DRC-2011-006150 - 0901a068802384d3

rage i ui i
Thomas Rushing ii - Rio Algom Mining LLC - Lisbon - Model Review Update
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To:
Date:
Subject:
CC:
Attachments:
"Ray, Billy WM" <[e-mail]>
Thomas Rushing ii <[e-mail]>
6/2/2011 8:08 AM
Rio Algom Mining LLC - Lisbon - Model Review Update
"Wentz, Chuck" <[e-mail]>
RAML - Lisbon - Action Plan - Transmittal Letter.pdf; Montgomery and Associates'Staff Resumes.pdf; Lisbon Action
Plan.pdf
Tom,
Rio Algom Mining LLC has selected Errol L Montgomery and Associates (M&A) to perform the model review for
the Lisbon site as requested by the DRC. The action plan and relevant M&A staff resumes have been submitted
to Mr. Rusty Lundberg (via USPS). A copy of the submittal is attached to this e-mail for your review.
Please feel free to contact me if you have any questions or if you need additional information.
Regards,
Billy
bhpbiliiton
Billy M. Ray
A.mbrosta Lake Site Manager
Rio Algom Mining LLC
PC Box 218, Grants. NM 87020 USA
Maiito [e-mail]
Internet http://v\/v\/w.bhpbilliton.com
Phone [phone] x 19 -
Mobile [phone]
Fax [phone]
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file://C:\Documents and Settings\Trushing\Local Settings\Temp\XPgrpwise\4DE74508EQDOMAlNEQRAD1001726274l74... 6/2/201
Rio Algom Mining LLC
June 2. 2011
Mr. Rusty Lundberg
Utah Department of Environmental Quality
Division of Radiation Controi
PC Box 144850
Salt Lake City, UT 84114-4850
Subject: Rio Algom Mining LLC - Lisbon, UT (UT 1900481)
Confirmatory Action
•Dear Mr. Lundberg; .
As requested by the DRC in the January 31, 2011 letter, Rio Algom Mining LLC (RAML)
sojicited proposals from quajified independent consultants to review pertinent
information and documents, including the existing ACL modeL relevant laboratory data. ,
LTGMP and associated technicai information, and to provide additional ground water
modeling as appropriate for the above reference project.
RAML is pleased to introduce the staff from Errol L. Montgomery and Associates (M&A)
that have been selected by RAML to perform the requested tasks, A summary of the
M&A's technicai capabilities and project staff resumes are included in this submittal for
your review,
The Action Plan proposed by RAML and M&A is also included in thts submittal for your
review.
The contractor selection and conlract negotiation took longer than anticipated. The
additional time required on the front end of the project should not significantly delay the
subsequent project work or final report timing. It should be noted that the Action Plan
includes a request for the final report due date to be moved from. August 1, 2011 to
August 12. 2011, RAML respectfully requests the DRC to consider this revised final due
date.
If you should have any questions regarding this submittal or if you need additional
information, please feel free to eontact me at [phone] ext 19 or by e-mail at
biHy. wrn..raypbhpbijjiton.com. We look foHA^ard to working with the..DRC to complete this
important project.
Respectfuiiy submitted,
Billy Ray
Rio Algom Mining LLC - Site Manager
Richard Sush-DOE
Tom Rushing - DRC (via e-nian)
•P.O. Box 2V8, Grants. NM- USA 87020 - Tel: [phone] - Fax; 505.285.5550
MONTGOMERY
& ASSOCIATES
Proposal for Groundwater Model Review & Update
Lisbon Uranium Mine, La Sal, Utah
Project Team
Our core team will include Hale Barter, Jonathan
Whittier, and Taylor Shipman. Tim Leo and Leslie
Katz will ser\'e as project advisors.
Hale Barter leads our modeling group and will di- ,
rect the project. He has nearly two decades of mod-
eling experience with a primar> emphasis on mining,
permitting, and groundwater remediation projects.
Hale will ensure that the work is conducted on
schedule and within budget. He will also review all
technical work, communicate with RAML and other
stakeholders, and attend all project meetings.
Jonathan Whittier will conduct data evaluation and
modeling tasks. He brings nearly 10 years of model-
ing experience to this project — experience that in-
cludes developing models to solve a variet\ of min-
ing and environmental problems. He has used flow-
and-transport models to assess feasibility of cleanup
methods, including monitored natural attenuation. In
addition, Jon has evaluated models developed by
others to determine their applicability' for new appli-
cations.
Taylor Shipman will assist in the data evaluation,
speciflcally with the statistical analyses of the water
quality data trends. Taylor has recentiy applied a
broad range of innovative statistical data evaluations
for several key mine permitting projects in the west-
em U.S.
Tim Leo, P.G., will provide senior technical over-
sight for the data evaluation and modeling. He has
over 20 years of modeling experience with an em-
phasis on contaminant fate and transport and
groundwater remediation at industrial and mine
sites. He has developed several models to support
monitored natural attenuation at sites in the westem
U.S. In addition, Tim has direct experience working
on projects for the NRC.
Leslie Katz, P.G., has ser\'ed as the project lead for
several BHP projects. She has extensive experience
managing large-scale, multi-disciplinar\' projects —
including many that incorporate groundwater mod-
els. Leslie has had opportunities to assist clients with
integrating traditional and innovative remedial
strategies at contaminated sites.
Resumes for these professionals follow.
mm ^
^1 BP '"iftl^P PAGE lofl
MONTGOMERY
& ASSOCIATES Resumes
Hale Barter, Principai tlydroiogist
Key Areas of Expertise
Hale Barter leads M&A's
HydroSogc ModeMng g^cup -
over 10 professionals with a
depth of tiieoretical
knovviecige and a breadth of
real-VYorid experience that is
unparaHeled in consulting
firnis bf our size.
Hale has attended short-
courses on various
groundwater modeling
topics: calibration,
stocl-iastic simulation,
discrete-feature data
analysis, geometric
modeling, exploration
simulation, and flow-and-
transport modeling.
He is a member of the
Arizona Hydrological
Society.
Years of experience; 23'
Years at M&A 16
Groundwater modeling for mining, municipal, and industrial clients
Analysis of impacts related to recharge and recoverv' operations
Design of contaminant remediation systems
Analysis of aquifer hydraulic and water qualitv'data
Design and supervision of groundwater qualitv^ monitoring activities
Design and supervision of aquifer testing and monitoring programs
Education
• B.S., Hydrology, University of Arizona (1988)
• M.S., Hydrology, University of Arizona (1995)
Representative Projects
Remediation & Risk Assessment • U.S. Air Force Plant44,Tucson Airport Area
Superfund Site • Raytlieon Company
Led groundwater flow, particle-path, and solute-transport modeling to simulate
TGE and 1,4-dioxane migration, to optimize the pump-and-treat remediation
sv stem, and to estimate future exposure-point concentrations for risk
assessment [PI fViA COU Nr/. AZ]
Feasibility Investigations • Resolution Mine • Resolution Copper
Led modeling and other analyses to evaluate potential surface water /
groundwater interactions in a volcanic, fractured-rock s>'stem for a potential
underground mine [PiNAL COUNTY, AZ]
Tailings Seepage Analysis • Toromocho Project • Minera Chinaico Peru
Planned and supervised groundwater flow and contaminant transport modeting
to evaluate seepage impacts from a proposed tailings facilit> to support an EIS
fJUNi'N, PERU]
Contaminant Transport Analysis* Santa Cruz In Situ Copper Mining Project •
ASARCO LLC
Modeled groundwater flow and contaminant transport for in situ mining
operations in fractured, mineralized bedrock |P!NAL COUNTY, AZ]
."STt-.v- ^S\0 «aiiki>a
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MONTGOMERY
S. ASSOCIATES Resumes
Seepage Analysis • Collahuasi Mine • Compafiia Minera Dona InesdeCollahuasi
SMC
Modeled groundwater flow and contaminant transport to assess the potential
impacts of seepage from a waste-rock dump adjacent to a proposed open-pit
mine in the Salar de Michincha basin iCHtLE]
Tailings Seepage Analysis & APP Support • SierritaMine • Freeport McMoRan
Modeled groundwater flow and solute transport to project the capture of mine
taihngs seepage by interceptor wells and to simulate the potential extent of
sulfate in groundwater [SOUTHERN AZ]
Critical Model Review • Confidential Site • Confidential Client
As part of Arizona adjudication proceedings, reviewed a model and technical
reports by opposing council's consultant and prepared formal comments to
support our client's litigation team [PirflA COUNTY, AZ]
Pit-DewateringAnalysis • Mt. Hope Mine • General Moly, Inc.
Planned and coordinated local-scale groundwater flow modeling in a fractured
bedrock system using telescoping-mesh techniques to simulate pit dewatering
and subsequent groundwater recovery at a proposed molybdenum mine
iEUREKA COUNTY, MV]
Pit-Dewatering Analysis • RosemontMine • Augusta Resources / Rosemont Copper
Company
Designed and provided oversight for numerical groundwater flow model used
to evaluate pit dewatering, post-mining lake development, and associated
drawdown impacts in a fractured bedrock flow system [PiMA COUNTY, AZ]
Hydraulic Continuity Analysis • Confidential Site • Tucson Electric Power Company
Led a technical team in the development of a numerical groundwater flow
model to simulate the interaction between a shallow, alluvial aquifer that is
hydraulically connected to a perennial stream system and a deeper, artesian
aquifer that supplies industrial and municipal water [SOUTHERN AZ]
Wellfield Optimizations • Various Mine Sites • Various Clients
Modeled altemative wellfield configurations to maximize production and
minimize impacts to environmentally sensitive salar lakes and springs iri the
Salar de Coposa, Lagimillas basins, Huachunta, Huarintapana, and Chilota
basins fCHiLE & PERUI
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.i'j* i&kkim . - 4,< , liiwi-*.
MONTGOMERY
& ASSOCIATES Resumes
Jonatiian Whittier, Hydrogeoiogist
Key Areas of Expertise
Jon's modeling sl'^ills are
essential to many of our
water supply and
e n V i r 0 n iri e n ta I p roj e cts,
including those vvith a
remedial design component
He has used flow-and-
transport models to assess
feasibiiity of cleanup
methods, including
monitored natural
attenuation. Where surface
water and groundvvater
systems intesact, he has
successfully developed
models to simulate the
potential impacts froi7"t
pumping.
Jon is proficient in a variety
of modeting tools —
MODFLOW, Groundwater
Modeling System (QMS),
Groundwater Vistas, MTSD,
MODPATH, and PEST - along
with Surfer, ArcGlS, Spatial
Anaiyst, and 3D Analyst.
Years of experience 9
Years with M&A 2
Groundwater flow, contaminant transport, and particle track modeling
Conceptual model development using GIS
Contaminant assessments
Aquifer test design and analysis
Monitored natural attenuation remedies
Evaluation of capture by extraction vvellfields
Education
B.S., Geological Sciences, Universit>' of Maine (1996)
M.S., Hydrology, University of Arizona (2004)
Additional Training
2009: Parameter Estimation (PEST)
Representative Projects
Pit Lake Analysis • RosemontMine • Rosemont Copper Company
Developed a three-dimensional model to evaluate groundwater-level impacts
associated with pit development and post-closure pit-lake conditions; calibrated
the model not only to current groundwater / surface water conditions but also to
the results of a 30-day, multi-well aquifer test [SOUTHEASTERN ARtzoNA]
Wellfield Optimization • Lagunillas Basin • Compania Minera Cerro Colorado
Developed a tiiree-dimensional flow model calibrated to historic groundwater
conditions to evaluate scenarios for managing a production,wellfield in a closed
Andean basin [CHILE]
Tailings Seepage Analysis • Copper Mine • Gallagher & Kennedy, PA
Inventoried seeps and springs; measured seep flow rates; characterized the
qualit>- of seepage, surface water, and groundwater; characterized groundwater
flow; developed a conceptual hydrogeologic model; and evaluated potential
NPDES / APP compliance issues as part of a comprehensive hydrogeologic
investigation [YA.VAPA! COUNTY, AZ]
PAGE3
& ASSOCIATES Resumes
Capture Analysis • Inactive Rancho Cordova Test Site • The Boeing Company
Developed a groundwater flow, contaminant-transport, and particle-tracking
model to evaluate capture for two extraction wellfields; ran two aquifer tests
and recalibrated the model; based on the model results, recommended
modifying extraction rates at some wells and installing additional extraction
and monitoring wells [SACRAiViENTO COUNTY, CAj
Feasibility Analysis • Inactive Rancho Cordova Test Site • The Boeing Company
Developed a groundwater flow, contaminant-transport, and particle-tracking
model to evaluate altemative distributions for extraction and injection
wellfields in a multilayer aquifer system [SACRAIVIENTO COUNTY, CA]
Bioremediation Feasibility Analysis • Aerospace Facility • The Boeing Company
Developed a flow and transport model to evaluate the preliminary feasibility of
VOC bioremediation in a multilayer aquifer system [SOUTHERN CAJ
FeasibilityAnalysis for Monitored Natural Attenuation • Porterville Plant Superfund
Site • Beckman Instruments, Inc.
Developed a groundwater flow and contaminant-transport model to evaluate the
applicability of monitored natural attenuation in a multilayer aquifer system
[TULARE COUNTY, CA]
Feasibility Analysis for Monitored Natural Attenuation • Apache Powder Superfund
Site • Apache Nitrogen Products, Inc.
Developed a groundwater flow, contaminant-transport, and particle-tracking
model to evaluate the feasibility of monitored natural attenuation [COCHISE
COUNTY: AZ] •••.--'.''.•'
Model Evaluation • Chemical Manufacturing Facility • Montrose Chemical Company
Evaluated the feasibility- of increasing the horizontal and vertical discretization
in an existing three-dimensional groundwater flow and contaminant-transport
model for a multilayer aquifer system [LOS ANGELES COUNTY. CAj
Pumping Impact Analysis • Lower San Pedro River Basin • Polsinelli Shughart PC
Developed a three-dimensional model calibrated to historic groundwater /
surface water conditions to evaluate scenarios for managing a production
wellfield in a complex aquifer system [SOUTHEASTERN ARIZONA]
Impact Analysis for an APP • Effluent Recharge APP • City of Avondale
Developed a groundwater flow, contaminant-transport, and particle-tracking
model to project the area potentially impacted by discharge from a proposed
recharge basin [MARiCOPA COUNTY, AZJ
•""""•ii , , , '•^^ PAdf A
i^ii^ d^*^ y.-i , . i . • ' "Wl-T
^ J MONTGOMERY
& ASSOCIATES Resumes
Lesiie Katz, P.G., Hydrogeoiogist, Principai
Key Areas of Expertise
Leslie Katz has ied many
large-scale water supply and
environmental projects. One of
her-areas of e.xpertise is the
analysis of surface water /
grouodwater interactions.. Ms,
Katz often provides key
technical input for'design of
groundwater production,
monitoring, and plume
containment networks, and
vadose zone monitoring
systems.
Years of experience: 26
Years at iVIM: 2:1
Management of environmental and water supply projects
Litigation support for water resources and environmental disputes
Interpretation of aquifer hydraulic and water quality data
Design and management of groundwater monitoring programs
Evaluation of surface water/groundwater interactions
Technical support to acquire and comply with state and federal permits
Design of field investigations to characterize subsurface contamination
Evaluation of remedial altematives and oversight of remedy implementation
Professional Registrations
Registered:Professional Geologist #28245, AZ
Education
• B.S., Geology, Universit}'of Arizona (1983)
• M.S., Hydrology, University of Arizona (1987)
Representative Projects
Technical Oversight • U.S. Air Force Plant 44, Tucson Airport Area Superfund Site •
Raytheon Company
Managed and provided technical oversight for modeling analyses of
groundwater flow, particle pathways, and fate and transport of VOCs and 1,4-
dioxane in groundwater; optimized the pump-and-treat remediation system and
estimated future exposure-point concentrations to asses risk [PiWA COUNTY; AZ]
Project Oversight • Phoenix-Goodyear Airport Superfund Site South • Goodyear Tire
& Rubber Company
Managed the technical review of a model (groundwater flow and TGE
transport) prepared by others to evaluate its use for assessing remedial
altematives, including monitored natural attenuation [F/IARICOPA COUNTY. AZ]
Project Management • North Indian Bend Wash Superfund Site • Motorola Inc.
Managed and provided long-term project support from initial characterization
of VOC contamination through final remedy implementation; oversaw solute-
mmmm PAGES
^ MONTGOMERY
& ASSOCIATES Resumes
transport modeling conducted to evaluate altemative remedial actions as part of
a feasibilit\ study and to support a 5-year review of remedy effectiveness
llVIARiCOPA COUNTY. AZl r • .
Project Design • Project 52nd Street Superfund Site • Motorola Inc.
Evaluated data for various facilities; developed recommendations for required
vadose zone and groundwater investigations to assess the contributions of
Potentially Responsible Parties to the regional contaminant plume
[MARICOPA COUNTY, AZ]
Hydrologic Impact Analysis ' Upper Gila River Basin • ASARCO LLC
Analyzed historical streamflow, reservoir release, and pumpage data to project
impacts to available groundwater reserves [PINAL COUNTV, AZ]
Project Management Hydrogeologic Investigations for Gas Storage • Arizona
Natural Gas Storage LLC
Managed a program to characterize hydrogeologic conditions, evaluate water
supply altematives, and obtain an APP for a planned project that involves salt-
cavem solution mining for underground storage of natural gas
[PiNAL COUNTY, AZl
Project Management • Solana Generating Station APP • Abengoa Solar
Managed a program to obtain an APP for disposal of process wastewater
associated with a planned, large-scale, concentrated solar power facility';
development a monitoring network for a shallow aquifer [MARICOPA COUNTY, AZ]
Project Management • Industrial Wellfield Conversion • Confidential Client
As part of site closure process, managed a large-scale field program to install
new production wells and abandon old ones with the goal of creating a
sustainable, high-quality water supply for future municipal and industrial uses;
project involved interval-specific testing to identify zones with poor water
qualit>' and monitoring to evaluate surface water / groundwater interactions
[PiNAL COUNTY. AZj
Project Management • Cholla Power Plant Wellfield Relocation & Expansion • APS
Managed a comprehensive field program to characterize hydrogeologic and
water quality conditions near the Cholla Power Plant; led the installation arid
testing of 12 production wells and 20 monitoring wells; developed and
implemented a long-term monitoring program [NAVAJO COUNTY, AZ]
r^...-:..i. , . . .
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"2!! PAGE6
MONTGOMERY
& ASSOCIATES Resumes
Timotliy P. Leo, P.G., Hydrogeoiogist
Key Areas of Expertise
Management of groundwater remediation projects
Hydrologic modeling
Hydrogeologic characterization
Contaminant fate-and-transport assessment
Aquifer test design and analysis
In situ treatment of groundwater contaminants
Water quality comphance for APPs
Professional Registrations
Tim Leo is a senior niember
of our Hydroio^c ModeHng
team, where he directs
• studies for a range of
appiieations.
Mr. Leo has over two
decades of experience He
has directed or developed
dozens of .groundwater
mode's to project pst filling
for mine closura. pit
hydraulic capture and water
quality conditions for APP
. compliance, and
groundvv'ater Infi'ow and
dewatering requirements for
an exploration adit; he has
also used models to design
and optimize remsediai well
fields and provide technical
support for environmentai
litigation.
Years of experience; 2.3
Years at MM: 2
• Registered Professional Geologist #33257, AZ
• Registered Professional Geologist #6163, CA
• Certified Professional Hydrogeologist #344, CA
Education
• B.S., Geologv', Bradley University (1983)
• M.S., Hydrology, University' of Arizona (1988)
Representative Projects
Project Oversight • Inactive Rancho Cordova Site • The Boeing Company
Provided strategic direction for the regional groundwater remedy; directed the
latter stages of remedial investigations, groundwater modeling, extraction-well
installation, pilot testing for soui;ce-area treatment, feasibility studies, remedial
action planning, and the conceptual design and operation of pump-and-treat
S>'Stems fSACRAMENTO COUNTY, CA]
Fate & Transport Investigations • State Superfund Site • Calcot, Ltd.
Analyzed fate and transport in the vadose zone for chlorinated organic solvents
to assess risk [FRESNO COUN TY, CA]
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,.s^-4 %-MI:H fe^iiZiaf PAGE 7
MONTGOMERY
& ASSOCIATES Resumes
Sulfate Migration Analysis • Carlota Mine • Carlota Copper Company
Developed a two-dimensional, groundwater flow-and-transport model to
evaluate sulfate migration from tailings impoundments in Pinto Valley
[GiLA COUNTY, AZ] - • ' •
Project Oversight • U.S. Air Force Plant 44, Tucson Airport Area Superfund Site •
Hughes Aircraft Company
Directed the development of a three-dimensional flow and transport model to
determine the relative historical contribution of TCE to supply wells; review ed
models developed by other consuhants [PiiviA COUNTY, AZ]
Tailings Seepage Anatysis • Confidential Copper Mine • Gallagher & Kennedy, PA
Managed a comprehensive hydrogeologic investigation that entailed
inventory ing seeps and springs; measuring seep flow rates; characterizing the
quality of seepage, surface water, and groundwater; and characterizing
groundwater flow, developing a conceptual hydrogeologic model, and
evaluating potential NPDES / APP compliance issues [YAVAPAI COUNTY, AZ]
Hydrogeologic Characterization • Proposed Heap Leach Facility • Gallagher &
Kennedy, PA
Managed a hydrogeologic characterization investigation at a copper mine to
assess project feasibility^ and potential impacts to groundwater and surface
water quality [GREENLEE COUNTY, AZ]
Heat-Transport Analysis • Oracle Nuclear Waste Site • U.S. Nuclear Regulatory
Commission
Modeled heat transport to assess tiie potential for using heat as a groundwater
tracer in fractured rock (performed in conjunction with the siting of a nuclear
waste repository) [PliViA COUNiY. AZ] -
Model Post Audit • Beckman Instruments Superfund Site • Beckman Instruments
Directed the post audits of a groundwater model; recalibrated to obser\'ed water
level / quality conditions and used results to negotiate a reduction and early
shutdown of wellfield operations with the EPA [TULARE COUNTY, CA]
Model Post Audit • Industrial Facility • Hughes Aircraft Company
Directed the post audits of a groundwater model; recalibrated to observed water
level / quality conditions and used the results to reduce wellfield operation costs
fORANGE COUNTf, CA] ' "
mmmm mmmm ' - "^ »^ • ^
PAGES
MONTGOMERY
S. ASSOCIATES Resumes
Tayior Shipman, Water Resource Economist / Hydrogeoiogist
Key Areas of Expertise
An expei t in the area, of
water economics, Taylor
Shipman helps M&A's
clients answer questions
about the sale, lease,
transfer, valuation, and
• mari-^et development of
various water supplies.
ayfor is one of the editors of
M&,A's Arizona Water Pohcy
• & Reporting Service.
• Years of experience: 4
• Years vvith P^M: 3
Statistical analysis of physical and economic datasets
Quantitative analysis of resource management strategies
Market valuation of water resources
Technical support for groundwater modeling investigations
GIS database development and maintenance
Water policy analysis
Education
B.S., Geology, Wheaton College (2006)
M.S., Agricultural & Resource Economics, University of Arizona (2008)
Representative Projects
Groundwater Modeling • Collahuasi Mine • Compania Minera Doiia Ines de
Collahuasi SMC
Developed a numerical groundwater flow model to quantify wellfield
performance over time; developed and managed large hydrogeologic datasets
[REGION L CHILE]'.
Cost Model for Recovering Stored Water • Constructed Recharge Project Site •
Central Arizona Project
Developed a cost model to optimize the system design for recovering 2 million
acre-feet of stored water; quantified the marginal effect of key variables such as
pumping energy rates, pumping water levels, equipment prices, and well
dispersion on recovery cost [fVfARicoPA COUNTY, AZj
Water Supply Acquisition Study • Fort Huachuca
Evaluated potential altematives for augmenting water supplies; characterized
the pohtical, economic, legal, and physical challenges and critical uncertainties
related to each supply [COCHISE coufffY, AZ]
Water & Energy Portfolio Diversification • Hopi Reservation & Federal Trust Lands •
Hopi Tribe
Developed an economic model to demonstrate the impacts of shortage; used the
model to assess the effect ofwater policy constraints and opportunities, both ,
•••3 —""Ttil .
^is&^M '&&f>ii^ \in£x^ k'S^. PAGE9
^ j MONTGOMERY
S. ASSOCIATES Resumes
existing and potential future, on the price and availability of supplies;
developed a 10-year plan for acquiring and managing water supplies
[NORTHERN AZ] - •
Water Resource Valuation • Various Sites • Various Clients
Estimated the fair market value of various w ater-resource assets for potential
buyers and sellers [CENTRAL AZ;
Brackish Groundwater Marketability Study • SunCal Companies
Helped determine tiie feasibility of developing and marketing brackish
groundw ater sources by assessing the likely willingness of buyers to pay for the
supply [BERNALILLO COUNTY. Nfvll
Litigation Support • Bryan Cave, LLP
Analyzed seven decades ofhistorical crop-water, commodity price, and
streamflow data and applied hedonic price techniques to estimate the marginal
value of water in agricultural production over time [CENTRAL AZ]
PAGE 10
MONTGOMERY
S ASSOCIATES 1550 East Prince Road
TucsoixAZ 85719
TIL 520 881-4012
FAX [phone]CSI
MEMORANDUM
DATE: June 1,2011 PROJECT: 1350.01
TO: Billy Ray
RIO ALGOM MINING LLC
FROM: Hale Barter and Tim Leo
MONTGOMERY & ASSOCIATES
SUBJECT: ACTION PLAN TO ASSESS OUT OF COMPLIANCE
CONDITIONS AT TARGET ACTION LEVEL WELL RL-1,
RIO ALGOM MINING LLC - LISBON OPERATION
In accordance with Out of Comphance License Condition 53.C.(3) for the Rio Algom Mining,
LLC - Lisbon Operation, Montgomery & Associates (M&A) has prepared an Action Plan to evaluate the
Uranium Target Action Level exceedances at well RL-1 and possible actions needed to restore and
maintain compliance witii License Condition 53.B, as instructed in the February 7, 2011 letter fi-om Utah
Department of Radiation Control (UDRC, 2011). Specific performance objectives to be addressed during
implementation of the Action Plan include:
a. Justify whether the current RL-1 data set is or is not sufficient to depict the Uranium
concentration trend;
b. Conclude with definitive evidence whether the Lisbon Valley Facility is operating within or
outside of tiie analyzed condition of tiie Nuclear Regulatory Commission (NRC) approved
"Application for Ahemate Concentration Limits" (ACL) (approved May 11, 2004)', and
Long-Term Groundwater Monitoring Plan (LTGMP), and; . • ~; '
c. Determine whether the ACL model should be revisited/revised- to account for more recent
data (UDRC, 2011).
The Action Plan includes the following tasks:
Task 1
Task 2
Task 3
Data and Site Characterization Review
Model Review
Prepare Report
MONTGOMERY
& ASSOCIATES
TASK 1: DATA AND SITE CHARACTERIZATION REVIEW
In general, the data evaluation conducted in Task 1 will largely address performance objective (a). The
follow ing data and information will be evaluated during Task 1:
Overall conceptual model of groundwater flow system
Groundwater level data
Water quality- data, and sampling and laboratory' protocols: generally focused on uranium
Monitor well construction and sample depth intervals .
Geologic and hydrogeologic site characterizations
Aquifer testing procedures and results
Characterization of sources for uranium groundwater contamination
The Task 1 evaluation will determine-if (1) measured uranium concentrations from well RL-1 are
representative of actual conditions; (2) apparent increasing uranium concentrations in RL-1 are
representative of an actual increasing trend; (3) trends in concentrations are consistent with the conceptual
understanding of groundwater movement, contaminant sources, and contaminant migration; and (4)
correlation of uranium concentrations between RL-1 and other monitoring locations and correlation of
uranium and other constituent concentrations at well RL-1 are explainable based on tiie current
conceptual site model (CSM). Statistical methods may be-used to evaluate trends in the RL-1 uranium
concentration data to tiie extent required. Recommendations from Task 1 may include identification of
additional data requirements necessary to understand current and future uranium concentrations at well
RL-1 and downgradient wells.
TASK 2: MODEL REVIEW
In tandem with Task 1, the model review conducted in Task 2 will address performance objective (b).
Task 2 will also address performance objective (c). In Task 2, M&A will conduct a tiiorough review of
the groundwater computer model and the model projections presented in the Response to Request for
Additional Information (RAI) (Komex, 2003) and tiie LTGMP (Komex, 2004). As a first step in tiie,
model review, M&A will evaluate the CSM used to develop the computer model. The data review
conducted in Task 1 will support the CSM evaluation. Important elements of the CSM include the
occurrence and hydraulic properties of hydrogeologic units, directions and rates of groundwater flow, tiie
nature and strength of tiie tailings source, fate and transport processes for compounds of concem in tiie
vadose and groundwater zones, and the study area hydrologic water balance.
Groundwater modeling at the Lisbon site has included flow and transport modeling, tailings drainage
modeling, and geochemical modeling. The geochemical modeling will not be reviewed during this
project, the flow model review will include evaluation of the grid, layers, initial and boundary
conditions, aquifer hydraulic conductivities, recharge, and calibration to observed water level data. The
transport model review will include evaluation of the fate and transport parameters and contaminant
sources, and comparison between the observed and model-proj ected concentrations. The transport model
was not formally calibrated to observed trends in concentrations of site compounds of concem (COCs) in
groundwater. As part of Task 2, M&A will graphically compare obsen/ed and projected, COC
concentrations (with focus on uranium) for the period 2003 tiirough present to assess how well the current
transport model matches recently observed concentration trends.
MONTGOMERY
& ASSOCIATES
The overall quality of the flow and transport model calibration to groundwater levels and COC
concentration data wilf largely determine its reliability for projecting future uranium (and other COCs) at
the site W'ells. Depending on tiie results ofthe model evaluation, revision of the modei to achieve an
acceptable calibration to observed COC concentrations may. be required to improve the model's
predictive capability for responding to the conceras of UDRC on this project.
TASK 3: PREPARE REPORT
A report will be prepared to summarize the activities and results of Tasks 1 and 2. The report will
speciflcally address each perfomiance objective.
PROJECT PROGRESSION AND SCHEDULE
UDRC requested a logic diagram and schedule as part of the Action Plan. This section addresses these
requirements in a narrative form. As indicated above, we anticipate addressing performance objective (a)
during Task 1 (Data and Site Characterization Review) and performance objectives (b) and (c) during
Tasks 1 and 2. Some of the work required for Task 1 was completed during preparation of the Action
Plan and in preparation for a site visit that was conducted by M&A on May 24, 2011. The data and site
characterization review are ongoing and are anticipated to be completed by June 24, 2011. Review ofthe
existing groundwater model (Task 2) will be conducted concurrently with Task 1. The model review is
anticipated to be completed by July 8. The report (Task 3) will be submitted on or before August 12,
2011.
Rio Algom Mining LLC requests that UDRC approve this work plan witiiout a logic diagram. Further,
Rio Algom Mining LLC requests that the report due date be August 12 instead of August 1, 2011.
REFERENCES
KOMEX, 2003, Response to Request for Additional Information (RAI), Application for Altemate
Concentration Limits Source Materials License SUA -119, Rio Algom Mining LLC, Lisbon
Facility, La Sal, Utah: prepared for Rio Algom Mining LLC, October 13, 2003.
, 2004, Long-Term Groundwater Monitoring Plan, Application for Altemate Concentration Limits
Source Materials License SUA -119, Rio Algom Mining LLC, Lisbon Facility, La Sal, Utah:
prepared for Rio Algom Mining LLC, Febmary 19, 2004.
Utah Division of Radiation Control, 2011, DRC Notice of Enforcement Discretion and Confirmatory
Action Letter: letter sent to Chuck Wentz, Rio Algom Mining LLC, Febmary 7, 2011.
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