DRC-2011-001709 - 0901a068801ff33e

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieuiennnl Governor
Department of
Environmental Quality
Amand.i Smith
E.xeciitive Director
DrVl.SION OF RADIATION CONTROL
Rusty Lundberg
Director
C-201 1-00 1709
MEMORANDUM
TO: File n
THROUGH: Loren Morton, P.G., Manager
FROM: Tom Rushing, P.G. jj< ^^^/'^
DATE: February?, 2010
SUBJECT: Review of the August 17, 2010 Semi-Annual Groundwater Stability Monitoring
Report, 1^' Half 2010, Rio Algom Mining L.L.C, Lisbon Facility, Received August
25, 2010 Radioactive Materials License No. UT1900481, Amendment 3
The Utah Division of Radiation Control (DRC) has reviewed the 2010 l" Half Groundwater
Stability Monitoring Report submitted by Rio Algom Mining L.L.C. (Rio) for the Lisbon Facility.
DRC review comments are below.
Report Content
The Report is broken into 9 sections. The sections are organized as follows:
1- Discussion
2- Analytical Data (Spreadsheets)
3- Time vs. Concentration Plots (Chloride, Sulfate, TDS, Arsenic, Molybdenum, Selenium,
Uranium)
4- Depth to Water Plots over time for the wells
5- Hydrographs for the wells
6- Field Data Sheets
7- Laboratory Analytical Repoils
8- Groundwater Contour/Concentration Maps
9- Sampling Methodologies (Low Flow Sampling Information)
The Report was reviewed to deteiTnine compliance with the Radioactive Materials License for the
facility. No. UT1900481, Amendment 3, Condition 53.
195 North l')50 West •Salt LakeCity. UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
ivn n-.dfq.ulah.i^oy
Prinlcd on I00':4' recycled piiper
Rio Algom Mining Lisbon Valley
2010 Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Page 2
Review for Compliance with Condition 53
Finding:
The Report was received on August 25, 2010. Per the License requirement in Condition 53.G.
(Table 4) the first semi-annual report is due by September 1 following the report period; therefore
the report was submitted on time
Finding:
One sample event in the period is listed on the data sheets (Samples collected April, 2010).
License requirement 53.G. The sample event per this Report conforms to time periods required by
the License (Semi Annual).
Finding:
The following text and tables summarize the reported concentrations for the parameters listed in
the License.
Review of data for "point of compliance" wells EF-3A and OW-UT-9 for the quarterly sampiing
events revealed that none of the.reported values exceeded the ACL maximum concentrations
listed in the License.
Table 1 - Reported Concentrations Values for the • ACL's listed in the License - Point of
Compliance (POC) Wells
Well
No.
Sample
Date
Mo
ACL
(mg/L)
Mo
Measured
(mgA.)
Se
ACL
(mg/L)
Se
Measured
(mg/L)
As
ACL
(mg/L)
As
Measured
(mg/L)
U
ACL
(mg/L)
U
Measured
(mgA.)
EF-3A 4/28/10 23.34 5.1 0.93 0.045 3.06 0.417 96.87 25.5
OW-
UT-9
4/29/10 58.43 50.0 0.10 0.043 2.63 2.21 101.58 84.0
Review of data for "point of exposure" wells RL-4, RL-5, and RL-6 for the quarterly sampling
events revealed that the reported concentrations for Uranium are below the uranium compliance
limits listed in Condition 53.B. of the License.
Table 2 - Reported Concentrations for Uranium Compared with Compliance Limits in the
Well No. Sample Date License Uranium
Compliance Limit
(mgA.)
Uranium Measured
(mg/L)
RL-4 4/27/10 0.32 0.0033
RL-5 4/27/10 0.32 0.0022
RL-6 4/28/10 0.32 0.0177
Review of data for trend wells EF-6, EF-8, ML-1, RL-1, RL-3 and H-63 revealed that laboratory
results for Uranium at Trend Well RL-1 exceed the License Uranium Target Action Levels for the
wells listed in the License. Additional infoiTnation conceming the DRC review is included in the
Rio Algom Mining Lisbon Valley
2010 U'Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Page 3
RL-1 Uranium POOC/OOC and Increasing U Trend section below. Per DRC review none of the
other trend wells exceeded the License target action levels for Uranium.
Table 3 - Reported Concentrations for Uranium Compared with Uranium Target Action Levels -
Trend Wells
Well No. Sample Date License Uranium
Target Action Level
(mgA.)
Uranium (mg/L)
EF-6 4/28/10 3.9 0.740
EF-8 4/28/10 0.30 0.183
ML-1 4/28/10 0.26 0.0142
RL-1 4/29/10 42.1 43.8
RL-3 4/28/10 37.3 11.1
H-63 4/27/10 0.06 O.OIOI
LW-1 4/27/10 0.028 0.0020
RL-1 Uranium POOC/OOC and Increasing U Trend
DRC received notification from Rio Algom that the April sample results for Uranium at well RL-
1 exceeded the Uranium License Target Action Levels on May 19, 2010 (via letter to Dane
Finerfrock). A copy of the letter is attached to this memo (Appendix 2). Per DRC review of the
EnergyLaboratories sheet submitted wilh the 1^' Semi Annual report it was noted thaqt the report
was issued on May 17, 2010. DRC noted that the notification was within the 30 day notification
requirement of License Condition 53.C.(1) Probable Out of Compliance Status (POOC).
Rio Algom instituted elevated quarteriy sampling for U at well RL-1 per the requirement of
License condition 53.C.(2) POOC. Per communication with Rio Algom representative, Chuck
Wentz. it was noted that quarterly samples were taken August 2010 (3'^'' Quarter) and October
2010 (4''^ Quarter). Per e-mail communication with Rio Algom it was noted that the August'
sample result was above the target action level which should have prompted Rio Algom to report
OOC status at the well and provide notifications of such change of status, elevate the sampling to
monthly, and re-evaluate the ACL model. It appears however, that Rio Algom did not implement
these OOC requirements.
The "Uranium Target Action Level" listed in table 3 of the License was based on breakthrough
curve predictions (best estimate high) listed in the Rio Algom Long-Term Groundwater
Monitoring Plan (LTGMP). It was noted that the breakthrough curve plots generate 3 lines:
• Best Estimate (Model) Curve
• Low Target Concentration
• High Target Concentration
Rio Algom Mining Lisbon Valley
2010 U' Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Page 4
The high and low target concentrations were generated based on sensitivity analyses indicating
that uranium concentrations in site monitoring wells may vary from the "best estimate" prediction
by a factor of approximately 0.31 to 3.4. It was noted that the Uranium ACL for well RL-1 was
approved by the Nuclear Regulatory Commission and used the highest value for the High Target
Concentration, 101.58 mg/L. DRC additionally notes that all monitoring wells (POC, POE, Trend
and Background) on the eastem arm of the plume were given the same ACL regardless of
anticipated breakthrough concentrations. Based on past DRC review of the NRC approved
ACL's, DRC felt it prudent in the interest of environmental health to choose more realistic values
of maximum breakthrough concentrations.
Therefore, the facility License does not use the LTGMP ACL value (approved by NRC) but
instead uses the high value for the best estimate curve (42.1 mg/L) for well RL-1 and prescribes 3
specific requirements (53.C.(1), (2) and (3)) for OOC compliance status if this value is exceeded
for two consecutive sampling events. These requirements are:
1) Verbally notify the Executive Secretary within 24 hours of discovery of the event; followed by
a written notice within 5 days of verbal notification:
2) Initiate monthly ground water sampling for the exceeded parameter in the well indicating the
exceedence unless the Executive Secretary determines that other periodic sampling is
appropriate, until the event is resolved to the Executive Secretary's satisfaction:
3) Prepare and submit within 30 days of discovery a plan and schedule to evaluate and assess the
source of the exceedence and possible actions needed to restore and maintain compliance with
License Condition 53.B. Such actions may include but are not limited to:
a) Re-evaluation of the ground water flow and contaminant transport models used to set
compliance limits and target action levels:
b) Additional site investigation and characterization, and investigation of potential
contamination sources, and:
c) Active ground water remediation deemed necessary by the Executive Secretary.
Rio Algom Mining failed to comply with the above 3 License Conditions.
Per Rio Algom e-mail notification to DRC on December 20, 2010, it was reported that the
October sample result for Uranium at RL-1 (4"^ Quarter) was below the License Target Action
Level. DRC also noted that August 2010 split sample result from the DRC contract laboratory
(Eberiine Services) for Uranium at RL-1 (39.5 mg/L) was below License Target Action Level. .
Per a telephone conversation between DRC and Rio Algom representatives on January 4, 2010,
Rio Algom representatives reported that they were unclear regarding the OOC status definition
and thought that OOC status would not occur unless two consecutive exceedences occurred after
the original POOC exceedence. This Rio Algom interpretation would have required 3 consecutive
quarterly exceedences prior to OOC status. While DRC feels that the License condition is clear
(OOC is defined as two consecutive exceedences), DRC does understand that this is the first
violation of the License for OOC reporting and that the current License Modification (License
UT190048I Modification 3), which included an update to the OOC reporting requirements, was
recently issued (signed by the Executive Secretary January 2, 2010).
Rio Algom Mining Lisbon Valley
2010 1" Semi Annual G round Water Stability Monitoring Report
DRC Review Memo
Page 5
Based on these findings, DRC will not pursue formal enforcement action for the above violations
and will instead use Enforcement Discretion based on the following justifications:
1. This is a first time violation regarding OOC status notifications and required follow-up
actions,
2. The Rio Algom 4'^ quarter (October 2010) sample result was below the License Target
Action Level for Total Uranium at RL-1 (40.1 mg/L as reported to DRC via e-mail dated
12/20/2010),
3. The DRC RL-1 Uranium split sample result for the 3''' quarter (August 2010) was below
the License Target Action Level,
4. Rio Algom has agreed to provide additional investigation/deliverables regarding the
apparent increasing uranium concentration trend at RL-1 as outlined in the "Confirmatory
Action" section below.
Confirmatory Action
Per DRC review of the time versus concentration plot and plotted regression line for well RL-1,
included with the 2010 1^' Semi-Annual Groundwater Stability Report (includes 28 plots
beginning in January, 2003 to present), an increasing U trend is shown for well RL-1. The
increasing trend is not in conformance with the Long Term Ground Water Monitoring Plan,
prepared by KOMEX, February 19, 2004 (LTGMP), predicted breakthrough curve for RL-1
which depicts a decreasing U concentration trend (Figure 6 of the LTGMP).
Based on this finding, the following confirmatory actions were negotiated during; 1. A telephone
conference call amongst Chuck Wentz (Rio Algom), Billy Ray (Rio Algom), Loren Morton
(DRC) and Tom Rushing (DRC) on January 26, 2011: 2. A follow up e-mail from Chuck Wentz
on January 27, 2011, and: 3. Subsequent conversations and e-mails between Rio Algom and DRC:
1. Rio Algom will hire an independent consultant, qualified to; 1. Review pertinent
information and documents, including the existing ACL model, relevant laboratory data,
LTGMP and associated technical information, and; 2. Provide potential additional ground
water modeling (revised ACL model) as appropriate. Per the January 27, 2011 e-mail, Rio
Algom expects that a qualified consultant can be under contract within 1 month of receipt
of this Confirmatory Action Letter (CAL). Rio Algom will notify DRC once the contract
has been finalized and provide information regarding the contractor name and individual
qualifications;
2. On or before May 1, 2011 Rio Algom will provide the Executive Secretary a detailed
written action plan and schedule for the investigation. The action plan is subject to review
and approval by the Executive Secretary. The action plan and schedule will include a
logic diagram identifying all actions, including dates that those actions will be initiated and
completed, necessary to achieve outlined performance objectives. Performance objectives
include but are not limited to:
a. Justify whether the current RL-1 data set is or is not sufficient to depict the U
concentration trend;
Rio Algom Mining Lisbon Valley
2010 U' Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Page 6
b. Conclude with definitive evidence whether the Lisbon Valley Facility is operating
within or outside of the analyzed condition of the Nuclear Regulatory Commission
(NRC) approved "Application for Altemate Concentration Limits" (Approved May
11, 2004), and LTGMP, and;
c. Detennine whether the ACL model should be revisited/revised to account for more
recent data.
3. On or before August I, 2011 Rio Algom will provide the Executive Secretary a written
final report. The report shall provide conclusions for all performance objectives listed in
the approved action plan and schedule.
DRC received confirmation of concurrence by Rio Algom with the above confirmatory actions
and schedule, after Rio Algoms review of a draft of this letter, via e-mail from Chuck Wentz dated
2/3/2011.
OA/QC Review
Finding:
QA/QC reporting requirements are found in Section 53.G. of the License as a series of footnotes
to Table 4. Reporting requirements include the following items: 1. Sampling Methodology, 2.
Field Parameter Measurements, 3. Laboratory Infonnation, 4. Data Evaluation, 5. Copies of Field
Measurements, 6. Laboratory Analytical Reports, and 7. Chain-of-custody Documentation.
Per DRC review all of the above required items were included with the Report. It was noted that
Rio does not provide a separate section detailing their own validation of sampling methodologies
and sample results, however, this type of evaluation is not clearly required by the License at the
time of this review.
All laboratory data and QA/QC was included with the Report. This includes verification of chain--
of-custody protocol. DRC noted that all TDS samples were analyzed by the laboratory within
sample holding time (EPA Recommended, 3 days). This is an improvement from past reports
which have flagged TDS holding times, typically for several of the samples.
Sampling analysis was conducted by Energy Laboratories. Energy Labs holds a current UT
certification. No. WY00002 which is valid through June 30, 2011.
Rio Algom field methodology for well sampling is conducted per ASTM Designation D 6771-02
"Standard Practice for Low-Flow Purging and Sampling for Wells and Devices Used for
Groundwater Quality Investigations." Per past correspondence with Rio Algom, as well as in-
house discussion regarding the current sample collection protocols used by Rio Algom, there are
concems regarding the quality of the sampling protocols; however, these are currently being
addressed according to comments generated during the Rio Algom/DRC split sampling events.
DRC has noted that Rio Algom generally addresses all DRC comments and that there has been
continual improvement in the sampling protocols as well as improvements in the collection
devices/field calibrations etc.
Background Concentration Wells Review
Table 4 - Reported Concentrations for Background Wells Compared with Established Background
Rio Algom Mining Lisbon Valley
2010 1^' Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Page 7
Well No. Sampled
Date ;
iVsfysA '?'f
Established
Background .
'(n^)
U-Nat
Measured
(mgA.) .;
^'•As^'--'
Established
Backgrourid
Measured
;|ing/l.) i,,.
Md-'- . ' • •
Established
Baiikgroundii.
(mgL) '^^
VMxy-";'
Measured
(mg4) . ...
Se
Established
Background
(iiig/L) ^
Measured
MW-13 4/27/10 0.02 0.0168 0.066 0.027 0.05 <0.1 0.01 0.008 ,
MW-5 4/27/10 0.01 0.0071 0.05 0.028 0.07 <0.1 0.01 0.061
The reported concentration values of Se at background well MW5 continue to be elevated above
the background concentration, 0.01 mg/l per the quarterly monitoring data. The measured
concentration has consistently averaged around 0.06/0.07 mg/L since the beginning of ground
water quality data collection at the well. On this report the reported value for Se was 0.061 mg/l
for the April 27, 2010 sampling event. The Report does not include an explanation of the elevated
concentrations or propose any changes to background selenium concentrations other than making
note of the exceedences and noting that the Class III Utah water quality standards are not
exceeded. Effective with the Febmary 25, 2010 Report there have now been 15 consecutive
sampling events where selenium levels in well MW-5 have exceeded the background
concentrations. However, the License does not require explanation or additional actions if
established background is exceeded.
Time vs. Concentration Plots
Per review of the current report, an upward trend was noted for Total Uranium at well RL-1. Per
DRC negotiations with Rio Algom, a full evaluation of the ACL vs. current conditions will be
provided by Rio Algom. The evaluation will utilize an independent consultant. Details are
included in the "RL-I Uranium POOC/OOC and Increasing U Trend" section above.
Groundwater Concentration Contour Maps
Per DRC Review the submitted concentration contour maps are in compliance with the License
and also continue to address past requirements according to DRC confirmatory action letters.
Groundwater Stabilitv Monitoring Report Conclusions
The 2010 1*' Half 2010, Rio Algom Groundwater Stability Monitoring Report is generally in
compliance with License Condition 53.
However a Notice of Enforcement Discretion and Confirmatory Action Letter will be sent to the
facility as detailed in the "RL-1 Uranium POOC/OOC and Increasing U Trend" section above.
The Confirmatory Action Letter will require Rio Algom to evaluate whether the facility is
operating within the ACL analyzed condition. This is deemed necessary based on the observed
increasing uranium trend at well RL-1 which is not in conformance with the ACL model
projections.
References
Rio Algom Mining LLC, Groundwater Stability Monitoring Report - l" Half 2010, August 17,
2010
Utah Radioactive Materials License No. UT1900481, Amendment 3
Rio Algom Mining Lisbon Valley
2010 1^' Semi Annual Ground Water Stability Monitoring Report
DRC Review Memo
Pages
Application for Altemate Concentration Limits Source Material License SUA-119, Lewis Water
Consultants Inc. March I, 2001
Response to Request for Additional Information, Application for Altemate Concentration Limits
Source Materials License SUA-1119, Komex, October 13, 2003
Rio Algom, May 19, 2010 letter from Chuck Wentz (Rio Algom) to Dane Finerfrock (Co-
Executive Secretary) notifying DRC of POOC status at Monitor Well RL-1
Long-Term Groundwater Monitoring Plan, Application for Altemate Concentration Limits Source
Material License SUA-1119, Rio Algom Mining LLC, Lisbon Facility, La Sal, Utah, Komex,
February 19, 2004.
Rio Algom Lisbon Valley
Semi Annual Groundwater Stability Monitoring Report 2010
DRC Review Memo - Appendices
Appendix I - Ground Water Module 30 Form
Utah Division of Radiation Control Inspection Foim
Ground Water Module 30 (Semi-Annual Ground Water Monitoring Report)
Rio Algom Mining Company ;
Lisbon Valley, Utah
Regulatory Requirements Inspected Against: Radioactive Materials License # UT 1900481,Condition 53
License-in-Force (date): February 2, 2010 (major modification number 3)
Applicable License Conditions: Condition 53 Ground Water Compliance Monitoring
Last Previous Inspection Date: March 15, 2010
Date(s) of Current Inspection: December 27, 20010
Violations Recommended: • Yes ^ No
Notes:
INSPECTION ITEM - Ground Water Monitoring Reporting (Module 30):
(check all that were included as part of this inspection)
Reporting Year: 2009
• A) Ground Water Monitoring Report (First Semi-Annual)
^ B) Ground Water Monitoring Report (Second Semi-Annual)
Ground Water Monitoring Requirements
1. Were the following wells monitored:
A. Background Samples - wells MW5 and MWI3?
^ Yes • No
B. Trend Samples - wells EF-6, RL-1, RL-3, EF-8, ML-1, H-63, and LW-1?
13 Yes • No
C. Point of Compliance (POC) samples - wells EF3A, OW-UT-9?
13 Yes • No
D. Point of Exposure (POE) samples - wells RL-4, RL-5, and'RL-6?
^ Yes • No
Notes:
2. WeU or Boring Installation Notification (Condition 53.H) - Were any borings or monitoring wells
reported to have been installed in any areas of potential groundwater impact, by either Rio Algom or any company
holding private mineral rights?
• Yes 13 No
A. If yes, was the Executive Secretary notified a minimum of 30 days prior to installation?
I I Yes Q No *see notes below
B. Does it appear that proper drilling techniques were employed?
r~] Yes No *see notes below
Notes: *There are ongoing drilling issues within and directly surrounding the LTSM boundary. DRC has
coordinated with the Utah Division of Oil, Gas and Mining and the Bureau of Land Management regarding
concems of cross contamination from the shallow aquifer to the deeper aquifers. Through DRC communication,
Rio Algom LLC is now being contacted by DOOM directly for input if any drilling is proposed in or near the
LTSM.
Also, a proposed irrigation project utilizing a water right directly east of the facility is also proposed (Redd
Ranches), BLM is in the process of approving an EA regarding the ground water withdrawal(s). DRC coordinated
with BLM regarding the well locations (see DRC Review Memo).
Rio Algom Mining Company
Module 30 Inspection Form Paae 2 of 5 Form Updated 12/17/2010
Ground Water Analysis Requirements
Laboratorv Requirements
3. Were all samples analyzed by a Utah Certified Laboratory?
Yes • No
Lab Name: Energy Laboratories
Certificate No.: Cert No. WY00002, Utah Track 3072350515 valid through: June 30, 2010
Notes: Energy Laboratories is reviewed for compliance annually by the Utah BLI
4. Did methods used to analyze ground water samples comply with the following:
A) Methods cited in UAC R317-6-6.3.L; and
B) Have detection limits which are less than or equal to the License Condition 53, Tables
1 through 3.
13 Yes • No
Notes:
5. Were the following laboratory parameters measured for each sample?
Parameter Y/N - Comments
Uranium Y - Method E200.8
Molybdenum Y - Method E200.8
Selenium Y-Method E200.8
Arsenic Y - Method E200.8
pH Y
TDS Y - Method A2540 C
Chloride Y - Method E300.0
Sulfate Y - Method E300.0
Bicarbonate Y - Method A2320 B
Water level elevations Y - Per ASTM Field Methods
Notes:
Yes • No
Reporting Requirements (Condition 53.G, Tables 4-6)
6. Report Submittal Date- Were semi-annual monitoring report(s) submitted on or before the following
deadlines:
First Semi-Annual Report - September 1
Second Semi-Annual Report - March 1
^ Yes • No
• Yes • No
Notes:
Ground Water Monitorins Reporting Content Requirements (Condition 5.?.G)
7. Does the monitoring report include the following criteria?:
Rio Algom Mining Company
Module 30 Inspection Form Page 3 of 5 Form Updated 12/17/2010
A. Sampling Methodology
Description of sampling equipment, purging volume, technique,etc.
^ Yes • No
Notes: The submission includes an Appendix with the ASTM sampling methodology (low flow purging)
which is being undertaken by Rio.
B. Field Parameter Measurements ^ Yes • No
Notes: The submission appears to comply with the License requirements.
C. Laboratory Information
Laboratory name, location, state certification, adequate MDL's and QA/QC validation, copies of laboratory
data, and, chain of custody form:
13 Yes • No
Notes:
The submission includes copies of the laboratory data sheets, QA/QC validation samples and results, and the work
order receipt checklist which indicates chain of custody presence and condition. A copy of the state certification
was not provided, however, this information is not required by the License and was obtained by looking on the
Utah Department of Health website.
D. Data Evaluation
Concentration vs. time plots, interpretation of data, time series trends:
^ Yes • No
Notes:
E. Figures - Ground water contour map, uranium concentrations versus the predicted concentration for
compliance wells, isoconcentration map for each of the following: arsenic, molybdenum, selenium, and
uranium.
13 Yes • No
Notes:
Compliance Limits (Condition 53.B and C)
8. Were all concentrations reported found to be below the Compliance Limits established in Tables 1, 2 and 3 in
the license as shown below?
TABLE 1: POINT OF COMPLIANCE (POC) WELLS'
Well Other
ACLs (mg/L)'
Uranium ACL (mg/L)'
EF-3A Molybdenum = 23.34
Selenium = 0.93
Arsenic = 3.06
96.87
OW-UT-9 Molybdenum = 58.43
Selenium = 0.10
Arsenic = 2.63
101.58
TABLE 2: POINT OF EXPOSURE (POE) WELLS*
Rio Algom Mining Company
Module 30 Inspection Form Page 4 of 5 Form Updated 12/17/2010
Well Uranium Compliance Limit (mg/L)
RL-4 0.32-
RL-5 0.32-
RL-6 0.32^
TABLE 3: TREND WELLS*
Well Uranium Target Action Level (mg/L)
EF-6 3.9'
EF-8 0.30'
ML-1 0.26"
RL-1 42.1"
RL-3 37.3"
H-63 0.06"
• Yes No
Notes:
9. If "no", list wells exceeding the above listed Compliance Limits in the following table:
Well ID Type of Well
(POC,
Trend, FOE)
Coiistituent in Excess
ofACL
Concentration Compliance Limit
RL-1 Trend Well Uranium 43.8 42.1
•
Out of Compliance Status (Condition 53.C (1)
10. In the event of Out of Compliance Status, answer the following questions:
a) Was the Execudve Secretary notified verbally within 24 hours following receipt of out-of-compliance
data?
^ Yes • No
Notes:
b) Was the Executive Secretary notified in writing within 5 day following receipt of out-of-compliance data?
13 Yes • No
Notes;
11. Was accelerated ground water sampling, in conformance with the License, initiated for the exceeded parameter
in the well indicating exceedance, or as specified otherwise by Executive Secretary:
Rio Algom Mining Company
Module 30 Inspection Form Page 5 of 5 Form Updated 12/17/2010
^ Yes • No
Notes:
12. Did the licensee prepare and submit within 30 days of discovei-y a plan and schedule to evaluate and assess the
source of the exceedence and possible actions needed to restore and maintain compliance with License
Condition 53.C:
• Yes ^ No
Notes: Per the License requirements, the source plan and schedule is not required unless the exceedences
result in Out of Compliance (OOC) status. The exceedences and follow up actions are currently under the
requirements for POOC and thus this plan was not required.
11. Additional Records Requested/Inspected:
Notes:
Inspection Staff: Tom Rushing, PG
Range of Records Inspected: From: L' Semi Annual 2010 GW Stability Report 1/1/10 To: 6/30/10
Modular Permit Inspection Form Version 1. updated December. 2010
F:\Rio AlgoniNGroundwater Monitoring Ist 20IO\RioLisbonGroundwaterStabilitylst2010ModuleForm30.doc
Rio Algom Lisbon Valley
I^' Semi Annual Groundwater Stability Monitoring Report 2010
DRC Review Memo - Appendices
Appendix 2 -May 19, 2010 Rio Algom POOC Notice for Monitor Well RL-1
DRC-2010-00
RIO Algom Mining LLC
May 19, 2010
Certified mail
Return Receipt (7001 0100 0002 9977 4981)
Mr. Dane L. Finerfrock, Director
Division of Radiation Control
Utah Department of Environmental Quality
168 North 1950 West
PO Box 144850
Salt Lake City, UT 84114-4850
Received
MAY 2010
Division of
inadiation ControJ
(68'
Re: License UT 1900481
Probable out of Compljance Status - Monitor Well RL-1
Lisbon Sampling Event - April 2010
Dear Mr. Finerfrock,
Please be advised that the latest sampling results for monitor v/eW RL-1
indicate that the well status is probable out of compliance according to
paragraphs 53. A and B of the above referenced license. Attached with this
letter are the laboratory results from Energy Laboratories and ACZ
Laboratories. An average uranium value of 43.8 mg/L was obtained from four
analytical results. The Uranium Target Action Level for this trend well is 42.1
mg/L.
Rio Algom Mining will commence sampling RL-1 on a quorterty basis for at
least two quarters, per paragraph 53.C(2), unless othen/vise directed by the
Executive Secretary.
If you have any questions or need additional Information, please call me at
505-287-8851 ext 15.
Sincerely,
Chuck Wentz
Radiation Safety Officer
Environmental Department Supervisor
Attachment: As stated
cc: L Morton (DRC)
P.O. Box 218, Grants, NM USA 87020 - Tel: [phone] - Fax: [phone]
ENERGY LABORATORIES, INC "2393 Salt Creek Hwy * PO Box 3258 * Casper, VVY 82602
MMM»1erAMiiid.-9 Toll Free 888.235.05t5 * 307.235.0515 * FM 307,234.1639 ' iyiiw.energyJab.coni
LABORATORY ANALYTICAL REPORT
Client:
Project:
Lab ID:
Client Sample ID:
RIO Algom Mining Corporation LLC
10-29
C10050031-009
RL-1
ReportDate: 05/17/10
Collection Date: 04/29/10 09:05
DateReceived: 05/03/10
Matrix: Qround Water
Analyses Fiesult Units Qualifiers RL
MCU
QCL Method Analysis Date / By
MAJOR IONS
Bicartionate as HCOS
Chloride
Sulfate
PHYSICAL PROPERTIES
Solids, Total Dissolved TDS @ 1B0 C
METALS - DISSOLVED
Arsenic
Molybdenum
Selenium
Uranium
1160
675
4410
0.003
10.4
0.067
44.1
mg/L
mg/L
mg/L
8540 mg/L
mgrt.
mg/L
mg/L
mg/L
30
0.001
0.1
0.001
0.0003
A2320 B 05/06/10 17:43 / dvg
E300.0 05/09/10 06:05 / Ijl
E300.0 05/09/10 06:05 / Ijl
A2540C 05/0»10 15:19/Ir
E200.B
E200.8
E200.8
E200.8
05/05/10 0359/ts
05/05/10 0359/ts
05/05/10 03:59/15
05/05/10 03:59/ts
Report
Definitions:
RL - /Vnalyte reporting limit.
QCL - Quality control limit.
D - RL increased due to sample matrix interference.
MCL - IMaximum contaminant level.
ND - Not detected at ttie reporting limit
Page 10 of 28
ENERGY lABOFlAJOniES, INC. * 2393 Salt Creek Hwy " PO Box 3258 * Casper, WY 82602
Toll Free 888.235.05f5 ' 307.235.0515 * FAX [phone] * www.eneTgylab.com
LABORATORY ANALYTICAL REPORT
Client: Rio Algom Mining Corporation LLC
Project: 10-29
Lab ID: C10050031-018
Client Sample ID: RL-1 A
Report Date: 05/17/10
Collection Date: 04/29/10 09.05
DateReceived: 05/03/10
Matrix: Groundwater
Analyses Result Units Qualifiers RL
MCU
QCL Metiiod Analysis Date/By
METALS-DISSOLVED
Uranium 43.8 mg/L 0.0003 E200.d 05/07/10 02:04/ts
Report
Definitions:
RL - Analyte reporting Hmit.
QCL - Quality control limit.
MCL - Maximum contaminant level.
ND - Not detected at tfie reporting limit.
Page 19 of 28
Laboratories, Inc.
2773 Downtiilt Drive Steamboat Springs, CO 80487(800)334-5493
V |-/?;'.-f
^••.•'/if'-^j:^.
Rio Algom Mining Company
Project ID: 58t58
Sample ID: RL-7A
ACZ Sample ID: L8^954-03
Date Sampled: 04/29/10 10:17
Date Received: 05/05/10
Sampie Matrix: Ground IVater
Metals Analysis
Uranium, dissolved M200.8 ICP-MS 43.30 mg/L 0.05
REPIN.02.06.05.01
Page 4 of 12
Laboratories, Inc.
2773 Dotmhill Drive Steamtioat Springs, CO 80487(800)334-5493
Rio Algom Mining Company
Project ID: 58158
Sample ID: RL-IB
ACZ Sample ID: L81954-04
Date Sampled: 04(29/10 10:17
Date Received: 05/05/10
Sample Matrix: Ground Meater
Metals Ar»lysis
Uranium, dissolved M200.8 ICP-MS 43.80 mg/L 0.05 0.3 05/12/1019:45 msh
REP)N.02.06.05.01
PageSof 12
Rio Algom Lisbon Valley
1 sl Semi Annual Groundwater Stability Monitoring Report 2010
DRC Review Memo - Appendices
Appendix 3 - February 19, 2004 Rio Algom Long-Term Groundwater Monitoring Plan
LONG-TERM GROUNDWATER
MONITORING PLAN
APPLICATION FOR ALTERNATE CONCENTRATION LIMITS
SOURCE MATERIALS LICENSE SUA-1119
RIO ALGOM MINING LLC
LISBON FACILITY
LA SAL UTAH
Prepared For:
Rio Algom Mining LLC
6305 Wctei^ord Boulevard
Suite 400
Oklahoma City, OK 73118
Prepared By:
KOMEX
1300 Jackson Street
Suite 200
Golden, CO 80401
FEBRUARY 19, 2004
LONG-TERM GROUNDWATER MONITORING PLAN
A long-term groundwater monitoring plan for the Lisbon site was presented in Section
10 of the RAI response document'. Based on comments received from the State of Utah
conceming the RAI response document^ and subsequent discussions with U.S. Nuclear
Regulatory Commission (NRC) staff, the groundwater monitoring plan has been
revised as described herein.
Figure 1 shows the location of wells proposed for long-term monitoring and the
uranium jsoconcentration map for the May 2003 sampling event. Table 1 lists revised
moniloring well locations to be sampled, a monitoring schedule, concentration limits,
and monitoring targets used to verify compliance with groundwater protection
standards and modeling predictions.
COMPLIANCE WELL LOCATIONS
Seven additional compliance wells have been added to the monitoring plan (EF-6, EF-8,
ML-1, MVV-5, MW-13, RL-1, and RL-3) for a total of 13 compliance wells (Table 1 and
Figure 1). Wells MW- 5 and MW-13 were added to the plan to monitor background
water quality. Wells EF-6, RL-1, and RL-3 are wells located inside the current plume
boundary and will serve to verify chemical transport modeling predictions and trends.
Well EF-8 is located on the edge of the existing southern uranium plume boundary and
will be useful to verify the onset of plume migration into this area and future
concentration trends. Well ML-1 is located downgradient of the southem aquifer plume
boundary and will also be useful to verify the onset of plume migration into this area.
Wells EF-3A and OW-UT-9 arc existing Point of Compliance (POQ wells located in the
plume "hot-spots". Wells EF-20, RL-4, H-63, and RL-6 (recently installed at NW POE
location) are wells located at the Long Term Surveillance and Maintenance (LTSM)
boundary and will serve to monitor conditions and trends at the Point of Exposure
(POE).
' Response to Request for Additional Information (RAI), Application for Alternate Concentration Limits,
Source Materials License SUA-1119, Rio Algom Mining LLC, Lisbon Facility, Sal, Utah. October 13,
2003.
^ Letter from Dane L. Finerfrock, State of Utah DEQ, to Mr. William Von Till, U.S. NRC, dated December
8,2003.
Long-Term Groundwater Monitoring Plan - RAM Lisbon Facility
1
MONITORING SCHEDULE
The frequency of monitoring has been increased as requested by the State of Utah and
the NRC as shown in Table 1. Monitoring will occur quarterly for the first three years
following the termination of the groundwaier Corrective Action Program (CAP). The
monitoring frequency will then decrease to a semi-annual schedule over the next five
years, followed by annual monitoring thereafter. Table 1 presents the regular sampling
schedule assuming no monitoring violations are observed.
There is a 1,000-year maximum time limit associated with the long-term sampling
schedule, although it seems reasonable to terminate the sampling program much sooner
if concentration trends follow predicted trends, with no violations.
MONITORING PARAMETERS AND ANALYTES
The list of analytes to be monitored has been expanded to include the complete list of
parameters currently monitored as part of the groundwater CAP (NRC license
condition) including constituents of concem (uranium, molybdenum, selenium, and
arsenic) and non-hazardous "indicator" parameters including pH, TDS, chloride, sulfate,
bicarbonate, and water level.
GROUNDWATER PROTECTION STANDARDS
The enforceable groundwater protection standards (concentration limits) for all site
monitoring wells will become the Altemate Concentration Limits (ACLs) established for
the site, as listed in Table 1. If ACLs are exceeded in any sampling event at any
compliance well location, sampling frequency will be retumed to a quarterly schedule
(four times per year). Out-of-compliance status will be defined as an exceedance of the
ACLs in any compliance well for two consecutive sampling events. In the event out-of-
compliance status is indicated, corrective actions may be required until compliance is
re-established and verified by additional monitoring. Corrective actions may include,
but not be limited lo, the revision of groundwater proteclion standards (ACLs) as
justified through additional risk assessment and groundwater modeling. The regular
sampling schedule will be followed and any corrective actions terminated once ACLs
are no longer exceeded in two consecutive sampling events.
Long-Term Groundwater Moniloring Plan • RAM Lisbon Facility
2
MONITORING TARGETS
In addition to moniloring for compliance with groundwater proteclion slandards
(ACLs), sile compliance wells will also be monitored to verify transport model
predictions and trends. Monitored concentrations and trends ("targets") will be
compared to model predicted concentrations and trends as a means of validating the
groundwater transport model.
As described in the hazard assessment portion of the ACL application, the RAI response
document, and the subsequent all-pathway risk assessment, uranium is the risk driver
and primarj' indicator parameter in site groundwater due to its relative mobility
(conservative transport) and concentration relative to other constituents of concem.
Therefore, monitoring targets for compliance wells will be established based on the
predicted or observed uranium concentrations in site groundwater.
Compliance Wells Impacted by Site Operations
Model-predicted uranium concentrations in site compliance wells impacted by site
operations are provided in Figures 2 through 10. These breakthrough curves will be
used as the basis for comparison between observed uranium concentrations and
predicted uranium concentrations presented in the RAI response documents
Figures 2 through 10 identify the predicted range in uranium concentrations expected in
compliance wells that are currently impacted by sile operations or that may become
impacted by site operations in the future (as predicted by transport modeling). The
target concentration range is based primarily on the model sensitivity analysis presented
in the RAI response document^, which is a rough measure of model uncertainties.
Results of sensitivity analyses indicate that uranium concentrations in site monitoring
wells may vary from the "best estimate" prediction by a factor of approximately 0.31 to
3.4. The target concentration range shown in Figures 2 through 10 are based on this
range of model uncertainty.
It should be emphasized that target concentrations identified in Table 1 and Figures 2
through 10 are not enforceable concentration limits or groundwater protection
^ Response to Comment 6, pp.40-45. Response to Request for Additional Information (RAI), October 13,
2003.
Table 6-2, Response to Request for Additional Information (RAI), October 13,2003.
Long-Term Groundwater Moniloring Plan - RAM Lisbon Facilil}'
3
slandards. However, in the event that target concentration limits are exceeded based on
results of groundwater monitoring, the groundwaier flow and/or transport model will
be re-evaluated to detennine the possible cause of the observed exceedance, and
adjustments to groundwater protection standards may be recommended based on this
review.
Compliance Wells not Impacted By Site Operations
Four of the eleven compliance wells (EF-20, H-63, MW-5 and MW-13) are background or
POE moniloring wells that are not currently impacted by site operations, nor are these
wells predicted to become impacted in the future by plume migration. Therefore, the
target concentration range for these wells was assigned based on the observed range in
historical uranium concentrations^
REPORTING
A report summarizing the results of the groundwaier monitoring program will be
submitted annually to the State of Utah until termination of the site license and transfer
of the site to the Department of Energy. The report will present the results of the most
recent monitoring events and all historical monitoring results for each parameter and
analyte in tabular form and graphically as concentration versus time curves (e.g.
breakthrough curves). Isoconcentration maps for the most recent monitoring period will
be presented for the following constituents: uranium, molybdenum, selenium, arsenic,
sulfate, chloride, and TDS. A water level map of the most recent monitoring period will
also be presented.
A discussion and interpretation of groundwater modeling results and concentration
trends will be provided, including the identification of any exceedances of groundwaier
protection standards (ACLs) and/or target concentrations. Figures comparing the
observed uranium concentration and the target concentration (Figures 2 through 10)
will be provided to demonstrate monitoring results are consistent with model
predictions.
' Based on the maximum and minimum historical uranium concentration values listed in Tables 1-2 and 2-1
in the RAI Response document.
Long-Term Groundwater Monitoring Plan - RAM Lisbon Facility
4
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