DRC-2009-006471 - 0901a0688014f6ab

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State of Utah
Department of
Environmental Quality
Richard W. Spron
E.wcuiivf Director
DIVISION OFRADI.^TION
CONTROI.
D.Tne L. Fincrfrnck
Oil fcti/r
JONM HUNTSMAN. JR
< invfnior
tiAKY HERBERT
I.it'inemmi Gcvti-mn-
M E M O R A N D U M
TO: File
THROUGH: Loren Morton ^^^^ IAHO\
FROM:
DATE:
Tom Rushing
December 1,2009
SUBJFXT: Review of September 3, 2009 Semi-Annual Groundwater Stability Monitoring
Report, l^' Half 2009, Rio Algom Mining L.L.C, Lisbon Facility, Received
September 9, 2009, Radioactive Materials License No. UTI900481, Amendment 2
The Utah Division of Radiation Control (DRC) has reviewed the 2009 L' Half Groundwater
Stability Moniioring Report submitted by Rio Algom Mining L.L.C. (Rio) for the Lisbon Facility.
Report Content
The Report is broken into 9 sections. The seciions are organized as lollows:
1- Discussion
2- Analytical Data (Spreadsheets)
3" Time vs. Concentration Plots (Chloride, Sulfate, TDS, Arsenic, Molybdenum, Selenium,
Uranium)
4- Depth to Water Plots over time for the wells
5- Hydrographs for the wells
6- Field Data Sheets
7- Laboratoiy Analytical Reports
8- Groundwater Contour/Concentration Maps
9- Sampling Methodologies
The Repon was reviewed lo determine compliance with the Radioactive Materials License for the
If.S Nonh I'Jid WVsl • I'O Bo.'t 144^50 • .Sjii L.ikf Cilv. I'T WI 14-4X50 • |iliunc (Kl)I i ri U.-aiSll • Hu (f*l)i j 5J3-4097
TDD iXOl) 516-4414 •n»i>'<^f(7.[(f«/(..(,VM
Rio Algom Mining L.L.C.
Memo Regarding the 1 st Half 2009
Groundwater Stability Monitoring Report
Page 2 of 6
facility. No. UT190048L Amendment 2, Condition 53.
Review for Compliance with Condition 53
Finding:
The Report was received on September 9, 2009. Per the License requirement in Condition 53.G.
(Table 4) the first semi-annual report is due by September 1 following the report period. The
report was 8 days late. The report is dated September 3, 2009. Rio Algom representatives did
contact DRC by e-mail on 8/31/09 to request an extension for (he repoil due dare. DRC contacted
Rio Algom back by phone call to inquire how much lime would be needed to complete the report,
Rio staled that the report could be sent to DRC by lhe first week of September. DRC responded
that since the extension request was being issued so late, an extension was not practicable or
reasonable, however, DRC would use enforcement discretion conceming the lateness based on the
quality ofthe repon.
Finding:
One sample event in the period is listed on the data sheets (Samples collected March 24 & 25,
2009.) The sample event per this Report conforms to time periods required by the License.
Finding:
The following tcxl and lables summarize the reported concentrations for the parameters listed in
the License.
Review of data for "poini of compliance" wells EF-3A and OW-UT-9 for the semi-annual
sampling event revealed that none of the reported values exceeded the ACL maximum
concentrauons listed in the License.
Table I - Reported Concentrations Values for the ACL's listed in the License - Point of
Com
Well
No;^^:
EF-3A
OW-
UT-9
Miance (POC
Sample'
Date
3/25/09
3/25/09
:) Wells
Mo
ACL
(mg/L)
23.34
58.43
Measured
(mg/C)
1.4
47.9
Se
ACL
(mg/L)
0.93
0.10
Se 'f4,_ >^'
Measured i
(mg/t)'.
0.035
0.032
•As'".-
ACL -
(mg/L)
3.06
2.63
As
Measured :
(mgA.) •"
0.079
2.34
U '^ \
AGL:>
96.87
101.58
:U:,;..;
Measured
(mg/L) •:
23.3
82.5
Review of data for "point of exposure" wells RL-4, RL-5, and RL-6 ft)r (he semi-annual sampling
event revealed that the reported concentrations for Uranium are below lhe uranium compliance
limits listed in Condition 53.B. of the License.
Rio Algom Mining L.L.C.
Memo Regarding the 1st Half 2009
Groundwater Stability Monitoring Report
Page 3 of 6
Table 2
License -
~ Reported Concentrations for Uranium Compared wilh
Point of Exposure (POE) Wells
Well No.
RL-4
RL-5
RL-6
Sample Date
3/24/09
3/24/09
3/24/09
Compliance Limits in the
-License Uranium-
Compiiance'Limit
(mp^)-... "v.
0.32
0.32
0.32
UraniurfiMeasured ' :
(mgA.)- ~i "•;;: • :../^
0.0044
0.0025
0.0189
Review of data for trend wells EF-6, EF-8, ML-1, RL-l, RL-3 and H-63 revealed that reported
concentrations for Uranium are below the uranium compliance limits listed in Condition 53.B. of
the License.
Table 3 - Reported Concentrations for Uranium Compared with Uranium Target Action Levels -
Trend Wells
WellNo. ..:;:
EF-6
EF-8
ML-I
RL-1
RL-3
H-63
LW-1
; Sample Date .>
3/25/09
3/25/09
3/25/09
3/25/09
3/25/09
3/24/09
3/24/09
Licerise;yranium
Target Action Level
(m,^/L) ,
3.9
0.30
0.26
42.1
37.3
0.06
Proposed Target
Action Level (0.03
mg/L) on Dec. 4,
2008.
Uranium (rrig/L)" "
-- •'.' J
0.702
0.105
0.0142
41.4
17.4
0.0105
0.0019
O.VQC Review
Finding:
QA/QC reporting requirements are found in Seclion 53.G. of the License as a series of footnotes
to Table 4. Reporting requirements include the following items: I. Sampling Methodology, 2.
Field Parameter Measurements, 3. Laboralory Infonnarion, 4. Daiii Evaluation, 5. Copies of Field
Measurements, 6. Laboralory AnalNtical Reports, and 7. Chain-of-cuslody Documentarion.
Rio Algom Mining L.L.C.
Memo Regarding lhe I st Half 2009
Groundwater Slability Monitoring Report
Page 4 of 6
Per DRC review all of the above required items were included with the Report. It was noted that
Rio does not provide a separate secrion detailing their own validarion of sampling methodologies
and sample results, however, this type of evaluarion is not cleariy required by the License.
Al! laboratory data and Q.VQC was included with the Report. This includes verification of chain-
of-custody protocol, it was noted, however that the samples were received by the laboratory
without seals on the sample bottles or ice chests. DRC did note an improvement regarding sample
riming and the avoidance of error flags from the laboratory. DRC noted that re-analysis was
requested for arsenic on several of the samples, and that Rio pertbmied a split sample with a
separate Laboratory (ACZ). These activities show atteniion to potential QA/QC discrepancies on
the part of Rio Algom. No error flags were present on the data sheets for the semi-annual event.
Primary sampie analysis was conducted by Energy Laboratories. Energy Labs holds a current UT
certification. No. WY00002.
Sampling methodology fonns stale that Rio has changed their field methodology. This has also
been noted in several past Ground Water Reports. The previous methodology was per lhe Rio
Algom Mining L.L.C. Health Physics and Environmental Procedures Manual. The new method is
the ASTM Designation D 6771-02 "Siandard Practice for Low-Flow Purging and Sampling for
Wells and Devices Used for Groundwater Quality Invesrigarions." A copy of the currently used
ASTM methodology was included as an appendix to the Report.
The field sampling methods have been evaluated by DRCduring split sampling events. 2008 and
2009. DRC has several concems regarding the current low flow purging protocols which have
been provided to the facility. The field collection protocols are a current item of discussion
between DRC and Rio Algom.
Background Concentration Wells Review
Table 4 - Reported Concentrations for Background Wells Compared with Established Background
Well-Nol
MW-13
MW-5
Sample
Date "•--
3/24/09
3/24/09
U-Nat
Eslablished •
Background
(mg/L)
0.02
0.01
U^Nai".-.
Measured
(mg/L) •
0.0154
0.0070
As ,•_ .' \' •
•Established
Background
(mg/L)
0.066
0.05
Measu reii'
(mga.) •
0.028
<0.00l
Mo: ,
•Established
Background
(mg/L).
0.05
0.07
Mo
Measured
(mgA.)
<0.1
<0.l
.Se-..'. •-.
Fstablished
Background
(mgO,) 0-
0.01
0.01
.Sc V' .^^
Measured "'
(mg/L
0.008
0.069
The reported ct>ncentration values of Se at background well MW5 continues to be elevated above
the background concentration, 0.01 mg/l per the current moniioring dala. The measured
concentration has consistenriy averaged around 0.06/0.07 mg/L since the beginning of ground
water quality data collection at the well. On this report the reported value for Se was 0.069 mg/l
for the March 24. 2009 sampling event. The Report does not include an explanation of the
elevated conccnlralions or propose any changes lo background selenium concentrations even
Rio Algom Mining L.L.C.
Memo Regarding (he lst Hair2009
Groundwater Stabilily Monitoring Report
Page 5 of 6
though this has been a long term trend. However, the License does not require explanarion or
additional actions if established background is exceeded.
Time vs. Concentration Plots
Per DRC review ofthe plots, no significant trends were noted thai are not in conformance with the
ACL modeling. It was noted that ail plots were submitted and follow the scaling format requested
by DRC per pas! report reviews.
DRC also conducts reviews of the data specifically with relation to the ACL model and expected
concenlrations with time. A summary of the findings regarding this review is included in the "U
Concentrations Comparison with the ACL Model" section below.
Groundwater Concentration Contour Maps
Per DRC review of the submitted contour maps it appears that the coniour lines drawn for U, Se,
As and Mo confoim to Lhe most recent data and are drawn to a reasonable scale. DRC also
reviewed the revised groundwater elevalion map and il appears to be adequately updated,
U Concentration Comparisons with .\CL Plume Proiections
CujTent concentrations at the POC, POE, and Trend wells were compared with the projected ACL
concentrations to determine if any premature elevarion of U concentrations could be determined in
the data. Projecrion charts from the "October 13, 2003 Report prepared by Koinex" was used as
the infonnation source; the documenl includes several time series diagrams of dissolved uranium
concentration within a projected plume shape. "'
An important aspect lo consider in this type of evaluation is that prior to the ACL acceptance,
from the year 1990 until 2000, the Lisbon site was actively engaged in an NRC approved
"Conective Action Plan (CAP)" which included groundwater withdrawal wiihin the plume and
discharge to two evaporalion ponds. This had the effect of creating 2 cones of depression; one
around the cunent EF-3A POC well, which was engaged as a pumping well, and one around the
OW-UT 9 well which was also engaged as a pumping well. Afler pumping ceased, a downward
U concentration trend is apparent at the EF-3.'\ well which is assumed to be related to the rebound
of water level within the well. The U concentrations in this well have shown decreases of approx.
55 mg/L concurrent with a rise of "depth lo water'' in lhe well of approx. 50 ft. The U
concentrations at well OW-UT-9 are highly sporadic between sample periods; this could be
attributed to aquifer properties of rhe pumping zone rebound and re-stabilization.
The October 13. 2003 Komex predicted plume diagrams depict the plume extending in two
defined amis, traveling northwest on either side of a flow divide (effect of lower hydraulic
conductivity zones as determined through inodel calibration simulations).
The southernmost arm (heading southeast then northwest) moves parallel to a no tlow boundary
zone created by the Lisbon Fault (aqiiiclude created by upthrown seclion ofthe Chinle fonnation).
POE well RL-6 is located down grudient along the fault line as a warning system for elevated
dissolved uranium concentrations from this arm. According lo the time series plots, it is not
expected that the plume will extend lo ihis well until the year 3000, and it is not projected that
Rio Algom Mining L.L.C.
Memo Regarding (he 1st Half 2009
Groundwater Stability Monitoring Report
Page 6 of 6
dissolved uranium coneenirations in this well will exceed 1 mg/L. at any time. It is predicted by
the modeled breakthrough curve (Komex) that the State Groundwater Quality Siandard for
Uranium of .030 microorams/L will be exceeded at POE well RL-6 in approximately the year
2600.
The northem arm of the plume (also heading northwest) is moving in the groundwater gradient
direcrion on the north side of the flow divide. POE wells RL-4 and RL-5 have been installed as
warning systems of plume migration from this arm. It is predicted by (he model that dissolved
uranium concentrations from lhe plume will not reach RL-5 al all (will remain at background) and
will not reach RL-4 until the year 2050, barely grazing lhe well then retreating. Dissolved
uranium concennalions at well RL-4 are not expected to exceed I mg/L at any time. It is
predicted by the Komex model that the State Groundwater Quality Standard for Uranium of 0.030
microgram.s/L will be exceeded at POE well RL-4 in approximately the year 2200.
All three POE wells appear to show slight rising trends for uranium. Well RL6 is showing a
current uranium concentralion of approximately 0.02 mg/L. Well RL-4 is showing a current
concentration of approxmiateiy 0.004 mg/L and Well RL-5 is showing a cuirent concentration of
approximately 0.003 mg/L. In general, the POE wells have begun showing more erratic
concentrations since they were initially sampled in year 2003.
Reported concentration values seem lo he conforming to the model so far, however, it is hard to
really determine if upward trends are oecujring at the POE wells without more data. Data from
trend wells indicates that concentrations are remaining fairly stable with lhe exception of wells
located within the POC EF3A cone of depression which are varying probably due to groundwater
elevarion rebound.
Conclusion
The 2009 P' Half, Rio Algom Groundwater Slability Monitoring Report appears to be in
compliance with License condition 53.
A Close-Out Letter will be sent to Rio for this report. The close-out letter will make reference to
the previous 2"^ Semi 2008 report which listed issues and deficiencies regarding rield sample
collection techniques.
References
Rio Algom Mining LLC, Groundwater Stabilitv Monitoring Report - T' Half 2009, September 3,
2009
Utah Radioactive Materials License No. UT19004SI, Amendment 2
Application tor Altemate Concentration Limiis Source Material License SUA-119. Lewis Water
Consultants Inc. March 1, 2001
Response to Request lor Addirional Information. Application for Alternate Conceniration Limiis
Source Materials License SUA-1 119, Komex, Oclober 13, 2003
Utah Division of Radiation Control Inspection Form
Ground Water Module 30 (Semi-Annual Ground Water Monitoring Report)
Rio Algom Mining Company
Lisbon Valley, Utah
Regulalory Requirements Inspi^cted Against: Radioactive Materials License # UT 190048 LCondilion 53
License-in-Force (date): March 6, 2006 (mtijor modification number 2)
Applicable License Conditions: Condilion 53 Ground Water Compliance Monitoring
Lasl Previous Inspeclion Date: July 13. 2009
Dale(s) uf Current Inspection: November 4. 2009
Violations Recommended: QJ Yes ^ No
Notes;
INSPECTION ITEM - Ground Water Moniioring Reporting (Module 30):
(check all thai were included as part of this inspection)
Reporting Year: 2008
^ A) Ground Water Monitoring Report (First Semi-Annual)
• B) Ground Water Monitoring Report (Second Semi-.Annual)
Ground Watef-Mohitliiile"R^luirements^'/t"i.? '"--•:• ^ -;--'=;3:^ -';'"^. ^"iftl.^^^-K^••#^liJ5f
1. Were the following wells monilored:
A. Background Samples - wells MW5 and MW 137
^ Yes n No
B. Trend Samples - wells EF-6. RL-1. RL-3, EF-8, ML-1, H-63. and LW-1 ?
^ Yes D No
C. Point of Compliance (POC) samples - wells EF3A. OW-LfT-9?
^ Yes D No
D. Point of Exposure (POE) samples - wells RL-4, RL-5, and RL-6 .^
13 Yes D No
Notes:
2. Well or Boring Installation Notification (Condition 53.H) ~ Were any borings or monitoring wells
reptjrted to have been installed in anv yreas of potential groundwater impact, by either Rio Algom or any company
holding private mineral rights?
D Yes IE No
A. If yes, wa.s the Executive Secreiary notified a minimum of 30 days prior to installation?
|~| Yes n No *see comment.'i
B. Does it appear thai proper drilling techniques were employed?
[~| Yes n No *see comments
Notes: *There are ongoing drilling issues within and direclly sunounding the LTSM boundary. DRC has
coordinated with the Utah Division of Oil, Gas and Mining and the Bureau of Land Management regarding
concems of cro^s conlamination from the shallow aquifer to the deeper aquifers. Through DRC communication.
Rio Algom LLC is now being contacted by DOOM directly for input if any drilling is propo.sed in or near lhe
LTSM. A proposed iuigation project utilizing a waler right directly ea.st of the facility is also proposed, BLM will
require EA conditions regarding potential ground water withdrawals.
Ground VVater Analysis Requirements
Laboralory Requirements
3. Were all .samples analyzed by a Utah Certified Laboratory?
Rio /\l|ioii-i Mining Cnmpanv
Module 30 !nspectioi-i Fonn Pape 2 ul5 Form Updated 1/22/2009
^ Yes D No
Luh Name: Energy Laboratories
Certit"icatc No.-. Cen No. WY00002. Utah Track 3072350515 Valid ihrough: June 30. 2010
Notes: Energy Laboratories is reviewed tor compliance annually hy rhe Utah BLI
4. Did method.'; used to analyze ground waler samples comply with the following:
A) Methods cited in UAC R317-6-6.3.L: and
B) Have detecrioii limits which are less than or equal to the License Condiuon 53. Tables
I through 3.
El Yes n No
Notes:
5. Were the following laborator\' parameters measured for each sample?
ParametefiTi^^^^^r^ S>J-2"„''"=: • ."r-'-'^ft.
Uranium
Molvbdenum
Selenium
Arsenic
pH
TDS
Chloride
Sulfate
Bicarbonate
Water level elevations
Y/N - Comn\ents. ": -.= V" s >^-c ^r. •' • z M~^^i~±
Y - Method E20O.8
V - Meihod £200.8
Y - Method E200.8
Y - Meihod E200.8
Y
Y - Method A2540 C
Y-Method E300.0
Y - Method E300.0
Y Method A2320 B
Y - Per ASTM Field Methods
Yes QNo
Notes:
Reporting Refluirements-XGon(liUon*=53£G^'Tables 4-6) : A\- "".'/^-i/cV--•-• :%^m
6. Report SubmilUil Date- Were semi-annual monitoring report(s,l submitted on or before the following
deadlines:
First Semi-Annual Report - September 1
Second Semi-Annual Report ~ March 1
n Yes ^ No
n Yes • No
Noles; The report was dated September 3, 2009 and received on .September 9, 2009, DRC will not follow
through with enforcement activities unless additional enforcement priorities are in place, even then there would be
enfoicenieni discretion regarding the violation.
Ground Water MoniUiritis Reportins Conient Requirements (Condition 53.G)
7. Does (he monitoring report include the following criteria?:
.A. Sampling Methodology
Description of sampling equipment, purging volume, technique,etc.
IE Yes DNo