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HomeMy WebLinkAboutDRC-2021-009441 - 0901a06880ee4193Dq6-9_02.t-voqtl Energy Fuels Resources (USA) Inc. 225 Union Blvd, Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com 1 July 7, 2021 EVIA PDF AND OVERNIGHT DELIVERY Doug Hansen, Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 1195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Div of Waste Management and Radiation Control JUL 1 2 2021 Re: State of Utah Stipulation and Consent Order ("SCO") Docket Number UGW-20-01 White Mesa Uranium Mill — Energy Fuels Resources (USA) Inc. ("EFRI") Plan and Time Schedule Pursuant to Part II.H.2 of the Groundwater Corrective Action Plan ("GCAP") included as Attachment 1 to the SCO IDear Mr. Hansen: Part II.H. I) of the GCAP states that "At any time EFR[I] submits a quarterly report that demonstrates an exceedance (second quarter of chloroform exceedance), EER[I] will provide a written exceedance notice Ito the Director ("Exceedance Notice") for all wells that have demonstrated such an exceedance." EFRI I provided notice to the Director that the concentrations of chloroform in TW4-30 exceeded the respective 1GCAL of 70 ug/L for two or more consecutive quarters by letter dated May10, 2021. Part II.H.2) of the GCAP requires that "Within 60 days after the time of submittal of a quarterly report 'that demonstrates an exceedance as defined in Part II.G, EFR[I] will provide a plan and schedule for Iremedial actions to address and resolve the excursion, for Director approval." 'This is the plan and schedule required under Part II.H.2) of the GCAP for TW4-30 for the first quarter of 2021. 1 If you should have any questions regarding this submittal please contact me at (303) 389-4134. Yours truly, j(11:1114t ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund, Terry Slade, Logan Shumway, Scott Bakken, Stewart Smith (HGC) WHITE MESA MILL State of Utah Stipulation and Consent Order Docket No. UGW-20-01 Plan and Time Schedule Under Part II.H.2 For Exceedances in TW4-30 in the First Quarter of 2021 Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 ENERGY FUELS July 7, 2021 1. INTRODUCTION lEnergy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the "Mill"), located near Blanding Utah. EFRI performed first quarter 2021 chloroform monitoring during the period from January 1, to March 31, 2021 under the September 14, 2015 Groundwater Corrective Action Plan ("GCAP"), included as Attachment 1 to the executed Stipulation and Consent Order ("SCO"). Part II.H.1) of the GCAP states that "At any time EFR[I] submits a quarterly report that demonstrates an exceedance (second quarter of chloroform exceedance), EFR[I] will provide a written exceedance notice to the Director ("Exceedance Notice") for all wells that have demonstrated such an exceedance." EFRI provided notice to the Director that the concentrations of chloroform in TW4-30 exceeded the respective GCAL of 70 ug/L for two or more consecutive quarters by letter dated May10, 2021. Part II.H.2) of the GCAP requires that "Within 60 days after the time of submittal of a quarterly report that demonstrates an exceedance as defined in Part II.G, EFR[T] will provide a plan and schedule for remedial actions to address and resolve the excursion, for Director approval." 1This is the plan and schedule required under Part II.H.2) of the GCAP for TW4-30 for the first lquarter of 2021. 2. WELLS SUBJECT TO THIS PLAN TW4-30 is covered by this Plan. 1 3. BACKGROUND 'Figure 1 is a site map showing the locations of perched groundwater wells and other site features; Figure 2 is a map showing first quarter, 2021 perched groundwater levels and the I boundaries of the chloroform and nitrate plumes; and Figure 3 is a detail map showing first quarter, 2021 chloroform concentrations. lAs shown in Figure 2, perched groundwater flow ranges from generally southwesterly beneath the Mill site and tailings management system (cells 1 though 4B) to generally southerly along the eastern and western margins of White Mesa south of the cells. Perched groundwater flow has been impacted by past (pre-2012) water delivery to the unlined wildlife ponds (Figure 1) which resulted in groundwater mounds that locally changed groundwater flow directions. Since delivery of water to these ponds ceased in the first quarter of 2012, the perched groundwater mounds associated with these ponds have diminished; however the impact of past seepage from 1 the wildlife ponds is still evident in Figure 2. As the groundwater mounds have diminished, hydraulic gradients have also diminished. In addition to changes related to past delivery of water to wildlife ponds and the cessation of water delivery to the ponds in 2012, pumping to remediate both chloroform and nitrate plumes has impacted water levels as cones of depression have developed. 1 As shown in Figures 2 and 3, the chloroform plume is entirely within the Mill property boundary and is bounded on all sides by wells having chloroform concentrations that are either non-detect or less than 70 Ilg/L except at the location of TW4-30. Until the fourth quarter of 2020, TW4-30 ' also bounded the plume. Currently, the plume is bounded to the north by TW4-25 (non-detect); to the west and southwest by MW-28 (non-detect), MW-31 (non-detect), MW-32 (non-detect), TW4-6 (approximately 3.8 Rg/L) and TW4-23 (non-detect); to the east by TW4-3 (non-detect), TW4-5 (nearly 13 lig/L), TW4-8 (nearly 27 p.g/L), TW4-9 (approximately 39 [A,g/L), TW4-13 (non-detect), TW4-14 (approximately 1.8 11 g/L), TW4-18 (approximately 52 ttg/L), TW4-27 (nearly 4.7 Rg/L), TW4-36 (non-detect) and TW4-38 (non-detect); to the south by TW4-34 (non- detect) and TW4-42 (non-detect); and to the southeast by TW4-35 (non-detect). As discussed above, the chloroform plume is under remediation by pumping. The impacts of pumping are displayed by the large drawdowns evident in the water level elevation contours shown in Figure 2. Pumping from wells within and immediately adjacent to the chloroform plume as of the first quarter of 2021 (5.2 gallons per minute [gpm]) exceeds calculated 'background' flow (HGC, 2020) through the plume (3.4 gpm) and is therefore considered adequate. In addition, because of continued reductions in saturated thicknesses and hydraulic gradients resulting from reduced wildlife pond recharge, 'background' flow through the plume is expected to continue to diminish, thereby reducing the pumping needed to control the plume. The southernmost portion of the chloroform plume is affected by multiple influences that include pumping and reduced wildlife pond recharge, in particular, reduced recharge from the southern wildlife pond. Water levels at most wells within and at the margins of the chloroform plume are decreasing; however, water levels at wells such as TW4-14, TW4-27 and TW4-30, which are either located in relatively low permeability materials (TW4-14 and TW4-27), or are relatively hydraulically isolated (TW4-30), are increasing to stable. Generally decreasing water levels (since about the fourth quarter of 2013), and generally increasing chloroform concentrations at TW4-26 and TW4-29 are consistent with reduced wildlife pond seepage, in particular, reduced seepage from the southern wildlife pond. Plots of water levels and chloroform concentrations at these wells over time are provided in EFRI (2021). The groundwater mound associated with the southern wildlife pond created a generally southeasterly hydraulic gradient within the southern extremity of the chloroform plume that caused plume migration to the southeast (and toward TW4-30). As the groundwater mound associated with the southern pond decays, groundwater flow directions in the southern extremity of the plume are becoming more southerly, and plume migration is turning more to the south. An increasingly southerly direction of plume migration is consistent with generally increasing concentrations at TW4-26 since the third quarter of 2016. A large hydraulic gradient directed from TW4-29 towards TW4-30 existed at the time of installation of TW4-30 (first quarter of 2013) as shown in Figure 4. At that time TW4-30 was almost directly downgradient of TW4-29. However, due to decreasing water levels at TW4-29, and increasing water levels at TW4-30 (Figure 5), the hydraulic gradient from TW4-29 to TW4- 30 has nearly disappeared, as shown in Figure 6. This change in hydraulic gradient removes the primary driving force for chloroform migration from TW4-29 towards TW4-30, which is now ' cross-gradient of TW4-29. 2 i 4. PLAN AND TIME SCHEDULE This is a plan and schedule for actions to address and resolve the excursion noted in Table 1 above as required by the GCAP. 1Part II.H.2).i) of the GCAP states that the plan and schedule may include, but is not limited to the installation of one or more pumping wells in the vicinity of the well found in exceedance and installation of one or more replacement wells for the compliance well in exceedance. EFRI plans to address the exceedance through the installation of one additional compliance well (TW4-43). 'Figure 7 shows the location of the proposed new chloroform compliance well TW4-43. The proposed location of this well is considered appropriate because, as shown in Figure 6, due to changes in flow directions in the southern extremity of the plume, TW4-30 is now cross- gradient of TW4-29; and TW4-35, currently non-detect for chloroform, is downgradient of TW4- 30. Therefore, as a downgradient well is already present, only one new cross-gradient bounding I well to the southeast of TW4-30 is needed. The GCAP Part II.H.2).i) states that the plan and schedule may include, but is not limited to the 1 installation of one or more pumping wells in the vicinity of the well found in exceedance. Pursuant to the requirements of the GCAP, EFRI reviewed the existing water level, hydraulic conductivity and perched groundwater data in the area in and around TW4-30 for the placement of a new pumping well; or the conversion of an existing well. Based on the results of the reviews of data for the existing wells, EFRI has determined that an additional pumping well in the southeast area near TW4-30 is not feasible due to the low permeabilities and small saturated Ithicknesses in the vicinity of TW4-30. Table 2 shows the results of hydraulic conductivity measurements, first quarter, 2021 saturated thicknesses, and calculated transmissivities of wells in the vicinity of TW4-30. Hydraulic i conductivity data are from HGC (2018) and HGC (2019). Transmissivities of pumping wells TW4-4, TW4-40 and TW4-41are underestimated due to the small saturated thicknesses resulting from pumping, However, even with the underestimation of pumping well transmissivities, calculated transmissivities of pumping wells TW4-4, TW4-40 and TW4-41 are one to three lorders of magnitude larger than the transmissivities of non-pumping wells. In addition, the transmissivity at TW4-30 is one to two orders of magnitude smaller than existing pumping wells TW4-4, TW4-40 and TW4-41. TW4-40 has the highest calculated transmissivity (399 ft2/day), which is approximately 69 times larger than the calculated transmissivity of TW4-30 (5.9 ft2/day). Based on reported quarterly pumping volumes for TW4-40, which sum to approximately 745,580 gallons over the eight quarters from the second quarter of 2019 through the first quarter of 2021, the average sustainable pumping rate for TW4-40 is approximately 0.71 gpm. Therefore, because the transmissivity of TW4-30 is less than 1.5% of the transmissivity of TW4-40, the expected average sustainable pumping rate for TW4-30 would be less than 0.011 gpm, or about one one- hundredth of a gallon per minute. 3 Based on this analysis TW4-30, and other nearby non-pumping wells, are not suitable for pumping, as their productivities would be so low as to make pumping impractical. Furthermore, there appear to be no nearby productive areas within which a new pumping well could be installed without interfering with an existing pumping well. 14.1. Experts Reports to be Prepared lAs required by Part II.H.4, EFRI will submit an as-built report within 60 days of well installation 'for the newly installed well proposed in this plan and time schedule. Boring logs for the well and test borings will be included in the as-built report. Assessment of the plume, hydraulic capture and effectiveness of the remediation strategy will be discussed in the quarterly chloroform reports submitted as required by the GCAP. 4.2. Time Schedule The installation of the proposed well and the completion of the as-built report will be completed lin accordance with the required timeframes specified in the approved and executed GCAP. The proposed wells will be installed and operational within 90 days of director approval of this plan and time schedule and the as-built report will be completed within 60 days of well completion. 5. CONCLUSION 1 The chloroform plume is currently entirely within the Mill property boundary and (except at TW4-30) is bounded on all sides by wells having chloroform concentrations that are either non- detect or less than 70 IA g/L. Data collected to date indicate that, except for the lack of a well bounding the plume at TW4-30, there are sufficient chloroform monitoring and pumping wells to effectively define, control, and monitor the plume. Chloroform pumping as of the first quarter of 2021 (5.2 gpm) exceeds calculated 'background' flow through the plume (3.4 gpm) and is therefore considered adequate. In addition, because of continued reductions in saturated thicknesses and hydraulic gradients resulting from reduced wildlife pond recharge, 'background' flow through the plume is expected to continue to diminish, thereby reducing the pumping needed to control the plume. As previously stated, within the southernmost portion of the plume, generally decreasing water levels (since about the fourth quarter of 2013), and generally increasing concentrations at TW4- 26 and TW4-29 are consistent with reduced wildlife pond seepage, in particular, reduced seepage from the southern wildlife pond. As the groundwater mound associated with the southern pond decays, groundwater flow directions in the southern extremity of the plume are becoming more southerly, and plume migration is turning from southeastward to southerly. Proposed new compliance monitoring well TW4-43 will be located southeast and generally cross-gradient of 1 TW4-30. Existing well TW4-35 will serve as the well downgradient of TW4-30. An additional pumping well in the vicinity of TW4-30 is not feasible due to transmissivities that are too low to make pumping practical. 4 6. REFERENCES ' EFRI 2021. White Mesa Uranium Mill Chloroform Monitoring Report. State of Utah Stipulation and Consent Order Docket No. UGW-20-01, 1st Quarter (January through March) 2021. HGC 2018. Hydrogeology of the White Mesa Uranium Mill and Recommended Locations of New Perched Wells to Monitor Proposed Cells 5A and 5B. July 11, 2018. HGC 2019. Installation and Hydraulic Testing of Perched Well TW4-42, White Mesa Uranium Mill Near Blanding, Utah (As-Built Report). June 1 1, 2019. HGC 2020. Corrective Action Comprehensive Monitoring Evaluation (CACME) Report, White Mesa Uranium Mill Near Blanding, Utah. March 30, 2020. 5 TABLES Table 1 Chloroform Results in TW4-30 Constituent Monitoring Event GCAL (ul ) Results (ug/L) Chloroform Q4 2020 Q1 2021 70.0 82.8 74.8 Table 2 Calculated Transmissivities for Wells Near TW4-30 well hydraulic conductivity (cm/s) hydraulic conductivity (ft/day) saturated thickness (feet) transmissivity (T) (ft2/day) comment TW4-4* 1.66E-03 4.65 11.68 54.3 T artificially low due to reduction in saturated thickness by pumping TW4-6 1.15E-05 0.032 17.9 0.58 TW4-26 2.40E-05 0.067 11.41 0.77 TW4-27 1.35E-06 0.0038 14.02 0.053 TW4-29 4.24E-05 0.12 13.57 1.61 TW4-30 1.44E-04 0.40 14.63 5.90 TW4-31 4.18E-05 0.12 28.49 3.33 TW4-33 5.51E-05 0.15 5.84 0.90 TW4-34 9.98E-05 0.28 18.55 5.18 TW4-35 6.27E-05 0.18 6.62 1.16 TW4-40* 9.81E-03 27.47 14.51 399 T artificially low due to reduction in saturated thickness by pumping TW4-41* 2.69E-03 7.53 4.43 33.4 T artificially low due to reduction in saturated thickness by pumping TW4-42 2.43E-05 0.068 17.13 1.17 Notes: * = pumping well T = product of hydraulic conductivity and saturated thickness cm/s = centimeters per second ft/day = feet per day ft 2 /day = feet squared per day FIGURES CORRA1 ) ... ,G11 01,01 41' TWN-12 abandonod • MW-01 1W14-10 TWN-09 • e mom TW N-06 TWN PIEZ-01 wildlife pond Wildlife pond • M4-24 MW-28 CelP 2 TVVN-01 TW4-21 PIEZ.34 ENtRANCL.sp,W 4 2T4WT4W-221-W4-374T:94..2TWO 4TW3:11W84-05 TW4-38 MW-26 4-12 TW4-ii-rwC:::‘_03 TW4?28 8N4-32 • MW-30 TW4-16 TW4-11 ° TW44.1214-13 .Th14-°7°.TRN4-08OTW4-3 mw_32 TWO-01 -rw4_04 TW4-41 OTW4-14 • MW-12 MW- .0 Cell 3 4441 DR-06 DR-07 MW-3541 4111.11 • MW-31 MW-360 7VV4-060 _TW4-21-1/44..3-1 T16/4-2 1w4.3ki 0 or • TW4-260 0TW4-30 MW-25 TW4-29- 0TW4-35 TW4-40' 0 TW4-421, TW4-34 wildlife pond DR-11 DR-12 DR-13 • PIEZ-05 MW-17 • MW 21 DR-14 MW-39 MW-▪ 38 EXPLANATION 4V1W-24A perched monitoring well installed December 2019 TW4-42 (:) temporary perched monitoring well installed April 2019 TW4-40 perched chloroform pumping well • installed February 2018 TW4-19 • perched chloroform or nitrate pumping well MW-38 perched monitoring well installed February 2018 CORRAL SPRINGS MW-5 • perched monitoring well TW4-12 o temporary perched monitoring well ;1- mile TWN-7 temporary perched nitrate monitoring • well PIEZ-1 perched piezometer RUIN SPRING seep or spring HYDRO WHITE MESA SITE PLAN SHOWING LOCATIONS OF GEO PERCHED WELLS AND PIEZOMETERS Int INV CHEM, INC. APPROVED DATE REFERENCE FIGURE R/718000/TW43/PandTS/Uwelloc1220.srf 1 NV" CORRAL C TWN-11 TWN-1 TWN- 5645 TWI4-16 abanril.on,f1 TWN-15 (56o.6 5540 14 ".11.1481eci TA-10 :188481)8d TWN4/9 TVA -06 /589 /INEZ-01 -°8 I MW -19 1 one RUIN SPRING EXPLANATION chloroform plume boundary nitrate plume boundary TW4-42 (:) 5526 MW-38 -1:}. 5463 estimated dry area temporary perched monitoring well installed April, 2019 showing elevation in feet amsl perched monitoring well installed February, 2018 showing elevation in feet amsl îii TW4-40 + 5526 MW-5 • 5504 TW4-1 2 0 5569 fNe temporary perched monitoring well installed February, 2018 showing elevation in feet amsl perched monitoring well showing elevation in feet amsl temporary perched monitoring well showing elevation in feet amsl 1 mile NOTES: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-21, TW4-'37, TW4-39, TW4-40 and TW4-41 are chloroform pumping wells; TWN-7 *5568 PIEZ-1 temporary perched nitrate monitoring well showing elevation in feet amsl perched piezometer showing 5589 elevation in feet amsl RUIN SPRING 5380 seep or spring showing elevation in feet amsl TW4-22, TW4-24, TW4-25 and TWN-2 are nitrate pumping wells; TW4-1, TW4-2 and TW4-11 water levels are below the base of the Burro Canyon Formation KRIGED 1st QUARTER, 2021 WATER LEVELS HYDRO AND CHLOROFORM AND NITRATE PLUMES GEO WHITE MESA SITE CHEM, INC. APPROVED DATE REFERENCE H/718000/ TW43/PandTS/Uw10321ChIN.srf FIGURE 2 PIEZ-02 QNS TW4-24 096 MW-25 OND - TW4-42 TW4-29 OTW4-30 0 75 OTW4-35 TW4-34 O t°4 • MW-27 • rTWN-02 0. es TWN-04 O I r r TW4-25 onto r— TWN-01 ONS PIEZ-3A -4; . TW4-g4 0400 TW4-19 TW4-22 C D 05100 TW4-20 93800 0 TW4-37 TW4-09 O OTW4-38 TW4-18 0 • OTW4-28 ND TW4-32 0 ND MW-31 OND . TW4-11 TW4-0g 0919 )21W-64 TA014-070' OTW4-08 "Ls '- 61 TW4-01 MW-3,2 --"114Nelk," OND "1"04t, OTW4-36 TW4-13 O 44, ' , TW4-41 01÷W4-04 TW4-14 O 1000 feet PIEZ-04 iti j" -23 ND TW4-26 TW4-06 O TW4-33 0 TW4-27 0 OTW4-31 EXPLANATION NS = not sampled; ND = not detected: ND 40 = not detected in 4th quarter kriged chloroform isocon and label temporary percnea monitoring welt installed April, 2019 showing concentration in pg/L TW4-40 temporary perched monitoring well +436 installed February, 2018 showing concentration in pg/L perched monitoring well showing concentration (pg/L) TW4-7 temporary perched monitoring well 0 875 showing concentration (pg/L) perched piezometer (not sampled) TW4-42 e? ND MW-32 •ND PIEZ-2 NS 111111111111111111111111111111M NOTES: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40 and TW4-41 are chloroform pumping wells; TW4-22, TW4-24, TW4-25 and TWN-2 are nitrate pumping wells -414;1 HYDRO GEO W*.r CHEM, INC. APPROVED DATE REFERENCE FIGURE H:/718000/1W43/PandTS/Uch10321det2 srf 3 KRIGED 1st QUARTER, 2021 CHLOROFORM (pg/L) WHITE MESA SITE (detail map) TWN -1 8 / / 4>i9 cb .<0 /le TW4-1 2 / 0 / ‹,- WI<N4-011) _ 40/' A( 0/ Ae• 4*- \-o 16 I • TW4-1 3 "'t MlAf4r1 , 055.73" TW4-0 7 07 \ OTW4-0 8 TVV4-0 1 - •••••••••••• ••••••• 7 '0 \CCP 556° 5 5 4 055,52 TW4•64 , - — — 7-- 0 , / TW4-4-4- , 7' // , / i TI/Vt06 / i ,rAn r i / ,,..,..,-,.., 1 /. 1 \ TW427 0 \ ATW4-3.1.1 I - 526\ 5520 01 x -.3 TW4-30 , 3. • '\ EXPLANATION hydraulic gradient vector MW-4 NOTE • 5552 innn fppt • MW-4, MW-26, TW4-4, TW4-19, and TW4-20 are chloroform pumping wells; TW4-22, TW4-24, TW4-25, and TWN-2 are nitrate pumping wells TW4-1 O 5555 based on knged water levels perched monitoring well showing elevation in feet amsl temporary perched monitoring well showing elevation in feet amsl PIEZ-2 perched piezometer showing elevation in feet amsl 5599 TW4-28 temporary perched monitoring well KE 5581 installed March, 2013 showing elevation in feet amsl APPROVED HYDRO GEO CHEM, INC. 101V VA" KRIGED 1st QUARTER, 2013 WATER LEVELS AND HYDRAULIC GRADIENT VECTORS WHITE MESA SITE (detail map) DATE REFERENCE H:/718000/ TW43/PandTS/Uw10313czv.srf FIGURE 4 5550 5545 5540 5535 (7) E 03 "Ir..--411--1111a4116"1111-11111411111---111---114.111-416"11111"111 —1111- ti a) 5530 c o fa: > IpAlll'''*"4111"'41--ar°11.-111-11..41r4I1 ej .....farar.411-4111 5525 §i 5520 5515 5510 01 13 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 13 13 13 14 14 14 14 15 15 15 15 16 16 16 16 17 17 17 17 18 18 18 18 19 19 19 19 20 20 20 20 21 Quarter ...48....TW4-29 --iii..i•TW4-30 min HYDRO WATER LEVEL ELEVATIONS AT TW4-29 AND TW4-30 1.1.1.11 GEO wolf CHEM, INC. Approved SJS Date X7/6/21 Author SJS Date 7/6/21 File Name Figure 5 Figure 5 H:\718000\TW43\PandTS\figures\Figure5.xlsx: Figure 5 MVt27 TWN,Q4 05580 MW-25 05532- - 1 TW4-40 /* TW4-34 0 1 I DA/4-42 -1060 ieet — Q5525 \N MW-31 \ 05548 • 25 575 r—TINN 01 ' 055 TVV2W11 N TAW...19 N 8 • .7 4-22 Ar, 055Sk \ 05,69 5560 TW4-, , y$,t4-19-:TW4cO5 5Av304,3 0/a 20bndr- \ is TW4- o- .„ / MW-26\ I n_Tw4-38/ , TW 10 TW4-03 . / / 11X4-32 / 055 4 1 5506111/1v74:321, 65 7 ,..`'„,3/1/ 23 05532 • "-•--..... ".......N•• --, ...._ -------. \ ia — • - ,-,- — - -.... --_,.... . • N ‘ \ c.:-.1C --------. .`<. ‘ / \ \ \ .. . \NN , TW4-06 7- 5529 0 C711/114,-31 0 TW TW4-26 4.2L____. TW4-29 - 0- 0 - b:ab 441, - -r I \ 1\ • • • • •••••^. =1181 4 r t I 8' A' 4 TA/1/4-14 . %Qs-2 r • I, ‘N, \\\*Ti1/4-1,3 \ . - \ • * 4\08, - \ b,)•-• 5540 533 • 0530 <0.25. 5525 .7 EXPLANATION HYDRO GEO CHEM, INC. ":Vre TW4-42 ed 5526 TW4-40 -4'5526 mw-25 • 5532 TW4-7 5539 PIEZ-2 G, 5583 hydraulic gradient vector based on kriged water levels temporary perched monitoring well installed April, 2019 showing elevation in feet amsl temporary perched monitoring well installed February, 2018 showing elevation in feet amsl perched monitoring well showing elevation in feet amsl temporary perched monitoring well showing elevation in feet amsl perched piezometer showing elevation in feet amsl _ NOTES: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40 and TW4-41 are chloroform pumping wells; TW4-22, TW4-24, TW4-25 and TWN-2 are nitrate pumping wells; TW4-1, TW4-2 and TW4-11 water levels are below the base of the Burro Canyon Formation KRIGED 1st QUARTER, 2021 WATER LEVELS AND HYDRAULIC GRADIENT VECTORS WHITE MESA SITE (detail map) FIGURE 6 APPROVED DATE REFERENCE H:/718000/ TW43/PandTS/Uw10321czy.srf / PIEZ-02 PIEZ-3A N T 4.-19 . fo TW \ TVy4=20, .., 0 ' Oatand '- \ r-..-., 95 4- I' ;I 1 / MyV-26 I. .55TW 10 TW4 t / -, ‘-z;'6 ..,, 4.`e°. —4 !*- -4---- . --.. — --- • ----- ----,. -1' T _ _ __ ._ _ -.727.7-:-.-...-----.- — —,- ---_.„- --',.. \ \\\IV/j-,.1,3„, / //-1-4:32 •... , . _.--- , 4F2„1, . / ; T / : ,:•-• ', \ V \` u0004 / / I / \*.\\ \ \ / / . b---) TVY.4kOtk\ tjw_4--16„" , - , ------ i , k \_-...6, -• , I N \ " \ 4 ....-_--_-_TifV4,4t . \ ----- ./// ---- - 5 5` -u4 TAN4-1-4 4 0 \ ,Q5536 . mattoOkasiamsgiiiimems- 10bGieet - -„„ TW4-2 0 ..;:fTW4-40 TW4-42 EXPLANATION TW4- t3 proposed location of TW4-43 hydraulic gradi-nt v-ctor based on kriged water levels TW4-42 (,) 5526 TW4-40 + 5526 MW-25 • 5532 TW4-7 0 5539 PIEZ-2 5583 temporary perched monitoring well installed April, 2019 showing elevation in feet amsl temporary perched monitoring well installed February, 2018 showing elevation in feet amsl perched monitoring well showing elevation in feet amsl temporary perched monitoring well showing elevation in feet amsl perched piezometer showing elevation in feet amsl NOTES: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40 and TW4-41 are chloroform pumping wells; TW4-22, TW4-24, TW4-25 and TWN-2 are nitrate pumping wells; TW4-1, TW4-2 and TW4-11 water levels are below the base of the Burro Canyon Formation PROPOSED LOCATION OF TW4-43 SHOWING KRIGED 1st QUARTER, 2021 WATER LEVELS AND HYDRAULIC GRADIENT VECTORS WHITE MESA SITE APPROVED HYDRO GEO CHEM, INC. DATE REFERENCE H:/718000/ TW43/PandTS/propTW43loc.srf FIGURE 7