DRC-2002-001042 - 0901a068809be155

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in Well MW-4 - the dePth to
-4 is a critical issue in that it forms the
basal boundar-y of ,t " opp".-ost aquifer, and may significantly control local groundwater
flow directions and chloroform transport. Unfortunately the depth of tn9f1! contact in this
well has been a matter of dispute. Pieviously, the DRC relied on the 1979 D'Appolonia well
completion diagram (Tlg4TitanReport, Appendix A), which indicated the Jmb contact was
found in MW4 at a iepth of l11feet Uetow ground surface (ft bgs). On this-basis' the DRC
asked IUC to re-perforate well MW-4 or install a confirmation boring or well nearby to
resolve this issue l3lzotuDRC Request for Additional Information (RAI), p. 3 and 617l0l
chloroform Investigation RAI, Atta;hment 1, p. 71. In response to this request' IUC cited a
Umetco Minerals Corporation geophysi cattog(1194 Titan Report, Appenglil)' which
indicated the Jmb coniact in welt fvfW-+ is found at a depth of 108 ft bgs (6l22lOLIUC
Sirmg* il"[,its]a
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
168 North 1950 West
P.O. Box 144850
Salt Lake City, Utah 84114-4850
(8ol) 5364250
[phone] Fax
(801) 536-,1414 T.D.D.
www.deq.state.ut.us Web
Michael O. Leavitt
Governor
Dianne R. Nielson, Ph.D.
Executive Director
William J. Sinclair
Director
March 7,2002
)
Mr. Harold Roberts
Vice President, Corporate Development
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
1050 l7th Street
Denver, CO 80265
Re: November 12,2OOl HGC Evaluation of Hydraulic Test Data at MW-4 White Mesa
Uranium Mill Site Blanding, utah: Request ror i.aaitional Information and Installation of
New Monitoring WelI Adjacentto MW'4'
Dear Mr. Roberts,
we have reviewed the Novemb er 12,2001 Hydro Geo Chem (HGC) submittal referenced above.
During this review, we determined that additi,onal information is required. Please resolve the
"on""i* and provide all information requested below:
1. Missine 1994 Pump Test Data (0'92 spm Rate) - the November l'2' 2001 HGC report
provides u pr-@test work apparently conducted by Peel
Environmental Services (Peel) in 1994 (ibid., Attachment 2). However, the HGC submittal
failed to include the raw water level or drawdown measurements for this 0'92 gallons per
minute (gpm) pump rate test. Please provide-the raw.data that corresponds to this test'
please also provide a complete description of how this test was conducted, data analysis
methods used, and uny.oi".tions to the drawdown data made in the analysis' Until this
information is providid, we are unable to confirm any HGC conclusions or interpretations
regarding this PumP test.
Mr. Harold Roberts
March 7,2002 Page2
Report, p. 8). Later in an October 5, 2001 meeting DRC staff raised concerns about
interpretation of this geophysical log, in that the neutron porosity portion of the log showed a
dramatic decrease in porosity below a depth of about I l0 ft. This decrease in porosity may
have been caused by a sandstone bed, which in turn would suggest the Jmb contact is found
at a lower depth in the well.
More recently, review of the 1999 HGC high rate pump test of well MW-4 sheds new light
on this issue. During the September 29,1999 high rate pump test the maximum drawdown
measured was 41.024 feet, which corresponds to a water level depth of 108.49 ft bgs, see
Table I below. If the base of the uppermost aquifer was truly found at a depth of 108 ft bgs
in well MW-4, then the shallow aquifer would have been completely de-watered at this point
during the pump test, and the pumping rate would have fallen to zero.
In contrast, well I\rIW-4 continued to yield 9.1 gallons per minute (gpm) even after the water
level fell below the 108 ft bgs interval. Furthermore, the pump yield was steady at this point
until HGC shut the pump off at 45 minutes into the high rate test. This well pumping
response suggests that the Jmb contact is located at a depth greater than 108.49 feet in well
MW-4. This observation conflicts with the earlier Umetco geophysical log interpretation that
placed the Jmb contact at a depth of 108 ft bgs.
Footnotes:(l) Equivalent water level depth below well measuring point (D6*) for maximum drawdown (D*) calculated as follows:
Durrp = D*t + D* + W., where:
D*ri = initial water level in well before pumping begins (ft bmp),
D,* = rrrsximum drawdown observed during pump test (ft).
Ws = w€ll's water level measuring point stick-up above ground surface (ft). For IUC well MW-4, stick-up = 1.56 ft.
(2) Water level depth below ground surface (D6r) calculated as follows: D5g, = Dup - W,
(3) Pressure transducer depth in well MW-4 provide d in a l2l2ll0l HGC facsimile. In this submittal, HGC explains the I l0 ft
bmp depth determined by length of transducer cable available at the time of the high rate pumP test (9/28199).
(4) Pump depth provided ir.l2l24l0l telephone call from Stewart Smith (HGC) to l-oren Morton (DRC).
(5) Initial depth to groundwater for the 1999 high rate pump test, 69.03 ft bmp, was provided to DRC in alZll2lOl HGC
facsimile.
Additional pump test details provided by HGC indicate that the pressure transducer was set at
a depth of about 110 feet below measuring point (ft b-p), while the Grundfos submersible
pump was set at about 120 ft bmp in well MW-4 before the high rate test began (see 9l29l0l
HGC fieldnotes and L2l2ll0l HGC facsimile to DRC). Well construction details show the
screened interval in well IvIW-4 is between 92 and 112 ft bgs. Consequently, the pressure
transducer was set above and the Grundfos pump set below the base of the well screen in the
Table 1. Summary of 9199 HGCHighRatePumpTestof WellMW-4
from 10/15/01 IGC electronic files Mw4dwnt2.dat and M ,ll,
Pumping
Time.
(min)
Pump
Rate
Measured
Drawdown-- Equivalent Water tevel
Pressure
Transducer
- Deoth @
Pump
Depth 1a)
Comment(gom)(ft)Depth (ft bmp)(ft bmo)
(ft bmp) ('(ft bgs) '"'
0.0 0 0.0 69.03,"110 t20 Initial water level
before pumping
43.3 9.1 40.54t4 109.57 108.01 ll0 120
43.733 9.1 41.024 110.05 108.49 110 t20 Maximumdrawdown
44.467 9.1 40.5414 t09.57 108.01 110 120
45.0 0.0 Pumo turned off
Mr. Harold Roberts
March 7,2002 Page 3
high rate test of IvtW-4 (see Table 1, above). Arguments could be made that ruC could have
placed the pressure transducer at a greater depth to better test the location of the Jmb contact
in well MW-4 (see Figure 1, below). As reported, the transducer was not set lower than 110
ft bmp at the time of the high rate pump test due to the limited length of the transducer cable
(l2l2ll0l HGC facsimile). Despite this constraint, DRC staff have concluded that a
pumping water level below the 108 ft bgs interval combined with a sustained well yield
during this portion of the pump test both suggest the Jmb contact is deeper than 108 ft bgs.
These findings directly conflict with the Umteco geophysical log and have other significant
implications for calculation of aquifer permeability from the MW-4 September, 1999 HGC
pump test work. Please resolve the DRC concerns listed below.
3. Need to Install New Well and Correct Partial Penetration Effects in Well MW-4 Pump Tests
- review of the November 12,2001HGC Report shows that at the time of the September,
1999 pump test that well MW-4 only partially penetrated the shallow aquifer. This finding is
based on the following observations:
A.Hieh Initial Water Irvel in Well - review shows that before pumping commenced the
initial water level in the well was 24.53 feet above the screened interval (see Figure 1
below). As a result, well IvtW-4 was screened across only a portion of the shallow
aquifer, and
Jmb Contact Below 108 ft bgs - from the DRC pump test findings above it appears that
the Jmb contact is found below the 108 ft bgs interval, and perhaps as deep as 125 ft bgs
as shownia+l+e 1979D:Appslonia-rye11-esrnpl,etion diagrxm(7l94rTitan Report,
Appendix A). As depicted by D'Appolonia, the screened interval in well MW-4 does not
reach the base of the shallow aquifer, but is limited to an interval of 92to lI2 ft bgs.
B.
Such partial penetration causes a significant vertical hydraulic gradient near the well screen,
which in turn artificially increases the rate of drawdown during a pump test @riscoll, pp.
249-252). This artificially high drawdown results in artificially low hydraulic conductivity
results unless corrections to the measured drawdown are made during analysis of the pump
test drawdown data (ibid.).
To make these corrections, it is necessary to know the degree of partial penetration in well
MW-4, which in turn requires determination of the true Jmb contact depth in this well.
Please install a new monitoring well immediately adjacent to MW-4 that accurately
determines the Jmb contact depth, then determine the degree of partial penetration in existing
well MW-4 and correct the 1992 Peel and September,1999 HGC drawdown data
accordingly.
4. Missing Description and Justification for Proprietary Pump Test Analysis Software: 1999
Pump Test Results - review of the November 12,2001HGC Report and discussions with
Mr. Stewart Smith indicate that the 1999 HGC pump test data for well IvIW-4 were analyzed
with proprietary computer software owned by HGC, i.e., WHIP (llll2l0l HGC Report,
Figures 6 and 7, and personal communication, Stewart Smith). Because this software is
proprietary, it is difficult for the DRC staff to ascertain and confirm the reliability of the
software used to analyze the well drawdown results from well MW-4. To resolve this issue,
please provide the following:
Mr. Harold Roberts
March 7,2002 Page 4
Additional Disclosure and Justification - please disclose the governing equations and
solution techniques used in the HGC WHIP progam to analyze the 1999 MW-4
drawdown data. Please provide a disclosure and evaluation of the Wtffi input variables
that are sensitive in the solution for aquifer hydraulic conductivity. Please provide
independent comparisons or case studies that confirm how W[ffi can produce reliable
pump test analysis, as compared with other commercial or public domain software that
has been peer-reviewed by the groundwater technical community, or
Use Other Analysis Software - that has undergone peer review by the groundwater
technical community to analyze the 1999 MW-4 pump test drawdown data. Such other
software may be either commercially available or public domain software.
5. Need to Evaluate and Correct AquiferDewatering Effects on Well MW-4 Measured
Drawdown Data - for some unconfined aquifer pump test solution techniques, aquifer de-
watering can cause artificially high drawdown response in a well during pumping, and a
significant under-estimation of hydraulic conductivity. For example, the Jacob-Cooper
solution technique requires the measured drawdown values to be adjusted in the event that
pumping de-waters the aquifer by more than 20 percent during the test @riscoll, pp. 918-
9re)
In order to determine if aquifer de-watering is of concern for the 1999 HGC low or high rate
pump tests, it will be essential to determine the depth to the Jmb contact in well MW-4, as
outlined by our request for a new well, discussed above. If the solution technique used by
the HGC WHIP program is sensitive to aquifer de-watering, please correct the observed. drawdown data for aquifer de-.watering before it is analyzed to determine aquifer
permeability.
6. Concerns with HGC Vertical Permeability Distribution Intemretation - the November 12,
2001 HGC Report indicates that a break in the drawdown slope in well MW-4 was caused by
a high permeability zone encountered in the well. Because the geologic log for this well is
cryptic, and because there is no other means of independently verifying this claim, it is
critical that careful scrutiny be applied to the drawdown and recovery pump test data for this
well. After careful consideration, DRC staff are unable to concur with your interpretation for
the following reasons:
A. Apparent Lack of Unique Solution: 1999 Drawdown Response Hieh Rate Data - review
of the November 12,2OOI HGC Report shows that at the same time that the vertical
break occurred in the drawdown response data, at about 30 minutes into the test, HGC
suddenly increased the pumping rate from 6.4 to 9.4 gpm (see Figure 1 below). As a
result, the near vertical response in the drawdown curve is a product of both the pump
rate increase and possible changes in aquifer characteristics.
Another factor that must be considered is casing storage, which is a function of the
pumping rate. Because the pumping rate increased, one can expect a degree of water
storage will exist temporarily in the casing while the system adjusts to a new equilibrium.
During this time of transition, casing storage will cause an artificial increase in drawdown
slope, which could also explain the near vertical slope at about 30 minutes into the high
rate test.
A.
B.
Mr. Harold Roberts
March 7,2002 Page 5
In light of these compounding factors, please justify how a unique solution for the head
response can be generated when three different independent variables are at play.
Lacking any additional justification, we will conclude that the drawdown side of the high
rate pump test is inconclusive and does not support the presence of any high permeability
zone at about 30 minutes into the test (- 92 ft bgs).
B. Apparent Lack of Unique Solution: 1999 Recovery Response High Rate Data - the water
level recovery portion of the 1999 high rate test shows two different recovery slopes are
apparent in the MW-4 recovery response (see Figure I below). The transition of these
two different recovery slopes occurs at about 53 minutes into the test (which corresponds
to a drawdown equivalent interval of about 25 feet). Prior to 53 minutes, well MW-4
exhibited a recovery rate of about 1.83 ft/min. After this point, the well recovered at a
477o higher rate,2.69 ftJmin However, it is important to note that at this same 53 minute
time interval, the water level in well MW-4 rose above the top of the well screen located
at a depth of 92 ft bgs. Consequently, it appears that the increase in the well recovery
rate above and beyond this point is the product of partial penetration effects in well MW-
4.
As a result of these findings, DRC staff conclude that the results of the 1999 HGC high rate
pump test are inconclusive and therefore do not support previous IUC claims that a higher
permeability zone exists in well MW-4 near the depth of about 92 ft bgs (25 feet of
drawdown).
7. Concems with Comparisons Made to the 1992 Peel Pump Test Results - with regard to
comparisons HGe made betweenthe l99}I{GGhighratepump testand the 1992 Peel low
rate pump test, the DRC staff have concluded that it is premature to make such comparisons
for the following reasons:
Higher Frequency of HGC Data Collection - the HGC test data appear to be a better data
set for pump test analysis purposes, in that the head response data were collected on a
constant interval of every 2 seconds during the 118 minutes of testing. In contrast, the
l992Peel test, was based on head response data collected on 11 different time intervals
that varied from 0.9 to 47 minutes each over a 333 minute duration of the test (2/93 Peel
Report, Appendix C).
Lack of Evaluation of Effects of Partial Penetration - the Febru ary , L993 Peel Report
failed to evaluate the effects of partial penetration in well IvtW-4 as a part of the analysis.
Until this evaluation is made for both the 1992 Peel data and the 1999 HGC data, it
would be inappropriate to compare these pump tests and their respective hydraulic
conductivities calculated.
Unexplained Adjustments to Drawdown Data - the 1992 Peel Report did make
adjustments to the head response data to correct for aquifer de-watering. Unfortunately,
no information was provided in the report to justify how or explain the basis for these
adjustments. Since the true depth to the Jmb contact is currently unknown in well MW-4,
it appears that the Peel adjustments were without foundation. Consequently, after
installation of the confirmation boring requested above, please determine the total
saturated thickness for the 1992Peel pump tests and revise the de-watering corrections in
the February,1993 Peel Report.
A.
B.
C.
Mr. Harold Roberts
March 7,2002
8.
Page 6
- review
of Figure 9 of the November 12,2001HGC Report shows a number of important geologic
data were omitted from or inaccurately displayed on the HGC hydrogeologic cross-secti,on,
including:
A. Missing Well Total Depth - the total depth of the temporary wells was not included on
the HGC cross-section for any of the wells displayed. Please revise the section to include
this information. In one case, TW4-3, the elevation of the well's total depth ,5491feet
above mean sea level (ft amsl), falls below the lowest elevation provided on the cross-
section (see Attachment l, below).
B. Missing Jmb Contact Elevations - the elevation of the Jmb contact in each well has also
been omitted from the HGC cross-section. This information is important in order to
understand the relationship between the conglomeratic zones and the base of the shallow
aquifer. Please revise the cross-section to include these data.
C. Missinq Conglomeratic Zones - review of the IUC geologic logs for the eight temporary
wells found on the HGC cross-section shows several conglomeratic zones have been
omitted from the figure, including:
1) Conelomeratic Zone Above the Jmb Contact - including a12.5 foot thick zone in
TW4-9 (see Attachment 1, below).
Conslomeratic Zones Below the Jmb Contact - review of the IUC geologic logs for
Sry4l.AqgestioS slgy that conglomgr4qre _zo4gllryqlq fqg observed at or below
the Jmb contact in 5 of the 8 wells disptay-cl on tne ftCC sectiorlse" Attachment 1
below). These include wells TW4-5, TW4-9, TW4-3, TW4-7, and TW4-6.
Please revise the cross-section to include all lithologies found in each well.
D. Thinner Conslomeratic Zones in Two Wells - the HGC cross-section indicates that the
conglomeratic zones in two separate wells were approximately 5 feet thick, including
T:W4-4 and TW4-6. However, review of the IUC geologic logs shows that these
conglomeratic intervals were only 2.5 feet thick. Please revise the cross-section for these
two wells.
After DRC revision of the HGC hydrogeologic cross-section it is apparent that several
isolated conglomerate zones occur in the Brushy Basin Shale that are not likely hydraulically
connected. This is not unreasonable in that these conglomeratic zones in the Cretaceous-age
Burro Canyon Formation (Kbc) were deposited in a fluvial depositional environment.
In a similar fashion, the Kbc conglomeratic zones seen above the Jmb contact may also be
disconnected hydraulically. Please justify why the Kbc conglomeratic zones, found in the
eight wells are hydraulically connected to one another. Please explain how such
interconnection is possible in light of the above discussion of how the 1999 HGC high rate
pump test was inconclusive in demonstrating the presence of a high permeability interval at a
depth of about 92 ftbgs in well lyfw-4.
2)
Mr. Harold Roberts
March 7,2002 PageT
9. Problems with Estimated Thickness of the Alleeed High Permeabilitv Zone in Well MW-4 -we acknowledge that the November 12,2001HGC report made an attempt to estimate the
thickness of the alleged high permeability interval in well lvIW-4 near the 92 ft bgs depth.
However, based on the above comments and discussion the presence of such a high
permeability zone near the 92 ft bgs interval in well NtW-4 is unsupported. Consequently,
the above issues, including partial penetration and aquifer de-watering during the pump tests,
among others, must be resolved first before DRC staff will consider the HGC arguments
regarding the thickness of the alleged zone in question.
10. Request for Additional Monitoring Well Near MW-4 - based on these findings, we conclude
that well IVIW-4 does not fully penetrate the shallow aquifer. Determination of true local
aquifer permeability at MW-4 will require correction of the partial penetration effects on
pump test drawdown and determination of true aquifer thickness in this well. In addition,
well MW-4 is the focus of an ongoing chloroform contamination investigation. Partial
penetration in this well has the potential of underestimating true chloroform concentrations in
the shallow aquifer at this location due to the effects of remote screen placement (617 t}l
DRC Request for Information, Attachment 1, p. 4, Item 1C). Therefore, in light of the above
mentioned concerns and shortcomings regarding completion and aquifer permeability testing
of well MW-4, we request that IUC install an additional monitoring well immediately
adjacent to MW-4 that fully penetrates the shallow aquifer. Please provide a work plan and
schedule for installation of this new monitoring well.
In order to expedite both the State groundwater permitting process and the chloroform
contamination investigation, please resolve the above concerns and provide the requested
moni'toring well workplan within30day"s-of+eeeipt of+is-l€tte+Jf it would be helpful, we
happy to meet with you to discuss these issues and concerns. If you have any questions
regarding the above comments and concerns, please call Loren Morton of my staff at (801) 536-
4262. Thank you for your cooperation in this matter.
Sincerely,
WJSILBM:lm
attachments: References
Figure I
Attachment I
cc: Bill von Till, NRC-Washington, D.C. (with attachments)
F:\.. .MW-4PumpTest.doc
Iile: IUC Groundwater Permit, Hydrogeologie Repors
Mr. Harold Roberts
March 7,2002 Page 8
References
Driscoll, 1986, Groundwater and Wells ,zndEd.,Johnson Division, St. Paul, Minnesota, 1089 pp.
Hydro Geo Chem,Inc., September 28-29,1999, unpublished fieldnotes by Stewart Smith from
pump test work performed on IUC well MW-4, submitted to DRC on 10/18/0l,pp.15-27.
Hydro Geo Chem,Inc., October 15,2001,6 electronic data files named Mw4dwntl.dat,
Mw4testl.dwn, Mw4testl.pmp, and Mw4dwnt2.dat, Mw4test2.dwn, Mw4test2.pmp;
received by DRC on 10/18/01.
Hydro Geo Chem,Inc., November l2,200l, "Evaluation of Hydraulic Test Data at MW-4 White
Mesa Uranium Mill Site Blanding, IJtah", unpublished consultants report, 10 pp., 9 figures,
3 attachments.
Hydro Geo Chem,Inc. December 12,2001, facsimile transmission of depth to groundwater
before the L999 HGC pump tests in IUC well MW-4, unpublished consultants information,
1p.
Hydro Geo Chem, Inc., December 2L,2O01, facsimile transmission regarding pressure transducer
depth during 1999 HGC pump tests of IUC well MW-4, unpublished consultants data, 1 p.
International Uranium Corporation, June 22,20Ol, "March 20,200I IIDEQ ktter and Request
for Additional Site Hydrogeology Information in Response to ruSA September 8, 2000
Rev,ised @oundwaterlnformationRepotr- unpublished-comparlylesponse,20 pp., 14
attachments. Includes June 21, 2001 HydroGeoChem Inc. Report entitled "Review of 1994
Drilling Program Results", unpublished consultants report, 5 pp., I table, 1 figure, 3
attachments.
Peel Environmental Services, February, lgg3, "Groundwater Study White Mesa Facility
Blanding,IJtah", unpublished consultants report, approximately 55 pp., 5 appendices.
Utah Division of Radiation Control, March 20,200l, "September 8, 2000 Revised Groundwater
Information Report: Groundwater Discharge Permit Application for White Mesa Mill:
Request for Additional Site Hydrogeology Information", unpublished agency information
request, 10 pp., 3 attachments.
Utah Division of Radiation Control, June 7,200l, "October 4,2000 IUC and HGC Investigation
of Elevated Chloroform Concentrations in Perched Groundwater at the White Mesa
Uranium Mill Near Blanding, Utah: August 23, L999 Utah Division of Water Quality
Notice of Violation and Groundwater Corrective Action Order; Docket No. UGW20-01:
Request for Additional Information.", unpublished agency request, 2 pp.,8 attachments
(Attachment l: DRC "Findings and Requested Information Regarding the October 4,2OOO
ruC/HGC Chlorform Investigation Report", 9 pp.).
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MW4-99PT.xls - x-sec 1l23t12
Michael O. travitt
Governor
Dianne R. Nielson, Ph.D.
Executive Director
William J. Sinclair
Director
Sq*Ril*$\ {" thilHEr
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF RADIATION CONTROL
168 North 1950 West
P.O. Box 1214850
Salt lake City, utah 84114-4850
(801) s36-4250
[phone] Fax
[phone] T.D.D.
www.deq.state.ut.us Web
MEMORANDUM
From: Loren Morton ,1""^ A ./'kF-
To: Bill Sincla r, q9
Date: November 15,2001
Re: Recent Meetings and Conference Call with International Uranium Corporation Regarding
Hydrogeologic Conditions at White Mesa Mill: October 4,18, and 24.200L.
The purpose of this memorandum is to document discussions and agreements made in two (2)
separate meetings on October 4 and 18, 2001 with International Uranium Corporation (ruC)
regarding characterization of local hydrogeologic conditions. An October 24,2001conference
call was also held in follow-up to these meetings. Each meeting and conference call is
summarized below.
General Hvdroeeoloeic Issues (L0/4/01 Meetine) - attendees inctuded:
Harold Roberts(IUC), Stewart Smith (Hydro Geo Chem[HGC]), and Bill Sinclair and Loren
Morton (DRC). Items discussed during this 10/4/01 meeting are summarized below:
1. Path Forward: Hydrogeologic Issues - some discussion was held regarding the need to
resolve DRC technical concerns regarding local hydrogeologic conditions at the White Mesa
facility in order to allow issuanee of the State Ground Water Discharge Permit (Permit). To
this end, the following goals were agreed upon:
A. Resolve Technical / Hydrogeologic Concerns: December 31, 2001
B. Deliver Draft Permit for IUC Review: March, 2002.
2. RCRA Groundwater Monitoring Approach - during the meeting, DRC staff explained the
RCRA approach to groundwater monitoring at potential discharge facilities, as follows:
A. Combination of Leak Detection and Groundwater Wells - typically a RCRA approved
waste disposal facility will combine a high efficiency leak detection system (LDS)
beneath the waste embankment with groundwater monitoring wells located immediately
adjacent to each potential discharge point or "solid waste management unit" (SMU).
B. RCRA LDS Design - is organized with at least two (2) flexible membrane liners (FML);
with the primary or upper FML underlain with both a geonet layer and a secondary or
Memorandum
November 15,2001
Page2
lower FML material. In this configuration the intervening geonet forms a high efficiency
leak detection layer that easily and readily diverts leakage to a collection sump where
easy measurement and detection is made available via an access pipe. The LDS access
pipe then forms the primary point of compliance for the facility. In addition, best
available technology policy for LDS provides for:
1) Allowable leakage or flow rates from the LDS collection sump, and
2) Maximum average heads over the lower FML
Despite these controls, it is still possible for small leakage to occur from the lower FML.
For this reason, discrete groundwater monitoring is also required under the classic RCRA
approach.
C. Groundwater Monitoring Wells: Discrete Early Warning - groundwater monitoring
wells are installed around each potential discharge point to allow discrete monitoring of
each tailings cell or SMU. Each monitoring well is installed in close proximity to its
potential discharge point so as to provide the earliest warning that a contaminant release
from the liner has arrived at the groundwater table. Such early warning allows the
operator to intervene early in the event of a release; thereby minimizing damage to the
environment and cost of groundwater remediation.
3. Existing Tailing Cells LDS: DRC Conclusions - during the meeting DRC staff shared their
conclusion that the existing design and construction of the existing LDS layers under IUC
tailings cells 1, 2, and3 does not:
A. Constitute a high efficiency LDS system; and hence would not provide early warning of a
contaminant release from a tailings cell,
B. Is not equivalent to the classic RCRA LDS design or performance, and
Both parties agreed that the existing LDS under the IUC tailings cells would only be able to
detect a catastrophic FML failure. As a result, certain small volumes of seepage could be
released from the tailings cells and go undetected by the existing tailings cell construction.
4. IUC Concerns With Discrete Groundwater Monitorin&- IUC staff expressed concerns with
installing discrete groundwater monitoring wells between Cells 1 and2, and2 and 3, based
on:
- that could be inflicted during drilling of
any new wells. DRC staff found this argument to be insignificant or of negligible risk.
- ruC staff asked that credit be given to the
poor quality of groundwater in the perched or uppermost aquifer, that renders the aquifer
unfit for human consumption. DRC staff explained that:
A.
B.
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November L5,200I
Page 3
1) Under the Utah Ground Water Protection Rules all groundwater is protected to one
degree or another, and
2) That an aquifer of limited beneficial use allows the site operator the luxury of extra
time to investigate and respond to a contaminant release,
3) Limited beneficial use does not waive or in any way relinquish the operator from
conducting representative groundwater monitoring.
IUC then asked that DRC staff discuss this issue with the Division of Water Quality(DWQ), to determine applicable policy of the Utah Water Quality Board. This meeting
was later held with DWQ on October 18, and is summarizedin another DRC
memorandum.
5. DRC Guidance for Additional Monitoring Wells Needed - during the meeting, DRC staff
outlined locations at the facility where additional monitoring wells are needed, including:
A. Discrete Monitoring Wells - between existing tailings Cells I and}; and Cells 2 and,3,
pursuant to the discussion above.
B. West Side of Existing Tailings Cells - the existing IUC monitoring well network is
designed with the assumption that local groundwater flows from North to South.
Recently, groundwater has been discovered to flow to the Southwest near the tailings
cells; apparently in response to a source of artificial recharge along the Northeast part of
the facility between existing wells MW-4 and MW-19. Consequently, additional wells
are needed along the West side of the existing tailings cells in order to respond to the
newly discovered groundwater flow direction.
C. East Side of Existing Tailings Cells - the chloroform plume currently under investigation
at the facility appears to be located along the Eastern margin of the facility.
Consequently, additional monitoring wells are needed along the East side of the existing
tailings cells to allow distinct monitoring of the tailings from the nearby chloroform
plume.
D. Additional Piezometers - head monitoring is needed in certain areas of the facility in
order to define and characterize local groundwater flow directions. This is especially true
in the Eastern portion of the facility where large head increases have been observed in
recent years in wells MW-4, Mw-11, Mw-18, and MW-19. In such cases, it is DRC
practice to require installation of piezometers for this purpose. Such piezometers can be
installed as permanent, small diameter wells used for only head monitoring of the
uppermost aquifer. Water quality sampling of these wells may not be required.
Consequently, they need not be of large diameter to allow sampling pump access.
Locations where these piezometers are needed include: the Northern Wildlife Ponds and
the Southern Wildlife Ponds. IUC staff agreed to consider installation of some
piezometers for this purpose.
Memorandum
November 15,2001
Page 4
E. Engineering Design Considerations: New Tailings Cell Locations - the exact number
and location of monitoring wells required will also need to consider the location of future
tailings cells that might be constructed. If possible, new wells should be designed and
located such that the addition of new tailings cells does not force IUC to close and
abandon new monitoring wells.
6. 9/25101 IUC Monitoring Well Effectiveness Evaluation Report - DRC staff acknowledged
receipt of a9125101 HGC Monitoring Well Effectiveness Evaluation Report. DRC staff
committed to provide preliminary comments on this report before the 10/18/01 meeting. The
comments are found in Attachment 1, below. Review of this report will be completed before
starting any other IUC report
7. Additional IUC Reports to Review - ruC provided a list of additional reports submitted for
DRC review, see Attachment 2, below. Both parties agreed that after completion of the
9l25l0l HGC Report, that theTll3l}l (Background for New Indicator Parameters) and
l0l3l01(Compliance Ranges for Groundwater Protection) IUC reports will be reviewed next
by DRC.
8. IUC Reclamation Plan - DRC staff reiterated that review of this report was not urgent for
purposes of issuing the Permit. However, IUC re-emphasized their desire that this report be
reviewed and DRC conditions agreed to before Permit issuance.
9/25101 HGC Monitorine Well Network Evaluation Report
(L0/18/0lMeetine) - attendees included: Harotd Roberrs (ruc), Stewarr smith (HGC),
and Loren Morton (DRC). Discussions during this meeting primarily focused on the I0/I6t0l
DRC preliminary email comments on the 9l25l0l HGC monitoring well network evaluation
report. Major points discussed during this meeting are outlined below.
1. TRACRN Model Details - during the meeting Stewart Smith provided a user's manual for
Version 1.0 of the TRACRN Model he used to predict the transverse width of the
groundwater plume at the IUC facility. Mr. Smith also provided copies of the electronic
input and output files for the model, as requested in the l0tl6t0l DRC email (see Attachment
1, below). Mr. Smith also explained that:
A. Model Applicability - TRACRN is a 3-dimensional finite difference
unsaturated./saturated flow and transport model developed by Los Alamos National
Laboratory (LANL) and written in Fortran. Mr. Smith claimed that TRACRN is the best
code he is aware of to do coupled vadose and saturated zone flow and transport
simulations.
B. Proprietary Model - Mr. Smith explained that although the original code was public
domain, it later became proprietary when HGC hired the LANL author (Mr. Brian
Travis) to write a biodegradation algorithm to interface with the model.
Memorandum
November I5,200I
Page 5
C. Computationally Intensive - the TRACRN model was written to run on a Cray
supercomputer, and hence is extremely demanding on computational resources. At HGC,
the simulation run for the 9l25l0l report was executed on a very fast Silicon Graphics
workstation with a dual processor, and still took about five (5) hours to complete each
simulation. Mr. Smith estimated that if the model were compiled to run on a PC
platform, each simulation might take l0-times longer to run.
D. 2 Versions of Model - two (2) versions of the TRACRN model exist at LANL, including
capability for either decoupled or coupled gas and tiquid flow. The decoupled version is
apparently more robust and easier to use due to less numeric convergence problems.
2. Model Layer Thickness - Mr. . Smith explained that:
A. Vertical domain in the model was 95 feet thick.
B. 10 layers were assigned in the 9l25l0l model with the uppermost layer (Layer 1) assigned
as l-foot thick, and the lowermost layers, Layers 9 and 10, assigned as l0-feet each.
Layers 9 and 10 were also assigned as saturated, and thus represented the aquifer
underlying the White Mesa facility.
C. Cell leakage was assigned to occur at a depth of 25 feet below grade; leaving a vadose
interval of 75 feet. This 75-foot interval was apparently divided evenly between model
Layers 2 thru 8 (-10.7 ft each).
D. Typically care is needed to assigning layer thickness in a finite difference model in order
to avoid numeric convergence problems. This is generally done by ensuring that
adjoining layers are no more than 2-times thicker than the overlying layer. However, Mr.
Smiths reported that the TRACRN model is very robust in this regard and is rather
forgiving of abrupt layer thickness transitions.
3. Model Time Domain - Mr. Smith said the simulations were run for 1,000 years.
4. Contouring of Model Results - Mr. Smith explained that he used the commercial contouring
software Surfer @ to draw the contours provided in Figures 2 tfuu 8 of the 9t25tol HGC
report. To decrease the computation time, Mr. Smith used a plane of symmetry technique to
divide vertical model domain in half. Reportedly, this plane of symmetry ran vertically thru
the near-saturated zone. To restore the results to the full problem, Mr. Smith simply copied
the output matrix to make a mirror image for the other half of the vertical domain. Then the
complete output matrix was then contoured using Surfer.
5. Vadose Zone Permeability - Mr. Smith explained that he assumed the vadose zone exhibited
the same permeability as the perched aquifer at the site. This permeability was determined
from the geomean hydraulic conductivity determined from nine (9) wells closest to the
tailings cells, including IUC wells: Mw-2, Mw-4, Mw-5, Mw-l l, Mw-12, Mw-14, Mw-
15, MW-16, and MW-17. Permeability from these wells was based on both aquifer slug and
pump tests. DRC staff agreed to review and confirm the geomean permeability used.
Memorandum
November 15,2001
Page 6
6. Unsaturated Zone Characteristics - Mr. Smith explained that the unsaturated characteristics
were taken from taken from two (2) general sources, as follows:
A. Brooks-Corey Fitting Parameters - literature values were selected from a datacatalog
authored by Case, et. al. (see Attachment 3, below). As reported, Mr. Smith determined
bubbling pressure (P6), pore size distribution coefficient (1,), from the following soiUrock
types in Case et. al:
1) Fine Sand - to represent the drain layer immediately below the tailings cell (model
Layer 1), and
2) BereaSandstone and the Hygene Sandstone - to represent the sandstone formations
below White Mesa (model Layers 2 -10).
As for why these literature values are representative of field conditions at the IUC
facility, Mr. Smith had little to offer, except to say that the characteristic curves of the
above three (3) materials were very similar.
B. Porosity (n) and Irreducible Saturation (SJ - Mr. Smith explained these values were
taken from the DRC summary spreadsheet of aquifer material properties. However, he
had culled the last five (5) values from IUC wells MW-16 (3 values) and MW-17 (2
values), which he believed represented the Brushy Basin Shale.
C. Constrictivity Coefficient (t ) - Mr. Smith explained that this model input was similar to
tortuosity for aquifers, in that it describes pore-throat geometry, and is most important for
diffusion processes of transport. If advective processes are most important at the White
Mesa site, it would appear that this model input is likely not sensitive in the TRACRN
model.
7. Dispersivity: Same Values for Vadose and Saturated Zones - Mr. Smith explained that the
TRACRN model assigns a single fixed dispersivity for each of the 3 model dimensions,
including the "x" and "y" horizontal directions , and the "2" verticaldirection.
Unfortunately, the model does not allow the user to assign different dispersivity values for
either the unsaturated or saturated zones; one (l) set ofvalues does all.
8. Vadose Zone Dispersivity is Insignificant - Mr. Smith argued that vadose zone dispersivity is
relatively insignificant in controlling the footprint of the contamination at the water table due
to the larger effects ofadvection caused by non-linear unsaturated characteristics ofthe
vadose materials (e.g., permeability). Central to this argument is the concept that a leak from
a model node sets up a zone of near saturation immediately underneath it, see Figure 1,
below (S - 0.8). Laterally from this central column are rings or zones of lesser saturated
intervals found below and outward from this central zone. Across these zones of variable
saturation, the in-situ moisture content decreases by almost l-order of magnitude. Because
unsaturated permeability is an exponential function, this l-order decrease in moisture content
causes a much larger decrease in vadose zone permeability, at the outward margins of the
vadose zone plume. As a result of this unsaturated permeability distribution, ttre majority of
Memorandum
November 15,2001
PageT
the contaminant mass flux in the vadose zone will be constrained to the central zone of
highest saturation. Further, Mr. Smith argued that the contaminant concentration at the outer
margin of the vadose plume could be 2-orders of magnitude lower than the central near-
saturated zone.
Figure 1
Ground Level ffi
s-0.8
Mr. Smith also argued that any vadose zone contaminant plume footprint would be further
altered upon arrival at the water table, where additional dilution would be caused by dispersion
and advection in the saturated zone. As a result of this horizontal movement of groundwater, any
vadose zone contaminant footprint would become smaller in area, as measured perpendicular to
the horizontal groundwater flow. This reduction in contaminant cross-sectional area in the
aquifer would apparently be governed by a ratio of the vadose zone (qr) and horizontal saturated
zone (qh) fluxes , i.e., qu / qr,.
9. Field Scale for Saturated Dispersivity - Mr. Smith agreed that use of a lOVo fraction of the
field scale is an appropriate factor for determining longitudinal dispersivity in the aquifer
layers of the model. Mr. Smith stated that the scale of the facility is about 6,000 feet, taking
into account the distance from the North side of Cell I to the South side of Cell 44; and
therefore felt a 2,000 foot field scale basis used in the model was conservative. In contrast,
DRC staff explained that the field scale should be based on an individual tailings cell basis,
and not a combination of the four (4) tailings cells at the facility. This DRC approach would
suggest that the field scale should be smaller than 2,000 feet.
10. Contaminant HalfJife - Mr. Smith explained that the TRACRN model uses two (2) numeric
solution techniques, implicit and explicit. Mr. Smith stated that the implicit method was
used, which by definition provides for no contaminant decay in the model. This same
solution method also allows transport via equilibrium kinetics and sorption.
o
Memorandum
November 15,2O0I
Page 8
11. Contaminant Sorption Coefficients - Mr. Smith stated that he set the sorption coefficient in
the TRACRN model equal to "0" to represent a conservative contaminant or tracer. Mr.
Smith agreed that use of a non-zero sorption coefficient would decrease the transverse width
of the contaminant plume in the aquifer.
12. Model Grid Size --Mr. Smith explained that the model grid size of 40 ft (transverse to aquifer
flow) by 100 ft (parallel to saturated flow) was arrived at empirically, in that a balance was
needed between the computational demands of the TRACRN model and the need to avoid
build up of head in the source cell under the FML. In other words, if a smaller grid size were
used it would require more computer time to run the simulation, and the more likely that the
fixed flux released would accumulate head on the bottom of the drain layer sand (model
Layer 1). Conversely, the larger the grid size, the more likely unsaturated conditions could
be rendered in Layer 1, and less computer time needed to run the model.
DRC concern in this area focused on how decreasing the size of the source cell may effect
the size of the vadose plume footprint on the water table and subsequently the transverse
width of the aquifer plume. Mr. Smith stated that a decrease by a factor of two (20 ttby 100
ft) would likely have little impact on transverse aquifer plume width after many years of
travel time (> 50 years).
13. Model [rakage Rates - Mr. Smith said he based the 1.0 and 0.1 gpm leak rates used at the
model's source cell on calculations made in the l2t3ll98 Knight Piesold (KP) report. No
effort was made by Mr. Smith to verify the KP calculations. However, Mr. Smith reported
that the KP calculations were based on diffusion flux thru the FML, which were assumed to
be uniformly dispersed across the entire footprint of the tailings cell. As a conservative
assumption, Mr. Smith assigned that aggregate flux value for the entire footprint to the 40 ft
by 100 ft source cell area. Mr. . Smith also acknowledged that if lower leakrates were to be
used in sensitivity testing of the TRACRN model, that both the vadose and saturated plume
geometry would be smaller. However, at some point the source term flux would become solow that the model would experience computational problems when simulations did not
converge on a solution. No further information was provided by IUC on why the 1.0 and 0.1
gpm leak rates are representative or conservative of site conditions.
14. Model Initial Conditions - Mr. Smith stated that for vadose zone flow, the initial saturation
was set equal to the residual saturation value (S.). For the contaminant transport, the source
node was set equal to a value of 1.0. All other nodes in the domain were setiqual to a "0"
concentration.
8/31/01 DRC Draft Memorandum: Hvdroeeoloev Issues (10/18/01
Meetine and 10/24101 Conference Call) - on both occasions the attendees
included Messrs. Harold Roberts (ruC), Stewart Smith (HGC), and Loren Morton (DRC).
Discussions which began during the 10/18/01 meeting were culminated during the lOl24t0l
conference call. Prior to the call Mr. Smith provided a facsimile which is found below in
Memorandum
November l5,2OOl
Page 9
Attachment 4. Both of these discussions are summarized below. References in parentheses refer
to the item and page number from the 8/31/01 draft DRC memorandum.
1. Resolution Plan and Schedule for Well MW-4 (Item 2. p. 2) - as for the need to install a new
well to confirm the geologic contacts in this well, DRC staff agreed to defer this decision
until after IUC provides results from passive diffusion bag (PDB) sampling from this well.
2. Test Well 17 fitem 3. p. 3) - ruC staff agreed that plugging and abandoning this well can be
included as a compliance schedule item in the upcoming Ground Water Discharge Permit
(Permit).
3. Site Land Survey (Item 4. p. 3) and Survey of Contact Seeps and Springs (Item 5. p. 3) - ruC
explained that requested information had already been included with the new survey results
submitted with the 9l7l0l IUC transmittal letter. DRC staff agreed to review this material
and respond.
4. Former Lab Wastewater Tank Drain Pipe (Item 6. pp .3-4) - both parties agreed that this
issue could be managed under the Ground Water Correction Action Order (Order).
However, Mr. Roberts recalled that the tank in question:
A. Was a buried fiberglass tank that received the sink and floor drain wastewater from the
office building laboratory, and
B. The drain line from the tank discharged due west into Tailings cell l.
Mr. Roberts agreed to investigate to see if the tank was still buried there and to double check
on its construction materials, including the drain lines to Cell 1.
- Mr. Roberts agreed
to provide DRC a plan and schedule for additional piezometers to investigate the cause of the
increasing heads apparently near the Northern and Southern wildlife ponds.
6. Aquifer Permeability (Item 8. pp. 4-6) - Mr. Roberts suggested these concerns be resolved as
follows:
A. Missing Dames and Moore Data - Mr. Roberts explained that the Dames and Moore raw
test data from borings 3, 9, 12, and 28 is missing, and held out no hope of ever finding it.
Consequently, both parties agreed to consider the data lost and ignore the Dames and
Moore reported permeability results.
B. 7/91 Hydro-Engineering Data: Now Deemed Unreliable - Mr. Smith stated he also had
difficulty in replicating the permeability results reported in the 7l9l Hydro-Engineering
(H-E) Report. Consequently, both parties agreed that the aquifer testing reported in
the2l93 Peel Environmental Report (Peel) appeared to be more reliable. During the
10/18/01 meeting a review was made of the available permeability data for the existing"M\ lr" series monitoring wells (see draftSl3ltOl DRC memorandum, Attachment 1).
This review found redundant aquifer permeability test data was available for all the
7.
Memorandum
November 15,200I
Page 10
existing "M\ryr" series wells at the facility in the 2193 Peel Report, with the exception of
well MW-5, which was only reported in the 7l9l }J-E Report. To provide reliable aquifer
permeability data for MW-5, Mr. Roberts proposed the following:
1) Call H-E - to secure a copy of the N/fW-5 raw aquifer test data, if available, and
2) Re-do the Aquifer Pump Test - in well MW-5 during the next couple of months.
IUC staff suggested that pump testing of well MW-5 could easily be combined with
testing for the new "T'W" series wells. IUC also agreed to notify DRC of when the
proposed pump tests will be conducted, so as to allow DRC staff to observe the testing in
the field.
C. Spatial Distribution Findings - both parties agreed to defer any analysis of spatial
distribution of aquifer permeability until after completion of new pump testing by IUC
and agreement by both parties as to the results derived therefrom.
Water Table High Near MW-4 (Item 9F. p. 8) - Mr. Smith agreed that higher head has been
observed in well MW-4, as compared to its nearby companion wells. However, Mr. Smith
attributes this higher head to aquifer heterogeneity and locally confining conditions in well
MW-4. Mr. Roberts also suggested that the former groundwater elevations may have
changed somewhat after re-survey of the measuring point elevations for the site wells (9/7/01
IUC submittal). DRC staff agreed to 9l7l0l IUC topographic map and well survey
information, and re-visit the relative head elevations in well MW-4.
Unexplained Change in Hydraulic Gradient Near Wells TW4-4 and 6 (Item 9G. pp. 8-9) -this change in hydraulic gradient is apparent North of the Southern Wildlife Ponds near wells
TW4-4 and 6. Mr. Smith argued that:
A. The apparent gradient reversal may be an artifact of non-uniform data distribution , data
kriging and data grid construction by the Surfer @ software used by DRC staff, and
B. The historic head trend in near by well MW-17, located about 1,500 feet West, shows
little head increase over its period of record; especially when considered to the 20 + foot
increase in seen in well IvtW-4. Consequently, it is possible that the Northern Wildlife
Ponds may have a greater influence on local groundwater flow directions than the
Southern Wildlife Ponds.
Mr. Roberts also added that:
C. The Southern Wildlife Ponds were not constructed until 1994.
D. The more Northern pond at this location was a historic stock watering pond used by local
ranchers before construction of the mill. During this time, it collected mainly ephemeral
rainwater/snow melt for local stock animals. After I994,\lC began supplying a constant
head in both of the Southern Witdlife ponds.
8.
Memorandum
November 15,2001
Page 11
DRC staff agreed to take this new information under advisement.
9. Unknown Mechanism for Chloroform Travel to MW-4 (Item 9H. p. 9) - new information
regarding N[W-4 pump test data was provided DRC staff during the l0l24lO1 conference call.
Previously, cursory DRC review of the 2193 Peel pump test drawdown curye suggested that
casing storage effects explained the long flat-line response in the early portion of the test, i.e.,
thru about 200 minutes of pumping (see 2193 Peel Report, Appendix C). However, Mr.
Smith argued that part of this early flat-line response was due to high permeability conditions
in the aquifer, as evidenced by:
A. Small Casing Volume vs. Long Aguifer Response - review of Peel pump test data
suggests that one (1) casing volume at the time of the MW-4 test was equal to about 6
gallons. At the pumping rate used by Peel, 0.46 gpm, this casing volume would have
been removed from IvtW-4 in about 13 minutes. In contrast, the early flat portion of the
Peel drawdown curve extends beyond 165 minutes. Consequently, the early-time
drawdown response represents a higher zone of permeability in the aquifer. Meanwhile
the steeper late-time response represents a zone of lower permeability.
Since the l0l24l01 conference call, DRC staff took a close look at Mr. Smith's argument.
Critical pumping time calculations were made for by DRC staff in accordance with
method proposed by Driscoll (p.233). From this review, DRC staff agree with Mr.
Smith that the early-time response of the 2/93 Peel Report appears to represent a higher
permeability zone in well MW-4, as found between about 26 to 165 minutes into the test
(see Attachment 5, below).
B. 1999 HGC MW-4 Stepped Rate Pump Test: Head vs. Time Graph - in 1999 HGC
performed a stepped rate pumping test on MW-4. From this test, Mr. Smith derived a
graph of standing head in the well vs. pumping time (see Attachment 4, below; HGC
Item 10). From this graph, an abrupt break in slope occurs at a standing head of about 16
feet, which equates to about 95 ft below the top of casing (btoc), or about 93 ft below
ground surface (bgs), after consideration of the well stick-up (1.56 f0. A similar break in
slope occurred during the recovery portion of the 1999 HGC pump rest (ibid.). Mr. Smith
admitted that the thickness of this high permeability zone is currently unknown, but
speculated that it may be 2-3 feet thick.
C. Nearby Well Logs: Conglomeratic Intervals - the available geologic log for well MW-4
is cryptic (Tl94TitanEnvironmental [Titan] Report, Appendix A). However, Mr. Smith
provided a draft cross-section to illustrate a conglomeratic zone found in several of the
"TWr" series wells,located near well MW-4 (see Attachment 4 below, HGC Item 7). Mr.
Smith asserted that this conglomeratic zone could be the cause of the higher permeability
zone seen in well MW-4.
D. Contribution of Multiple Zones to Well Yield - Mr. Smith also provided some
calculations to document the relative water yield to a well from two (2) different zones ofpermeability (see Attachment 4, below; HGC Item 11). From this analysis, Mr. Smith
Memorandum
November 15,200I
Page 12
estimated that9TVo of the pump test yield from well MW-4 came from the high
permeability zone seen at a depth of about 95 ft btoc.
Mr. Smith acknowledged that none of the 1999 HGC pump test information has been
provided to the DRC to date. Mr. Roberts agreed to have a detailed report prepared by HGC
and submitted to the DRC by November 15, 2001.
Comparison of the well completion diagram for well MW-4 also provides some noteworthy
information. The Tl94TitanReport states that the top of the perforated interval in well MW-
4 was set at a depth of 92 feet bgs. As a result, it appears that the screen in this well may
only intercept l-foot of the higher permeability zone reported in MW-4. If true, an additional
well or a replacement well may be needed near MW-4.
10. Status of Well MW-16 fitem 9I. p. 10) - previously DRC staff recommended that well MW-
16 be deepened or replaced because it failed to intercept the shallow water table (see 8t3l/OI
Draft DRC Memorandum, p. 10). However, Mr. Smith argued that well MW-16 could have
easily been completed at the Jurassic-age Brushy Basin shale (Jmb) contact, based on:
A. MW-16 Well Construction / Logging - the geologic log'for this well, prepared by Peel
Environmental Services, was based on continuous core samples drilled between 20 feet
bgs to the well's total depth (91.5 ft bgs, see Ttg4TitanReport, Appendix A). Although
the Jmb contact can be gradational, ruC assumes that the geologist properly located thi
well's screen interval immediately above the Jmb contact.
B. Thin Saturated Thickness in Nearby Well MW-12 - nearby well MW-12 is found about
900 feet North of well MW-16. During the November,2000 split sampling event, the
water level found in well N/fW-12 equated to a saturated thickness of about 6 feet at this
location.
C. Small Structural Rise - a small structural rise, say l0-feet, over the 900 foot distance
between these two (2) wetls could easily dry-out the MW-16locale; thereby forcing the
perched aquifer to flow around this area.
Mr. Roberts also added that well MW-16 is found inside the proposed footprint for TailingsCell48, and will therefore need to be plugged and abandoned before cell construction. From
this information, DRC staff made the following determinations:
D. New Well(s) for Cell48 - it makes little sense to replace or deepen well MW-16 if
tailings cell construction is imminent. Consequently, it would more effective and cost
efficient to install new monitoring wells at the perimeter of future Cell 48. However, this
decision should be revisited at a future date, if Cell 48 is not constructed in the near
future.
E. Evidence of Heterogeneity: Aquifer Pinch-out - The apparent pinch-out of the aquifer
near existing well MW-16 suggests that significant hydrologic and geologic
heterogeneity exists in the shallow aquifer. Where such pinch-outs are found, local
groundwater flow directions would be greatly altered. This apparent heterogeneity
Memorandum
November 15,2001
Page 13
reinforces the need for additional wells and borings at the site to properly characterize
groundwater flow directions at each individual disposal cell on the White Mesa facility.
F. ' Implications for Future Cell4B Design - the aquifer pinch-out apparent at well MW-16,
indicates that there is no upgradient hydrologic direction under Cell48. In this case, the
structural gradient at the Jmb contact will be critical to placement of monitoring wells.
Care will need to be taken to ensure that the Cell 4B monitoring wells are placed at the
margin of the apparent Jmb structural high where groundwater can be found.
Consequently, exploratory wells and borings will need to be installed before design of
Cell48 could be approved. In the event that these investigations show that the receiving
groundwater cannot be monitored separately or distinctly from other cells at the facility,
it may be necessary to re-design and re-locate Cell48 to a new location that will afford
discrete groundwater monitoring.
11. Fly-Ash Pond and Well 7-2 (Item 10. pp. 10-11) - during the lOl24tOl conference call, both
parties agreed:
A. Vadose Zone Anisotropy - the shallow saturated interval found in Well 7-2 represents a
different body of perched ground water in the vadose zone that is hydraulically distinct
and separate from groundwater found at the Jmb contact. The presence of this new
perched interval documents that anisotropy exists in the unsaturated formations at the
White Mesa facility. Both parties agreed that an adequate groundwater monitoring
system should be installed into the first or shallowest body of groundwater found beneath
a potential discharge source.
B. New Contaminant Source: Fly-ash Pond - ruC consultant reports indicate that the
contamination found in well 7-2was previously linked to disposal of wastewater at the
Fly-ash Pond. Mr. Roberts provided additional history regarding this disposal pond, as
follows:
1) Originally this pond was constructed as a construction water holding pond during the
time the mill site and tailings cells were built. During this time, water held in this
pond came from the mill site water well.
2) Sometime later during operation of the mill, ruC decided to dispose of fly-ash from
their coal-fired boilers in this pond.
3) Later when groundwater contamination was apparent in well 7-z,ruC ceased use of
this pond and built a new holding pond, which later became the Northern Wildlife
Ponds,
4) At some point, Umetco decided to excavate the fly-ash material in this pond and
dispose of it in Tailings Cell 1.
Mr. Roberts agreed to look for a Umetco company report that documents excavation and
removal of the fly-ash material from this disposal location. DRC staff explained that if IUC
is to avoid the need for discrete groundwater monitoring at this location, it will have to
Memorandum
November 15,2001
Page 14
demonstrate that the Fly-ash Pond no longer represents a potential groundwater pollution
source.
12. Brushy Basin Shale Structural Contour Map (Item 11. pp. 11-12) - DRC staff concerns with
the 612210l IUC Jmb structural contour map focused on a suspect Southeast plunging ridge
between wells MW-l and MW-4. With regard to this postulated ridge, Mr. Smith explained
that he:
A. Hand contoured the Jmb structural contour map provided in the 6l22tol IUC report, and
B. Based the plunging ridge on earlier structural contour maps drawn by other IUC staff /
consultants. Mr. Smith admitted that he performed no investigation to verify or confirm
the availability of geologic data to support the previous IUC interpretation.
To help resolve these concerns, Mr. Smith proposed that:
C. A field survey be completed to examine the Jmb contact at the margin of White Mesa,
both in westwater Canyon to the west and corral canyon to the East,
D. A GPS system be used to approximate the location and elevation of the Jmb contact at
these outcropping areas, and
E. The Jmb structural contour map be revised to include the outcrop information before
plans are made for additional wells at the facility.
Mr. Roberts suggested that two (2) Dames and Moore (D&M) Borings, Nos. 12 and 28, may
help shed some light on this issue. Mr. Roberts agreed to look to see if geologic logs are
available for these borings, and determine if they are located in the right location to satisfy
this question. Later, DRC review of the Tlg4TitanReport (Figure 2-1) showed only Boring
No. 12 is located in the general vicinity of well MW-l. Unfortunately, the geologic log foi
this boring shows it never intercepted the Jmb contact (ltI7l18 D&M Report, Appendix A,
Plate A-7).
DRC staff agreed that survey of the outcrop Jmb contact would be valuable information, and
asked for prior notice so as to allow a joint site visit. IUC agreed to provide this notice and
suggested that this work could be done at the time of the upcoming pump tests for the "TW"
series wells and MW-5.
DRC staff also suggested that the installation of additional monitoring wells along the North
side of Cell I could provide a significant amount of useful information to better define the
Jmb structural features at the facility. Mr. Roberts acknowledged the suggestion, but refused
to commit to drilling new wells near Cell 1 without first consulting his management and
completing the outcrop survey mentioned above..
13. Need for Discrete Groundwater Monitoring (Item 13. p. 13) - Mr. Roberts acknowledged
DRC concerns regarding the need for additional groundwater monitoring wells. However, he
refused to discuss any details regarding the 8/31101 DRC draft memorandum, pending
Memorandum
November 15,2001
Page 15
discussions with IUC management. Further, Mr. Roberts made no commitment on when
IUC will decide on how many or where any additional wells may be installed at the facility.
14. Hydrogeological Report Addendum (Item 14. p. l6) - both parties agreed that the upon
completion of any new monitoring wells, piezometers, or borings at the facility that a
hydrogeologic addendum should be prepared to document all new information gathered.
15. Well Spacing Report (Item 15. p. 16) - DRC staff agreed to continue its review of the
9l25l0l HGC Report.
16. Open Groundwater Ouality Issues (Item 16. p. 16) - both parties agreed that this review
would be completed at a later date.
17. Next Steps - at the conclusion of the l0l24l0l conference call, the following action items and
schedule was agreed to:
A. HGC Pump Test Report for Well MW-4 - to be submitted to DRC by lIllltcl.
B. IUC Documentation on Closure of the Fly-Ash Pond - Mr. Roberts will investigate and
report back to DRC within about I week (10/31/01). As of this date, no information has
been provided by IUC on this matter.
C. New Pump Tests for the "TW" Series Wells and MW-5 - a schedule for completion of
these tests is to be submitted to DRC within about 2 weeks (lllTl}l). Tests are to be
finished before January. Field reconnaissance and determination of Jmb contact
elevations will also be done as a part of this effort.
D. Plan and Schedule for Wildlife Pond Piezometers - to be submitted to DRC by late
November,2O0l.
LBIWIm
F:\...VIG_mtgsl0-0l.doc
File: IUC Well Spacing Modeling Reporrs
Memorandum
November 15,2001
Page 16
References
Dames & Moore, January, I'7,1978, "Report Site Selection and Design Study Tailing Retention
and Mill Facilities White Mesa Uranium Project Blanding, Utah for Energy Fuels
Nuclear, Inc.", unpublished consultants report, 33 pp., 9 plates, 2 appendices; found in
Appendix H of the January, 30,1978 Dames & Moore "Environmental Report White
Mesa Uranium Project San Juan County, Utah for Energy Fuels Nuclear, Inc.".
Driscoll, 1986, Groundwater and Wells ,znd Ed.,Johnson Division, St. Paul, Minnesota, 1089 pp.
Hydro Geo Chem,Inc., September 25,200I, "Assessment of the Effectiveness of Using Existing
Monitoring Wells for GWDP Detection Monitoring at the White Mesa Uranium Mill
Blanding, IJtah", unpublished consultants report, 24 pp.,1 table, I appendix, 8 figures.
International Uranium Corporation, June 22,200l, "March 20,2OOl UDEQ Irtter and Request
for Additional Site Hydrogeology Information in Response to IUSA September 8,2000
Revised Groundwater lnformation Report ...", unpublished company response, 20 pp.,14
attachments. Includes June 21, 2001 HydroGeoChem Inc. Report entitled "Review of
1994 Dritling Program Results", unpublished consultants report, 5 pp., 1 table, 1 figure, 3
attachments.
International Uranium Corporation, SeptemberT,20OL, "Updated Topographic Map, Ground
Water Discharge Permit Application for White Mesa Mill", unpublished company letter,
I p., includes topographic map and well boring and monitoring well coordinates ,4 pp.
Knight-Piesold, LLC, December 31, 1998, "Methodology for Calculation of Flux thru Cell3
Liner, White Mesa Mill", unpublished consultants letter report, 5 pp., 1 figure, I table, 3
appendices.
Peel Environmental Services, February, lgg3,"Groundwater Study White Mesa Facitity
Blanding, Utah", unpublished consultants report, approximately 55 pp., 5 appendices.
Titan Environmental Corporation, July, lgg4,"Hydrogeologic Evaluation of White Mesa
Uranium Mill', unpublished consultants report, approximately 51 pp., 5 tables, 19
figures,7 appendices.
Utah Division of Radiation Control, August 3l,2OOl, "June 22,2OOl IUC Response to March
20,2001DRC Request for Additional Site Hydrogeology Information: Staff Findings
and Recommendations", unpublished and draft staff technical memorandum, 20 pp., 6
attachments.
ATTACHMENT 1
Utah Division of Radiation Control
Preliminary Staff Comments on the
9/25101 HGC Monitoring Well Network Evaluation
for the IUC White Mesa Facility
1011610l Email from Loren Morron (DRC
to Harold Roberts (ruC) and Stewart Smith (HGC)
From:
To:
Date:
Subject:
Findings
Loren Morton
Harold Roberts; Stewart Smith
10/16/01 9:09AM
IUC:. 9/25101 HGC Report on Monitoring Well Network Evaluation - Preliminary Staff
Harold and Stewart,
As per our October 4 meeting, I have completed my review of the 9/25101 HGC Report. I am in process of
writing my comments up in a letter. Unfortunately, I am out of the office the rest of today and tommorrow,
and won't have time to complete my letter until after our Thursday, October 18 meeting. However, I can
share some of my preliminary thoughts, as outlined below. Several additional information items are
needed before I can complete my review of the 9/25101 HGC repoft, including:
1. TRACRN Model- lwillneed:
a) Copy of the user's manual and any other documentation for the code,
b) Electronic copy of the source code and executible code (PC-based) for the model,c) Electronic copy of the TRACRN model input and output files used for the 9l25lo1 HGC Reportd) Description of the layer thicknesses assigned for Layers 2 thru 8 in the model,e) Explanation of how the model results were contoured, as illustrated on the repoft's figures.
2. Additional Justification - for the following items:
a) Vadose zone permeability (saturated)
b) Vadose zone unsaturated characteristics, including: total porosity, bubbling pressure, residual
saturation, pore size distribution coefficient, constrictivity coefficient, etc. Also need explanation why the
Brooks-Corey approach used in TRACBN is representative of unsaturated characteristics in the vadose
zone at the site.
c) Dispersivity input values for both verticaland horizontalflow domains - horizontaldomain should be
based on the average size of 1 tailings cell. Ten percent of the horizontal domain is appropriate for
longitudinal horizontaldispersivity. However, a9l25lO1HGC model assumed a 2,000 foot long domain for
the horizontal path that is much greater than the size of any one cell at the facility. Vertical dispersivity
should also be based on vertical domain path length, and the 1.0 foot dispersivity appears to be greatly
under-estimated.
d) Contaminant half-life used in model
e) Contaminant sorption coefficients used in model - including soil/water and water/gas phasef) Vertical domain f low distance - p. 17 of the report says its 70 feet to groundwater; p. 19 says a 95
foot distance was modeledg) Model grid size - including source cellsizeh) Leakage rates used - including an explanation for why the 1.0 and 0.1 gpm leak rates are
representative or conservative of possible field conditions at the sitei) Model initial conditionsj) Model mass balance analysis - including both water and contaminant mass balance
3. Needed Reference lnformation - I need a copy of the 1983 Brooks - Corey reference entitled
"Unsaturated Flow Properties Data Catalog, Volume 1", as listed in the reports references.
Additional issues may be added as I put together my letter. lf you have questions regarding these
preliminary findings, we can make time to discuss them on Thursday.
See you then.
Loren
CC:Bill Sinclair; Dane Finerfrock
ATTACHMENT 2
IUC Listing of Recently Submitted Reports
To the DRC
Received l0l4l}l
S4une 22,2007 Response to March 20 UDEQ Letter
July 13, 2001 Background for New Indicator Parameters
July 17, 2001 Draft Spill Management Plan
September 7,2001 Updated Topographic Map
,,/ September 25, 2001 Assessment of Effectiveness of Using Existing
Monitor Wells
October 3,2001 Compliance Ranges for Groundwater Protection
ATTACHMENT 3
Title Sheet of IUC Reference
For Unsaturated Characteristics
Used in the 9l25l0l HGC Report
Received 10/18/01
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HGC Facsimile Submitted to
Support an October 24,200L Conference Call
Received l0l22lol
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ATTACHMENT 5
Utah Division of Radiation Control
Evaluation of Drawdown Response Data from
Well MW-4 Pump Test as Found in the
February, 1993 Peel Environmental Report
DRC Spreadsheet AquiferK.xls
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Michael O. Leavitt
Govemor
Dianne R. Nielson, Ph.D.
Executivc Dircctor
William J. Sinclair
Dircctor
*,'*N:T H*HENTAL'M
*W') @ J
DIVISION OF RADIATION EONTROL ,,.-*I.,
168 North 1950 West
P.O. Box 144850
Salt Lake city, utah 841144850
(801) s3642s0
(801) 533a097 Fax
(801) s364414 T.D.D.
www.deq.state.ut.us Web
March 20,2001
Ms. Michelle Rehmann
Environmental Manager
International Uranium (USA) Corporation
Independence Plaza, Suite 950
1050 17th Street
Denver, CO 80265
RE:September 8, 2000IUC Revised Groundwater Information Report: Ground Water Discharge
Permit Application for White Mesa Mill: Request for Additional Site Hydrogeolory
Information.
Dear Ms. Rehmann:
We have reviewed the September 8, 2000 International Uranium Corporation (IUC) Revised
Groundwater Information Report (GIR), referenced above. As you recall, our March 13, 2001 letter
outlined a three (3) part work effort to resolve remaining open issues regarding the September 8,
2000 Revised GIR. This letter represents the second part of this effort.
Our purpose herein is to outline certain technical issues remaining from the February 7, 20OO
Division of Radiation Control (DRC) Request for Information (RFI), and to request that IUC resolve
these by providing additional information. Technical information items that yet remain unresolved
are outlined below. References provided in brackets [ ] refer to relevant sections of the original
February 7,2000 DRC Rf'L
Remainins Open Issues (February 7.2000 DRC RFI)
1. Well Construction Diaerams and Geologic Loes [p. 2. Item 2.C and p. 4. Item 3] - several
wells, piezometers, and/or boring remain without well completion diagrams and geologic
logs, as already provided, see discussion below
A. Seven Wells and Piezometers [p. 2. Item 2.C.21 - we acknowledge that seven (7), not
six (6), wells and piezometers are at issue here, including three (3) wells, MW-20
thru MW-22,andfour (4) piezometers: MW9-1, MW9-2, MWl0-1, and MW10-2.
We appreciate the new survey coordinates provided for these seven (7) installations.
However, the September 8, 2000 ruC Revised GIR failed to provide well completion
diagrams for these seven (7) wells and piezometers. Please provide the required well
Ms. Michelle Rehmann
March 20,2001
Page2
B.
completion diagrams, and geologic logs for these seven (7) installations. In the event
that this information has been lost, please provide a schedule for completion of video
and geophysical logging to collect the required information.
Three Wells Formerly Named SMW-I thru SMW-3 [p.2. Item 2.C.3] - from the
description provided, it is clear that after installation these three (3) wells were
actually named MW-20, MW-21, and MW-22. We also acknowledge that new
survey coordinates have already been provided for these three (3) wells (9/8/00 IUC
Revised GIR, LANDesign map Sheet I of l). In addition, DRC staff has also visited
each of these during the last split groundwater sampling event in November, 2000.
However, please provide the following information still found lacking for these three
(3) wells:
Geologic logs - that locate the depth to the upper Brushy Basin Shale contact,
Well completion diagrams, and
Dates of well installation.
Four Geotechnical Borings: GH-l thru GH-4 [p. 4. Item 3.A.4] - from review of the
September 8, 2000 Revised GIR, it is clear that four (4) geotechnical borings were
also installed near the tailings cells in conjunction with wells MW-20 thru MW-22;
as a part of studies completed for the NRC and EPA (9/8/00 ruC Revised GIR, pp.
4-5). Apparently these borings were narned GH-I, GH-2A, GH-3 and GH-4. We
acknowledge receipt of field and laboratory permeability data from these four (40
borings in the September 8, 2000 Revised GIR (Attachment 10, Tables C-5 and C-6).
However, this report also explained how other information was collected from these
borings, including:
Wireline geophysical logs,
Wireline video logs,
Geologic logs
Please provide reliable survey coordinates and all geophysical, video and geologic
logs made for these four (4) borings.
Former Monitoring wells [p. 4. Item 3.A.4 and 3.B.2] - apparently IUC has been
unsuccessful in their attempts to provide information on former monitoring wells
now abandoned. However, additional information is required, as follows:
(l) Well MW-13 - after IUC's unsuccessful attempt to locate this information
(9/8/00IUC Revised GIR, pp.12 & 16), DRC staff found the required well
Mw-13 data in a March, 1983 Energy Fuels Nuclear (EFN) construction
C.
(r)
(2)
(3)
(1)
(2)
(3)
D.
Ms. Michelle Rehmann
March 20,2001
Page 3
Report for cell 3 (Appendix D, see I llll12 D'Appolonia consulting
Engineers letter report). Please provide reliable survey coordinates for this
well.
-1. MW MW - please
explain what efforts were completed to locate the required well completion
diagrams and geologic logs for these six (6) former wells. In the event that
new efforts find this information, please provide it with reliable survey
coordinates for each well at your earliest convenience.
n and 2.C.61- we acknowledge
your inability to produce awell completion diagram and geologic log for well MW-
3. This information is essential for determination of aquifer thickness and elevation
of the Brushy Basin Shale upper contact. At this time, it appears that there are only
two options to resolve this problem:
(l) Wireline Video and Geophysical Logs - to locate the screened intervals in the
well, and depth/elevation of the Brushy Basin Shale upper contact.
(2) Install a Confirmation Boring - in the event that the geophysical logs are
unsuccessful in locating the Brushy Basin Shale upper contact, a
confirmation boring may need to be installed near well MW-3 to allow an
adequate geologic log to be assembled.
Please provide a plan and schedule for these resolution activities for well MW-3
within 3O-days of receipt of this letter.
-we
acknowledge that no additional well construction information is available for MW-4. Close
review of the available IUC information indicates that the base of the well's screened interval
is about 13 feet above the Brushy Basin Shale upper contact (Tlg4TitanReport, Appendix
A, well completion diagram). After consideration that chloroform has been detected in this
well, it is clear that the potential exists for dense non-aqueous liquid (DNAPL) contaminants
to go undetected with this well configuration. As a result, we see no other option but to ask
IUC to complete one of the following activities:
A. Re-oerforate Well MW-4 - by cutting new perforations in the well casing, below the
existing screen interval, to allow well access to the aquifer interval in question, or
(2)
E.
2.
Ms. Michelle Rehmann
March 20,2001
Page 4
3.
B. Installation of a Second Well - in the immediate vicinity of well MW-4 to provide
a screened interval that is in direct contact with or is screened across the Brushy
Basin Shale upper contact.
Please provide a plan and schedule for one of these activities for well MW-4 within 30-days
of receipt of this letter.
Additional Geologic Information [p. 4. Item 3 and o. 1 l. Item I l AJ - several requested items
from the February 7,2000 DRC RFI remain unresolved, including:
A. Missine IUC Reports - several existing consultants reports have yet to be provided
to the DRC. Please provide the following reports:
(l) Reports Available to Titan Environmental - as listed in Table 2.2 and the
References section of the July, 1994 Titan Environmental Report, including:
(a) February, l98l D'Appolonia Consulting Engineers, ,'Assessment of
the Water Supply System, White Mesa Project, Blanding, Utah"(b) July, 1991 Hydro-Engineering, "Ground-Water Hydrology at the
White Mesa Tailings Facility"
(c) June, 1994 Peel Environmental Services, "Groundwater Study, White
Mesa Facility"
(2) Report(s) Prepared for NRC / EPA - including reports to document drilling
and hydrogeologic investigations related to existing wells MW-20 tlvu 22
and geotechnical borings GH-l thru GH-4 (see discussion above).
(3) Any Other - report related to groundwater hydrology or geology of the site.
Dames and Moore Borines 3 and 9 [p.4. Item 3.A.2] - please provide reliable survey
coordinates for these two borings at the facility.
Test Well 17 (East of Mill Site) [p.4.Item 3.B.1.| - we recognizethatlUC believes
this former test well has been plugged and abandoned. However, please provide the
following information for this well: date of well installation, geologic log, well
completion diagram, reliable survey coordinates, and a plugging and abandonment
report.
Five Dry wells and Piezometers [p. 5. Item 3.B.3] - apparently IUC was
unsuccessful in its attempts to locate the requested information for dry wells MW- 16,
B.
C.
D.
Ms. Michelle Rehmann
March 20,2001
Page 5
Mw9-1, Mw9-2, Mwl0-1, and MWl0-2. However, additional information is
required, as follows:
well MW-16 - DRC staff found awell completion diagram and geologic log
for this well in the February,'1993 Peel Environmental services Report
(Appendix A).
(2) wells MW-16. MW9-1. MW9-2. MWl0-1. and MWl0-2 - please explain
what efforts were completed to locate the required well completion diagrams
and geologic logs for these four (4) dry wells. In the event that new efforts
find this information, please provide it at your earliest convenience.
E. Two Nested Angle Borings Near Cell 4A [p. 5. Item 3.B.4J - please explain what
efforts were made by IUC to locate the requested information for these two (2)
borings. Should new efforts locate this data, please submit it at your earliest
convenience.
Land Survey Information [pp. 5-6. Item 4. p. 9. Item 9. and p. 13. Item l3] - we acknowledge
submittal of two (2) IUC maps of the facility, including:
A. August 28. 2000 LANDESIGN Site Control Map - prepared by LANDESIGN
Engineers, Surveyors and Planners of Grand Junction, Colorado, Sheet I of l, Rev.
I (submitted as a part of the September 8, 2000 IUC Revised GIR). This drawing
included a data table of survey coordinates, and a simple relative position plot for
many of the requested facilities at the White Mesa site.
B. IUC Topographic Map - provided to the DRC by Mr. Ron Hochstein of IUC on June
13, 2000. This detailed topographic map, prepared by an unknown party, provides
location details for many of the site facilities, including but not limited to: footprint
of tailings ponds, tailings pond berms, site roads, mill site, mill site product and
process storage tanks, ore storage pad, wildlife ponds, topsoil storage pads, mill
process buildings, administration building, current truck scale building, and mill site
process wastewater pond ("Roberts Pond"). This map was reportedly prepared at
I :3,600 scale (l " : 300 ft), as derived from photogrammetry data collected for the
site in February, 1999.
Review of these two (2) IUC maps shows that much of the information requested in the
February 7 ,2000 DRC RFI has been provided on one map or the other, with the exception
of the following items and concerns:
(1)
4.
Ms. Michelle Rehmann
March 20,2001
Page 6
Table
C.Combination of Site Plan and Topographic Maps [p. 9. Item 9] - forease of reference
and to facilitate preparation of future DRC hydrogeologic cross-sections and other
maps it is essential for all the required elements to be presented on a single map. For
this reason, DRC staff request that IUC combine the above site control and
topographic maps into a single map.--'Please ensure that the accessible discharge
related facilities are shown on the combined map, including, but not limited to [p.5,Item 4.A.1 thru 5, and 4.8.21: tailings ponds, tailings pond berms, existing
groundwater monitoring wells, former wells and piezometers, water supply wells,
exploratory borings, dry wells and piezometers, and the chloroform investigation
temporary wells.
Nearby Stockwaterine Wells [p.6. Item 4.A.61 - nearby stockwatering wells
constitute potential points of exposure for the facility. Please provide survey
coordinates, including ground surface elevations for both the Jet Pump and Jones
stockwatering wells located near the facility.
Nearby Contact Seeps and Springs [p. 13. Item l3l - nearby seeps and springs at the
edge of White Mesa also form potential points of exposure for the facility. Please
provide survey coordinates and ground surface elevations for all contact seeps and
springs near the facility.
Confirmation of DRC Estimated Scalehouse Leachfield Coordinates lnew item] -
after comparison of the site plan map from the October 4, 2000 chloroform
investigation report (Figure I I ) with the IUC topographic map provided on June 13,
2000, we have estimated the survey coordinates of the septic tank drainfield located
a short distance Southwest of the existing truck scale house. Please confirm the
accuracy and content of the DRC estimated survey coordinates for this leachfield, as
provided in Table 1, below:
l. DRC Estimated Survey Coordinates: Former IUC Truck Scale House Leachfield
Corner Easting (feet)Northing (feet)
Northwest 2,580,735 322,330
Northeast 2,580,800 322,330
Southeast 2,580,900 322,260
Southwest 2,580,735 322,260
lated Facilities lnew - after review of
D.
E.
F.
G.
the IUC information provided to date, DRC staff have determined that additional
Ms. Michelle Rehmann
March 20,2001
Page 7
(2)
(3)
related facilities at the site need to be located on the combined site plan and
topographic map, including but not limited to:
(1) Existing Administration Buildine Septic Tank Drainfield - reportedly located
a short distance North-Northwest of the truck scale house.
(4)
(s)
Former Administration Buildine Septic Tank Drainfield - once located
southeast of the main office building.
Former Laboratory wastewater Storage Tank and Drain Pipe - including the
location ofthe above ground tank that was once located on the North side of
the mill administration building and the pipe that drained it to the mill site
wastewater catch pond ("Roberts Pond").
Former Mill Site Sedimentation Pond - also known as the fly-ash pond(6179
D'Appolonia Design Report, Sheet 4 of l6).
Former Solid Waste Landfill - located near one of the wildlife ponds East of
the mill site.
5.
Please ensure that the survey coordinates for all of the related facilities outlined above are
accurately plotted on the combined map also requested.
Explanation for Increasing Groundwater Head Trends [p. 14. Item l4] - we appreciate the
description of the number of wells and the magnitude of head increase seen in wells at the
facility (9/8/00 IUC Revised GIR, p.26). However, as outlined in the March 13, DRC
Request for Confirmation (RFC) letter, DRC staff will complete the final water table contour
and isopach thickness maps for the shallow aquifer (3ll3l0l DRC letter, pp. 4-5). This
leaves two remaining items from the February 7, 2OOO DRC RFI that continue to be
unresolved, as outlined below:
A. Plan and Schedule for Additional Monitoring Wells or Piezometers [p. I 5. Item l4.C]
- we have reviewed your September 8, 2000 response and found it failed to address
the need to identify the root cause for the increasing head trend. As explained
previously it is likely that the rising groundwater levels observed is likely due to
some artificial source of groundwater recharge. Consequently, such a study will
require the installation of additional wells and/or piezometers in order to identify the
source of the man-made recharge. In order to facilitate this effort, DRC staff have
prepared several figures to guide your planning, as described below:
Ms. Michelle Rehmann
March 20,2001
Page 8
DRC corrected well Hydrographs - have been prepared for existing
monitoring wells at the facility, based on corrected groundwater elevation
data provided you in the March 13,2001DRC RFC letter, see Attachment 1,
below. These hydrographs establish that the wells with the greatest increases
in groundwater head include (indecreasing order): MW-4, MW- 19, MW- 18,
and MW-I1.
DRC water Table Equipotential Map: September. 2000 - this water table
contour map prepared from IUC water level data collected in September,
2000 includes groundwater head data from most of the existing monitoring
wells at the site, plus all the chloroform investigation wells recently installed.
Review of this DRC map suggests that the artificial groundwater recharge
source is located North and East of wells MW-4 and MW- 19, see Attachment
2, below.
(3) DRC Delta Head Contour Map - the magnitude of increased head in each
IUC well was calculated by DRC staff after review of the hydrograph trends
seen in Attachment l. DRC staff took selected heads from the spring of 1983
as representative of baseline conditions at the facility. From this, increases
in head were calculated for each well thru Summer, 2000. These head
increases (Delta Head values) were then tabulated and contoured on a map;
see Attachment 3, below. This map suggests that the artificial source of
groundwater recharge is located east of MW-4 and MW-19.
Please provide a plan and schedule for the installation of additional monitoring wells
and/or piezometers to locate the source of the artificial groundwater recharge
apparent North and East of wells MW-4 and MW-19.
Additional Groundwater Ouality Data [p. 15. Item l4.D] - we acknowledge that your
chloroform investigation report will address groundwater quality issues and the
potential for other contaminants as indicators of chloroform discharge (10/4/00 IUC
Chloroform Report). We have also received your September 15, 2000 Groundwater
Background Water Quality Report. This issue and both of these reports will be
reviewed at a later date.
and
Item I 1.8] - the September 8, 2000 ruC response referred to your failure to locate copies of
original laboratory permeability data. In contrast, our original February 7,2OOO request was
for copies of notes, calculations, and data for the field permeability tests conducted on
monitoring wells, borings, and piezometers at the facility. To reiterate, please provide the
following:
(l)
(2)
B.
6.
a
Ms. Michelle Rehmann
March 20,200I
Page 9
A. Field notes and data collected from each field permeability test, and
B. Detailed description and justification of calculations and analysis methods used to
determine permeability. In the event that test data from certain wells was re-
analyzed, please explain why re-analysis was required.
After submittal and review of this information, DRC staff will prepare a summary table of
all available permeability data and ask for IUC concurrence.
In the event that the information requested above cannot be provided, please submit a plan
and schedule for field permeability testing ofall shallow aquifer wells and piezometers at the
facility.
Please resolve the above open issues within 30 days of receipt of this letter. If you have any
questions regarding this request, please contact Loren Morton of my staff at (8Ol) 536-4262.
We appreciate your cooperation in this matter.
Sincerely,msL
Director
WJS/LBM:lm
attachments (3)
F:\...\iucgw-rfi 3b.wpd
File: IUC Groundwater Discharge Permit, Hydrogeology
Ms. Michelle Rehmann
March 20,2001
Page l0
References
D'Appolonia Consulting Engineers, Inc., June, 1979, "Engineers Report Tailings Management
System", unpublished consultants report, approximately 50 pp.,2 figures, 2 appendices.
Energy Fuels Nuclear, Inc., March, 1983, "Construction Report Second Phase Tailings Management
System", unpublished company report, 18 pp.,3 tables,4 figures,5 appendices.
International Uranium Corporation, September 8, 2000, "Groundwater Information Report Revision
Package", unpublished company report, 3l pp., I I attachments.
lntemational Uranium Corporation, September 15,2000, "Summary of Groundwater Background
Water Quality and Other Water Quality Studies for the White Mesa Mill", unpublished
company report, 5 pp., 2 tables, l2 attachments.
lnternational Uranium Corporation and Hydro Geo Chem Incorporated, October 4, 2000,
"Investigation of Elevated Chloroform Concentrations in Perched Groundwater at the White
Mesa Uranium Mill Near Blanding, Utah", unpublished company report, 44 pp.,l8 figures,
4 appendices.
Peel Environmental Services, February,
Utah", unpublished consultants
appendices.
Titan Environmental Corporation, July,
Mill", unpublished consultants
appendices.
1993, "Groundwater Study White Mesa Facility Blanding,
report, approximately 56 pp., 6 tables, 2l figures, 5
1994, "Hydrogeologic Evaluation of White Mesa Uranium
report, approximately 5l pp., 5 tables, 19 figures, 7
Utah Division of Radiation Control, February 7,2000, "Muy, 1999 IUC Groundwater Information
Report: DRC Request for Additional Information Related to Site Hydrogeology",
unpublished agency request, 2 pp. transmittal letter, includes Utah Division of Radiation
Control technical information request of February 7, 2000 "Request for Additional
Information Related to Site Hydrogeology", l8 pp.,2 attachments.
Utah Division ofRadiation Control, March 13,2001, "September 8,2000IUC Revised Groundwater
Information Report: Ground Water Discharge Permit Application for White Mesa Mill:
Request for Confirmation of Information Gathered by DRC", unpublished agency request,
7 pp.,4 attachments.
ATTACHMENT 1
Utah Division of Radiation Control
Monitoring Well Hydrographs for
Wells Along the Eastern Facility Margin
at the IUC White Mesa Uranium Tailings Facility
DRC File: Gwhead.xls
Graphs: Necorr, Ecorr, Scorr, and Wcorr
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ATTACHMENT 2
Utah Division of Radiation Control
Water Table Contour Map
for the IUC White Mesa Uranium Tailings Facility:
September, 2000 Water Level Measurements
DRC Maps: 9-00bHead.srf and 9-0Ob2Head.srf
DRC Spreadsheet: 9-O0bHead.xls - 9-00
I nternational U raniln Corporation
September, 2000 Water Table Contour
(lncludes TW4 series well data; no data available for wells MW-3 and MW-5)
o
Map
326,
325,
324,
323,
322.
-o,
.E-c
oz 321,000
320,000
319,000
318,000
O"
"oo
qt,
$rrlw-rr
qrTo
Close-up Area
for DRC map
9-00b2Head.srf
cSOO
- Suw-rs .--Quw-rn
%
_ $trirw-s
2,576,000 2,577,000 2,578,000 2,579,000 2,580,000 2,581,000 2,582,000
Easting (ft)
__:_l
-_
0 1200
Contour lnterval = 5 feet
-
4800
9-00bHead.srf
IUC 9/2000 Waterlble Contour Map
Closeup of MW-4 and TW Series Wells
(lncludes TW4 series well data; no data available for wells MW-3 and MW-S)
szr,ooo-l '- --
*__:-{ry 1-- -. -.-r*o"l_- .-i - -- .-
t_ _ _ _i- - - - it---_--- _ raZO,ZOO-J----1 1.--..._ref---..-i---',, t--.:-,- .---|'-2,580,200 2,580,400 2,580,600 2,s80,800 2,581 ,000 2,s81,20O 2,581,400 2,581 ,600
Easting (ft)
----__=_l
0 250 500 750 1000
Groundwater Elevations:
MW4 = 5,560.07 (8/31/00)
TW4-7 = 5,560 (9/20/00)
Contour lnterval = 1 foot 9-00b2Head.srf
9-00bHead.xls - 9-00 3t15t2001
I nternational Uranium Corporation : G roundwater Water Level Elevations
Samole Date = 8/31/00 thru 9/5/00
MW-1 12,579,330.421325,671.85 5,s76.71 I 9/5/001
s,506.441 9/1/00
MW-4 i2,580,905.96'320,991.17
MW-14
MW-15
2,576,417.05 317,340.58
2,577,47 8.42 1 320,51 9. 1 2 1 nl a
2,578,798.'t0
25?6.665,06
2,578.142.39
320,245.47
319,156.70
319,296.302,577,45',t.00
325,121.342,580,133.04
2,581,423.33 324,491.73
320,862.99
321,143.99
321,663.862,580,918.88
320,594.771 5,5281 9/1/00
2.580.874.1 I I 321.831.07
2,581,060.74
ATTACHMENT 3
Contour Map of Monitoring Well
Head Increase (Delta Head)
Between March, 1983 to Summer,2000
for the
IUC White Mesa Uranium Tailings Facility
DRC Spreadsheet:
DRC Map:
Gwhead.xls - deltaH
deltaHead.srf
Gwhead.xls - deltaH 3t15t2001
b;tween DecemberJgg2 anO SeptemUer, Z-ObO
delta
GWEtev
1 12,579.330.42 325,671.85 1.081 5575.63t 5576.71
MW-3 Trs76.417o5
7.211 0.0611
7.451 0.131
317,340.58
320.991 .1 7
2.578.798.10
31 9,156.702,578,142.39
2,577.451.00
318,453.44
325,121.34
324,491.73
2.578,892.21
2,580,1 33.04
2,581,423.33
2,576,209.93
2,581,423.33
Statl of lltah @ #0,,,,,10.,' h''1DErARTMENT oF ENvrRoNupNrer\t/alrry ( X N\DIVISIoN oF RADIATION coNTRoL \ v I '/ '''-
168 North 1950 West
P.O. Box 144850
Salt Lake City, Utah 841144850
(801) s3642s0
(801) 5334097 Fax
(801) s364414 T.D.D. -
wwrv.deq.state.ut.us Web
March 16,2001
Ms. Michelle Rehmann
Environmental Manager
International Uranium (USA) Corporation
Independence Plaza, Suite 950
1050 l7'h Street
Denver, CO 80265
RE:September 8, 2000 IUC Revised Groundwater Information Report: Ground Water Discharge
Permit Application for White Mesa Mill: Request for Confirmation of Site Hydrogeology
Information Gathered by DRC.
Dear Ms. Rehmann:
We have reviewed the September 8, 2000 International Uranium Corporation (lUC) Revised
Groundwater Information Report (GIR), referenced above. As you recall, this Revised GIR was
provided in response to a February 7,2000 Division of Radiation Control (DRC) Request for
Information (RFI). During our review we noted several information items that have yet to be
resolved from our February 7, 2000 RFI.
We also acknowledge a recent meeting with IUC management wherein we discussed a possible
solution to this missing information problem. We would now propose the following course of action
to resolve the February 7,2000 DRC RFI:
DRC Resolution / IUC Confirmation - including DRC efforts to gather currently available
IUC information to resolve part of the February 7 , 2000 DRC RFI open issues. After DRC
collection and summary of this data, we request that IUC confirm this information for
accuracy and content. This is the purpose of this letter.
IUC Resolution - of certain other information items currently open and unresolved from the
February 7,2000 DRC RFI. A second letter will soon follorv that outlines those open issues
yet unresolved.
Michael O. Leavitt
Govcmor
Dianne R. Nielson, Ph.D.
Executivc Dircctor
William J. Sinclair
Dircctor
l.
2.
l.
Ms. Michelle Rehmann
March 16,2001
Page2
Results of DRC Information Gatherins
DRC staff has assembled relevant hydrogeologic information for the White Mesa facility from
several IUC reports currently available. This effort was made in order to expedite resolution of
many of the February 7,2000 RFI technical issues yet open and unresolved. Please review and
confirm the information outlined below and in the enclosed attachments for accuracy and content.
References provided below in brackets [ ] refer to relevant sections of the original February 7,2000
DRC RFI.
Well / Piezometer / Boring Status and Completion Table [pp. I -3. Items I & 2] - DRC staff
have completed a spreadsheet to summarize the following items for all wells, borings, and
piezometers at the White Mesa facility, including
A. Well Completion Details - including: date installed, current status, date plugged and
abandoned, most recent survey coordinates (easting and northing), ground elevation,
water level measuring point elevation, well stick-up distance (above ground surface),
total depth, drilling method, well development method, boring diameter, casing
diameter and type, depth of casing perforations or well screens, screen length, depth
to annular seals, depth to first groundwater.
B. Geoloeic Summary Information - including: depth to bedrock, bedrock elevation,
subsurface depths to top of geologic formations (Mancos Shale, Dakota Sandstone,
Burro Canyon Sandstone, and Brushy Basin Shale), and elevation of same formation
tops.
Please review the spreadsheet enclosed in Attachment l, below, and confirm the accuracy
and content thereof.
Elevations of Brushy Basin Shale [p. 16. Item l7] - because the shallow aquifer is a perched
groundwater system, it is critical to identiS the subsurface elevations of the upper contact
of the geologic formation that perches this aquifer near the facility, i.e., the Brushy Basin
Shale. This information will aid greatly in interpretation ofi
A. Local Groundwater Flow Directions - and determination of the adequacy of the
existing monitoring well network at the White Mesa facility, and
B. Potential Flow Paths - for dense non-aqueous phase liquid (DNAPL), such as
chloroform.
2.
Ms. Michelle Rehmann
March 16,2001
Page 3
During the course of our- review of the September 8, 2000 Revised GIR, and other IUC
reports, DRC staff assembled a listing of apparent elevations of the upper contact of this
formation, see Attachment 2 below. Please review the DRC spreadsheet in Attachment2,
below and confirm the accuracy and content ofthe contact depths and elevations provided.
3. Revised Structural Contour Mao: Brushy Basin Shale [p. 16. Item 17] - we acknowledge
your proposal to include a revised structural contour map for the upper Brushy Basin Shale
contact in the chloroform contamination investigation report. We have received this report,
dated October 4,2000 and prepared by IUC and Hydro Geo Chem (1014100 IUC^{GC
Report). DRC review of the October 4,2000 IUC/HGC Report shows that a number of
existing and former IUC wells and boring at the site have been omitted from this map
without explanation, including (ibid., Figure l):
A.
B.
C.
D.
Dames & Moore Borings - 3,9,12,19, and 28
Former Wells - MW-6 thru 8 and MW-I3,
Existing Wells - MW-20 thru MW-22, and
Temporary Wells - TW4-l thru TW4-4, and TW4-7 thru TW4-9
4.
Consequently, DRC staff will prepare the final revised structural contour map after receipt
of additional information from IUC. Thereafter, we will ask for your concurrence with the
final DRC map.
Corrected Groundwater Elevation Data [p.6. Item 5 and p. 14. Item l4] - after review of the
groundwater elevation and well hydrograph information provided in the September 8, 2000
Revised GIR, DRC staff found additional errors that have been corrected by DRC staff in
Attachment 3, below. These discrepancies include:
Omission of Increasins Trend in Well MW-l I - contrary to the statement made in the
September 8, 2000 Revised GIR (p. 17), the measured heads in well MW-1 I do show
an increasing head trend. Review of the IUC revised well hydrograph data indicate
that the head in this well has increased by 5 feet since about 1986.
Static Water Level in Well MW-3 - the September 8, 2000 Revised GIR indicated
that the water table elevation in well MW-3 did not vary at any time during the
period ofrecord (5,466.87 ft-amsl, 3124193 - 512100, ibid., Attachment 7). This error
has been corrected in the Attachment 3, below.
Water Level Measurements Made Before Well Installation: MW-14 - in the
September 8, 2000 Revised GIR, both the data table and hydrograph chart for well
A.
B.
C.
Ms. Michelle Rehmann
March 16,2001
Page 4
5.
MW-14 show 12-data points reported before installation of this rvell in September,
1989. Consequently, DRC staff culled these erroneous data in Attachment 3, below.
D. DRC Rejection of MW-16 Data - review of the September 8, 2000 Revised GIR
shows the water table elevations reported correspond to a depth of more than 90 feet
below well MW-16's water level measuring point (ibid., Attachment 7, well
hydrograph and table). Review of the well's completion diagram shows that these
data correspond to depths below the base of the well's screened interval (7l94Titan
Environmental Report, Appendix A). Hence, the water levels reported correspond
to the well's casing foot which is not open to the formation. Consequently, DRC
staff culled these erroneous data in Attachment 3, below.
E. Conflicting Water Level Depths: Multiple Wells - review of the available IUC data
show that for dozens of water level measurements in many IUC wells that conflicting
water level depths have been reported. One example ofthis discrepancy is well MW-
3 where l8 conflicting depth to water values are reported (see Attachment 3, below;
cells marked with an outline). Because these discrepancies cannot be resolved by
new survey correction of the well's water level measuring points, please indicate
which of data should be used for each of these conflicting data pairs.
F. Missine Water Level Depths: Multiple Wells - review of the available IUC data
shows that large blocks of time exist where no groundwater level data have been
reported for a number of wells (see Attachment 3, below). Please fill in the blanks
for these missing data.
Please review the DRC spreadsheet in Attachment 3, below and confirm the accuracy and
content of the water table depths and elevations provided.
Revised Water Table Contour Maps h. 14. Item l4.A] - we have reviewed the water table
contour maps found in the September 8, 2000 IUC Revised GIR, Attachment I l. Three of
the maps provided were found to be grossly inadequate, in that the author prepared the data
label post map at a different scale than the contour portion of the map (ibid., 6/15/94,
3l20l97,and616100). In order to expedite resolution of this problem, DRC staff will prepare
new revised contour maps for these three sampling dates, and ask IUC to concur with them
at some future time.
Hydrogeoloeic Cross-Sections [pp. l0-ll.ltem l0l - we appreciate your willingness to
prepare new hydrogeologic cross-sections after agreement on new well survey information
(918/00 Revised GIR, p. 22). However, pursuant to our previous meeting, DRC will prepare
these sections after resolution of certain issues and ask for your concurrence at a future date.
6.
Ms. Michelle Rehmann
March 16,2001
Page 5
A.
Shallow Aquifer Physical Properties Data hp.11-12. Item I ll - DRC staff have completed
a summary table of all available IUC data regarding geologic formation moisture content,
dry weight density, porosity, particle specific gravity, saturation, retained moisture (oZ),
Atterberg Limits, and rock type or lithology. These information are provided in Attachment
4, below. During the course of assembling this data, two things were observed:
Rounding of Reported Values - latter references appeared to have rounded laboratory
values provided in earlier reports, and
Apparent Errors - a few errors were observed that could not be attributed to rounding
errors. These may have been caused by transcription errors present in the latter
reports.
Consequently, DRC staff have concluded that those data available in the February, 1993 Peel
Environmental Services Report appear to be more reliable, and will be used to determine
physical properties of the shallow aquifer. If IUC has additional information, or if IUC can
explain why the February, 1993 Peel Environmental Services data should not be considered
reliable or complete, please provide this information at this time.
Shallow Aquifer Isopach Thickness Map [p. 15. Item l6] - we acknowledge your statement
that the raw data for such a map has been provided to DRC. We continue to believe that
identification of shallow aquifer "pinch-out" zones is important to determination of
groundwater flow directions in a perched flow system. Consequently, after review of
available IUC information, DRC staff will prepare this isopach map, and at some future date
ask for your concurrence with it.
Shallow Aquifer Permeability Contour Map - we acknowledge your proposal to include a
map of shallow aquifer point specific permeability data at the facility in the October 4,2000
IUC/I{GC Report (Figure 2). Preliminary DRC review of this map shows that a number of
data have been omitted, including:
A. Former Borings - including Dames & Moore borings 3, 9, 12, and 28, and
geotechnical borings GH-94-l and GH94-2A, and
B. Existine Wells - including IUC well MW-2
Other concerns with this map or available IUC permeability data may be provided you in a
future DRC letter. After resolution of all issues and concerns in this regard, be advised that
DRC staff will prepare a final shallow aquifer permeability contour map, and later ask for
IUC concurrence.
Ms. Michelle Rehmann
March 16,2001
Page 6
In summary, DRC staff have taken on the task of completing several of the information items
outlined in the February 7,2000 DRC RFI. This effort was made in order to expedite resolution of
several open issues that were unresolved. In the near future a separate DRC letter will outline certain
other technical issues that will need to be resolved.
Please review the attached DRC summary inforrnutio, for accuracy and completeness. If errors or
mis-interpretations are found, please bring these to our immediate attention within 30-days ofreceipt
of this letter. If you feel it necessary to meet with us concerning this information, please arrange
such a meeting with Loren Morton of my staff at (g}l) 536-4262.
Thank you for your cooperation in this matter.
Sincerely,
@ZQ-
William J. Sincla(9/
Director
WJS/LBM:lm
attachments (4)
F:\...\iucgrv-rfi 3a.wpd
File: IUC Groundwater Permit, Hydrogeologic Report
Ms. Michelle Rehmann
March 16,2001
PageT
References
International Uranium Corporation, September 8,2000, "Groundwater Information Report Revision
Package", unpublished company report, 3l p_p.., I I attachments.
International Uranium Corporation and Hydro Ceo Ctrem Incorporated, October 4, 2OOO,
"Investigation of Elevated Chloroform Concentrations in Perched Groundwater at the White
Mesa Uranium Mill Near Blanding, Utah", unpublished company report, 44 pp.,l8 figures,
4 appendices.
Peel Environmental Services, February,
Utah", unpublished consultants
appendices.
1993, "Groundwater Study White Mesa Facility Blanding,
report, approximately 56 pp., 6 tables, 2l figures, 5
Utah Division of Radiation Control, February 7,2000, "Muy, 1999 IUC Groundwater Information
Report: DRC Request for Additional Information Related to Site Hydrogeology",
unpublished agency request, 2 pp. transmittal letter, includes Utah Division of Radiation
Control technical information request of February 7, 2OOO "Request for Additional
Information Related to Site Hydrogeology", l8 pp., 2 attachments.
ATTACHMENT I
Utah Division of Radiation Control
Summary of Well, Piezometer, and Boring
Completion Information from Various IUC Reports
for the White Mesa Uranium Mill
DRC Spreadsheet: Wellcomp.xls
Tabsheet: data
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ATTACHMENT 2
Utah Division of Radiation Control
Summary of the Elevation of Upper Contact of
the Brushy Basin Shale Member
(Morrison Formation)
from Various IUC Reports
DRC Spreadsheet JmbElev.xls
Tabsheet: Nerv Survey
JmbElev.xls - NewSurvey 3t1312001
IUC: Elevation of Upper Brushy Basin Member Contact
in bold = depths used to calculate Jmb elevation.
Depth to Jmb Top Contact
2,579,330.42i 325,671.851 5,649.26r 110.0 1201 I 5,495.
2,576,417 nla
--{25"0
2,577,478.42
5,612.01
s,6ul0
319,156.70
5,519.58
315,490.81
316,871 .69
313,968.74
2,574,794.90
2,580,981.05
s,623.10 i t os.o
2,580,890.s9
2,580,943.64 32't,143.99
2,580,918.88 321,663.86
320,594.772,580,936.51
2, 580,859.24 | 322,002.88
Z,t8o-ie3ss.k2o343r3
JmbElev.xls - NewSurvey 3t13t2001
Cell: D6
Comment: Ground Surface Elevation: from new survey data found in 9/8/00 IUC hydrogeologic Report, Attachment 2.
Cell: E6
Comment: Depth to Top of Jmb Contact: DRC picks from spreadsheet WellComp.xls, as based on well logs and completion diagrams provided in the 7/94
Titan Environmental Report, Appendix A.
Cell: F6
Comment: Geophysical Logs Only: depths estimated by DRC staff from UMETCO gamma and neutron density logs found in the 7/94 Titan Environmental
Report, Appendix A (MW-1 , MW-2, MW-4, MW-5, MW-1 1 , MW-l2, MW-14, and MW-15).
Cell: G7
Comment: Other IUC Reports lnclude:
1) 3/93 Energy Fuels Nuclear Cell 3 Construction Report, Appendix D,
2) 5128199 IUC Groundwater lnformation Report, Part C, p. C-40
Cell: E8
Comment:MW-1,JmbTogl. Tl94TitanEnvironmental report,AppendixA,Fig.3(well completiondiagram)listsaclaystoneatll0feetof depth(presumec
to be Jurassic-age Brushy Basin Member of Morisson Formation, Jmb).
E9
MW-2, Jmb Top: 7194 Titan Environmental report, Appendix A, Fig. 3 (well completion diagram) lists a claystone at 119 feet of depth (presumec
to be Jurassic-age Brushy Basin Member of Morisson Formation, Jmb).
Cell:810
Comment: MW-3 Survey Coordinates: the Easting value found in the 9/8/00 IUC Revised Groundwater lnformation Report (Attachment 2) is in conflict with
the 8/28/00 Landesign well survey/site control map (Rev. 1), as follows:
9/8/00 IUC 8l28lOO Landesign
Report (fl) Map, Rev. 1 (ft)
Easting 2,576,417.05 2,576,4'17.89
Gell: E11
Comment: MW-4, Jmb Top: 7194 Titan Environmental report, Appendix A, Fig. 5 (well completion diagram) lists a claystone at 125 feet of depth (presumer
to be Jurassic-age Brushy Basin Member of Morisson Formation, Jmb).
Cell:812
Comment: MW-s, Jmb Top: the depth of 118 feet is based on:
1) 7/94 Titan Environmental report,AppendixA, Fig. 11 (well completiondiagram) lists a "dark sandy shale" ata depth of 118ftbgs. Similar
lithology was reported for the upper Jmb contact in 2 other nearby wells, MW-1 1 and MW-12 ( "dark sandy shale").
Cell:
Comment:
Cell:
Comment:
2) Review of historic water levels shows phreatic surface occurs at about 108 feet bgs, which is consistent with perched conditions at site, and
3) Close review of the 7/94 Titan Jmb structural contour map, shows it was the 1 18 ft depth they used for the map.
Despite this DRC interpretation, a brown claystone is found immediately below the "dark sandy shale" at '133 feet of depth.
E13
MW-1 1 , Jmb Top: 7/94 Titan Environmental report lists a dark sandy shale at a depth of 130 feet (Appendix A, Filg. 1 , well completion diagram)
Log also states that overlying sandstone was moist. Consequently, the dark sandy shale is interpreted to be Jurassic-age Brushy Basin Membe
of Morisson Formation (Jmb).
E14
MW-12, Jmb Top: 7/94 Titan Environmental report lists a dark sandy shale at a depth of 115 feet (Appendix A, Fig. 2, well completion diagram).
Log also states that overlying sandstone was moist. Consequently, the dark sandy shale is Interpreted to be Jurassic-age Brushy Basin Membe
of Morisson Formation (Jmb).
816
MW-15 Survey Coordinates: the values found in the 9/8/00 IUC Revised Groundwater lnformation Report (Attachment 2) is in conflict with the
8l28l10 Landesign well survey/site control map (Rev. 1), as follows:
9/8/00 IUC 8l28lOO Landesign
Report (ft) Map, Rev. 1 (ft)
Easting 2,577,45'1.00 2,577,451.45
JmbElev.xls - NewSurvey 3t13t2001
Northing 319,296.30
Cell: E17
319,296.27
Comment: MW-16, MW'17, MW-18, and MW-19 Jmb upper contact depths: taken from well completion diagram in the 2/93 Peel Environmental Services
report, Appendix A.
Cell: E18
Comment: MW- l 7, MW-18, and MW-1 9 Jmb upper contact depths:
Appendix A.
Cell: E19
taken from well completion diagram in the 2/93 Peel Environmental Services report,
Comment: MW-17, MW-18, and MW-19 Jmb upper contact depths: taken from well completion diagram in the 2/93 Peel Environmental Services report,
Appendix A.
Cell: G20
Comment: MW-20 thru 22, Jmb Contact: no geologic logs provided for any of these wells. However, the 5/28/99 IUC Groundwater lnformation Report sayr
that each of these wells was drilled 20 feet into the Brushy Basin Member. Consequently, DRC staff estimated the Jmb contact depth by
subtraction from each well's total depth.
Cell: E23
Comment: TW4-1 Jmb Contact: depth from 1Ol4lO0 IUC Chloroform Report, Appendix C (temporary well drill logs).
Cell:824
Comment: TW4-2 Survey Coordinates: the values found in the 9/8/00 IUC Revised Groundwater lnformation Report (Attachment 2) is in conflict with the
8l28l0l Landesign well survey/site control map (Rev. 1), as follows:
Easting
Northing
W.L. Meas. Pt. Elevation
Ground Surface Elevation
Cell: E24
2,580,943.64 2.580,9't6.11
321,143.99 32 t,115.39
Comment: TW4-2 Jmb Contact: depth from 10l4lOO IUC Chloroform Report, Appendix C (temporary well drill logs).
Comment: TW4-l Jmb Contacl: depth from 'l0l4l10 IUC Chloroform Report, Appendix C (temporary well drill logs), after comparison with draft geologic log
provided in 1l28l0O Smith, Pyrih, and Popietak report for IUC (see Appendix).
Cell: E26
Comment: TW4{ Jmb Contact: depth from 1Ol4l0O IUC Chloroform Report, Appendix C (temporary well drill logs).
Cell: E27
Comment: TW4-5 Jmb Contact: depth from 1014100IUC Chloroform Report, Appendix C (temporary well drill logs).
Cell: E28
Comment: TW4-6 Jmb Contact: depth from 10l4l0o IUC Chloroform Report, Appendix C (temporary well drill logs).
Cell: E29
Comment: TW4-7 Jmb Contact: depth from 1Ol4lO0 IUC Chloroform Report, Appendix C (temporary well drill logs), after comparison with draft geotogic log
provided in 1/28/00 Smith, Pyrih, and Popielak report for IUC (see Appendix).
Cell: B30
Comment: TW4-8 Survey Coordinates: the values found in the 9/8/00 IUC Revised Groundwater lnformation Report (Attachment 2) is in conflict with the
8128100 Landesign well survey/site control map (Rev. 'l), as follows:
5,625.00 ft amsl 5,628.22 ft amsl
5,623.10 ft amsl 5.626.26 fr amsl
9/8/00 tuc
Report (ft)
9/8/00 tuc
Report (ft)
8l28lOO Landesign
Map, Rev. 'l (ft)
8l28l10 Landesign
Map, Rev. 1 (ft)
Easting
Northing
2,581,060.74 2,581,030.27
321,007.97 320,976.89
W.L. Meas. Pt. Elevation 5,621.71 ft amsl 5,624.90 ft amsl
Ground Surface Elevation 5,620.30 ft amsl 5,623.43 ft amsl
JmbElev.xls - NewSurvey 31131200'l
Cell: E30
Comment: TW4-8 Jmb Contact: depth from 1014100 IUC Chloroform Report, Appendix C (temporary well drill logs), after comparison with draft geologic log
provided in 1128100 Smith, Pyrih, and Popielak report for IUC (see Appendix).
Cell: E3l
Comment: TW4-9 Jmb Contact: depth from 1014100 IUC Chloroform Report, Appendix C (temporary well drill logs).
Cell:834
Comment: MW-16 Survey Coordinates: the values found in the 9/8/00 IUC Revised Groundwater lnformation Report (Attachment 2) is in conflict with the
8l28l00 Landesign well survey/site control map (Rev. 1), as follows:
9/8/00 tuc
Report (ft)
8128100 Landesign
Map, Rev.'l (fl)
Cell:
Comment:
Easting
Northing
W.L. Meas. Pt. Elevation
Ground Surface Elevation
E34
MW-16, MW-17, MW-18,
report, Appendix A.
2,576,662.00 2,576,661.65
319,820.90 319,820.94
5,590.22 ft amsl - no change -
5,589.00 ft amsl 5,589.03 ft amsl
and MW-19 Jmb upper contact depths: taken from well completion diagram in the 2l/93 Peel Environmental Services
Cell: G41
Comment: MW-13 Jmb Contact: taken at contact at depth of lOO.O ft bgs between moist sandstone and sandy "clay". This sandy clay bed was immediate
underlain at 105.0 ft bgs by a Dark Sand Shale.
Cell: E44
Comment: Dames & Moore Borings Nos. 3 and 9: IUC agrees with Jmb contact depths (9/8/00 IUC Revised Groundwater lnformation Report, Attachment
4).
ATTACHMENT 3
Utah Division of Radiation Control
Summary of Groundwater Monitoring Well Hydrographs
Including Water Level Depths and Elevation
from Various IUC Reports
DRC Spreadsheet Gwhead.xls
Tabsheet: CorrData
Gwhead.xls - CorrData 3115t2001
active
t2.A
Water Level
ou12l81 109.0 5,503.4
Wr,Q 1oe.6E5o3r
09/01/84 108.17 5,504.3
os/2648il fi8.215;sdi'2
12101t84'108.0 5,504.4
_,gs!4 1 o8.o f 9r5_o-4.402t01185 108.0 5,504.4
o2iiipgl 1oa.o J-5,5G1
06/01/85 108.'17 5,504.3
09/30/851 107.s1s,504.!
1o/01s5-10/3iib5
i1loras
11127t85
1AO1l85 108.08
1 08.112t15t85
01t24t86
02t28t86
03/01/86
o5/20ra6 108.21s,504.'
06/1 9/86 107.9215,504.4
,ee/04/8ql
12101t86
roz.si-s,s-o+I
108.17 5,504.:
06/26/86 t-ozsl-5s04:
09/01/86 107.92 5.504.r
la1u861,1o8.2l55oai
02t20t87 roa.iil S"soa:
= dates before well installation or after P/A
= new data from 9/8/00 IUC Report
Date lnstalled:
-- Date PYA
WLMP Elevation:5,558.335,616.64
Sample ,.Depth
G !qP)
Elev.Elev.
(ft-amsl
Elev.
(ft-amsl)Date -(ft blto
I
I
=r1r ------L ,)_t----i
'1i09/10/79
-ilo-sn-aDs,
r108.5
77.
76.615,574.1109t25n9___,--.1 _ __1l1U10n9-_tllr4ot-al
1) 02t28t80-- --- -L---*1 03t20180_L,___-_
tgzs.1
5.577.1
5,577.1
1 I 05/30/80 5,- - 1 lo6/1r8d- I :-:::5,575.I 07t16t80-- 1n8/1e/so_ _-,t- - -_.,-
1 I 09/07/80 76.2
1 | 09/1 1/80_--: F:-:- :::-'74.3-- 2i osTinao-- r rroloe/8ol 74.3 5.576
76.215,574- 2l oatztyi--loniml
---t, 09/01/84
- --l]er1444_ ?I!2!0119!I ',t2105184-- 2i ouolititioiQlai)
2 06/01/85
79.6 5,571
75.3
83.3 5,567
83.21 5,567.
76.0 5.575.1
76.0 i 5.575.1
76.0 5,575.1
76.015,575.13
76.2 5,574.93
1 i 06/25/85 76.2E,5i4.
2 09101t85
1 , 09/30/85 7s.4 i s,57s.,-- ',i-::1"-:.::2 10t01t85
't : r o7s r7s5 f---z-s. dr s, szo. r
2't 11t01t85 75.9 5,575.23-i I 11D7tlsi 75.s-5,s75--i:Tuuil{ 7s.s ssTs
-_-_ ffZt 5/9_El__ r!!l!f ?s
1i9q?118!i ry.4j'-,570._ 1,33!4!9 7s.81 5,57s.
2 03/01/86 75.8 5,575.
1'0372d/Bq 76.2-s,s74.- _rio-rzzr{{-zr.d@
2i 04t01t86 75.6 5,575.
1i9119Y991119i!fZl1 06/19/86, 75.71 5,575.2:ll
- i::.r^.^-i-:l---
,1 lgqeq{q! j 75.78,57s.43
-ospln(ft bmp)
05/30/80. 94.3 i 5,531 .53
o-o7z'lgo'- -s+.s[ 5s3T.s3
07l16t80: 94.3i5,531.53
08/19/80 i 94.2 i 5,53'l .63
09/07/80 i 94.115,531 .43
!e/l_11q91 s4.315,531.53
09/15/80 94.3 5,531.53't0/08/80 94.4 5,531 .43
02t't2181 94.4 5,531.43otntt0' 94.3[55315i___-__l09to1tu 96.4 5,529.43$Bq, so.ais-'g_9.1!'t2l01tu 94.0 s,531.83yL-o:ly, s4.o-s;ttl33
o2to'u85 94.2 5,531.63
o7p14as s4.2115-3-1.63
06/01/85 94.0 5,531.83
_Q_o1zvqs. e4.o['s,531-.Bi
09/01/85 93.4 5,532.43qqryq{ ss.rfglssz.as-10/01/8t 93.4 5,s3233
1 1lo t/85 93.4 5,532.43
1UO1t85 93.5 5,532.33'tziini, s3.515F32i3
/01/86 110.0 5,515.83
94.01s,s31.83
rjolrs7e6 93.421s,s32.41,l
06/26186 93.415,s32.43
ogloTaet 93.5f5,53233
12tO1t86 93.17 5,532
12l1ot86t 95.7 5,530.1
oLnod'- -sssz1s,ss
0 4 t 28 t 87, _,s_a. t l1!,_s!!t
j - ---- L-- -l- -l.09/0619 93.015,532.83'
lisTozrzsf -e+7] 5,53 1 . 1 3l
igqtpaLrEel-qq4r!;
___ L_L_08t14187 93.251 s,532.
'-
1 15.21 5,501.
'ofr.inn,' -817''i 5,fi a'. 55
[e-mail] sV?!^3
5,507.14
tso8s4
o-ilro7aal ffi,4-5475j'3
ql-.e]_5.4_re.1!
ry.8F,41111
83.1 i5,475.23
es.615/74
83.6is,474.7308/19/801 1 10.01 5.506.64
orl lnoTlloETsso6r4
09/15/80 110.5 5,506.14
1o/o8so] 111.1 I s5os54
0412t81 t't0.1 5,s06.54
W 110.0
09t01184 1 12.3 5,504.34ggl@l rrz.sgso+ar
12tO1tU 1't0.5 5,506.14
@ 110.4[550624
02101185 110.3 5,506.34@ rro.sf,qqo.sa
06/01/85 110.5 5,506.14
oon-sEs-l 11o.5GFo6r4
09/01/8s 110.0 5,506.64
oglso/8t 1 1 o.o I s5-06s4
10/01/85 110.8 5,505.84
-tolg1l85] rto.aFsiiS3a
11101t85',t12.2 5,504.44
't2t01t85 110.3 s,s06.34
1 10.31 5,506.34
o2t28t86i 110.1 1s,506.5403/01/86 1 10.3 5,506.34
03/20/861 110.515,506.14
09/11/801 83.7
5,474.63
02l1au 84.9 5,473.436mq as.opza.zs
09/01/84 83.2 5,475.13
_o-g2ql--al s7.5[5,470f3
1UO1|U 80.8 5,477.53lZg@ 840F,4I1.33
02101t85 83.7 5,474.63
-og?llga 84.3i5,47433
06/01/85 83.7 5,474.63'oouzSlasJ ea.s €,a73.8 3
bglo-vai aq.l sJ73.93
oTlpgla{ 63.7 i5,a7as310/01/85 83.6 5,474.
fgq@_q ar.oi5/47s.si
11/01/85 87.6 5,470.73
12t01185 84.00 5,474
12/15/8sl 83.7i5,474
91!4!86'L g3:719,!7!
944!861 83.815,474
03/01/86 U.3 5.474.
oanoradl sa.sj
03t27t861 84.015,474
04/01/86 U.5 5,47
04/08/85-1 84.88771
06/1946_1 83.415,474.
e6!1sJ86l 83.7l|5t74
06/26/86i 83.4i 5.474.-__) L09/01/86 83.0 5.475.
09/04/86t 83.8-____-J
12110t861 83.815.474.53
b27zora7 [-- 8ttri,q1 a st-ozrnrul as.zlf4.65
5,504.44
01124186t 110.0
04/01/86't09.9 5,506.7
04/08/86i 109.91s,506.74
1 11.3 [5505.a
r r r:5is"so5.
o8l14t87l 111.08 5,505.56
l---05l30l8ol11 12.2 l#VALU
sSoas
09/1 5/80
1 0/08/80
Page 1
08t14t87 108.33
3115t2001
IUC White Mesa Mill bold r calcu isqt lfi;ll.ili = available, but ---l_
IGroundwater Head Data italics = different values; same day I iX-i= oites Gfore weii iniiattationE
= new data from 9/8/00 IUC Report r------r--l --- l
Date lnstalled:Sep-7S Sep-79 Sep-7!| [ sep-zs
Date P/A:active active active active active
I WLMP Elevation:5.651 . t3 (ft-amsl)5,616.64 5,C5U.J.i 5,625.83 5,612.1
MW-1 Water Level MW.2 Water Level MW-3 Water Level MW-4 Water Level MW.5 Water Level
uata
SonrA
Sample Elev.
(ft-amsl)
Sample Depth-Elev.
(ft-amsl)
Sample Depth Elev.Sample Depth Elev.
(ft-amsl
Samplel Depth I Elev.
-oate-| 1tt umpl |1n-amslrDate(ft bmp)Date (ft bmp)Gte-
08t14t87
(ft bmp)(ft-amsl)
5,463.58
Date (ft bmp)
2 94.75
11t20187 i 76.0 5.575.13 11t20t87 110.42 5,506.22 11t20t87-tuirirai 83.9
83.4 -s,4ul?5,474.93
11t20187 93.33 5,532.50 1'.120t87
lirio,e;
108.3
104.33
5,504.
s,soe.2
1
I-_-,_-'-l01t26t88 75.92 5157rz|o1/26S8
ut27l88
't10.42
110.42
5,506.22 0'v26t88-01127188 93.58
93.58
5,532.25-{$z2s01t26t88 83.8 5,474.53 01126t88 5,508.'
s_,soa:
,5_,_Q9a_
5.s08.i
1 otnzteal 75.92 5,575.21 5,506.22 01t27n;d si.als.474s3 01n7t1a 108-3--_-__+06/01/881 108 3-, ____-t06/01/881 104.3
06/01/88I 75.75 5,575.38 06/01/88 1 10.33 5,506.31 83.8 5,474.53 06/0't/88 93.42 5,532.41
2 83.7 5,474.63
08t23t88 75.17 5,575.96 08/23l88 1 10.08 5,506.56 83.4
83.75
5.!74
5,474.58
08t23t88 5,532.73 o8/23l88[ .LE s,so1
2 08/23l88 5,531.75 I L--11t02t88 108.08 5,504.:
rrtoyssl 108.1 [5,sd4.:
2 1'vozt88 75.33 5,575.80 11102t88 1 10.00 5.506.64 11t02t88
r iloy88l
83.75 5,474.58
83.515,474.83
11t02t88
11/03S8
93.33
93.3
j,51199
5,532.5311/03/881 75.33 5,575.80 1 1/03/88 1 10.0 5.506.64
03/09/89 73.0 5,578.13 03/09/89 110.1 5,506.54 83.8
83.33
s,474.53
s,azs.oo
03/09/89
ciiTos/e0
1!!?!!.
5,531.83
9_319s/q9flm6.7l5,Al03/0e/8el ,0s.e | 5,503.i2
06/21l89 r 76.1 5,575.03 06121189 1t0.3 5,506.34 06121t89
06/rla0
63.t
83.92
5,474.63
5A74A1
06/2 t/89 93.23 5,532.60 06/21l891 108.091 5,504
2 -T,|09/01/89 75.55 5,575.58 09/01/89 110.4 5,506.24 09/01/89
ogloilsg
85.7
83.83
5,472.63
5474sd
09/01/89 93.27 5,532.56 0s/01/ssi 108.15i 5,504
2 tl
1, 11l',!5189 75.79i5.575.34 11115189t 110.12 5,506.52 1 1/1 5/89
r ilrs7-as
6J. /
83.83
9,-41L-6!
5.474.50
1 1/1 5/89 93.1 2 5,532.71 t ili5lagf 1og3l5.5oar___t I -'
1 1/15/891 708.0S I s,504.:
02/16/901 108.14i s,s04.:
21
'ti 02t16t90 75.81 i 5,57s.32 02t16t90 109.98 5,506.66 oa16t9(
o2h6t9(
83.64
83.42
5,474.69-
5,474.91
02t16t90 93.1 1 5,532.72
2i t I1 05/08/90 75.51 5,575.62 05/08/90 109.8 5,506.84 05/08/90 83.615,474.73
08/07/90
o8/07/90
t t lt slgo
o83.
83.8
9fl1
5,474
284.
83.7
s174l
5,474.6
{47i.6
sdt_24
5.474.6
83.7
85.7
.43
4.53
At3
4.63
4.63
2.6n
a.61
1 1 /1 3/90
6ziiirgt
ourlEi
05t21t9i 5,4
oal21lst as.oa 5-1474109
05/08/90 92.9 5,532.93 o-stoaiso [ 1 o8r 5[ s,soZ
oero?7so[- roa.2f s,sonr i oarozrgo, z5.o5is,57o.ro 08/07/90 1 10.01 5,506.63 08/07/90 92.93 5,532.90
2i rl
i iiiiigo*l{e-lssir331
_t_l11/13/90i 109.015,503.::---l _- -
Io2t27t91l 108.07 5,504.
11t13t91l 109.815,s06.84 1 1 /1 3/90 92.8 5.533.03
2 T-*-
I
oa27t91 92.47 5,533.361 02127t91, 75.58 5.575.55 o2t27t91 110.07 5.506.57
2
osiz{igl 92.42 Ssss.ai __1
05121t911
_l108.3 5,5041 05t21t91 , 75.45,5.575.68 OSl21l91 110.04, 5,506.60
2 __r-_]-08t27t91 108.55 5,503.
o-s7z-+rsi'l 108.5 i t503.
i zovsil- i6a.as I s,so5.I---l-
2 08t27t91 75.45 5,575.68 08t27191 110.19 5,506.45 08t27t91 92.56 5,533.27
1':09t24191i 75.0,5,576.13 09t24t91 110.3,5,506.34 o9t24t91 84.0i5,474.33 09124t91 92.6 5,533.23
1' 12103191i 75.7 t 5,575.43 12t03t9',tl 110.38i 5,s06.26 t zosAt l--- s3-e I s d:t-q ei 1AO3B1 92.54 5,533.29
2 i26atsTl 83.64 I s,.+74.60
1i 03t17t92 75.7 5,575.43 03t17t92 1 10.02 5,506.62 03t17t921 83.815,474.s3
03t17 ts2l $.8715,474.i6
03t17192 92.2 5,533.63 03t17 t92i 108.18i 5,504.'
21
06111192 75.71 t5,575.42 06t11t92i '.t10.22 5,506.42 o6t11t92l 83.715,474.63oanszl 84.21\474-13
06111t92 92.48 5,s33.35 o6t't 1 tszl ro67z | 5soa.c
2 I l-t09/03/92 75.235,575.90 09/03/92 i 1 10.091_5,s0_655
09/13/92 110.09 5,506.55-!Ig!g 110.0[s--50a64
12to9t92 110.00 5,506.64o:gttsx 11o.oo 5,5066i
_09!8ler 110.19 s1g!a45
09t22t93 1 10.35 5,506.29
09/03/92 83.7 i 5,474.63 ry03f3 s2.415,53_q.49
ost13192 92.435,533.40l[gg s2.4[5s3i43
12t09t92 92.41 5,533.42
q:rys4 rosi[tsoi.c
09113192 108.37 5,504.111gq! 1o8.4ftso4r
12t09t92 108.44 5,504.(
o-s-124l95 108.29 s504.1
ooio-e/-gt 108.30 5,so4.i
934-!gl 108.s1 5,503.!
12114193 108.03 5,504.!
oiat'{agi 1 08.42 5,5otlb-oltrgr toa.so s,soa.i
08t18t94 108.22 5,504.2ogrrTrgaW
12!l3ql 108.00 5,5041
E4As! 108.18 _5,504.i
99!*21!s:_ 108.1 0 5,504.:
09/20/95 108.06 5,504.r
tztTtts{ 107.92 -5.504.-r
2
-l- -1----/_-,
09113t92 75.2311t19t9i 75.7 -5.{7sA3
yleqnL 75.65 5,575.4!
03t24t93 75.505,575.63
ooTosis3 2s.41 s,s7s.72igll2|sl 75.60 5s7r53
09t13t92, AS.O5ISL+ZaSa
11119t92 lS.S637413L-12to9t92 83.74 5,474.59o:ni@_ s3.63 -5-,az+so
06/08/93 83.905.474.43
03t24t93 92.085,533.75
06/08/93 92.13 553i.70
09t22193 83.755,474.58 09t22t93 92.14 5,533.69
2- -.,
-._*,--,
2--- 1-_,--,---2-,
12t14193 75.695,575.44Olpllgl 76.04 5s75ie
06/'15/94 75.86 5,575.27
balrarg? 75.7s 5F75-.35
ost12ts4 ffisB:5.PJqfTffir--.-- @@
u!13!ea 75.76 s,575.37
03/15/95 75.68 5,575.45
0:lt2't t31 75.76 5,575.37
09/20/95 75.605,575.53
12t1Ttgi 75.56 s575s7
12t14t93 109.83 5,506.81
osn4t94 110.04 Eto6.6o-ooTrysa ros.ge sso6.66
oa/1s/% 109.92 5"so6.z
12114t93 83.685,474.65
L@tro 83.70 s/472s3
06/15/94 83.86 5,474.47
08/18/94 83.77 5,474.56
o9.t12t%- 83.87 5,474,46
12113t94 83.91 5,474.42
gg4gryF $.71 sA74.62
06t27t95 83.75 5,474.58osZolsi 83.73 5/474s0
Tznu% 83.7s 5/474.s8
121*4!33 e2.s8-5,533.25
03t24t94 91.35 5,534.48
06t15t94 90.985,534.85
oairsig+ 90.71 -s,s35.12oet'tzte4wffffff:ff&w#ffi.9!4291ffi$W12!13!9! 8e.75 5,s36.08
E116le1 88.e1 5,s36:e2
06t27195 87.63 5,538.20
!-_29€{ 86,8e 5538.%
1?,11195 85.17 5.540.66
12t13t94 109.90 5,5!6.74
9346/9e 110.'r4 5,506.s0
06t27t95 109.95 550_6.69
9g?9ry9 10s.s8 5,506.66
12t1',v95 109.73 5,506.91
Gwhead.xls - CorrData
Page 2
Gwhead.xls - CorrData 3t15t2001
IUC White Mesa
Groundwater Head Data
Date lnstalled:
Oaie Pln:
' Wlrrrrp Eievition:
bold = calculated fields = available, but missang data
f76ms l= different values; same day E<= dates before well installation or after p7R
= new data from 9/8/00 IUC Report
' -lTep-?rl i -l I
I
-8
active
5,612.4
Water Level
Depth I Elev.
(ft bmp) | (ft-amsDate
03i28,ts6
o6io7/96
o9/i 6/06
11t22t56
$no/sl
o6tlltsl
ogrcolsz
03il 6/98
ost12js8
OStnAlgA
1 1 /03/98
o2t18tgg
04toTlgg
05/1 1 /99
07l06/99
o9/28/99
12t09t99
oiros/oo
oJrrTrco
o4l04/00
osioztoo
05/1 1i00
o5/1 5/OO
05/25l00
o6/06/oo
o6/07/oo
o6/09/oo
06/1 6/OO
o6/26/OO
07/06/00
07 t13t00
07118t00
oilzsioo
08/02/00
08/09/00
o8/1 5/00
08/31/00
o9/o 1 /oo
o9/04/00
os/9s100
108.02 5,504.4
108.10 5,504.3
107.99 5,504.4
107.90 5,504.5
108.30 5,504.r
't07.9o 5,504 5
108.03 5,504.4
108.OO 5,504.4
107.60 5,504.€
'107.80 5,504.€
'lo8.oo 5,504 4
108.40 5,504.C
108.50 5,503.S
1oB.OO 5,504.r
107.S0 5,504.t
107.80 5,504.€
.. '- .- i--
107.55 5,504.('..' .', ,.', . : -
108.00 5,504 ,
11127t)O | 108 75 5,503.
11t28t00 107.90 5,504.
Page 3
Gwhead.xls - CorrData 3t15t2001
active
5,603.4
Water Level
Elev.
(ft-ams
:_l_
I
103.67 5,510
103.0 5,5't 1 .30
103.915,510.
103.01 5,51 1 .30
102.8i5,s11.s0
103.0 5,511.30
103.0 [*5"51 1 3b
102.83 5,51 1 .47
103.2i5,5't1.10
5,5't1.'t3
09t26t84 77.315,493.051--l -L -:---
r.____!_____t _ ____ _.10a21t85, 73.3,s197.0-5:__ t_i_ ___lOOl25l85 73.2,5,497.15, IUAlZ5l63', 15.2,3,49t."15. lll--il-_]. ,09/30/85 77.0 5,493.35: i----r------T--!----l
1 0/31/85
qqle l(ft ump)
---t---r-Il
-f--
_ _l -____
--a --
-- -._t___
tati-l---f-t-i---_-l--==-r:[
---a-
---l
I
I
___- a . __.-.--t ,
I
I
--l
---
__:i_
l---:lii
L_ __liii--_-i
lmtuinFiT-l#v^w
09/0 t/84 1'11.75 5,500.r
99/,1el@ rrr.afssoo^as
1AO1t84 109.58 5,503.07g@g ros.opsosos
02101t85 110.08 5,502.57
o?l2i!!d rro.r psozsS
06/01/85 109.83
o6/2slgsl ros.afssc
og/o-ile5|-loB.83J sFc-oe/3ora5i- maaFsc
12t01185't09.67 5,502.
01t24t86
o2na86
a
_l_
II
06/19/86 77.2t5493.',t5.,-__l_ I ___L___ l_06/26/86: 77.215,493.15,:_]__- _L-- |os/oalg6i--zt3ls.q%.zsi l
o3t27t86l 110.0
gg41oL8gF o s. ir1. o3. g q
09/01/86 109.25 5,503.40
@l4@ ros.apsos:5
12t01186 111.17 5,501.48
12t10t86l 111.2 | 5,501.45
onulT-tl7f -110.iF,soz.ca
5,511.88
Page 4
Gwhead.xls - CorrData
active
5,603.4
r Level
(ft-ams
5,495.(
0??!!s1
oa27t91
osDugi
tisnusl
oBDitel
ostiqlsl lg7.q2[{4s5j
12t03191 107.76 i 5,495.(
119Li
9-C95,r
11e-!.!
5,494.(
5/95.;
03t17t92 107.71
oo7 vs2[-rorszl-ir06l
ll
!9/01194 107.71 i5,4e5.,
09t13t92 107.71 5,495.t
-lndlq 107.58[q4s5]
12t09t92 107.58 5,495.r
09t22t93 107.69 5,495.
OII|6 107.43-5/4-t5r
03t24t94 107.58 5,495.r
oofl5l0? 108.23 5,40s.
o8i1u% 107.44 s,49tioglrzgaffi__k*wr12l13/s4[ffiiW
03/16/95 107.35 5,496.1
o6D7t9{ 107.31 5,49A
lgl3glgq 107.2s s/4eo
12111t95't07.20 5,496.1
3115t2001
+- -i- -li_t- - ,t - .-lr1-_ -l s";
t__ _| 1'tt'tst8,g 105.20 5,496.44
, 1 1/1 3/90 1 05.00 I 5,496.64!- --
-r---- -: ----
i oztzt tsti 105.37 i s,496.27I .vLlzalJ ll lVJ.J,.J.rJV.-a
. | -,-l ----_ I 0_!7?1 t g1_", _19 5,1 9 i !,19"6.2Jt{"__-_loatzttgt 1os.4s 5.496.19
__l 1?JW!e1 1 05.48 !,1s:6J !,03124193 105.44 5,496.2(,03124193 105.44 5,496.
I ooloalgg 10s.38 5,496.---; ogilzet 105.s1 5Je6J3
iTziiaEi fis.22-sAs6A2-
--lostzust
ros.ar -s,ago.zs
.06/'t5/94 105.30 5.496.34_l :I oa/tBlga 105.23 5.496.41
-i--i-qrlla€1;12t13t94 105.21 5,496.43-- _lbg/16lss
1os.1o 5r96.s4
i06t27t95 105.'12 5.496.52I
-
I ogtzotgs 105.08 5,496.s6
-7-innugs tos.oo-srtgosa
Elev. I Sample
(ft-amsl)l Date
- \--_r--l -
'---i----r09/01/89::;;:t]#
'109.67 5,502.98
't09.67 5,502.
06/01 /88 |109.5815,503.07
11102t88 109.25 5,503.Iilms8l ios.2[5,503.45
o3/oo/8el losslSsoSr__t l-o3/os/8el ,0e.6 | s,!ql!
o6/21l89,'t09.23i 5,503.
1 1/15/891 109.51 5,503.1
I 1 t 1 stsel 1 0e.2 5 | 1f9_3.191
02116190t 109.451 5,503.20.-4--
03t17t92" 109.44
09/03/92
os/t s/92
12t09t92 109.64 5,so3.o1l____
os I 2a I $ t og.oo
-s,
so g. os; ----
06/08/93 109.67 55OZ98l
-, - - 1:-1-_:l'@@ ros.os sso3^odi'tautgs tog.ss -s"5o33oi
d3/16/95 109.44
*5-,Eo32t
12t11t95 109.16
06127 t95 1 09.30 -5, 5-0-335:
o9r2o/s5 109.28 5503.4
102.83 5,51 1.4
2t 11102188 '102.5 5,51 1 .- - i rr loeTaa-l 102.6i 5J1r-.---._,,.-.- -1 03/09/89J 102.515,511.80- z -osrostall rcz.als,ut.to
1 ' 06t2',U89 102.49 1 5,51 1 .8'l1 ' 06t2',U89 102.49 i 5,51 1 .81.' ')- T-tl
4 66rn4106| 4daC.Ia4 I1i1i 09/01/891 102.6r5,511.70
-T ozrorsoJoza rsll-?B
?r- i I
__--L,_,+---l- - Ti6a7o8/00.i 1o2l6iTq12 14
1, 08/07/90. 102.56 5,51'1.74,,_:__L__i__
1 I 1 1/1 3/90 | 1 02.5 , 5,51 'l .802t!!' 7': wnt tg'ti - ru1 *:-u,517u2 -__l---I-
1 05t21t91 102.45 5,51 1 .85z -,
;--*--
2:08t27t91 102.58 5,51 1.72
1 otii24ts1, roz.o-ssit.7o
1 02.1 I
102.4
't 02.36
101.87
101 .95
't01 .97
't01.52
10'.1.70
101 .35
101.20
|s-stz.t
-- llTih'grsi)
zl'tztogtgz----+-_--2t 03t24t93I _-_--2i 06/08/93-'-znsnitei
- * ,i ia14ts3
z osD4i04, ,_-. +-2t o6t15t94
___zl[81B;ot2t Ogl12194___ t.___-.2l 12113194_ ___]_2t 03/16/95l_
2106t27t95* -nIosnoqs__f_ ___2 12t11195
101.00 5,513.
100.77 5,513
't00.44 5,513
103.17i5,511.1
76.9i5.493.45!___+_.: --- r
77.415.492.95.
J----t
-!.41Jlt_-
09/01/89 109.36
]__ _-l_
1
I
Page 5
Gwhead.xls - CorrData 3t15t2001
- lGrounawi-
I
Date I-l- -:I'', wIMCE
ater Hear 9_19
-...--1,-.-l L ___ I
i .-- - - i
nstalled:
rate P/A
teGtion:
10t22t82 ----- -+ . .--
II ,-.,
l-amsl) ,
10t22t82 nla Sep-89 I acttve
5SO3/
active actrve
i f55?035
active
5,614.30 5,612.65 5,601.64
MW-11 Water Level MW-121 Water Level MW-13 Water Level MW-141 Water Level MW-15 Water Level
Data I Sample I Depth I Elev Sample I Depth I Elev. I Sample
oaie I rn um;)l(ft-amsr)f_bJg_
o3/2-8i's6'l' .":"-:- :i
ooloTrgo 109.31 5,503.34:
os/r6790 109.21 5,503.441
Depth I Elev. I Sample I Dentn_l Elev.
(ft bmp) I(ft-amsl)l Dqte | (ft bmo)l(ft-amsl)-Tt--l 03128/e6' 104.s1' 5,4s6.73\l I ooloztgo 105.20 s,496.44
o,atri l1t.u1n) | {n-"..
03/28/96 107.10 5,496.3
o-o/o7l'go 107.45 5,495.9
oslioTs6 107.42 5,4s5.s
tlt2ziga i07.1o 5,4e6.3
rilt2oyg;t 107.44 "5,495.9
o6t11tg7 107.13 5,496.2
09/30/97 107.31 5,496.1
03/16/98 "107.00 5,496.4
o5t12tg8 106.83 5,496.5
osh4tsE 107.20 s,4s6.2
1 1/03/98 107.50 5,495.9
o2l18/99 1o7.OO 5,496.4
oltoTtss ." :.:. _,'. "
."
05/1 1/99 107.45 5,495.9
ozloolgd 107.10 5,496.3
09/28/99 107.32 5,49b.0
izTogrgg 107.40 5,496b
grlgq{o_o ., '"; ,' ;-:::.'.;
03t17 t00 107 .25 5,496.1
oiiiOqlOb :j, ",r,'i'.,! t. :ii) :*' :,. t.- ,:, ,.,:..05/02/00 ; '; .' " 'r
d5/1 1/oott''" I:': j:' '
osllsloo - -.i ,"j. - .,. .
05125100 - l;' ',:;
06/06/00,,.,....: :","
06/07/00 107.35 5,496.0
06/09/00 - '' '
06/26/00 ,: ,07/06/00. ,,.
07113t00 :'
ozTiaroo' i;
O-glOSlOO :r :'l'. ': ,,', '
08/15/00 " ::; !-{-+.: 1i -
o8/3i70o . ::': ::. 'r.,
0e401/oo: ,.-..- '- . . --09/04/00 107.36 5,496.C
ogtosto-o' - -- .j' ' '-=' '
cdoA;11t23tOO' 1oi.a1
.t
SourCel grtq_l 1! orp) I (ft-amsl)
03/28/96 100.42 5,513.882
2 06t07t96 100.50 5,513.80
2 09/16/96
2:, tllzzna
zl oirzolgi
z: oayist
2,09t30t97_
2 03/16/98
2t 05112t98
2 09124198
z:tttoltgia
z:oiltatgg
z oqioitse'
2 05t11199
2 07106199
2' Ostrstsg
2-12t69t99
z o11-oj19y;.
2 03117100
z: oqioq,too i"
2 05t02t00'.
2 05111100 .
2 05/15/00,
2 05t25t00 "
2 06/06/00
2 o6to7/oo'
2 06/09/00'
2 o6/16/bo'
2 06t26t00
2 oTtoitoo
2:o7n3too '
2 07t1}tOO
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3 11i27tOO:
100.26 ssr404l
1oo.05 5,514.251
100.56 sr513J4l
99.95 5,514.351
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99.50 5,514.801:1
99.40 5,514.90
99.50 5,514.80
100.00 a,sia.i-0
99.75 5,514.55
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5,496.67
5,496164
5,496.84
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03/16/-98 1o5.OO
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07106/99 105.00
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07106/99 109.30 -5,503.45i
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06/26l00
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Page 6
Gwhead.xls - CorData 3t't5t2001
Water Level
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Page 7
Gwhead.xls - ConData 31151200'l
Water
activt
5565.r
Elev,
(ft-amr
----l--.-iI Date lnstalled:
reteLr
Date
87.38 5,491.21
87.59 5,491
87.38 5,491.21
ffi:ffiMi:dll@
87.15 5,491.44
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92.26 5,568.75
92.00 -5-,569.01
92.12 5568-89
91.82 5,569.19
85.06 5,575.95
06/15/94 91.65 5,569.36
08/18/94 91.49 5,569.52
it
03124193 85.48@gq Bs.4s
09t22t93 85.30 5,573.1
12tmt% 85.15owUsa 87.42'5,571.04
06/15/94 84.84 5,573
08/18/94 84.70 5,573.
12t13194 84.405,574.06't2113t94 91.32 5,569
12t11t95ff.
06127t95
o9/20/95
Page 8
03t24t93
06/08/93
09t22t93
121',t4193
12t13194
03/16/95
06t27t95
09/20l95
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Gwhead.xls - CorrData
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o6io7i96
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0'5/1 1/99
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Page 9
Gwhead.xls - CorrData 3115t2001
activr
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Page 10
Gwhead.xls - CorrData 3t15t2001
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WLMP Elevation 5520.97 llt 5622.08 5628.22 5635.73
2 Water Level TW4-1 Water Level TW4-2 Water Level TW4-3 Water Level TW4-4 ter Leve
Data
s;;a€
slmnle_
Date
_99Pth
(ft bmp)
. Elev.
(ft-amsll 9_?!Ple
Date
Depth Elev.
(ft-amsl)
Depth Elev.
(ft-amsl)!qrpLu
Date
Depth
(ft bmP)
Elev.
(ft-amsll
salp!g
Date
Depth
(ft bmo)
Elev
ft-am(ft bmp (ft bmp)
2 03t28196:.'l, -;i
_ :tq_ololigq#.iJj
? r 99il Y96:lai',::,i211122196i{sEB
/-r--i \
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2 09t30t97 ::,,i;l:{!,::
2' o sl io/tiil-:'l-'.:#rr$Fi' f{i
z. os1 zrsa ;r..,xffi,"i i 1{;:.,.2 09 t 24 t 98 1;;, :;ftIffiF+li:r,.
2 liloslga=.'''-';iif't;li:,, ;'''
z, o2t 1 a t ss t.: :;.j{ffi ;i{.:i j ."j:1,., 9aay7!;{,ffi;.}kiiH2 05111199 ",::"jdb;)i,,r:lr:; .
zl Oil OA t gg;.--:''fi i;'i .'",:, ;,;
z I oelzalgs j"ill**i"/trJxsh':,1i'," 2. lztostsni.;i::1.S?$*-11i1lg*:
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03/ 1 7/00 ii:..;i.*'.:i E.,6i.,-;i1.1
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2 0610T lOO ;. ,;,;!*r.. ',.rr i,r.-:.;- a:"::,9i". -., 7.:.2 og/o?/99..:,.&r.,.
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2 o7tootoo' .l;i-i'.': ;..1',
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2 07 t2SiOO t:'.1-'1.;5t*i; i:: :.i'*'- z o9i94eo_,,::, j*f:;,.,;;a,
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I-,,1_73.52I 5,554.--i----3
Gwhead.xls - CorrData
Page 12
Gwhead.xls - CorrData 3115t2001
I
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Page 13
Gwhead.xls - CorrData 3/1 s/2001
active
to41J
It- - -.
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i Date P/A:, l---I WLMP Elevation:
11t17
Elev.
(ft-amsl)
_1=i__|* --i-
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Page'14
3t15t2001
rlUC Whitr- 19'91ffi
1.....-lDate. _ -_t _ _tt.-i WLMP E
: Mesa lV
ata-r He;1l
939_ _l
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12t13199 il11tOA 11117199 11117199
active
tt-imsii
active f--active active I activr-t I so+t.5644.20 5612.28 5624.57 5621 .7
iTw4-5 Water Level TW4-6 Water Level TW4-7 Water Level TW4-8 Water Level TW4-9 Water Leve
uala ,_5-qTple_
Date
Depth Elev.
(ft-amsl)
Sample Depth.Elev.
{ft-amsl
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Elev.
(ft-amsl)
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2t I r / i-r-\/l -\rl--'-l-l
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2 OTtO6tO;O;. ; .r..". i....'.";..
2' 07 t13too'.. i'';. :-i.i;.:':i:'
2 07118100, ".'i :.^ il-,*. ,.|,]2 07t25t00....,.. .:,jir ." ....._, - -i.'"- r.- .:. "..''.i| ;!i2 08102100 r;:i^.'t?:--: ":'.i: 1 "+
z : oato gloo "il {.r..$:t€,g1--f4;:
. i'.' tJ-- J...r.1, .J;'..2 08/15/00 ; ;;-. ;1,r.:1.';!:-"s.":r
z oarcrroo[f;=iET'#ff
2 09{01 /qq :11,n,.. i*.h.: :"i, ::;.;i2 09/04/00 X: .i, , .";.1.: ri ''^'. :
2 09/05/00'i:"^i. :li':r'i:', i;,,.!E; :
03 I 17 100 ii /:r,fs" ;;!-r4;i:3;n*i
o4l04/oo rI1-:X:jtf
06/26/00;" .J',,r..' r:*j!.
' :, ' .i. .:':. '! :07/06/00 *.,ii . ,' :" 't"'
oot2-oibo :r .' -.::':il;ltlrt:.
61766166 i,-"i:,, 11i::-,.q i li::
07 I 1 3tOO'': :.':'lan:'l' ::.'
{-1 - ';' .r}.';,:.;' .":: " r-r
07118100 . -. . ,..:..r ,:, _,,
07/1 1/00 i.i.: ; .1.,o7t18too: '' ':
9129-99 i,'r''.lj'"
08/02/00 $*:_*1i"*.1
----.- --.
.."- *i*
08/09/00 li ,r:r.---.:
O8/15/00j"'".-:.r.jd
o8i31lOO:xi;:'.-: .i_ -____+" iiim
09/0 1 /00 o:.r.-'. ;-,o;
os/04/00 i$?*;i.i;fi.
l'r F;i;1i..
j;:..-... *"
. -_.. , .,i ._
{';Tt''ir;:.aiit;::
O7l25lOO ::i ; -, I l.:1r_-: j, .
O8iO2lOO il*,r.P'-{+'-+F .; :-,
oa1b91oo ;. r;1: ,;, .,1. i;,- i
0 8/ 1 5/0 0 1::i.f*"+'1f]ji*::"j ::,',..+_ _ et5tril]#h!}t41}it,{.\1:.
Itf;ir;:r;.
.;4ffi*:lJr;r':1;
.?}^-1i-r.
0 9/0 5/00,1*.E**XtS.la:$l:,:gi
11t27tOO AA2s5r 5,525.Sg
J 11t28t00 86.695,525.59 l.l11t29t00 72.46
L
i.sas.z3 11t29t00 59.10 5,585.10 '_T 11t29t00 64.62 5,559.95
-1 I
Gwhead.xls - CorrData
Page 15
Gwhead.xls - CorrData 3t15t2001
Cell: C5
Comment: Date P/A = Date well plugged and abandoned.
Cell: Y5
Comment: MW-13, Plugging and Abandonment Date: well MW-l3 plugged and abandoned as part of Cell 4A construction, see 6/23/89 Umetco memo from
Sampson to J.S. Hamrick (in August, 2OOO lUC "Construction Report Tailings Cell 4A White Mesa Uranium Mill - Tailings Management System",
unpublished company report by Harold Roberts, consultant; Appendix G). Umetco memo states that 4" PVC casing reamed down to 120 feet bgl
(well TD - 1 15 feet), and that cement slurry mixture pumped into new boring as drill pipe was removed
Other Related References:
1) 7/94 Titan Environmental Report, Table 2.3 says MW-l3 was destroyed during Cell 4A construction.
2) May, 1999 IUC Groundwater lnformation Report cites that Cell 44 was constructed in 1990 (ibid., Part C, p. C-51)
Comment: Water Level Measuring Point Elevation (ft amsl): elevation data for each monitoring well is from new engineer's survey of IUC monitoring wells
reported in the 9/8/00 IUC "Groundwater lnformation Report Revision Package", Attachment 2; unless amended by additional DRC staff research
Comment: MW-1 3 Water Level Measuring Point Elevation: data trom 7194 Titan Environmental Report, Appendix B, Phreatic Elevation spreadsheet.
Cell: BC6
Comment: TW4-2 Measuring Point Elevation: from 8/28/00 Landesign surveyors drawing (Rev. 1). This value, 5628.22 ft amsl, differs from that found in th
9/8/00 IUC Report, Attachment 2 (5625.00 ft amsl).
Cell: BU6
Comment: TW4-8 Measuring Point Elevation: komBl2SlOO Landesign surveyors drawing (Rev. 1). This value, 5624.90 ft amsl, differs from that found in th
9/8/00 IUC Report, Attachmenl2 (5621 .71 ft amsl).
Cell: A9
Comment: Data Source: key to sources of information, as follows:
1=7194 Titan Environmental Report, Appendix B, p. I
2 = 918100 IUC Report, Attachment 7 tables.
3 = 11127 - 1211100 DEQ split sampling event.
Cell: 813
Comment: MW-1 , 9/1 O/79: this value rejected by DRC based on fact that well was installed in 9/79 and large apparent outlier depth to water value.
Cell: C13
Comment: Red Text = data omitted from the 9/8/00 IUC Report.
Cell: N20
Comment: MW-s, 5l3O/80: this value rejected based on head is about 4 ft lower than rest of trend and was measured shortly after well installation (5/80).
Cell: Q29
Comment: MW-1 1, 1127182: this head value rejected by DRC based on fact that well was not installed until 10/82.
Cell: T29
Comment: MW-12, 1127182 this head value rejected by DRC based on fact that well was not installed until 10/82.
Cell: L48
Comment: MW-4, 3/1/86: this value appears to be an outlierwhen compared with adjoining data, see hydrograph.
Cell: F70
Comment:MW-2,6/1/88: theg/8/00 lUCReport,AttachmentTliststhisvalueasll0.33ft(insteadof 110.4,2/93Peel Env.ServicesReport,AppendixD).
Cell: F80
Comment: MW-2, 9/1/89: the 9/8/00 IUC Report, Attachment 7 lists value at 1 10.4 ft (instead of 1 1 0.0 ft, 2/93 Peel Env. Services Report, Appendix D).
Comment: MW-15: water level depth data was illegible in the 7/94 Titan Environmental report, Appendix B, Water Depth spreadsheet. However, legible da
was found in the 2/93 Peel Environmental Services report, Appendix D.
Cell: FB4
Comment: MW-2, 2/16/90: the 9/8/00 IUC Report, Attachment 7 lists GW depth as 109.98 ft (instead of 110.01 ft, 2/93 Peel Env. Services Report, Appendi
Page 16
Cell: AF105
Comment: 1 1 l31l92, MW-1 7:
Gwhead.xls - CorrData
water level depth from 2/93 Peet Environmental Services report,Table 5.1-1
12t92.
Water level later rejected by
3t't5t2001
DRC because IUC r
Cell: A1105
Comment: 11l3)lg2, MW-18: water level depth from 2/93 Peel Environmental Services report,Table 5.1-1. Later this data rejected by DRC after review of lt
well completion dale, 12192.
Cell: AL105
Comment: 1,t12lg2, MW-19: water level depth from 2/93 Peel Environmental Services report,Table 5.1-1. This value later rejected by DRC after comparis<
with IUC well completion dale, 12192.
Comment: MW-17, 6/7/00: the 8/30/OO IUC Semi-Annual Monitoring Report to NRC (Iable V) reported the water table elevation = 5491 .39 ft amsl on this d:
Cell: N161
Comment: Data from DRC/IUC split sampling event of 1'1127100 - 11/30/00.
Cell: O161
Comment: Data from DRC/IUC split sampling event of 11127100 - 11/30/00.
Cell: Tl61
Comment: Data from DRC/IUC split sampling event of 11l27lOO - 'l 1/30/00.
Cell: AX161
Comment: Data for this well obtained during a ORC/IUC split sampling event between 11127100 to 11/30/00.
Cell:8G161
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11127100 to 11/30/00.
Cell: BM161
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11127100 to 1 l/30/00.
Cell: N162
Comment: Data from DRC/IUC split sampling event of 11127lOO - 11/30/00. For low-yield wells MW-S, MW-12, TW4-1 , TW4-4, and TW4'6, the 'l 1/28100
measurement was done about 24 hours after initial purging.
Cell: T162
Comment: Data from DRC/IUC split sampling event of 11127tOO - 11/30/OO. For low-yield wells MW-S, MW-12, TW4-'l , TW4-4, and TW4-6, the 11/28/00
measurement was done about 24 hours after initial purging.
Cell:2162
Comment: Data from DRC/IUC split sampling event of 'l1l27lOO - 1'l130/00.
Cell: AC162
Comment: Data from DRC/IUC split sampling event of 1'll27lOO - 11/30/00.
Cell: AX162
Comment: Data from DRC/IUC split sampling event of 11127100 - 11/30/00'
measurement was done about 24 hours after initial purging.
Cell:8G162
Comment: Data from DRC/IUC split sampling event of 1112710O - 1'l/30/00.
For low-yield wells MW-5, MW-12, TW4-'l , TW44, and TW4-6, the 1 l/28100
For low-yield wells MW-5, MW-12, TW4-1, TW4-4, and TW4-6, the 11/28/00
measurement was done about 24 hours after initial purging.
Cell:8M162
Comment:DatafromDRC/IUCsplitsamplingeventof 11127100-1'l/30/00. Forlow-yieldwellsMW-5,MW-12,TW4-'l,TW44,andTW4-6,thel1/28100
measurement was done about 24 hours after initial purging.
Cell: AOl63
Comment: Water Levels in MW-20, MW-21, and MW-22: measured by Loren Morton (DRC) with Wally Brice (lUC) during a 1'll29l90 site visit.
Page 17
Cell: AR163
Comment: Water Levels in MW-20, MW-21, and MW-22:
Cell: AU163
Comment: Water Levels in MW-20, MW-21, and MW-22:
Cell: BD'163
Gwhead.xls - CorrData
measured by Loren Morton (DRC) with Wally Brice (lUC) during a
3t15t2001
11129100 site visit.
measured by Loren Morton (DRC) with Wally Brice (lUC) during a 'l1l29loo site visit.
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11127100 to 11/30/00.
Cell:8J163
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11127100 to 11/30/00.
Cell:8P163
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11l27lO0 to 1 1/30/00.
Cell: 8S163
Comment: Data for this well obtained during a DRC/IUC split sampling event between 11127100 to 'l 1/30/00.
Cell:8V163
Comment: Data for this well obtained during a DRC/IUC split sampling event between 111271O0 to 1'l130/00.
Page 18
ATTACHMENT 4
Utah Division of Radiation Control
Summary of General Material Properties
of Subsurface Geologic Formations
from Various IUC Reports
DRC Spreadsheet matprop.xls
Tabsheet: Sheetl
li
3t1212001
--
rl__
Depth DRC
Calc.
Qltr rrrliar
Atterbero Limits l
lnterval Moisture Reported Retained Liquid Plastic Plastic
Eedrock Well (ft, bss)Content Drywt.Porosity Particle Saturation Limit Limit lndex Rock lnfo
% vol.Formation ID Top Bot.wt.%Vol. %(tb/ft^3)o/o Sp. Gr o/o %o/o o/o o/o Type Sourc
Kds MW-16 26.4 27.1 1.51sryili 3.3 135.2 '17.9 2.64 18.2 18.44 5.1 nla nla nla;i;'SS
ss- -2andiMW.16 l6x 3.3 135.2 2.64 18.2 5.1 nla nla
MW-16 37.8 38.4 0.4 0.8 127.4 ,22.4 2.63 3.7 3.57 6.3 nla nla and
MW.17
MW-17
27.0 27.5 o.2s 0.6 138.8 13.4 2.57 4.8 4 5.1 nla nla nla SS
?ya_
,;;d'
27.0 27.5 -{ts,u.l 0.6 't38.8 13.4 2.57 4 {,*.\.:i15.nla nla nla
MW.17 49.0 49.5 3.62 7.1 121.9 26.0 2.64 27.2 27.3 9.6 nla nla nla SS
MW.17 49.0 49.5 €16r?:qn i.5.b 7.1 121.9 26.0 2.64 27.2 9.6 nla nla nla SS
- tnzKbc
MW-16
45 45.5 5.6 12 140.16.4 2.7 77.2 76.83 nla 29.6 15.4 Mds-s and
i'aia47.5 2.56 5 142.8 12 2.6 48.9 49.17 4.37 nla nla SS
MW.16 47.5 5 142.12 2.6 48.9 i,S:iS4.4 nla nla nla SS
MW.16 53.5 54.1 0.68 1.4
1A
129.0 19.9 2 7.1 _ t.ol I 6.38
| '"ri.6.4
I
nla nla nla SS
MW-16 53.5 54.1 i.c#,0.z 129.0 19.9 i 2.58 | 7.1 nla nla nla SSt_L_
MW-16
MW.l6
60.5 61 0.'l 0.2
0.2
117.9
11Zt
27.6 2.61
,.61
0.8
o3 *___9.72 I S.89
I'qtsos
lnla ln/al--+ -ln/a 14
nla SS
{{na60.5 6 ,.1roll nla U)
MW-16 i 65.5, 661 2.62 5.5 131 5 19.61 2.62 28.2 28.06 I 7.13 lq" L{q nla SS
lnformation
'l) = 2/93 P
2) = 7194 Tt
3) = 5/28/91
MW-16 | 6s.51 66
--
| --f-,MW-16 i 6s.5t 66
2.62 I 5.5t_,__.__l-i.q
I
l-:i.:
I
l-ii
I| --n5
l__ *
1___I e.8
II 0,4
l-o:t-t-,L__
rort, Tat--.--:-pon, r a
R"p"(
't31 5 2.62
19.3 2.62--_-_l_--
I
__ _zo.-o,i-_;:tii20.61 2.63
___t_____
18.5 i 2.64-- -ra.si- - 2.s+----' - '1
-*-]i -iul
2i 2.64
I____L--29.11 2.67
I
1.7 t, 2.67
-_-+-**,1.7 | 2.67.l___
Il_
I
1___lii---1-----, ____ l__
l
1 28.2t___.-i 28.2
Ii_____- --i 1.3l-- ------. -I 1.3t-'- -^-t--, -l 0.6';-,--,- -'.-.... ,"..I 0.6i----..----'
!,---- --. --i 1s.8
SS- itis
lt_I 33.8f___.__--
II=trI 26.6L___
L
t_
I
I
1
t-----
It-- .--.-- ---- -.I 1.46f---t-
Il___.-.,i 0.54t-- -t-
I| ,- . ,-.-,- -i 1s.00
Ii.-*_
I
I 33.68
I+--I 23.53t---
l--__lKev to Noli;6ry1'tsH.';:i;&r' i-,
l.r,,isi":',
I . Bold"-"
I 7.1
l__ll
iL--.,--r 5.5l-..- - --.-I 5.5I--'
-{7al.** ,-
| ' ',1 +.9
II or5
l:.*::.0:s
I
l!!--_
I o.ar
Fmo:L__
es:
i= r"lr.res1@l=rg:r
lryL-F4-ln/a ln/a
t:-_ i_ -
lnla 'n/ai -. -. --.-;-,. - ---.-',nla in/at- i-- -
I nla- inlaI ___--]._,__-_ -_ln/a in/a _lilnra inli -
lviiryr -l_!__I 33.7i 16.2f--1.--l./, i./aI _ 1_,__- _
ln/a __ln/al_l_i -r----differentlhan Fr
nt rounding erro
rpparently NOT
T-*-'r-'--
nla SS
SS
l_
[9s
t!!
Ii-- -" -ISSl--,-
ISS
ISS -iSSr--
L
lctsi--
-It,.__-
199 _lssF-'
t__ _
II-_-
portsr--I-
undingr-
ffi:[131 .5 nla
lna--iv;--l_i{r_
I n/a
l-,-,_
1vr
I n/ai_
l-"'-u
I
l,v,E,f_ _,l--L_,
:vious re
'S
lue to;
III- -.- '_J---l-MW-16 73t 73.5!.--.---.i.--- L---
IMW-16 i 73i 73.s
l1,_i--
1!tw116 I y?,,82.!
IMW-16 ) 821 82.4l. .-.- ---1-. ----r .---
t___i___,
lraw-ro i goi so.z
lrrrw-ro i -go'--so7',-__1 il---1--+-
LMW:16 Le1.1L91.1ili
inr-w-rz I toq
ilr,tw--rz T- roa1-_____--- +-._105
llll-- --1---i __ !__- -i__
Sources i i
--
rel Environmental Serv
ian-gnvlronmentiGen
I rUc-crounOwater tntc
f oJ3El'r
t o"o5t-----.,l' 'o.t
iffi
l"sor
II 5.2r--I 017
lw'tr
il__
I1-t__
,ce! Xgl
/ices R€
,rn,ation
[-i{q!.I 130.3F---
l---.-
i_ 1311
i 134.31-----i____I 161 .5I 161.tl_
I1__-I 118.1T-_-L-i 161 .4l_i 161 .4
]---
I
ile 4.2-1
ble 2l -
Table C.3
matprop.xls - Sheetl 3112t2001
Comment: Bedrock Formations: key to abbreviations:
Kds = Dakota Sandstone,
Kbc = Burro Canyon Formation
Cell: K5
Comment: Calculated Saturation, S:
S=theta/n*100,where:
theta = volumetric moisture content,
n = total porosity
(from Daniel B. Stephens, 1996, "VadoseZone Hydrology.", Lewis Publishers, Boca Raton, p. B)
Cell: P5
Comment: Rock Types: Key is as follows:
SS = Sandstone,
Mds-s = sandy Mudstone,
Cls = Claystone
Cell: Q5
Comment: lnformation Source: 2 sources listed indicates that both sources reported the same values for the test and depth
interval listed.
Gomment: MW-16, 26.4 -27.1depth: bottom depth reported by the 7l94Tilan report, Table 2.1 was 38.4 feet. However, the 1
Peel Environmental Services report, Table 4.2-1 reports bottom depth as 27.1 feet. All other properties values the
same. DRC staff used the Peel depth provided.
D6
@
lvlichael O. Leavitt
Covcmor
Diannc R. Niclson. Ph.D.
Ercutivc Dircctor
William J. Sinclair
DiEctor
//i// r *),,ii,i,ot
AL auA;fi"'*'' lili?'
DIVISION OF RADIATION CONTROL
168 Norrh 1950 West
P.O. Box l4{850
Salt Lake City, Utah 8.ll l.l-.1850
(80 I ) 536-4250
(801 ) 533-4097 Fax
(801) 536-411.r T.D.D.
www.deq.state.ut.us Wcb
"@'
February 1,2000
Ms. Michelle R. Rehmann
Environmental Manager
International Uranium (USA) Corporation
Independen ce Plaza, Suite 950
I050 17'h Street
Denver, CO 80265
May, l999IUC Groundwaterlnformation Report: DRC Request for Additional Information
Related to Site Hydrogeology.
Dear Ms. Rehmann:
We have reviewed the May, 1999 International Uranium (USA) Corporation (lUC) Groundwater
Information (GWI) Report for the White Mesa uranium mill near Blanding, Utah. During this
review we also examined the July, 1994 Titan Environmental Report regarding local hydrogeology
of the White Mesa facility.
As a result of both reviews, we have identified additional information and concerns that need to be
resolved in order to move forward with issuance of a Utah Ground Water Discharge Permit
(hereafter Permit). Please resolve the groundwater hydrology related issues listed in the attached
document.
During our review, we discovered that hydrogeologic information for the White Mesa site was
scattered among several documents. We also found that other groundwater related studies had been
undertaken by IUC after completion of the July, 1994 Titan Environmental Report; which were not
includedintheMay, l999GWIReport. Inordertofacilitatethereviewprocess,werecommendthat
the July, 1994 Titan Environmental Report be revised into one stand-alone document to include all
currently available information, and resolve the attached Division of Radiation Control (DRC)
information needs.
During our meeting of January 24,2000 meeting we agreed that revierv of the engineering related
issues was the highest priority; followed by groundwater hydrology considerations and others. By
way of information, we have received your engineering plans and as-built reports in a transmittal
dated February 2,2000 which included six reports, as follows:
2.
J.
4.
5.
6.
Ms. Michelle R. Rehmann
February 7 ,2000
Page 2
t. D'Appolonia Consulting Engineers, June, 1979, "Engineer's Report: Tailings Management
System". This report was submitted to DRC previously.
D'Appolonia Consulting Engineers, February, 1982, "Construction Report: Initial Phase -
Tailings Management System". This report is a new submittal to DRC.
D'Appolonia Consulting Engineers, May, 1982, "Engineer's Report: Second Phase Design -
Cell 3 Tailings Management System". This report was submitted to DRC previously.
EnergyFuelsNuclear,March, lgS3,"ConstructionReportSecondPhaseTailingsManagement
System".
Umetco Minerals Corporation, August, 1988, " Cell4 Design Tailings Management System".
This report is a new submittal to DRC.
Titan Environmental Corporation, September, 1996, "Tailings Cover Design White Mesa
Mill". This report is a new submittal to DRC.
We rvillcommence review of these engineering plans and as-built reports shortly. In the meantime,
the attached hydrogeologic comments are intended to resolve other outstanding concerns and issues.
If you have any questions regarding the attached hydrogeologic information needs, please call Loren
Mortonofmystaff at(801)536-4262. Thankyouforyourcontinuedcooperationinthismatter.
EQ.-
WJS:LBIWlm
attachment (l)
Larry Mize, DWQ (w/attach.)
Dianne Nielson, DEQ
Bill Von Till, NRC (w/attach.)
David Arrioti, DEQ District Engineer (w/attach.)
F:\...\i uc grv-rfi 2.rvpd
File: IUC I l/30/99 Draft Ground Water Discharge Permit
Sincerely,
Utah Division of Radiation Control
Request for Additional Information Relatecl to Site Hyclroeeolosy
International Uranium (USA) Corporation
White Mesa Uranium Mill
Near Blanding, Utah
February 7, 2000
Hydrogeologic Information Needs
To date, IUC has provided three reports which partially describe groundwater conditions at the site,
these include: l) the May, 1999 IUC Groundwater Information (GWI) Report, 2) a hydrogeologic
evaluation found in the July, 1994 Titan Environmental Report [hereafter July, 1994 Titan Report],
and 3) and a point of compliance report found in the October 7 , 1994 Titan Environmental Report,
Revision I [hereafter October, 1994 Titan Report]. A number of IUC semi-annual monitoring
reports to the U.S. Nuclear Regulatory Commission (NRC), dated between February 26,1993 and
September 14, 1999, have also been provided to the Division of Radiation Control (DRC), some of
rvhich are listed below. After DRC staff review of these reports, the following constitute the
hydrogeologic and groundrvater related inflormation needs:
l. Well / Piezometer / Boring Status Summarv Table - review of the information provided shows
that a large number of wells, borings, and piezometers have been installed at the IUC facility
during design, construction, and operation of the mill. It appears that these borings and
monitoring devices have been installed at different times and for different purposes during the
life of the facility. Some of the installations appear to be in operation today; while orhers
apparently have been plugged and'abandoned. Due to the long history of the facility, the large
number borings and devices installed, and the multiple reports wherein they are documented,
a significant degree of conlusion appears to exists about theircurrent status. Consequently, we
request that IUC prepare a comprehensive table to summarize the identity, location, purpose,
construction details, and current operational status for all wells, piezometers, or borings installed
at the facility. Data that should be listed in this table include: rvell/boring/piezometer name,
date installed, ground surface elevation, total depth, purpose (well, geologic log, etc), boring
diameter, depth to major geologic contacts (e.g., depth to bedrock, depth to Brushy Basin
Member, etc.), depth to groundwater, water level measuring point stickup and elevation (wells
and piezometers), current operational status, date and reaSon for plugging and abandonment.
2. Monitorins Well Completion Details - the groundwater related reports submitted to date fail to
provide construction details for several groundwater monitoring wells at the White Mesa
facility. As a result, we are unable to conclude if these wells conform to the construction
requirements found in the EPA RCRA Ground-Water Technical Enforcement Guidance
Document (TEGD), as outlined by the Utah Groundwater Quality Protection (GWQP) Rules
[see Utah Administrative Code (UAC) R3l7-6-6.3(lX6)]. Please provide the follorving
information:
A. Well Drilling and Development Methods: All Wells - none of the groundwater related
reports listed above discloses the drilling or well development methods used to install any
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill
February 7,2000
Page 2
facility. Please provide information on rvell
of the existing and former monitoring rvells
of the monitoring wells at the White Mesa
drilling and development methods for all
installed at the facility.
B. Datum for Seven (7) Well Construction Diagrams - revierv of the July, 1994 Titan Report
shows that the well completion diagrams for seven (7) wells are missing a relative elevation
datum for the reported well construction details (ibid., Appendix A, wells MW- I thru MW-
5, MW-ll and MW-12). This missing vertical scale makes it unclear if the well
construction details and depths referenced the local ground surface or the final well's water
level measuring point. Please provide an elevation datum for each of the seven (7) wells
mentioned above.
C. Well Completion Diagrams: IUC Wells Installed or Proposed - rvell completion diagrams
have not yet been provided or need to be revised for l2 or more monitoring wells installed
or proposed at the facility, including:
l) Two (2) NRC Approved Monitoring Wells - please submit completion diagrams for
wells MW-14 and MW-15.
2) Six (6) Wells and Piezometers Reported Installed at Facility - please provide
completion diagrams for wells MW-20 and MW-22 (2128195 Energy Fuels Nuclear
[EFN] Report, Table 20), and piezometers #9- l, #9-2, # l0- I , and # l0-2 (7194 Titan
Report, Table 2.3, and Figure Fl).
Three (3) Proposed IUC Wells - please submit completion diagrams for three shallow
aquifer monitoring wells to be located south of Tailings Cell 4, including: SMW-1,
SMW-2, and SMW-3 (1194 Titan Report, Figure 4.1),
All Other Additional Wells - please provide completion diagrams for any other wells
or piezometers installed at the facility after completion of the July, I994 Titan Report.
Monitorine Well MW-4 - please revise the well completion diagram for well MW-4
to include all details of well construction. Review of the July, 1994 Titan Report
shows that the boring for rvell MW-4 was over-drilled and then back-filled before the
well screen rvas installed (ibid., Appendix A, Figure 5). Horvever, the well completion
diagram provided failed to provide several important construction details related to this
over-drilling, including: l) total depth of the boring, 2) depth interval backfilled, and
3) thickness of the lowermost bentonite seal installed below the well casing foot.
Please provide a revised well completion diagram accordingly.
Monitoring Well MW-3 - the completion diagram provided for this well did not
include a geologic log (719a Titan Report; Appendix A, Figure 4). As a result, we are
unable to confirm the hydrostratigraphic interval within which this well is completed.
Please revise the well completion diagram to include the geologic log for this well.
3)
4)
5)
6)
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill
February 1,2000
Page 3
D.
E.
Please ensure that a geologic log is p,rovided on the well completion diagrams requested
above. Well completion diagrams should disclose all key elements of rvell construction in
conformance with the EPA RCRA TEGD (e.g. Section 3.5), including, but not limited to:
drilling method to install boring, boring diameter and total depth, casing diameter, screened
and filter pack intervals, depth/location and type of annular seals, casing/screen/filter pack
construction materials, type of screen, ground surface elevation, etc.
Identification of WaterLevel Measurine Points: AllWells - none of the IUC groundwater
related reports submitted disclose or describe the physical location of the groundwater
water level measuring point at each monitoring well. Please ensure that this point is clearly
marked and identified at each rvellhead, and a description thereof provided for DRC review.
DiscreBncy of Water Level Measuring Point Elevations: Wells MW-l l. MW-12. and
MW-17 - reponed elevations for the water level measuring point for three (3) different
wells has varied from one IUC report to another. In the case of wells MW- I I and MW- 12,
these elevations have varied between i.63 and 1.87 feet, see Table l, belorv. However, for
well MW-17 the discrepancy is extremely large, over 82 feet. Please resolve these
discrepancies and provide the true water level measuring point elevation for all three wells.
Table l. IUC Water Level Mea Point Di
F. Discrepancies in Well Completion Dates: MW-l l. MW-12. and MW-13 - the July, 1994
Titan Report states that wells MW-ll, MW-12, and MW-13 were installed in October,
1982 (ibid., Table 2.3). However, Appendix B of the same report states that water level
measurements were made in these three (3) wells in January of the same year. Please
provide the correct the well completion dates for these wells.
sunn n
Reported Water Level Measuring Point
Elevation (feet, amsl)
IUC Reference MW-ll MW-12 MW-t7 MW-19
July, I994 Titan Report, Table 2.3 5,611.08 5,609.45
July, 1994 Titan Report, Appendix B 5,609.45 5,611.08
August 13, 1999 lUC Letter 5,610.89 5,609.2 r
Range of Discrepa,rcy:1.63 feet 1.87 feet
February 28,1995 EFN Report, Table l9 5657.58 5575.06
February 28, 1995 EFN Report, Table 20 5575.06 5655.05
Range of Discrepancy:82.52 feet 19.99 feet
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill
February 1,2000
Page 4
3. Additional Geoloeic Information - a Permit applicant must provide geologic and hydrologic
information, including well logs for a l-mile radius around the facility [UAC R3l7-6-6.3(E)1.
Review of the July, 1994 Titan Report suggests that several items of geologic information are
missing for wells installed at the facility and need to be provided, including:
A. Geologic Formation Interpretation - most of the geologic logs found in the July, l994Titan
report include lithologic descriptions, but did not designate any geologic formation or
formation contacts (ibid., Appendix A). As a result, we are unable to confirm the structural
contour map found in Figure 2.6. At a minimum, please provide and justify the depth to
the Burro Canyon Formation / Brushy Basin Membercontact for the following monitoring
wells and borings:
l) Monitoring Wells - MW-l, MW-2, MW-3, MW-4, MW-5, MW-l l, and MW-12,
2) Dames & Moore Borings - No. 3, No. 9, No. 12, No. I9, and No. 28,
3) FormerMonitoring Wells - including wells MW-6, MW-7, MW-8, and MW-13, which
apparently have been plugged and abandoned.
4) AdditionalWells-installedaftercompletionof theJuly, tgg4TitanReport,including,
but not limited to: l) the three (3) proposed wells south of the tailings cells [7/94 Titan
Report, pp.46-48 and Figure4.ll, and 2) any exploratory wells installed in compliance
rvith the August 23, 1999 Ground Water Corrective Action Order.
B. Geologic Logs for Wells Installed or Proposed - review of the July, 1994 Titan Report
(Figure 2.1) shows that geologic logs are missing for a number of wells at rhe facility.
These logs rvill facilitate the revierv of the local subsurface geology, and may allorv
con[irmation of the depths and elevation of the Burro Canyon Formation / Brushy Basin
Member contact in the vicinity of the White Mesa facility. Well logs missing include, but
are not limited to the following wells:
l) Two Water Supply Wells Named " 17" - two different water supply wells are found on
the site plan map which have the same name ," lf " . One is located east o[ the mill site,
the other southeast of the "Jones" well (see ll94Titan Report, Figure 2.1). Please
provide geologic logs and well completion diagrams for these wells. We alsb suggesr
that IUC provide a unique name or identification for each of these wells.
2) Four (4) Former Monitoring Wells - it appears that four (4) former monitoring wells
have been plugged and abandoned as a result of additional tailings cellconstruction
at Existing Cells 3 and 4A, including iUC wells MW-6, MW-7, MW-S, and MW-13
(1l94Titan Report, Table 2.3). No geologic logs, well completion diagrams or well
plugging and abandonment reports were found for these wells in the July, 1994 Titan
Report. Please provide the geologic logs, well completion diagrams, and plugging and
abandonment reports for these four (4) monitoring wells.
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill
February 7, 2000
Page 5
3) Five (5) Dry Wells and Piezometers - apparently five (5) wells and piezomerer have
been installed at the White Mesa facility that failed to encounter groundrvater,
including well MW-16, and piezometers #9-1,#9-2, #10-1, and #10-2 (7/94 Titan
Report, Table 2.3). None of the IUC reports submitted to date includes any geologic
Iogs or well completion diagrams or details for these five (5) wells. Please provide this
information for DRC review.
4) Proposed Nested Angle Borings - two (2) nested angle borings have been proposed
along the west margin of Existing Tailings Cell4A (7l94Titan Report, pp.45-46 and
Figure 4.1). Please provide rhe geologic logs for these borings.
4. Land Survey Information - a Permit applicant must submit plans and specifications relating to
the construction, modification, and operation oldischarge systems at the facility IUAC R3 l7-6-
6.3(J)1. Part 3 of the Utah Water Quality Regulations also requires engineering reports for
wastewater disposal systems to be prepared by a Utah regisrered professional engineer (UAC
R3l7-3-1.2(AXl)l.Certifiedlandsurveystodeterminelocalsurveycoordinatesandelevations
are essential to the preparation of acceptable engineering reports. Unfortunately, none of the
reports submitted to date provide tables of local coordinates or elevations for key tailings
discharge and monitoring faci lities.
However, we recognize that the Permit rvill be issued long after the White Mesa mill rvas
constructed; and that certain elements of the facility are no longer accessible for survey today
due to burial during construction or by tailings disposal operations. Consequently, our request
for land survey information is organized into two parts, as outlined below:
A. Accessible Discharge Related Facilities - for discharge related facilities that are accessible
today please provide a new land survey, certified by a Utah licensed engineer or land
surveyor, to determine local survey coordinates and elevations. These facilities include:
Tailines Ponds - please provide local survey coordinates for the top and outer toes of
the tailings pond berms, and all related appurtenances that are exposed at the surface
(e.g., piping, spillrvays, etc.).
Existing Groundwater Monitoring Wells - please provide local survey coordinates for
all monitoring wells at the facility, including, but not limited to: MW-1, MW-2, MW-
3, MW-4, N4W-5, MW-l I, MW-14, MW-15, MW-17, MW-lg, MW-lg, MW-20, and
MW-22. For each well please include the following data and survey accuracy (EPA
RCRA TEGD, Section 3.5): local horizontal survey coordinates (t 0.5 foot), ground
surface elevation (t 0.01 foot), and elevation of groundwater water level measuring
point (+ 0.01 foot).
3) Three Prooosed Monitoring Wells - apparently installed south of Tailings Cell 4,
including SMW-1, SMW-2, and SMW-3.
r)
2)
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page 6
4) Explorator.v orTemporalv wells - recently installed near IUC wellMW-4 in responseto the August 23, Lg99 Ground water Corrective Action order.
5) Water Suppl.v Wells - please provide local survey coordinares for the five (5) deepwater supply wells installed on site, including warer wells WW-l thru WW-5 (7/94Titan report, Appendix A). Please ensure that all these wells are also located on thesite plan map, especially WW-5 which has to date not been plotted thereon (ibid.,Figure 2.1).
6) Nearby Stock-watering Wells - please provide local survey coordinates for all of thestock-watering wells found near or adjacent to the white Mesa facility, as Iisted in theJuly,1994 Titan Report (Figure 2.1), or this request for informarion.
B..forfacilitiesthatareinaccessibleforsurvey
today due to burial by disposal operations, please provide the following information fromexisting IUC survey data:
l) - we anticipate that essential design andconstruction details for the tailings ponds will be prorid.d in the engineering-designplans, specifications, and/or construction as-buili reports, e.g., tailing, pona no-o,location and elevations; interior slopes, elevation of internal ip.r, sumps or pumps,etc' If after receipt and review of these materials, soon to be submitted, we determineadditional information is necessary, we will contact you accordingly.
2) ExistinS and Proposed wells and Geolosic/SoilExploratorv Borines - no local surveycoordinates have been provided for a number of borings ono *.rrr r,ave been installedor proposed for installation on site, including, but not limited to:
a) Deep Dames & Moore Exploratory Borings - including No. 3, No.9, No. 12, No.19, and No. 28 (ibid., Appendix A),b) Former Monitoring Wells - including Mw-6, MW-7, Mw-g, and MW-I3 thathave been plugged and abandoned,c) Proposed Angle Borings - Iocated west oITailings Cell4A, including Borings A-I and A-2. Please include direction and angle of said borings (ibid., Figur."+. t;.d) Dry Wells and Piezometers - including rvellMW-16, and piezometers #9-l ,#g-2,#10-1, and #10-2 (ibid., Table 2.3).
Please provide local survey coordinates and ground elevations for ail these wells andborings.
5.-aPermitapplicantmuStproVideahydroIogic
description of the discharge facility, including groundwater florv directions and gradient [UACR3l7-6-6.3(E) and (lXl)1. Review of the IUC reports submitted shows several discrepancies
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill
A. Suppl_v Well WW-2 Driller's Log - the driller,s
pack was installed between the l5 inch boring
in groundwater water level data provided. Please resolve the fbllorving items in order completeand correct existing groundwater flow direction and gradient information:
A.
February 7,2000
Page 7
I - review of theve
July, 1994 Titan Report shows that the reporred groundwater elevations in Table 2.3 for a
Table 2. Di
B. Re the reported water tableelevation in well Mw-17 for August, 1994, 5,570.2 feet, is approximarely 80 feet higherthan any other groundrvater elevation reported for this well in any of the IUC r.po.t,submitted to DRC (see2l28l95 EFN Semi-annual Repo(, Table l9). ptease resolve thisapparent outlier.
C. _ review of the February 2g, 1995EFN Semi-annual Report shows reported water level elevation of 5,490.36 feet, whichcorresponds with a depth to groundwater o[ 164.69 feet, based on the reported water levelmeasuring point elevation of 5575.06 (ibid., Table t9). However, the July, 1994 TitanReport says the total depth of MW-19 is 149 feet. Please resolve this error.
sM for W upply Well WW-2 - as you recall, aPermit applicant is required to demonstrates that the discharge can be controlled and will not
November 19, 1992 sampling event are inconsisient with values provided in Appendix Bof the same report for the same day. Please resolve these discrepancies which range from0.01 to 1.67 feet, and are summarized in Table 2, below.
migrate into or adversely effect the quality of any other waters oIthe state [UAC R3l7-6-6'3(G)1. During DRC review of the July, 1994 Titan Reporr, we discovered that the currenrconstruction of water supply well WW-2 has created a potential open conduit between theshallow and deep confined aquifer. This conclusion is based on theiollowing observations:
w
6.
log shows that a very long annular gravel
and the 9-718 inch steel casing, across a
lscrepancles tn Ke ater Level Elevations:{ovember l9 r qq?
Reported Water Level
Elevation (ft, amsl)Delta
Elevation
(ft, amsl)
Reported Water Level
Elevation (ft, amsl)Delta
Elevation
(ft, amsl)
Well ID Table 2.3 Appendix B Well ID Table 2.3 Appendix B
MW-l 5572.77 5572.55 0.22 MW-l r 5508.55 5507. l0 I.45
MW-2 5503.43 5503.46 0.03 MW-12 5499.77 5501.44 1.67
MW-3 5471.58 547 t.46 0.t2 MW-14 5491.05 5490.81 0.24
MW-4 5530. t5 5530. I 6 0.01 MW- t5 5490.34 549 1.04 -0.70
MW-5 nJa 5500.89 5500.89
DRC Requesr for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2OOO
Page 8
depth of 100 feet to the bottom of the casing at 1,250 feet belorv ground surface (BGS,ibid', Appendix A, well drillers report). Thisinnulargravelpack must be very permeable,in that its particle size was reported to range from 3/8 to 3/4 inch (ibid.). Below the 1,250foot depth, the well was constructed with a simple 635 foot long open hole completionacross the Entrada and Navajo Sandstones(total iepth = 1,8g5 re.i, i6ia.;. A submersiblepump was then installed inside the well casing at a depth of about 1,000 feet BGS (May,l999IUC GWI Report, p. A-21). No informatlon rvas provided regarding any annularsealat the bottom of the l0 inch steel casing; which leaves the possibility for fluids in theannular space to flow around the casing ihoe and into the weil casing.'
B. _ nearby to Supply Well WW_2, is foundIUC monitoring well Mw-18, where groundwater was found ri o o.ptr, of about 9i.4 feetbelow ground surface (7/94Titan Report, Appendix A). Depth to the upper Brushy BasinMember contact was reported to be aboui i39 f..t below ground surface (ibid., peelEnvironmental Services well completion diagram). This leaves a saturated interval ofapproximately 39 feet in the shallow unconfined aquifer open ro the annular gravel packof WW-2.
C.-comparisonofthewelIcompletiondiagrams
shows that water level in the deep aquifer is lower than the shallorv aiuifer; hence theshallow groundwater can flow downrvard into the deep system. This evidence is found inthe higher level in Mw-18, located at a depth of about 9l feet BGS and the head in thedeep sysrem ar abour 450 feet BcS 1l[)+ Titan Reporr, Appendix A, Mw-rg weilcompletiondiagramandww-2welldriller'sreport). Furthermorl,theapparentdownrvardhydraulic gradienr is rikery grearry exacerbatei during periods or pr*iing.
As aresult, it is apparent that a potential avenue of hydraulic communication may exist in theannular space of supply well ww-2. Such a conduit could result in degradation of the deepaquifer groundwater-quality; especially if tailings pond seepage was to adversely impact theshallow aquifer and find its way to the vicinity of WW_2.
i,xl';:il:"r*:r^ll::.lln,,thepotentiarforporrutionorthedeepaquirerissmauasrongv..rsrr sJ rvrr5
::,::,, H:1 :b,."'li,r:,lrely pumped,.il_d_:ll'annurar seepage removed by the pumpingaction. However, if and when supply well ww-2 is closed and abandoned, cascadi
I:.1jl:,:halro:,/ aquirer ;1{1; ;;.;;;;';;;;;;';;:":::i;Ti:::"';: :::,'Jthe deepEntrada,/Navajo Sandstone aqui fer.
In order to prevent this possibility, it will be important to complete special measures forplugging and abandoning supply wellWW-2, presumably at the time of mill site closure. SinceJ atvtL rr rr _L, prcsuulauly a[ lne Ume Ot mlll Slte Cthis is not an imminent activity at your facility, we p.opor. that a condiil", u" rljadded to the draftvu rv tltv uldlt
i."::::: :.^1i,]: ]Y9,. rr:p,o..,o ptan for ipp.oror o, ,o*. furure date regarding the specialmeasures needed to adequately plug and abandon this well.
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February '7 ,2000
Page 9
7' Monitoting'T.t,ing ond Erolro,ion Plrn fo, o,h., Suppl.u w.ll, - in order to fulfill therequirements of UAC R3l7-6-6.3(G), as mentioned auor., rt,r ,.poftant to evaluate all thedeep supply wells at the facility to ensure they have adequate annularseals to isolate the deepand shallow aquifers. ReView of f: driller;s logs provided in the July, l994Titan Reportsuggest that annular leakage is possible in three (3iotirer supply rvells at tie facility, including:ww-1, ww-4, and ww-5. This conclusion based on: l) ti,l a.itt.r', reporr that surface sealswere Iimited to depths of l8 to 125 feet for these supply wells, and 2) the jeologic log of nearbymonitoring wellMW-18 which suggests the baseoitr,.shallow rquif".iJfound below 125 feet.PIease provide additional information to confirm and document construction of the these watersupply wells at the facility. In the event that IUC is unable ro documenr and justify howadequate annular seals were constructed in these supply wells, please provide a ptan fo. sLlringthis problem.
8' Nearby croundwater water Rights - a Permit applicant must disclose the location of all waterwells, including the status and use of said wells, rvithin a l-mile radius of the discharge IUACR3l7-6-6'3(D)l' DRCreviewof thegroundwaterwellsandwaterrightslistedintheMay, 1999IUC GwI Report (Figure A-3 and Table 44) shows thar seven (7) warer rights were omitred,as outlined in Table 3, below. Please revise the July, 1994 Titan Report (Table l. I and Figurel'3) and the May, 1999 IUC GwI Report (Figure A-3 and Table e-iy to include these missingwells and waterrights. one waterright o*n.Jby a Mr. Lorenzo Harvkins, appears to be locateda short distance southwest of the tailings ponir, and may pose a point olexposure shouldgroundwater under the tailings ponds become contaminated.
with regards to the terminated water rights listed in Table 3, belorv, please conduct a fieldsurvey and submit evidence to confirm that these water wells in fact were not drilled, or wereplugged and abandoned.
9' Revised Site Plan Map - a Permit applicant should include a site plan map of all water wellswithin a one-mile radius of the discharging facility tuAC R3l7-6-6.3(D)j. nigure 2.1 of theJuly, 1994 Titan Report provides a map oimost bt.l-ngs, monitoring wells, exploratory wellsat the time of report issuance. However, several welG, borings, a,id piezometers have beenomitted from this drawing, including, bur not limited ro: .supply well WW-5, boring No. 21,piezometers#9-1, #9-1, #10-1, and #10-2, and former monitoring wells MW-6,1r4w-7, Mw-g,and MW-13 (see discussion above). Certain other wells have also been installed andexploratory borings drilled by IUC aftercompletion of the July, 1994 Titan Report. In addition,some water rights have been omitted from the IUC tabulation, at least one or *r,i.r, appearsdowngradient and in close proximity to the tailings ponds (see Table 3, above, LorenzoHawkins well). Please revise the Site Plan Map to.niu.. it is complete in its representation ofall wells (monitoring, supply, Stock-watering, etc.), borings, and piezometers installed at oradjacenr ro the White Mesa facility.
trarDy urounowater water Rl Omirt d from Mav, lggg lUC GWI Reporr(r)
O,'vner [quantity](reported water use)
Location(2)
(ieet)
From
Corner
Section Torvnship
& Ran-qe(l)
Depth
(feet)
Water
Right No.
State Approved Gra undwater Water Rights
Martha Lyman [4.73 ac-ft]
(irrigation, domestic. Stock-watering)
660'South
700'West
NE )l 37 South,
22 Easr
r80 09-2006
Anna M. Rafferty I l.4g ac-ft]
(inigation, domestic, Stock-watering)
I160' South
320'Easr
NW 22 37 Sourh,
22 East
180 09-2001
Dale & Marrha Lyman [4.73 ac-
rrl
(irrigation, domestic, Srock-rvatering)
1095'Nonh
725'West
E%2l 37 South,
22 East
160 09-t912
Lorenzo Hawkins [0.0074 cfs]
(Stock-warering)
152'South
76'West
NE 32 37 South,
22 Easr
240 09-466
St at e Te ntt itrat ed G ron ndwat e r lVat e r Ri gfu s tll
Neldon E. Holt [0.015 cfs]
(inigarion, Stock-watering)
1340'Sourh
1300 East
N%2t 37 South,
22 East
100 -
700
09-895
Boyd Laws [0.015 cfs]
(irrigation, domestic, Stock-rvateri ng)
2400'Sourh
210'West
N%22 37 South.
?7 East
100 -
250
09-6 I 9
Grant L. Bayles [0.015 cfs]
(irrigation, domestic, Stock-rvateri ng)
I155' Nonh
870'East
SW 22 37 South,
22 East
120 09-663
DRC Requesr for Information: Hydrogeology
IUC White Mesa Uranium Mill February 1,2000
Page l0
Table 3. Nearby Ground
Footnotes:
l) Data gathered from the Utah Division of water Rights (DWR) on Seprember 13, 1999; as baserl on a 10,560 foor (2-mile) search radius from the general vicinity of itre wtrite Mesa uranium mill, i.e.. Sourh % corner, Section 2g,Torvnship 37 South' Range 22 East, Salt Lake Baseline and Meridian. Search conclucred on rhe DWR internerhomepage located at hrtp://nnvrt l.nr.state.ut.uvrvrinfo/rvwwprat.hrmr.2) Distance in feet anci compass direction from referenc. .o-.i.3) Salt Lake Baseline and Meridian.4) Terminated water rights that need fielcl confirmation to ensure that wells were never installed.
l0' H-vdrogeolqgic Cross-sections - a Permit applicant should provide a hydrogeologic descriptionfor a one-mile area around of the discharging facilities [uAC R317-6-6.3(-E)]. uyo.ogeologiccross-sections can in part fulfill this requirement. However, DRC review of the IUChydrogeologic cross-sections in theJuly, l994Titan Report show several errors were made.Please revise the cross-sections to correct the errors listed belorv, or provide additionalhydrogeologic data to justify the cross-sections provided. Also, please add or update the cross-sections with any new geologic or groundwatei hydrology information provided by recentlyinstalled wells or borings.
A.three errors were noted on this east_west cross_
DRC Requesr for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,20A0
Page I I
l) _ total depths for wells MW-2 and MW_4are in error in.that they are depicted on the crosi-section as ll0 and 100 feet,respectively' However, Appendix A of the same report shows the total depths forthese two (2) wells is 125 feet for Mw-2, and more than 125 feet in Mw_4.
2) Erroneous water Level: MW-2 - the water level depicted in well MW-2 is found atabout 95 feet below ground surface (BGS). In contrast, review of the historicgroundwater levels reported by IUC shows depth to the water table in this well hasranged between 108 - l l2 feet betow ground surface (Bcs).
3) Subiective Geologic Loe: ww-3 - review of the driller's log for this well in AppendixA shows it cannot support determination of the geologi. .ontr.t found at the uppersurface of the Brushy Basin Member (Morrison Formation). As a resulr, this geologiccontact near well ww-3 should be drawn as an uncertain or infened contact (dashedline), unless other information can be provided to justify otherwise.
B.-severalerrorswerefoundinthenorth.southcroSs-
section, including:
l) Erroneous Total Depth: Boring #9 - the geologic log for this boring in Appendixplaces the total depth of the hole at 132 feet. Ho*Ierer, on this cross-section itdepicted at abour 107 feet.
2) pi and 28 - Table 2.2 of
A
is
the July, 1994 Titan Report states that all th" po.k.it.rtf uG to determine formarionpermeability in Borings 3, 19, and 28 were conducted within the Burro CanyonFormation. Review of the boring logs in Appendix A of the reporr shows how eachpacker test was conducted down to the total depth of each boring. Despite these facts,the cross-section in Figure 2.3 suggests .r.i, of these borinls penetrated a shortdistance into the underlying Brushy Basin Member.
3) Geologic Log: ww-3 - as mentioned above, the geologic contacts depicted near thiswell are uncertain and should be drawn as an inferred contact.
ll' MissingAquifer/FormationPhysicalPropertiesData-aPermitapplicantmustincludedetailed
information regarding physical properties and characterization oiir,. groundrvater most likelyto be affected by the discharge, i.e., shallow aquifer [see UAC R3l7-6-;.3(K)]. These physicatproperties or characteristics include, but are not limited to: depth to groundwater, saturatedthickness, flow direction, porosity, perrneability, etc. DRC review o1 the July, 1994 TitanReport shows several deficiencies exist in this area. Please provide the following data relatedto the physical properties of the shallow aquifer and subsurface formations:
A. _ review of the July, 1994 Titan Reportshows that the information provided on aquifer and formation properties in Tables 2.I and
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page 12
B.
2'2 are limited to summary information of laboratory tests conducted by others. Summaryinformation does not allow the DRC to confirm the values provided. please provide copiesof the original laboratory results for all laboratory tests.
The July, 1994 Titan Report describes plans for additional borings and tests to beconducted' Please provide all aquifer and formation property test data collected sincesubmittal of this report. Please demonstrate how the tests conducted were completed inaccordance with standardized test methods.
Field Penneabilit-v Notes and Calculation Results: All Data Available - the fieldpermeability results listed in Table 2.2 of the July, 1994 Titan Report rr.i. olro limited toa simple summary of test results described elsewhere. Please provide a detailed report ofall aquiferandformationpermeabilitytestingthatincludes: l)fieldnotesfromeachtest,and 2) detailed description of calculations and analysis methods used to determinepermeability.
If any other shallow aquifer or formation permeability testing has been done at the whiteMesa facility, besides that found in the July, 1994 Titan Repoft, please also provide thatinformation. Please also demonstrate how all said permeability tests were completed inaccordance with standardized methods.
_ review of the May,1999 IUC GWI Report shows summary tablei *... proula.a regarding field and laborarorypermeability test results for various wells and borings completed in 1994 (ibid., pp. C-40and 41, and Tables C-5 and C-6). Please revise the plrmeability rurnraryiables found inthe July, 1994 Titan Report (Table 2.2) to include ott tt. permeability rest data availableto date' If additionalphysical properties testing was conducted on samples r.o* tr,.r. ror"wells and borings, please also update the phyiical properties table inih. July, 1994 TitanReport to include all available dara (Table 2.1).
D.the July, 1994 TitanReport describes at least two (2) previous reports where joints and fractures were studiedin the outcrops of the Dakota Sandstone and Burro Canyon Formations in the vicinity ofthe white Mesa Mill (ibid., p. 45, and Appendix F, p. F-7). Please provide copies of thesereports.
Missine Follow-up Investigations - in order to provide an adequate characterization of thephysical properties the shallow aquifer, pursuant to UAC R3l7-6-6.3(K), it is importanr toprovide all available information regarding local hydrogeologic studies. DRC review showsthat the July, i994 Titan Report proposed additional hyd-rogeologic investigarions ro: l) srudythe occurrence of subsurface fractures or joint sets below-the tailings ponds, 2) quantify thehydraulic properties of the underlying Brushy Basin Member of the Morrison Formation, 3)determine the horizontal extent of the shallow aquifer sourh of the tailings ponds, and 4)
DRC Requesr for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page 13
qualitative determination of vadose zone moisture content with electrical geophysical methods(ibid., pp. a-51).
A summary of some of this additional work was provided in the May, 1999 IUC GwI Reporr
Ilp: a:1,r_.11 11: 11a r.autls C-s. a1d C-6). However, as discussed above, summary'-' '-"""*'Jinformation doesn't allow the Executive Secretary to validate the data collected or the methodsused to analyze it. Please provide a copy of the original reports used to document all of theadditional studies at the white Mesa facility that post-date the July, 1994 Titan Report. please
ensure said reports include all raw data collected and fully documenr analysiis of saiidinformation.
_ a permit applicant mustinclude a description of all springs within a one-mile rr-ai* of thllischarging facility IUACR3l7-6-6.3(D)1. one spring, identified as G5R in the May, 1999 IUC Gwl R.port (part C,Figure C-8), appears to be located within one-mile of the tailings ponds. Trvo othersprings alsoappear downgradient of the tailings ponds, identified as G3R (i.uin Spring) and G4R in thissame report (ibid.). The July, 1994 Titan Report provides a hydrogeoltgiJcross-secrion rhruRuin Spring in its description of local dischirge points for the sha-llow-aquifer (ibid., Figure2'3)' All of these springs or seeps appear to be icontact" springs or seeps formed at the contactbetween the Dakota Sandstone/Buno Canyon Formation and the underlying Brushy BasinMemberof the Morrison Formation. othercontact springs orseeps may also be located in otherlocations along the edge of White Mesa.
In order to better understand local groundwater flow directions, it is important to place thesecontact springs and seeps in context rvith shallorv groundwater levels or elevations found in theIUC monitoring or nearby stock watering wells. To this end, please provide the followinginformation:
Land Survey - please provide a detailed land survey of the location and elevation of allcontact springs and seeps along the edge of white Mesa. Please base the elevation of eachcontact spring on the elevation at the head oi upper end ofeach spring or seep.
Equipotential Map - please prepare an equipotential map for the shallow aquifer thatincludes all groundwater monitoring wells at the white Mesa facility and the heaj elevationof each contact spring or seep located at the edge of white Mesa.
C.-pleaseprovideastudyofgroundwaterquaIity
sampling and analysis results for each contact spring or seep located at trre edge of WhitlMesa. Please include all field and laboratory parameters required by Table lA and partI'E'6 of the November 30, 1999 DRC Draft Ground Watei Discharge permit. please
correlate all data generated by this study with historic groundrvater quality informationfrom contact seePs, as summarized in the May, 1999 IUC GWI Report, ittachment 7(Dames & Moore summary table).
A.
B.
DRC Requesr for Informarion: Hydrogeology
IUC White Mesa Uranium Mill
_ a permit applicant must include adescription and characterization of local hydrogeologic conditions, intl'ding, but not limitedto, groundwater flow directions and sarurated thickness (see uAC R3l7-6-6.3(E) and (K)J.DRC staff have summarized water table elevation information for the shallorv aquifer providedby IUC, see Attachment 2, below. Review of the available hydrograph information indicatesan increasing head trend exists in four (4) monitoring wells located along the eastern margin ofthe tailings pond facilities, including: MW-4, Mw-l l, Mw-lg, and Mw-19. In contrast, allother monitoring wells at the facility have demonstrated an unchanging (relatively horizontal)or decreasing trend in water table elevation. In the case of well Mw-4, the shallow aquifer headhas increased dramatically, about 20 feer in the last five (5) years.
In order to adequately determine the number and location of the compliance monitoring wellsneeded at the IUC tailings ponds, it is essential to complete an investigation of this localgroundwater phenomenon.
Please collecFie*additionat hydrogeologic data to explain, identify, and justify the source ofnearby recharge that has caused the increasing head trends observed. -At aminimum, anappropriate course of action would include the following activities:
Additional water Table Contour Maps - the July, 1994 Titan Report only included one ( I )watertablecontourmapfortheshallorvaquifer;preparedforthen'att, tgiZsamplingevent(ibid., Figure 2.4). Based on the rising water table observed in rvells MW-4, MW- I l, MW-18, and Mw-19, particularly in the Iast five (5) years, it is essential to provide additionalwater table contour maps for subsequent monitoring events. please submit a shallowaquifer water table contour map for each monitoring event conducted between the Fall,
1992 and the current date. Please provide tables of supporting groundwater elevation datafor each equipotential map submitted. Please "nru.. ihe water level measuring point ateach monitoring well orpiezometer is re-surveyed and certified by a State licensejengineeror land surveyor, as requested above, before preparation of these new maps.
_ the July, 1994 Titan Reportincluded only one ( l) water table contour map for the shallow aquifer, prepared for the Fall,1992 sampling event (ibid., Figure 2.5). Because the warer tabie has risen significantly inthe last five (5) years in wells MW-4, N/ttV-l l, Mw-18, and Mw-19, it is im-portanr to re-visit the shallow aquifer isopach maps for subsequent monitoring events in order toevaluate changes in saturated thickness over time. Such maps may provide indication ofthe relative location of the source of recharge observed in lrre rt,oilow aquifer. please
provide a shallow aquifer water table contour map for each monitoring "r.nt between theFall, l992andthecurrentdate. Pleaseprovidetablesof supportinggroundwaterelevation
data for each isopach map submitted. PIease ensure the water leueimeasuring point at eachmonitoring well or piezometer is re-surveyed and certified by a State ticenseo'engineer orland surveyor, as requested above, before preparation of these new maps.
February 1,2000
Page 14
A.
B.
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page l5
C. - to characterize the locationand cause of the increased head in the shallow ,qulr.r. we recommend that these newwells or piezometers be installed both in proximity to existing well Mw-4, and at adistance in order to investigate all possible sources of nearby ...hn.g..
D.aoottronat uroundwater Oualit-v Data - be collected from the additional wells/piezometers
fti:.*:]le facility to determine and confirm the source of the shailow aquifer rechargein question.
ng Well Dara - a Permit appli-"-"" " "Ye"vr LYuryvrvtrtrdr iYrdu. lvllsslng well ljata - a Hermtt appllCant muSt prOvideinformationongroundwaterflowdirectionstuACR3lT-6-6.3(E)and(r)1. neviewoftheJuly.Review of the Ju ly,1994 Titan Report shallow aquifer equipotential map (Figure 2.4) shows that three wells rvere
::fi::::l1y:.T:.*r*dwatertabl"..l..l1,_ons,whlninlactnosuchdataexists. Specificany,groundwaterelevations reported forwells lvlw-17, Mw- l g, and Mw- lg have no correspondingsupporting data for the Fall, 1992 time period in Table 2.3 or Appendix B of the July, 1994Titan Report. As a result, Figure 2.4 appears to have .rron.ouiiy reported the water levelelevationsinthesewellsforthetimeperiodinquestion. Pleasecorrectthisdeficiencybyeither:l) providing the missing head data in question, or 2) revising Figure 2.4 toinclude water rableelevation contours based only on actual existing head data.'
- a Permit applircant mustprovide information regarding the saturared thickness of the aquifer mosr lirsSdrurrS r.ilc sarurareo rnrcKness ot the aquiter most likely to be affectedby the discharge [UAC R3l7-6-6.3(K)]. IUC apparently arrempred ro sarisfy this requirementfy this requirementrvith a shallow aquifer saturated thickness or isopach map in Figure 2.5 of the July, 1994 TitanReport for the Fall, 1992 time period. Howevir, this figure includes a number o[errors ordeficiencies that must be resolved, including:
A' Elevation Datum - no mention is made in the July,lgg}Titan Report regarding the datumfrom which the saturated thickness in each well was calculated. please disclose the datumused and how the saturated thickness of the shallow aquifer was calculated in each rvell.
B. _ Table 2.3 of the Titan report suggesrs thesaturated thickness in MW-3 was at least 14.26 feet. This is similar to the 14.l feet ofsaturated thickness found by DRC measurements in May, 1999. In contrast, Figure 2.5 ofthe Titan Report suggests the shallow aquifer thickness in well Mw-3 is a negative value.
C. _ the saturated thickness reportednear well Mw-16 on Figure 2.5 is in error, based on two lines of evidence:
I ) Well Total Depth - the well completion diagram for MW- l6 reports the ground surfaceelevation to be 5,588.18 feet amsl and the total well depth obout 91.5-feet (see July,1994 Titan Report, Appendix A). Therefore, the well's total depth equares ro anelevation of about 5,496.6g feet amsl.
a
16.
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page 16
2) water Table Contour Map - the shallow aquifer water table contour map for the Fall,-1992 sampling event shows the water table elevation in the vicinity or Mw-16 to beless than 5,490 feer amsr (see Jury, 1994 Titan Reporr, Figure 2.4).
As a result, it appears that well Mw-16 is dry because ir rvas not ddlled deep enough tointercept the water table. Consequentty, this data point should be ignored in preparationof any saturated thickness map for the shallow rquif.r. please revise the map to correctthese errors and resubmit.
17. Need to ReviselUpdate Brushv B
A.
_ a permit applicant must includea description of local geologic conditions within o on.-rnil. radius around the dischareinqe (]lscnarglngfacility [uAC R3l7-6-6.3(E)]. Geologic strucrural conrour maps are an imporranr part of thisdescription' Figure 2-6 of the July, t99+ Titan Report includes a srructural .ontou1 map of theupper contact of the Brushy Basin Member near the white Mesa facility. Review of this mapand the data upon which it is based shows that a number o[ errors and omissions needs to beresolved. Please revise the structurar contour map and re-submit, as folorvs:
_ after revierv of the shallow aquif,erwater table contour'(Figure 2.4) andthe saturated thickness (Figure 2.6) maps in the July,1994 Titan Report, it is apparent that well Mw-16 rvas not drilled deep enough to interceptthewatertable(seediscussionabove). Iftheshallowaquiferisindeedperchedonropof
the Brushy Basin Member, then the geologic contact reiorted in well Mw-16 is in error.otherwise, IUC's interpretation that the shallow aquifei is perched on this member is inerror' To resolve this discrepancy, please: l) Revierv the available data and ensure thestructural contour, water table contour, and shallorv aquifer thickness maps are consistentwith one another, or 2) re-visit your interpretarion regarding the perchin! of the shallorvaquifer on the Brushy Basin Member.
Need to Add omitted Data Points - review of Figure 2.6 shorvs that a number o[ wells havebeen omitted and need to be included, includin!:
l) Dames & Moore Borines - No.3, No.9, No. l2,No. 19, and No.2g,
2) Former Monitoring weils - Mw-6, Mw-7, Mw-g, and MW-13, and
3) Additionalwells - installed aftercompletion of theJuly, l994Titan Reporr, including,but not Iimited to: l) the three (3) proposed wells south of the tailings.ltt, izll+ ti,onReport, pp- 46-48 and Figure 4. I ), and 2) any exploratory wells installed in compliancewith the August 23, 1999 Ground water corrective ection order.
Please revise the structural contour map to correct the error listed above and include all boringsand wells at the white Mesa facility that have penetrated the Brushy Basin Member. please alsoinclude the elevations of this formation contact at the canyon walls at the edge of white Mesa.
B.
DRC Request for Information: Hydrogeology
IUC White Mesa Uranium Mill February 't ,2OOO
Page 17
18.- a Permit applicant mustalso include a characterization of permeabitity.onoltio^ in tt e shallow aquifer at the site IUACR3l7-6-6'3(K)l' A contour map of permeability conditions in the uppermost aquifer i..,rvsvrrrrJ vuilurLr(rils lil ultr upperTnosl aqulter ls animportant part of this characterization. DRC review of both rhe May, lggg IUC Gwl and Julv.and July,,.,rqr.uJurJ,1994 Titan Reports showed that no contour map of shallow aquifer permeability has beenprovided for the white Mesa facility. Please submit a shallow aqulreipermeability conrourmap' Please include field permeability test data from all shallow aquifer monitoring wells andboreholes completed to date at rhe facirity (see Item ll, above).
DRC Requesr for Information: Hydrogeology
IUC White Mesa Uranium Mill February 7,2000
Page 18
References
Barcelona, M'J', J.P. Gibb, and R.A. Miller, August, 1983, "A Guide to the Selection of Materialsfor Monitoring well Construction and Ground-water Sampling", Illinois state water Surveyfor U.S. Environmental protection Agency, 7g pp.
D'Appolonia Consulting Engineers, June, 1979, "Engineers Report Tailings Management system,white Mesa Uranium Project Blanding, uta;", unpublished consultants design reporr,approximately 48 pp., 8 tables, I figure, and 2 appendices; A (16 engineering drawings) and B(construction specifications, approximately 29 pp., Z figures).
Energy Fuels Nuclear, Inc., February 28, 1995, "Energy Fuels Nuclear, Inc. SUA- 135g: Docket No.40-8681 Semi-Annual Effluent Report", unpublis-hed company report from Donald K. Sparling,Scott L' Schierman, and Janet c. Mays to ioseph Holonith irunc), 4 pp., I figure, 2l tables,9l graphs, I appendix.
International Uranium (usA) Corporation, May28, 1999, "Groundrvater Information Report, whiteMesa Uranium Mill, Blanding, Utah", unpublished company report, lI3 pp., r2 tables, l5figures, 8 attachments.
International Uranium (usA) Corporation, August 13, lggg, "Utah Request for Monitoring wellSurvey Coordinates", unpublished company letter from Michelle R. iehmann to Loren Morton,I p.,2 attachments.
Titan Environmental Colporation, July, 199-1, "Hydrogeologic Evaluation of white Mesa UraniumMill", unpublished consultants report, approximaLly 5i pp., 5 tables, l9 figures, T appendices.
Titan Environmental Corporation, october 7, lgg4, "Points of Compliance white Mesa UraniumMill, Revision 1", unpublished consultants report, l3 pp., I table,4 figures,3 appendices.
Environmental Protection Agency, Septembdr, 1986, RCRA Ground-water TechnicalEnforcement Guidance Document, oswER-9950. r, 20g pfi., 3 ,pp.ndi..,
utah Division of Radiation Control, November 30, 1999, "Draft Ground water Discharge permitNo. UGW370004", unpublished proposed permit, 27 pp.
LBIWIm
attachments (2)
F:\iucgw-rfi2.rvpd
File: IUC lll30l9g Draft Grouncl Water Discharge permit
ATTACHMENT 1
Comparison of
Existing Monitoring Well Depths:
Reported As-Built Depth
vs.
Depths Measured in May, 1999
Utah Division of Radiation Control
Spreadsheet: GWSpLIT.XLS
Tabsheet: field
lnternational ur@
, 1999 IUC/UDEQ Sptit croundwater
Depth
to
Waier
(ft)
Diss-
Oxvoe"
5t12t99 lrurW-rZ
5t12t99 IMW-l2 lperched
14.0i 6.5 3.21 3,7451 129.11 Oo 12s.m
-1.8; 107.45, 30.6i- 38
6.81 5.13.41 2,611
1.8t 130.61 -4.6i 1103
-3.0 i 83.91 14.1
1.51 150.0
23.01 7.'l5rNA
Gwsplit.xls - field I 2/8/1 999
Page 1
ATTACHMENT 2
IUC White Mesa Mill
Groundwater Monitoring Well Hydrographs
Utah Division of Radiation Control
Spreadsheet: GWHEAD.XI-S
Graph: allWells
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Date F-jt. Br 200$nder'sFedExAccounrlrrro"r-1f,128-El775-7
IxrBnNerro*orp
UneNrul,r (usa)
ConponATroN
Independence Plaza, Suite 950 . 1050 Seventeenth Street . Denver, CO 80265 . 303 62g 77gg (main). 303 389 4125 (fax)
November 13,2001
VIA OVERNIGHT DELIVERY
Mr. William J. Sinclair
Director, Division of Radiation Control
Utah Department of Environmental euality
P.O. Box 144850
168 North 1950 West
salt Lake city, UT g4tl4-4950
Re: Evaluation of Hydraulic Test Data, Monitor Well4
Ground water Discharge permit Application, white Mesa Mill
Dear Mr. Sinclair:
As promised to Loren Morton during our meeting of October 18, 2OOl, attached is areport prepared by Hydro Geo Chem, Inc., summarizing the hydraulic tests conducted onMonitor Well 4 in 1999 and 1992. This information was presented and discussed duringthe meeting of October 18, and we agreed to formalize the information in support of theGroundwater Discharge Permit Application.
lf you have any questions on the attached report, please feel free to contact me at (303)
389-4160.
very Ly yotxs, /,1a1u?u*,s'
Harold R. Roberts
Vice President - Corporate Development
cc/att: Larry Mizq UDEQ Division of Water eualityLoren Morton, UDEQ Division of Radiation Control
R. William von Till, NRC
Michelle R. Rehmann, IUSA
Stewart J. Smith, Hydro Geo Chem
Roman Z.Pyrih
Dianne Nielson, UDEQ
Dave Arrioti, S.E. Utah Health Department
Ron F. Hochstein,IUSA
David C. Frydenlund, IUSA
z sA_6_>\
J)\e
19,\'o,Sl -=
s'i* s/
cc: w/out att:
EVALUATION OF HYDRAULIC TEST DATA AT MW-4
WHITE MESA URANIUM MILL SITE
BLANDING, UTAH
Prepared for:
INTERNATIONAL URANIUM (USA) CORPORATION
Independen ce Plaza, Suite 950
I 050 Seventeenth Street
Denver, CO 80265
Prepared by:
HYDRO GEO CHEM,INC.
51 West Wetmore Road, Suite 101
Tucson, Arizona 85705-1 678
(s20) 293-1s00
November 12,2001HYDRO GE,O CHEM, n\TC.
Eruyit onrnentol Science (? Tbchnologl,
EVALUATION OF ITYDRAULIC TEST DATA AT MW-4
WHITE MESA URANIUM MILL SITE
BLAI\DING, UTAII
Prepared for:
INTERNATIONAL URANIUM (USA) CORPORATION
Independenc e Plaza, Suite 950
I 050 Seventeenth Street
Denver, CO 80265
Prepared by:
HYDRO GEO CHEM,INC.
51 West Wetmore Road, Suite l0l
Tucson, Arizona 85705-1 678
(520) 293-1s00
November 12,2001
TABLE OF'CONTENTS
1. INTRODUCTION . .. . I
2. WATER LEVELS AND HYDRAULIC GRADIENT NEAR MW4 . . . .2
3. HYDRAULICTESTSATMW-4 ......3
3.1 l992Tests ........3
3.2 l999Tests. .......4
3.3 Vertical PermeabilityDistributionatMw-4 ......5
3.4 Conelation of Vertical Permeability Distribution at MW4 to Lithology Logged at
NearbyTemporaryWells ....6
3.5 Estimated Thickness of the Higher Permeability Zone at MW-4 . . . . . .7
4. CONCLUSIONS .....9
5. REFERENCES. ....10
I
2
J
4
5
6
7
8
9
FIGURES
Water Level Contour Map, August 1990, White Mesa Uranium Mill Site
Water Level Contour Map, August 1994, White Mesa Uranium Mill Site
Water Level Contour Map, December 2000, White Mesa Uranium Mill Site
Water Level Contour Map, Sepember - October 2001, White Mesa Uranium Mill Site
Re-Analysis of Constant'Rate Pumping Test, Conducted at MW4 on lll7l92
Pumping Test Results, Low Rate Step Test at MW-4
Pumping Test Results, High Rate Step Test at MW-4
Raw Water Level Data from Pressure Transducer,1999 High Rate Test at MW-4
Approximate Intervals of Conglomeratic Sandstone Logged in Temporary Well Borings
ATTACHMENTS
Evaluation of Hydraulic Test Data at MW-4
G 17 I 8000\Reports\TestDataEvaluation.wpd
November 6,2001
I. INTRODUCTION
This report is pursuant to a meeting between International Uranium (USA) Corporation
(IUSA), Utah Department of Environmental Quality (UDEQ), and Hydro Geo Chem,Inc. (HGC)
on October 18,2001. The purpose of this report is to document the results of hydraulic tests
conducted at perched monitoring well MW-4, located at the White Mesa Uranium Mill near
Blanding, Utah, during 1999. The results of hydraulic tests conducted in 1999 are compared with
results oftests conducted in1992. Implications oftest results with regard to lithology, perched zone
permeabilitY, and transport of chloroforrn near MW-4 are discussed. This report is intended to
support the ongoing investigation of elevated chloroform concentrations in perched water near
MW-4 discussed in IUSA and HGC, 2000, and IUSA and HGC, 2OOl, and to help resolve
hydrogeologic issues raised by UDEQ that are related to both the chloroform investigation and
Groundwater Discharge Permit detection monitoring at the site. Background information for this
site is available in IUSA and HGC, 2000.
Evaluation ofHydraulic Test Data at lvfw-4
G17 I 8000\Reports\TestDataEvaluation.wpd
November 6,2001
2. WATER LEVELS AND ITYDRAULIC GRADIENT NEAR MW.4
Figures I through 4 are water level contour maps for August 1990, August lgg4,
December 2000, and October 2001. Although water levels on the east side ofthe site were difficult
to define prior to the installation of perched wells MW-18, MW-19, and MW-22, a southerly
gradient has existed near MW-4 from 1994 through the present time, and likely existed prior to that
time. This is reasonable considering site topography and the presence of canyons along the
northwest, west, and east sides of the site, into which perched water is known to discharge via
springs. In the absence ofartificial recharge sources, the hydraulic gradient can be expected to
naturally change from southwesterly on the west side of the site, to southerly, as one moves from
west to east across the site, towards the canyon on the east side of the site. This southerly gradient
likelyexisted betweenMW4 andthe source ofthe chloroform inMW-4 (the abandoned scale house
leach field, as discussed in IUSA and HGC, 2000) prior to 1994.
Beginning in l994,water levels in MW-4 began to rise and the hydraulic gradient steepened.
A more westerly component of flow began to occur in the vicinity of the abandoned scale house
leach field at about that time due to enhanced recharge to the northeast, as discussed in IUSA and
HGC, 2000. As discussed in IUSA and HGC, 2}}l,additional temporary perched monitoring wells
are planned to the west and northwest of MW-4, and phased installation of piezometers is planned
in the northeast portion of the site, to further investigate these changes and to further delineate the
chloroform in the perched water near MW-4.
Evaluation of Hydraulic Test Data at MW-4
G17 I 8O0otReports\TestDataEvaluation.wpd
November 6,2001
3. IIYDRAULIC TESTS AT MW.4
In the following sections, hydraulic tests conducted at MW-4 in l992are compared with tests
conducted in 1999. The results ofthese tests are then related to the vertical permeability distribution
and lithology near MW-4.
3.1 1992 Tests
Peel conducted pump tests at MW4 in 1992. Two tests were performed; one at a constant
pumping rate of 0.46 gallons per minute (gpm) (reported in UMETC O,lgg4)and one at a constant
pumping rate of 0.92 gpm (apparently not previously reported). Both tests demonstrate similar
behavior and yield similar results, as will be discussed below.
Attachments I and 2 are plots ofthe drawdown data for these two tests, which include peel,s
calculation of transmissivity for the "late time" data. An interpretation of the ..early time,' data
(which is not really "early time" because the behavior of the data is the same through the first
379 hours of the 0-46 gpm test, and through the first l7s hours ofthe 0.92 gpmtest) is provided in
a box at the top of the drawdown plot in both figures. In both cases, this "early time" data forms a
nearly straight line on the semi-log plot until a break in slope occurs at a drawdown of approximately
2%to 3 feet (approximately 95 feet belowtop of casing(btoc)). It is perfectly valid to interpret this
"early time" data using the Jacob-Cooper methodology in the same way that peel did for the ,.late
Evaluation of Hydraulic Test Data at MW-4
G 17 I 8ooo\Reports\TestDataEvaluation.wpd
November 6, 2001
time" data, after the break in slope occurred, because nearly straight lines occur both before and after
the break.
As shown in the figures, a hand-fit line to the "early time" data yields a transmissivity of
152 gaUdaylft(20.3 ft'zlday) forthe 0.46-gpm test, and 16l galldaylft(2l.6ftrlday) forthe 0.92-gpm
test. These values are approximately 39 and 26 times higher, or about an average of a little more
than30 times higherthanthe values calculated forthe "latetime" (post-slope-break) drawdown data.
The "early-time" data for the 0.46-gpm test was also re-interpreted by HGC using WHIp, a
well hydraulics interpretation package developed and marketed by HGC (Figure 5). A transmissivity
of 22.8 ft2lday was obtained, which is very close to the hand-fit results for the same data.
3.2 1999 Tests
Two tests were conducted at MW-4 in 1999. At this time, water levels in MW-4 were more
than20 feet higher than in 1992. A low rate test, where the well was pumped at increasing rates of
approximately Yz,lYz, and2 gpm, was performed using a bladder pump. The pu{pose of conducting
the test at increasing pumping rates was to determine if non-linear well efficiency effects may be
influencing the drawdown in the well, resulting in underestimation of transmissivity. The results
indicated that such effects were negligible. A high rate test, at rates of approximately 6 to 9 gpm,
Evaluation of Hydraulic Test Data at MW-4
Gl7 I 8000\Reports\TestDataEvaluation.wpd
November 6, 2001 4
was performed using a GrundfosrM submersible pump. In both tests, water levels in the well were
continuously monitored using a GeoKonrM pressure transducer and data logger.
The results of the two tests are shown in Figures 6 and 7. A transmissivity of 38.4 ft2/day
was obtained for the low rate test, and a transmissivity of 21.5 ft2/day for the high rate test. The fit
is superior for the low rate test and therefore the results ofthis test are considered more reliable. The
results of the high rate test, in which water levels were drawn down into the range of the 1992 tests,
are, however, nearly identical to the results of the 1992 tests.
Figure 8 shows the raw water level data collected during the high rate test at MW-4. As
shown in the figure, a distinct break in slope occurs in the drawdown and recovery portions of the
curve at a depth ofapproximately 95 ft btoc. The rate of drawdown increases when water levels drop
below this depth, and the rate of recovery increases when water levels rise above this depth.
3.3 Vertical Permeability Distribution at MW-4
The hydraulic test data collected at MW4 to date indicate that areduction in permeability
occurs below a depth of about 95 feet btoc at MW-4, and that this depth therefore coincides with the
base of a higher permeability zone or layer at that location. The break in slope in the peel test data
from 1992 is interpreted as occurring upon dewatering of that higher permeability layer at about
3% hours into the 0.46 gpm test (or about l2ls hours into the 0.92 gpmtest). At the start of each test
Evaluation of Hydraulic T€st Data at MW*4
G17 I 800O\iRepons\TestDataEvaluation.wpd
November 6, 2001
only the lower 2Yzto 3 feet of the layer was saturated. Once this layer was desaturated near the well,
most of the water entering the well was derived from materials below that layer. Because the rate
of drawdown increased by about a factor of 30 once the upper layer was dewatered, the materials
below 95 feet btoc are interpreted as having a much lower permeability than the material
immediately above.
Attachment 3 provides a calculation ofthe permeability of the saturated portion ofthe layer
above 95 feet btoc. The average permeability of the entire saturated thickness at that time is
calculated as:
2lft2 /dav! / =l)ftldayt7 ft
assuming a depth to Brushy Basin of 108 ft below land surface (bls) and a saturated thickness of
17 feet at that time. As calculated in Attachment 3, the permeability of the saturated portion of the
high permeability layer is approximately 7 fttday.
3.4 Correlation of Vertical Permeability Distribution at MW-4 to Litholory Logged at NearbyTemporary Wells
Figure 9 is a north-south cross section from TW4-5 through TW4-6. Tw4-T,located
approximately 30 feet west of MW-4, is the well closest to MW-4. Approximate intervals of
conglomeratic sandstone logged in these wells are depicted. As shown, wells close to MW-4 have
Evaluation of Hydraulic Test Data at MW-4
G 17 I 8ooo\Repons\TestDataEvaluation.wpd
November6,200l 6
a conglomeratic interval with a base ranging from about 90 ft bls to about 95 ft bls. This zone most
likely correlates to the higher permeability zone revealed by hydraulic tests at MW-4. Because this
zone exists below the perched water table at all temporary perched wells north of MW-4, it likely
influences the movement of perched water and transport of chloroform in the vicinity of MW-4.
Based on the 1992 hydraulic tests at MW-4, at least the lower 2%to 3 feet of this zone has a higher
permeability than underlying materials.
3.5 Estimated rhickness of the Higher permeability zone at MW4
The transmissivity of 38 ft2lday estimated from the 1999 test at MW-4 yields an average
permeability ofapproximately I ff/day (assuming a saturated thickness of40 feet at that time), which
is about the same as estimated from the 1992 data.
The thickness of the higher permeability zone,assumed to correlate with the conglomeratic
material logged in nearby temporary wells, can be approximated as:
38 ft2 / dav
ffi(3ft)=ss-ft
assuming the permeability of the zone is constant over its thickness, that the permeability of the
material above and below the zone is about the same, and that most of the water supplied to the well
is from the high permeability zone. However, the well screen only extends to about 92 feetbls, and
Eraluation ofHydraulic Test Data at MW-4
G:v I 80oo\Reports\TestDataEvaluation.wpd
November 6,2001 7
it is unclear how far above the screen that water from the formation could enter the annular space.
Such calculations are therefore suspect because the thickness ofthe saturated portion ofthe perched
zone above the well screen that can contribute water to the well is uncertain. Based on the well
construction diagram, it's possible that water could enter the annular space at depths as shallow as
the bentonite seal at 86 ft bls.
Regardless of the thickness of the higher permeability zone at MW-4, the data show that at
least the lower portion of this zone (the lower 2%to 3 feet) has a permeability sufficiently high to
have allowed chloroform migration from the abandoned scale house leach field to MW4 over a
2}-year period. The estimated permeability of 7 ftlday for this zone atMW-4 is more than 3 times
higher than would be needed to transport chloroform from the abandoned leach field to MW-4 in
20 years, assuming a porosity of 20% and an average hydraulic gradient of 0.016 ff/ft. The actual
transport time would depend on the average permeability of this zone between the leach field and
MW-4, which could be as low as approximately one third of the calculated value of 7 ftlday at
MW-4.
Evaluation of Hydraulic Test D.ta at MW-4
Gl7 I 8000\Reports\TestDataEva.luation.wpd
November 6, 2001
4. CONCLUSIONS
Hydraulic test data from MW-4 and lithologic logging of nearby temporary wells indicate
that a conglomeratic zone at least 5 ft thick with a permeability of approxim ately 7 fl/day near its
base exists at MW-4. Conglomeratic materials have been logged in all temporary wells between
MW-4 and the upgradient abandoned scale house leach field, which is the most likely source for the
chloroform in MW-4. Because this conglomeratic material is present belowthe perched water table
in the temporary wells upgradient of MW-4, it could have significantly influenced perched water
movement and chloroform transport between the abandoned leach field and MW-4. The calculated
permeability of the lower few feet of this layer at MW-4, 7 ftlday, is more than sufficient to have
resulted in chloroform transport to MW-4 over a 2}-year period.
Evaluation ofHydraulic Test Data at MW-4
G 17 I 8000\Reports\TestDataEvaluation. wpd
November 6, 2001 9
5. REFERENCES
Intemational Uranium (USA) Corporation (IUSA) and Hydro Geo Chem (HGC), 2000.
Investigation of Elevated Chloroform Concentrations in Perched Groundwater at the White
Mesa Uranium Mill near Blanding, Utah. Submiued to UDEe.
IUSA and HGC, 2001. Update to "lnvestigation ofElevated Chloroform Concentrations in Perched
Groundwater at the White Mesa Uranium Mill near Blanding, Utah." Submitted to UDEQ.
Umetco Minerals Corporation,1994. Groundwater Study, 1994 Update. White Mesa Facility,
Blanding, Utah. Submiued to United States Nuclear Regulatory Commission.
Evaluation of Hydraulic Test Data at MW-4
Gl7 I 8000\Reports\TestDataEvaluation.wpd
November 6, 2001 l0
FIGURES
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ATTACHMENT 3
INrBnxerrono"O
UnRNruH,r (use)
ConponATroN
Independence Plaza, Suite 950 . 1050 Seventeenth Street . Denver, CO 80265 . 303 628 7798 (main) . 303 38g 4l2S (fax)
June 22,2007
VIA EXPRESS COURIER
Mr. William .I. Sinclair
Director, Division of Radiation Control
Utah Department of Environmental Quality
P.O. Box 144850
168 North 1950 West
salt Lake city, UT 84114-4950
Reference: - March 20,2001 UDEQ letter and Request for Additional Site Hydrogeology
Information in response to IUSA September 8, 2000 Revised Groundwater
Information Report
- Ground Water Discharge Permit Application for White Mesa Mill- Follow up to May I l, 2001 letter from David C. Frydenlund to William J
Sinclair
Dear Mr. Sinclair:
As a follow up to International Uranium (USA) Corporation's ("IUSA's") letter of May 11,
2001, we are submitting herewith the additional information promised in the May 1ltr' ietter.This information is provided in response to the comments from the Utah Department ofEnvironmental Quality ("UDEQ") Division of Radiation Control ("DRC") transmitied by letter
dated March 20,2001, in response to IUSA's scheduled submittal of September 8, 2000, and theApril 25, 2001 meeting to discuss DRC's comments.
Included with the May l ltl' submittal was a revised schedule for completing the requirements forthe Groundwater Discharge Permit ("GWDP"). Absent comments from DRC, IUSA iscontinuing to work fiom this schedule for the remaining submittals, and hopefully the ultimate
issuance of the Permit.
For ease of reference, the request language contained in your letter of March 20 (the Request forInformation, or "RFI") is repeated in the same order as used in the letter, indicated in italicsbelow.
\
I
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Mr. William J. Sinclair
Iune 22,2007
Page2 of20
Remainins Open Issues (February) 7, 2000 DRC RFI)
several wells, piezometers, and/or boring remain without ,"tt *-ptotn, diograms andgeologic logs, as already provided, see discussion below
seven wells and Piezometers [p. 2, Item 2.C.2J - we acknowledge that seven (7),nol six (6), wells and piezometers are at issue here, including three (3) welts,MW-20 thru MW-22, andfour (4) piezometers; MWg-|, Mw9-2, MWlb-\, andMW10-2. We appreciate the new survey coordinates providedJbr these seven (7)installations. However, the september 8, 2000 ruc Reviserl cinTalea tu providewell completion diagrams for these seven (7) wetts and piezimeters. please
provide the required well completion diagrams, and geologic logs for these seven(7) installations. In the event that this information has been lott, plnotn provide aschedule .for completion of video and geophysical togging to coliect thi requiredinformalion.
RESPONSE
As detailed in IUSA's May I ltl'letter, a search was conducted of IUSA,s Denverand Blanding office and central files, as well as Umetco Minerals' files in GrandJunction, with the conclusion that this search located all existing information andadditional searches would be fruitless.
During this search, IUSA located working files and field notes from drilling ofwells MW-20, -21, and -22, as well as similar information for the angle h"olesreferenced in question 1.c., below. In addition, IUSA located a Table u-nd pug",from a report by D'Appolonia Consulting Engineers, which gives data for shallowborings 9-l , 9-2, 10-1, and 10-2. Enclosed as Attachment Ais a summary report,prepared by Stewart J. smith, project Hydrogeologist, HydroGeochem, Inc.("HGC"), reviewing the data from the well logs, field notes and completiondiagrams found in the files for MW 20 -22, and,thi angle holes. Also enclosed asAttachment B are the Table and pages from the D'Appolonia report.
rly Named SMW-Irem 2.C.3J - from thedescription provided, it is clear that after inttollotion th^, th*, (, *Lil., *nruactually named MW-20, MW-21, and MW-22. we also acknowledge that newsurvey coordinates have already been provided for these three (3) iels (g/S/00IUC Revised GIR, LANDesign map sheet I of l) In addition, DRC staff has alsovisited each of' these during the last split groundwater sampling event inNovember, 2000. However, please provide the following in/ormitioi stilt .foundlacking.for these three (3) wetls.
B
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Iune 22,2001
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(1) Geologic logs - that locate the depth to the upper Brushy Basin shale
contacl,(2) Well completion diagrams, and(3) Dates of well installation.
RESPONSE
This is the same request, essentially, as l.A. above. It was earlier agreed that a
response to items 1.A. and 1.B. may be combined as one response, and the scopeof both responses would be as defined above under item 1.A. Enclosed asAttachment A are the well logs, field notes and completion diagrams found in thefiles for MW-20. -21. and -22.
C.-.from review ofthe September 8, 2000 Revised GIR, it is clear that four (4) geotechnical boringswere also installed nectr the tailings cells in conjunction wiih welts MW-20 thiuMW-22' as a part of studies completedfor the NRC and EPA (g/S/00 illC RevisedGIR' pp. 4-5). Apparently these borings were namerJ GH-\, GH-2A, GH-3 andGH-4. We acknowledge receipl of .fielct ancl laboratory permeability data fromthese four (1) borings in the September 8, 2000 Revised GIR (Attachmeit 10,Tables C-5 and C-6). However, this report also explainecl how other information
was collected.from these borings, including;
(1) Wireline geophysical logs,(2) Wireline video logs(3) Geologic logs
Plea,se provide reliable survey coordinates and all geophysical, video andgeologic logs made for these.four (l) borings.
RESPONSE
Searches were performed as described under l.A. above. Geologic logs, field
notes and test data have been located, as well as a video log that relate to at leasttwo of the borings. A copy of the video log will be sent urrd.. separate cover toMr. Loren Morton for archiving and review by personnel from the DRC. A copyof the video will also be on file at the White Mesa Mill office. The additionalinformation located for these borings is included in Attachment A to thissubmittal, and described in the answer to question A. 1., above.
Because the borings were plugged and abandoned soon after drilling, the locationswere not surveyed, and a visual inspection of the area failed to locate evidence ofthe boring locations. DRC has previously indicated that it is acceptable to
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approximate locations, if surveys are impractical. IUSA has approximated these
coordinates on the map attached in response to item 4., below. A work planincluded in the 1994 Umetco Report, located during the file search reference in LA. above also indicates the planned locations for these points. IUSA used those
approximate locations to place these on the map, and to estimate x, y and z
coordinates.
Former Monitorinq wells [p. 4, Item 3.A.4 and 3.8.2J - apparentty IUC has been
unsuccessful in their attempts to provide information on;fbrmer monitoring wells
now abandoned. However, additional information is requirecl, as follows;
(1) Well MW-|3 - after IUC's unsuccessful attempr to locate this information
(9/8/00 IUC Revised GIR, pp l2 & l6), DRC sra/ffound the recluired well
MW-L3 data in a March, 1983 Energy Fuels Nuclectr (EFN) Cinstruction
Report .for cell 3 (Appendix D, see l l/l/g2 D'Appolonia Consulting
Engineers letter report). Please provide reliable survey coordinstes .forthis'well.
RESPONSE
Searches were performed as described under A.l. above. IUSA located data from
a D'Appolonia report of l1ll/1982, and the phase 2 Tailings Management SystemDesign which included a map indicating where this well would be after Cell 4 wasconstructed. In addition IUSA also located the November 1 , lgg2 D,Appoloniaconsulting Engineers installation repoft for Monitor wells MW-ll, MW--12 andMW-13, as well as installation notes for MW 13 and 14. This report andinformation is enclosed as Attachments c and D. The phase Two Tailings
Management System Design was previously sent to DRC. MW-13 was initialiylocated so it would be on the crest area of the Cell 4 Dike at the time it wasconstructed. A re-design of Cell 4 caused the well to be within the interior of Cell44, therefore, it was plugged and abandoned as apartof the Cell 44 construction.Details of the plugging of this well were described in Section 5.5, page 9, andAppendix G, of the cell 4,A construction Repoft, August 2000. This report haspreviously been sent to DRC. The location of MW-lJ *u, approximated on thedrawing attached in response to item 4., below.
(2),retff; tvlyyo-1. MWo-/, MW/_1, MW7_2, MWg_], and MWg_2 _ pleaseexplain what efforts were completed to locate the required well ,o*)luioncompletion
'6-1, MW6-2. MW7-2MW
diagrams and geologic logs for these six (6) former wells. In the eventthal new efforts find this inJbrmation, please provide it with reliable
survey coordinates for each well at your earliest convenience.
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RESPONSE
Searches were performed as described under r.A. above, and IUSA was able tolocate installation data for these shallow borings. This information is enclosed asAttachment B, in response to a portion of question 1.A above. These wells wereoriginally installed within the area now occupied by cell 3. The wells wereplugged and abandoned as a pafi of the cell 3 construction. The plugging is
described in the construction Report, Second phase, Tailings Munugerri."t
System, March 1983, section 3.5, page 3-3.
Survey coordinates for the wells were approximated from the locations shown onthe Second Phase Design, cell 3, Tailings Management System, May 19g1, Sheet2- The approximate location of the wells are indicated on the drawing attached inresponse to item 4., below.
E Resoluti and Wel 2I 5J- *e acknowledgeyour inability to produce a well completion diagram and geologic log for wellMW-3. This information is essential for determination of aqurfir thickiess andelevation rf the Brushy Basin Shale upper contacl. At this time, it appears thatthere are only two options to resolve this problem;
(1) Wireline Video and Geoph.vsical Logs - to locate the screenecJ intervals in
the well, and depth/elevation o.f rhe Brushy Basin shale upper contact.
(2) Install a Con-firmation Boring - in the event that the geophysical logs areunsuccessful in locating the Brushy Basin shale upper contict, acon/irmation boring may need to be installed near well MW-3 to allow an
adequate geologic log to be assembled.
Please provide a plan and schedule.for these
within 3}-days of receipt of this letter.
RESPONSE
resolution activities for well MW-3
Information searches were performed as described under l.A. above. These
searches failed to yield a more detailed geologic log for MW-3. Constructiondetails for MW-1 , -2, -3, -4 and -5 were located during the data search, and havebeen included as Attachment E.
IUSA will continue to discuss with DRC the feasibility and need for defining theBrushy Basin contact at this location. IUSA notes that the top of the BrushyBasin throughout our entire site, which is in excess of 5,000 acres, cannot bequantified in complete precision, because there would always be too few data
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points. The site conceptual model, however, which has been published andavailable for public comment since the Environmental Assessment was firstpublished in 1980, supports the general conclusion that the Brushy Basin ispresent as a confining unit beneath the site. This is evidenced in a number ofways, including: pressure head observed in wells drilled to the underlying
Entrada/lrtravajo sandstones; observed contact in canyons adjacent to the site:observed contact seepage at the contacts; historical descriptions of regionailithology, by independent geologists; and observed presence of the contact inwells drilled throughout the site.
The Environmental Report (Dames & Moore, lg78) describes, in Appendix H, the
construction features for groundwater monitoring wells at the project-site. plate 9,"Sketch of Typical Ground Water Monitoring Well (for *ui.. table of perchejground water)" illustrates drilling of a well in such a manner that the screenedinterval would enable monitoring a saturated zone that could vary somewhat,based upon the "highest expected water level" and the "lowest expected waterlevel". The text indicates that the monitor wells should be constructed of 4- to 6-inch diameter PVC plastic casing (as shown on Plate 9) to a depth below the"lowest expected water level.,,
Based on all of the well logs for monitoring wells installed at the Mill. it is
evident that this approach was consistently applied. That is, the monitoring wellswere completed in such a manner that they would be capable of monitoring
groundwater at the lowest expected water level - which would mean that it wouldbe necessary to drill the wells to the confining unit upon which the groundwater isperched beneath the Mill, the Brushy Basin. In the case of MW-3-, although thewell log does not show the location of the contact with the Brushy Basin*, it is
reasonable to expect that the depth of MW-3 is reflective of the approximate
depth to tl-re Brushy Basin at this point, for the following reasons:
l. IUSA has seen no information to suggest that any monitoring wells
at the Mill, except for those specifically defined to be ,,shallow
wells", were drilled differently from the method set forth in Dames& Moore 1978. Hence, Mw-3 would have been drilled is such a
manner as to be capable of monitoring the "lowest expected waterlevel", which would have required it's being .o-pr"t"d at o.slightly below the top of Brushy Basin.
2. The depth of MW-3, 96 ft. below it's land surface datum, is only 5ft. more than the depth to the Brushy Basin at MW-20 and MW-lz
(91 ft.), and 6 fl more than the depth to the Brushy Basin at MW-
21 (90 ft.) (These three wells nearest to MW-3 present a reasonable
representation of the top of the Brushy Basin). placing the depth
data for these wells relative to each respective land suriace datum.
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2
Mw-3 fits properly in the contour, as shown on the contour Map
of Top of Brushy Basin. This map is also referenced in a later
Response (Question 6), and is enclosed as Attachment N.
Absent our ability to convince DRC that this additional information adds little to
the overall understanding of the site, IUSA will first consider running a natural
gamma log of the well. Natural gamma has been successfully used at the site to
distinguish the Brushy Basin shale from the overlying Burro Canyon sandstone,
and can be conducted in a cased boring. If the natural gamma log is not
successful in distinguishing the contact, then IUSA will consider drilling anexploratory hole just down gradient of MW 3 to confirm the lithology ai the
location, if DRC and IUSA believe this is essential to protecting g.orrd* ater at
the site
Schedule itorinp Well MW-4 -we
acknowledge that no additional well construction information is oriitoUto 7or MW-4.Close review of the available IUC information indicates that the base oi the well's
screened interval is about l3 feet above the Brushy Basin Shale upper contact (7/94 Titan
Report, Appendix A, well completion diagram). After consicleration that chloroform has
been detected in this well, it is clear that the potential exists for dense non-aqueous liquid(DNAPL) contaminants to go undetected with this well configuration. As a iesult, *i ,uuno other option but to ctsk IUC to complete one of the following activities;
A. Re-pe\forate Well MW-4 - by cutting new perforations in the well casing, belowthe existing screen interval, to allow well access to the aquifer interval in
question, or
B. Installation qf a Second Well - in the immediate vicinity of well MW-4 to provide
a screened interval that is in direct contact with or is screenecl across the BrushyBasin Shale upper contact.
Please provide a plan and schedule .for one of these activities for well MW-4 within 30-
days of receipt of this letter.
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RESPONSE
With regard to this technical question, prior to meeting with DRC on April 25, IUSA
asked our independent hydrology consultant to review the data for MW-4. ffCC reportedthat the well completion diagram is in error, and that the geophysical log shows the
correct contact of the Brushy Basin. The geophysical log for MW-4 provided in TITAN,1994, shows the Burro Canyon/Brushy Basin contact at 108 ft bls. This depth is
consistent with the lithologic logs of nearby temporary perched monitoring wells TW4-1,TW4-2,TW4-7, and TW4-8, in which the same contact is at approximately 103 ft, 105 ft,98 ft, and 105 ft bls, respectively. This would place the base of the screened interval ofMW-4, which extends to ll2 ft bls, approximately 4 feet below the contact.
The 125 foot depth that has been reported for the Brushy Basin at MW-4 is apparently
based on the well completion diagram provided in TITAN, 1994, which notes a contact
between "sandstone" and "claystone" at 125 ft bls. However, no additional lithologicinformation is provided to indicate whether the "sandstone" is continuous from ihesurface to 125 ft bls, or whether the "sandstone" is a small lens or thin layer encounteredwithin the Brushy Basin. Such lens are known to be present within the Brushy Basinformation. The formation names are also not designated on the diagram.
With regard to the geophysical log of MW-4, there is a clear response in the naturalgamma at 108 ft bls that is consistent with a shale or claystone at 108 ft bls. This
response is also consistent with the natural gamma response at the Brushy Basin contactas depicted in other geophysical logs at the site. Because the geophysical log clearly
depicts the Brushy Basin contact at 108 ft bls in MW-4 and becauie this is consistentwith lithologic logs of nearby temporary wells, the 108 foot depth is considered reliable.
The implications with regard to any chloroform DNAPL that may be present are:
l. Any DNAPL present near MW-4 would be expected to enter the well
casing which is screened across the Brushy Basin contact,
2. Because any DNAPL present at the Brushy Basin contact near MW-4would be expected to enter the well casing, there is no need to replace orre-perforate MW-4, and
3. Based on the results of multi-depth sampling, which indicated thatchloroform concentrations do not increase with depth in MW-4, and
maximum chloroform concentrations which are more than 3 orders of
rnagnitude lower than the solubility of chloroform, no DNAPL existswithin or near MW-4.
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,J.
Because of the recent letter (June 8, 2001) from DRC to IUSA with respect to the
chloroform investigation, additional comments on this issue will be held for discussions
and response to that letter.
Additional Geologic l4formation [p. 4, Item 3 and p. ] l, Item I l.AJ - several requested
itemsfrom the February 7, 2000 DRC RFI remain unresolved, including;
A. Missing IUC Reports - several existing consultants reports have yet to be
provided to the DRC. Please provide the .following reports;
(1) Reports Available to Titan Environmental - as listed in Table 2.2 ctnd the
References section of the July, 1994 Titan Environmental Report,
including:
(c)
RESPONSE
February, 1981 D'Appolonia Consulting Engineers, "Assessment
of the Water Supply Sy,rtem, White Mesa Project, Blanding, Utah"
July, l99l Hydro-Engineering, "Ground-Water Hydrolog,t at the
White Mesa Tailings Facility"
June, 1994 Peel Environmental Services, "Groundwater Study,
White Mesa Facility"
Searches were performed as described under 1.A. above. IUSA located 1994
umetco, 1993 Peel, and 1991 HydroEngineering Reports. These repofts were
sent to DRC as attachments to the May I 1,2001 letter. IUSA has not located the
1981 D'Appolonia report, and regrets it may not be possible to locate that
particular report. However, IUSA did locate three additional reports prepared by
D'Appolonia, dated September 9, September 28, and November 30, 1981. These
reports are enclosed as Attachments F, G and H to this submittal
(2)Reoort(s) Prepared -for NRC / EPA - including reports to document
drilling and hydrogeologic investigations related to existing wells MW-20
lhru 22 and geotechnical borings GH-1 thru GH-4 (see discussion above).
RESPONSE
Searches were performed as described under l.A. above. During the search of the
Mill records, IUSA located some working files, field notes and data.
These additional wells and borings were installed as part of the investigation
performed by Umetco during the time that the Mill was being considered as a
(a)
@)
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(:
candidate site for disposal of the Monticello tailings. As we discussed, after the
decision was made by DOE not to relocate the Monticello tailings to the Mill, thework on these investigations abruptly ceased. The information located on these
wells and borings is attached to this submittal as Attachment A in response to
question 1.C above.
(3)Ary other - report related to groundwater hydrology or georogy of the
site.
RESPONSE
Searches were performed as described under 1.A. above. As stated in Response3.A.(l), above, IUSA located three additional reports prepared by D'Appolonia,
dated September 9, September 28, and November 30, l9gl. These reports are
attached as Attachment F, G and H to this submittal.
Dames and Moore Borinss 3 and 9 [o. I. Item 3.A.21 - please provide reliable
suryey coordinates.for these two borings at the.facility.
RESPONSE
IUSA has approximated the location of these borings on the drawing attached in
response to item 4., below. The locations were obtained from information
contained in the original documentation for the Dames & Moore borings. DRC
agreed during the April 25th meeting that it is acceptable to approximate tcations.
Test Well l7 (East o.f Mill Site) [p. 4, Item 3.8. ] I - we recognize that IUC believes
this.former test well has been plugged and abandoned. However, please provide
the following information for this well; date of well installation, geilogic log, well
completion diagram, reliable survey coordinates, anrl a pliggini and
abandonment report.
RESPONSE
Searches were performed as described under l.A. above. IUSA located, duringthe search of the Mill records, logs and completion descriptions for the deepwells' This information has been organized in the form of a Deep Well Summary
Memorandum describing the test well and other deep wells, which includes a drill
date (February 23, 1977) for the test well. This summary information is included
as Appendix I to this submittal. A visual inspection of the location of the Test
Well confirms that the well has not been plugged. The actual location of the Test
B
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well was not surveyed during the August 2000 LANDesign field work, but thelocation has been approximated on the map provided in response to item 4.,
below.
_ apparently I(tC was
unsuccessJul in its attempts to locate the requested information for tlry wells MW-
16, MW9-1, MW9-2, MWt0-1, and M'tYr0-2. However, addiriinal iiformarion isrequired, as follows:
(l) well MW-|6 - DRC stalf found a well completion diagram and geologic
log .for this well in the February, 1993 Peel Environmental Services
Report (Appendix A).
(2) wells MW-16, MW9-1, MW9-2, MWjT-r, and MllttT-2 - please explainwhat efforts were completed to locate the required wilt compietion
diagrams and geologic logs for these.four @) dry wells. In the evint thatnew e.ffort.r find this information, please provicle it at your earliest
convenience.
RESPONSE
Searches were performed as described under 1.A. above. IUSA located, duringthe search of the Mill records, logs for the wells and completion desciiptions.IUSA has also located packer tests and well logs for MW-16, -17, -lg ani -tg.This information is enclosed as Attachment J. Information on nested wells MW-9and MW-10 has been included as Attachment B in response to question l.A.
above.
Two Nested Angle Borings Near cell 4A [p. 5, Item 3.8.4 - please explain whatefforts were made by IUC to locale the requested informatiin for thise two (2)borings. Should new e/.forts locate this data, pleaie submit it at your earliest
conyenience.
RESPONSE
Please see response to question l.C. and 3.A.(2) above.
and
acknowledge submittal of two (2) IUC maps of the facility, includiig.
D,
4
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Mr. William J. Sinclair
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A. August 28, 2000 LANDESIGN Site Control Map - prepared by LANDESIGN
Engineers, Surveyors and Planners ofGrand Junction, Colorado, Sheet I qf l,
Rev. I (submitted as a part oJ the September 8, 2000 I(lC Revised GIR). Thisdrawing included a data table of survey coordinates, and a simple relative
posilionplotfor many of the requested.facilities at the Whle Mesa site.
B. IUC Topoqraphic Mao - provided to the DRC by Mr. Ron Hochstein of IUC on,lune 13, 2000. This detailed topographic mctp, prepared by an unknown party,
provides location details .for many of the site facilities, including but not limited
to: footprint of tailings ponds, tailings pond berms, site roads, mill site, mill siteproducl and process storage tanks, ore storage pad, wildlife ponds, topsoil
storage pcrds, mill process buildings, administration building, current truck scale
building, and mill site process wastewater pond ("Roberts Pond"). This map wasreportedly prepared at l:3,600 scale (r": 300 ft), as derived.from
photogrammetry data collected.for the site in February, 1999.
Review of these two (2) IUC maps shows that much of the information requestecl in theFebruary 7, 2000 DRC RFI has been providecl on one map or the oiher, with the
exception of the following items and concerns;
C. Co*binrtion o-{'Situ Plon ,rd Topogrophi, Mortt [p. 9, Itu* 9l - fur ease of
reference and to .facilitate preparation of .future DRC hyclrogeoiogic cross:-
sections and other maps it is essential for atl the required elements to be
presented on a single map. For this reason, DRC staf;f request that IUC combine
the above site control and topographic mqps into a single map. Please ensLtre
that the accessible discharge related facilities are shown on tie combined map,including, but nol limited to [p 5, Item 4.A.] thru 5, and 4.8.2J. tailings ponir,
tailings pond berms, existing groundwater monitoring wells, former iuils orrl
piezometers, water supply wells, exploratory borings, dry wells and piezometers,
and the chloro.form investigation temporary wells.
RESPONSE
IUSA has enclosed, as Attachment K, a copy of a topographic map titled "lnternational
Uranium (USA) Corporation, White Mesa Mill, Topographic Map - 1999 Contour Base,,,indicating the location of all topographic features on the site, ai well as monitor wells,former wells and borings. water supply wells and chloroform investigation wells.
As discussed with DRC, the existing grid system and vertical datum of the most recent
topographic maps (1999) do not line up exactly with the x, y and z coordinate system
established during the August 2000 survey completed by LANDesign, Inc. IUSA hasevaluated the options for resolving this conflict and has decided to proceed with
generation of new topographic maps based on the most recent survey, with in adjustment
back to the original elevation datum. Use of the original elevation datum will eliminate
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potential conflict with years of historical data and reports. Therefore, elevation data
presented to DRC since August of 2000 will be adjusted by a constant factor to bring theinformation back into conformance with the historical data and reports. IUSA has
enclosed, as Attachment L, a revised listing of the features surveyed ty LANDesign inAugust of 2000, using the new elevation datum. Additional features requested Uy LrnC
have also been added to the listing of x, y and z coordinates. IUSA will make thenecessary adjustments in data and spreadsheets that IUSA will maintain for the Mill,
which will save DRC the burden of changing values. This information will be submitted
under separate cover.
Until new aerial photography can be obtained and topographic maps generated, IUSA issubmitting the attached drawing based on DRC's statements that itsintirest is in knowing
where wells are located relative to features of the site, such as ponds or stockpiles. IUSAwill continue in its efforts to resolve survey issues, and will, upon resolution of such
issues, then prepare updated cross sections and other maps, including perched zone waterelevation contour maps and water surface elevation contour maps. These contour mapswill be periodically updated by IUSA and provided to DRC.
D. Nearby Stockwaterine Wells [o.6, Item 4.A.6J - nearby stockwatering wellsconslitute polential points of exposure for the facility. Please provide survey
coordinates, including ground sur.face elevations for both the Jet Pump ancl Jonis
stockwatering wells located near the.facility.
RESPONSE
DRC agreed that it is acceptable to approximate locations. The map enclosed asAttachment K indicates the approximate location of the Jones Well, and the coordinatesare listed on Attachment L. The Jet Pump Well is located off the northern limits of theattached map and is not shown. The coordinates of the Jet Pump Well are indicated onAttachment L.
E- Nearb)t Contact Seeps and Springs [p. ]3, Item l3J - nearby seeps and springs atthe edge of White Mesa also form potential points of exposure for thi yoitity.
Plea,;e provide survey coordinates and ground surface elevationi for atl contict
seeps and springs near the facilily.
RESPONSE
In the September 8, 2000 GIRRP submittal to DRC, IUSA submitted aerial photos,Attachment 10, showing vegetative patterns indicative of seepage along the nearesicanyon margins, which, based on our meeting of April 7, 2000, we understood to besufficient for the present purposes. As reported in the GIRRP, IUSA could not, however,
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provide detailed land survey locations fbr all contact seeps and springs, because suchfeatures vary depending on a number of hydrogeologic conditions. tUSa submitted acurrent map showing water surface elevations for the perched groundwater zone. Thewater surface elevations in the perched groundwat er zone generally decrease near the
margins of the canyons, where the perched groundwater zonethins and is discharged.
Plate 2.6-10. in the Env hite Juan
(Dames & Moore, J""*ry 30, lr?gl th"
relevant portion of which are contained in Attachment I of IUSA's Sepiember 15,2000
transmittal to UDEQ, Sum roundwater Backsround W
other Water Oualit)u Studies For The White Mesa Mill, lists fou. rp.,.rgs *frich wereamong locations of groundwater sampling stations in the proposed project ,i.irrity during1977-78. The locations of these stations were described in the Environmental Report asfollows:
Station No.
GlR
G3R
G4R
G5R
Location
spring in corral creek, 500 feet upstream of earth dam and surface
water station 53R, upgradient of project site
Spring near Ruin Spring Point, drains to Cottonwood Creek.
downgradient of project site
Spring near base of Dakota sandstone cliffs about 500 ft east ofjeep trail, drains into cottonwood creek, downgradient of project
site
Spring about 1,500 ft east of westwater creek in canyon, to west
and possibly downgradient of project site
As it is evident that the objective of these early siting studies was to locate any potentialwater sampling locations in or around the project site in order to establish baseline waterquality conditions at such features, IUSA will use the above information regarding thesesprings to guide it's search for springs, and will then attempt to produce coordinates andelevations for the locations of these particular springs.
To provide approximate coordinates for these seeps or springs, IUSA will conduct fieldreconnaissance to attempt to define locations of such features and will utilize hand-heldGPS with a resolution of */-5 feet to locate the x, y, and z coordinates for them.Information generated will be compared against historic maps to verify locations andelevations. IUSA will present these findings to DEe by the end of July.
S:\MRR\groundwarer discharge-pcrnrit\March20Olrspn\Follow up to 05 ll0l Letter.doc
Mr. William.l. Sinclair
Jwe22,2001
Page 15 of20
F
after comparison of the site plan map from the october 4, 2000 ,hto*yor*
investigation report (Figure I l) with the I(IC topographic map provided on June
13, 2000, we have estimated the survey coordinates of the septic tank drainfield
located a short distance Southwest of the existing truck scale house. piease
confirm the accuracy and content of the DRC e stimated survey coordinates forthis leachfield, as provided in Table l, below.-
Table DRC 1. Etti*o!:!!ry:! tooldinates; Former IUC Truck Scale House Leachfield
Corner Easting (feet)Northing (feet)
Norlhwe.gt 2, s80,7 3 5 3 22,3 30
Northeast 2,580,800 3 22,3 30
Southeasl 2,580,800 322,260
Southwe.rt 2,5 80,7 3 5 322,260
RESPONSE
The searches defined above under 1.A. yielded original engineering drawings whichdepict the design location of the historic scalehouse leachfield. IUSA has used thishistorical information to locate the Scalehouse Leachfield on the drawing enclosed asAttachment K. The coordinates are also listed on the summary of coordinates andelevations enclosed as Attachment L.
Submittal Relsuomtttat o-r survey Loordinates Jor Related Facilities [new iof the IUC information provided to date, DRC staff hav
Coordi cJ lttvyv ttctftl - ultct ruvlcw
staff have determined that
after review
additional related facilities at the site need to be localed on the combined siteplan and topographic map, including but not limited to;
(1)ic Tsnk reportedly
located a short distance North-Northwest of the truck scale house.
(2) Former Administralion Building Septic Tank Drain-field - once locaterl
southeast o.f the main o.ffice building.
(3)rormer Laooratory wastewater storage l'ank and Drain pipe _ including
the location of the above ground tank that was once located on the Norrh
side of rhe mill administration buitding and the pipe that drained it to themill site wastewater catch pond (" Roberts pontl').
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Mr. William J. Sinclair
ltne 22,2001
Page l6 of20
(1)
(s)
Former Mill site sedimentation Pond - also known as the .fly-ash pond
(6/79 D'Appolonia Design Report, Sheet a of t 6)
Former Solid waste Land-fill - located near one of the wildlife ponds East
of the mill site.
Please ensure that the survey coordinates .for all of the related facilities outlined above
are accuralely ploiled on the combined map also requested.
RESPONSE
The searches defined above under
depict the design locations of these
features and indicated them on the
coordinates are also listed on the
Attachment L.
l.A. yielded historic engineering drawings which
features. IUSA estimated the coordinates of these
map enclosed as Attachment K. The features and
summary of x, y and z coordinates enclosed as
5 rlxptananon.tor tncreastng Groundwater Head Trends [p. ]4. It
the description o.f the number o.f wells and the magnitudi of hea,of head increase seen in wells
we appreciatelonGrHead
at thefttcility (9/8/00 IUC RevisedGIR, p 26). However, as outlinecJ in the March 13,DRC Request .for Confirmation (RFC) letter, DRC sta.ff will complete the .final waterlable conlour and isopach thickness maps for the shallow aquifer (3/13/01 'DRC letter,pp 4-5) This leaves two remaining items .from the February 7, 2000 DRC RFI thatcontinue to be unresolved, as outlined below;
rtun unu pcneaute.lor Addttrcnal Montforinq Wells or piezometers [p.]5, It
14.c1 - we have reviewedyour september 8, 2000 response and fou"a ir foitno
and ,
failed to
Addir torins Wells or Piez
address the need to identifu the root cause for the increasing head trlend. As
explained previously it is likely that lhe rising grounclwater levels observed islikely due to some artificial source of groundwater recharge. Consequently, sucha study will require the installation of additional wells and/or piizomiters in
order to identify the source of the man-made recharge. In order ro facilitate this
ef.fort, DRC staff have prepared several .figures to guide your " planning, as
described below;
(1)DRC corrected well H)tdrographs - have been prepared for existingmoniloring wells at the facility, based on corrected groundwater elevation
data provided you in the March t3, 2001 DRC RFC letter, see Attachmentl, below. These hydrographs establish that the wells with the greatest
increases in groundwater head include (in decreasing order); MW-4, MW-
19, MW-18, and MW-ll.
A
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Mr. William J. Sinclair
Jwe22,2007
Page l7 of20
(2)DRC water Table Equipotential Map; september, 2000 - this water table
contour map prepared from IUC water level data collected in September,
2000 includes groundwater head data from most of the existing
monitoring wells at the site, plus all the chloroform investigation wells
recently installed. Review of this DRC map suggests that the artificial
groundwater recharge source is located North and East of wells MW4
and MW-19, see Attachment 2, below.
DRC Delta Head contour Mao - the magnitude of increased head in eachIUC well was calculated by DRC staff after review o.f the hydrograph
trends seen in Anachment l. DRC staff took selected heads .from the
spring of 1983 as representative o.f baseline conditions ctt the facility.From this, increases in head were calculated for each well thru summer,
2000. These head increases (Delta Head values) were then tabulated and
contoured on a map; see Attachment 3, below This map suggests thal the
artificial source of groundwater recharge is located east of MW-4 and
MW-|9
(3)
Please provide a plan and schedule for the installation of additional monitoring
wells and/or piezometers to locate the source of the artificial groundwater
recharge apparent North and East of wells MW-l and MW-l9.
RESPONSE
IUSA has, in the Chloroform Investigation, provided (based on discussions with
DRC) qualitative data as to potential sources of increasing water levels observed
on the eastern portion of the Mill properly. However, we understand DRC,s
request that IUSA further investigate the increasing water levels in certain wells.
In general, the wells exhibiting water level increases are in the portions of the sitethat early investigators indicated would be most likely to exhibit naturallyoccurring groundwater mounding. For example, the early Mill siting
investigations reported the probability of natural-occurring groundwater
mounding beneath the project site. In particular, the Environmental Report
(Dames & Moore, 1978) stated, in Appendix H:
"lt is probable that slight ground water mounding may occur in the
east-central part of the mesa. Ground water levels may be highestin the center of the mesa, coincident with the highest land
elevations, and lower to the east and west where ground water can
drain from the mesa through springs and seeps in the canyons of
Westwater, Cottonwood and Corral Creeks."
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Mr. William J. Sinclair
Iune 22,2001
Page l8 of20
"lt appears that the shallow ground water forming the water table
throughout the project vicinity has a gradient toward the south-
southwest. The general ground water gradient appears to be
related to the general topographic gradient; i.e., the highest
elevations are generally at the northeastern edge of the project site
near Highway 163 and the lowest elevations are at the property,s
southwest corner."
As later reported in
Enersv F f Land M
Uranium Project San Juan Count)r. Utah (Dames & Moore, Julyprobability of naturally-existing groundwater mounding was
substantiated by water levels measured in drill holes and wells in the
the White Mesa mill (Dames & Moore, 1978).
White M
1980), the
"partially
vicinity of
IUSA concurs with DRC that the source of apparent recharge is most likely
northeast of the Mill. In response to DRC's request for a plan and schedule foreither additional monitoring wells or piezometers, as well as similar related
questions raised in DRC's June 7, 2001 letter to IUSA regarding the Chloroform
Investigation, IUSA requests the opportunity to meet with DRC to discuss
specifics of the following concepts IUSA would propose to include in our field
investigations. Specifically, IUSA anticipates that the field investigations would
include siting of approximately two to four piezometers in un ui"u north and
norlheast of monitoring wells showing the greatest increases in water levels.IUSA would include scheduled, regular surveillance of water levels in those
piezometers until the water levels reach post-drilling equilibrium, and continue
such scheduled water level measurements to evaluate the water table gradient.
Also, as discussed at the April 7, 2000 meeting, IUSA will continue to generate
updated water table plots incorporating these data, for the purpose of evaluating
how the perched groundwater zone behaves during this investigation period, and
to provide these updated plots to DRC.
In addition, IUSA anticipates performing pumping tests in those wells exhibiting
significant water level increases to assess potential changes in their hydraulic
performance due to water level increases and to relate the implicationi of thepump test results to groundwater protection issues and the Chloroform
Investigation. These field investigations will therefore be designed to address the
data objectives required to respond to DRC's questions regarding the Chloroform
Investigation, while also allowing IUSA to fuither investigate the source of what
appears to be man-made recharge originating to the north and northeast of the
property.
S:\MRR\groundwater dischargc_permit\March200lrspn\Follow up to 05 ll0l Letter.doc
Mr. William J. Sinclair
June 22,2007
Page 19 of20
In the meantime, as IUSA and DRC discussed during the April 25th meeting,IUSA will be responsible for preparing water table contour and saturated
thickness maps for the perched groundwater being monitored at the Mill. An
independent hydrologist assisted IUSA in preparation of contour maps, using the
correct interpretive tools based upon the distribution of the data at the site.
Enclosed as Attachment M are maps depicting the Water Level Contours for
December 2000 and March 2001, and Saturated Thickness of PerchedZone.
B. Additional Groundwater Oualit-v Data [p. ]5, Item l4.DJ -we acknowledge thatyour chloro.for* investigation report will address groundwater quality issues and
the potential .for other contaminants as indicators of chloroform discharge
(10/4/00 IUC Chloroftrm Report). We have also received your September i5,
2000 Groundwater Background LVater Quality Report. This issue and both of
these reports will be reviewed at a later date.
ions. and
Item I l.Bl - the September 8, 2000 IUC response referred to yourfailure to locate copiesof original laboratoryt permeability data. In contrast, our orig,inal February 7, 2000
request was .for copies o.f notes, calculations, and data for the ./ield permeability tests
conducted on monitoring wells, borings, and piezometers at the /acility. To reiterate,
please provide the ./bllowing ;
A. Field notes and data collected.from eachfield permeability test, and
B. Detailed description and justffication oJ calculations and analysis methods used
to determine permeability. In the event that test data from certain wells was re-
analyzed, please explain whv re-anctlysis was required.
After submittctl and review of this information, DRC staffwill prepare a summary table ofall available permeability data and askfor IUC concurrence.
In the event thal the information requested above cannot be provided, please submit aplan and schedule for Jield permeabiliQ testing of all shallow oqii\u, wells and
piezometers at the .facility.
RESPONSE
Searches were performed as described under l.A. above, and IUSA was successful in
locating some new data. This information is included in the response to item L A. above.In addition, HGC is compiling some of its field notes and a discussion of analytical
techniques for the tests conducted at MW-4 and MW-19. Based on this complete review
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Mr. William J. Sinclair
June 22,2001
Page 20 of20
of available hydraulic data, IUSA is proposing to conduct pump tests on selected wells to
provide additional information.
The drilling and logging data indicate that the physical characteristics of the rocks
beneath the Mill vary considerably both vertically and laterally. Therefore, in June of
2000, IUSA discussed with DRC the appropriateness of attempting to use the limited data
available to create a "contour" *up based on specific data for specific bore holes. The
feasibility of such an approach may be limited in view of the fact that hydraulic
properties of this stratum, which have been determined from 12 single, well-
pumping/recovery tests and from 30 packer tests yielded a broad range ofhydraulicproperties, which will not reasonably lend themselves to a defensible contouring
approach. Furthermore, the depositional history and composition of the Burro Canyon
Formation is such that one would expect random variability rather than mapable contours
from one point to another. Given these limitations, IUSA asked HGC to attempt to show
general areas with similar permeability values based upon selected data available for the
saturated zone, which is presented as a Perched Zone Permeability map. In addition,
HGC prepared a Contour Map of Top of Brushy Basin. These two maps are enclosed as
Attachment N.
If you have any questions or comments regarding this letter, please contact me at (303) 3g9-
4160.
:21{2,ru-
Harold R. Roberts
Vice President - Corporate Development
Enclosures, Attachments A - N
cclatt: Larry Mize, UDEQ Division of Water euality
Loren Morton, UDEQ Division of Radiation Control
R. William von Till, NRC
Michelle R. Rehmann
Stewart J. Smith
Roman Pyrah
cc w/out att: Dianne Nielson, UDEQ
Dave Arrioti, S.E. Utah Health Department
Ron F. Hochstein, IUSA
David C. Frydenlund, IUSA
Yours truly,
S:\MRR\groundwater_discharge-permit\March200lrspn\Follow up to 05 I I 0l Letter.doc
INrBnNerroNo"O
Unaxruu (use)
ConponATroN
Independence Plaza, Suite 950 o 1050 Seventeenth Street r Denver, CO 80265 . 303 628 7798 (main) . 303 389 aI2E (fax)
May I l, 2001
YIA FACSIMILE AND EXPRESS COURIER
Mr. William J. Sinclair
Director, Division of Radiation Control
Utah Department of Environmental euality
P.O. Box 144850
168 North 1950 West
Salt Lake city, uT g4t 14-4850
March 20, 2o0l UDEQ letter and Request for Additional Site HydrogeologyInformation in response to rusA september g, 2000 Revised GrouidwaterInformation Report
Ground water Discharge Permit Apprication for white Mesa Mill:
Dear Mr. Sinclair:
International Uranium (USA) Corporation ("IUSA") appreciated receiving the comments fromthe Utah Department of Environmental Quality 1"LtI)Eq"y Division 6r Raaiation Control("DRC") transmitted by letter dated March 20,zdol, in response to IUSA,s scheduled submittalof September 8, 2000. Thank you for meeting with us on April 25 to discuss DRC,s comments.As we discussed at the meeting, IUSA has prepared a revisei, accelerated schedule to respond toDRC's March 20 comments while also preparing a number of the other technical submittalsrequired for the Groundwater Discharge permit 1..GWDp,,;.
As shown on the enclosed revised schedule, ruSA will need until mid-June to complete andsubmit all responses required to the March 20 response and request for additional information, inaccordance with the scope discussed for each item on April 25. To help ensure that the plannedscope of our technical submittals is as DRC requested, we have outlined below ourunderstanding, based on our discussion with DRC, of the form of response ruSA should provideto each item. But in addition to submittal of these responses, IUSA and our indeiendentengineers, hydrologists, and geochemists are simultaneously preparing a number of othertechnical submittals, all of which, as shown on the enclosed accelerated s=chedule, are projectedfor delivery to DRC during the months of July and August.
Mr. William f. Sinclair O
May 11, 2001
Page2 of2l
We also transmit herewith selected items which were more readily available and did not requirecompilations or organizationby IUSA. We have noted transmittaiof these items in the ,u*rurybelow.
ruSA will continue tomake every effort to resolve technical information items as completely aspossible, given availability of historic informatioq and we appreciate DRC's ugr"Lr.nl toaccept information from historic reports, where appropriate, as hai been discussed in our March1999 meetings, when original data prove to be unavailable. In addition, further searches forhistoric information have been successful in locating much of the information you requested.
For ease of reference,--the- request language contained in your letter of M arch Z0 (the Request forInformation, or "RFI")) is repeated in the same order is used in the letteq indicated in italicsbelow.
t.'ell
several wells, piezometers, and/or boring remain without *iiio*4tiilaagro*s indgeologic logs, as already provided, see discussion below
I. Seven Wells and-Piezopeters [p. 2. Item 2.C.2J - we achtowledge that seven (7),not six (6), wells and piezometers are at issue here, includin! three (3) ,ilit,MW-20 thru MW-22, andfour (4) piezometers: MW7-L, tulwi-2, MlFl0-t, qnd
MWI0-2. We appreciate the new survey coordinates providedfor these seven (7)
installations. However, the September 8, 2000 illC Revised CinftaiUa b providewell completion diagrams for these seven (7) wells and piezimercrs. please
provide the required well completion diagrams, and geologic logs for these seven(7) installations. In the event that this information has teen los{ please provide a
schedule for completion of video and geophysical logging to coiect thi requiredinformation.
COMPLETED
As discussed during our meeting on April 25, ruSA has engaged Harold R.Robert, P.E., to assist in searches of IUSA Denver files and Umetco files in GrandJunction- Mr. Roberts, a licensed professional engineer, has been involved withthe White Mesa Mill since its construction, and as iuch is an asset in searching forthe records DRC requested. Mr. Roberts also searched Mill archives, officeslandoffice files. Having completed those searches during the week of epiit 3g-May 4,Mr. Roberts concluded that records transfer information provided to him at thetime of closure of IUSA's Grand Junction office appearJ to be correct; that is,records regarding the Mill were transferred to the Mill, while records regarding
the Mines were transferred to the Dove Creek offrce, and those were later sent onto the Fredonia office. Mr. Roberts believed this to be evident by the fact that rawdata from the 1994 drilling campaign were found in Mill urrhiu., he searched;
s:\MRR\groundwater-discharge_permit\March200lrspn\respto3200l deqletO5l l0l.doc
Mr. William J. Sinclan
('
May I l, 2001
Page3 of2l
therefore, he has reported that he believes it would be fnritless to search for thesame records in Fredonia. As a result, the expanded search he performed at theMill and umetco's Grand Junction office is the final search of records.
As a result of these searches, IUSA has located constant head pressure tests forseveral of these MW's and borings. IUSA is organizing and sorting these data,
and will submit the results in the June data transmittal a-s shown on ih" proposedaccelerated schedule. rusA has also searched Mill archives, offrces, ura om..files for:
(l) Well completion diagrams for MW-20 , -Zl, -22(2) Well logs for MW9-1, MW9-2, MWl0-1, and MWt0_2
During this search, ruSA located working files and field notes from drilling ofwells MW-20, -21, and -22. In addition, rusA located what appears to be a
]able and pages from a report by D'Appolonia, which gives data for shallowborings 9'1,9'2,10-1, and 10-2. ruSA iJ reviewing these data and will transmitto DRC, in the June data transmittal shown on the pioposed accelerated schedule,the well logs and completion diagrams found in the files of the table and pagesfrom the D'Appolonia report.
SCOPE OF RESPONSE, BASED ON DRC/IUSA MEETING OF APRIL 25,2001 (the *APRIL 25 MEETING')
DRC and ruSA noted that video logging may be impractical in cased wells.rusA is to consider different potential means
-of
geopirysical logging, if rusAdoes not locate well completion diagrams and well logs^for all of thiatro"ve wells.
ruSA noted that a conceptual model of the site, reported by geologists, existedprior to the Mill siting and this conceptual model has been conoboiatej Uy Uittlicensing activities. DEQ noted that the Brushy Basin contact is the gellogicfeature of interest to DRC, and concurred that, irrespective of the numbeiof datapoints available, there will remain uncertainty in difining the top of the BrushyBasin throughout the Mill property. DRC indicated that if would not benecessary to pull casing in order to log these wells, but asked ruSA to considergeophysical means of establishing the contact. For this item, DRC wasparticularly interested in:
Attempt to define the contact in these wells.
consider whether any geophysics might be used, if well logs cannot belocated.
Determine whether or not the dry wells located the contact.completion diagrams would be best, but at a minimum, find the top andbottom ofthe screened interval.
(r)
(2)
(3)
(4)
s:\MRR\gro'ndwater-discharge_permit\March200lrspnvespto3200ldeqletO5l l0l.doc
Mr. William J. Sinclafu
(,
May I l, 2001
Page 4 of2l
2.
description provided, it is crear that after inttattiiii *uitn i @ ,Lil, *r*actually named MW-20, MW-21, and MII-22. we also acknowleige that newsurvey coordinates haue already been provided for these three (3) ielts (9/S/00IUC Revised GrR, ItlNDlsign map sheet t of I). In addition, DRC staff lns alsoujlited each of these during the last split groundwater samplin{ event inNovember, 2000. How1u7r, p-l-ease provide the foilowing nformittoi still foundlackingfor these three (3) wetls:
(I) Geologic logt - that locate the depth to the upper Brushy Basin Shalecontact,(2) Well completion diagrams, and(3) Dates ofwell installation.
COMPLETED
This .is same request, essentially, as (A) above. Searches were performed asdescribedunder 1.1. above. ruSA located working files and field notes fromdrilling of wells Mw-20, -21, and -22. As discusse-cl under item 1. above, rusAalso located what appears to be a Table and pages from a report by D,Appolonia,which gives data foiihallow borings 9-1, g-i,10-1, and l0-r. ruSA is rwiewing
these data and will transmit th9 any georogic (well) logs, completion diagrams, ordates of installation found in the firei or the tabie and pages irom 'the
D'Appolonia report, in the June data transmittal shown o, tt. proposed
accelerated schedule.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 24 MEETINGIt was agreed that items 44 and 48 may be combined as one response, and thescope of both responses would be as defined above under item 4A..
3.-I thru GH-4 lo. 4 -.from review ofthe september 8, 2000 Revised GIR, tt is cleailhatfour 111 g*tuinni*t borings
Wreline geophysical logs,
Wireline vifuo logs
Geologic logs
were also installed neor the tailings cells in conjuiction wiih wells MW-20 thruMW'22; as a part of studies completed/or the NRC and EpA (g/S/00 IUC RevisedGl_!, w. a-5). Apparently these borings were named GH-\, GH-2A, GH-3 andGH-4. we aclcnowledge regeipt of field qnd laborqtory permeability data fromthese four (40 borings ln the september g, 2000 Revised GIR (Atiachmuit 10,Tables c-5 and c-6): However, this report also explained how oihu information
was collectedfrom these borings, including:
u)
(2)
(3)
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Mr. William J. Sinclai. O
May 11,2001
Page 5 of2l
Please provide reliable survey coordinates and all geophysical, video andgeologic logs madefor thesefoir (4) borings.
COMPLETED
Searches were performed as described under 1.1. above. Geologic logs havebeen located. A video log that appears to relate to at least two oflhe boiings has
been located_, a1d is being reviewed by IUSA. A copy of the video tog witt beincluded in the June transmittal to DRC.
The Umetco 1994 report (referred to by DRC as the "peel Report,,) is beingreviewed by IUC.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
For the above-referenced !!rvey coordinates, DRC indicated that it is acceptableto approximate locations, if surveys are impractical. ruSA will designate thosecoordinates for which locations have been approximated. The Uriet co 1994report (also located) shows, in a work plan, the planned locations for these points.ruSA is to approximate these on a map, and estimate coordinates. IUSA reportedthat it seems likely that we will not be able to find the boring locations in thefield, however.
4. Former Monitoring Wells [p. 4. Item 3.A.4 and 3.8.21 - apparently I(JC has beenunsuccessful in their attempts to provide information onfior*r, monitoring wells
now abandoned. However, additional information is reqiired, asfollows:
Q) Well MW'13 - afier I(IC's unsuccess/ul attempt to locare this information(9/8/00IUC Revised GI& pp. 12 & 16), DRC-stafffound the requiredwellMW-|3 data in a March, 1983 Energt Fuels Nuitiar (EFN) Cinstruction
Report for-Cell 3 (Appendix D, see ll/t/52 D'Appolonia Consulting
Engineers letter report). Please provide reliable survey coordinates fithis well.
COMPLETED
Searches were performed as described under l. l. above. Mr. Roberts copied
data from a D'Appolonia report of I l/l lllg82. ruSA has also located a letter toNRC that showed a map indicating where this well would be after Cell 4 wasconstructed. It is now inside Cell area. Copies of the report and letter to NRCwill be provided to DRC.
ruSA is approximating coordinates from information IUSA has located.
SCOPE OF RESPONSE, BASED ON DRC/IIJSA APRIL 25 MEETING
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Mr. William J. Sinclair
May I l, 2001
Page 6 of?l
The "reliable" coordinates that DRC has requested may be estimates, because thewell location is now inside the Cell 4A area. ruSA will designate ihe points as
estimates.
(2) wells MW6-1. MW6-2. MW7-t. MW7-2. MW8-t. and ttwra-z - please
explain what efforts were completed to locate the required well iompletion
diagrams and geologic logs for these six (6) formir wells. In the eventthat new efforts find this information, please provide it with reliable
survey coordinatesfor each well at your earliest convenience.
COMPLETED
Searches were performed as described under L l. above. ruSA was able to locate
installation data for these shallow borings. This information will be organized
and transmitted to DRC with the June transmittal package.
SCOPE OF RESPONSE, BASED ON DRC/TUSA APRIL 25 MEETINGruSA is to provide DRC with descriptions of IUSA's search for logs andcompletion diagrams. If estimation of coordinates becomes ,ecessary, DRC
agreed that it is acceptable to approximate locations, if surveys are impractical.ruSA will designate those coordinates for which locitions have been
approximated.
5. R tolution Plo, ond S_.hrdrl"fot wull MW-3 [p. 2. Itr^ 2.C.6J - we acknowledgeyour inability to produce a well completion diagram and giotogic log for wZllMW-3. This information is essential for determination of iquifir thickness andelevation of the Brushy Basin Shale upper contact. At tits iie, it qpears thatthere are only two options to resolve this problem:
(I) Wireline Video and Geophysical Logs - to locate the screened intervals in
the well, and depth/elevation of the Brushy Basin Shale upper contact.
(2) Install a Conrtrmation Boring - in the event that the geophysical logs are
unsuccessful in locating the Brushy Basin Shale uryer contqct, ctconfirmation boring may need to be installed near well MW-3 to allow an
adequate geologic log to be assembled.
Please provide a plan and schedule /or these resolution activities for well MW-3within 304oys of receipt of this letter.
COMPLETED
In the Groundwater Information Report Revision package (..GIRRII,,;, rusA
submitted construction detail from the Titan Hydrogeologic Report (it had been
copied from D'Appolonia). The detail does not show geJogy on this detail, andthe contact is not shown. It appears that this well wis orty d.itt.d to 96 feet,
slMRR\groundwater-discharge_permit\MarcM00 lnpn\respto3200 ldeqlet05 I l0 l.doc
Mr. William f. Sinclair O
May I1,2001
PageT of2l
based upon this report. In addition, searches were performed as described underl.l. above. These searches failed to yield a more detailed geologic log forthisparticular well.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETINGruSA will continue to discuss with DRC the feasibility and need for defining theBrushy Basin contact at this location. IUSA notes that the top of Brushy i'asinthroughout our entire site, which is in excess of 5,000 acres, cannot be quantifredin complete precision, because there would always be too few data points. Thesite conceptual model, however, which has bein published and available forpublic comment since the Environmental Assessment was first published in 19g0,
supports the general conclusion that the Brushy Basin is presint as a confiningunit beneath the site. This is evidenced in a number of ways, including: pressurl
head observed in wells drilled to the underlying Entraia/tiavajo Jandstones;observed contact in canyons adjacent to the site; observed contact seepage at thecontacts; historical descriptions of regional lithology, by independent geilogists;
and observed presence of the contact in wells drilled throughout the site.
DRC had requested a schedule describing IUSA's plan to resolve the abovequestions, submitted within 30 days of the March io letter. ruSA and DRC
agree-d that IUSA is to prepare a proposed revised schedule for GWDp submittals,in light 9f the delays experienced by IUSA in compiling the requested information
and by DRC in reviewing.IUSA's previous submissions. ru-Se has prepared arevised, accelerated schedule to respond to DRC's March 20 comments while alsopreparing a number of the other technical submittals required for the Groundwater
Discharge Permit GWDP.
As described in the introduction to this letter, ruSA will need until mid-June tocomplete and submit all responses required to the March 20 response and requestfor additional information, in accordance with the scope discusied for each item
on April 25.
With regard to this technical issue, ruSA is to provide DRC with its approach todefining the top of contact at this location. Options could include gLbphysical
logging, or possibly drilling a confirmatory boring. ruSA agreed to discuss thiswith our technical consultants, and then will ask fo, u *r.Iing to discuss theirrecommendations with DRC.
2. P _we
aclmowledge that no additional well construrtio, in 4.Close review of the available IUC information indicates that the base oj the well,sscreened interval is about l3 feet above the Brushy Basin Shale upper contait (7/94 TitanReport, Appeyrdix,a', rtl-!_completion diagram). After consideroii* that chloroform hasbeen detected in this well, it is clear that ihe p,oteniial existsfor dense ,on-queous liquid
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Mr. William J. Sinclan O
May I l, 2001
Page 8 of2l
(DNAPL) contaminants to go undetectedwith this well configuration. As a result, we seeno other option but to askIUC to complete one of thefollating activities:
I. Re-pedorate Well MW-4 - by cutting new perforations in the well casing, belowthe existing screen interval, to allow well access to the aqurfer int-e:nal fnquestion, or
2. Installation of a Second Well - in the immediate vicinity of well MW-4 to provide
a screened interval that is in direct contact with or is screened across thi BrushyBasin Shale upper contact.
Please provide a plan and schedule for one of these activities for well MW-4 within 30-days of receipt of this letter.
COMPLETED
The schedule for our responses is as previously discussed in this letter.
With regard to this technical question, prior to meeting with DRC on April 25, ruSAasked our independent hydrology consultants to review the data- for 'fufW-+.
HydroGeo9!", (HGC) reported that the well completion diagram is in error, and that thegeophysical log depicts the correct contact of the Brushy gasin. The hydrologist foundthat the M.W-4 well completion diagram provided in Appendix A tf Ti;n, lgg4,conflicts with the geophysical log of MW-4, which is also pr&iA.O in Appendix A of thesame report. In the well completion diagram, the Brushy Basin contait is apparentlydepicted at a depth of approxim ately 125 ft bls, and in thi geophysical log, the nrushyBasin contact is depicted at 108 ft bls. The geophysical tog is stated to be the moreaccurate value, based on the lithologic logs of nearby temporary wells TW4 -1, TW4-2,TW4-7, TW4-8 In these logs, the Brushy Basin contact is noted at approximateiy 103 ft,105 ft, 98 ft, and 105 ft bls, respectively. Based on this information, ihe actual iepttr oithe contact at ivrw-4 is reported by HGC as being most likely tos ft bls.
In the Chloroform Report (ruC/HGC, 2000) memorandum, HGC notes its disagreementwith DRC's statement that "it is clear that the potential exists for non-aqu.om liquid(DNAPL) to be undetected at the well". Rather, HGC reports that the data'clearly pointto the opposite conclusion. For example, HGC reported that, because the screenedinterval at MW4 extends to a depth of itZ ft bls, ary ONAPL that might potentially bepresent would, therefore, be expected to enter the well casing. As discussed ir:- theChloroform Report, howeveq there is no evidence of DNAPL at VfW-4, in any of theother temporary wells, or in the vicinity of the abandoned scale house leach field which isconsidered to be the original source of the chloroform in the perched water. Thisconclusion is based on all of the following facts:
(l) Low soil gas concentrations(2) Maximum groundwater chloroform concentrations that are more than three orders
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Mr. William J. Sinclair O
May l l, 2001
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of magnitude less than the solubility of chloroform, as detailed in IUC, 2000Multi-depth sampling of MW-4 did not indicate increasing chloroformconcentrations with depth in the well bore, as would be expect-d if DNAPL
existed at lv[W-4.
Based on the above facts, and because of the close proximity of temporary wells to MW-4 (TW4-7 is within approximately 30 feet of MW-4), HGC determined that there is noneed to rehabilitate or re-perflorate MW-4, nor to install additional wells near MW-4.ruSA notes that the individual performing these analyses and providing the aboverecommendation is.an experienced hydrologist with particular expertise ii evaluating
mo_vem9n! of organics in the subsurface. For DRC's reference, the hydrologist,s ,.ruri
and technical memorandum dated April23,2ool, is transmitted herewith. -
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETING
DRC noted that due to the presence of chloroform in MW-4, DRC regards this well as afocus of attention, and wants very clear indication as to the location olthe contact. DRCnoted that the top ofthe Brushy Basin is, as discussed earlier in the meeting, irregular dueto its depositional environment. DRC hypothesized that it may vary ..cJnsidelbly,, inthe few feet between MW-4 and the five temporary wells drilled near it.
DRC recommended that IUC respond that it believes that lZ5'is the wrong value, andprovide support for that statement. In response to this specific request, ru$e transmitsherewith the independent hydrologist' s technicar *.'no.undu,,.
ruSA is to provide DRC with its approach to further defining the Brushy Basin contact atthis _ location. Options could include geophysical loggi-ng, or possibly drilling aconfirmatory boring. DRC suggested considering gurnrnuio look atihe contact throughthe casing, or to consider the feasibility of using etU or neutron-density logging. ruSAagreed to discuss this with our technical consultants, and then ask fo. a rneeting withDRC to discuss this well.
(3)
3.3
itemsfrom the February 7, 2000 DRC RFI remain unresolved,including:
- several requested
I. Missing IUC Reports - several existing consultants reports have yet to be
(l) Reports Availsble to Titan Environmental - as listed in Table 2.2 and the
Refere-nces section of the July, Igg4 Titan Environmental Report,including:
(l) February, lgBI D'Appolonia consulting Engineers, ,,Assessment
of the laatur supply system, wite Mesa project, Blanding, (Jtah"
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Mr. William J. Sinclair
May ll,200l
Page l0 of2l
(2) July, l99I Hydro-Engineering, "Ground-lllater Hydrolog,t at the
l(hite Mesa Tailings Facility"(3) June, 1994 Peel Environmental Services, "Groundwater Study,
White Mesa Facility"
COMPLETED
Searches were performed as described under l.l. above. rusA located 1994
Umetco, 1993 Peel, and 1991 HydroEngineering Reports. ruSA has not located
the l98l D'Appolonia report, and regrets to report that it believes it may not be
possible to locate that particular report. However, as noted under 3.1.(3) below,
ruSA did locate three additional reports prepared by D'Appolonia, dated
September 9, September 28, and November 30, 1981. These are being copied and
will be included in the June transmittal to DRC.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETING
DRC would like the above reports. ruSA transmits herewith the l994lJmetco,
1993 Peel, and l99l HydroEngineering Reports.
(2) Reportk) Prepared Ior NRC / EPA - including reports to document
drilling and hydrogeologic investigations related to existing wells Mll-20
thru 22 and geotechnical borings GH-l thru GH-4 (see discussion above).
COMPLETED
Searches were performed as described under l.l. above. ruSA located, during the
search of the Mill records, some working files and field notes or data.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
These additional wells and borings were installed as part of the investigation
performed by Umetco during the time that the Mill was being considered as a
candidate site for disposal of the Monticello tailings. As we discussed, after the
decision was made by DOE not to relocate the Monticello tailings to the Mill, the
work on these investigations abruptly ceased. No final reports were prepared, and
ruSA received no final reports from umetco during Mr. Roberts' check of
Umetco files. Howeveq IUSA located, during the search of the Mill records, some
working files and field notes or data, which ruSA is currently organizing and
copying, to be transmitted to DRC in the June package.
Any Other - report related to groundwater hydrologt or geologt of the
COMPLETED
Searches were performed as described under 1.1. above. IUSA located three
additional reports prepared by D'Appolonia, dated September 9, September 28,
(3)
site.
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Mr. William J. Sinclair
May ll,200l
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and November 30, 1981. These are being copied and will be included in the Junetransmittal to DRC.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETING
ruSA is to report to DRC the results of these searches to DRC. ruSA reports
above regarding having located the three additional D'Appolonia reports. ruse
has identified no other reports at this time related to groundwater irydrology or
geology of the site.
2.Dames and Moore Borings 3 and 9 [p. 4. Item 3.A.2J - please provide reliableflrvey coordinates/or these two borings at thefacility.
COMPLETED
IUSA is attempting to determine the approximate locations of these borings fromhistorical maps. This information will then be used to approximate the locations on a
map.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
DRC agreed that it is acceptable to approximate locations. ruSA will designate those
coordinates for which locations have been approximated.
3. Test Well 17 (East qf Mill Site,t [p. 4. Item 3.8.]J -we recognize that IUC believes
this former test well has been plugged and abandoned. However, please provide
thefollowing informationfor thiswell: date ofwell installation, grologrt iog, well
completion diagram, reliable sarvey coordinates, and ; pligging and
abandonment report.
COMPLETED
Mr. Roberts assisted ruSA in reevaluating information on deep wells. Searches wereperformed as described under l.l. above. ruSA located, duringthe search of the Mill
records, logs for the deep wells and completion descriptions. This information is being
organized and copied, and will be transmitted to DRC in the June package. In additionlMr. Roberts has developed a deep well summary memorandum deicribing the test well
and other deep wells, which includes a drill date @ebruary 23, lg77) for-the test well.Mr' Roberts is continuing to investigate whether or not the "test well" was plugged. The
results of this evaluation, together with Mr. Roberts' report on the deep wJlls, will be
included in the June transmittal package to DRC.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
DRC had requested completion diagrams. ruSA reported that construction details are onthe driller's report, and asked if these would suffice. DRC indicated that if no other
records exist, then the construction details would be acceptable.
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Mr. William J. Sinctan (D
May 11,2001
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4. _ apporently lUC wasunsuccessful in lts attempts to locate the requested informatioif* dry welts MW-
16, MW9-I,IVIW9'2, MWl0-1, andMllrl0-2. However, additional iiformation isrequired, asfollows:
(I) Well MW-16 - DRC stafffound a well completion diagram and geologic
log for this well in the February, 1993 peel Enviionmental -servies
Report (Appendix A).
(2) wells MW-16. MW9-t. MW9-2. MWI0-L. and MW.IT-2 - please explainwhat efforts -were completed to locate the requirea wiU compietiondiagrams and geologic logs for these four @ dry'wells. In the evint thatnew efforts find this information, please provide it at your earliest
convenience.
COMPLETED
Searches were performed as described under 1.1. above. IUSA located, during thesearch of the Mill records, logs for the deep wells and completion descriptlons.ruSA has also located packer tests for MWl6-19, and well logs. The packer testresults for MW 16-19 and the 1993 Peel report are being reviJwed by'IUSA andHGC, for inclusion in a new data table of hydrogeologic pur"..t.rr. Theinformation used to prepare the data table will be tra-nsmitled, together with thetable, to DRC in the June package.
lJ - please explain whatefforts were made by IUC to locate the riquested information for thise two (2)borings. Should new efforts locate this data, pleaie rubmit il at your earliest
convenience.
COMPLETED
ruSA has reviewed the Work Plan in Appendix F of the 1994 Umetco report. As detailedin response to item l. L above, having completed the searches described ln r. f . durint theweek of April 30-May 4, IvIr. Roberts concluded that records transfer informaltionprovided to him at the time of closure of IUSA's Grand Junction office appears to becorrect; that i_s,_.records regarding the Mill were transferred to the Mill, while recordsregarding the Mines were transferred to the Dove Creek office, and those were later senton to the Fredonia office. Mr. Roberts believed this to be evident by the fact that rawdata from the 1994 drilling campaign were found in Mill archives he searched; therefore,he has reported that he believes it would be fruitless to search for the same records inFredonia- As a result, the expanded search he performed of the Mill locations is the finalsearch ofrecords.
As a result of these searches, ruSA has also located constant head pressure tests fortheseborings. Geologic logs have been located. As stated in response to i.:. above, a video log
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5.
Mr. William J. Sinclair
May I l, 2001
Page l3 of2l
that appears to relate to at least tw9 of the borings has been located, and is beingreviewed by IUSA. A copy of the video log will bJincluded in the June transmittat tiDRC.
ruSA is organizing and sorting these data, and will submit the results in the June datatransmittal as shown on the proposed accelerated schedule.
SCOPE OF RESPONSE, BASED ON DRC/TUSA APRIL 25 MEETINGAs stated above, these additional wells and borings were installed as part of theinvestigation performed by Umetco during the time that the Mill was being considered asa candidate site for disposal of the Monticello tailings. As we discu-ssed, after thedecision was made by DOE not to relocate the Montic.Ilo t"ilirgs to the Mill, the workon these investigations abruptly ceased. No final reports were prepared, and IUSAreceived no final reports from Umetco during Mr. Roberts' cheik
-of
Umetco files.Howeveq ruSA located, during the search of the Mill records, some working files andfield notes or data, which ruSA is currently organizing and copying, to be transmitted toDRC in the June package.
L _we
aclcnowledge submittal of two (2) IUC maps of tnrT*@
I. August 28, 2000 LANDESIGN Site Control Map - prepared by L4NDESIGN
Engineers, Surveyors and Planners of Grand Junctiin, Coloraio, Sheet I of l,Rev. I (submiltgd as a part of the September 8, 2000 illC Revised GfR). fniidrawing included a dota table of survey coordinates, and a simple relativeposition plotfor many o/ the requestedfacilities at the White Mesa siti.
2. IUC Topographic-Map - provided to the DRC by Mr. Ron Hochstein of IUC onJune 13, 2000. This detailed topographic map, prepdred by an anknown party,provides location details for many of the site faiilities, inciuding but not timited
to: footprint of tailings ponds, tailings pond berms, site roads, iiil ,itr, mill siteproduct and process storage tanlcs, ore storage pad, wildlife ponds, topsoil
storage pads, mill process buildings, administration building, iurient truck scalebuilding, and mill site process wastewater pond ("Roberts P"ond"). This map wasreyortedly prepared ot I:3,600 scale (1" 300 n, cts derived .fromphotogrammetry data collectedfor the site in February, tggg.
Review of these two (2) IUC maps shows that much of the information requested in theFebruary 7, 2000 DRC RFI has been provided on one mqp or the oiher, with theexception of thefollowing items and concerns:
3.
reference and to facilitate
sections and other maps it
A - "forpreparation of future DRC hydrogeologic
is essential for all the required elements
ase of
cross-
to be
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Mr. William J. Sinclair
May 1 1,2001
Page 14 of?l
presented on a single map. For this reason, DRC staff request that IUC combine
the above site control and topographic maps into a single map. Please ensure
that the accessible discharge related facilities are showi on tie combined map,
but not limited to [p.5, Item 4.A.1 thru 5, and 4.8.2J: tailings pordr,tailings pond berms, existing groundwater monitoring wells,-former ieits ana
piezometers, water supply wells, exploratory borings, dry wells and piezometers,
and the chloroform investigation temporary wells.
COMPLETED
ruSA attempted to combine the above noted maps. IUSA is investigating the best meansof resolving survey issues. ruSA will then develop maps and cross-sections.
SCOPE OF RESPONSE, BASED ON DRC/TUSA APRIL 25 MEETINGAs discussed with DRC, the existing forms of the maps noted above do not line upexactly. ruSA has begun considering options, and Mr. Roberts has met with thlsurveyors. ruSA offered to submit, as an interim response, the current form of combinedmap' ruSA noted that this map would not show exact locations of surveyed points
relative to the contour locations, and DRC finds this acceptable as an interim response.
DRC clarified that its interest is in knowing where wells arC located relative to features ofthe site, such as ponds or stockpiles. DRC needs X, y, and z coordinates for the wells.ruSA will transmit, in the June package, a draft map combining the two above-noted
maps, noting that the locations are approximate relative to the contours. IUSA will
continue in its efforts to resolve survey issues, and will, upon resolution of such issues,then prepare updated cross sections and other maps, including perched zone wateielevation contour maps and water surface elevation contour.rpr. These contour mapswill be periodically updated by IUSA and provided to DRC
4. Nearbt Stoch,vatering Wells [p.6. Item 4.A.6J - nearby stockwatering wells
constitute potential points of exposare for the facility. Please providi survey
coordinates, including ground surface elevationsfor both the Jet Pump and Jonis
stoc lcw at e ring w e I I s I oc at e d ne ar t he fac i I i ty.
COMPLETED
ruSA is attempting to determine the approximate locations of these stockwatering wells.This information will then be used to approximate the locations on a map.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
DRC agreed that it is acceptable to approximate locations. ruSA will designate those
coordinates for which locations have been approximated.
5. Nearby Contqcl Seeps and Springs [p. ] 3. Item I3J - nearby seeps and springs atthe edge of White Mesa also form potential points of exposuri for thi Taitity.Please provide Mrvey coordinates and ground surface elivationi for al[ contict
seeps and springs near the facility.
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Mr. William J. Sinclan O
May I l, 2001
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COMPLETED
In the September 8, 2000 GIRRP submittal to DRC, ruSA submitted aerial photos, asDEQ agreed would be acceptable. As reported in the GIRRP, ruSA could not, however,provide detailed land survey locations for all contact seeps and springs, because suchfeatures vary depending on a number of hydrogeologic conditions. ruje submitted acurrent map showing water surface elevations for the perched groundwater zone. Thewater surface elevations in the perched groundwater zone generally decrease near themargins of the canyons, where the perched groundwater zone thins and is discharged.ruSA transmitted in Attachment 10 of the GIRRP an aerial photograph shoiingvegetative patterns indicative of seepage along the nearest canyon margins, which, baselon our meeting of April 'l,2OOO, we understood to be sufficieni for the fr.r.nt purposes.
SCOPE OF RESPONSE, BASED ON DRC/IUSA MEETING OF APRIL 25,2OOIIn addition to the foregoing response, DRC requested that ruSA now also attempt todevelop survey coordinates for those seeps which appear to have been developed in thepast. Evidence of development would be the presence of pipes (flowing or noi; or stocktanks. ruSA will conduct field reconnaissance to "tt.rpt to define locations of suchfeatures and will ul.-o, as DRC suggests, evaluate rnlunr of approximating, withreasonable accuracy, the x, y, and z coordinates for such features. Iiind-held GFS mayprovide sufficient resolution, or historic maps may be used to approximate locations andelevations of these features. ruSA will investigate methods of mapping those well-
defined features, and will discuss its findings wittr Onq.
after comparison of !, site plan map from thi ocabe, l3ooo "nto*|or*investigotion report (Figure I l) with the IUC topographic map provided on-June13, 2000, we have estimated the survey coordirntis o7 tn, t"pil" tank drainfieldlocated a short distance Southwest of the existing -truck
scale house. please
confirm the accuracy and content of the DRC estimated survey coordinates /orthis leachfield, as provided in Table I, below:
Table DRC 1. Estimated Survey Coordinates: Fr lUC Truck Scale House Leachfield: laoruner
Corner Easting (feet)Northing (feet)
Northwest 2,580,7i5 322,330
Northeast 2,590,900 322,330
Southeast 2,590,900 322,260
Southwest 2,590,735 322,260
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Mr. William r. Sinclair O
May ll,200l
Page 16 of2l
COMPLETED
ruSA is evaluating the above coordinates. The searches defined above under l.l. yieldedengineering drawings which depict the design location of the historic scaiehouseleachfield. ruSA will use the drawings to estimate the coordinates of this particular
leachfield.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETINGruSA noted that it would like to prepare more complete maps that could include theabove feature, after the survey results are reviewea. ruSe noies that the review of thesurvey data may alter IUSA's interpretation of the above results.
ruSA was requested by DRC to include this feature on maps that would be provided toDRC.
sqb*ittol-ol su*ry coordirot"t lo, R rotud Forilititt [r* itu*J - ofter reviewof t-he IUC information provided to date, DRC staff have cletermined thatadditional related facilities at the site need to be lociied on the combined site
_ once located
southeast of the main ofice building.
7.
plan and topographic map, including but not limited to:
Q)
(2)
(3)
Building Septic Tank Drainfield - reportedly
located a short distance North-Northwest of the truck siale house.
- including
the location of the above ground tank that was once tocatei on the Norlhside of the mill administration building and the pipe thot drained it to themill site wastewater catch pond (,,Roberts pond).
(4) Former Mill Site Sedimentation Pond - also known as the fly-ash pond(6/79 D'Appolonia Design Report, Sheet a of 16).
(5) Former Solid Waste Landfill - located neor one of the wildlife ponds Eastof the mill site.
Please enflire that the ffirvey coordinates for all of the related facilities outlined aboveare accurately plotted on the combined map also riquested.
COMPLETED
The searches defined above under 1.1. yielded engineering drawings which depict thedesign locations of these features. To the extent poisible, ruSA will use the drawings toestimate the coordinates of these features.
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Mr. William J. Sinclan O
May I 1,2001
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SCOPE OF RESPONSE, BASED ON DRC/ruSA MEETING OF APRIL 25,2OOIIUSA noted that it would like to prepare more complete maps that could include theabove features,_ after the survey results are reviewed. Other torrections to the survey
database should be performed first. Then, these maps would be provided to DRC.
5.- we appreciate
the description of the number of wells and the mognituie o7 herd i*r"at" seen in wellsat the facility (9/8/00 IUC Revised GIR, p. 26). However, as outlined in the March 13,D!! Request for Confirmation (RFC) letter, DRC staff will complete the "ftnol water
table contour and isopach thiclcness mapsfor the shaliow aquifer (j/13/01bRC btter,pp. 4'5). This leqves two remaining items from the February 7, 2000 DRC RFI that
continue to be unresolved, as outlined below:
I4.cJ -we hqve reviewed your september 8, 2000 response ordyorrd ttToit"d n
address the need to identifu the root caase for the lncreasing head trend. As
exPlained previously it is likely that the rising groundwater levels observed islikely due to some artificial source of groundwater recharge. Consequently, sucha study will require the installation of additional wells and/or piizomiters in
order to identrfy the source of the man-made recharge. In order n facilitate thise{ort, DRC staff have prepared several figures
-to guide your-planning, as
described below:
(1) DRC correcte-d weU Hldrographs - hove been prepared for existing
monitoring wells at the facility, based on corrected groundwater elevation
data provided you in the March 13, 2001 DRC RFC lefier, see AttachmentI, below. These hydrographs establish that the wells with the greatest
increases in groundwater head include (in decreasing order): M'fir:4, MW-
19, Mlry-|\, andMW-I I.
COMPLETED
IUSA has, in the Chloroform Investigation, provided (based on discussions with
DRC) qualitative data as to potential sources of increasing water levels observed
on the eastern portion of the Mill property. However, we understand DRC,s
request that IUSA further investigate the increasing water levels in certain wells.
We are currently reviewing this issue to determine the best way to answer DRC,squestions. We will submit a final response to these questions in our June 22,2001 submittal.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETINGAt the April 7,2000 meeting, DRC indicated that the objective of evaluatingwater level increases would be to provide contour maps uring local water level
data to show how the perched groundwater zone has beliaved over time.
l.
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Mr. William l. Sinclair O
May 11, 2001
Page 18 of2l
As IUSA and DRC discussed, ruSA will take responsibility for preparing watertable contour and saturated thickness maps for the perchid groundwatlr b.irgmonitored at the Mill. As we discussed, ruSA is iesponsible for maintainin!water levels and water quality data in databases for a number of regulator!purposes. To optimize management of these data, ruSA will need to coniinue to
generate these databases, but will be happy to provide DRC with electronic copiesas the databases are updated. In addition, IUSA will task indepenient
hydrologists to assist us in preparation of contour maps, using the correct
interpretive tools based upon the distribution of the data at th; site. IUSA
requested assistance from our independent hydrologists, HGC, in reviewing thecontour maps prepared by DRC. A technical memorandum was prep".ed byHGC regarding this review, which identifies concerns and limitations wit'h r.rp..tto use of computer-aided plotting packages when data are unevenly distribuied.HGC's memorandum is transmitted herewith. ruSA will make cautious use of
such packages, and will produce hand-contoured maps when the data distribution
indicate this to be a more appropriate method.
(2) DRC Water Table Equipotential Map: September. 2000 - this water table
contour map preparedfrom IUC water level dota collected in September,2000 includes groundwater head data from most of the- existing
monitoring wells at the site, plus all the chloroform investigation wellsrecently installed. Review o/ this DRC map ruggests that the artificial
groundwater recharge source is located North and East of wells tutw-l
and MW-19, see Attachment 2, below.
COMPLETED
Please see responses to item 5. l.(l) above.
(3) DRC Delta Head Contour Map - the magnitude of increased head in eachIUC well was calculated by DRC staff after review of the hydrograph
trends seen in Attachment l. DRC staff took selected heads yrim inespring of 1983 as representative of boseline conditions il th; facility.From this, increases in head were calculatedfor each well thru Summir,2000. These head increases @elta Head values) were then tabulated ond
contoured on a map; see Attachment 3, below. This map suggests thot theartificial source of groundwater recharge is located i"rt-it tntw-4 andMIII-19.
Please provide a plan and schedule for the installation of addifional monitoringwells and/or piezometers to locate the source of the artificial groundwati
recharge apparent North and East ofwelts MW-4 andMW-19.
COMPLETED
Please see response to item 5.1.(l) above.
s:\MRR\groundwater-discharge-permit\March2OOlnpn\respto3200ldeqlet05l l0 r.doc
Mr. William J. Sinclair O
May ll,200l
Page 19 of2l
Additional Groundwater Qualiy, Data [p. t5. Item I4.DJ - we aclcnowledge thatyour chloro/orm investigation report will address groundwater quality isies ondt|re potential for other contaminants as indicators o7 chloioform discharge
(10/4/00 IUC Chloroform Report). P[/e have also received your September 15,2000 Groundwater Background water euariry Report. rhis issue'and both of
these reports will be reviewed at a later date.
Ite-m I I.BJ 'the September 8, 2000 illC response refeted ti y*rTatui to li""te copiesof original lqboratory permeability data. In contrqst, our originol February Z, i1OOrequest was for copies of notes, calculations, and data for th;rteW prr*ribility testsconducted on monitoring wells, borings, and piezometers at thi faciiity. To reiterate,please provide the following :
I. Field notes and data collectedfrom eachfield permeability test, and
2. Detailed description and justification of calculations and analysis methods usedto determine permeability. In the event that test datafrom certain wells was re-
analyzed, please explain why re-analysis was required.
After submittal and review of this information, DRC staffwill prepare a summary table ofall available permeability data and askfor I(JC concurrence.
In the event that the information requested above cannot be provided, please submit aplan and schedlle for field permeability testing of oll tirtlo* aqurfer wells andpiezometer s at the facility.
COMPLETED
Searches were performed as described under l.l. above. In addition, HGC is compiling
some of its field notes and a discussion of analytical techniques for the tests conducted atMW-4 and MW-19. ruSA and its consultant will compill, review, and table any dataIocated. Updated tables and associated data (when available) will be provided to DRC.Based on this complete review of available hydraulic data, IUSA will evaluate anypotential need to conduct selected pump tests on wells for which adequate data are notavailable.
The drilling and logging data indicate that the physical characteristics of the rocks
beneath the Mill vary considerably both vertically and laterally. Therefore, in June of2000, ruSA discussed with DRC the appropriateness of attempting to use the limited dataavailable to create a "contour" map based on specific data for specific bore holes. Thefeasibility of such an approach may be limited in view of ine fact that hydraulicproperties of this stratum, which have been determined from 12 singli well-pumping/recovery tests and from 30 packer tests yielded a broad range oihydraulic
s:\MRR\groundwater-discharge-permit\March200lrspn\respto3200ldeqlet05 t l0l.doc
2.
6.
Mr. William J. Sinclair
May 1 1,2001
Page20 of2l
properties, which will not reasonably lend themselves to a defensible contouring
approach. Furthermore, the depositional history and composition of the Burro CanyonFormation is such that_one would expect random variability rather than mapable contoursfrom one point to another.
In response, DRC indicated that, in some situations, it is possible to convert permeability
test results to log values and create contour maps of the iog values. pnC indicated thatthey would want to see the field notes first. DRC stated an interest in first reviewing the
data and field notes, lhen determining how best to present the results. DRC suggistedthat IUSA submit a phased approach encompassing these two elements, in the GIRRp.ruSA discussed this issue further with DRC on August 14, and agreed to create a mapshowing the point-specific permeability values as part of the GCiReport. This ,"port
was transmitted under separate cover, and as per the Chloroform Investigation schedule.
See Figure 2, Permeability of Perched Groundwat er Zone in cm/s, in fnvestigation offll^--^r^l nl-l- ,- n ^whi
Uranium Mill near Blanding. Utah (rusA and HGC, october 4, zooo).
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
YSA will compile data requested by DRC, will review such data, and will table the data in aformat compatible with DRC's draft tables and spreadsheets that DRC provided to IUSA. Toensure integrity of the database used by ruSA for the Mill's regulatory purposes, and topreserve DRC's position of the reviewer of Mill technical submittals made to OnC, IUSA willthen maintain such tables and spreadsheets for use in preparing technical submittals for DRCincluding data plots, contour maps, etc., and will providl fjnC *itf, copies of these same tables
and spreadsheets.
ruSA is committed to bringing the GWDP approval process to completion as soon as possible.With the added help of Mr. Roberts, who has the most complete historical knowledge of Millactivities, ruSA believes it has made considerable progriss since our last submission incollecting the additional information being requested byDRC. In addition, in order to make upfor some delays in accumulating the historical informition, we have already initiated work onother GWDP tasks that were initially to run in series following completion of Cm.np comments,but which now, in the accelerated schedule, are being ,unug"d conclrrently.
If you have any questions or comments regarding this letteq please contact me at (303) 3g9-4130.
slMRR\groundwater-dischargelrermit\March20olrspnvespto3200ldeqlet05l l0l.doc
Mr. William J. Sinclan
'May I1,2001
Page2l of2l
Enclosures
cclatt: LarryMize, UDEQ Division of Water euality
Loren Morton, TIDEQ Division of Radiation Control
Bill von Till, NRC
Michelle R. Rehmann
Harold R. Roberts
cc dout att: Dianne Nielson, UDEQ
Dave Arrioti, S.E. Utah Health Department
s:\MRR\groundwater-dischargepermit\MarcM00lrspn\respto3200ldeqletO5l l0l.doc
MEMORANDAM
To: Michelle Rehmann,IntemationalUraniumCorporation
From: Stewart Smith, Hydro Geo Chem,Inc.
Date: Apr1l24,2001
Re: Computer Gridding and Contouring of Water Levels,IUC White Mesa Mill Site
Computer gridding and contouring packages allow rapid production of contour
maps for various types of spatially distributed data such as, for example, land surface
elevation, hydraulic head, and dissolved chemical constituents. Packages such as
SURFERTM are very convenient to use, especially when the raw data exist in the form of
computer spreadsheets or other computer data files that are compatible with the software
input requirements. The ease of use makes it tempting to produce computer-contoured
maps and to rely on them for interpretation while in many cases ignoring the inherent
limitations of the resulting product. In cases where data is very unevenly or sparsely
distributed, or both, hand-contouring of hydrogeologic data by an experienced
hydrogeologist may be superior to computer contouring.
Nearly all of the available computer-contouring packages require two steps: 1) a
gridding step in which a uniform grid is superimposed on the area of interest, ffid
numerical values of the desired parameter (water level, etc.) are estimated at each grid
node based on the comparatively random, relatively unevenly distributed raw data and
using an algorithm such as inverse distance, kriging, etc.; and 2) a contouring step which
draws lines of constant parameter value through the gridded values. Two important
factors to consider when generating computer contour maps are 1) the adequacy (spatial
coverage and density) of the raw data used as input, artd 2) the appropriateness of the
gridding algorithm and associated user specified input parameters for the particular raw
data set to be contoured.
Because computer gridding and contouring rely entirely on data provided and
cannot supply any guidance based on geologic or hydrogeologic principles, or on
consistent historical trends or pattems supported by more extensive past data, the
resulting product may not be reasonable even though it satisfies mathematically the
requirements of the gridding and contouring algorithms based on the user's input. The
problems can become worse the more non-uniform the distribution of data becomes.
The choice of gridding algorithm will also strongly affect the resulting contour
pattern, especially in areas where there is no data. Both kriging and minimum curvature
algorithms, for example, will project trends from areas of denser data coverage into areas
of sparser, or no-data coverage. Inverse distance, for example, has less tendency to do
this, and minimum curvature generally has the greatest tendency. Paradoxically,
although minimum curvature is the best mathematically for gridding water levels
(because it satisfies the requirements for potential fields such as hydraulic head), it can be
S :\MRR\groundwater_dischargejermit\March200 I rspn\ssmithMemo I 0 I 0.doc
the most inaccurate when data distribution is non-uniform. Furthermore, all gridding
algorithms are affected by the grid spacing, raw-data search parameters, and other user-
specified factors. Using the same data set as input, contour maps that look quite different
can be developed by using different gridding algorithms or by varying input parameters
for a particular algorithm, such as grid spacing and data search specifications. Kriging is
the most sophisticated algorithm overall, but to take fuIl advantage of its capabilities
requires a geostatistical analysis of the input data to determine whether a linear, spherical,
or other model is most appropriate, and what type of data search is most appropriate for
the particular data set. The linear model default in SUMERTM is typically chosen when
no other information is available.
Examples of some of the potential problems that may result are illustrated by the
September 2000 gridded and contoured water level maps provided in Attachment 2 of the
March 20,2001letter from UDEQ to IUC.
The September 2001 gridded and contoured water level map shows a strong
southwest direction in the water level gradient in both the northwest and southeast
portions of the map area even though there are no data points in these areas. Because of
this, there is a change in gradient direction from southerly to southwesterly in the eastem
portion of the site south of MW-4. This is an artifact of the gridding algorithm and the
lack of data points in the southeast portion of the site. When data from MW-22,located
in the southeast portion of the site, has been included in contour maps in the past, for
example, Figures 38 and 3C of IUC/HGC, 2000r, a southerly gradient throughout the
entire eastern portion of the site is supported. When data from this well is not included,
leaving only data points that are within the portion of the site that has always exhibited a
southwesterly gradient, the southwesterly trend will be more or less projected (depending
on the gridding algorithm used) into areas where no data exist, such as into the northwest
and southeast portions of the September 2000 map. The fact that the contour pattern can
be so strongly affected by the inclusion or exclusion of one data point illustrates the
potential hazards of accepting a computer interpretation without an accompanying
hydrogeologic appraisal. Furthermore, a southerly gradient in the eastern portion of the
site is supported by water levels measured at temporary wells, even though not all these
water levels have yet stabilized. The "bulls eye" centered on MW-19 is also an artifact of
data distribution and the gridding and contouring algorithms.
Because of the potential problems associated with computer contouring, it is
appropriate to look at consistent historical trends and patterns that are evident when more
and better distributed data were available when contouring data collected at times when
the data are less uniform or complete (for example, when no data is available for MW-
22). Computer gridding and contouring can only be relied upon when adequate data
distribution is available as input. At times when the data distribution is inadequate, it is
necessary to use hydrogeologic expertise and judgment to recognize false trends or
pattems generated by computer contouring, or to hand-contour the data taking into
account these consistent past trends and patterns.
I International Uranium Corporation and Hydro Geo Chem, Inc. 2000. Investigation of Elevated
Chloroform Concentrations in Perched Groundwater at the White Mesa Uranium Mill near Blanding, Utah.
S :\M RR\groundwater_dischargejermit\March200 I rspn\ssmithMemo I 0 I 0.doc
o
ITH
EDUCATION:
P,s (Geosciences), university of Arizona, Tucson, Arizona, 19g0.M.s. (Hydrology), University of Arizona, Tucson, Arizona, i9g9.
EXPERIENCE:
Hydro Geo Chem.Inc.
Mr. Smithjoined Hydro Geo Chem in 1989 as a Hydrogeologist. His responsibilities includemanagement of site charucterization and remediation aitivit]es, d-esign of soil and groundwaterremediation systems, collection and interpretation of chemicai and iydrog"otogi. -clata, use ofnumerical models for remedial design and as predictive and interpretive tooTs,-anl preparation oiinterpretive reports.
Proj ect involvement includes :
' Design of deep soilvapor extraction (SVE) systems for protection of groundwater beneaththree Tucson landfills. Systems were configured to maximize removaiof deep vados " roi"volatile orga$9 compounds (VOC) that have acted as a source to groundwater whileminimizing air intrusion into the overlying landfill. The design pro."rrlr4uded the use ofthree-dimensional numerical gas flow and transport models that utilized estimates of soilproperties derived from field air permeability teits.
Development of a three-dimensional numerical model of groundwater flow through afanglomerate drinking^water aquifer located in central Arizoia. The modeling was part ofan ongoing remedial effort at an Airzona mine site. The model has been used io prediict thehydraulic interaction between the_fanglomerate and an overlying alluvial aquifer underpresent conditions and under conditions of anticipated remedial f,umping of-ttre alluvialaquifer.
Management of an SVE_design study at a U.S. Environmental Protection Agency Superfirndsite located near Gary, Indiana. Work included performance of a pilot tJst, design of anSVE remedial system fol the site using numerical models, and preparation ora'aesigi report.The effects of biodegradation resulting from SVE operatio, *"r. included in the evaluation.The system is currently operating within design parameters.
Numerical modeling of unsaturated flow and transport within mine tailings impoundmentsat acopper mine in Atizona and a Trona mine in Wyoming. Three-dimeisional numericalmodels have been used_to: 1) predict the impact of past anicurrent wet tailings disposal onregional groundwater, 2) assess remedial opions, 3) direct further data collecion activities,and 4) provide data for slope-stability studies.
RESUME OF STEWART J. SM
Development of a three-dimensional numerical flow
effectiveness of various remedial pumping strategies
Arizona.
and transport model to predict the
on acid mine drainage at a site in
Page I of 4 5/10t01
Hydrogeologic assessment of a mountainous terrane for an Indian tribe in Nevada. Workincluded estimation of sustainable water supply and water quality, and recommendation ofareas most favorable for water development.
Analysis of multi-depth. soil gas data collected at a municipal landfill in Tucson, Arizona.Work included supervision of field activities and development of numerical flow andtransport models that incorporate groundwater and soil gas data as an aid to understandingpast history and current and potential future impacts of VOCs on groundwater.
Supervision of an SVE /air sparging pilot test at the site of a gasoline release in phoenix,
Arizona. Work included preparation of site-specific work pl;s, quality urr**"" projeciplans, health and safety plans, and analysis a.,d interpretation ofhita datu using numericalmodels.
IVlanagement of a remedial investigation at a U.S. Environmental protection AgencyNon-Time Critical.Emergency Response site located in Fort Wayne, Indiana. Work hasincludedinvestigation of on- and off-site subsurface VOC contarnination and preliminarydesign of a soil and groundwater remedial system.
Supervision of the design olal lVE system to remediate a VOC-contaminated Superfundsite located in Kalamazoo, Michigan. Work included preliminary system desigir usingnumerical models.
Assessment of the longterm impact of vadose zone VOCs on groundwater at a site locatedwithin the North Indian Bend Wash Superfund site. Work inclJded use of numerical modelsand preparation of an interpretive report.
Supervision of the design and installation of an SVE/Enhanced Bioremediation System forclean-up of a fuel oil spill in Phoenix, Arizona. Work included predictive numericalmodeling of vapor extraction and biodegradation efficiency for the purpor" lf pilot testdesign, performance of a pilot test, interpretation of pilot tlst results, *a p."p*ution ofinterpretive reports.
Supervision of an investigation of subsurface contamination by organic compounds at aSuperfund site in the Livermore Valley, Califomia. Duties included if*"i"g "ild directionof soil gas, soils, and groundwater work.
Supervision of the investigation and remediation of tetrachloroethylene soil contaminationat a site located within the San Gabriel Basin Superfund site, souihern California. Dutiesincluded planning and direction of field activities, design of remedial alternatives, andpreparation of interpretive reports.
Biostimulation soil rlelting pilot tests. Duties included preparation of site-specific workplans, supervision of field. operations, performance of venting efficiency *a i*""r tests,interpretation of results using numerical models, and preparati-on of interpr"iir" r"portr.
SVE pre-design investigations. Duties included supervision of soil gas sampling and soil airpermeability tests, and interpretation of results using numerical models.
Page2 of 4 5/10/01
' Environmental audits. Duties included research and investigation into all aspects of past and
present property use which may have an impact on potential site contamination and ownerliability, as well as investigation into the possibility of contamination from off-site sources.
Preparation of interpretive reports based on the results of research and on-site investigations.
' Acid mine water contamination study. Duties included sampling and on-site analysis of
groundwater to delineate the extent and type of contamination, supervision of moniior andproduction well installation, performance and interpretation of aquifer tests, and preparation
of interpretive reports.
Prior Experience
Geologist/Geologic Engineer forNewmont Exploration Ltd., Tucson, Aizona,l984 to 1989. Major
duties included:
' Analysis of the hydrogeology of the area surrounding a developing mine site in Nevadathrough interpretation of geologic maps. Recommendation of areas favorable for
development of production wells to serve mining operations.
' InterPretation of geophysical data with respect to lithology and structure. Co-author of
in-house repgrt relating major gold districts to basin and range structure (as defined by
regional gravity and aeromagnetic data). Development of a statfutical model io quantiff thl
spatial as sociati on of minerali zation to aeromagnetic features.
r Geostatistical ore deposit modeling. Transformation of drill-hole data into complete
engineering models used for mine design and planning, corporate financial planning, andpublished corporate ore reserve statements. Process required detailed analysis oi tfr.
geologic environment, as well as in-depth study of the statisiics and geostatistics of elementdistribution within an ore deposit, to ensure accurate estimation by kriging or
inverse-distance techniques.
' Field acquisition, transcription, reduction, and presentation of data. Use of existing softwareto load, edit, grid, contour, and image process data on Burroughs mainframe, IBM pC, andCOMPAC portables.
' Development of computer software to improve data processing procedures and design ofroutines to process new types ofdata sets.
' Research and field examination of areas with potential for bulk-minable gold mineralization.
Using satellite .imagery, located prospects with potential significant enough to warrant
property acquisition.
\Iingral Exploration Geologist for AMAX Exploration,Inc., and St. Joe American Corporation (now
Bond Gold), 1980 to 1984. Responsibilities included research and field evaluation ofproperties withpotential for bulk-minable gold, silver, tin, tungsten, and molybdenum mineralization;preparation
of geologic reports and recommendations; supervision of drilling operations; and collection andanalysis of geophysical data.
Page 3 of 4 5/10t01
PROFESSIONAL AFFILIATIONS :
Member, National Groundwater Association
AWARDS/IIONORS:
Member, Phi Kappa Phi (Honorary Society).
SHORT COURSES:
General Physics Corporation Short Course, "Bioremediation Engineering" November 1992.
Air and Waste Management Association Seminar, "Bioventing and Vapor Extraction: Uses and
Application in Remediation Operations", April 1992.
OSHA 40-Hr Health and Safety Training for Hazardous Waste Site Activities, September 1989. 8-
Hr Refreshers, December 1991, April 1993, April 1994
PROFESSIONAL PUBLICATIONS :
Bentley, H.W. and S.J. Smith. 1998. Soil Vapor Extraction of Chlorinated VOCs in the Vicinity of
a Landfill Equipped with a Landfill Gas Control System. Presentation at the 1998 Arizona
Hydrological Society Eleventh Annual Symposium. September 23 to 26, 1998. Abstract
with Proceedings.
Bentley, H.W., J. Tang, S.J. Smith, D. Samorano, R.G. Arnold. 1998. Analysis of Remedial Optionsfor Chlorinated VOCs at Harrison Landfill. In: Bioremediation and Phytoremediation,
Chlorinated and Recalcitrant Compounds. The First International Conference on
Remediation of Chlorinated and Recalcitrant Compounds. Monterey, California, May l8
to 21, 1998. pp. 21-26
Ward, J.J. and S.J. Smith. 1998. Arid ZoneLandfills: What Do Investigation and Modeling of
Containment Migration Reveal About Transport Mechanisms? Presentation at the 1998
Arizona Hydrological Society Eleventh Annual Symposium. September 23 to 26,1998.
Abstract with Proceedings.
Smith, q.J.,J. Pepe, and G.R. Walter. 1995. The Effect of Variable Injection Rates on Air Sparging
Patterns in Heterogeneous, Porous Media. Presented at the First Intemational Symposium
on In-Situ Air Sparging for Site Remediation. Las Vegas, Nevada.
Smith, S. and G. Walter. 1993. Numerical Modeling of "Raining" Soil Vapor Extraction Wells for
a Hypothetical Alluvial Aquifer. Presented at Rocky Mountain Ground Water Conference
- Ground Water Technology and Tasks in the 90's, Albuquerque, New Mexico, 1993.
Walter, G.R., R.D. Philip, and S.J. Smith. 1993. ChickenlEgg Arguments in the Establishment of
Soil Cleanup Standards. Presented atHazmacon'93, San Jose, Califomia.
Page 4 of 4 s/t0t01
T-201 P 0l J ob-429
H''"r#*erfinr,
unaNruu (usA)
ConponltoN
Indcpild€nc€ Plus, Suite 950 , 1050 Scvcntecnth Street , D€rv€f,, CO 80265 , 303 628 7?98 (main) , 303 389 4l2s (fDO
FACSIMILE TRANSMITTAL
Williarn Sinolair, Director FAXNo: (801) 531-409'l
IJDEQ Divicion of Radiation Control PHoNENo: [phone]
FRoM: Dovid C. FrYdcnlund DATE: MoY 11,2001
International Uranium Corporation PAGE I oF: 22
IFALLPAGES ARE NOTRECEIVED, PLEASE CALL:Sharon Cq,moll
PHoNENo: [phone]
dran totheposon towhom ttrey are ad&essed as a t
equipment fsiture q trumsn ;*. h,i; Corimruricetion is inte,nded sohly'for rhc ,.U311 Hi .ry"-Tr:ry,yTf:
ot *y ortn teephooro or Fo< nrrEb€rB shorm above ifyou art aot thc addrcsrcc or somcono rcspuuiblc fo'r &livctirrg it to thc addrcscc' wc t
au riglrts md pnvileges as to this co$tfirrrtrication and pmhibit any disserninatiorr, digributiorr or copying by or to aoyone other tharr the Eddre
our itrrce wili anause for its neilrn by 0te united States E
T-e0l P.02 J ob-429IIAY-l 1 -01 I 6:28 F rom r oINtnnNATIoNAL
UnirNlulut (us,t)
Conrr:nATloN
Intlependerree Plazs, Srrite 950 ' 1050 Seventectrth street . Denver. C() 80265 . 30ts 628 7798 (rnain) r 303 380 4195 (ftu)
May 11,2001
Mr. Witliam I. Sinclair
Diroctor, Division of Radiation Control
Utah Department of Environmental Quality
P.O. Box 144850
168 North 1950 West
salt Lake city, uT 84I 14-4850
Reference:March 20, 2001 LJDEQ letter and Request for Additional Site Hydrogeology
fnfoimrtion in responsi to ruSA Seftember 8, 2000 Revised Groundwater
Information RePort
Oroona Wutii bisoharge Permit Application for White Mesa Mill:
Dear Mr. Sinclair:
International uranium (usA) corporation (rusA") appreciated receiving the comments from
the Utalr Department bf gnvironmental Oualitv ('tiDEQ) Division of Radiation Control
("DRC") transmiftcJ iy f*toi Jatcd tvlarch Zo, Zriof , in rosponso to IUSA'o ssheduled submittel
of SeptemUer 8, 2000. Thank you{or meeting with us on April 25 to discuss DRC's comments'
As we discussed at the **tind, rusA has ffiared a rwised, accelerated schedule to respond to
DRC,s March 20 commentr -*hil. atso piepiring a number of the other technical submittals
required for the Groundwater Discharge Permit ("GWDP")'
As shown on the enclosod revised sohedule, ruSA will need until mid-June to complete and
*urit rff responsecrequired to the March 20 responso and request fortdditional information' in
accordance with the #pr ai*".d for each item on April 2j. To help ensure that the planned
;;p. ;a ,* toftnirot submittals is ss DRC requested, we have outlined below our
,rO1,r-arAin!, UasJ on ou, discussion with DRC, of the form of response IU|A should provide
to each item. But in addition to submittal of these responses, IUSA and our- indep-endent
;;gilil; -frvarofosirir,
unO geochemists are simuttaneously grepari.ng.a .number of other
technical sgbmittals] all of wtrictr" as shown on the enclosed accelerated schedule' are projected
for delivery to DRC during the months of July and August.
1-01 16:?9 From:
Mr. William J. Sinclair
May ll,200l
Page 2 of2t
T-20r P.03 J ob-429
l,
We also fiansmit herewith solecied items which were moro readily rvailable and did not require
*rpii"ti** o. org*irriion by IUSA. We have noted transmittal of these iterns in the summary
below.
IUSA will continue to make evQry efron to resolvo technlcal lnformation items as completely as
po.riUt", givorr avaitabiliry of historic informatioq and we lPPreciate.DRC's agreement to
io"pt indrmation *o, frirtoric reports, whcre apprlpriate as hii been discussed in our March
6f;;t"gr, *hen original dete prove to Ue ""sailable. In additionr further searches for
historic infor-mation have-beon succeisful in locating much ofthe information you requested-
For ease of reference, the request language contained in your letter of March 20 (the \quqst.{or
infoimation, or ..Rrri1 is ripe*ed In tfie same order is used in the letter, indicated in itdics
below.
RemalntngOWn Isntes (Febtuary 7. 2ooo DRQ..Ffl)
t rrrrt *rtll Plr* "t ry aiii, boring remain withoat well complelion diryrams ard
geotogic logs, as alredy provided. see discassion below
L SevenWellswdPiemmeters [P. 2. Itgm 2.C.2,1 -we achnwledge that sgven (7)'
rs dre al issue here, including ihree (3) wells'
MW-20 thru MW-22, utdlour (4) piezometers: MW9-1, MW9-2, MlyI0'|, dtul
MWt0-2, We qpreciata tiae new sur.,,ey coordirutes prwidedf_or th-es1 seven (7)
tnstalhtlorc. Iiowever, the September E, 2o0o lllc Refised GIRJatled to prwtde
well complelion diagrmts lor ttrese seven (7) wells ad pignmlers-. Pleaw
provide ihe requiredwelt completion diagrums, ad SegWic losslor fircse seven
'(7) inslaltalions. In the event that this intor'matian llrs been lost, please provifu a
tih"futrlor completian olvideo and geophysical logging to collect the required
inlormation.
COMPLETED
As discussed during our meeting on April 25, ruSA has engaged Harold R.
Robert, P,E., to assist in searohes of IUSA Denver files and Umetco files in Grand
Juncion. Mr. Roberts, a llcensed professlonal englneer, has been lnvolved wlth
the White Mesa Mill since its oonstnrctioq and as srch is an esset in searching for
the records DRC requested. Mr, Roberts also searched Mill a,rchives, officee, and
offrce files. Heving compteted those searches during the week of April 30-Mey 4,
Mr. Roberts concluded that records transfer information provided to him at the
tirnc of olosurc of IUSA's Clrand Junstion offics sppcsrs to bc corrcct; that is,
records regarding the Mill were transferred to the Mill, while reoords regarding
the Mines were transferred to the Dove Creek ofrice, and those were later sent on
to the Fredonia office. Mr. Roberts believed this to be evident by the fact that raw
data from the 1994 drilling campaign were found in Mill archivec he soarchod;
S:\L{RR\grtundurtc-dischargclormit\Mrrch200lrpn\rcipto0200ldeqlet0Sl l0l.doc
IIAY-Il-01 l6:29 From:
Mr. lililliam J. Sinclair
May ll,200l
Page 3 of21
T-201 P.04/22 Job-129
thorefore, he has rpported that he bolieves it would be ftritlesr to search for the
same records in Fredonia. As a re$lt, the expanded search he performed at the
Mill and Umetco's Grand Jundion offrce is the final seerch of records.
As a rczult of thcse searches, IUSA has located constartt hcad presrurc tcsts for
soveral of these MW's and borings. IUSA is organizing and sorting these data,
snd will submit the results in the June data tnnsmittal as shown on the proposed
accelerated schedule. ruSA hgs glso searched Mill archives, ofriceg and offrce
files for:
(l) Well completion diagrems for lvl\il-20, -21, -22Q) Well logs for MW9-1, M1f,I9-2, ld\illGl, and }v{ItrlG.2
During this search, IUSA located working files and field notes from drilling of
wctls MW-zo, -Zl, and -22. In additiorl ruSA bcatcd what appcars to bc a
Table and pages from a report by D'Appolonia which gives data for shsllow
borings 9-1,9-2,1G.1, and l0-2. IUSA is reviewing these data and will transmit
to DRC, in the June data transmittal shown on the proposed accelerated schedule,
the well logs and completion diagrams found in the files of the ta,ble and pages
from the D'Appolonia report.
SCOPE OF RESPONSE, BASED ON DRC/ruSA MEETING OF APRIL 25
2001 (the *APRIL 25 MEETING')
DRC and IUSA noted that video logging rnay be impractical in cased wells.rusA is to considcr diffcrcnt potcntial means of gcophysical logging, if IUSA
does not locate well completion diagrams and well logs for all ottlie aUbve wetls.
rusA noted that a conceptud model of the sitg reported by geologists, existed
prior to the Mill siting, and this conceptual model has been corroborated by Mill
licensing activities. DEQ noted that the Brushy Basin contact is the geologic
feature of interest to DRq and concurred that, inespective of the number of data
points availoble, there will remain uncertainty in defining the top of the Brushy
Basin throughout the Mill property. D&c indicated that it would not be
necesgary to pull casing in order to log these wells, but asked ruSA to consider
gcophysical mcans of establishing the comacl For this itenr, DRC was
particularly interested in:
Attompt to define the oontact in these wells.
consider whether any geophysics might be used, if well logs cannot be
located.
Determine whether or not the dry wells located the contact.
Completion diagrams would be best, but at a minimum, find the top and
bottom ofthe screened interval.
(1)
(2)
(3)
(4)
8:\r'lB8\grumdrmtor-dirchrrgoJrcflnitur{orcl20t)lrrpnvorprol2@ldaqler0ill0t-doc
MAY-Il-01 16r30 From:
Mr. William J. Sinclair
May ll,2001
Pqge 4 of2l
T-201 P.05/?? Job-429
Tbee Wells Formerly IWed SMW-I thnt fu{W-3 [p.2. hew 2.C.3] - from the
fuscription provided, it is cleqr tlnt Ser ircallation lhes three (3) wells were
actually tamed MW-20, MW-21, frid MW-22. We als wlmowledge tlnt new
survey coordinates lwve alredy been provlded tor these lhree (3) wells (9/8/00
IUC RatsedGIR, LANDesign map Sheet I "I1), Inaddttion, DRC staffhas alo
visited each ol llrese dtring the lqst split grutdwaler sanpling evenl in
Nwember, 2000, Howewr, please provide the following inforualion slill foundlackinglor these three (3) wells;
0 Geologic lryt - tlwt lqate lhe depth to ilp upryr B^lrt Easin Slale
contacl,(2) Well cotnpletion diagrans, *d(3) futes ofwell installation.
COMPLETED
This is same reguest, essentially, a$ (A) above. Searches were performod as
describedunder l.l. above. IUSA located working files and field notes from
drilling of wells MW-20, .21, arrd -22. l\s discussed under item I. above, ruSA
atso located what appears to be a Table and pages from a report by D'Appolonia"
whioh gives data for shallow borings 9-1,9-2,10-1, and lO-2. ruSA is rvrricwing
these data and will transmit the any geologic (well) logs, completion diagRms, or
dates of installotion found in the frles or the table and prges ftom the
D'Appolonia report, in the lune futa transmittal shown on the proposed
accelerated schedule.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 24 MEETING
It was agreed that items 4A and 4B may be combined as ore responso, and the
scope of both responses would be as defined above under item 4A.
Fggr-.G.epJ#hfiigqlForings:-.ffi.1 thru GH4 [p. 4. Item 3.A.4J -from review oJ
the september 8, 2000 Revised GlR. it is clear fiatlar (4) geotechnical borings
were ako inctdlled new the tailings eells in canjunction with wells MW-20 thnt
MW-22: c,s a rurl of sudies canpletedlor the NRC ad EPA (9/8/00 IUC Revised
GIR, pp, a-il, Apparently these borings were runtted GH-|, GH-LA, GH-i frtd
GH'4. We aclmov,ladge rccaipt oltield ard laboralory permeability dala from
these frur (40 borings in the September 8, 200a Rewsed GIR (Attachnwnt 10,
Tables C-S qndC-6). However, lhis report also exphined how olher inlormation
was collectedfiom these borings, including:
(I) Wirclino geoplrysical logs,(2) Wireline video logs(3) Geologic logs
s:\lrdlf,.\grogndwrrer-dirohrrgc-pcrgrir\M$Gh200ttrpnkesplol2ootdoqlou)51l0l.doc
MAY-Il-01 l6:30 Fromr
Mr. William J. Sinclair
May 11,2001
Pago 5 of 2l
T-201 P.06/?2 Job-129
Please provldc reliable suryey coordingtes md all geophysical, video ard
geologic logsndelo ilrcwlwr (4) borings.
COMPLETED
Sesrches w6re porformed as described under l.l. above. Geologic logs hnvc
been locstad. A video log that appears to relaie to at least two of the borings has
been located, and is being rwiewed by IUSA. A copy of the video log will be
included in the fune transmittal to DRC.
The Umetco 1994 report (refened to by DRC as the '?eel Report") is being
roviewed by IUC.
scoPE oF RESPONSE, BASED ON DR.C/ruSA ApRrL 25 MEETING
For rhe above-re&reflced zurvey coordinates, DRC indicated that it is acooprable
to approximate locationq if surveys are impractical. ruSA will designate those
coordinates for which locations have been approximated. The Umetco 1994
report (also looated) shows, in a work plan, the plannod locations for these points.
IUSA is to approximate these on a map, and estimate coordinatos. IUSA reported
that it sccms likcly that wc will not bc ablc to find thc boring locations in tho
field, however.
Former Monito"ring wells lpJ,ltpn i.A.4 atd 3.8,-*2J - appwently II]C las been
unsuccessful in tlpir qttemPls to provide intomwlion onformer monitoring wells
now aWoned However, addillonal informatlon isreEired, asfollaws:
(l) Well MW-13 - $er IUC's unarccessful anempt to luate this in/ormation
(9/u00 IrIc Revised GIR pp I 2 &L I 6), DRc stfffouttd the required weilMw-|3 data in a March, lgBJ Energt Fuels Nuclear (F,Fry constnrclion
Report for cell 3 (Appendix D, see Il/I/82 D'Appolonia connrting
E-ngineers leller reporl), Please provide reliable Mrvey coordirutes lorthis welL
COMPLETED
Searchcs were performed as described under l.l. above. Mr. Roberts copied
data from a D'Appolonia repon of 11/l 111982, ruSA has also located a lettir to
NRC thet showed a map indicating where this well would be affer Cell 4 was
constructed- It is rtow iltside Cell erea. Copies of the report and letter to NRC
will be provided ro DRC,
rusA is approximeting coordinates from information IUSA has located.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
srwlRR\goundmta-diaohargn-9omit\M,curDlnpilrrxfioS2ooldoql.toJil0r.doc
IIAY-Il-01 16:31 From:
Mr. William J. Sinolair
May ll,200l
Fagc 6 ofZl
T-201 P.07/2?, Job-429
The "reliable" coordinates that DRC has requested may be estimates, because the
well location is now insido the Cell 4A srea. IUSA will designato the points as
estimatos.
(2) Wells MWcl. M!,7:'.4-2, MltT-|. MW7-2. MlYs-t. ad MW8--2 - phasc
exphin wlal efforts were coilpleted to locate lln required well completion
diagrans and geologic logs lor these six (6) Iorner wells. In the event
tlut tew efforts fitd this i4fomation, pleare provide il with reliable
suruey curdinales tor eqch well at your earliest catwenience.
COMPLETED
Searclres were performed as described under Ll, above. ruSA was able to locate
instellrtion dsta for these shallow borings. This information will be organized
and transmitrcd to DRC with the Juno transmittal package,
SCOPE OF RESPONSE, BA^SED ON DRC/ruSA APRIL 25 MEETING
ruSA is to provide DRC with descriptions of IUSA's search for logs and
completion diegrams. If estimation of coordinatee becomes necessary, DRC
agfeed that it is acceptable to approximate locations, if surveys are impractical.IUSA will designate those coordinates for which locations have been
approximated-
Resolutiott Plot ard Schedtlefor WellMW-3 tp:.Z..I.tefn 2.Q.OJ -ve rchtowledge
your irubility to prdtce a well completion diagrmt *d geologic log for well
MIY'3. this ir{ormotion is essential for &termirution ol ayifcr thickncss ard
elevstion of tlre Erashy Easin Slwle apwr contsct. At this time, it qpems tlnl
lhere sre only two options to resolve this problem:
(1) Wireline Yideo and Geoplytg4trLk# - to locate the screened intervuls in
the well, and deptVelevation olthe Brushy Basin Slale Wper contsct.
(2) hq,lgll q Cotfrrmalion Doring - in the ewnt tM the geoptrysiml logs are
ansuccessful in loeating the Bntshy Bain Slrale upryr conlact, a
confinnation boring may need to be installed near well MW-S to allow qn
adequate geologlc log to be assembled
Please provi& q plon md she&tle lor lhese resolulion activities for well MW-3
vithin 304rys ofreceipt of this letter.
COMPLETED
In the Groundweter Information Report Revision package ('GBRp'1, rusA
submitted construction deail from the Titan Hydrogeologic Report (it had been
copied from D'Appolonia). The detail does not show geology on this detail, and
the contact is not shown. It appears that this well was only drilled to 96 feet,
S:\MRR\goudwdq_dirchnFJr6nrit\March200 t npn\rcrtro3zm I &qle{Oj I l0 I .doc
MAY-Il-01 I6:3I Fromr
Mr. \Uilliam J. Sinclair
May tl,200l
Page 7 of2l
T-201 P.08/22 Job-429
based upon this repoft. In additiou searcher were performod as described under
1.1. above. These sesrches failod to yield a more detailed geologic log for this
putioilarwell.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
ruSA will continue to disorss with DRC the feasibility and need for de.fining the
Brushy Basin sontact at this locatiort. ruSA notes that thc top of Brushy Basin
throughout our entire eite, which is in excess of 5,000 screg, cannot be quantified
in completo precisiorl because there would always be too few dala points. The
site conceptual model, however, which has been published and available for
publio comment sinco the Environmental Assessment was frst published in 1980,
supports the general conclusion that the Brushy Bagin is present as a confining
unit beneath the site. This is evidenced in a number of ways, including: Pressure
head observed in wells drilled to the underlying EntradaNavajo sandstones;
observed contact in canyons adjacent to the site; observed conta$ scepcge et tho
contacts; historicEl descriptions of regional lithology, by independent geologists;
and observed presence of the contart in wells drilled throughout the site.
DRC had requested a schedule describing IUSA's plan to resolve the above
questions, submitted within 30 days of the March 2o leirer. rusA and DRC
€Ieed that IUSA is to prepare a proposed revised schedule for GWDP submittals,
in light of the delays experienced by IUSA in compiling the requested information
and by DRC in reviewing IUsA's previous submissions. IUSA has prepared a
revised, accelerated schedule to respond to DRC's March 20 comments white also
preparing a numbcr of the othcr technical submittals required for the Choundwatcr
Disoharge Permit GWDP.
As described in the introduc-tion to this letter, ruSA will need until mid-Iune to
complete and submit all responses required to the March 20 response and request
for additional information, in accordance with the scope discussed for each item
on April 25.
With regard to this technical issue, IUSA is to provide DRC with its approach to
defining the top of contact at this location. Options could include gibphysical
logging; or possibly drilling a confirmatory boring. IUSA agreed to discuss this
with our technical consultants, and then will ask for a meeting to disanss their
recommendations with DRC.
-we2.
aclmowledge tlut no additional well corrstraction infurmation i" qrAtqbl" jiUW-1.
Close review oI tlp gwihble IUC irformation indicales that fiE base o! the well'sscreenedintentsl is about l3leel above the Bruslry Basin Stnle uppr conta;t (04 Titan
Pf*t Appendix A, well_complelion diogrun). A/ter conside*iion tlut chloroform has
been detected in thiswell, it is clear that the ptential exislslor &nse non-acyueous tiguid
S:WRR\grounrhvrtor_dircheqc-prmitwilrl000lnpn\[e-mail]
MAY-Il-01 l6r3l From:T-201 P.09/22 Job-429
Mr. William J. Sinclair
May 11,2001
Page 8 of2l
(DNAPL) wttwrrirun s to go andetecledwilh lhiswell configuration As a reslt, we see
no olher oplion bat to ask IUC to complele one of the lallowing octivities:
L Re-pgrtorate lllell MW-4 - by culting nw prloratiotts in the well casing, below
lhe erlsttng ffreen intertal, lo allow well access to the aquifer intenal in
Eteslion, or
2. Installatien ola Second Well - in lfu immediale vicinily oJwell MW-4 to provide
a sueened intetwl tlnt is in direct contacl wilh or is yreened rcro&t the Brushy
Basin Slrule upryr contact,
Please provide a plan md schedtle ft one of these activities lor wetl MW-4 within i0-
days otreceip otthts letter.
COMPLETED
The schedule for our responses is as previously discussed in this letter.
With regard to this technical Questioa prior to meeting with DRC on April 25, IUSAasked our independent hydrology consultiants to revieur the data for lvflil-4.
HydroGeoChem (HGC) reported that the wetl completion diagram is in eror, aod thot the
qeophysical !9S deplcts the conrct contact of the Brushy Basin. The hydrologist foundthst the lvf\il4 well completion diogram provided in Appendix A tf TitarL Lgg4,
conflias with the geophysical log of MW-4, which is also prwiOeO in Appendix A ofthe
some report. _In thc well cornpletion diagram, the Brushy Basin contact is apparently
lcpictc0 at a dcpth of approximatcly 125 ft bls, and irr thc gcophysical log, *rc nrushy
Ba.sin cont&ct is depicted at 108 ft bls. The geophysical log is stated tJbe the morl
accurate value, based on the lithologic logs of nearby tempoiary wells TW4-1, TW4-2,
TW4-7' TW+8. In these logs, the Brushy Basin contaot is noted at approximately 103 ft,
105 ft, 98 ft, and_-105 ft bls, respectively. Based on this information, ihe actual iepth of
the contact at lvIW-4 is reported by HGC asbeing most likely l0g ft bls.
In the Chloroform Report (ruC/HGC, 2000) memorandum, HGC notes its disagreement
with DRC's statement that "it is clear that the potential exists for non-aqueous liquid(DNAPL) to be undetected at the well". Rather, HGC reports that the dua-cleorly pointto the oppositc conclusion. For oxampla, HGC rcportcd that, beaausc thc scrccnEd
interval at MW4 extends to a depth of 112 ft bts, any DNAPL that might potentially be
present would, therefore, be expected to enter the well casing, As discussed in theChloroform Repon, however, there is no evidence of DNAPI, at UfV<, in any of the
other temporary wells, or in the vicinity of the abandoned scele house leach field which isoonsidered to be the originat source of the chloroform irr thc pcrchcd watcr. This
conclusion is based on all ofthe following facts:
(l) Low soil gas concentratiorrs(2) Maximum groundwater chloroform concentrations that are more than three orders
$:\MRR\gqafua€r-dirchrgc-porrit\Mudr200rrrylbcspro3200rdcqlct05t r0r.dm
l{AY-11-01 16r32 From:T-201 P.10/22 Job-429
Mr. William J. Sinclair
May ll,200l
Pago 9 of2l
of magnitude less than the solubility of chloroforrq rs deailed in IUC, 2000(3) Multi-depth sampling of lvf\il4 did not indicarc increasing chloroform
ooncontrations with depth in the well borg as would be oxpected if DNAPL
ocisted at lvl\il-4.
Based on the above facts, and because ofthe close proximity of ternporary wolls to M\V.
4 (nV+7 is within approximately 30 feet of MW-4), HGC determind that there is no
need to rehsbilitatc or re-perforate ld\il-4, nor to instclt additional wells near lv[W-4,
IUSA notos that the individual performing these analyses and providing the above
reoommertd4tion is an experienced hydrologist with partiarlar expertise in eveluating
movement of organics in the subzurface. For DRC's referonce, tho hydrologist's resume
and technical memorandum dated April 23, 2001, is transmitted herewith. -
SCOPE OF RESPONSB, BASED ON DRC/IUSA APRIL 25 MEETING
DRC notcd that duc to tho prcsoncs of chloroform in MW-4, DRC rogards this woll as a
focus of attentiorL and wants very clear indication as to the location of the contact. DRC
noted that the top of the Brushy Basin is, as discussed earlier in the meeting, inegular due
to its depositional environment. DRC hypothesized that it may vary "consideiably' in
the few feet between MW-4 and the five temporary wells drilled near it.
DRC recommendd that ruC respond that it believes that 125' is the wrong valug and
provide support for that $atement. In response to this specifro request, ruSA tr&nsmits
herewith the independent hydrologist's technical memorandum.
ruSA is to provido DRC with its approach to fir*hcr dcfining thc Brushy Basin contast at
this-location.- Options could include geophysical logging, or poisibly drilling a
confirmatory boring. DRC suggested considering gamma to look *ihe .ontaot tlrough
the casin& or to consider the feasibility of usingrEM or neutron-density logging. IUSA
agreed to discues this with our technical sonsultants, and then ask for a meeting with
DRC to discuss this well.
$ilitiqnal G-eolog_ic lrforualiotr [p, 4. lten i mdp. t t. Item t t.AJ - $everel reguesled
ilemstrom the Febrzary 7, 2000 DRC RFI remain unresolved including:
I. Missing IUC Retnrls - serwal existing consultants reports have yet to be
provided to the DRC, Pleaw provide thefollowing reports:
(l) Reputs Available b ntu, F.nvironmentql - as listed in Table 2.2 ard the
References section oJ the July, 1994 Titur Erwironnennl Report,
inoluding:
(l) Febraary, r9|r D'Applonia consalting Engineers, "assessment
otlhe Water Supply System, White Mes Projea, Btatding, [Jrah,,
8:\MRRuruedtrfef_dirctrryc3cnnil\Muoh2tXl l rryu\retf oi200 l d6qlc$5 l t O t.doc
t{AY-11-01 16:33 From:
Mr. William J. Sinclair
May ll,200l
Page I0 of2l
T-201 P.1l/?2 Job-129
(2)
(3)
W, l99l Hy*rhgtneering, 'Growrd-Waler Hy*ologr at the
llhite Mes Tailings Frcility"
Jurre, 1994 Peel Etwlronmental Seryices, "Grourdwaler Study,
White Mesa Facility"
COMPLBTBD
searches wore performed as desoribed under Ll. above. rusA bcoted 1994
IJm&co, lgg3 Peel, and l99I HydroEngineering Eeporte. rusA has not loceted
the lgEl D'Appolonia report, and regrefs to report that it believes it may not be
possible to locate that paniarlar repo(. Howerror, as noted under 3,1.(3) below,
ruSA did locate three additional reports propared by D'Appolonia, dated
septembcr 9, septembor 2E, and November 30, 1981. Thes€ are being copied and
will be included in the Iune trursmittal to DRC.
SCOPE OF RESPONSE BASED ON DRC/IIJSA A}RIL 25 MEETING
DRC would like the above reports. ruSA ransmits herewith the 1994 Umetco,
1993 Peel, and I99l HydroEngineering Reports.
@ Rep.ut(s) Prepred lor NRC / EPA - including relnrts to document*ifiing md hydrogeologic imrustigations rebted to erisling wells ]utll.Zo
lhra 22 ond geoleclnical borings GH-t thnt GH-4 (ree discttssion above).
COMPLETED
searches_wae performed as described under t. L above. rusA bcated, during the
search of thc Mill records, sttmc working filcs and frcld notos or data.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRIL 25 MEETING
These additional wetls and borings were instelled as part of the investigation
performed by Urnetco during the time that the Mill was being considered as a
candidate site for disposnl of the Monticello tailings. As we disorssed, after the
decision was rnade by DOE not to relocate the Monticello tailings to the Mill, the
work on these investigations abruptly ceased. No final reports wire prepared andIUSA received no final reports ftom Umetco during Mr. Roberts,-cheok of
Umetco files. However, [USA located, during the rearch ofthe Mill records,'sorte
workjng filcs and field notcs or datq which rusA is currcntly organieing and
copying to be hansmitted to DRC in the June package.
6)
site,
trv othu - repart rehted to grundwaler hydrologt or geologt oI the
COMPLETED
Searches were performed as described under Ll. above. IUSA locsted three
additional reports prepared by D'Appoloniq dated September 9, September 2t,
$:\MRR\gro$ndtmlrr-dirdhffgcJrcruil\M{dr200tnpn\iBproS2oordcqlcoJr l0r.doc
IIAY-l l-01 l6:33 From:
Mr. William J. Sinclair
May ll,200l
Pege I t of21
T-201 P.1Z/?? Job-429
and November 30, 1981. These are being copied and will be included in the June
hansmittal to DRC,
SCOPE OF RESPONSE, BASED ON DRC/TIJSA APRIL 25 MEETING
IUSA is to report to DRC the reEults of these searches rc DRC. IUSA repons
aboyq regarding having looetod the three additional D'Appolonia reports. IUSA
has identified no other reports at this time related to gr6undwater hydrology or
geology ofthe site.
2, Dqes ud Moore Borings 3_-qnd,9,[p, 4. ftem S.A.2J - please provide reliable
Mnqy caordinqtestor these lwo borings at tlrefacility.
COMPLETED
ruSA is attempting to determine the approximate locations of these borings from
historical maps. This information wtll then be used ro approximue the locations on a
map.
SCOPE OF RESPONSE BASED ON DRC/TIJSA APRIL 25 MEETING
DRC agreed that it is accepable to approximate locations. ruSA will designate those
coordinates fbr which locarions have been approximated.
3. Test Well 17 (East of Mill Site.t [p!.ll,e.n j.8.4-we recognize tlat IUC believes
thisfonner testwell las been plaged ard aMoned However, please provide
tltefollwinginformationlu thiswell: date olwell installation, geitqic [og,well
contpletion dlagram, reilable suney coordnates, and a phging qnd
abandomtenl reporl.
COMPLETED
Mr. Roberts assisted ruSA in reevaluating information on deep wells. Searshes were
performed as described under l,l. above. IUSA locate( duringthe search of the Mill
records, Iogs for thedeep-wells and completion descriptions. This information is being
organized and copied, and will be transmittod to DRC-in the lune package. In addition,Mr. Robens has developed a deep well summary rnemorandum descrihing the test well
and other deep wells, which includes a drill date (February 23, lg77\ foithe test well.Mr. Robens is contlnulng to lnvestigate whether or nu the "re$ well" wqs plugged, The
results of this evaluation, together with Mr. Roberts' report on the deep-wJffi, will be
included in the lune transmiftal package to DRC.
SCOPE OF RESPONSE BASED ON DRC/IUSA APRIL 25 MEETING
DRC had requested completion diagrams. IUSA rcported that conrtruciion details trE on
the driller'B report, and asked if these would suffise. DRC indicated that if no other
records exist, then the construction details would be acceptlble.
s:\MRR\gumdwrrsr-dicd*rgcJrcrnirwarchz00Irppn\retpro3200ldqlcl0it IoLdoc
ltlAY-Il-01 l6:31 From:
Mr, William tr. Si
May ll,200l
Page 12 of 2l
T-201 P.13/?? Job-429
4. Five Dry Weils ad Piezerwlgfs*,IE.J. Item J.8.3,1, - qparentb IUC u,us
wilccesslul in its attempls to lmte the reqrested t$trtnatifrrlor &y wells MW-
16, MW9-1, MW9-2, MWIA-|, and MW10-2. Hov,ever, dditioml irformation is
reEtired, asfollws:
(l) Well MW-16 - DRC stafflwnd s well completion diagram ard geolryic
log for lhis well in the FebnttS4 1993 PeeI Envirannentql Sertices
Report (Appendixil.
(2) Weils Mly-16. MW0-1. MW$-Z. MVll-t. ad MW|G2 - please eqlain
wlnt efforts were completed to locate the reEdred well complelion
diagrams aM geologic logsJor thesefour @ eywells. In the event tM
new efforts rtnd his information, please provide it at yoar earliesl
convenience.
COMPLETED
Searches were performed es described under I.l. above. IUSA located, during the
soarch of the Mill records, logs for the deep wells and completion descriptions,
ruSA has also located packer tests for MWI6.|9, and well logs. The pscker tast
results for trvtW l6-tg and the 1993 Peel r€port are being reviewed by IUSA and
HGC, for inclusion in a new data teble of hydrogeologic parameters. The
information used to prepare the data table will be transmitted, togdher with the
table, to DRC in the June packqge.
5. Two Nesred Aryle,-Bofings Neu aell 44 [p, 5. Item 3.8.4J - pleasa explain wlut
eflorts were made by IUC to lomte the reEtested informalion lor lhese two (2)
borings, Slrottld new efforts locqle this dala, please sbmit it at your earliesl
convenietrce.
COMPLETED
IUSA has reviewed the Work Plan in Appendix F of the 1994 Umetco roport. As detailed
ln response to item t. L above, having completed the searches described i; L l. during the
week of April 30-May 4, Mr. Robefis concluded that records transfer inforrnation
provided to him at the time of clozure of IUSA's Grand Junction office appears to be
corroct that ie, reoords regarding the Mill were trensfi:rrcd to thc l.till, whilc rgcords
regarding the Mines were transferred to the Dove Creek oftice, and those were later sent
on to the Fredonia oflice. Mr. Roberts believed this to be evident by the fact that raw
data ftom the 1994 drilling oampaign were found in Mill archives he searched; thereforq
he has reported that he believes it would be fiuitless to search for the same records inFrsdonir. Ae a rosult, the expanded s€arch he perforrned ofthe Mill locations is thc final
search ofrecords.
As a result of these Beatrches, ruSA has olso located constant head pressure tests for theseborings. Creologic logs have been located. As stated in response to i.3. above, a video log
S'WRR\Eumdryrtc_dirchtrgc_pmrit\Mrctr2t[trrynVwpto32$tdoqle{lflI0l,doc
O
nolair
MAY-Il-01 16r34 Fromr
Mr. Willirm J. Sinclair
May 11,2001
Pags 13 of2l
T-201 P.14/22 Job-129
that appears to relate to at least two of the borings has been located, and is being
reviewed by IUSA. A *py of the video log will be included in the June transmittal to
DRC.
IUSA is organizing and sorting these data, and will submit the results in the June data
transmittal as shown on the proposed accelerated schedule.
SCOPE OF RESPONSE, BASED ON DRC/ITJSA APRIL 25 MEETING
As stated &bove, these additional wells and borings were installed as part of the
investigEtion porformed by Umetco during the timc thu the Mill was being oonsidered as
a candidate site for disposal of the Monticello tailings. As we discusserd after the
decision was made by DOE not to relocate the Monticello tailings to the Mill, the work
on theoo investigations *bruptly ceased. No firrel reporte were prepated end ruSA
received no frnal repofis ftom Umetco during Mr. Roberts' check of Umetco files.
Howerrer, ruSA loc&tod, during the search of the Mill reoords, some working files and
field notes or dttE, which ruSA is cunartly organizing and copying, to be transmitted to
DRC in the June package.
l,ard Suntqlu lilfuugfipn [pp. 5-6. Iten 4, p. 9. Ilem 9, and p ll-ftuu 14 - we
rcbtowledge submlfial o{two (2) IUC maps of lheldctllry, lncludlttg:
I. August 2E, 2000 /"i.NDESIGN Site Conlrol Map - prepred by I/4NDESIGN
Engineers, Surteyors and Platmets of Grad Junclion, Colorado, Sheet I ol I,
Rev. I (nbmitted as a lnrt ol the Sepleuber 8, 2000 IUC Revised GIR). This
fumting included a data table ol s'uryey coordlnales, qnd a slmple relqtlw
posimn plot/or nany of the requestedtacilities at the White Mesa site.
2. IUQ Towgraphic Map - provided to the DRC by Mr. Ron Hachstein ol IUC on
June 13, 2000. This deailed topographic map, preryed by qn unlmown pwt!,
provifus lacalion detoils for many ol the sile tacililies, including but not limiled
to: footprint of fuifings pnds, tailings pond berms, site rmds, mill site, mill Ste
prduct and prwess slorage tanlcs, ore sloroge pd, wildlife pords, topsoil
sloraga pds, mill praoess buildings, dflinistralion building, current truck scale
building, andmill sile pnocesswaslewaler pond ("Roberts Pond"). This mapwas
reportedly prepared at I:3,600 rcale (1" = 300 fr), as derived trom
plptogran metry dala callectedtor lhe sile in February, 1999.
Reyiew of these lwo (2) IUC maps shtws that much of the infumatiott requested in the
Febntary 7, 2000 DRC RFI lws been provided on orts tnap or the otlnr, with the
ercaption ol tha follou, ing ilems qnd oonoerns :
3. Cambirutiotrol Sile Plan ard Topogrfrthil Mgts,[p-,.2,-*em 9J - for ease af
reference ard to lacilitale prepration ol futare DRC hyfuoSeoWc crors-
vctions md other maps it is essenlial lor all the reguired elements lo be
s:WiRR\Sroundu6r*_diucbrrgo-pcnnhWrrch200lr+oVcqdo3200ldcq&ioj I lOl,doo
IIAY-Il-01 I6:35 From:
Mr. William J. Sinclair
May ll,200l
Poge 14 of2l
T-?01 P.15/22 Joh-429
prewnled on a single mry, For this rea,son, DRC stSrequasl llat IUC combine
llp qbove site contol ud topogrqhic nqs lnto a single mq. Please ensure
thot tlp accessible didwsp relatedlactlities se shown on lhe combined mq,
ircluding, but not limiled lo [p.5, Item 4.A,1 tlrru 5, and 4,0.2J: tailings ponds,
tailings p*rd betms, eristittg ttoundx,atcr monilotitg wells, former wells and
piezomelers, water supply wells, exploratory borings, by wells od piezometerg
qtd the ch loroforu inve sligation temporay w e lls.
COMPLETED
ruSA attempted to combine the above noted maps. ruSA is investigating the best me4ns
of resolving suryey issues. IUSA will then develop maps and cross-sections.
SCOPE OT RESPONSE BASED ON DRC/ruSA A}RIL 25 MEETINGfu discussed with DRC, the existing forms of the maps noted above do not Iine up
ocactly. IUSA has begun considcrirrg options, and Mr. Robertr has met with the
zurveyors. ruSA offered to zubmit, as an interim response, the crrrrent form of combined
map. ruSA noted that this map would not show exact locations of surveyed points
relative to the contour locations, and DRC finds this acceptable as en interim responso.
DRC clarified that its interest is in knowing where wells are located relative to features of
the ritc, such as ponds or stookpilos. DRC ncods x, y, and z coordinotes for the wells.
ruSA will transmit, in the June package, a draft map oombining the two above-noted
mtps, noting that the locuions are approximate relative to the contours. IUSA will
continue in its effo(s to resolve survey issues, and wilt, upon resolution of such issues,
then prepare updated cross sections and other maps, including perched zone water
etovation sontour maps and water surfaoe elevatiort contour maps. These contour maps
will be periodically updated by IUSA and provided to DRC.
4. Nearby StqkymleilW.-WeUs h.6, lbn a./.6J - ne*by stocluatering wells
constitute polenlial poinls of expoure for the fircilily, Please provifu survey
cmrdinates, including grarul sarface elevationslor both the Jel Pump and Jones
stoclwakrtng we lls lqated ruo the facility.
COMPI.ETED
ruSA is atternpting to determine tho approximate losations of these stockwatering welle.
This information will then be used to approximate the locations on a map.
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
DRC agreed that it is acceptable to approximate locations. IUSA will designate those
coordinates for which locations have been approximated.
5, NearW Contrct Seeps and ,Springs [p. 13. ltem l3J - nearby seeps atd springs at
lhe edge of l{hite Mes also torm potential points of expomre tor the facility,
Please provi& sr.rvey coorditales od gand ntrlace elevations tor all contact
*eps md springsnear thefrcility.
Sr\MRR\groudqr.r_dirchargo_pmrir\Musl000lrrynrrarpco32mldcqh0jll0l.doc
-01 1 6:35 From:O
Mr. William J. Sinclair
May ll,200l
Prge 15 of2l
T-201 P.16/?2 Job-129
COMPLETED
In the September 8, 2000 GIRRP submittal to DRC, ruSA srbmitted aeriat photos, as
DEQ aereed would be acoeptable, As roported in the GIRRP, IUSA could not, however,
providc dotrilcd land nrrvcy locations for all contact sccpr and springs, bccausc such
features vary depending on a number of hydrogeologic conditions. ruSA rubmitted a
orrent map showing water surface elevations for the perched groundwater %\p, The
water surfaco elevations in the perched groundwater zone generally decrease near the
margins of the canyont, where the perched groundwater zone thins and is discharged.
IUSA transmitted in Attachment l0 of the GIRRP ar oerisl photogaph showing
vegetative patterns indicative of srepage along the nearest cenyon margins, which, based
on our meeting of April 7,?:000, we understood to bc srfEoient for the present purposes.
SCOPE OF RESPONSE BASED ON DRC/IUSA MEETING OF APRIL 25,2OOI
In eddition to thc forcgoing rcsponlcr DRC rcqucstcd that ruSA now alco attsmPt to
dwelop survey ooordinatss for those soeps which appear to have been doveloped in the
pest. Evidence of development would be the presence of pipes (flowing or not) or stook
tanks. IUSA will conduct field reconnaissance to attempt to define locations of such
features and will also, as DRC suggests, evaluate means of approximating, with
roasonable accuracy, tho x" n and z coordinates for such features. Hend-held GPS may
provide suffrcient resolution, or historic m*ps may be used to approximate locations and
elevatiorts of these fegtures. ruSA will investigate methods of mapping those well-
defined &atures, and will discuss its findings with DEQ.
Confimration qf DRC Estimated Smlehwrc Leachtield Coordinates [new itcm| -
after compuiton ol the sile plan nap trom the October 4, 2000 chlorolorm
invesligalion report (Figltre l1) with the IUC topographic map provided on,lune
13, 2000, we hwe e$limated the surltey coardinates oJ the septic tffik bqinlield
lmqled a shorl dislance Soutlwest of the existing tntck sale house. Pleqse
conJirm lhe acaracy atd conlent of the DRC estimated wrtey coordinales lor
this leachfieW, as provided in Table l, belou,:
Tqble DRC l, Eclinaled Scale House kacffieldCoordindtes: Former IUC Truck
Corrcr hstw (feet)Northing (feet)
Nortfuest 2,580,735 322,330
Norlheasl 2,580,800 322,330
Soulheasl 2,580,800 322,260
Sottthwesl 2,580,735 322,264
8l\Illf,\Eoundwrtor_dircbrrgolxrmil\MrrcE00lnpn\$p.o3200tdeqlet0Jl l0l.doc
tlAY-I1-01 I6:36 From
Mr. William I.
May I l, 2001
Page 16 of2l
T-201 P.1l/22 Job-129o
Sinclair
COMPLETED
IUSA is evaluating the above coordinates. The s€archos defined abone under l.l. yieldod
engineering drawings which depict the design location of the historic soalehouse
leachfield. ruSA will use the drawings to ertimat€ the coordinates of this partiarlar
loachfield.
SCOPE OF RESPONSE, BASED ON DRC/IUSA APRJL 25 MEETING
ruSA noted that it would like to prepare more complae maps that could include the
above feature, after the survey results are reviewed. ruSA notes that the review of the
survey data may alter IUSA's interpretation ofthe above results.
IUSA was requosted by DRC to include this feature or m&ps that would be provided to
DRC-
Submittal o! Sunte.v Cmrdirutes lor Related Faailities lneut ltemJ - 4e, review
oJ the IUC inlormation provided lo date, DRC staff lnve futermined tlut
ffiitiorul related tacilities at the site need to be lxated on tlp comhined site
plqn atd lopographic map, including but not limited to:
(l) Eristing Adninistmtion Duilding Septic Tgtb Drqiryfield - relnrtedly
luated a short distmce North-Norllwesl olthe lruck scale huse,
(2) Fome,r Afuinistation BuiWing Seilic Tank Drairfreld - once located
fiurheast of the main ofice building,
(3) Former labomtory Wasaa,o(er.Slprage Tank and Drain Pipe - including
lhe lrcation of the above grourd tank tlwt was once lomted on lhe North
side of tlw mill adninistation buildins wd the ptpe tlwt &ained it to the
mill site waslewqler calch pottd ("Roberts Pond').
(4) Former Mill Site Sedifiefitilon Pond - also lnov,n as the llrysl, prd
(6/79 D'Appolonia Design Reporl, Sheet a of 16).
(5) Former fulid Wase l"$Cfrll - located rusr otre olthe wildlife pords kst
dtln mill site.
Please ensure lM lhe suryey coordirutes far all ol tlre related Jacilities outlined abovv
are accumlely ploued on the combined map also requested
COMPLETED
The scarches defined above under t.l. yielded engineering drawings which depict the
design locations of these features. To the extent possiblg IUSA will use the drawings to
estimate the coordinates ofthese features.
sr\i-lRR\froun6mter:dirchrrgo3crni$Mrrch2fi)lr4nVonpro82ooldeqlc0JI t0Ldoc
MAY-Il-01 l6:36 From:
Mr. Witliam J. Si
May 11,2001
Page 17 of 2l
T-201 P.18/22 Job-429
SCOPE OF RESPONSE, BASED ON DRC/ruSA MEETN{G OT APRIL 25,2OOI
ruSA noted that it would like to prepare more oomplete maps thnt could inolude tho
abovc features, after the survey re$lts are reviewed. Other corrections to the survey
database should be performed first. Then, there maps would be provided to DRC.
- we alryreciale
the de*riptton o{ the mtnber of weAs od the of head increae seen in wells
at rheJaciliV 0/8/00 IUC Revivd GIR p 26). Hwever. as ouilined in the Much 13,
DRC ReEtest tor Corftrmation (RFC) Ietter, DRC stff will complele tlp firwl water
table contour ard isopch thicbess mapslor tlp sMlow qqufer (3/13/01 DRC letter,
pp. 4-s). This leaves two remaining items from the Febntary 7, 2000 DRC Mt tlat
continue lo be unresoNed. as outlitud below:
l. Plm and Schedule.for AMitioml Monitoring Wells or Piezomelerc tp,li. Ilem
14.CJ - we luw rcviewed your September 8, 2000 rcqnnse odlotnd it/aited to
dfuess fip need to identily the root cattse tor lhe increasing hed lrend, As
explained previously it is lilcely tlnt the rising growdwater levels obsemed is
likcb fue to some arlificial source qf grourdwater reclurge, ConseEtently, uch
a sludy will require the inslallation ol additional wells od/or piezometers inot&r to idenlifu the source of the ma*rffi reclntge, In order lofacilitate this
effort, DRC stS hm,e prepred several frgrrot to gtti& your planning, as
described below:
(I) DRC Conected Well Hydrographs - lmte been preryed for existing
noniloringwells at lhefacility, bassd on conecled growdwater elewliott
data provided you in the March 13, 200/ DRC MC letter, see Attcahmentl, belw, These lrydrographs estqblish llwt lhe welk wilh the greatest
inereases in groundwater hed include (in deueasing order): MW-4, MW-
19, MW-IE, urdMW-|1.
COhdPLETED
IUSA has, in the Chloroform Investigation, provided (based on discussions with
DRC) qualitative data as to potential Bources of increasing water levels observed
on the eastern portion of the Mill property. However, we understand DRC's
requoet that IUSA further inveetigate the inoroasing water levels in certnin wells,
We are curently reviewing this iszue to d*ermine the best way to Enswer DRC's
questions. We will submit a final response to these questions in our June 22"
200I submittEl.
SCOPE OF RESPONSE, BASED ON DRCAUSA APRIL 25 MEETING
At the Aryif 7, 2000 meeting DRC indicated that the objectivo of evaluating
water level increases would be to provido contour maps using local water leve]
data to show how the perched groundwater zone has behaved over time.
a
nclair
t
8;WRR\groundrwer_dircluryo__pcrnit\MarcM$lupn\nepro3200ldcqld0il tOl,doc
lilAY-Il-01 lE:37 From 'o
lvlr. Wllism I. Sinclair
May 11,2001
P1ge 18 of 2l
T-201 P.19/22 Job-429
As IUSA and DRC discussed, IUSA will take responsibility for prepering water
table contour and saturated thicknese maps for the perched groundwatir being
monitored at the lvfill. As we discussed, IUSA is responsible for maintaining
water levols and water quality data in databases for a number of regulatory
purposes. To optimize manrgomont of theso data, IUSA will neod to continue to
generatc those databases, but will be happy to provide DRC with electronic copies
as the datebases Ere updated. In additio4 ruSA wilt task independent
hydrologists to assist us in preparation of contour meps, using the corred
interpretive tools bascd upon the distribution of the data at the site. IUSA
requested aseistanco from our independent hydrologists, HGC, in reviewing the
contour mEps prePared by DRC. A technical memorandum was prepared by
HGC regarding this review, which identifies conoerns and timitations with respect
to use of computer-eided plotting packages when data are unevenly dietributed.
HGC's memorandum is transmitted herewith. IUSA will rnake oautious use of
suoh peoklgcs, and will produce hand-contoured maps whcn the data distribution
indicue this to be a more appropriate method.
(2) DRC Water Table FquipoleqtielMM;_Eenkwber "n00 - this water lable
contour map prepredtrom IUC wsrer level futo collecred in Septenrber,
2000 includcs grourdwater hcd futa fiom most of tlre exisling
monitaring we!_ls at lhe sila, plus all the chloro/arm investlgation wells
recently iwlqlled Revian, ol this DRC map.srrlilresrs tlru, ihe arlificial
gtoudwater rechmge source is localed Norrh frid East of wells MW-4
atdMV-|g, see Aflqchmenl 2, below,
COMPLETED
Please see responses to item 5.1.(l) above.
(3) DRQ Delta Hed C.ontoul.M@- the nagnitude o! increased hed in each
IUC well was calcalated by DRC staff dter review o! the hy*ograph
lrends seen in Attaclntent t. DRC slff tooh serected heads Trim ine
srying of 1983 tts representative of fuseline corditions qt the facility,
From lhis, in*eases in luad were calatlated tor each well thru &mmir,
2000. These head increases (Delta Head values) were then tabulated and
conlutred on a map; see Attsohmenl 3, below. Thts map^rrrgge,sr^$ tlnt tlrc
arlificial wurce of grourulwater recharge is lualed iast-o! lutw-4 ard
MW-r9.
Please provide a phn and schedtle tor lhe inslallation of additionql monitoringwells ard/or piezomelers lo locate the soarce of llu artificial grourdwaw
reclarge apparent North ad Edst of weils MW-r qndlulw-tg,
COMPLETED
Please see response to itern 5.1.(l) above.
S:WRR\gromdwrrff;dirchnrgcJrsmir\Mrch200tEprrvosplo32o0tdlqlctott l0t.doc
IIAY-Il-01 l6:37 From:
Mr. William J. Sinclair
May ll,200l
Page t9 of2l
T-201 P.20/22 Job-429
2, Additional Groutdwaler Saalitv Data [p, 15. nen I4.DJ -we actonwledge tlwt
your chlorotorm investigalion rcport will @es groundwater WW isues wtd
firc pobntial tor olher cofitenhwrts as irdicqtors of chtorolonn disclwge
(10/4/00 I(E Chlorcform Reprt). We luw aln roooived your September 15,
2000 Grundwaur Baclcground Water Quality Report. This isste and both oI
thew reportswill be reviewed at a lqter date,
Slwllaw Agtgler.EieW temegbililv: copies of Nates. Calcaldtions. md Dqta [pp. ] tJz,
Itelt I l.Bl - the September 8, 2000 ruC rcspon& relened to yourtailare to locate copies
of origirul laloratary permeability futa. ln contrast, ur origirul Febntary 7, 2A0A
requesl was for copies of notes, ulaialions, ad futq for the field permeability tes*
cMucted on moniloring wells, boriltgs, nd piezomelers at the Jacility. To reiterate,
pleax povi& the follov,rng:
l, Field notes and futa collectedfiom eachfield pnneability lest, ud
2. Detailed fuscriplion md justificalion S calcalqtions md unalysis methds used
lo determine permeabilily, In the event ilnt test datatrom certain wells was re-
anafued, plaasa explain why rv<rulysis was rcquircd
Alter wbmillal ildrevi*t of this information, DRC stafwillprepme a summary lable of
all available permeability data and askfor IIJC concunence.
In the event tM tln intormalion reguested abow cannot be provi&d, please *bmit aplan and sclpfule for tield permeability te.tting oJ atl shallov, aquiler wells urd
plezometers at the tacility.
COMPLETED
Searche_s werc performed as described under L l. above. In additiorL HGC is compiling
some of its field notos and a discussion of analytical techniques forthe rc$s conduciea atMW-4 and MW-19. ruSA and its consultrant will compilg review, and table any data
locatqd. Updated tables and associated dara (when available) will be provided to DRC.
Based on this complete review of availabte hydrarlic data, IUSA will evaluate anypotential need to oonduct scl*ted pump tcsts on wclls for which adcquatc date are not
available.
The drilling and logging data indicate that the physioal characteristics of the rocks
beneath the Mill vary considerably both vertically and laterally. Therefore, in June of2000, ruSA dipctrssed with DRC the epproprioteness of attempting to use thc limitcd data
available to create a "contout" map based on specific data for specific bore holes. Thefeasibillty of suoh an approach may be limited in view of ihe fact that hydrarlicproperties of this stratum, which have been determined from 12 single, well-
pumping/recovery tests and from 30 packer tests yielded a broad range ofhydraulic
s:\MRRbromdw4r-disctrargeJrormir\Mrch200lnpohsDro320oldGqlcoir t0l..hc
I 6:38 From:T-201 P.2l/22 Job-429
Mr, William J. Sinclair
May Il,200l
Page 20 of2l
propcrties, which wilt not rearonably lend themselves to a defensible contouring
appoaoh. Furthmnrorq the deporitional history and composition of the Burro Canyon
Formation is such that one would oxpect random variability rather then mapable contours
from one point to another.
In response, DRC indicated that, in some situetions, it is possible to convert permeability
test rerults to log values and create contour maps of the log vatues. DRC indicued th*
they would want to see the field notes first. DRC stated an interest in first revieuring the
data and field notes, then determining how best to present the results. DRC zuggested
thEt IUSA submit e phasod approach encompassing these two elements, in tho GIRRP.
IUSA discussed this issue firrther with DRC on August 14, and agreed to oreate E map
showing the point-specifio permeability values as part of the GCt Report. This report
was trsnsmitted under separete cover, and as per the Chloroform Investigation schedule.
See Figure 2, Permeability of Perched Groundwater 7.one in cm/s, in Investigatigq,,gf
EleYgtg4,, -Chlorqform Concentrulons in Perched Groundwuer _U. the White Mesa
Uruium Mill Up..qf Hlpnding, Utah (ruSA and HGC, October 4, 2000).
SCOPE OF RESPONSE, BASED ON DRC/ruSA APRIL 25 MEETING
IUSA will compile data requested by DRC, will roview such datq and will table the data in aformat compatiblo with DRC's draft tables and spreadshcets that DRC provided to IUSA. To
ensure inlg{V of the database used by IUSA for the Mill's reguletory purposes, and to
preserye DRC'g position of the reviewer of Mill technical submittali made t6 DhC, IUSA will
then maintain such tables ond spreadsheets for use in preparing technical zubmittals for DRC
including data plots, contour maps etc., and will provide DRC with copies of these s4me t4bles
and sprcadshoets.
ruSA is committed to bringing the GWDP approval process to completion as soon as possibte.
With the added help of I\,1r. Roherts, who hes the most complete historicol knowledge of Mill
activities, ruSA believes it has madp considerable progress since our last submission in
collecting the additional information being reguested by DRC. In addition, in order to make up
E *qt lt]ays in accumulating the historical information, we have already initiated work on
other GWDP tasks that were initially to run in series following completion of CU,np cornmentq
but which now, in the accelerated schedule, are heing managed concurrently.
f 19" havc any questions or commcrrts rcgardirrg this lcttcr, plcasc coiltact fic at (303) 3S9-
4130.
SfMf,R\grqndula-diacturgolrcnrit\MaroM00lrrryaVcrpo320tdoqlc0sl l0t.doc
[lAY-ll-01 16:38 From:
Mr. William I. Sinclair
May ll,200l
Page 2l of2l
T-201 P.22/22 Job-429
Enclozures
calalt: I^erry Mize, LJDBQ Division of Water eualityI,oron Mortort IJDEQ Division of Redietion Control
Bill von Till, NRC
Michelle R. Rehmann
tfuold R. Roberts
cc dout att: Dianno Niolso4 TIDEQ
Dsve Arrioti, S.E. Utah Heslth Departrnent
$:\MRR\gord*rte-ditcbnrgs-pornit\Muclo00lrpdrt4o3200ldcqlot0stI0I.doo
Michael O. LeavittGovemor
Dianne R. Nielson. Ph.D.Executive Director
William J. SinclairDirector
TO:
FROM:
DATE:
State of Utah
DEPARTMENT OF ENVIRONMENTAL QUALITYDIVISION OF RADIATION CONTROL
MEMORANDUM
International Uraniu4r Corporation File
LorenMorron ,/-^ B /ilr,L
September 28,2000
SUBJECT: September 26,2000 DRC Staff Site Visit: IUC core Samples, Former Laboratory
Wastewater Tank, and New Chloroform Investigation Wells MW4-4 and MW4-6.
The purpose of this memorandum is to document DRC staff findings made during a recent visit tothe International Uranium Corporation (IUC) uranium mill facility at White Mesa near Blanding,Utah. I arrived on site at approximately 9:00 am and during my visit was escorted by MichelleRehmann (IUC), Stewart Smith of Hydro Geo Chem, tnc. lHcil of Tucson, Arizona,and LarryCasebolt, consulting geologist recently used by IUC to
-log drill core and chip samples formonitoring wells installed.
Three general issues were reviewed during the site visit, including: 1) examination of available drillcore samples from borings and wells at the site, 2) review of the former laboratory wastewaterholding tank on the North side of the IUC office building, and 3) inspection of two (2) newtemporary monitoring wells installed for the ongoing chloroform investigation near well MW-4.DRC staff findings for each of these topics is presentld below.
Review of Available IUC Core Samples
1' Introduction - the main purpose for examining the available IUC core samples was toconfirm a claim made by Ms. Rehmann during an August 15, 2000 meeting that secondarypermeability was an insignificant issue for the shallow aquifer at the IUC facility, in thatfractures and joints did not exist in the subsurface.
During the site visit only aportion of the available boxes of core samples were examined byDRC. Some attention was given the chloroform investigation wells MW4-l and MW4-2.The entire section of core, however, was examined from monitoring well MW-16. portions
of the available core were also examined from IUC geotechnicai borings GH94-2A andGH94-3' Core boxes actually examined by DRC staff perhaps represented about one-halfof the available core boxes held in storage at the IUC facilitv u,,fr" time of the visit.
Memorandum
September 28,2000
Page2
2. Core Sampling Difficulty at IUC - during the August 15, 2000 meeting Ms. Rehmann
explained that core sampling was impractical at the IUC site due to the extreme hardness of
the Dakota and Burro Canyon Sandstone Formations. In particular, Ms. Rehmann cited the
fact that during the recent chloroform investigation that the driller had worn-out four (4) or
five (5) diamond drill bits in the drilling of the first two (2) wells (MW4-1 and MW4-2).
In contrast to this claim, Mr. Casebolt explained that the difficulty experienced by the driller
was due to the driller's lack of experience in core drilling methods, and not the hardness of
the formations involved. This conclusion was confirmed later when DRC examination of
the core samples found a large variation in the hardness and induration of the Dakota and
Burro Canyon Sandstone Formations. In some core samples the sandstones were dense
enough that a hammer would be required to break the core. In other core samples, the same
formations were readily friable and easily broken by touch of a finger.
3. DRC Joint/Fracture Examination and Interpretation - DRC review ofthe core samples found
many mechanical breaks in the core caused by the drilling and sampling process, placement
in the storage boxes, and/or transport from the drill site. However, a few open joints and
fractures were observed in the core samples that represent conduits for groundwater flow in
the subsurface. The DRC staff interpretation of openjoints and fractures in the core samples
was based primarily on iron and manganese oxide minerals deposited on the open joint faces
or surfaces. In each case where an open joint or fracture was identified in the core samples,
Mr. Casebolt agreed with the DRC finding.
No quantitative analysis was made regarding fracture length, width, aperture, or density
during the site visit. Observations made were limited to qualitative review regarding the
general presence of fractures and joints in the core samples. In alargemeasure, much of the
core samples examined did not contain open joints or fractures that could rapidly conduct
groundwater. However, a few open fractures or joints were found in each well examined,
see summary in Table 1, below. Details regarding DRC staff findings are provided below.
1) Chloroform Investigation Wells - the first core samples we examined were found ina storage trailer on the West side of the office building where NX size
(approximately 2 inch diameter) core samples from two (2) monitoring wells from
the recent chloroform investigation were stored in cardboard storage boxes. Both of
the chloroform wells in question, MW4-1 and MW4-2,were completed as vertical
borings, which has consequence on interpretation of the orientation and types of
joints or fractures found in the field. Both sets of core samples are discussed below:
(1) Well MW4-1 - an open joint was seen in this well's core between the 90 to
100-foot depth interval. Because this joint was oriented perpendicular to the
core axis, DRC staff interpreted it as a sub-horizontal bedding plane joint
(see attached photograph 1). The presence ofhorizontaljoints at such deep
intervals could contribute to rapid horizontal movement of groundwater in
the shallow aquifer.
Well /
Boring
Hole
Orientation
Depth
Interval (ft)
Joint
Status
No. of
Joints Joint Type / Orientation
MW4-1 vertical 90 - 100 open Sub-horizontal bedding plane joint
MW4-2 vertical 90.5 - 100.s open Sub-vertical joint
GH94-2A angle 20.0 - 30.0 open 2 Sub-horizontal bedding plane joints
GH94-3 angle 90.0 - 100.0 open 1 Sub-horizontal bedding plane joint
140.0 - 150.0 open I Sub-vertical joint
MW-16 vertical 22.0 - 31.5 closed I Sub-venical joint (healed)
open 2+Sub-horizontal bedding plane joints
41.5 - 51.5 open 4+Sub-horizontal bedding plane joints
Memorandum
September 28,2000
Page 3
(2)well MW4-2 - an open joint was observed with limonite stains in the 90.5 to
100.5-foot interval of this well's core (see attached photograph 2). Because
this joint formed an acute angle with the core's axis, DRC staff interpreted
it as a sub-vertical joint. The geologic contact between the Burro canyon
Sandstone (white colored) core and the Brushy Basin Member of the
Morrison Formation (purple colored) core was also apparent in this depth
interval. Presence of the sub-vertical fracture above this geologic contact is
evidence that joints do occur in the saturated portion of the Burro Canyon
Sandstone. Such vertical fractures or joints can facilitate rapid vertical
movement of groundwater or contaminants in the shallow aquifer.
Table 1. summary of Joints/Fractures DRC observed in IUC core Samples
2) IUC Geotechnical Borings - in an effort to resolve questions raised by the NRC
regarding the possibility of shallow aquifer secondary permeability, IUC drilled
some angle borings and collected core samples at four (4) wells at the facility during
1994. Two (2) borings each were drilled across the South berm of Cell 3 and the
West berm of Cell 4A. Of these four borings, DRC staff examined core samples
from two angle holes, GH94-zAand GW94-3, each is discussed below:
Boring GH94-2A - review ofthe core from this boring found two (2) obvious
iron and manganese oxide stained joints in the 20 to 3O-foot depth interval
(see attached photograph 3). Bothjoints formed an acute angle with the core
axis, however because the boring was an angle hole, DRC staff determined
these joints to be sub-horizontal bedding plane joints in the Dakota sandstoneformation. The presence of such horizontal joints could cause lateral
spreading of infiltrating waters or wastewaters.
(1)
Memorandum
September 28,2000
Page 4
(2) Boring GH94-3 - two (2) joints were observed in this boring's core samples,
as described below:
Sub-horizontal Bedding Plane Joint - found in the core in the depth
interval of 90 to 100 feet, and slightly stained with limonite (see
attached photograph 4). Because this boring was an angle hole, and
the joint formed an acute angle with the core axis, DRC staff
concluded that this was a bedding plane joint.
Sub-vertical Joint - the geologic contact between the Burro canyon
Sandstone (white colored core) and the underlying Brushy Basin
Member (greylgreen colored core) was observed by DRC staff in the
interval of I 40 to I 50 feet in this well's core (see attached photograph5). A sub-vertical joint was also observed in the Brushy Basin
Member a short distance below this contact, as evidenced by a
limonite stained fracture that ran parallel to the core's axis. This
vertical joint may have extended vertically into the overlying Burro
Canyon Sandstone.
Monitoring Well MW-16 - the complete core section of IUC monitoring well MW-
16 was examined by DRC staff. This well was installed inside a vertical boring,
which has bearing on joint interpretations listed below. Both open and closed joints
were observed in the core, as summarized below:
22.0 to 31.5 Feet - a closed vertical joint, healed with iron oxide minerals,
was located in the core in the Dakota Sandstone Formation (see attached
photograph 6). From this observation, DRC staff concluded thatatone time
the vertical joint had been open and transmitted groundwater. However, with
precipitation of the iron oxide minerals over time, the joint gradually lost itspermeability, such that today it would unlikely contribute much to the bulk
permeability of the formation.
In contrast, several bedding plane joints, stained with iron oxide minerals,
were also observed in this section of core, oriented perpendicular to the core
axis (ibid.). when handled, each of these joints appeared more open, and
appeared to be openings in the rock, along which the core could separate.
consequently, these bedding plane joints may increase the bulk permeability
of the Dakota Sandstone.
clayey stringers were also apparent in this section of core, oriented
perpendicular to the core axis (ibid.). These may be bedding plane partings
that could impede the vertical infiltration of groundwater.
a)
b)
3)
(l)
Memorandum
September 28,2000
Page 5
(2) 4 I .5 to 5 1 .5 Feet - multiple j oints oriented perpendicular to the core axis and
stained with limonite were observed inside this interval of drill core (see
attached photograph 7). Based on the fact that this was a vertical boring,
DRC staff interpreted these as bedding plane joints.
(3) 81.5 to 91.5 Feet - the geologic contactbetweenthe overlying Burro Canyon
Sandstone and the Brushy Basin Member of the Morrison Formation was
observed in this core interval (see attached photograph 8).
From these core sample observations two (2) conclusions can be drawn regarding hydraulic
conditions in the vadose zone and shallow aquifer, and about the types olhydraulic testing
needed to characterize said conditions, as follows:
1. Local Hydraulic Conditions - both open and closed joints were observed in the core
samples examined by DRC staff. In general, the DRC staff concluded that the openjoints found were few in number. However, open joints were found in each well
examined. Of the open joints observed, the majority appeared to be sub-horizontal
bedding plane joints. This horizontal orientation has the potential of increasing
horizontal permeability and flow of groundwater and contaminants.
Open vertical joints were also found in the core samples, but were less prevalent.
Perhaps this was due to the lower probability of intercepting a vertical fracture orjoint with a boring that was also largely vertical in orientation.
Because the fractures observed in the core samples were generally oriented at 90
degrees to one another, i.e., along vertical and horizontal planes, there may be
potential for hydraulic inter-connection of these two (2) joint sets. In the event that
vertical and horizontal joints were to be interconnected in the subsurface, the vertical
and horizontal permeability of vadose zone and aquifer could be greatly increased.
The presence of a fracture network in an otherwise low permeability material can
cause profound increases in hydraulic conductivity and groundwater flow (Freeze
and Cherry, p. 409). It is not uncommon in cases such as this to see joints and
fractures raise the bulk permeability of a material by several orders of magnitude
(ibid.).
The presence of a fracture network may in part explain the rapid movement ofchloroform thru the vadose zone to monitoring well MW-4. IUC predictions of
tailings cell wastewater seepage and vertical travel time across the vadose zone have
been wide ranging, including:
1) 29 to 57 yearc (2193 Peel Environmental Services Report, p. 5-10),2) 50 to 150 yearc (7/27/g4TitanEnvironmental Report, pp. 3g - 39),3) 1,300 years based on an estimated Tailings Cell 3 seepage rate (1 ll23lg1
Knight Piesold Report, p. 10).
Memorandum
September 28,2000
Page 6
All of these predictions focused only on the vertical travel time needed for
wastewater to reach the water table; additional time would be required for horizontal
travel to a monitoring well.
In contrast, chloroform, aman-made compound, appears to have been released from
some on-site source, has migrated vertically to the water table, and has traveled a
significant horizontal distance to monitoring well MW-4 in approxim ately 21years.
As a result of these observations, it appears that secondary permeability caused by
subsurface joints and fractures may have significantly increased the bulk
permeability ofthe vadose zone and shallowaquifer; thereby accelerating wastewater
infiltration and flow from an on-site source and transport of chloroform to IUC
monitoring well MW-4.
Tvpes of Hydraulic Testing Needed - in light of the apparent secondary permeability
present in the subsurface at IUC, it appears prudent to determine field permeability
of the shallow aquifer by large-scale testing methods, such as aquifei pump tests,
single well pump tests, and slug tests. Small scale hydraulic condultivity data
derived from vertical core samples and laboratory testing should not be considered
representative of the actual field conditions.
During the site visit, I asked to see the laboratory wastewater holding tank reported to be locatedalong the North side of the IUC office building (gl30l9g IUC Chloroform -So*..
Assessment
Report, p. 7). Ms. Rehmann explained that this wastewater holding tank had been removed by IUCat some unknown time in the past. Ms. Rehmann further explained that today the laboiatorywastewater drained directly via underground pipe to the Cell 1 evaporation pond.
During the September 26 site visit I asked to see the two new wells for the chloroform investigation,IUC monitoring wells MW4-4 and MW4-6. Ms. Rehmann and the other escorted me to thesi wellswhere I found well MW4-4 located some distance south of the contaminated well MW-4, seeattached photograph 9. At a distance farther south of this location I found the second well, MW4-6
(see attached photographs 10 and 11). Both of the new wells were completed in a similar fashionas the previous temporary wells, with an approximately 4-inch ID PVi casing protruding from alarger diameter PVC surface casing, closed with a pvc end-cap.
From the residual drill cuttings left in the vicinity of each well head, and statements made by Mr.Casebolt, both of these new wells had been drilled with air-rotary methods. As a result, the shallow
aquifer was air-sparged in the process; thus volatilizing and reducing any chloroform concentrationsin groundwater near the wells. As a consequence of this drilling practice, it is clear that multiplegroundwater samples will need to be collected and aralyzed oui. u period of time in order toestablish true shallow aquifer chloroform concentrations at these new well locations.
Memorandum
September 28,2000
Page 7
References
Freeze, R.A. and J.A. Cheny, 1979, Groundwater, prentice-Hall
Jersey,604pp.
lnc., Englewood Cliffs, New
International Uranium Corporation, September 30, 1999, "Chloroform Source AssessmentReport',,
unpublished company report by Michelle Rehmann, 13 pp., 2 figures, and 2 upp"rdi""r,
including:
1)Smith, S., September 9,1999, "soil Gas Sampling Results", unsigned, unpublished
consultants letter report from soil gas sampling of August 3l and Septem-ber I and
2,1999, Hydro Geo Chem, Inc., 3 pp., 3 tables and 6 figures, and
Koch,A.,Septemberl3, l999,"yaporTrace@shallowSoilGasSurvey/SoilSample
Collection for International Uranium Corporation White Mesa Mill Blanding, Utah
August 3l - September 2, I999u , unpublished consultants report, Tracer Research
Corporation, T pp, and 4 appendices.
Knight Piesold, November 23,1998, "Evaluation of Potential for Tailings Cell Discharge - White
Mesa Mill", unpublished consultants report, 15 pp., 5 figures, includes transmittal letter of
same date from Samuel J. Billin to Anthony J. Thompson, 1 p.
Peel Environmental Services, February, 1993, "Groundwater Study White Mesa Facility Blanding,IJtah", unpublished consultants report, approximately 54 pp., 6 tables, 21 figures, I
appendices.
Titan Environmental Corporation, July, Igg4,"Hydrogeologic Evaluationof White MesaUraniumMill", unpublished consultants report, approximately 51 pp., 5 tables, 19 figures, 7
appendices.
LBM:lm
NRC (w/attachments)
attachments: DRC photographs (11)
F :\...\9-26-00inspmemo.wpd
File: IUC GW corective Action order: MW-4 chloroform contamination
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