DRC-2010-002829 - 0901a06880184b82

State of Utah \
Department of
Environmental Quality
Amunda Sinilh
y.xemtive Director
DIV ISION OF RADIATION
CONTROL
Dane L. rinerfrock
Direitur
GARY R. )itkBhRr.
Governor
GREG BT^I,[
Lieutenant Governor
MEMORANDUM
TO: File
THROUGH: Loren Morton, PG, Manager
FROM: Tom Rushing, PG ^'lo- id
DATE: April 19, 2010
SUBJECT: Review of the February 25, 2010 Semi-Annual Groundwater Stability Monitoring
Report, 2"^* Half 2009, Rio Algom Mining L.L.C., Lisbon Facility, Received March
L 2010, Radioactive Materials License No. UT1900481, Amendment 3
The Utah Division of Radiation Control (DRC) has reviewed the 2009 2"? Half Groundwater
Stability Monitoring Report submitted by Rio Algom Mining L.L.C. (Rio) for the Lisbon Facility.
This memorandum also includes review of the results from the August II, 2009 split sampling
done by DRC staff as well as the Rio Algom November 4, 2009 Letter in response to a DRC RFI
dated Augusi 26, 2009 Regarding QA/QC Problems noted during the 2008 and 2009 DRC/Rio
Algom split sample events. .
Report Content
The Report is broken into 9 sections. The sections are organized as follows:
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
IftK North 1*)50 Wcsl • PO Do\ 144850 • Salt Like City. I'T S4114-4850 • plionc (8011 536-4250 • fax [phone]W7
T.D.D. [phone] • WA^-.-.deq Utah ^ov
Rio Algom Mining L.L.C.
Memo Regarding the 2"'' Half 2009
Groundwater Stability Monitoring Repon
Paee 2 of 10
6- Field Data Sheets
7- Laboratory Analytical Reports
8- Groundwater Contoiu'/Concentration Maps
9- Sampling Methodologies (Low Flow Sampling Information)
The Report was reviewed (o determine compliance with the Radioactive Materials License for the
facility. No. UT 1900481, Amendment 3, Condition 53.
Review For Compliance with Condition 53
Finding:
The Report was received on March 1, 2010. Per the License requirement in Condition 53.G.
(Table 4) the first semi-annual report is due by March 1 following the repoil period; therefore the
report was submitted on time
Finding:
One sample event in the period is listed on the data sheets (Samples collected August, 2009).
License requirement 53.G. The sample event per this Report conforms to time peiiods required by
the License (Semi Annual).
Finding:
The following text and tables summarize the reported concentrations for the parameters lisled in
the License.
Review of data for "point of compliance" wells EF-3A and OW-UT-9 for the quarterly sampling
events revealed that none of the reported values exceeded the ACL maximum concentrations
lisled in the License.
Table 1 - Reported Concentrations Values for the ACL's listed in the License - Point of
Compliance (POC) Wells
AVelfe Sarnple. .
Date
Mo-fl.^^^.
ACL
(mg/L)
Measiifed •-..
i(mg4)--;
'XCL
(mg/L)
Measured •
ifn^A^.'
^As=^.-. ^A(rf?:^\.
-fmg/L),
,AS
Measured-
:(mg/L):
AotA
:(mg/L)1
'Measured'
:(mi/L)" .
EF-3A 8/12/09 23.34 1.6 0.93 0.021 3.06 0.088 96.87 22.9
OW-
UT-9
8/13/09 58.43 49.1 0.10 .024 2.63 2.20 101.58 85.4
Review of data for "poim of exposure" wells RL-4, RL-5, and RL-6 for the quarteriy sampling
events revealed that the reported concentrations for Uranium are below the uranium compliance
limits listed in Condition 53.B. of the License.
Rio Algom Mining L.L.C.
Memo Regarding the 2"^ Half 2009
Groundwater Stability Monitoring Report
Page 3 of 10
Table 2 - Reported Concentrations for Uranium Compared with Compliance Limits in the
;We!l;Np^f^^';,;;^-:Sa'mpie'P'ate :uA'\^ ^License':Urariium-i> -
fCo'rripli ance: Limi I Jft^
^omg/i3t#^ ^-^siirz
. Ui'ani unrMeasured ' '••
{mg/]2AA^^7'^AA -i."-'^;
RL-4 8/12/09 0.32 ' 0.0119
RL-5 8/11/09 0.32 0.0044
RL-6 8/11/09 0.32 0.0003
Review of data for trend wells EF-6, EF-8, ML-1, RL-1, RL-3 and H-63 revealed that none of the
laboratory results for Uranium exceed the License Uranium Target Action Levels for the wells
listed in the License.
Table 3 — Reported Concentrations for Uranium Compared with Uranium Target Action |Levels -
Trend Wells
'M^jl:Nop^^:H.c^' 1 '^^Sampte'^Datei;. . A^/.A : tLicehse^Urahi um „. r^: j
vTarget Action;!^
:(n^^:fo-^'^£:
.;Urahiiim -(rhg^)"495l, .'•'
EF-6 8/12/09 3.9 0.688
EF-8 8/12/09 0.30 0.122
ML-I 8/12/09 0.26 0.0145
RL-1 8/13/09 42.1 42.1
RL-3 8/11/09 37.3 22.5
H-63 8/12/09 0.06 0.0106
LW-1 8/11/09 0.028 0.0023
OA/OC Review
Finding:
QA/QC reporting requirements are found in Section 53.G. of the License as a series of footnotes
to Table 4. Reporting requirements include the following items: 1. Sampling Methodology, 2.
Field Parameter Measurements, 3. Laboratory Information, 4. Data Evaluation, 5. Copies of Field
Measurements. 6. Laboratory Analytical Reports, and 7. Chain-of-cuslody Documentation.
Per DRC review all of the above required items were included with the Report. Tt was noted lhat
Rio does not provide a separate section detailing their own validation of sampling methodologies
and sample results, however, this type of evaluation is not cleariy required by the License at the
time of this review.
Rio Algom Mining L.L.C.
Memo Regarding the 2"^ Half 2009
Groundwater Stability Monitoring Report
Paee4of 10
All laboratory data and QA/QC was included with the Repoil. This includes verification of chain-
of-custody protocol, it was noted that the samples were originally recorded by the laboratory as
not having valid seals on either the coolers or the individual containers, however, an amended
chain of custody record was included which indicated that seals were present on the coolers. DRC
noted that 5 TDS samples were analyzed by the laboratory beyond sample holding time (EPA
Recommended, 3 days).
Table 4- Energy Laboratories TDS Holding Time Discrepancies
QA Violation (Energy
Labs)
Relevant Samples Samples
Collection Dates
Sample
sReceived
Dale
Samples
Analyzed
Date
Holding Times were
exceeded for TDS
analysis (or submitted
without time for the
laboratory to conduct
analysis within holding
time) for 5 samples
LW-1, MW-5,
RL-3. RL-5, RL-6 8/11/09-8/13/09 8/17/09 8/19/2009
This is the third advisory by DRC of this problem. The current License requiremenls do not
provide for specific QA/QC protocols. Rio Algom has been advised, via RFI letter, that the
License will be modified to include requirements for the development, and Executive Secretary
Approval, of a Facility Quality Assurance Plan regarding field collection and laboratory handling
procedures. The license will additionally be modified to require an in-house review by Rio
Algom of the field and laboratory QA/QC.
Sampling analysis was conducted by Energy Laboratories. Energy Labs holds a current UT
certification. No. WY00002 which is valid through June 30, 2010.
Sampling methodology forms state that Rio has changed their field methodology. This was also
noted in the 2"*^ Semi 2007 and 1'' Semi 2008, 2"^^ Semi 2008 and 1'* Semi 2009 Ground Water
Reports. The previous methodology was per the Rio Algom Mining L.L.C. Health Physics and
Environmental Procedures Manual (Based on well casing purge volumes). The new method is the
ASTM Designation D 6771-02 "Standard Practice for Low-Flow Purging and Sampling for Wells
and Devices Used for Groundw ater Quality Investigations."
The field sampling method was reviewed by DRC staff on August 5, 2008 during the second semi
annual monitoring 2008 split sampling event and August 11, 2009 during the 2009 split sampling
event with Rio Algom. An August 20, 2008 DRC memo was created to discuss issues with the
field methodology cuirently used by Rio Algom, this memo is included as appendix 4 of this
memo (Ihe response memo is included as appendix 5). Several deficiencies are noted on that
memo that relate to EPA ground water sampling guidance and standardized professional practices.
A January 7, 2009 response memo was additionally generated by DRC management outlining the
Rio Algom Mining L.L.C.
Memo Regarding the 2'"^ Half 2009 ^
Groundwater Stability Monitoring Report
Page 5 of 10
r
priority of pursuing formal enforcement regarding the violations. Given lhat the Rio "Algom
facility does not have a State Ground Water Quality Permit and is cunently in the process of
License transference to the U.S. Department of Energy, which is expected to occur within 12
months, formal enforcement of the ground water monitoring quality assurance issues have been
given a low priority. However, based on the faci that it has now been more than 1 year since the
January 7, 2009 DRC Memo, and Rio Algom has yel to submit a closure report and complete title
transfer, it is appropriate lhat the DRC pursue a License Amendment to secure a ground water
QAP. Therefore, License Amendment #4 is currently in process to include requirements for Rio
Algom lo create and comply with a Quality Assurance Plan for field collection and sample
analysis of ground water samples.
Ground Water Hydraulic Evaluation
DRC reviewed the data plots for Depth to Water in Each Well (Appendix 3 of the Report) and the
Hydrograph Plots for each well (Appendix 4 of the Report) to evaluate irends in the historical
groundwater mound and effects of rebound from historical pumping of the mound. ,
Hydrograph Evaluation of Historic Pumping Wells EF-SA and OW-UT-9:
The current compliance wells and historic pumping wells, EF-3A and OW-UT-9 show similar
trends in their hydrograph plots. Both hydrographs show the water table lowering due to .pumping
in the mid I990's and ihen a slow rebound due to groundwater redistribution. Groundwater at
well OW-UT-9 is currently fairiy stabilized at approximately 6580 ft and may be showing a slow
decreasing trend, although there are not currently enough plots to show this definitively.
Groundwater at well EF-3A appears to be stabilizing at an elevation of about 6480 feet. 'This is a
difference of approximately 100 feet of elevation at the two compliance wells, however,'it should
be noted that the two wells lie on opposite sides of a no tlow boundary due stratigraphy
differences followin the plunging anticline. The no-flow boimdary was delineated by Komex for
the ACL modeling, therefore, it is noted that the monitoring wells and trend wells were put in
place with an understanding of both, this central no flow boundary in the middle of the site as well
as the western no flow boundary due (o Ihe Lisbon fault.
Hydrograph Evaluation of Trend Wells and Background Wells:
It was noted that for the most part, the water elevation data in the trend wells and background
wells is fairly steady, showing minor fluctuations due to seasonal precipitation, with the exception
of wells located closer to the groundwater mound. In the case of the two upgradient wells, MW-
13 and H-63, DRC noted a slight downward trend, though noting that the elevation has remained
within 10 feet at both of these wells. A sy.stematic mound fluctuation at trend well EF-8 and
compliance well EF-3A was noted (decreasing trend and then increasing groundwater level due
probably to ground water rebound).
Rio .Algom Mining L.L.C.
Memo Regarding the 2"^ Half 2009
Groundwater Stability Monitoring Report
Page 6 of 10
Hydraulic Conclusions:
The groundwater elevation plots near the pumping wells show decreasing elevation due to
pumping, followed by an upward trend due to redistribution from radial flow. Wells on the
margins of the mound show slight decreasing trend due to this pumping cone redistribution.
Groundwater elevations seem to be consistent with the no flow boundaries delineated by Komex
in the ACL modeling documents.
Background Concentration Wells Review
Table 4 - Reported Concentrations for Background Wells Compared with Established Background
' WefllNd.: ^Sample
"fbate?!
\U-Niii •
Eslabli.shed
. Background
•{nig/D ••
Measured =
':(mg/L)^,V5
;;As- fef'''
~ Established
Background
•(mg/^J_,
Measured,, J^stqblished;.
" Backgi ou ind
-Measured;
Se • -
Established
.^Background
Ymg/L)-v'-''
rMeisured=f
MW-13 8/12/00 0.02 0.0116 0.066 0.027 0.05 <0.1 0.01 0.007
NW-5 8/I1/U9 0.01 0.0073 0.05 <0.001 0.07 <0.1 0.01 0.059
The reported concentration values of Se at background well MW5 continue to be elevated above
the background concentration, 0.01 mg/l per the quarterly monitoring data. The measured
concentration has consistently 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 0.059 mg/l
for the August 11, 2009 sampling event. The Report does not include an explanation of the
elevated concentrations or propose any changes to background selenium concentrations other than
making note of the exceedences and noting lhat ihe Class 111 Utah water quality standards are not
exceeded. Effective with the February 25, 2010 Report there have now been 14 consecutive
sampling events where selenium levels in well MW-5 have exceeded the background
concentrations. However, the License does not require explanation or additional actions if
established background is exceeded.
DRC noted thai the reporting limits for Molybdenum in both background wells (reported as <0.l)
is not appropriate since the reporting limit is above the established background concentration.
This will affect continuing establishment of background since it will include additional non
detectable concentrations in the data set which would be en'oneous and bias the data set. Rio
Algom will be advised of the discrepancy in an RFI letter, additionally, future License
modification will provide for enforcement of continuing discrepancies by addition of the new
License condition.
Time vs. Concentration Plots
Per DRC review of the plots, no significant trends were noted that are not in conformance with the
ACL modeling. DRC also conducts reviews of the data specifically with relation to the ACL
Rio Algom Mining L.L.C.
Memo Regarding the 2""^ Half 2009
Groundwater Stability Monitoring Report ,
Page 7 of 10 ;
model and expected concentrations with time. A summary of the findings regarding this review Is
included in the "U Concentrations Comparison with the ACL Model" section below.
Additionally, the plots were provided with correct scaling and included a trend line.
Groundwater Concentration Contour Maps
Per DRC Review the submitted concentration contour maps are in compliance with the License
and also continue to address past requirements according to DRC confirmatory action letters.
U Concentration Comparisons with ACL Plume Projections
Current concentrations at the POC, POE, and Trend wells were compared with the projected ACL
concentrations to determine if any premature elevation of U concentrations could be determined in
the data. Projection charts from the "October 13, 2003 ACL Modeling Report prepared by
Komex, titled" was used as the infonnation source; this Komex document includes several time
series diagrams of dissolved uranium concentration within a projected plume shape. The Komex
report includes plots and data for the solute breakthrough concentration curves calculated for the
licensed wells. '
Piior to the ACL acceptance, from the year 1990 until 2000, the Lisbon site was actively engaged
in an NRC approved "Con'cctive Action Plan (CAP)" which included groundwater withdrawal
within the plume and discharge to two evaporation ponds. This had the effect of creating 2 cones
of depression; one around the current 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.
The October 13, 2003 Komex diagrams (conceptual grids) depict the plume extending in two
defined arms, traveling northwest on either side of a flow divide (effect of lower hydraulic
conductivity zones as determined through model calibration simulations using aquifer test data).
The southernmost arm (heading southeast then northwest) moves parallel to a no flow boundary
zone created by the Lisbon Fault (aquiclude created by upthrown section of the Chinle formation.)
POE well RL-6 is located down gradient along the fault line as a warning system for elevated
dissolved uranium concentrations from this arm. According to the lime series plots,'it is not
expected that the plume will extend to this well until the year 3000, and it is not projected that
dissolved uranium concentrations 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 Standard for
Uranium of 30 micrograms/L will be exceeded al POE well RL-6 in approximately the yeai' 2600.
The northem arm of the plume (also heading northwest) is moving with the groundwater
downgradient direction on the noith side ofthe 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 the model that
dissolved uranium concentrations from the plume will not reach RL-5 at all (will remain at
background) and will not reach RL-4 until the year 2050, barely grazing the well then retreating.
Dissolved uranium concentrations al well RL-4 are not expected to exceed 1 mg/L at any lime. Tt
is predicted by the Komex model that the State Groundwater Quality Standajd for Uranium of 30
micrograms/L will be exceeded al POE well RL-4 in approximately the year 2200.
Rio Algom Mining L.L.C.
Memo RegardingUie 2"'' Half 2009
Groundwater Stability Monitoring Report
Page 8 of 10
Reported concentration values seem to be conforming to the model so far. however, it is hard to
really determine if upward trends are occuning at the POE wells without more data. Data from
trend wells (Trend Wells = EF-6, EF-8, ML-I, RL-1, RL-3, and H-63) indicates that
concentrations are remaining fairly stable with the exception of wells localed within the cone of
depression which are varying probably due to groundwater elevation reboimd.
Groundwater Stability Monitoring Report Conclusions
The 2009 2"'' Half 2008. Rio Algom Groundwater Stability Monitoring Report is generally in
compliance with License Condition 53. Per the information in this memo and the Augusi 30,
2008 DRC memo detailing the split sample field review, DRC continues to note problems with the
sample collection techniques and QA review.
DRC/Rio Aleom Spiit Sample Review
Review of Rio Algom November 4, 2009 Letter in response to a DRC RFI dated August 26,
2009 Regarding QA/QC Problems noted dunng the 2008 and 2009 DRC/Rio Algom Split
Sample Events (Documcntum Tracking No. 2009-004448).
The submission includes a cover letter and an attached letter and supplementary dala sheets from
Robert Lewis, PG of WorieyParsons (WP). WP was contracted by Rio Algom originally to create
the low flow sampling procedure and was again contacted to address the DRC concerns with the
observed field procedures.
The Rio Algom letter outlines corrective actions which will be taken in the field to address the
DRC concems, including:
• Perfonn the suggested in-office calibrations before going to the field and perfonn field
cahbration checks each day,
• Make the necessary changes in flow-cell positioning and/or use of check valve to maintain
proper water levels within the cells,
• Modify decontamination procedures as suggested by WP in an effort to ensure total
decontamination of sampling equipment.
• Screen intei-vals will be added to the field sampling log sheeis and pump placement will be
adjusted as suggested by WP.
The WP data addresses each of the DRC concerns listed in the August 26. 2009 RR, including; 1.
Field calibration; 2. Field chemistry readings: 3. Low flow purging; 4. Decontamination of the
bladder pump and hoses, and: 5. Custody seals missing on the sample containers. The Rio Algom
corrective actions listed in the bullets above were taken directly from the WP recommendations,
additionally, DRC noted during review ofthe 2009 2"'^ Half Ground Water Stability Monitoring
Report.
Rio Algom Mining L.L.C.
Memo Regarding the 2""^ Half 2009
Groundwater Stability Monitoring Report
Page 9 of 10
In general, the response has addressed the field sample collection and laboratory issues identified
in the August 26, 2009 RFL DRC will evaluate the improvements to the field sampling
techniques during the 2010 split sampling event. Additionally, DRC will require that the Rio
Algom prepare a ground water sampling quality assurance plan as per the "Split Sampling
Conclusions" section below. ',
Non-Radiologic Parameter RPD Calculations
I
The DRC Draft Split Sample Guidance Documenl for Uranium Mills, August 7, 2007 includes a
section for data comparison of non radiological parameters. Per the Guidance all data other than
radiologics will be compared and the relative percentage difference will be calculated. The
Guidance outlines the acceptance criteria for samples spiit between different laboratories as a
maximum 30% RPD. ;
Appendix 2 outlines the RPD calculations for the non-radiological data resulls for the August
2009 split sample trip. Samples which were reported as non-detect (sample result below the
MDL) were not included in the RPD column since the data is not comparable.
Comparison ofthe Rio Algom & DRC split samples shows the sample results were well within
the 30 % acceptance criteria for compared analyses. Uranium, Selenium, Molybdenum and
Arsenic. Therefore, no further action is needed.
DRC Blind Duplicate Results
Results of the DRC 2009 Blind Duplicate sample submitted to Lionville laboratory showed all
results well within the 20% (same lab criteria) RPD as outlined in the August 7, 2007 DRC Split
Sample Guidance for Uranium Mills (Appendix 3).
2009 DRC/Rio Algom Split Sampling Conclusions
The dala comparisons of August 11, 2009DRC and Rio Algom groundwater split sampling data
showed all results to be well within the comparison criteria listed in the DRC Uranium Mill Split
Sampling Guidance as outlined above. Therefore, none of the well data will need to be re-split in
2010.
DRC will modify the current Rio Algom Radioactive Materials License to include language
requiring the development of a Ground Water Monitoring Quality Assurance Plan (QAP). The
License will require a time frame for creation and submission of the QAP and will require that all
samples be collected with methods prescribed therein, and that all analysis be performed
according to prescribed methods and that all laboratory QA/QC be reviewed according to an
outlined planned, as well as listings of all violations and prescribed con'ective actions for'any non-
Rio Algom Mining L.L.C.
Memo Regarding the 2"'' Half 2009
Groundwater Stability Monitoring Report
Page 10 of 10
conformance with the QAP. DRC will require that the draft QAP be submitted for Executive
Secretary review and approval.
An advisory concerning the upcoming License modification (Modification 4) which will include
requirements to maintain an Executive Secretary approved QAP will be included in the letter
conespondence for the 2'"' Half 2009 Rio Algom Groundwater Stability Monitoring Report.
References
Rio Algom Mining LLC. Groundwater Stability Monitoring Report - 2""^ Half 2009, February 25,
2010
Utah Radioactive Materials License No. UT1900481, Amendment 3
Application for Alternate Concentration Limits Source Material License SUA-119, Lewis Water
Consultants Inc. March 1.2001
Response to Request for Additional Information, Application for Alternate Concentration Limits
Source Materials License SUA-1119, Komex, October 13, 2003
November 4, 2009 Letter from Chuck Weniz (Rio Algom) lo Dane L. Finerfrock (Director Utah
Division of Radiation Control), "Response to DRC Request for Information Letter from DRC
dated August 26, 2009 regarding Rio Algom Mining LLC's 2"" Half 2008 Groundwater
Monitoring Report, received by RAM on September 8, 2009."
Rio Algom
2"'' Half 2009 Ground Water Stability Report
DRC Review Memo
Appendix I - DRC Modular Inspection Form, Ground Water Module 30
'i|i|4:!.j#i;,^'cvUtaH^:bivisionri^ GontrolJtispediiDn •Form-. X s^M: "-''^^-.i
Grouiiid Water Modulel30 (Semi-Annual Grouhdi Water^^M^ Report)
i$ ^- ' -l^^^^-Rid^Algom |lLriing (d|inplnF#^: ^A^, :•;
Regulatory Requirements Inspected Against; Radioactive Materials License # UT 1900481,Condition 53
License-in-Force (dale): February 2, 2010 (major modification number 3)
Applicable License Conditions: Condition 53 Ground Water Compliance Monitoring
Last Previous Inspection Date: November 4,, 2009
Date(s) of Current Inspection: March 15. 20010
Violations Recommended: • Yes ^ No
Notes:
INSPECTION ITEM - Ground Water Monitoring Reporting (Module 30):
(check all that were included as part of this inspeclion)
Reporting Year: 2009
• A) Ground Water Monitoring Report (First Semi-Annual)
^ B) Ground Water Monitoring Report (Second Semi-Annual)
Ground-W^aterJMp^ ^AAA'^M7§^zMAmM7:^^
1. Were the following wells monitored:
A. Background Samples - wells MW5 and MW13?
[3 Yes • No
B. Trend Samples - wells EF-6, RL-l. RL-3, EF-8, ML-I, H-63, and LW-l?
^ Yes • No
C. Point of Compliance (POC) samples - wells EF3A. OW-UT-9?
^ Yes • No
D. Point of E.xposure (POE) samples - wells RL-4, RL-5. and RL-6?
S Yes. • No
Notes:
2. Well or Boring Installation Notification (Condition 53.H) - Were any borings or monitoring wells
reported to have been installed in any areas of potential groundwater impact, by either Rio Algom or any company
holding private mineral rights?
• Yes ^ No
A. If yes, was the Executive Secretary notified a minimum of 30 days prior to installation?
• Yes Q No *see notes below
B. Does it appear that proper drilling techniques were employed?
Q Yes • No *see notes below
Notes: *There are ongoing drilling issues within and directly surrounding the LTSM boundary. DRC has
coordinated with the Utah Division of Oil. Gas and Mining and the Bureau of Land Management regarding
concems of cross contamination 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 proposed in or near the
LTSM.
Also, a proposed irrigation project utilizing a water right directly east of the facility is also proposed (Redd
Ranches). BLM is in the process of approving an EA regarding the ground water withdrawal(s). DRC coordinated
with BLM regarding the well locations (see DRC Review Memo). DRC is currently in communication regarding
this activity and plans to coordinate future license conditions with Rio Algom to include additional modeling.
Rio Algom Mining Company
Module 30 Inspection Form Page 2 of 5 Eorm Updated 1/22/2009
monitoring well installations and/or the establishment of GWCL's at existing upgradient monitoring well (southern
LTSM boundary) locations (background well MW-13 and trend well H-63).
Ground Water Analysis Requirements
Laboratory Requirements
3. Were nil samples analyzed by a Utah Certified Laboratory?
Yes • No
Lab Name: Energy Laboratories
Certificate No.: Cert No. WY00002, Utah Track 3072350515 valid through: June 30, 2010
Notes: Energy Laboratories is reviewed for compliance annually by ihe Utah BLI
4. Did methods used to analyze ground water samples comply with the following:
A) Methods cited in UAC R317-6-6.3.L; and
B) Have delection limits which are less than or equal lo the License Condition 53, Tables
I through 3.
^ Yes • No
Notes:
5. Were the following laboratory parameters measured for each sample?
Yes • No
Notes:
Tarameter.^^J-v" '^^'/-j^v- A''~ \ \fW--Q&rani^nts^z..A^^&7AW
Uranium Y-Method E200.8
Molybdenum Y - Method E200.8
Selenium Y - Method E200.8
Arsenic Y-Method E200.8
pH Y
TDS Y - Method A2540 C
Chloride Y - Method E300.0
Sulfate Y - Method E300.0
Bicarbonate Y - Method A2320 B
Water level elevations Y - Per ASTM Field Methods
Reporting Requireinents (Condition 53.G, Taife;^):^^^
6. Report Submittal Date- Were semi-annual monitoring report(s) submitted on or before the followinj
deadlines:
First Semi-Annual Report - September 1
Second Semi-Annual Report - March I
• Yes
M Yes
• No
• No
Notes:
Rio Algnm Mining Company
Module 30 Inspection Form Page 3 of 5 Form Updated 1/22/2009
Ground Water Monitorine Reporting Content Requirements (Condition 53.G)
7. Does the monitoring report include the following criteria?:
A. Sampling Methodology
Description of sampling equipment, purging volume, technique.etc.
E Yes • No
Notes: The submission includes an Appendix with the ASTM sampling methodology (low flow" purging)
which is being undertaken by Rio which is an ASTM meihod. Method Number D 6771 -02. DRC reviewed this
methodology in the field during the 2008 split sampling event. DRC review of the method was documented on the
review ofthe 2"^ Semi Annual Report 2008 and has also been documented in a memo dated August 20, 2008 to
Loren Morton from Tom Rushing and an additional memo from Loren Morton to Dane Finerfrock. briefing Dane
as (o the discrepancies noted through field review and recommending no further action. Per further coordination
with Rio Algom (2009 and 2010) and a DRC RFI sent loRio Algom dated August 26, 2009 regarding review of
the 2'"' half 2008 ground water stability report, the facility Licen.se will be amended to include requiremenls for
Quality Assurance for both field collection of ground water samples as well as Rio Algom in-house review of all
laboratory QA/QC reports and follow up actions as appropriate. Rio Algom responded to the RFI by leiter dated
November 4. 2009 and including an attachment generated by WorieyParsons and regarding the low flow technique
and answers to DRCs RFT questions.
B. Field Parameter Measurements ^ Yes • No
Notes: The submission appears to comply with the License requirements. |
C. Latraratory Information
I
Laboratory name, location, state certification, adequate MDL's and QA/QC validation, copies of laboratory
data, and, chain of custody fonn:
^Yes QNo
Notes:
The submission includes copies of the laboratory' data sheets, QA/QC validation samples and results, and the work
order receipt checklist which indicates chain of custody presence and condition. Per DRC review it was noted that
the samples were originally logged as not having custody seals on the sample shipping container, however, per a
note from C.D.W (Chuck Wentz) it was noted that an amended Workorder Receipt Checklist was .submitted which
amended the check in status to include custody seals. A copy of the state certification was not provided, however,
this information is not required by the License and was obtained by looking on the Utah Departmentiof Health
website.
D. Data Evaluation
Concentration vs. time plots, interpretation of data, time series trends:
Yes • No
Notes:
E. Figures - Ground water contour map. uranium concentrations versus the predicted concentration for
compliance wells, isoconcentration map for each of the following: arsenic, molybdenum, selenium, and
uranium.
13 Yes • No
Rio Algom Mining Company
Mndule 30 Inspection Form Page 4 of 5 Eorm Updated 1/22/2009
Notes:
Compliance Limits (Condition 53.B and Cj
8. Were all concentrations reported found to be below the Compliance Limits established in Tables 1, 2 and 3 in
the license as shown below?
ITABLE illROINT OF.COMFLIANCE (POC)WELLSl^
kWeU
OW-U I 9
Other
•\cLs (nifl/l.)'
Molybdenum - 2?.34
Selenium - 0.9."^
Arsenic = 3.06
Mulybdcniim - 58.43
Seleiiiutn = 0.10
Arsenic = 2.63
JraniimijVCL^(iTigjilj>=^
96.87
101.58
V- -. u-:v. v.\iTABLE2: POINTOF EXPOS0RE(roE) V^^ :
: V I Well I . ; S ^"-:-^=l •T=. ~-rUranium CompUanceLimir(nie/li)i-r-:'..^V-- • • '-^'i-
RL 4 0.32'
RL-5 0.32-'
RL6 0.32^
^;-;_-..,-:r" • . • ••• •TABLE]3: TREND-wEi^LSfe^l^ -- -.-^^.-r -
• - il~ t" . Uranium Tareet Actionlievel (niB/L)
, B _ ' EF-6 3.9^
EF-8 0.30'
ML-1 0.26'
RL-1 42.1"'
RL-3 37.3^
H-63 0.06-'
Yes • No
Notes:
9. If "no", list wells e.xceeding the above listed Compliance Limils in the following table:
•"WeU^U):^ ^Type of Well [' Cbhstitueht in Excess 1 GoncentiratibnJ > >™
^OPpfc^/ivvi^'T ^-A^MArf': . At- \S^9\AA
frrendvPbE)-L •'•^•"S:-'-^MTJ^t.: ^-\': A-\''':'A ^A"^'^--^'-
Ipbiaipliance Limit .;
Rio Algom Mining Companv
Module 30 lnspeciit)n Form Piige 5 of 5 Form Updated 1/22/2009
Out of Compliance Status (Condition 53.C (!)
10. In the event of Out of Compliance Status, answer the following questions:
a) Was the E.\ecutive Secretary notified verbally w^ithin 24 hours following receipt of out-of-compliance
data?
• Yes • No
Notes:
b) Was the E.xectitive Secretary notified in writing within 5 day following receipt of out-of-compliance data?
• Yes • No
Notes:
11. Was monthly ground water sampling initiated for the exceeded parameter in the well indicating exceedance. or
as specified otherwise by Executive Secretary:
• Yes • No
Notes:
I
12. Did the licensee prepaie and submit within 30 days of discovery a plan and .schedule to evaluate and assess the
source of the e.\ceedence and possible actions needed to restore and maintain compliance with License
Condition 53.B:
• Yes • No
Notes;
II. Additional Records Requested/Inspected:
Notes:
Inspection Staff Tom Rushing. PG
Rangeof Records Inspected: From: 2"^ Semi Annual 2009 GW Stability Report 7/1/09 To: 12/31/009
Modubr Peimil In'ipectlon Form Version I, updaled Januar>'. -00*)
F:\Kio AI<!om\(;ri>undwaier Moniiuring 2nd 2(H»\RioUsbLinCrauridw;itcrSuh!lily2nd2(KWMf)dulcFnrTTi.dcx.-
Rio Algom
2"" Half 20(
DRC Review Memo
2"" Half 2009 Ground Water Stability Report
Appendix 2 - Non-Radiological Data Comparisons, Rio Algom/DRC Split Sample
Results (Augusi 11,2009)
55
1
mi:
3
cn
Rio Algom
2"^ Half 2009 Ground Water Stability Report
DRC Review Memo
Appendix 3 -- DRC Blind Duplicate Analysis
F'Pamet^^M^ vSampl^'Date -^Ing/L^ W-^ Aha^ Analysl
Arsenic 8/11/2009 0.001 0.001
Molybdenum 8/11/2009 0.014 0.013 7.4
Selenium 8/11/2009 0.008 0.008 0.0
Uranium 8/11/2009 0.0166 0.0137 19.1
Rio Algom
2"'^ Half 2009 Ground Water Stability Report
DRC Review Memo
Appendix 4 - DRC August 20, 2008 Ground Water Split Sampling Field Technique
Review Memo
^'"^£7271''' •
State of Utah
JON M. HUNTSMAN, JR.
Governor
GARY HERBERT
Lieuienant Governor
Uepaitment of
Environmental Quality
Richard W. Sprott
Executive Direclor
Dr/ISION OF RADIATION CONTROL
Dane L Finerfrock
Direclor
MEMORANDUM
TO: Loren Morton, P.G., Manger
FROM: Tom Rushing, P.G., Hydrogeologist
DATE: August 20, 2008
SUBJECT: Rio Algom Split Sampling (8/5/08), DRC Review of Rio Algom Field Techniques
Field Review
On August 5, 2008 Tom Rushing (DRC) and Chariie Bishop (DRC) met with Don Sweeney
(RSO, Rio Algom Mining LLC) and Gail Alexander (Rio Algom) to conduct split sampling at the
Rio Algom facility in the Lisbon Valley near LaSalle, UT.
DRC conducted a review of the Rio Algom field sampling techniques, collected split groundwater
samples and shipped the samples lo the DRC contracted laboratory for analysis (Lionville
Laboratories Inc., Exton, PA.) The laboratory data will be reviewed subsequent to receipt of the
Rio Algom sample data which is required to be submitted to DRC with the Semi-Annual Ground
Water Monitoring Report by March 1, 2009. This memo serves to summarize DRC concems with
the Rio Algom field procedures and to document ground water sample locations where split
samples were taken and laboratory QC documentation.
Table I - Satnple Locations and Laboratory Check-in QC Information
Well. Number Sample
Date/Time
Laboratory Check-in Analysis Requested
RL-5 POE Well 8/5/2008
1030
Custody Transfer
Sheet and Sample
Check-in Sheet
Received from
Lionville Laboratory
Inc., No flags
regarding sample
preservation or
custody tags etc.
Total Uranium (mg/L)
Total Molybdenum (mg/L)
Total Selenium (mg/L)
Total Arsenic (mg/L)
TDS (mg/L)
Chloride (mg/L)
Sulfate (mg/L)
Bicarbonate (mg/L)
168 North 1950 West • Salt t-ake City, UT
Maihng Address: P.O Box 144850 • Salt Lake City. UT 84114-4850
Telephone {801) 536-4250 • Fnx (801-53:J-4097 • T.D.D. [801)530-4414
www (icq iiicih gov
Prrnled on lODSI. iccyclctl p;ipcr
Rio Algom Split Sample Trip Memo
Page 2
RL-4 POE Well 8/5/2008
11:30
Custody Transfer
Sheet and Sample
Check-in Sheet
Received from
Lionville Laboratory
Inc., No flags
regarding sample
preservation or
custody tags etc.
Total Uranium (mg/L)
Toial Molybdenum (mg/L)
Total Selenium (mg/L)
Total Arsenic (mg/L)
TDS (mg/L)
Chloride (mg/L)
Sulfate (mg/L)
Bicarbonate (mg/L)
RL-9 Blind Duplicate
of RL-4
8/5/2008
12:15
RL-9 is a
bimd
duplicate
sample of
RL-4
Custody Transfer
Sheet and Sample
Check-in Sheet
Received from
Lionville Laboratory
Inc., No flags
regarding sample
preservation or
custody tags etc.
Tolal Uranium (mg/L)
Total Molybdenum (mg/L)
Total Selenium (mg/L)
Total Arsenic (mg/L)
TDS (mg/L)
Chloride (mg/L)
Sulfate (mg/L)
Bicarbonate (mg/L)
Rio Algom Field Equipment:
DRC splits with Rio Algom were conducted in tandem and thus the DRC samples were collected
using the Rio Algom equipment. DRC met with Rio Algom early on the first day of sampling
(Rio was conducting a 3 day trip), thus, it was noted that the Rio representatives did not field
calibrate or decontaminate any eqmpment at the first well location.
Table 2 - Field Equipment Observed by DRC (Also See Photo Log - Attachment 2)
Equipment Type Manufacturer DRC Notes
Probes: pH, Conductivity, 02 WTW Probes were not calibrated in
field, nor were membranes etc.
checked or replaced in field if
determined inadequate, (see
notes in Field Calibration
Section Below)
Flow Cell WTW, Small Flow Cell Which
was Manufactured to accept
the associated probes (see
Photo I attached), constructed
with non reactive polyurethane
material
Flow Cell did not provide
adequate check valves to keep
water on probes at all times
(see notes in Field Parameter
Measurement Section Below)
Water Level Indicator Tape
(Spooled)
Unknown Tape appeared to be working
cortectly, sound indicator
Bladder and Housing, Same
Unit Inserted into each well
(See Photo 6 attached)
Polysyntheiic housing with a
disposable bladder insert
Rio Algom Split Sample Trip Memo
Page 3
Tubing Non reactive polysynthetic
CO2 Canisters Typical gas canisters, 2 loaded
onto truck on their side
Rio Algom sampling staff
stated that the C02 canisters
were purchased in Moab
Coolers Standard Coolers
Peristaltic Pump Geotech Pressure
Indi c ator/Regul ator
Buckets for Soapy Water,
Clean Water and Deionized
Water
DRC inquired as to the type of
soap that was used for
disinfection, the manufacturer
was not known. It was noted
that through the cleaning
process, it was doiibtful that
the soap was completely
rinsed. See field disinfection
procedures below.
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 samphng run. It
was also stated that no calibration standard solutions are kept in the field, 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 sample over the probe
tips (membranes) when the field readings were taken. In particular, 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" valve be installed to prevent drainage of the sample water from the flow cell
during sample readings.
Field Decontamination Procedures:
The field procedure for decontamination 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, 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.
Rio Algom Split Sample Trip Memo
Pase 4
Per DRC field observations, it did not appear that the soap was completely rinsed from the hose
after completion of the DI rinse. Rio Algom representatives did allow a complete rinse of the
hose, utilizing an induced air bubble in the hose as a reference mark to insure full rinse. It was
noted however that a soapy residue was potentially present and that additional rinsing was likely
warranted. The onsite representatives stated that the rinse methodology was per training they
received from "Komex."
Low Flow Sampling Method:
Per observation of the well sampling techniques, Rio Algom was undertaking a low flow method
of sampling. It appears that the sampling methodology used by Rio Algom is the same as an EPA
article (not guidance) published in April 1996 {EP7^540/S-95/504, Low Flow Ground Water
Sampling Procedures, Robert W. Puis and Michael J. Barcelona.) This is the first time that DRC
has observed the Rio Algom sampling techniques. DRC noted the following during the sampling:
• Rio representatives did not calculate purge volumes or purge the wells prior to sampling.
Rio representatives instead pumped a very small volume from the monitoring well to
maintain an in-well water level elevation that was designated as the top of the well screen.
• When asked by DRC representatives if the sampling technique was adequately flushing
well pack and media, Rio responded that they were conducting the sampling as per
training by their consultant, "Komex."
• Rio representatives collected sample from the well after it was pumped through the flow
cell. Pump rate ^yas based on previous calculations but was very low for the two POE
wells which were spht sampled.
• Rio representatives used a pre-prescribed pumping rate for each well and tested the
amount of drawdown using a sound tape, per Rio representatives the objective was to
maintain the water level in the well at the top of the well screen. Rio representatives stated
that per their communication with Komex this would ensure that the groundwater sampled
was free flowing through the well screen and should eliminate stagnant water from being
sampled.
Collection Bottles/Filters
Sample bottles and preservatives were provided by the respective laboratories for DRC and Rio
Algom. The bottles were filled alternately per the DRC split sampling guidance. Cartridge filters
were used for the metals bottles. It was noted that the cartridge filters would become fairiy
plugged after filling approx. 2-3 liters of sample. The sample stream, however, appeared clear
and was not discolored etc., also the unfiltered water from the pump was not cloudy or discolored.
DRC asked Rio why the filter was so rapidly plugged but did not obtain an explanation of
chemistry (TDS, Fine Solids, Microorganisms, etc.) or other effects which would cause the filter
to foul.
Rio Algom Split Sample Trip Memo
Page 5
DRC contacted the Division of Water Quality monitoring section to ask whether the decreased
flow through the cartridge filter would be considered unusual. According to DWQ, they
commonly use the cartridge filters for groundwater field sampling and have noted that the filter
will commonly slow down after filtering volumes as low as 1 liter. DWQ also did not have
specific reasons for why the filter would foul so quickly.
DRC Actions
It is recommended that future action conceming findings of the split sampling event with Rio
Algom be delayed until DRC receipt of the laboratory data from Rio Algom and Eberline
Services. This will allow full evaluation of QA/QC and Relative Percentage Difference
calculations.
It is recommended, however, that once the data is evaluated, a "Confirmatory Action Letter" be
sent to Rio Algom which refiects the following observations during field collection as well as
future findings of the data comparisons:
1. Rio Algom will be required to submit a copy of their low flow sampling plan. Per
explanations in this memo, Rio Algom consistently referred to recent field sampling
training that they had received from "Komex," however, no written prescribed
methods have been provided or reviewed by DRC.
2. Per preliminary review ofthe low flow sampling technique undertaken by Rio, it
appears that the method used is not documented as approved by EPA, although articles
have appeared in print under the EPA logo and published by the Superfund
Technology Support Center for Ground Water. Rio Algom will be asked to present the
technical information which supports the low flow method lhat they are using at the
Lisbon Facility, as well as, their well by well analysis showing that the method is
appropriate based on individual well design, stratigraphy and flow characteristics.
3. Rio Algom will be required to justify why field calibration of probes is not taking
place. Field calibration needs to occur per a prescribed method and time interval. Rio
will also be required to justify why no field maintenance of instruments is conducted,
this would include the observation of probe membranes and replacement as needed.
4. Rio Algom will be required to justify why there was no field decontamination of
equipment at the first well sampled.
5. Rio Algom will be required to justify their field readings through tbe flow cell which
was continually draining below the field probe membranes. Per DRC observation, the
readings were not stabilizing prior to Rio recording the readings and it did not appear
that the reading had stabilized prior to sample collection.
6. Rio Algom will be required to provide evidence that the field decontamination
procedures for the bladder pump, housing and hoses is adequate and is clearing the
equipment of soap residue.
Rio Algom Split Sample Trip Memo
Page 6
Conclusion
This trip constitutes the first split sampling event between DRC and Rio Algom at the Lisbon
Valley Site. This memo identifies several concems with the Rio field techniques and equipment.
A full evaluation including data comparison will be conducted by DRC after receiving the data,
cortespondence with Rio will be delayed until the full evaluation is complete.
References
1. Puis, Robert W. and Barcelona, Michael J., "Low-Flow (Minimal Drawdown) Ground-
Water Sampling Procedures," United States Environmental Protection Agency, Office of
Reasearch and Development, EPA/540/S-95/504, April 1996.
2. Utah Radioactive Materials License No. UT1900481, Amendment 2.
Rio Algom Split Sample Trip Memo
Photo Pages
Page 1 of 3
Photo 1 - WTW Field Chemistry Instrument
Photo 2 - Geotech Pump Pressure Requlator
Rio Algom Spht Sample Trip Memo
Photo Pages
Page 2 of 3
Photo 3 - Flow Through CeD with Probes Inserted During Field Reading
Photo 4 - Pump and Field Chemistry' Set Up
Rio Algom Split Sample Trip Memo
Photo Pages
Page 3 of 3
Photo 5 - Buckets for Bladder and Hose Decontamination
': .iA~ •^••^7 ^^il^A'-^^-A-^-^^^'Ar^^^A'' " •
•r-:.r7.^\ ^ \A(^P-0^.t. 7:. .•'^•-•7'
1 !••;<;• 1.^'
Ai .!^:y:-
Photo 6 - Removing the Bladder for Decontamination
Rio Algom
2""^ Half 2009 Ground Water Stability Report
DRC Review Memo
Appendix 5 - January 7. 2009 DRC Field Review Memo Response, Stay of
Administrative Action
State of Utah
JON M. HUNTSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
William J. Sinclair
Acting Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
SUBJECT:
TF
Dane Finerfi-ock fj mAjr^
MEMORANDUM
Loren Morton
January 7, 2009
DRC Staff Findings Regarding Rio Algom Groundwater Sampling Practices
During August 5, 2008 Split Sampling Event: Recommendation for Stay of
Administrative Action.
The ptirpose of this memo is to recommend a stay of administrative action on the part of the
Executive Secretary regarding recent DRC staff findings and observations of improper
groundwater sampling procedure at Rio Algom.
In a memo of August 20, 2008, DRC staff documented several Quality Assurance (QA) problems
observed during an August 5, 2008 groundwater split sampling event at the Rio Algom 1 le.(2)
facility in Lisbon Valley. Some of these problems included:
• Lack of calibration of field instruments before sampling (pH, conductivity, etc),
• Lack of field decontamination of sampling equipment before collection of the first sample,
• Improper operation of a flow cell during the sampling process,
• Failure to calculate purge volumes prior to sampling,
• Failure to collect equipment rinsate samples to verify field decontamination.
As you are aware, these kinds of groundwater QA issues are normally part of a Groundwater
Discharge Permit and are addressed in a QA Plan (QAP), that closely follows EPA RCRA
guidance (e.g., TEGD).
In the August 20, 2008 memo, DRC staff recommend use of a Confirmatory Action Letter (CAL)
to encourage Rio Algom to improve their QA program for groundwater sampling.
However, I recommend that the DRC stay any administrative action in this regard, for the
following reasons:
168 North 1950 West * Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke Cily, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D [phone]
wMw.deq iiinli.gov
Printed on 100% recycled paper
Page 2
1. Lack of Groundwater Permit - no State Groundwater Discharge Permit has been
required of Rio Algom previously. Consequently, the company has not been required
to prepare and implement a QAP. Currently only rudimentary groundwater monitoring
requirements are mandated in the Radioactive Materials License.
2. Closure Report - In a 12/18/08 letter, Rio Algom staff informed the DRC that the
company intends to submit a Closure Report for the facility for DRC review / approval
by 4/30/09.
3. Limited DRC Resources - DRC staff resources can be better used reviewing the
Closure Report instead of preparing any CAL or License amendment to compel Rio
Algom to improve their groundwater monitoring program.
4. License Termination and Transfer to DOE - after DRC approval ofthe Closure Report
the Rio Algom 11 e.(2) License can be terminated. Thereafter, transfer of the property
to DOE can be completed.
5. DOE Groundwater Monitoring Expertise - DOE has a well developed protocol for
groundwater sampling. As a result, these QA problems should be avoided by the
future owner.
LBM:lm
Fy.../2008 Split Sampling Memo.doc
File: Rio Algom 2008 Split Sampling
Rio Algom
2""^ Half 2009 Ground Water Stability Report
DRC Review Memo
Appendix 6 - Rio Algom Split Sampling Tracking Spreadsheet (Prepared by DRC Staff)
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