DRC-2009-003804 - 0901a06880137eb5

State of Utah
GARY R. HERBERT
Governor
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Department of
Environmental Quality
Amanda Smith
Acting Executive Director
DFVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
August 26, 2009
CERTIFIED MAIL
(Return Receipt Requested)
Chuck Wentz, Environmental Department Supervisor/RSO
Rio Algom Mining L.L.C.
P.O. Box 218
Grants, NM 87020
Dear Mr. Wentz:
Subject: Rio Algom Mining L.L.C. February 25, 2009 Lisbon Operation, 2"'' Half 2008
Groundwater Stability Monitoring Report, Received by DRC March 2, 2009,
Radioactive Materials License No. 1900481: DRC Request for Information
DRC has initially reviewed the document titled, "Rio Algom Mining LLC, License UT 1900481,
Semi Annual Groundwater Stability Monitoring Report - 2"'* Half 2008, February 25, 2009." The
document was received by DRC on March 2, 2009 to comply with requirement 53 ofthe Utah
Division of Radiation Control Radioactive Materials License, UT1900481, Condition 53 (Ground
Water Compliance Monitoring Program.)
DRC has concems regarding ground water collection techniques observed during the August 5,
2008 and August 11, 2009 split sample events as well as ongoing concems regarding quality
assurance flags associated with reported data. Both of these issues are discussed in the sections
below. DRC is requesting additional information to complete the review as follows:
Field Sample Method Request for Information
Two Field Sampling Events are summarized below:
August 5. 2008
On August 5, 2008 Tom Rushing (DRC) and Chariie Bishop (DRC) met with Don Sweeney
(RSO, Rio Algom Mning LLC) and Gail Alexander (Rio Algom) to conduct split sampling at the
168 North 1950 West • Salt Lake City. UT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Rio Algom 2"^* Semi Annual Ground Water Stability Report
DRC Request for Additional Information
Page 2
Rio Algom facility in the Lisbon Valley near LaSalle, UT. Per discussions with Rio Algom
During the field review, DRC had the following concems.
Field Calibration:
Per onsite conversation with Gail Alexander (Rio Algom) daily field calibrations are not
conducted. It was stated that calibration is conducted in the New Mexico office only with no
additional calibration (or maintenance, e.g. membrane replacement) during the sampling mn. It
was also stated that no calibration standard solutions are kept in the field, and there is no way to
check the validity of the office calibration.
Field Chemistry Readings:
The field chemistry readings were conducted during active well pumping. DRC noted that the
flow through cell, into which the probes were inserted, was not maintaining water sample over the
probe tips (membranes) when the field readings were taken. DRC noted that the Dissolved
Oxygen reading was fluctuating greatly and was not allowed to stabilize prior to the recording of a
reading. The onsite Rio Algom representative stated that the method used was per training given
to her by "Komex."
DRC expressed concems about the flow cell during the split sample inspection and
"recommended" that a valve be installed to prevent drainage of the sample water from the flow
cell during sample readings to insure that the readings were stabilized.
Field Decontamination Procedures:
The field procedure for decontamination of the sample tubing and bladder pump and housing
between well sites was to pump three different solutions from 5 gallon buckets through the pump
and tubing. The first solution used was a soap mixture. DRC could not obtain the manufacturer
or type of soap being used (not available onsite), the second solution was tap water from Moab
which was used as an initial rinse of the soap, the final rinse was with deionized water to clean
any residues from the tube and remove any remaining soap.
Per DRC field observations, it did not appear that the soap was completely rinsed from inside the
hose after completion of the DI rinse. Rio Algom representatives did measure one complete rinse
of the hose, utilizing an induced air bubble in the hose as a reference mark for both the tap water
and deionized water. It was noted however that a soapy residue was still present in the hose and
that additional rinsing was likely warranted. The onsite representatives stated that the rinse
methodology was per training they received from "Komex."
August 11.2009
On August 11, 2009, Tom Rushing (DRC) met with Chuck Wentz (Rio Algom, RSO), Gail
Alexander (Rio Algom) and Barbara Gallegos (Rio Algom) to conduct split sampling at the Rio
Algom facility in the Lisbon Valley near LaSalle, UT. DRC acknowledges that Rio Algom was
Rio Algom 2"'' Semi Annual Ground Water Stability Report
DRC Request for Additional Information
Page 3
not formally informed of the field collection concems noted during the August 5, 2008 (listed
above) prior to the 2009 split sampling. It was therefore noted during the 2009 split sample event
that the same issues were still occurring regarding; 1. Lack of onsite field calibration of samples,
2. Flow cell issues regarding lack of continuous sample on probes and the inability to obtain tme
field stabilization readings and, 3. Field decontamination techniques.
Low Flow Purging
This is the first time that DRC has observed the Rio Algom Low Flow Sampling Technique.
DRC reviewed the ASTM method which was included with the 2°'* Semi Annual Report. The
ASTM method is specifically ASTM D 6771-02 "Low-Flow Purging and Sampling for Wells and
Devices Used for Ground-Water Quality Investigations". DRC noted that there was apparently no
communication from Rio Algom regarding the change in purging methods before it was
implemented. DRC does have a significant concem regarding whether samples collected at the
Lisbon site by low flow sampling protocols are representative of the formation ground water and
is requesting the following additional information:
Copies of field tests used to determine appropriate pump rates and purge
volumes for each compliance well where low flow sampling has been
implemented.
Justification that the water sampled during the low flow technique was
representative of the formation water. According to the ASTM method there is
a strong reliance on compatible well construction to achieve representative
samples by low flow techniques. DRC is concemed that there is not adequate
evidence included with the Ground Water Stability Report to show that the
sampled water is being delivered from the formation via the upper portions of
the well screen and not from stagnant water within the casing or the
surrounding filter pack. Per the comments in the Field Chemistry Readings
above it was noted that DRC did not see field reading stabilization, and that per
DRC observation it would have been impossible to obtain stabilized field
readings since the flow cell was intermittently drained of all water during the
pumping period. According to the ASTM method, the stabilized field readings
are the primary avenue to show that the collected water is formation water and
not stagnant water from the well screen and well pack.
Please provide any additional information in this section within 30 calendar days of receipt of this
letter. Additionally, DRC will prepare a "draft" License modification, including prescriptive
requirements for Quality Assurance Protocols during well purging, sample collection and analysis
for Rio Algom's review.
Laboratory Quality Assurance Request for Information
DRC noted the following laboratory QA problems during the review ofthe Febmary 28, 2009
report:
Rio Algom 2" Semi Annual Ground Water Stability Report
DRC Request for Additional Information
Page 4
QA Problem
Custody Seals were not
present on coolers
(containers or samples)
Holding Times (7 day) were
exceeded for TDS analysis
(or submitted without time
for the laboratory to conduct
analysis within holding
time) for 9 samples
Relevant Samples
EF-3A, OW-UT-9, RL-
4,RL-5,RL-6,EF-6,
EF-8,ML-1,RL-1,RL-
3, H-63, LW-1
EF-3A, OW-UT-9, RL-
4, RL-5, RL-6, EF-6,
EF-8,ML-1,RL-1,RL-
3, H-63, LW-1
Sample Collection
Dates
10/14/08-10/16/08
10/14/08 - 10/16/08
Sample
Received Date
10/23/08
10/23/08
As you may recall, these same problems were noted during the 2008 1^' Semi Annual report
review and a DRC letter was submitted to Rio Algom (c/o Don Sweeney), dated Febmary 17,
2009, with the advisory that although the problems are not a direct violation ofthe License, they
do need to be resolved as soon as possible. DRC realizes that the Febmary 17, 2009 letter was
submitted to Rio Algom after the sample collection for the 2"^ Semi Annual Report.
As stated above, DRC will prepare a "draft" License modification regarding Quality Assurance
Protocols during well purging, sample collection and analysis. Rio Algom will be given the
opportunity to review that "draft" License.
Additionally DRC is requesting additional information regarding actions which have or will be
implemented to avoid these problems in the future. Please submit response within 30 calendar
days of your receipt of this letter.
If you have questions or concems, please contact Tom Rushing at [phone]. Thank you.
Sincerely,
UTAH WATER QUALITY BOARD
Dane L. Finerfrock, Co-Executive Secretary
DLF:TR:tr
F:\Rio Algom - LisbonXGroundwater Monitoring 2nd 2008\Rio2nd2008GWStabilityCloseOut and Advisory.doc