Work Days

Preparation of Semi-annual Reports (Professional Engineer)

40

HR

$180.10

$7,203.84





Assumed Annual Maintenance Costs (revegetation, watering, fence repairs)

1

LS

$40,000.00

$40,000.00



6.0

Subtotal: Additional First 12-years Annual PRSC Costs:







$65,518



Months

Present Value - O&M costs for 12 years (@-7% discount rate)









$520,390



24 99 Years O&M Costs











TOTAL

Annual Inspection (2 person crew, 4 days, lOhrs/day)

80

HR

$95.68

$7,654.08





Mileage Albuquerque, NM to Site (round trip)

212

MI

$0.62

$131.44



229

Inspection Crew Per Diem

8

DAY

$155.00

$1,240.00



Work Days

Assumed Annual Maintenance Costs

1

LS

$20,000.00

$20,000.00





Preparation of Annual Report (Professional Engineer)

24

HR

$180.10

$4,322.30



8.9

Subtotal 99-years Annual PRSC Costs:







$33,348



Months

Present Value - O&M costs for 99 years (@-7% discount rate)









$475,810



TOTAL ESTIMATED COST









$15,423,164

0.7

TOTAL ESTIMATED COST (rounded up to nearest $1,000)









$15,424,000

Years

w USEPA REGION 6

Page 8 of 18	TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-4 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 3 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Effort Legend

Excavation and Disposal of Contaminated Soil at an On-Site Repository

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Key Assumptions:

1)	Labor factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

2)	Materials factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

3)	Equipment factor is based on the Gallup, New Mexico city cost index for Contractor Equipment (RSMeans, page 635).

4)	Costing assumes that the EPA will contract directly with a construction subcontractor/manager working out of the Grants, NM area.

5)	Mileage is estimated to be 106 miles one way from Albuquerque, NM to the field site

6)	Costs were developed assuming a 10-hour work day and 6 working days per week.

7)	Mobilization costs include transportation of needed equipment and personnel (e.g. heavy equipment, office trailers, and additional supplies/equipment).

Equipment rates are based on monthly rental rates from RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. All unit rates are marked up to include an
operator, laborors are separate for ground support.

Unit costs and production rates are based on rates obtained from RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. Unit costs include materials,
equipment, and labor.

10) Per diem rates are based on the maximum Federal 2022 CONUS Per Diem Rates.

Present value of post removal site control (PRSC) costs assume quarterly SWPPP inspections and an annual general inspection and report for the first 12 years. Costs ata
assume minor fencing, revegetation, and water system repairs during each inspection.

12)	Present Value Subtotal for PRSC costs assume a discount rate of 7.0%.

13)	For detailed information on personnel and equipment rates, quantities, and cost adjustment factors, see Tables K-6 thru K-8.

The average density of all wastes were assumed to be 1.3 tons per cubic yard. A capacity of 45,000 lb/load was assumed, which is 22.5 tons/load. Loose cubic yards
assumed a 20% swell factor.

Abbreviations:

CY = Cubic yards
LB = pound

MSF = thousand square feet
MI = Mile

CF = cubic foot
LF = linear feet
SF = square feet

PRSC = post-removal site control

EA = each
LS = Lump sum
SY = square yards

HR = hour
MO = Month
AC = Acre

US EPA REGION 6

Page 9 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-5

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 4 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Capping of Contaminated Soil in Place

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR/EPA
CONSTRUCTION CONTRACTOR

Item

Description

Quantity

Unit

Unit Cost

Extension

Item Total

Duration

CAPITAL COSTS:













1

Engineering Costs (Design Costs)















Project Manager

150

HR

$115.00

$17,250.00







Project Engineer

450

HR

$180.10

$81,043.20







Design Engineer

900

HR

$112.56

$101,304.00







CAD/GIS Operator

600

HR

$95.68

$57,405.60







Admin

150

HR

$100.00

$15,000.00







Expenses

1

LS

$5,000.00

$5,000.00



3.0



Subtotal Engineering Costs









$277,003

Months

2

Planning Documents (Work Plan, Health & Safety Plan, QA Plan, and SWPPP)















Project Manager

50

HR

$115.00

$5,750.00







Project Engineer

300

HR

$180.10

$54,028.80







CAD/GIS Operator

100

HR

$95.68

$9,567.60







Admin

50

HR

$100.00

$5,000.00







Expenses

1

LS

$1,000.00

$1,000.00



Concurrent with



Subtotal Planning Documents









$75,346

Item 1

3

Resource Surveys















Geotechnical T esting and Report

2

EA

$28,000.00

$56,000.00







Pre-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00







Post-Project Aerial LIDAR Survey

20

AC

$201.60

$4,032.00



Concurrent with



Subtotal Resource Surveys









$64,064

Other Work

4

1 Mobilization/Demobilization

1

LS

$1,549,264.48

$1,549,264.48



0.5



Subtotal Mob/Demob









$1,549,264

Months

5

Improve/Blaze Access Roads















Gravel Road Surfacing (8" Depth)

11,734

SY

$4.06

$47,618.49







Dozer, D-9 (2)

2

DAY

$4,458.86

$8,917.72







Grader (1)

1

DAY

$1,884.66

$1,884.66







Backhoe Loader (2)

2

DAY

$1,423.67

$2,847.34







6000 Gal Water Truck (1)

1

DAY

$2,361.91

$2,361.91







Laborer (5)

41

HR

$71.19

$2,918.96



0.4



Subtotal Improve Access Road









$66,549

Months

6

Construction Water















Construction Water, including Hauling

914,000

GAL

$0.11

$95,970.00







Portable Water Tower Trailer, 10,000 gallons (2)

463

DAY

$1,740.93

$806,049.66



Concurrent with



Subtotal Construction Water









$902,020

Other Work

7

1 Clearing and Grubbing















Dozer, D-9 (2)

7

DAY

$4,458.86

$31,212.03







Crawler Loader (1)

4

DAY

$2,790.58

$11,162.31







Brush Chipper, 12"

4

DAY

$1,317.51

$5,270.05







6000 Gal Water Truck (1)

4

DAY

$2,361.91

$9,447.64







Laborer (5)

167

HR

$71.19

$11,889.43



0.2



Subtotal Clearing and Grubbing









$68,981

Months

8

1 Fence Construction / Repair















Fence Materials

2,640

LF

$23.95

$63,235.31







Flatbed Truck (1)

9

DAY

$1,267.94

$11,411.48







Manual Fence Post Auger (1)

9

DAY

$1,158.96

$10,430.62







Laborer (5)

440

HR

$71.19

$31,325.45



Concurrent with



Subtotal Fence Construction/Repair









$116,403

Other Work

9

Erosion and Sediment Control















Silt Fence

16,000

LF

$0.54

$8,644.61







Sediment Log, Filter Sock, 9"

4,000

LF

$4.20

$16,808.96







Loader, Skid Steer, 30 H.P. (1)

10

DAY

$1,351.41

$13,514.10







Flatbed Truck (1)

10

DAY

$1,267.94

$12,679.42







Laborer (5)

493

HR

$71.19

$35,098.74



Concurrent with



Subtotal Erosion and Sediment Control









$86,746

Other Work

10

Headworks Removal















Flatbed Truck (1)

2

DAY

$1,267.94

$2,535.88







Structural Steel Foreman (1)

20

HR

$105.30

$2,106.00







Structural Steel Worker (1)

20

HR

$101.81

$2,036.21







Truck Driver (1)

20

HR

$82.56

$1,651.26







Laborer (5)

100

HR

$71.19

$7,119.42



Concurrent with



Subtotal Headworks Removal









$15,449

Other Work

w USEPA REGION 6

Page 10 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-5 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 4 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Capping of Contaminated Soil in Place

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR/EPA
CONSTRUCTION CONTRACTOR

11

Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)















Dump Truck, 34 CY, Off-Road (1)

4

DAY

$2,940.28

$11,761.10







Backhoe Loader (1)

4

DAY

$2,610.55

$10,442.20







Pump, Concrete, Truck Mounted, 4" Line, 80' Boom (1)

1

DAY

$3,207.40

$3,207.40







Polyurethane Foam

32

CY

$390.00

$12,365.66







Laborer (5)

162

HR

$71.19

$11,533.46



0.2



Subtotal Fill Adit and Vent Shaft and Plug with Polyurethane Foam (PUF)









$49,310

Months

12

Excavation, Transportation, and Stockpile of Clean Cover Material















Backhoe Loader (2)

316

DAY

$4,913.37

$1,552,626.47







Loader (2)

70

DAY

$3,207.40

$224,517.88







Dozer, D-9 (1)

35

DAY

$4,458.86

$156,060.14



Number of Loads



Tractor Truck, 6x4 (450 HP) (6)

153

DAY

$1,796.76

$274,903.89



3,758



Dump Trailer Only (20 CY)

153

DAY

$155.14

$23,736.02







6000 Gal Water Truck (1)

35

DAY

$2,361.91

$82,666.87







Laborer (5)

1,727

HR

$71.19

$122,952.38



Concurrent with



Excavation, Transportation, and Stockpile of Clean Cover Material









$2,437,464

Item 13

13

Construction of Clean Soil Cover















Dozer, D-9 (2)

61

DAY

$4,458.86

$271,990.53







Backhoe Loader (2)

379

DAY

$3,207.40

$1,215,603.94







Grader(2)

11

DAY

$1,884.66

$20,731.30







Sheepsfoot Roller, Dozer Towed (1)

11

DAY

$1,884.66

$20,731.30







Smooth Drum Roller, Dozer Towed (1)

11

DAY

$1,854.50

$20,399.51







6000 Gal Water Truck (1)

31

DAY

$2,361.91

$73,219.23







Laborer (5)

1,522

HR

$71.19

$108,357.57







Compaction Testing

53

EA

$342.18

$18,217.79



7.4



Subtotal Construction of Clean Soil Cover









$1,749,251

Months

14

Confirmation Sampling - will happen concurrently with field work















Develop Sampling and Analysis Plan (SAP)















Geologist

80

HR

$118.19

$9,455.04







Project Manager

20

HR

$115.00

$2,300.00







Admin

20

HR

$100.00

$2,000.00







Sampling















Sampling Team (two 2-person crews)

300

HR

$95.68

$28,702.80







Mileage Albuquerque, NM to Sites (1 round trip per week)

265

MI

$0.54

$143.10







Per Diem (4 people)

30

DAY

$142.00

$4,260.00







Gamma Scanning Equipment and Miscellaneous Field Supplies and Expenses

1

LS

$2,625.00

$2,625.00







Lab Analysis (15 samples per 2,000 m2 survey area = 30 samples per acre)

600

EA

$84.75

$50,850.00







Oversight during the Construction Duration















Project Manager

7,000

HR

$115.00

$805,000.00







Site Superintendent

7,000

HR

$100.00

$700,000.00







Radiation T echnician

7,000

HR

$135.00

$945,000.00







Field T echnician

7,000

HR

$80.00

$560,000.00







Off-Site Office

9

MO

$700.00

$6,300.00







Reporting















Geologist/Project Scientist

120

HR

$118.19

$14,182.56







Project Manager

30

HR

$115.00

$3,450.00







Project Engineer

30

HR

$180.10

$5,402.88







Health Physicist

30

HR

$180.10

$5,402.88







CAD/GIS Operator

120

HR

$95.68

$11,481.12







Admin

30

HR

$100.00

$3,000.00







Copying

4

LS

$31.25

$125.00



Concurrent with



Subtotal Confirmation Sampling









$3,159,680

Other Work

15

Site Restoration (staging areas, general disturbance areas)















Tractor (2)

6

DAY

$1,529.30

$9,175.77







Grader(3)

11

DAY

$1,884.66

$20,731.30







Flat Bed Truck (1)

4

DAY

$1,267.94

$5,071.77







Power Mulcher (1)

2

DAY

$1,500.82

$3,001.65







6000 Gal Water Truck (1)

4

DAY

$2,361.91

$9,447.64







Laborer (5)

146

HR

$71.19

$10,394.35







Seed Mix

20

AC

$12.52

$250.44







Soil Amendments (Humate)

20

AC

$192.39

$3,847.78







Fertilizer

20

AC

$0.68

$13.60







Mulch

20

AC

$6.36

$127.30



0.2



Subtotal Site Restoration









$62,062

Months

16

Per Diem















Construction Crew Per Diem (40 people)

13,886

DAY

$142

$1,971,771



Concurrent with



Subtotal Construction Crew Per Diem









$1,971,771

Other Work

w USEPA REGION 6

Page 11 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-5 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

ALTERNATIVE 4 - PRELIMINARY CONSTRUCTION COST ESTIMATE

Capping of Contaminated Soil in Place

Tronox Navajo Area Uranium Sites Section 10 Mine; McKinley County, New Mexico

Effort Legend

START CONTRACTOR/EPA
CONSTRUCTION CONTRACTOR

Contractor Project Management

Project Manager

1,900

HR

$115.00

$218,500.00

Site Superintendent, H&S Officer, and QA/QC Officer

7,000

HR

$100.00

$700,000.00

Site Foreman (3)

7,000

HR

$29.27

$204,859.20

Field Accountant (1)

4,700

HR

$100.00

$470,000.00

Site Vehicles- 4WD Trucks (7)

9

MO

$5,402.88

$48,625.92

Mileage Albuquerque, NM to Site (106 mi/each way)

42,583

MI

$0.54

$22,994.74

Fuel for Vehicles

926

MO

$3,253.33

$3,011,657.14

Port-o-let Rental (4)

9

MO

$499.47

$4,495.20

Job Trailers (2)

9

MO

$294.16

$2,647.41

Storage Boxes (2)

9

MO

$103.26

$929.30

Field Office Lights/HVAC (1)

9

MO

$195.70

$1,761.34

Telephone/internet (1)

9

MO

$104.46

$940.10

Field Office Equipment

9

MO

$276.15

$2,485.32

Field Office Supplies

9

MO

$104.46

$940.10

Trash (2 dumpsters)

9

MO

$490.08

$4,410.70

Air Monitoring Equipment

9

MO

$9,914.21

$89,227.91

Generator (1)

9

MO

$2,498.30

$22,484.70

Subtotal Contractor Project Management

$4,806,959

SUBTOTAL CAPITAL COSTS:

19	Contingency - 25% (Items 1-17)

20	Indirect Costs - 8% (Items 1-17, and 19)
TOTAL CAPITAL COSTS:

$17,458,322
$17,458,322 4364580.615
$21,822,903 1745832.246

Project

$23,568,735

Planning

3.0
Months

PRSC COSTS (O & M):

21

Additional Effort for First 12-years O&M

Quarterly Inspections (2 person crew, 2 days, 10 hrs/day)

160

HR

$95.68

$15,308.16

Mileage Albuquerque, NM to Site (round trip)

848

MI

$0.62

$525.76

Inspection Crew Per Diem

16

DAY

$155.00

$2,480.00

Preparation of Semi-annual Reports (Professional Engineer)

40

HR

$180.10

$7,203.84

Assumed Annual Maintenance Costs (revegetation, watering, fence repairs)

1

LS

$40,000.00

$40,000.00

Subtotal: Additional First 12-years Annual PRSC Costs:







$65,518

Present Value - O&M costs for 12 years (@-7% discount rate)









99 Years O&M Costs









Annual Inspection (2 person crew, 4 days, lOhrs/day)

80

HR

$95.68

$7,654.08

Mileage Albuquerque, NM to Site (round trip)

212

MI

$0.62

$131.44

Inspection Crew Per Diem

8

DAY

$155.00

$1,240.00

Assumed Annual Maintenance Costs

1

LS

$20,000.00

$20,000.00

Preparation of Annual Report (Professional Engineer)

24

HR

$180.10

$4,322.30

Construction

231
Work Days

9.0

Months

$520,390

306
Work Days

Subtotal 99-years Annual PRSC Costs:

Present Value - O&M costs for 99 years (@ -7% discount rate)

$33,348

11.9

Months

$475,810

TOTAL ESTIMATED COST

$24,564,935

1.0

Years

TOTAL ESTIMATED COST (rounded up to nearest $1,000)

$24,565,000

Key Assumptions:

1)	Labor factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

2)	Materials factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

3)	Equipment factor is based on the Gallup, New Mexico city cost index for Contractor Equipment (RSMeans, page 635).

4)	Costing assumes that the EPA will contract directly with a construction subcontractor/manager working out of the Grants, NM area.

5)	Mileage is estimated to be 106 miles one way from Albuquerque, NM to the field site

6)	Costs were developed assuming a 10-hour work day and 6 working days per week.

7)	Mobilization costs include transportation of needed equipment and personnel (e.g. heavy equipment, office trailers, and additional supplies/equipment).

Equipment rates are based on monthly rental rates from RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. All unit rates are marked up to include an
operator, laborors are separate for ground support.

Unit costs and production rates are based on rates obtained fiom RS Means Heavy Construction Cost Data, 34th Annual Edition, 2020. Unit costs include materials,
equipment, and labor.

Per diem rates are based on the maximum Federal 2022 CONUS Per Diem Rates.

Present value of post removal site control (PRSC) costs assume quarterly SWPPP inspections and an annual general inspection and report for the first 12 years. Costs also
assume minor fencing, revegetation, and water system repairs during each inspection.

Present Value Subtotal for PRSC costs assume a discount rate of 7.0%.

For detailed information on personnel and equipment rates, quantities, and cost adjustment factors, see Tables K-6 thru K-8.

The average density of all wastes were assumed to be 1.3 tons per cubic yard. A capacity of 45,000 lb/load was assumed, which is 22.5 tons/load. Loose cubic yards assumed
a 20% swell factor.

9)

10)

11)

12)

13)

14)

Abbreviations:

CY = Cubic yards
LB = pound

MSF = thousand square feet
MI = Mile

CF = cubic foot
LF = linear feet
SF = square feet

PRSC = post-removal site control

EA = each
LS = Lump sum
SY = square yards

HR= hour
MO = Month
AC = Acre

USEPA REGION 6

Page 12 of 18	TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-6

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Equipment and Personnel Rates for the Section 10 Mine Site

Reference: RS Means Heavy Construction Cost Data 2020

Equipment and Operator Unit Prices for the Section 10 Mine Site

Equipment/Personnel

RS Means

Equipment
Hourly Operating
Cost

Equipment
Rental per
Month

Equipment Cost
per Day

EPA Provided
Operator/ Driver
Hourly Rate

Equipment +
Operator

Total per Day,
including O&P

Manual Fence Post Auger

RSM 01 54 33.20 0095

$

0.54

$ 54.00

$

7.52

$

95.51

$

962.59

$

1,158.96

Backhoe Loader(40 hp)

RSM 01 54 33.20 0400

$

14.28

$ 2,175.00

$

227.38

$

95.51

$

1,182.45

$

1,423.67

Excavator(7 CY)

RSM 01 54 33.20 0340

$

210.30

$ 26,300.00

$

3,125.80

$

95.51

$

4,080.88

$

4,913.37

Brush Chipper, 12" (130 hp)

RSM 01 54 33.20 0550

$

28.41

$ 2,525.00

$

382.34

$

71.19

$

1,094.28

$

1,317.51

Grader (30,000 lbs)

RSM 01 54 33.20 1910

$

39.44

$ 5,550.00

$

610.26

$

95.51

$

1,565.34

$

1,884.66

Power Mulcher

RSM 01 54 33.20 2860

$

21.66

$ 1,925.00

$

291.46

$

95.51

$

1,246.53

$

1,500.82

Sheepsfoot Roller, Towed (50 hp)

RSM 01 54 33.20 3150

$

30.77

$ 3,150.00

$

430.24

$

$

430.24

$

518.01

Smooth Drum Vibratory Roller, (125 hp)

RSM 01 54 33.20 3400

$

33.15

$ 6,525.00

$

585.21

$

95.51

$

1,540.28

$

1,854.50

Scraper (21 cy)

RSM 01 54 33.20 3550

$

169.70

$ 19,900.00

$

2,470.93

$

95.51

$

3,426.00

$

4,124.90

Dozer, D-6 (200 hp)

RSM 01 54 33.20 4260

$

75.82

$ 11,700.00

$

1,213.16

$

95.51

$

2,168.23

$

2,610.55

Dozer, D-9 (500 hp)

RSM 01 54 33.20 4370

$

160.11

$ 29,500.00

$

2,748.30

$

95.51

$

3,703.37

$

4,458.86

Crawler Loader (3 CY)

RSM 01 54 33.20 4560

$

85.71

$ 13,000.00

$

1,362.68

$

95.51

$

2,317.75

$

2,790.58

Front End Loader (8 CY)

RSM 01 54 33.20 4810

$

109.44

$ 15,800.00

$

1,708.88

$

95.51

$

2,663.95

$

3,207.40

1 Loader, Skid Steer (30 hp)

RSM 01 54 33.20 4880

$

11.49

$ 1,350.00

$

167.36

$

95.51

$

1,122.43

$

1,351.41

Dump Trail Only (20 CY)

RSM 01 54 33.20 5400

$

7.44

$ 1,400.00

$

128.85

$

$

128.85

$

155.14

Dump Truck, 34 CY, Off-Road (50 ton)

RSM 01 54 33.20 5610

$

100.98

$ 15,600.00

$

1,616.46

$

82.56

$

2,442.09

$

2,940.28

Tractor, with Attachment

RSM 01 54 33.40 6465

$

20.91

$ 2,725.00

$

315.11

$

95.51

$

1,270.18

$

1,529.30

6,000 Gal Water Truck

RSM 01 54 33.40 6950

$

86.39

$ 7,000.00

$

1,136.09

$

82.56

$

1,961.72

$

2,361.91

Flatbed Truck (20,000 lb)

RSM 01 54 33.40 7290

$

18.37

$ 1,125.00

$

227.48

$

82.56

$

1,053.11

$

1,267.94

Truck Tractor, 6x4 (450 hp)

RSM 01 54 33.40 7600

$

53.25

$ 3,450.00

$

666.70

$

82.56

$

1,492.32

$

1,796.76

Portable Water Tower Trailer, 10,000 gallons

RSM 01 54 33.40.6925

$

11.74

$ 1,775.00

$

186.42

$

$

186.42

$

224.45

Pump, Concrete, Truck Mounted, 4" Line, 80' Boom

RSM 01 54 33.10.2120

$

35.87

$ 7,950.00

$

667.84

$

82.56

$

1,493.47

$

1,798.13

Generator

RSM 01 54 33.40.2500

$

9.15

$ 2,075.00

$

172.19

-

-

$

275.72

Off-Site Office

Engineering Estimate

-

$ 700.00

-

-

-

$

700.00

USEPA REGION 6

i2Sz$

Page 13 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-6 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Construction and Engineering Personnel Rates for the Section 10 Mine Site

Personnel

Source

Hourly Rate

Daily Rate



Truck Driver (Heavy)

RS Means Labor Data

$ 82.56

$ 825.63



Laborer

RS Means Labor Data

$ 71.19

$ 711.94



Foreman

RS Means Labor Data

$ 29.27

$ 292.66



Equipment Operator

RS Means Labor Data

$ 95.51

$ 955.07



Site Superintendent

RSM 01 31 13.20

$ 100.00

$ 1,000.00



Field Accountant

Engineering Estimate

$ 100.00

$ 1,000.00



Sampling Team/Scientist

Engineering Estimate

$ 95.68

$ 956.76



CAD/GIS Operator

Engineering Estimate

$ 95.68

$ 956.76



Design Engineer

Engineering Estimate

$ 112.56

$ 1,125.60



Geologist/Project Scientist

Engineering Estimate

$ 118.19

$ 1,181.88



Professional Engineer

Engineering Estimate

$ 135.07

$ 1,350.72



Project Engineer

Engineering Estimate

$ 180.10

$ 1,800.96



Project Manager

Engineering Estimate

$ 115.00

$ 1,150.00



Structural Steel Foreman

RS Means Labor Data

$ 105.30

$ 1,053.00



Structural Steel Worker

RS Means Labor Data

$ 101.81

$ 1,018.11



Radiation Technician

Engineering Estimate

$ 135.00

$ 1,350.00



Field Technician

Engineering Estimate

$ 80.00

$ 800.00



Health Physicist

Engineering Estimate

$ 180.10

$ 1,800.96



Per Diem and Mileage Rates







Allowance

Source

Lodging

M&IE

Total

Per Diem Rate (per Day)

www.gsa.gov

$ 96.00

$ 59.00

$ 155.00

Mileage Rate (per Mile)

www.gsa.gov

--

--

$ 0.62

Key Assumptions:

1)	Hourly labor rates were taken from RS Means trade data (RS Means, inside back cover) and escalated from 2020 to 2022 rates.

2)	Hourly labor rates calculated using engineering estimates were provided by Weston Solutions' Estimating Department.

2)	Daily rates assume a 10-hour work day.

3)	Weekly and Monthly rates assume a 6-day work week.

4)	RS Means production rates assume 8-hour work days. Equipment production rates were increased by 25% to account for the longer 10-hour work days.

5)	Per diem and mileage rates are based on the maximum Federal 2022 CONUS Per Diem Rates.

USEPA REGION 6

i2Sz$

Page 14 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-7

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Material and Work Quantities and Unit Prices for the Section 10 Mine Site

Reference: RS Means Heavy Construction Cost Data 2020 unless otherwise noted.

Waste Material Earthwork Areas and Volumes



Depth

Surface Area

Surface Area

Volume

Volume

Remediation Area - Alternative 2

(ft)

(ft2)

(Acres)

(ft3)

(CY)

Waste Material Volume











1-Foot Depth Area

1

857,700

20

857,700

31,767

Sub-Economic Material Pile







196,869

7,291

Totals of Excavation

857,700

20

857,700

39,058

Transported Volume, CY

Applying a 20% Swell Factor

46,870

Transported Weight, TONS

Assuming 1.3 Tons per CY

60,930

Number of Loads

Assuming 45,000 lb/load

2,708



Depth

Surface Area

Surface Area

Volume

Volume

Remediation Area - Alternative 3

(ft)

(ft2)

(Acres)

(ft3)

(CY)

Waste Material Volume











1-Foot Depth Areas

1

857,700

20

857,700

31,767

Sub-Economic Material Pile







196,869

7,291

1-Foot Depth Areas within Repository Footprint*

1

378,972

8.7

378,972

14,036

Totals of Excavation

478,728

11

478,728

25,022

Transported Volume, CY

Applying a 20% Swell Factor





30,026

* Areas in the cleanup zone that overlap with the footprint of the repository were removed from the total waste volume estimates since that material would remain in place.

Cap Earthwork Areas and Volumes











Section 10 Mine Repository Cap Volume - Alternative 3

Estimated Cap Volume tor 40,000 CY Repository from Preliminary Design, CY







28.547

In-Place Cap Volume - Alternative 4

Estimated Cap Footprint, Acres

20

Estimated Cap Footprint, SY

96,800

Estimated Cap Footprint, Square Feet

871,200

Cap Thickness, ft

3

Estimated Cap Volume for In-Place Preliminary Design, CF

2,613,600

Estimated Cap Volume for In-Place Preliminary Design, CY

96,800

Estimated Cap Volume for In-Place Preliminary Design Applying 10% Factor to Account for Topography, CY

106,480

Revegetation Areas

Revegetation Area - Alternative 2, 3, & 4

(MSF)

(ft2)

(Acres)*

Removal Area / Repository Area / Cap Area

858

857,700

20

?	US EPA REGION 6

Page 15 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-7 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Material and Work Quantities and Unit Prices for the Section 10 Mine Site

Reference: RS Means Heavy Construction Cost Data 2020 unless otherwise noted.

Polyurethane Foam (PUF) Plugs for Adit and Vent Shafts

Adit and Vent Shaft Closure Fill Material and PUF Plug
Volumes

Depth
(ft)

Diameter (in)

Diameter (ft)

Volume

(ft3)

Volume
(CY)

Fill Material Volume











Shaft (less 20 feet for PUF plug and surface cover)

271.4

120

10

21,316

790

Vent (less 20 feet for PUF plug and surface cover)

331.6

36

3

2,344

87

Shaft - Polyurethane Foam

10

120

10

785

29

Vent - Polyurethane Foam

10

36

3

71

3

Shaft - Fill Above Polyurethane Foam

10

120

10

785

29

Vent - Fill Above Polyurethane Foam

10

36

3

71

3

Total Fill Material Below Foam, CY

877

Total Fill Material Above Foam, CY

32

Total Polyurethane Foam, CY

32

Study Area Quantities and Unit Prices

Work Item

Quantity

Unit

Unit Price

Extended Price

Reference

Assumptions

Cultural Resources Mitigation

1

Each

$

200,000.00

$

200,000.00

Priced by NV5

Adjusted to reflect 2022 price

Geotechnical Testing and Report

2

Each

$

28,000.00

$

56,000.00

RSM 02 32 13.10

Assumed two studies for project

Aerial Survey (LIDAR)

20

AC

$

201.60

$

4,032.00

RSM 02 21 13.16 2000

Assumed price x2 due to small area

Construction Quantities and Unit Prices

Road Gravel (Materials) - All Alternatives

Quantity

11,734

Unit

SY

T

Unit Price /
4.06

Extended Price

$ 47,618.49

Reference
RSM 01 55 23.50 0100

Assumptions

1.0 mile of road, 20 feet wide

Fence Repair (Materials)

2,640

LF

$

23.95

$

63,235.31

RSM 32 31 13.20 0200

Assumed 0.5 miles for duration of project

Silt Fence (Materials)

16,000

LF

$

0.54

$

8,644.61

RSM 31 25 14.16 1000

Assumed 800 feet required per acre

Sediment Log, Filter Sock, 9" (Materials)

4,000

LF

$

4.20

$

16,808.96

RSM 31 25 14.16 1250

Assumed 200 feet required per acre

Seeds (Materials) - All Alternatives

20

AC

$

12.52

$

250.44

RSM 32 92 19.14 5300

$12.45/52000sqf * 43560sq/lac

Soil Amendments (Humate) (Materials) - All Alternatives

20

AC

$

192.39

$

3,847.78

RSM 32 91 13.23 4050

$2575.00/700000sqf * 43560sqf/lac

Fertilizer (Materials) - All Alternatives

20

AC

$

0.68

$

13.60

RSM 32 91 13.23 4150

$9.10/700000sqf * 43560sqf/lac

Multch (Materials) - All Alternatives

20

AC

$

6.36

$

127.30

RSM 32 91 13.16 0700

$64.50/530000sqf * 43560sqf/lac

Waste Soil Transportation

60,930

TON

$

62.15

$

3,786,829.33

Facility Quote

Assumed 1.3 tons per CY, and 20% swell

Waste Soil Processing Fee

60,930

TON

$

84.75

$

5,163,858.18

Facility Quote

Assumed 1.3 tons per CY, and 20% swell

Truck Mobilization Fee

2,708

Each

$

1,266.73

$

3,430,304.84

Facility Quote

Assumed 300 trucks, 2-day rotation

Truck Tarp

2,708

Each

$

118.65

$

321,304.20

Facility Quote

Assumed 300 trucks, 2-day rotation

Job Trailers

1

MO

$

294.16

$

294.16

RSM 01 52 13.20 0350

Assumed a 138 kV Transmossion Trai

Storage Boxes

1

MO

$

103.26

$

103.26

RSM 01 52 13.20 1250

Assumed a 138 kV Transmossion Boxe

Field Office Lights/HVAC

1

MO

$

195.70

$

195.70

RSM 01 52 13.40 0160

Assumed a 138 kV Transmossion Ligh

Telephone/internet

1

MO

$

104.46

$

104.46

RSM 01 52 13.40 0140

Assumed a 138 kV Transmossion Tele

Portable Toilet



MO

$

249.73

$

499.47

RSM 01 54 33.40 6410



Field Office Equipment

1

MO

$

276.15

$

276.15

RSM 01 52 13.40 0100

Assumed a 138 kV Transmossion Equi

Field Office Supplies

1

MO

$

104.46

$

104.46

RSM 01 52 13.40 0120

Assumed a 138 kVTransmossion Supp

Trash (2dumpsters)

1

MO

$

490.08

$

490.08

Engineering Estimate

Assumed a 138 kV Transmossion dump

Air Monitoring Equipment

2

MO

$

4,957.11

$

9,914.21

Vendor Quote

Assumed a 138 kVTransmossion Equi

Site Vehicles- 4WD Trucks

3

MO

$

1,800.96

$

5,402.88

RSM 01 54 33.40 7200



Site Vehicles

2

MO

$

563.31

$

1,126.61

Engineering Estimate



Fuel for Vehicles

1

MO

$

3,253.33

$

3,253.33

Engineering Estimate

$4.88/gal, 15 mi/gal, 10,000 miles/month

Truck Scales

1

MO

$

339.00

$

339.00

Engineering Estimate

Assumed a 138 kVTransmossion Seal

Construction Water, including Hauling - Alternative 2

1,266,000

GAL

$

0.11

$

132,930.00

Engineering Estimate

Assumed 2 gal/CY for excavation, 30 gal/CY for hauling dust control

USEPA REGION 6

Page 16 of 18

TDD No. 0001/17-044


-------
Appendix K (Continued)

Cost Estimate Details
Table K-7 (Continued)

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Material and Work Quantities and Unit Prices for the Section 10 Mine Site

Reference: RS Means Heavy Construction Cost Data 2020 unless otherwise noted.

Construction Water, including Hauling - Alternative 3

811,000

GAL

$

0.11

$

85,155.00

Engineering Estimate

Assumed 2 gal/CY for excavation, 30 gal/CY for hauling dust control

Construction Water, including Hauling - Alternative 4

914,000

GAL

$

0.11

$

95,970.00

Engineering Estimate

Assumed 2 gal/CY for excavation, 30 gal/CY for hauling dust control

Portable Water Tower Trailer, 10,000 gallons

2

MO

$

1,740.93

$

3,481.86

RSM 01 54 33 40 7660



Compaction Test (Field) - Alternative 3

27

EA

$

342.18

$

9,165.18

Engineering Estimate

Assumed 1 test per 2,000 CY. Density, proctor, Atterburg, and sieve test

Compaction Test (Field) - Alternative 4

53

EA

$

342.18

$

18,217.79

Engineering Estimate

Assumed 1 test per 2,000 CY. Density, proctor, Atterburg, and sieve test

Radiological Confirmation Sample (Lab) - Alternative 2

600

EA

$

84.75

$

50,850.00

Engineering Estimate

Assumed 30 samples per acre, $60/lab sample, $15/sample for shipping

Radiological Confirmation Sample (Lab) - Alternative 3

339

EA

$

84.75

$

28,730.25

Engineering Estimate

Assumed 30 samples per acre, $60/lab sample, $15/sample for shipping

Radiological Confirmation Sample (Lab) - Alternative 4

600

EA

$

84.75

$

50,850.00

Engineering Estimate

Assumed 30 samples per acre, $60/lab sample, $15/sample for shipping

Polyurethante Foam

32

CY

$

390.00

$

12,365.66

Academic Paper

Price from paper in 1994 adjusted for 2022

Selective Demolition, Radio Towers, Self Supported, 60'

1

EA

$

3,668.00

$

3,668.00

RSM 02 41 13.78 0700

Treat headframe as a radio tower for demo purposes

Generator, Diesel Engine, 20 kW

1

MO

$

2,498.30

$

2,498.30

RSM 01 54 33.40.2500



Notes:

1) Unless noted otherwise, quantity items are applicable to Alternatives, 2, 3, and 4.

USEPA REGION 6

Page 17 of 18	TDD No. 0001/17-044


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Appendix K (Continued)

Cost Estimate Details
Table K-8

Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Markup Factors for Gallup, New Mexico

Reference: RS Means Heavy Construction Cost Data 2020

Weston Solutions Estimating and Controls, RS Means Historical Cost Indexes, accessed September 2022

The majority of the work will be Excavation (as defined by RSMeans) by Equipment Operators, Laborers, and Foremen

Labor1

Category

Gallup. NM
Installation
Factor

Time Factor

Total Factor

Excavation

1.005

1.12

1.13

Materials2

Profit

Gallup. NM
Materials
Factor

Time Factor

Total Factor

0.1

1.072

1.12

1.20

Equipment3

Profit

Gallup. NM
Equipment
Factor

Time Factor

Total Factor

0.1

1.075

1.12

1.20

Time4

Historical Cost Indexes

January 2022

January 2020

Time Factor

January 2022

January
2016

Time Factor

January 2022

January 2019

Time Factor

261.6

234.6

1.12

261.6

207.3

1.26

261.6

232.2

1.13

1	Labor factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).
Workers Comp % is based on New Mexico rates for Excavation (RSMeans, page 620).

2	Materials factor is based on the Gallup, New Mexico city cost index for Site and Infrastructure, Demolition (RSMeans, page 635).

3	Equipment factor is based on the Gallup, New Mexico city cost index for Contractor Equipment (RSMeans, page 635).

4	Time factor is based on adjusting 2020 RS Means cost data to January 2022, using RS Means Historical Cost Indexes

and online data from Weston's Estimating and Controls group, accessed in August 2022 to obtain January 2022 cost index.

e

US EPA REGION 6

Page 18 of 18	TDD No. 0001/17-044


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APPENDIX L

LONG-TERM STORAGE FACILITY (REPOSITORY)
RADON FLUX CALCULATIONS


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-------
Appendix L

Long-Term Storage Facility (Repository) Radon Flux Calculations

Alternative 3 (Non-Incised, On-Site Repository)















3Long-term

















Average













4Radon

4Radon

Moisture

4Specific







2Porosity of

3Density of

Emanation

Decay

Content (Dry

Gravity of





"'Thickness of

Material

Material

Coefficient

Constant

weight

Soils



Type of

Layer (cm)

(Unitless)

(g/cm3)

(Unitless)

(1/s)

percentage)

(Unitless)



Material

(x)

(n)

(P)

(E)



(w)

(G)

Contaminated Soils

Native soil

500

0.305660377

1.84

0.35

2.10E-06

10

2.65

Cover layer

Native soil

91.44

0.305660377

1.84

0.35

2.10E-06

10

2.65













Equilibrium

















distrubution

2Radon Flux





3Specific

2Moisture

2Radon

inverse



Coffecient of

from the bare

2Radon Flux



Activity of

saturation

Diffusion

relaxation

interface

Radon in

contaminated

from the



Ra-226

fractions

Coefficients

length

constants

Water and

soil

Cover



(pCi/g)

(Unitless)

(cm2/s)

(1/cm)

(cm2/s)

Air (pCi/cm3)

(pCi/m2-s)

(pCi/m2-s)



(R)

(m)

(D)

(b)

(a)

(k)

(J,)

(Jc)

Contaminated Soils

150

0.6020

5.75E-03

0.0191

0.0002

0.2600

106



Cover layer

1

0.6020

5.75E-03

0.0191

0.0002

0.2600



18.5

State of New Mexico Guidance Radon Flux Limit:

20

1Thickness of cover layer was determined by trial and error in order to determine the maximum thickness with a Radon Flux result less than
or equal to the state of New Mexico guidance limit of 20 pCi/m2-s. A cover thickness of 91.44 centimeters is equivalent to 3 feet. The
contaminated soil thickness of 500 centimeters = 16.4 feet. The long-term storage facility (repository) design (Non-Incised, Surface, On-Site
[Alternative 3]) features a contaminated-soils thickness greater than 500 centimeters; the radon flux calculated result remains the same
(18.5 pCi/m2-s) beyond a thickness of 500 centimeters.

2Value calculated per NRC Regulatory Guide 3.64 formulas noted below. The NRC Regulatory Guide 3.64 formulas were designed with
uranium mill tailings in mind; therefore, the subscripts't' and 'c' in the formulas below refer to 'tailings' and 'cover', respectively. In this
case, the formulas and terms with the't' subscript are used for 'Contaminated Soils' and the formulas and terms with the 'c' subscript are
used for 'Cover layer'.

Value obtained from Design Engineer or Project Manager.

Value obtained from NRC Regulatory Guide 3.64.

NRC Regulatory Guide 3.64 Radon Flux Formulas:

J, = = 104 * R * p * E * V(A * D) * hyperbolic tangent of (x * V(A/D))

2*j * e"b * x

I _ t c c
Jf-

1 + V(at/ac;

D = 0 07 * e"4 : '¦m"if": n"2'+ 'm"5"

m = 10"2 * p * w

n * pw

¦; pw is the mass density of water = 1 g/cm3

G*PW

"; pw is the mass density of water = 1 g/cm3

b = V(A/D)

a = n2 * D * (l-((l-k) * m))2

©

US EPA REGION 6

1 of 1	TDD No. 0001/17-044


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APPENDIX M

LONG-TERM STORAGE FACILITY (REPOSITORY)
PRELIMINARY DESIGN DRAWINGS


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APPENDIX N
GREEN ALTERNATIVES ASSESSMENT


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Appendix N
Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Green Alternatives Assessment

Based on EPA Guidance, there are five core (key) elements in "greener cleanup activities" that
should be considered throughout the remedy selection process (EPA, 2016). These key elements
include: minimizing total energy use and increasing the percentage of renewable energy;
minimizing air pollutants and greenhouse gas emissions; minimizing water use and negative
impacts on water resources; protecting ecosystem services; and improving materials management
and waste reduction efforts by reducing, reusing, or recycling whenever feasible (EPA, 2012).
This analysis compares the effects each removal action alternative, described in Section 3.0, has
on the five key "green" elements. Each of the five elements was qualitatively scored for each
alternative (1, 2, 3, and 4) using a numerical ranking system 1-4, with a 1 being best and a 4
being worst (i.e., low scores are greener cleanup alternatives). The alternative's Greener Cleanup
Assessment Score was derived from the sum of the five scores for that alternative. The results of
this assessment are summarized in Table N-l.

Total Energy Use and Percentage of Renewable Energy

Out of the four removal action alternatives, Alternative 1, the No Action Alternative is the only
alternative that requires no energy. For the other alternatives, energy usage can be broken into
two main categories: electrical usage and direct fossil fuel combustion. All of the alternatives
have relatively low electrical requirements. The main electricity demands are expected to be for
power to pump water from the onsite supply well, operation of the water treatment system to be
constructed as part of the removal action, and for the office trailers brought in to support
personnel; particularly for heating and cooling the trailers. Alternative 2 would have higher
electrical demand than Alternatives 3 and 4 since the off-site disposal facility would require
additional office support and water. Since active removal work is expected to be conducted
during daylight hours, lighting requirements are expected to be minimal for all alternatives. The
primary expected lighting needs would be during the darkest winter months, should work occur
during those periods, to illuminate the on-site office trailer and equipment yards. Grid power is

w _ USEPA REGION 6

1 of 7

TDD No. 0001/17-044


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Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

potentially available at the site which will preclude the need for temporary on-site generators,

eliminating a potential source of fossil fuel consumption.

The greatest fossil fuel consumption will be for heavy equipment and trucks used during the
excavation and transportation. The transportation requirement of each alternative is summarized
in Table 4-2. The use of biodiesel in place of diesel for heavy equipment use or transportation is
recommended. Given that the ability to use biodiesel does not vary between alternatives and it is
unknown if biodiesel fuels will be ultimately used, this analysis assumes heavy equipment will
be operated using traditional petroleum-based fuel sources.

Excluding Alternative 1, which does not require any energy consumption, Alternative 3 will
have the lowest fossil fuel consumption, followed by Alternatives 4 and 2. Alternative 4 requires
significant hauling of clean fill material which will require additional fossil fuel consumption not
required for Alternative 3. Alternative 2 has fossil fuel demands estimated to be more than an
order of magnitude greater than any other alternative due to having the greatest number of loads
transported off-site and farthest distance to the off-site disposal facility. The alternatives rank as
follows in order of least fossil fuel consumption to most: 1, 3, 4, and 2.

Air Pollutants and Greenhouse Gas Emissions

Relevant air pollutants include greenhouse gases, nitrogen oxides (NOx), sulfur oxides (SOx),
particulate matter less than 10 microns in size (PM10), and hazardous air pollutants (HAPs).
Fossil fuel combustion is expected to be the only source of HAPs as well as the major source of
greenhouse gases, NOx, SOx, and PM10. Estimated greenhouse gas emissions due to off-site
trucking are summarized in Table 4-2.

PM10 is generated during excavating and grading activities, including excavating material,
hauling or otherwise handling excavated material, placing and compacting earthen materials, and
driving on unpaved roads. Dust generation can be reduced through dust suppression methods,
such as applying water, covering material in open trucks, using soil tackifiers, covering
stockpiles, limiting on-site vehicle speed, and revegetating excavated areas as quickly as

US EPA REGION 8

2 of 7

No. 0001/17-044


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Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

possible. Due to the factors discussed above, the air pollution emissions will be highest for

alternatives that transport waste off-site.

As with energy demand, the greatest air pollution generation will be from the operation of heavy
equipment during excavation activities and from trucks used to transport materials and waste.

Thus, the ranking for air pollution is the same as for energy consumption. The alternatives rank
as follows from least air pollution generated to most: 1, 3, 4, and 2. As with energy demand,
Alternative 2 is expected to create air pollution that is an order of magnitude greater than the
other alternatives due to the significant number of loads transported off-site and distance to the
off-site repository.

Water Use and Impacts on Water Resources

Surface waters in the area are ephemeral and are generally only present for a day or two after
rains occur during summer monsoon periods. Because of this, a local water source is
unavailable; water demand will have to be meet with water trucked in from outside or by
installing a well. Water use should also be considered as part of the energy demand
transportation requirements and thus should be minimized both because of the impact on water
resources and because of associated increase in electrical and fossil fuel demands. The main use
of water, regardless of which alternative is selected, will be for dust suppression and soil
moisture conditioning to achieve the required relative density for compacted soil, followed by
equipment decontamination. Thus, the alternatives with the highest excavation, consolidation,
and transportation requirements will also have the highest water use.

Water use will not be the only impact on water resources. The creation of impervious caps
reduces the infiltration of stormwater, resulting in higher peak flows in the receiving stream. The
creation of engineered soil caps will temporarily increase runoff until vegetation is well
established and final stabilization is achieved, which could take as long as 10 years. The higher
peak flows will result in an increased risk of flooding and higher rates of erosion, which would
impact water quality. This effect will increase in direct proportion to the footprint of any
impervious cap. If the waste is disposed of at licensed facility, the size of the cap in relation to
the volume of waste may be reduced due consolidation with waste from other sites. However,
USEPA REGION 8

3 of 7	No. 0001/17-044


-------
Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

these facilities are also the most likely to use impervious caps. The risk of increasing peak flows

can be mitigated by diverting the runoff for another use, such as irrigation, or to an area it can
infiltrate into the ground, such as bioswales and stormwater detention basins. In addition to
reducing infiltration, a cap can potentially change drainage patterns. However, this effect can be
reduced by mimicking the slope of existing terrain.

Sediment runoff, particularly during excavation activities, can also degrade water quality during
the project. Sediment runoff will increase nutrient loading and suspended solids in the receiving
water. Since the sediment runoff would largely be from contaminated soil, another potential
impact is the migration of radiation into nearby water resources. The greater the excavation
footprint and duration of excavation, the greater expected impact. Sediment runoff can be
minimized by avoiding excavation activities during the monsoon season, minimizing the amount
of soil disturbed at a given time, and using sediment controls (e.g., reseeding bare soil as quickly
as possible; installing silt fence, straw wattles and fiber rolls; and constructing stormwater
detention basins). Migration of waste off-site through stormwater is a general concern for water
bodies. With the exception of Alternative 1, the No Action Alternative, all of the alternatives
provide long term mitigation of waste migration offsite.

Given all the factors outlined above, the alternatives rank as follows for water use and impact on
water resources from best to worst: 3, 4, 2 and 1.

Materials Management and Waste Reduction

Materials management and waste reduction efforts consider the total amount of materials used
on-site and the percentage of those materials that are produced from recycled material, reused
material, or waste material. Excluding fuels, which are evaluated separately, imported materials
include the earth and rock materials in caps, geotextile fabrics, temporary fencing, silt fencing,
culverts, large rock for riprap, and other water management and sediment and erosion control
devices. The alternatives will all generate cleared vegetation in proportion to the amount of land
disturbed. These factors are expected to apply regardless of which alternative is selected (i.e.,
whether on or off-site, all are expected to require varying amounts of the above materials).

US EPA REGION 8

4 of 7

No. 0001/17-044


-------
Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Given these factors, the alternatives rank as follows for impact on materials management and

waste reduction from best to worst: 1, 3, 4, and 2.

Ecosystem Services

The negative effect on water resources described above is one of the ecosystem services impacts.
Degrading water quality and quantity will affect the flora and fauna that depend on these sources.
Increased nutrient loading could cause algae blooms in downstream water bodies and increased
suspended solids could inhibit stream life by blocking sunlight that allows photosynthesis. The
more effective alternatives will be more protective of ecosystem services.

Given that none of the alternatives disturb previously undisturbed areas, or areas with hazardous
waste, long term habitat degradation on land is unlikely in all alternatives. However, removal
activities themselves will cause a temporary disruption to wildlife. Noise, ground disturbing
work, and any artificial light can all impact sensitive species. To minimize these impacts, it is
recommended to avoid conducting operations during nesting or breeding seasons whenever
possible.

Given all the factors outlined above, the alternatives rank as follows for impact on ecosystem
services from best to worst: 3, 4, 2, and 1.

Summary

A summary of the rankings for each of the core elements can be found in Table N-l. The table
also presents an overall greenness score for each alternative. The score was calculated by
summing the ranks each alternative received for each of the five core areas. The overall ranking
of alternatives for greenness, from best to worse, are as follows: 3, 1, 4, and 2.

References

USEPA. 2009. Principles for Greener Cleanups. August 27.

USEPA. 2012. Methodology for Understanding and Reducing a Project's Environmental
Footprint. February.

USEPA REGION 8

5 of 7	No. 0001/17-044


-------
Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

USEPA. 2016. Memorandum: Consideration of Greener Cleanup Activities in the Superfund
Cleanup Process. August 2.

List of Tables

Table N-l Green Alternatives Assessment Summary

USEPA REGION 8

6 of 7	No. 0001/17-044


-------
Appendix N (Continued)

Green Alternatives Assessment
Tronox Navajo Area Uranium Mines, Section 10 Mine
McKinley County, New Mexico

Table N-1 Green Alternatives Assessment Summary



Minimizes Total
Energy Use and
Maximizes Use of
Renewable Energy

Minimizes Air
Pollutants and
Greenhouse Gas
Emissions

Minimizes Water Use
and Impacts to Water
Resources

Reduce, Reuse, and
Recycle Materials and
Waste

Protect Land and
Ecosystems

TOTAL

Alternative 1, No Further Action

1

1

4

1

4

11

Alternative 2, Excavation and Off-Site Processing and
Disposal of Contaminated Soils at Licensed Low-Level
RadioActive Waste Facility (Clean Harbors, Deer Trail, CO)

4

4

3

4

3

18

Alternative 3, Excavation and Disposal of Contaminated Soil
at the On-Site Repository

2

2

1

2

1

8

Alternative 4, Capping of Contaminated Soil in Place

3

3

2

3

2

13

USEPA REGION 6

7 of 7	TDD No. 0001/17-044


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APPENDIX O
TDD NO. 0001/17-044


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This page intentionally left blank.


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment # :
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose :TDD initiation

Priority :
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 08/15/2017

Completion Date : 08/15/2018
Effective Date : 08/15/2017

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:





Phone Number:

214-665-7199

(Signature)

(Date)

Fax Number:

Contracting Officer Representative William

Rhotenberry

Branch Mail Code :





Phone Number:

214-665-8372

(Signature)

(Date)

Fax Number:

Contract Specialist: Brian Delaney



Branch Mail Code :





Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Contracting Officer: Brian Delaney



Branch Mail Code :

Electronically Signed by Brian Delaney

08/15/2017

Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)

(Date)

Fax Number:

Description of Work:The initial funding ceiling for this TDD is set at $100,000. This site has
a Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables .

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment # :
Contract#: ep-ss-17-02


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment#: 001
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose :INCREMENTAL funding, extend pop

Priority : HIGH
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 03/28/2016

Completion Date : 12/18/201E
Effective Date : 03/28/2016

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:







Phone Number:

214-665-7199

(Signature)



(Date)

Fax Number:

Contracting Officer Representative

William Rhotenberry

Branch Mail Code :







Phone Number:

214-665-8372

(Signature)



(Date)

Fax Number:

Contract Specialist: Michael

J. Pheeny



Branch Mail Code :







Phone Number:

214-665-2798

(Signature)



(Date)

Fax Number:

Contracting Officer: Michael

J. Pheeny



Branch Mail Code :

Electronically Signed by Michael J. Pheeny

04/05/2018

Phone Number:

214-665-2798

(Signature)



(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)



(Date)

Fax Number:

Description of Work:

Amendment 001 - Extend the TDD POP to 12/18/2018 and increase the funding ceiling by $100,000
(for a new ceiling of $200,000) so that work can continue.

Base ORIG - The initial funding ceiling for this TDD is set at $100,000. This site has a
Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables .

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment#: 001
Contract#: ep-ss-17-02


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment#: 002
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose : extend pop

Priority : HIGH
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 03/28/2018

Completion Date : 08/14/2019
Effective Date : 03/28/2018

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:







Phone Number:

214-665-7199

(Signature)



(Date)

Fax Number:

Contracting Officer Representative

William Rhotenberry

Branch Mail Code :







Phone Number:

214-665-8372

(Signature)



(Date)

Fax Number:

Contract Specialist: Michael

J. Pheeny



Branch Mail Code :







Phone Number:

214-665-2798

(Signature)



(Date)

Fax Number:

Contracting Officer: Michael

J. Pheeny



Branch Mail Code :

Electronically Signed by Michael J. Pheeny

08/13/2018

Phone Number:

214-665-2798

(Signature)



(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)



(Date)

Fax Number:

Description of Work:

Amendment 002 - Extend the TDD POP to 08/14/2019 so that work can continue. No other changes
needed.

Amendment 001 - Extend the TDD POP to 12/18/2018 and increase the funding ceiling by $100,000
(for a new ceiling of $200,000) so that work can continue.

Base ORIG - The initial funding ceiling for this TDD is set at $100,000. This site has a
Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables.

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment#: 002
Contract#: ep-ss-17-02


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment#: 003
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose : change cor

Priority : HIGH
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 03/28/2018

Completion Date : 08/14/2019
Effective Date : 03/28/2018

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:





Phone Number:

214-665-7199

(Signature)

(Date)

Fax Number:

Contracting Officer Representative William

Rhotenberry

Branch Mail Code :





Phone Number:

214-665-8372

(Signature)

(Date)

Fax Number:

Contract Specialist: Brian Delaney



Branch Mail Code :





Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Contracting Officer: Brian Delaney



Branch Mail Code :

Electronically Signed by Brian Delaney

12/14/2018

Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)

(Date)

Fax Number:

Description of Work:

Amendment 003 - Change the primary COR for this TDD to Warren Zehner.

Amendment 002 - Extend the TDD POP to 08/14/2019 so that work can continue. No other changes
needed.

Amendment 001 - Extend the TDD POP to 12/18/2018 and increase the funding ceiling by $100,000
(for a new ceiling of $200,000) so that work can continue.

Base ORIG - The initial funding ceiling for this TDD is set at $100,000. This site has a
Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables.

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment#: 003
Contract#: ep-ss-17-02


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment#: 004
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose : extend pop, incremental funding

Priority : HIGH
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 03/28/2018

Completion Date : 08/14/2019
Effective Date : 03/28/2018

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:





Phone Number:

214-665-7199

(Signature)

(Date)

Fax Number:

Contracting Officer Representative William

Rhotenberry

Branch Mail Code :





Phone Number:

214-665-8372

(Signature)

(Date)

Fax Number:

Contract Specialist: Brian Delaney



Branch Mail Code :





Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Contracting Officer: Brian Delaney



Branch Mail Code :

Electronically Signed by Brian Delaney

04/16/2019

Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)

(Date)

Fax Number:

Description of Work:

Amendment 004 - Extend the TDD POP to 08/14/2020 and increase the funding ceiling by $125,000
(from $200,000 to $325,000) for additional LOE within the existing specific elements of this
TDD. Funding for this amendment is from the Tronox NAUM TR2 account A6PK.

Amendment 003 - Change the primary COR for this TDD to Warren Zehner.

Amendment 002 - Extend the TDD POP to 08/14/2019 so that work can continue. No other changes
needed.

Amendment 001 - Extend the TDD POP to 12/18/2018 and increase the funding ceiling by $100,000
(for a new ceiling of $200,000) so that work can continue.

Base ORIG - The initial funding ceiling for this TDD is set at $100,000. This site has a
Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables.

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment#: 004
Contract#: ep-ss-17-02


-------
EPA

Technical Direction Document

Page 1 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc.

TDD # • 0001/17-044
Amendment#: 005
Contract#: ep-ss-17-02

TDD Title : Tronox NAUM Section 10

Purpose : C0RRECT completion date field

Priority : HIGH
Overtime Authorized : Yes
	Invoice Unit:	

Verbal Date :

Start Date : 03/28/2018

Completion Date : 08/14/2020
Effective Date : 03/28/2018

SSID: 0600

Project/Site Name : Tronox NAUM Section 10
Project Address :

County: McKinley
City:

State : nm
Zip Code :

WorkArea : Response / Removal
Work Area Code :

Activity: Engineering Evaluation / Cost Analysis (EE/CA)
Activity Code : EE
Operable Unit:

Emergency Code :

FPN :

Performance Based : No

Authorized TDD Ceiling :

Amount

LOE (Hours)

Previous Action(s) :
This Action :

$0. 00
$0. 00

O O

o o
o o

New Total :

$0. 00

o
o

o

Specific Elements :

Description of Work :

See Schedule

Region Specific :

CERCLIS: :

Misc 2 :

Accounting and Appropriation Information:

SFO:

Line

Budget / FY

Approp

Budget

Program

Flpmpnt

Object
Class

Site Project

Cost

DCN Line-ID

Funding

TDD Amount


-------
EPA

Technical Direction Document

Page 2 Of 2

U.S. EPA, Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Vendor- WEST0N solutions, inc

Project Officer: Will LaBombard



Branch Mail Code:





Phone Number:

214-665-7199

(Signature)

(Date)

Fax Number:

Contracting Officer Representative William

Rhotenberry

Branch Mail Code :





Phone Number:

214-665-8372

(Signature)

(Date)

Fax Number:

Contract Specialist: Brian Delaney



Branch Mail Code :





Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Contracting Officer: Brian Delaney



Branch Mail Code :

Electronically Signed by Brian Delaney

04/29/2019

Phone Number:

214-665-7473

(Signature)

(Date)

Fax Number:

Other Agency Official

Branch Mail Code :

Phone Number:

(Signature)

(Date)

Fax Number:

Description of Work:

Amendment 005 - Amendment 4 extended the POP to 8/14/2020, but the "Completion Date" field was
not changed from 8/14/2019. This amendment corrects the "Completion Date" field to also reflect
8/14/2020.

Amendment 004 - Extend the TDD POP to 08/14/2020 and increase the funding ceiling by $125,000
(from $200,000 to $325,000) for additional LOE within the existing specific elements of this
TDD. Funding for this amendment is from the Tronox NAUM TR2 account A6PK.

Amendment 003 - Change the primary COR for this TDD to Warren Zehner.

Amendment 002 - Extend the TDD POP to 08/14/2019 so that work can continue. No other changes
needed.

Amendment 001 - Extend the TDD POP to 12/18/2018 and increase the funding ceiling by $100,000
(for a new ceiling of $200,000) so that work can continue.

Base ORIG - The initial funding ceiling for this TDD is set at $100,000. This site has a
Reimbursable Account (TR2, TR2B, etc.) and all TDD costs shall be invoiced against this
SSID-specific TO funding. The contractor shall notify the PO and COR when the TR2B funding is
85% expended. When this special account funding is not available, costs shall be invoiced
against the oldest 6A00E or 6A00S funding on the task order.

The contractor shall use SSID A6PK on all forms, reports, emails, communications, and
deliverables.

The Contractor shall conduct assessments, sampling and
other taskings such as archaeological assessments in
support of an Engineering Evaluation/Cost Assessment
(EE/CA). The EE/CA shall be conducted utilizing
established procedures and protocols from previous
Tronox NAUM sites.

Warren Zehner will be the alternate COR on this TDD.

TDD # ¦ 0001/17-044
Amendment#: 005
Contract#: ep-ss-17-02


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