SUMMARY OF GROUND-WATER QUALITY IMPACTS
   OF URANIUM MINING AND MILLING IN
  THE GRANTS MINERAL BELT, NEW MEXICO
          Robert F.  Kaufmann

           Gregory G.  Eadie

          Charles R.  Russell


              August  1975
 U.S.  Environmental Protection Agency
     Office of Radiation Programs
          Las Vegas Facility
       Las Vegas,  Nevada   89114

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                     TABLE OF CONTENTS


                                                     Page


TABLE OF CONTENTS        "                             i
                         i

TABLES                                               iii

FIGURES                                               iv

PURPOSE OF STUDY                                       1

SUMMARY AND CONCLUSIONS                                3

RECOMMENDATIONS                                       10

AREAL DESCRIPTION                                     12

    Location and Description of
     Study Area                                       12
    Principal Industries                              14

GEOLOGY AND HYDROLOGY                                 16

INDUSTRY-SPONSORED WATER QUALITY
MONITORING PROGRAMS                                   21

    Introduction                                      21
    Adequacy of Water Quality Data
     and Monitoring Programs                          22

GROUND-WATER QUALITY IMPACTS                          26

    Introduction                                      26
    Bluewater-Milan-Grants                            ^5
    United Nuclear-Homestake Partners
     Mill and Surrounding Area                        40
    Ambrosia Lake Area                                44
    Churchrock Area                                   47
    Jackpile-Paguate Area                             49

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    Significance of Radiological Data                 51

        Regulations and Guidelines                    51
        Radium-226                                    52
        Other Radionuclides                           55

REFERENCES CITED         ..                            57
                             11

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                           TABLES
Tables
   1.  Uranium Economy of New Mexico
   2.  Sampling Point Locations and Gross Chemical
       Data for Ground-Water Samples from the
       Grants Mineral Belt, New Mexico                    27
   3.  Selenium and Vanadium Concentrations in
       Selected Ground-Water Samples                      30
   4.  Radiological Data for Selected Ground-Water
       Samples                                            31
   5.  Typical Background Radionuclide Concentra-
       tions by Geographic Area and Aquifer               34
   6.  Summary of Reported Concentrations for
       Radium, Gross Beta, and Natural Uranium
       in Ground Water in the Grants Mineral Belt         37
   7.  Locations with Radium-226 in Excess of the
       PHS Drinking Water Standard                        54
   8.  Radium Concentrations for Municipal Water
       Supplies                                           54
   9.  Maximum Permissible Concentrations in Water        56
                              111

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                        FIGURES
Figures                                              Page

  1.   Map of Northwestern New Mexico Showing
      General Location of Sampling Areas in
      the Grants Mineral..Belt                          13
  2.   Generalized Structure Section from
      Bluewater to Ambrosia Lake                       17
  3.   Generalized Structure Section from
      Gallup to Churchrock Mining Area                 18
  4.   The Anaconda Company Uranium Mill and
      Tailings Pond-Bluewater                          36
  5.   Radium and Nitrate Concentrations in
      Ground Water in the  Grants-Bluewater Area        38
  6.   Radium, TDS and Chloride in Ground Water
      Near the United Nuclear-Homestake Partners
      Mill                                             42
  7.   Water Table Contours and Well Locations at
      the United Nuclear-Homestake Partners Mill
      Site                                             43
  8.   Radium Concentrations in Ground Water in
      the Ambrosia Lake Area                           46
  9.   Radium Concentrations in Ground Water in
      the Churchrock-Gallup Area                       48
 10.   Radium Concentrations in Ground Water in
      the Paguate-Jackpile Area                        50
                            IV

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                    PURPOSE, OF STUDY
     In September 1974, the State of New Mexico Environ-
mental Improvement Agency  (NMEIA) made a request of Region
VI of the U.S. Environmental Protection Agency (USEPA) to
conduct a definitive survey of the Grants Mineral Belt area
(Wright, 1974).  At  this time,  a  summary  report evaluating
the problem areas in the study  area was also  prepared  by
Region VI (Keefer, 1974). -Briefly, the water-quality  impacts
associated with ongoing and projected  uranium mining and
milling were unknown.   Whether  a  problem  existed \\ras ques-
tionable but \\rorthy  of investigation because  of the toxic
nature of the effluents and their persistence in the environ-
ment.  The study areas of most  concern were  located near
Churchrock, Ambrosia Lake-Grants  and Laguna-Paguate.

     In late November  1974, the  Office of Radiation Programs-
Las Vegas Facility  (ORP-LVF) and the National Enforcement
Investigations Center  (NEIC)-were requested  by Region VI to
provide direct assistance  to the  NMEIA to conduct the study.

     Representatives of ORP-LVF,  NEIC, and NMEIA completed
a field reconnaissance  of  the study area during the week of
January 24,  1975.  Industry representatives  were contacted,
arrangements were made  for site  access, and  sampling  locations
and collection schedules were finalized after revaewing com-
pany monitoring programs.  Study plans were  prepared  by both
ORP-LVF and NEIC defining  study  participants, responsibilities,
and specific analyses  to be completed per location by each
laboratory.

     Subsequent meetings between  the three participating
agencies resulted in a  final study plan which defined the
following study objectives to the satisfaction of NMEIA
(Bond, 1975):

     1.  Assess the impacts of waste discharges from uranium
mining and milling on  surface waters and ground waters of the
Grants Mineral Belt.

     2.  Determine if  discharges  comply with all applicable
regulations, standards, permits,  and licenses.

     3.  Evaluate the  adequacy of company water quality moni-
toring networks, self-monitoring  data, analytical procedures,
and reporting requirements.

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     4.  Determine  the  composition of potable waters at ura-
nium mines  and  mills.

     5;  Develop priorities  for subsequent monitoring and
other follow-up studies.

     Ground-water aspects of objectives 1, 3, and 5 were the
responsibility of ORP-LVF whereas the remaining objectives
were pursued by NEIC.

     Actual sample  collection began in late February, 1975,
in the Ambrosia Lake-Blue\\rater area.  It proceeded to Paguate-
Jackpile and was finally completed in the Gallup-Churchrock-
area in early March, 1975.  Laboratory analyses for the trace
metals, gross alpha, and radium-226 analysis were completed by
NEIC and the other  radiological analyses were completed by the
Environmental Monitoring and Support Laboratory.  Radiometric
analyses w^re assigned at the highest priority at each labora-
tory and were completed, in July 1975.

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                 SUMMARY AND CONCLUSIONS
TASK:  Assess the Impacts of Waste Discharges from Uranium
       Mining and Milling on Surface and Ground Waters of
       the Grants Mineral Belt

     1.  Ground water is the principal source of water
supply in the study area.  Extensive development from the
San Andres Limestone aquifer occurs in the Grants-Bluewater
area where the water is used for agriculture, public water
supply, and uranium mill feed water.  Development of shallow,
unconfined aquifers developed in the alluvium also occurs
in this area.  Principal eround-water development in the
mining areas at .Ambrosia Lake, Jackpile-Paguate, and Church-
rock is from the Morrison Formation and, to a lesser extent,
from the Dakota Sandstone or the Tres Hermanos Member of
the Mancos Shale.  The Gallup water supply is derived
primarily from deep wells completed in the Gal]up Sandstone.
The well fields are located in the urban area and, more
recently, 11 kilometers north of the city.

     2.  Contamination of shallow ground water, largely
used for livestock watering, results from the infiltration
of 1) effluents from mill tailings ponds, 2) mine drainage
water that is introduced to settling lagoons and natural
water courses, and 3) discharge (tailings) from ion exchange
plants.  It is unlikely that seepage from these sources
returns to the deep bedrock aquifers.  Deterioration of
water quality in the latter occurs in the mining areas as
a result of penetration or disruption of the ore body coin-
cident with underground mining.  The most dramatic changes
are greatly increased dissolved radium and uranium.  Induced
movement of naturally saline ground ivater into potable
aquifers is also likely but undocumented.

     3.  With the exception of the area south and southwest
from the United Nuclear-Homestake Partners mill, widespread
ground-water contamination from mining and milling was not
observed in the study area.  In the vicinity of the Anaconda
mill, radium and nitrate concentrations in the alluvial aqui-
fer decline with distance from the tailings ponds, but no-
where does either parameter exceed the drinking water limit.
Contamination of ground water with radium was not observed
despite concentrations of as much as 178 pCi/1 in mine and
mill effluents.  padium removal is pronounced, primarily.
due to sorptive capacity of soils in the area.

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     4.  Mining practices, per se, have an adverse effect
on natural i^ater quality.  Initial penetration and disruption
of the ore body in the Churchrock mining area increased the
concentration of dissolved radium in ground water pumped
from the mines from 0.05 to 0.62 pCi/1 to over 8 pCi/1.
Subsequent development work over a two-year period increased
the concentration to over 20 pCi/1, or 23 times the natural
concentration.  If the pattern in Ambrosia Lake is- repeated,
ultimate concentrations of 50 to 150 pCi/1 are expected.

     5.  Ground water in parts of the shallow aquifer down-
gradient from the United Nuclear-Homestake Partners mill
is contaminated with selenium, and alternative supplies
should be developed.  The he^t alternative is deeper wells
completed in the rhinle formation or, preferably, the under-
lying San Andres Limestone.

     6.  Seepage from the Anaconda tailings pond at Blue-
water is estimated to average 183 million liters/year (48.3
million gallons) for 1973 and 1974.  The average volume in-
jected for the same time period was 348 million liters/year
(91.9 million gallons).  Therefore, approximately one-third
of the waste enters the shallow aquifer, which is a source of
potable and irrigation water in Bluewater Valley.  From 1960
through 1974, seepage is estimated to have introduced. 0.41
curies of radium to the shallow potable aquifer.  .Adequate
monitoring of the movement of these wastes is not underway.

     7.  There are indications that waste injected into the
Yeso Formation by the Anaconda Company are not confined to
that unit as originally intended in 1960.  Three nearby moni-
toring wells, completed in the shallower San Andres Lime-
stone and/or the Glorieta Sandstone show a trend of increas-
ing chloride and uranium with time.  Positive correlations of
water quality fluctuations with the volumes of waste injected
are a further indication of upward movement.  The absence of
monitoring wells in the injection zone is a major deficiency
in the data collection program.

     8.  The maximum concentration of radium observed in
shallow ground water adjacent to the Kerr-McHee mill at
Ambrosia Lake was 6.6 pCi/1. Calculated seepage ^rom the tail-
ings ponds occurs at the rate of 491 million liters/year (130
million gallons/year), and has contributed an estimated 0.7
curies of radium to the ground water to date.  This is 29 per-
cent of the influent to the "evaporation ponds" and attests to

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their poor performance in this regard.  Padium and gross alpha
in the seepage are 56 pfi/l and 112,000-144,000 pCi/1, respec-
tively.  Wells completed in bedrock and in alluvium along water
courses containing mine drainage and seepage from tailings ponds
contain elevated levels of TDS, ammonia, and nitrate.  One well,
now contaminated with 3.7 pCi/1 of radium, contained 1.0 pCi/1
in 1962.  Sorption or bio-uptake of radium is nronounced, hence
concentrations now in ground water are not representative of  .
ultimate concentrations.

     9.  Contamination of the Gallup municipal water supply
by surface flows consisting mostly of mine drainage is ex-
tremely unlikely because of geologic conditions in the well
field.  Another well field north of the City will, in no
way, be affected by the drainage.

    10.  Water quality data from 11 wells over a 200-square
kilometer area in ,.the Puerco Piver and South 'Pork Puerco
Piver drainage basins revea]  essentially no noticeable
increase in concentrations of radionuclides as well as gross
and trace constituents in ground water as a result of mine
drainage.  Natural variations in the uranium content of
sediments probably account for differences in radium content
in shallow wells.  Dissolved radium in shallow ground water
underlying stream courses affected by waste water is essen-
tially unchanged from areas unaffected by mine drainage.
None of the samples contained more than recommended maximum
concentrations for radium-226, natural uranium, thorium-2.30,
thorium-232, or polonium-210 in drinking water.  However,
the paucity of sampling points and the absence of historical
data make the ^oregoing conclusion a conditional one, par-
ticularly in the reaches of the Puerco River within approxi-
mately 10 kilometers of the mines.

    11.  Four i^ells sampled in the vicinity of the Jackpile
mine near Paguate contained 0.31 to 3.7 pCi/1 radium-226.
With the exception of the latter value from the new shop
well in the mine area, remaining supplies contain 1.7 pCi/1
or less radium.  The Paguate municipal supply contains 0.18
pCi/1.  None of the wells were above MFC for the other common
isotopes of uranium, thorium, and polonium.   Hround water from
the Jackpile Sandstone may contain elevated levels of radium
as a result of mining activities.  Mine drainage water ponded
within the pit contained 190 pCi/1 radium and 170 pCi/1 of
uranium in 1970.   The impacts of mining on ground-water
quality downgradient from the mining area are unknown due to
the lack of properly located monitoring wells.   No adverse .
impacts from mining on the present water supply source for
Paguate is expected.

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                                                                    (o
    12.  Of the 71 ground-water samples collected for the
study, only two potable water supplies have radium-226 in
excess of the 3 pfi/1 PUS drinking water standard.  These
are located downgradient from the Kerr-McHee mill and in
the Jackpile mining area.

    13.  The highest isotopic uranium and thorium, and
polonium-210 contents for any potahle water supply in the
study area are less than 1.72 percent of the total radionuc-
lide population guide-MFC as established in NMEIA regulations.

    14.  The lowest reported concentrations (background
levels) are summarized as follows:

     Padionuclide     Pange  (pCi/1)    Average (pCi/1)

     radium-226       0.06 - 0.31          0.16
     polonium-210 .•    0.27 - 0.57          0.36
     thorium-230      0.013  - 0.05]        0.028
     thorium-232      0.010  - 0.024        0.015
     U-natural           14  - 68           35

    15.  The uranium isotopes (uranium-234, -235, and -238)
are the main contributions to the gross alpha result; however,
in several determinations, the gross alpha result underesti-
mated the activity present from natural uranium.

    16.  No correlation was found relating a gross alpha
content greater than 5 pCi/1 to a radium-226 content in excess
of the 3 pCi/1 PHS drinking water standard.

    17.  It is doubtful that the gross alpha determination can
even be used as an indicator of the presence of other alpha
emitters (e.g., H-natural and polonium-210); and since the
gross alpha results have such large error terms, no meaningful
determinations of percentage of other radionuclides to gross
alpha result can be implied.

    18.  Gross alpha determinations also fail  to indicate the
possible presence of lead-210 (a beta emitter)  which, because
of the low MFC of 33 pri/1, may be a significant contributor
to the radiological health hazard evaluation of any potable
water supply.

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                                                                   7
    19.  Radium-226 in ground water is a good radiochemical
indicator of waste water from mines and mills.  It also pro-.
vides the best means of health evaluations due to the low
maximum permissible concentration.

    20.  Polonium-210 , thorium-230 and thorium-232 con-
centrations in ground water fluctuate about background levels
and are poor indicators of ground-water contamination from
uranium mining and milling activities.

    21.  For routine radiological monitoring of potable water
supplies, isotopic uranium and thorium, and polonium-210
analyses do not appear to be necessary due to their high
maximum permissible concentrations.  (Chemical toxicity of
uranium may be a significant limiting factor, however.)

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Task:  Evaluate tlie Adequacy of Company Water Quality Moni:
       toring Networks, Self-Monitoring Data, Analytical
       Procedures, and Reporting Requirements

     1.  Environmentally-oriented company sponsored ground-
water monitoring programs range from imperfect to nonexistent.
Actual monitoring networks are deficient in that sampling
points are usually poorly located or of inadequate depth/loca-
tion relative to the hydrogeologic system and the introduction
of contaminants thereto. Compared to the multi-million dollar
uranium industry, producing multi-billion liters of toxic
effluents, the ground-water sampling and monitoring programs
represent minimal efforts in terms of network design, imple-
mentation, and level of investment.

     2.  Company radiochemical analytical methods evident
to date are inadequate for measuring environmental levels
of radionuclides. , Of specific concern are overly high
minimum detectable activities and large error terms.  Incom-
plete analysis of radionuclide contents prevails.  Few data
are reported on other naturally occuring radionuclides such
as isotopic thorium, polonium-210, and radium-228.
In some cases, monitoring has been restricted to analysis
of radium-226 and natural uranium, without consideration of
these other radionuclides or toxic metals.

     3.  Monitoring of hydraulic and water-quality impacts
associated with conventional mining and with solution (in
situ) mining is not reported to regulatory agencies.  It is
likely that such monitoring is limited to meeting short-
term economic, and engineering needs of the companies rather
than addressing long-term, general environmental concerns.
As a result, overall impacts on ground water are not rou-
tinely determined and reported.

     4.  Off-site ground-water sampling networks do not
utilize wells specifically located and constructed for
monitoring purposes.  Reliance on wells already in existence
and utilized for domestic or livestock use falls short of the
overall monitoring objectives (i.e., to determine impacts
on ground water and to adjust company operations to accept-
able levels).  Deficiencies of this type can allow contami-
nation to proceed unnoticed.

     5.  Proven geophysical and geohydrologic techniques
to formulate environmental monitoring networks,  specify
sampling frequencies, a;nd provide data to adjust subsequent.
efforts are, with few exceptions, not part of the industrial
efforts with respect to ground water.

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     6.  Monitoring the effects of the Jackpile and Paguate
open pit mines on ground-water quality is non-existent,
despite the magnitude of these operations.  Whereas back-
ground radium concentrations are less than 4 pCi/1, drainage
water within the pits contains 190 pCi/1.  Padium in two wells
used for potable supply and completed in the ore body is also
elevated above background, further indicating a need for data
to determine what the future impacts might be when mining
ceases and before additional programs for heap leaching
and in situ mining are implemented.

     7.  Careful analysis of material and water balances
for the various tailings disposal operations is not evident.
For the Anaconda Company, the method utilized has not been
altered in 14 years and for Kerr-McGee, overland flow
into the ponds is erroneously regarded as negative seepage
or as an influx of ground water.

     8.  Records of U.S. Atomic Energy Commission (USAEC)
inspection reports, mill license applications, seepage reports,
etc., on file with the State appear to be incomplete and not
readily accessible.  No interpretive summary or review-type
reports utilizing the monitoring data reported by industry
are available from either the State or the USNRC.  Liberal
mill licensing conditions with respect to ground-water mon-
itoring and water quality impacts were initially established
by the U.S. Atomic Energy Commission (USAEC) and have been
followed by scant review or no review, in any critical sense,
of company operations.  The uranium mining and milling indus-
try has not been pressed to monitor and protect ground-water
resources.   Prior to the present study requested by the State
of New Mexico, the efforts put forth by industry to date have
largely not been reviewed by regulatory agencies at the State
and Federal levels.
TASK:  Develop Priorities for Subsequent Monitoring and
       Other Follow-Up Studies

     (See RECOMMENDATIONS)

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                     RECOMMENDATIONS
     1.  Improved industry-sponsored monitoring programs
should be implemented and the data made publicly available
to detect likely hydraulic and water quality impacts from
uranium milling and mining (open pit, underground, in situ).
Revamped programs, specifically developed by joint- concur-
rence of industry and regulatory agencies, should be incor-
porated in licenses, where possible.  Licenses should spe-
cify minimal radiochemical analytical methods for detecting
specific radionuclides as well as requirements for partici-
pation in quality assurance programs.  Specific reporting
procedures should include raw data, summary reports, and
interpretations of data.  Conclusions concerning impacts of
operations on ground-water quality and remedial steps taken
to abate or eliminate adverse impacts should be prepared.

     2.  Additional legislation at Federal and State levels
should be developed to supplement existing authority under
the National Polution Discharge Elimination System (NPDES) ,
the Safe Drinking Water Act,  and State water quality regu-
lations to effect stricter controls on environmental mon-
itoring and reporting with respect to ground water.

     3.  With regard to the Anaconda \vaste injection program,
all available chemical and water level data for pre-injection
and post-injection periods should be evaluated to ascertain
if waste is migrating out of the Yeso Formation and into
overlying aquifers containing potable water.  Of particular
concern are radium-226 and thorium-230 because of its abun-
dance (82,000 pCi/1) in the injected fluid.

     4.  Available chemical data for ground-water samples
collected by Kerr-McGee from wells located adjacent to
Arroyo del Puerto and San Mateo Creek should be evaluated
for long-term trends in water quality.  Data for the Wil-
coxson (P. Harris), Bingham,  Marquez, and County Line Stock
Tank wells are of principal concern.

     5.  Water-quality data from the newly completed moni-
toring wells peripheral to the Kerr-McGee mill should be
cross-checked using outside laboratories to determine the
extent of contamination in the Dakota Sandstone.

     6.   If the verified source of ground-water contamina-
tion in the Broadview Acres .and Murray Acres subdivisions
is the nearby uranium mill,'a sound monitoring program
should be developed to predict off-site contaminant migra-
tion and to determine if there is a need for remedial action.

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     7.  The breadth of mining and milling activities in
the Grants Mineral Belt clearly requires additional study
if ground-water impacts are to be understood in any detailed
or quantitative sense.  The present study provides a pre-
liminary assessment of but a small facet of the overall
activity in the district.  Further study is recommended to
determine impacts of past operations or expected impacts
from mines and mills now in the planning or construction
stage.  Site specific investigations are necessary to deter-
mine the hydraulic and water quality responses to dewatering
and solution mining.

     8.  Additional ground-water samples should be collected
from wells adjacent to the Rio Puerco and east of Gallup to
determine if radium concentrations are acceptably low and
to establish baseline conditions for future reference.   Con-
centrations of trace metals should also be measured (recom-
mended) for the latter reason.

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                                                          12

                   AREAL'DESCRIPTION


                         of Study Area
     The  Grants Mineral  Belt,  located  in  the  south-
 eastern part  of McKinley County  and the north-central
 portion of Valencia  County,  is a rectangular  shaped
 area in northwestern New Mexico  (John'  and West,  1963).
 It  is 24  to 32 kilometers-wide in the  north-south direction
 and 137 to 177 kilometers.long from east to  west  (see  Figure
 (Kelley,  1963; Kittel, Kelley, and Melancon,  1967).

     At present,  three mining  districts dominate the
 Mineral Belt.  These are Churchrock on  the  west,  Grants -
 Ambrosia  Lake  in  the center',  and Paguate-Jackpile on
 the east.  These  contain the  Gallup, Churchrock,  Smith
 Lake, Ambrosia .Lake,  Grants,  North Laguna,  and South
 Laguna mining  areas.  The districts are physiograph-
 ically separated  by  Mt.  Taylor,  which  separates  Laguna
 lying to  the  east and Grants  and Gallup to  the west
 (Kelley,  1963; Kittel, Kelley, and Melancon,  1967).

     The  Continental Divide,  extending through approxi-
mately the middle of the  area, separates the region
into two  areas of drainage.   West of the Divide streams
and rivers drain into the Gulf of California via  the
Colorado River system, while to  the east  they eventually
join the Rio Grande  (Button, 1885).  Nearly all the
streams in the area  are  intermittent and  flow only dur-
ing periods of intense precipitation (Cooper and John,
1968; Gordon, 1961).
     The Grants Mineral Belt of northwestern New Mexico
is within the Navajp and Datil sections of the Colorado
Plateau physiographic province (Fenneman, 1931).  To
the east are the Southern Rocky Mountains and to the
west and south, the Basin and Range province.  To the
north lie the Central Rocky Mountains.

     Characteristic landforms within the study area
include rugged mountains, broad,  flat valleys, mesas,
cuestas, rock terraces, steep escarpments, canyons,
lava flows, volcanic cones, buttes, and arroyos
(Kittel, Kelley, and Melancon, 1967; Cooper and John,
1968).   Lava flows and volcanic necks are the predomi-
nant landmarks of the Datil section (Fenneman, 1931).

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13

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                                                           14
     There  are no perennial, streams  in  southeastern
McKinley  County.  These  and' the natural  depressions
such as'Ambrosia Lake, Casamero Lake  and  Smith  Lake
contain water only  after heavy rains.'  There  are  inter-
mittent ponds and lakes  in" the volcanic  craters of the
Cebollcta Mountains.   The--only perennial  source of
water  is  part of Bluewater Lake at  the  junction of Azul
and Bluewater Creeks  (Cooper and John,  1968).
        1 I n d u s t r i e s
      The principal  industries  in McKinley  and Valencia
 Counties of northwestern  New Mexico, until  relatively
 recently, were  farming  and  ranching.  Tourism and  small-
 scale logging were  secondary.  The  land  is  mostly  used  for
 livestock grazing,  while  some  irrigated  farming  is clone in
 the valleys of  Bluewater  Creek and  the Rio  San Jose.  The
 main  crops are  vegetables,  and plants exist in the area for
 processing and  packaging  them.

      Now that: uranium ore has  been  found to be wide-
 spread throughout the Grants Mineral Belt,  the uranium
 mining and milling  industry predominates.   What  was a rural
 agricultural economy has  metamorphosed into an industrial
 one>  The figures on Table 1 indicate the importance of
 the uranium industry in the economy of New  Mexico, especially
 the northwest part.  The growth of the uranium industry has
 created a need  for associated  industries and services,
 especially the  chemical industry.  Caustic  soda  and soda ash
 are the main alkalies used in  uranium milling.   The construc-
 tion  and housing industries have flourished, and mining
 supply firms and concrete companies have been established
 (Gordon, 1961).

     Gallup and Grants have grown rapidly, as have some of
 the smaller villages and communities.   The population of
McKinley County has grown from 27,451  in 1950 to 43,208 in'
 1970,  and. that of Valencia from 22,481 to 40,539 (Univer-
sity of -New Mexico,  Bureau of Business Research,  1972).

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                                                           16
                  ' GEOLOGY  AND  HYDROLOGY
      The  principal  bedrock  and  alluvial  stratigraphic
 units in  the  Grants Mineral Belt  range  in  age  from
 Pennsylvania!! to  Recent  (Hilpert,  1963).  Figure 2  through
 the  Grants and Ambrosia Lake areas portrays these units and
 the  dominant  structural feature which is the Chaco slope
 developed on  the north flank of the Zuni uplift.  Conditions
 in the Churchrock area are essentially the  same.
     Pronounced topographic expression of the gently
sloping bedrock units is abundantly evident in the
Grants Mineral Belt.  The sandstone strata on the
mesas, actually gently dipping cuestas, form protective
caps which resist weathering,   The concave  slopes
and bottom lands form on Jess resistant units, typi-
cally shales and thin-bedded sandstones interbedded
with shale.  Although geographically less extensive,
.lava beds and limestone strata also function as caprocks.
     Due to the scarcity of perennial surface water bodies,
ground water is the principal source of water in the study
area.  Industrial, municipal, stock, and private domestic
wells tap both bedrock and alluvial aquifers.  In general,
wells of low to moderate productivity, are possible in the
unconsolidated valley fill which con-stitutes an aquifer,
primarily along the broad valleys of the Rio San Jose and
the Rio Puerco.  Numerous shallow domestic wells south
and southwest of the United Nuclear-Homestake Partners mill
also tap shallow, unconfined aquifers.  Part of the water
supply for Gallup, and essentially all of that for Milan
and Grants, is derived from shallow wells tapping valley
fill and interbedded basalt layers (Dinwiddie et. al., 1966)

-------
                                                                                        17
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                                                                                 18
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                                                          19
     Process water for the various uranium mills is derived
from deep wells tapping bedrock aquifers.  This is true for
the Anaconda Company and United Nuclear-Homestake Partners'
mills, both of which tap the San Andres Limestone.  Part of
the feed 'water for the Kerr-McGee mill is from wells in the-
Morrison Formation and the more deeply buried Glorieta Sand-
stone and San Andres Limestone, with the balance coming from
treated mine drainage water.  Without exception, the opera-
ting mines continuously pump ground water as part of the
mining operation.  Where economical concentrations of uranium
are present, ion exchange plants are operated to effect
recovery from the waste streams, but radium removal is not
practiced.  In effect, the various mines are high capacity .
wells which locally dewater.the ore-bearing formations,
chiefly the Westwater Canyon Member of the Morrison Forma-
tion and to a lesser extent, the overlying strata such as
the Dakota Formation.

     The  impacts of  ground-water pumping and discharge to
surface water courses are xraried.  Declining water levels in
the aquifers tapped, and possibly in the adjacent formations,
are immediately noticeable.  For example, in the Churchrock
area, the static water level in the old Churchrock mine is
declining about 0.3 m/mo clue to dewatering at the United
Nuclear and Kerr-McGee mines.  Discharge of the mine water
transforms nearby dry washes and ephemeral streams into
perennial ones.  Rio Puerco, Arroyo del Puerto and San
Mateo Creek are cases in point.  Water introduced to these
channels will persist until the losses due to bed infiltra-
tion, evapotranspiration, and diversion equal inflow.  In-
filtration of such waters to shallow alluvial aquifers may be
adverse,  depending on the quality of infiltrating water
relative  to ambient water quality in the aquifer and the use
to which  shallow ground water is or will be put.  The com-
bination  of declining water levels in the deeper, bedrock
aquifers  and deteriorated water quality in the shallow
aquifers may have particularly adverse impacts on stock wells
also used by the local populace for potable supply.

     Sorption of radionuclides such as radium on the stream
sediments may result in a buildup of material that will later
be dispersed by channel scouring associated with flash flood-
ing.  Both the gradual buildup of radium in the sediments
and its subsequent redistribution will result in increased
levels of radioactivity in the environment as compared to
ambient, pre-mining conditions.

-------
                                                          20
     Uranium mining and milling in the study area are of
particular importance to several aquifers in the study area.
Wastes from the Anaconda Company mill in Bluewater have
infiltrated via the tailings pile and affected the shallow,
unconfined aquifer  (Tsivoglou and O'Connell, 1962).  Injec-
tion of wastes into the deeply buried-Abo and Yeso Formations
has increased radioactivity and salinity levels therein.
Strictly speaking, these-are not considered aquifers because
of the mineralized water naturally present, and the impacts
were expected or predicted beforehand.  However, should the
contamination move upward into potable aquifers and extend
too far laterally, injection would likely be terminated.
Widespread contamination of the shallow aquifer adjacent to
the tailings pond would similarly require abatement.

     The Chinle Formation is a source of domestic water in
the Murray Acres and Broadview Acres subdivisions down-
gradient from the United Nuclear-Homestake Partners mill.
As will be shown below, the shallow alluvial aquifer in this
area is already believed to be contaminated by  the  infil-
tration of effluents from the mill.


     In the Ambrosia Lake area, contamination of shallow
ground water is likely to be a result of infiltration of
1) effluents from the tailings ponds at the Kerr-McGee
mill, 2)  mine drainage water that is introduced to settling
lagoons and natural water courses,  and 3)   discharges from
ion exchange plants.  Seepage from the now inactive United
Nuclear,  Inc., (formerly Phillips)  mill tailings pile is also
undoubtedly present in the shallow subsurface ,

     The  ultimate  impact  of  these waste waters on
ground water quality is unknown.   It is unlikely that seepage
returns to the deep, bedrock aquifers will occur because of
their relatively great depth and the presence of numerous
impermeable layers between the shallow alluvial materials
and the principal aquifer (V/estwater Canyon Member).   Very
limited volumes of water in the shallow alluvium render
it an insignificant source  of  supply.  What water is
present near the mining and milling areas  is now likely to
be contaminated to varying degrees  by industrial effluents.
The long-term infiltration of radium-laden water along the
stream'channel of San Mateo Creek may adversely affect the
quality of shallow ground water now developed for stock
watering, both above and below the  confluence with Arroyo
del Puerto.

-------
                                                           21
      The potential for future problems of water availability
 for ore processing in Ambrosia Lake have been cited by
 Cooper and John (1968).  In essence, dewatering of the prin-
 cipal aquifer (Westwater Canyon Member of the Morrison
 Formation) to facilitate mining may necessitate use of the
 poorer quality water in the underlying Bluff Sandstone.

      Hydrogeologic conditions in the vicinity of the Church-
 rock mines basically resemble those in Ambrosia Lake with
 respect to potential impacts of mining and milling on ground
 water.  The potential for contamination of shallow ground-
 water resources is greatest along the channel of the Rio
 Puerco.  Under natural conditions, shallow ground water was
 scarce or nonexistent; hence, deeper wells completed in
 bedrock are required for a reliable supply.   With continued
 infiltration of mine drainage water, at least local satura-
 tion of the alluvium may occur and lead to ground water
 development using shallow wells.   However, the radium con-
 tent of the drainage water discharged to date is excessive
 for potable or stock use of such water, and long term
 recharge with mine drainage water is not recommended.   The
 potential for contamination of shallow wells along the Rio
 Puerco, particularly on the east and west fringes of Gallup,
 is unlikely*


    1NDUSTRY^SPONSOI^                MONITORING  PROGRAMS
 I n t rodu c 11on

      A principal  goal  of the  project was  to  evaluate  the
 nature and extent  of water  monitoring programs,  and data
 therefrom, as  implemented by  industry.   This  presumed  that
 descriptions  of  the  sampling  points,  analytical  procedures,
 and resulting  data would be available' for examination  upon
 request to the companies.   With  the  exception of the Ana-
 conda Company, this  was  not the  case.

      The  inadequacies  of industry-supported  testing and
 monitoring programs  noted by  Clark (1974)  include  lack of
 sufficient data,  intermittent data,  and unreliable  data....
 conclusions, which are  at least not  contradicted by the
 present study.


     The most extensive monitoring and testing programs
to detect ground-water  contamination  are conducted by Kerr-
McGee and Anaconda.  By comparison, United Nuclear and
United Nuclear-Homestake Partners  have minimal programs
both at the mines and at the mills.   Therefore,  the  Kerr-McGee
and Anaconda programs,  although in need of revision, are a
marked improvement compared  to inactivity.

-------
                                                          22
     Of greatest environmental concern is the discharge of
waste water originating from mining and from ore processing
Included in the latter is the discharge stream or tailings
from conventional acid and alkaline leach mills and from
ion-exchange plants.  A third problem area, concerning im-
pacts on ground-water quality from solution mining in the
Ambrosia Lake area, is essentially unknown outside the
industries involved.
     Identification of industrial ground-water monitoring
programs, if any, to determine hydraulic and water quality
responses to both shaft and solution mining were beyond the
scope of the present project.  It is expected that solution
mining and the use of IX plants, with and without recycling,
will gain in popularity, particularly if stricter discharge
limits for uranium induce greater capital investment in IX
equipment.  For this reason, and also because of the heavy
ground-water extraction associated with deep mining,
deliberate monitoring programs should be implemented and the
data made publicly available to detect likely hydraulic and
water quality responses .
Adequacy of Water Quality' Data and Monitoring Programs
     Evaluating the adequacy of a ground-water monitoring
program is rather subjective and rarely will there be
unanimity of opinion.  The diversity of mining activities
and geologic or hydrologic settings necessitates great
variety in program design.  Outlooks and goals of diverse
groups also play a large-role.


     On the basis of the information utilized, the principal
deficiencies with ongoing programs can be classified under
the following headings:

       1.   Ground-water  monitoring
       2.   Analytical techniques and reporting procedures
       3.   Regulatory agency review

-------
                                                          23
     Existing ground-water sampling networks range from
non-existent to defective.  The non-existent networks in-
volve entire operations, as in the case of the United Nuclear
Corporation^or portions of operations, as in the case of the
solution mining conducted by United Nuclear-IIomestake Partners
The latter's monitoring of a single wel] to determine shallow
ground-water contamination is considered grossly deficient.
In essentially every instance of mining and milling, baseline
ground-water conditions were not defined, hence any changes
due to disruption of natural conditons cannot be assessed.
In the case of the Anaconda waste injection program, for
example, there is no information concerning pre-injection
concentrations of stable and radioactive chemical species
in overlying potable reservoirs possibly already affected
by the wastewater.


     Of the active ground-water monitoring programs that
were reviewed, great reliance is placed on documenting
the quality of water in active wells within the surround-
ing region.  This is laudable with respect to current water
use, but-not especially productive in terms of defining
water quality impacts.  In many instances, sampling wells
are located hydraulically upgradient or are so far removed
from the likely effects of mining or milling as to show no
change.  Wells of excessive depth, i.e., below the aquifer
likely to show change, are also of dubious value as monitor-
ing points.  With the exception of a portion of the Kerr-
McGee onsite net, wells specifically constructed for monitor-
ing are commonly too few in number and improperly situated
with respect to depth and (or) location.  Compared to the
multi-million dollar uranium industry, producing multi-
billion liters of toxic effluents, the ground-water sampling
and monitoring programs represent minimal efforts in terms
of network design, implementation, and level of investment.
There are indications  that deterioration in water quality-
is occurring through  time  and  very possibly in response to
the waste volumes  disposed of  in the  last 15 years.  With
regard to this  disposal  scheme, there  is real question as
to whether the  data  that have  been generated have been scru-
tinized.   In other instances,  expected adverse impacts of
seepage on shallow ground water have  not been found because
they have either  not  been  sought or have been sought in
unlikely locations.

-------
                                                          24
     No  response  to  the  requests  for  information  regarding
analytical methods and reported results  was  received from
three  of the  four companies  contacted.   A review  of the
available records by the authors  at the  New  Mexico  Environ-
mental Improvement Agency  indicates many deficiencies in
the  company programs.  These  deficiencies include lack of
information concerning minimum detectable activities for
analytical procedures utilized, overly large  error terms,
poor agreement with outside laboratories, absence  of quality
assurance programs,  inability to  detect radionuclides at truly
environmental or background levels, and irregular  or random
sampling frequencies.  Analysis for specific  radionuclides
such as thorium, lead-210, polonium-210,  radium-228, all of
which are associated  with mining  and milling  effluents,  is
rarely done.   With the exception  of the Anaconda Company,
results of monitoring programs to  determine background levels
of both radionuclides or  chemical  components  are not discussed
in any of the reports of  the  companies.   From the  data/reports
reviewed, it  is unknown whether the various company  labora-
tories have the analytical capabilities to accurately analyze
for environmental  levels  of the common radionuclides associated
with the uranium mining and milling industry.
      During  February  11  and 12,  1975,  a brief review of
 available  company  records,  USAEC  inspection reports, and
 mill  licenses  in the  possession  of NMEIA was  conducted.
 The following  findings  are  preliminary, as  not all of the
 company  records were  available at the  time  of the  review:

      1.  The available  records are disorganized and incomplete.
 A  complete copy of each  company's radioactive material li-
 cense and  supporting  correspondence could not be found.  Radio-
 logical  monitoring data  reports  were often  missing or incom-
 plete.   Attachments and  maps referred  to in correspondence
 in the records could  not be found.

      2.  Except for the  license  condition requiring monitor-
 ing data related to the  Anaconda waste iniection program,  USAEC
 licenses for the other uranium mills have never specifi-
 cally required the establishment of ground-water monitoring
 networks or  reporting of any data pertaining  to such moni-
 toring.   (Some limited  programs  have,  however, been described
 in company license applications).

-------
                                                          25
     3.  It appears that no effort has been made to review
or to summarize the reported monitoring data.  No interpretive
or summary reports concerning environmental impact have been
prepared.

     4.  Almost no information lias been reported by the com-
panies describing their radiochemical analytical procedures,
quality assurance programs, or the accuracy and precision
of reported results.

     5.  Reports of company efforts to evaluate the fate of
liquid tailings waste effluents (e.g., materials and water
balances between input versus evaporation, spillage, or
ground seepage and total pound capacity) are essentially
non-existent.

     Noted deficiencies at the Federal level stem largely
from the rather liberal, initial licensing conditions (with
respect to ground-water monitoring),  perfunctory inspection
of company monitoring programs and data, and, in general,
the somewhat haphazard manner in which information was filed
and catalogued for later reference.  Simply put, the uranium
mining and milling industry has not been overly pressed to
monitor and protect ground-water resources and what efforts
they have put  forth have largely not  been reviewed.

-------
                                                          26
               GROUND-WATER QUALITY IMPACTS

Introduction

     The breadth of mining and milling operations  in  the
study area clearly requires additional study if  ground-water
impacts are to be understood in any detailed or  quantitative
sense.  The following discussion must  necessarily  be  regarded
as a preliminary assessment of but  a small  facet of the over-
all mining and milling activity.  Impacts  of inactive opera-
tions, such as the Phillips mill, or future impacts from
sources under development, such as  the Gulf mine and  mill
in San Mateo or the nearby Johnny M mine,  are not  addressed
herein.  Very large voids in our knowledge  of impacts on
water sources include solution mining  practices  and dewater-
ing of ore bodies.  Essentially no  data or  interpretive
reports are available outside industry circles that describe
the hydraulic and water quality impacts of  these operations,
which may well have the greatest impact of  all on  ground-
water.

      Contaminated  and  background concentrations of selected
radionuclides, as  well as'gross  and trace  chemical constituents,
were  determined  for  71 wells  in  the study  area. These data
are presented in  Tables 2  through 5.   In certain  locations,
these data relate  to surface  water  phenomena such as natural
streams or to manmade  features,  foremost of  which are tail-
ings  disposal ponds  or streams  originating  as mine discharge.

      The data are  discussed by  study  area  and by  uranium
mining/milling activities  therein.

      Table 5 summarizes background  data from the  present
study and categorizes  the  data  according to  study area
and aquifer.  These  reported  values are the  lowest concen-
trations reported  for  samples  collected during  the study
and may not necessarily represent "true" background  or
ambient values that may have  existed prior  to uranium
mining and milling activites  in  this  area.   For the  most
part, the values  shown for  "bedrock"  aquifers are not from
the principal ore-producing formations, namely  the West-
water Canyon Member of the Morrison Formation.  In the
Grants-Bluewater  area, "bedrock" refers primarily to the
San Andres Limestone, whereas near  the United Nuclear-
Homestake Partners mill,  the  term includes  the  San Andres
Limestone and the  Chinle  Formation.  At Ambrosia  Lake,
the Westwater Canyon Member and  the Bluff Wingate Sandstones
were  sampled, whereas bedrock aquifers in the Churchrock
area  mostly include the Dakota Sandstone.

-------
                                                                                                                                                        27
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              Table 3
Selenium and Vanadium Concentrations
  in Selected Ground-water Samples
NUMBER
United
9102
9107
9113
9134
9135
Grants
9117
9118
9119
9120
9121
9123
9129
DESCRIPTION Se (mg/1)
Nuclear-Homestake Partners
G. Wilcox
C. Worthen
C . Meador
Well #2 (UNHP) -
Well D (UHNP)
Bluewater
Monitor well (Anaconda)
Well #2
Well #4
Mexican Camp
Berryhill, Section 5
Engineer's well
Jack Freas

1.06
1.06
' 0.20
<0.01
1.52

0.01
0.01
<0.01
<0.01
<0.01
0.01
0.02
V (mg/1)

<0.3
0.3
0.3
1.3
0.4

0.3
0.8
0.9
1.0
0.8
1.1
1.3
Ambrosia Lake
9132
9201
9207
9208
9209
9211
9213
9214
9215
9219
N. Marque z windmill
KM-46, P. Harris (Wilcoxson)
KM--S-12
KM- 4 3
KM- 4 4
KM- 4 8
KM-B-2
KM- 3 6- 2
KM- 4 6
KM- 5- 2
.13
<0.01
<0.01
.29
.01
<0.1
<0.1
.02
<0.01
0.01
< .3
< .3
0.4
0.8
<0.3
0.5
O.G
<0.3
<0.3
<0.3
Gallup-Churchrock
9138
9140
9141
9142
9221
9222
Paguate
9230
9232
923-3
Boardman Trailer Park
Dixie well
Churchrock Village
White well
CRKM-11, E. Puerco
CRKM-16, Puerco well
-Jackpile
Well #4
New Shop well
Paguate Municipal well
<0.01
<0.01
<0.01
<0.01
0.01
<0.01

<0.01
<0.01
0.01
<0.3
<0. 3
<0.3
<0.3
<0.3
<0.3

<0.3
<0.3
<0.3

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                                                          35

 In  the  Paguate-Jackpile  area,  three  of the  four  wells  examined
 are  in  the Morrison  Formation  (Jackpile Member).

     Table 6  is  a compilation  of published and unpublished
 uranium,  radium, and  gross beta concentrations in ground water
 for  various localities in the  Grants Mineral  Belt.   These
 are  largely from the  ore bodies or from strata adjacent
 thereto,  and  arc intended to show natural concentrations of
 these radionuclides.  Despite  the wide  variations,  radium
 rarely  exceeds 10 pCi/] a'licl is commonly less  than 5  pCi/1,
 except  in mines, or  in ponds formed  from mine drainage.
 Dissolved uranium is  also enriched in waters  associated
 with active mines and. can readily reach concentrations
 of several hundred pCi/1.  Natural background uranium  levels
 are difficult to estimate from the limited data, but would
 appear  to be  on the order of 20 pCi/1 or less.   Concentrations
 markedly greater than the foregoing, particularly if associat-
 ed with mining and milling activity, may be evidence of
 degradation.

 Blu cwa t e r-Mila n-Gr a n t s

     The Anaconda Company mill  and  tailings  pile  is  partially
 bounded by cultivated areas  situated  in Bluewater Valley, which
 contains the  town of Bluewater  on  the western  edge.   Irregularly
 snaped  landforms  northeast  and  east  of  the mill are  basalt
 lava flows which are also the  substrate for  a  portion of the
 tailings ponds.   In nearby  areas  the  basalt  constitutes a
 principal shallow aquifer.   The San Andres Limestone, the
 principal bedrock aquifer,  also crops out  in close proximity
 to the ponds.   Thus, there  are  means  by which  wastes  from
 the ponds can enter potable  ground water.

     The expected impacts of uranium mining  and milling on
groundwater in the developed area between Bluewater and Grants
 can be traced to the Anaconda Company mil].    It is also pos-
 sible, but unlikely, that the United Nuclear-Homestake Part-
 ners mill could adversely affect  ground-water  in  this area.

     Radium and nitrate concentrations   in ground  water  are
 depicted in Figure 5.  With the exception of the  Berryhill
 Section 5 well (station #9121)  and the Anaconda injection
 well (#9021),  radium-226 in both the alluvial/basalt aquifer
 and in the underlying San Andres  Limestone ranges from 0.06
 to 0.42 pCi/1.  If well #9124 is  considered as a background,

-------
                 ^$*S^#ffi
                 &%v5:^u^^«
  \\. \ ^>^W^ \Wn'i"*ri*8^X ^ SANDY ' M. •£^£V\*CTffiSI*^l

^|^>X^^
1, ^ i\iW^-fr''^^HJ^'^^^i^^fc^        ^?\!^^K
>«^%«4jjjjhs3^^^^^^^           :J&jj>
                 mfa&vm&Msiii
                         \Vjt$aP W-1 •^^Jfe^S
Figure 4 .   The Anaconda fompany Uranium Mill  and
          Tailings  Pond-Bluewater

-------
                                             Table 6
                                                                                                       37
                                Summary of Reported Cqnconlrat ions
      for Radium, Gross Beta and Natural Uranium In Ground Wator In the Grants Mineral  Belt
Location
T R S Q
9 12 11 222
12 11 24 4
12 11 24 4
12 12 4 343
12 10 8 3
13 8 30 100
13 8 30 200
13 9 29 144

13 9 29 41
14 9 28 441
14 9 32 413
14 9 32 221
14 9 17 400
14 9 18 400
14 9 28 143
14 9 29 312
14 9 30 200
14 9 32 122
14 9 32 314
14 9 34 422
14 9 36 313
14 9 36 313
14 10 24 100
15 12 17 123
17 12 20 11
17 16 35 14
17 16 35 14
17 16 35 14
17 16 35 12

23 14 .3 13

Source Depth
(melers)
Paxton Spring Spring
Industrial Wei 1
Anaconda Well (Injection)
109
109
Aquifer2
Qb

Ps
Radium
pCi/l
4.3
0.4
0.36
gross
B






Bluewater Lake Surface <0.1
Well
El Paso Natural Gas Co.
El Paso Natural Gas Co.
Westvaco Mineral Development
Co.
Mine Dri ft
Wei 1
We 1 1
Mine Drift
Kermac Nuclear Fuels Corp.
Kermac Nuclear Fuels Corp.
Kermac Nuclear Fuels Corp.
Phillips Petroleum Co.
Kermac Nuclear Fuels Corp.
Homes1ake-New Mexico Partners
Homestake-New Mexico Partners
United Nuclear Company
United Nuclear Company
United Nuclear Company
Kermac Nuclear Fuels Corp.
Homestako-Sapin Partner
Crownpoi n1 Wei I 1
UNC-Nt Churchrock Mine
UNC-NE Churchrock Mine
UNC-NE Churchrock Mine
KM-Section 35, Churchrock
Mine
Gas Company Burnham Well 1
Pond In South Paguate pit
442 -.




137

174



216
224

196
168
306

457 '

372
714
457
518
549
549

1585
Pond
Pym
Jmw
Kd
Jt

Jt
Jmw
Jmw
Jmw
• Kd
Jmw
Jmw
Jmw
Jmw
Jmw
Jmw
Jmw
Kd
Jmw
Jmw
Jmw
Jmw
Jmw
Jmw
Jmw
Jrnw

Jmw

0.2±0.1
8.5+1.7
2.9+0.6
5.1

5.1
1.1
10 +2
42
2.7+0.5
5.6+1.1
1.1
10 +2
2.0±0.4
42
1.1+0.2
1.4+0.3
27 +5
1.2±0.2
2.310.5
0.2+0. 1
0.05
0.62
0.09
8.10


0.24
190

36
12
150





18
37
69
39
12
49
18
9.
75
6.
56
9.









+ 5
1 2






+ 3
+ 6

+ 7
+ 2

± 4
0+1.3
11 1
5± 0.9
1 8
8± 1.4








U natural
d I ssol ved
pCi/l .
1.82
4.27

0.84
1.96




139
<.07
8.4
16.1












<0.28
185
22
847


0.05
170
1.  Data sources are as follows:
         Ambrosia Lake area:  Cooper and John, 1968
         Laguna-Paguate:  Letter from F. P. Lyford, U. S. Geological Survey, WRD, Albuquerque, NM
                          to John Dudley, New Mexico Environmental  Improvement Agency,
                          dated February 12, 1975.
         Churchrock:  Written communication from W. Hiss and T. Kelley, U. S. Geological Survey,
                      WRD, Albuquerque, NM to John Dudley, New Mexico Environmenlal Improvement
                      Agency, dated February 14,  1975.
         Grants-Bluewater-Prewitt:  Letter from J. M. Stow, U. S.-Geological Survey, WRD, Albuquer-
                                    que, NM to Eugene Chavez, State Engineer Office, Roswell, NM,
                                    dated April  14, 1961.
2.  Aquifers:
        Qb
        Kd
        Jmw
        Jt
        Ps
        Pym
basalt flow
Dakota Fm.
Morrison Fm., Weslwater Canyon Mbr.
Tod 11 to Fm.
San Andres Ls.
Yesd Fm, Meseta Blancha Mbr.

-------
                                                                                 38
            0.06
            ©124
           0.8
 O.26
0123
 3.2
                                  O.17
                                  E3122
                                   1.3
                                T<;i!ings
                                 Pond
Bluewater
       liftti
      0.95
         riAnaconda
         U0.50
           £2118
           9.0
QUALITY OF WATER INJECTED
Period
19GO to
1S65
1966 to
1963
Radium
292
pCi/l
11DpCi/[
hSilrste
105ppm

Source
West;
1S72
MR!;
1975
                      O.18
                      ©115  0.2
                       3.9  ell9
                            5.4
                 0.27
                 EI 120
                 0.73
            O.14
            ©129
            2.5
                                     O.21
                                     ra127
                                     0.03
                              O.15
                              0128
                               1.4
                 N
                 >
     O
4 km
                                                   O.13
                                                   0101
                                                   4.2
              SCALE
                                          O.O9
                                          ©103
                                           5.5
            Principal water bearing unit

          ©  ALLUVIUM/BASALT

          Q  SAN ANDRES LIMESTONE

          A  GLORIETA  SANDSTONE

          X  YESO FORMATION (injection)
                  Map symbols

              ^-radium, pCi/l
         0.18""^
         ©127—well  location and identifier
         3.8 >^
              ^ nitrate plus nitrite, mg/l
      Figure  5.   Radium  and Mtrate  Concentrations  in  Ground
                    Water in the Grants-Bluewater  Area

-------
                                                           39
there is evidence of leakage from the injection zone.
Natural uranium and chloride from the monitor well  (#9117),
Roundy windmill, and North well (#9122)  for the period,  1969
througn 1973 are increasing with time and vary directly  with
the volumes of waste injected.   The concentration of polonium-210
(2.3 pCi/1) exceeds all ot'her wells in the Bluewater-Grants
area and is well above the. average of 0.33 pCi/1 for six wells
in bedrock.  Concentrations of chloride  and natural  uranium  in
the waste water average 2010 ppm arid 7340 pCi/1, respectively
for the period, 1960 to 1965 (West, 1972).   Radium  from  1960
through 1969 averages 221 pCi/1 (Clark,  1974).   Contrary to
original projections, contamination apparently extends  into
the San Andres Limestone, according to the partial  chemical
data for these three monitoring wells.
      Significant introduction of wastes into ground water in
 the Bluewater area occurs as a result of seepage from the
 tailings ponds.  Past investigators noted the migration of
 nitrate from the ponds (New Mexico Dept. of Public Health,
 1957).   Changes in the milling process greatly reduced
 the nitrate content in the tailings, but seepage has con-
 tinued  at a rather high rate, averaging 182.9 x 106 liters
 per year for 1973-1974 (Gray, 1975).  The average volume
 injected in the same period was 348 x 106 liters.  Therefore,
 the seepage:injection ratio is 0.53.  In essence, one-third
of  the waste stream portion not evaporated enters the shallow
aquifer.  Assuming that this ratio applies to the period
1953-1960, seepage is estimated at 3200 x 106 liters or
845 million gallons.  From 1953 to mid-1960,  the seepage frac-
tion was probably even larger, but is unknown.   Discounting
this seven-year period and assuming an average  radium concen-
tration of 130 pCi/1 in the seepage, 0.4 curies of radium
entered the shallow aquifer, which is very definitely potable.


      It  is  strongly recommended that all available chemical
data  for both  pre-  and post-injection periods  be evaluated,
together  with  monthly  or  quarterly injection volumes to fur-
ther  confirm or deny the  apparent trends.   If  the
trends  shown are valid,  thorough reevaluation  of the
injection method of waste disposal and construction of
additional  monitoring  wells in the Yeso Formation and the
Glorieta-San Andres is in order.   Because of low MFC values,
this  is  particularly true if increasing concentrations  of
radium-226  are appearing  in the aquifers above  the  injection
 zone.

-------
                                                         40
     Impacts of tailings pond seepage on nearby shallow
groundwater are unknown because of the inadequacy of properly
located sampling wells.  Ground-water flow patterns in the
vesicular basalt and interbedded alluvium underlying the
northwest pond and portions of the main pond are not described
in the available references.  Complex permeability distri-
butions and density considerations add further complications.
However, seepage is occurring and it is possible that the
Company estimates stated above are conservative.

United Nuclear-Homestakc:. Partners Mill and Surrounding Area

     The mill is partially  surrounded  on  the soutlwest
or downgradient side by housing  developments and irrigated
farm lands,  both of which depend on  local ground-water
supplies.   Also obvious in  the photograph as a dark
tan band around the base of the  tailings pile is extensive
seepage.  This is collected and  pumped back to the
pond above the sandy tailings, but seepage from  the
pile proper and from the encircling moat can enter the
ground-water reservoir.  The five-sided polygon adjacent
to the mill buildings is an inactive tailings pile that
was formerly part of the Komestake-New Mexico Partners
mill.  In the upper left-hand portion of the photograph
is shown the terminus of the San Mateo Creek drainage
from the San Mateo and Ambrosia  Lake areas .

     Three distinct aquifers are present in the area of the
mill and surrounding developments.  In ascending order, these
include the San Andres Limestone, the Chinle Formation, and
the alluvium.  Water table conditions and a  southwestward
lateral flow gradient prevail in the latter,  with static water
levels about 15 meters below land surface.   The San Andres
Limestone originally was under artesian head,  but heavy pump-
ing for irrigation and for industry has removed much of the
head once present.   Data presented by Gordon (1961) indicate
a downwind flow gradient, but the permeability of the Chinle
Formation is low and actual vertical water  transfer is prob-
ably minimal.  The chief significance of these hydrogeologic
conditions is that liquid effluents  produced by the uranium
milling operation are likely to  infiltrate  at the mill site
and travel in a south-southeast  direction toward the nearby
subdivisions.  On the other hand, water quality in the Chinle
Formation and the still deeper San Andres Limestone is likely
to be unaffected.

-------
                                                         41
     Radium concentrations-in groundwater (Figure 6) from
the San Andres and Chinle range from 0.05 to 0.27 pCi/1,
with a mean of 0.16 pCi/1 for six determinations.  Realis-
tically, assuming that minimum detectable amount is 0.1
pCi/1 versus 0.05, the average increases to 0.18 pCi/1.
The peak value from shallow wells tapping the water table
aquifer in the alluvium is 1.92 pCi/1 in well D, the
mill's single active monitoring well (#9135).  Although
below the standard of 3 p"Ci/l, this value does indicate move-
ment of contaminants away from the tailings pond.  Attenuation
due to sorption may mask a very sharp concentration gradient
between this well and the pond.  At a distance of approximately
0.6 kilometers from the ponds, radium in the shallow aquifer
reverts to levels of 0.13 to 0.72 pCi/1 and averages 0.36 pCi/1,
or about twice that present.in the bedrock reservoirs at
depth.  Relatively high concentrations (0.72, 0.61 pCi/1)
in the Worthen and Enyart wells may reflect plumes or fronts
of contaminants - that have advanced ahead of the main body.
The water table map (Figure 7) prepared by Chavez (1961),
portrays an elongated, northeast-trending lobe or mound cen-
tered on the smaller tailings pile from the now inactive
Homes take-New Mexico Partners mill.

     The possibility of ground-water pollution from the United
Nuclear-Homestake Partners tailings pond was noted in the
early 1960 's (Chavez, 1961).   Samples from on-site monitor-
ing wells completed in the alluvium contained from 0.8 to
9.5 pCi/1 radium despite the fact that ore had been pro-
cessed for less than two years.  These concentrations arc
markedly above the normal range of 0.1 to 0.4 pCi/1 in
wells several miles west of the mill and from wells in the
alluvium between San Rafael and Grants.

     Chloride and TDS data for well #9107 (Figure 6) support
the idea of a tongue of contaminated groundwater in the area
between this well and the tailings pile.  Heterogeneities
in sediment permeabilities, coupled.with irregular induced
flow gradients resulting from seepage return flows, make
definition of the polluted front rather difficult.  It is
clear that one well (well D,  #9135) is inadequate for the
task.

     Selenium concentrations  (see Table 3) in several of the
domestic wells located downgradient from the mill are anoma-
lously' high and are, perhaps, the best indicator of ground-
water contamination.  Nearby wells (#9102, #9107, and #9113)

-------
                                                        /
                                                                        42
                                                      /
      Principal water bearing unit



     @ ALLUVIUM/BASALT



     A CHINLE FORMATION



     fj SAN ANDRES LIMESTONE
            Map symbols



      ^^> radium, pCi/l



   ©1C7	well location and identifier

  2200/90-^

          TDS/chloride, both  in mg/l
                                                    /v
                                  |i(
                                  oi;
                                    (
                                 *v
                               &
                            $s
                             (

                            a
           ||2?00/1 10


           II


           II  Murray

              Acres

           li
     HOO/37,1

          II

       o.osl!

         AH 05
	L3^0!4! J|
Figure 6.   Radium, IDS and  Chloride in  Ground Water Near

             the United  Nuclear-Homestake Partners  Mill

-------
                                                                   43
                                                                   #1  Supply
                                                                    © Well
 #10
 0120
   110
6514.35
 (New) Well D
                                                      #14
                                                     60°
                                                     65 _
                                                         #13
                                                          © J8—Total Depth, m
                                                      651O 14—Top of Chinle, m
                                                      Static water level elevation,
                                                      feet above MSL
                                                       © CASED WELL
                                                       O UNCASED WELL
              65O3.25 ©  69
                                                    1OO  2OO 3OO  4OO meters
    BROADVIEW ACRES SUBDIVIS Of
 Figure  7 .   Water  Table  Contours and Well Locations at  the
               United Nuclear-Homestake Partners  Mill  Site

-------
                                                          44

contain from 20 to 106 times the recommended maximum sele-
nium concentration of O.Ol'mg/1 (National Academy of
Sciences-National Academy of Engineering, 1972).  Two of
the wells contain approximately two-thirds of the concen-
tration in the monitor well (1.52 mg/1).  The water supply
for the mill contains <0.01 mg/1,  whereas  the seepage
collection ponds adjacent to the presently active  pile
contain 0.92 me/1.   Analyses for additional  wells  are
in process to further define the source and  extent of
the contamination.

     Elevated levels of  polonium-210 are present in
well D  (#9135) and in other wells f#9102,  #9106, #9107,
and # 9113) downgradient from a suspected contamination
front in  the shallow aquifer.   Whereas  background for
polonium-210 is approximately  0.34  pCi/1  (Table 5), in  wells
tapping the Chinle Forrnatioji and  in alluvial  wells  removed
from suspected  contamination,  concentrations  range  from 1.0
to 2.3 pCi/1 in wells suspected to  be  contaminated.  Maximum
values for polonium-210 are from well D (ffyiii>).  The
elevated  levels of polonium-210 in supply well #2  (#9134)
cannot be'explained.


     Provision  of an alternative  water  supply is  strongly
recommended to  avoid consumption  of shallow  groundwatcr
exceeding 0.01  mg/1  selenium.   Deeper wells  completed only
in the Chinle Formation  and preferably  fully  cemented in
the interval from land surface  to 15 meters  into  the Chinle
should be considered minimum.

Ambrosia  Lake Area

     The  Kerr-McGee mill is located on  the  dip  slope of
a southeast-facing cuesta.  The area is underlain by a
thin veneer of  silt  and  clay alluvium  over  the  Mancos Shale.
The large network of tailings ponds  and water storage
reservoirs were built by excavation  and by selectively
sorting the coarse tailings for retention dams.   Discharge
from numerous mines and from ion exchange plants gives
rise to perennial flow in Arroyo del Puerto which
trends north-south.  Seepage from the  tailings  ponds and
from the  aforementioned  sources is  evident  from the vege-
tation present  in the formerly  dry  washes.  At  the  right
center edge of  the photograph  is  the inactive tailings
pile at the United Nuclear  Corporation  mill.

-------
                                                         45
     Water sampling in the Ambrosia Lake area focused on the
Kerr-McGee tailings disposal operation and the combined im-
pact of various ion exchange plant and mine water discharges
into San Mateo Creek and Arroyo del Puerto.  Because of in-
fluent stream conditions, these surface water bodies repre-
sent line sources of recharge to the shallow ground-water
reservoir.  The determination of impacts associated with
mine dewatering and solution mining exceeded the scope of
the study.  Of the 22 wells sampled in the area (see Figure
 8) all but 3 were part of the Kerr-McGee Nuclear Corporation
environmental monitoring network.   The absence of sampling
points near the United Nuclear mill and tailings pile or near
the active mines and ion exchange plants precluded study in
these areas.  It is obvious, however, that seepage from set-
tling ponds, from open channels leading to the two principal
streams in the area and the disposition of solutions involved
in in-situ leaching remain as unknowns.

     Nevertheless, the conservative parameters clearly in-
dicate the infiltration of wastewater.  Whereas shallow
ground water beneath San Mateo Creek contains about 700
mg/1 TDS  in the reach above Arroyo del Puerto, the reach
below has about 2000 mg/1.  Ammonia increases four fold
from 0.05 to 0.22 mg/1 and nitrite plus nitrates goes
from an average of less than 1 mg/1 to 24 mg/1.  The
selenium  and vanadium data do not indicate widespread move-
ment from the tailings piles.  One exception is well KM-43
(#9208) which contains 0.29 mg/1 selenium as well as high
radium and TDS.  The Marquez windmill  (#9132) is also
enriched  in selenium which further substantiates the TDS,
chloride, ammonia, and nitrate data results, i.e., con-
tamination of the shallow aquifer.

     The  concentration of radium in ground water in the
vicinity  of the tailings piles at the Kerr-McGee mill
averages  1.7 pCi/1 for the 12 wells sampled.  The highest
concentration, 6.6 pCi/1, occurs at station #9213 near the
base of the seepage catchment basin and probably character-
izes the  quality of ground-water seeding  beneath ami thro^h
the retention dam.  Water in the basin, per se, contains""0"
65 pCi/1  radium.  Note that high TDS, chloride, ammonia,
and nitrate plus nitrite appear in the seepage, but in the
adjacent  ground water (stations #9207, 9213), only chloride
and TDS persist.  Within 1 to 2 kilometers of the tailings
pile periphery, radium concentrations in shallow ground
water to depths of 17 meters are 4 pCi/1 or less,  and average
about 1 pCi/1.  The maximum concentration of 1 to 4 pCi/1
appear approximately 1.5 kilometers east of the main tailings
dam.

-------
                                           ell United Nuclear Mill
                                 Tailings Pond
                               95) (inactive)
                               03C40)
 Storage Pond
Kerr-McGeo Mill lib
                                Q-GROUND-WATER SAMPLING POIMT #9201
                               (035)
                                 \
                                  Radium concentration, pCi/l
Figure   8  .   Radium  Concentrations  in  Ground  Water  in  the
               Ambrosia Lake Area

-------
                                                          47
      The general pattern described is in agreement with the
 migration pattern described by the Kerr-McGee staff at  the
 time of the field study.  Despite a concentration of 65 pCi/1
 in seepage from the ponds,  concentrations in the  immedi-
 ately adjacent ground water do not exceed 6.6 pCi/1,  and
 quickly reduce to 4 pCi/1 or less.  Seepage leaving the
 property and moving southeastward parallel to Arroyo  del
 Puerto averages 0.47 pCi/1  radium.


     Despite the  relatively  localized contamination of ground
water  adjacent  to the Kerr-HcGee  tailings ponds, serious
question remains  concerning  their  adequacy as a means of
waste  disposal.   Company data for  1973 and 1974 reveal that
seepage from the ponds averaged 935 liters/minute.  Influent
averaged 3181 liters/minute; therefore, 29 percent of the
wastes entered  the ground water and the balance evaporated.
Assuming 60 pCi/1 in the seepage and a 20-year operating
period, 0.6 curies of radium are introduced to ground  water.
The company data  indicate that the seepage rate was fairly
constant at 946 and  924  liters/minute for 1973 and 1974,
respectively.  Also  shown in the water balance is  "negative"
seepage in the  third quarter of each of three years (1972,
1973,  1974).  This is interpreted  by the company as seepage
entering the ponds.  The writers consider this highly unlikely
and suggest that  it  is,  in fact, overland flow related to
thunderstorm activity prevalent at this time of year.   Re-
porting of data in this manner distorts interpretation of
the water balance for the tailings ponds by implying, in
this case, that no seepage occurred during these periods.
More importantly, the influx of overland flow into the ponds
prompts questions concerning their stability and overall
management.

Churchrock Area

     The Puerco River at Gallup was ephemeral until upstream
mining operations reached a scale such that wastewater dis-
charge was sufficient to cause perennial flow.  At present,
the combined discharge from the United Nuclear and Kerr-McGee
mines, located as shown  in Figure 19, is about 16  x 106
liters/day, and characterized by 8 to 23 pCi/1 radium,
700 to 4900 pCi/1 uranium, 0.01 to O.JD4 mg/1 selenium, and
0.4 to 0.8 mg/1 vanadium.  In terms of radium, selenium and
vanadium, the water  is unfit for stock or potable  uses and
not recommended for  irrigation.  Infiltration of the mine
wastewater could threaten potable  ground water  in the vicinity
of the Puerco River and possibly  the  Gallup municipal supply.
In part., the present "study examines whether noticeable ground-
water quality deterioration  has  occurred  to date.

-------
                                                                                    48
              NAVAJO INDIAN RESERVATION
                                                       J20
                                                      012
                       
-------
                                                         48
      In this setting, sampling in the Churchrock area in-
 volved 13 wells located along the Puerco River,  South Fork
 Puerco River and, for control purposes, an adjacent water-
 shed tributary to the Rio Puerco.  A single sample from a
 newly developed well serving the Gallup area was also tested.
 The sampling points included water used for stock, domestic
 use, and for public drinking water supplies.  Alluvial and
 bedrock aquifers were sampled in an area of 200  km2 located
 generally east and northeast of Gallup.

      None of the ground-water samples contain sufficient
 quantities of naturally occurring radionuclides  to constitute
 a health problem.  The radiochcmical, trace element and
 gross chemical data do not indicate that contamination of
 ground water is occurring as a result of the mining opera-
 tions underway.  More suitably located sampling  points,
 together with revised analytical programs are strongly
 recommended improvements to the existing industrial efforts.

     By comparison, the effects of mining on the concentration
of radium in ground water are pronounced.  Present discharge
from the Kerr-McGee mine, which is in the development versus
mining stage,  averages 7.9 pCi/1 as compared to 23.3 pCi/1
for the United Nuclear mine.  The latter is producing ore.
In both cases, elevated radium concentrations are present.
In large part, these are attributable to mining operations
and practices  and do not represent natural water quality,
evident from samples of ground water collected from 4 wells
and 3 long holes, all in the Westwater Canyon Member  (Hiss
and Kelley,  1975).  Radium varied from 0.05 to 0.62 pCi/1
compared to  0.28 to 184.8 pCi/1 uranium.  An additional
sample collected  in November 1973 from the settling pond
discharge at the  United Nuclear mine contained 8.1 pCi/1
radium and 847 pCi/1 natural uranium.  Thus, initial pene-
tration of the ore body increased radium at least 10-fold
and subsequent mine development work over a two-year period
resulted in another three-fold increase.  Compared to
.natural concentrations, radium increased some 23 times and,
if similar trends seen in the Ambrosia Lake area prevail,
ultimate radium  concentrations on the order of 50  to  150
pCi/1 are likely.

-------
                                                          49
Jackpile-Paguate Area

     Sampling in the vicinity of the Jackpile-Paguate open
pit uranium mine included four wells located as shown in
Figure 10-  One of these (#9233)  is  the  Pa^uate municipal
supply which is a. flowing arte'sian well completed in*"allu-
vium at a depth of 22.9 meters.  The remaining three wells
are property of the Anaconda Company and are used for potable
supply and for equipment washing, etc.  It is believed that
all three were former exploration holes that have been
reamed out, cased, and equipped with a submersible pump.
The water quality is probably representative of the Jackpile
Sandstone Member of the Morrison Formation, which also is
the principal ore body in the Laguna mining district.

     Dissolved radium in water from the Jackpile Sandstone
aquifer ranges from 0.31 to 3.7 pCi/1.  The latter value is
from the new shop well which is a source of potable and
nonpotable  water for the facility.  Consumption should be
discontinued because the radium exceeds the drinking water
standard of 3 pCi/1.

     The village of Paguate water supply is well below the
recommended maximum level for not only radium, but also the
other isotopes considered in the present study.  Selenium,
however, is at the maximum recommended level of 0.01 mg/1.
It is extremely unlikely that the present shallow-well
supply will be affected by mining unless the open pit was
extended close to the well field.  Recharge to the shallow
aquifer is derived from runoff which infiltrates to the west
and north.  After percolating southward, it then reappears
in a marshy area west of the village.   Springs and artesian
conditions are likely the result of decreasing transmissivity
due to the near surface occurrence of shales and poorly per-
meable sandstones in the lower reaches of Pueblo Arroyo.

     The downstream impacts of the Jackpile-Paguate mine
on ground water were not determined because of the absence
of suitable sampling points.  It is recommended that shal-
low monitor wells be installed at several points along the
Rio Paguate to ascertain the chemical, radiochemical, and
trace element species present.   Limited coring in the
sediment-filled Paguate reservoir would provide data on
variations in the radium and uranium content before and
during mining.  Such data would  also provide information on
radioactivity associated, with sediment transport during
periods of peak runoff and erosion.

-------
                                                           50
              i-\?T
        PaguateV'"
      T 11 N
Anaconda Co.
Jackpile-Paguate
Open Pit
                                     Paijuata Reservoir
                                                       I-40
  230
  © GROUND-WATER SAMPLING POINT #9230
(0.6)
    N Radium  concentration, pCi/l
    10.  Radium  Concenti a.Lions in  Hround 'Vater in  the
         Paguate-Jackpile Area

-------
                                                          51
      Significance  of-  Radic>_logicjxl Data

      Regulations  and  Guidelines

      On  August  14,  1975,  the U.S. B.P.A. published  in  the
 Federal  Register  (40  FR1SS, p.  34323-34328)  a  "Notice  of
 Proposed Maximum  Contaminant Levels  for  Radioactivity" to
 be  included  in  10  CFR Part  141  - Interim Primary Drinking
 Water Regulations.  The  following are the proposed  maximum
 contaminant  levels  for radium-226, radium-228  and gross
 alpha particle  radioactivity:

      (1.)  Combined radium-226  and radium-228  not to exceed
 5 pCi/1

      (2.)  Gross  alpha particle activity (including
 radium-226,  but exclusive of radon and uranium contents)
 not to exceed IS  pCi/1

 The proposed regulations  also discuss maximum  contaminant
 levels of beta  particle  and photon radioactivity from
 man-made radionuclides.

      Therefore, with  respect to these proposed radioactive
 contaminant  levels, the  following conclusions  may be ob-
 tained from  this  study:

      1.)  Additional  analysis for radium-228 and lead-210
 will  proceed and  be reported in a separate report at a
 later date.

      2.)  Since radium-228 is a daughter product of
 thorium-232, and  thorium analyses of these waters fluctuated
 around background concentrations, it appears that the
 radium-228 content  should also be at background levels;
 i.  e., less  than  0.02  pCi/1; hence, the  radium-228  content,
 under assumed equilibrium conditions, should be less than
 0.042  pCi/1, the highest reported thorium-232  content.

      3.)  Only  two  locations, out of the 71 ground water
 locations sampled, have radium-226 concentrations in excess
 of  5  pCi/1.  The proposed new standard of 5 pCi/1,  combined
 radium-226 and  radium-228 contents, is therefore exceeded
 at  these two locations.

      4.)   Sixty (60) of the  71  ground water locations had
gross  alpha results in excess of the  proposed 15 pCi/1
limit'; however,  the gross alpha  results  reported here include
uranium isotopes.   Included  in  the  list  of sixty locations

-------
                                                          52
 are  several  locations where  the  gross  alpha  results  are  less
 than 15 pCi/1,  but  consideration of  the  2  sigma  confidence
 level would  then  indicate  a  gross  alpha  possibly in  excess
 of the 15 pCi/1 limit.

      5.)  The proposed maximum gross beta  limit  excludes
 naturally occurring  radionuclides  (e..  g.,  lead-210) ;  there-
 fore, there  is no presently  proposed maximum contaminant
 level for lead-210;  and  the  NMEIA  population guide MFC of
 33 pCi/1 appears  to  be the only  current  applicable guide-
 line  for lead-210 content.

      Since the above radioactivity contaminant levels are
 proposed and not  final interim primary drinking  water
 regulations, the  following discussions of  the radiological
 analyses of water samples  obtained during  this study will
 be based on the U.S.P.H.S. Drinking Water  Standards  (1962)
 and  current NRC/NMEIA maximum permissible  concentration
 levels.

 Radium-226

      Of the  71  ground-water  sampling locations of this
 study, only  6  locations  showed radium-226  concentrations
 in excess of the  3.0 pCi/1 drinking  water  standard
 (U.S.P.H.S.  Drinking Water Standards,  PUS  Publication
 Mo.  956; 1962).   The population  guide--maximum permis-
 sible concentration (10CFR,  Part 20, Table II, column 2,
 unrestricted areas)  is 10  pCi/1.   Table  12 lists the  6
 locations and presents the gross alpha and radium-226
 results based  on  NEIC laboratory analysis.

      The Jackpile-New Shop Well,  Paguate (#9232),  is
 a potable water supply having a  radium concentration  in
 excess of the  drinking water standard.   This water need
 not  be used  for human consumption  since  other nearby  wells
 have much lower radium concentrations  (e.g., the Paguate
 municipal supply  (#9233)  or  the  Jackpile Well  (#9230)).

      The Phil Harris Well, Grants  (#9201),  is the
 only other potable  water supply  with a radium concentra-
 tion in excess  of 3.0 pCi/1.  The  Berryhill  Section  5
 Windmill, Bluewater (#9121), is  used as  a  stock  water
 supply; and  since there  are  no nearby  human  consumers, the
 radium concentration of  6.3  ±  0.1 pCi/1 is  of no  immediate
 health hazard.

     Two of  the  Kerr-McGee  monitor  wells, samples  from KM-43
 (#9208) and  KM-B-2  (#9213), also  had radium levels in excess
of 3.0 pCi/1.   Stable inorganic species in  the water also
render it unfit  for  human consumption.  In  addition, the  well
is not in use for  water supply and  therefore does  not present
a health hazard.

-------
                                                          53
     Sample #9212, a surface water sample, obtained from
the seepage collection pit at the base of the Kerr-McGee
tailings pond, had a radium concentration of 4.9 pCi/1.
However, this water is certainly not fit for human con-
sumption nor is it used as a livestock or irrigation
supply.

     For comparison purposes, Table  8  shows the radium
concentrations for municipal water supplies surveyed dur-
ing this study.

     A radium concentration of Or68 pCi/1 from the Erwin
Well, Gallup  (#9233) was the highest radium concentra-
tion for the municipal supplies.  It appears that, on
the whole, municipal water supplies in the Grants Mineral
Belt area do not exceed 23% of the drinking water standard
of 3.0 pCi/1.

     Ten privately owned, potable water supplies were
surveyed in the Murray Acres-Broadview Acres and other
areas surrounding the United Nuclear-Homestake Partners
mill.  The highest radium concentration was 0.72 pCi/1
at the IVorthen Well (# 9107), and the lowest concentra-
tion was less than 0.05 pCi/1 at the Schwagerty Well
(#9105).  The average radium concentration for these
10 private wells was 0.26 pCi/1.

     Six privately owned,  potable water  supplies in the
Ambrosia Lake area contain 0.07  to  3.6 pCi/1.  Of nine
privately owned potable  water  supplies surveyed in the
Grants-Bluewater area,  the maximum  radium  concentration
was 0.24 pCi/1.   Only  two privately  owned  wells were used
solely as potable water  supplies  in  the  Gallup area.  These
were the Hassler (#9139)  and Boardman (#9138) residences.
The radium concentrations at these  two locations were 0.22
and 0.64 pCi/1, respectively.   The  other  8 wells in the
Gallup-Churchrock area were used mainly  as stock water
supplies and had an average radium  concentration of 0.35
pCi/1.

-------
                                                                           54
                                Table  7
                   Locations  with  Radium-226  in Excess  of
                     the  PUS  Drinking  Water Standard  *
Location
Description
'9121-Berryhill
Section 5
Bluewater
/9201-P. Harris
Grants KM- 4 6
(9208-KM-43
Grants
J9212-KM Seepage
Return-Grants
/9213-KM-B-2
Grants
?9232-Jackpile-
New Shop Well
Paguate
2
£a_d i urn - 22^^^
DissoTvetTTywo Sigmn
	 pCi/1 ! pCi/1
6.3

3.6

4.0

4.9
6.6

3.7
oil

0.1

0.1

0.1
0.1

0.08
£ross A
DissoTv'etf
pCi/1
12

110

49

112,000
8

18
2
Ipha
lwcr*"S*igina
pCi/1
14

40

35

3,000
32

13
Remarks
Windmill Stocl
Feed Water

Potable Water
Supply
Monitor Well

Surface Water
Sample
Monitor Well

Potable Water
Supply
 1   PHS  Drinking  Water  Standard,  1962,  is  3.0 pCi/1  for  Radium-226.

 2   Radium  and  gross  alpha  analysis by  NEIC-Denver.
           Radium
              Table  e

Concentrations for Municipal Water Supplies
Location
Description
#9112-Grants
City Hall
#9116-Milan City
Well HI
S912S-LDS
Blucwater
#9137-Erwin Well
Gallup
#9233-Municipal Well
Paguate
Village"*"
Radium- 226
Dissolved
pCi/1
0.42
0.14
0.22
0.68
0.18
0.1 2
Two Sigma
pCi/1
0.02
0.01
0.01
0.03
0,02
0.01
Gross Alpha
Dissolved
pCi/1
19
12
8
10
2
3
Two Sigma
pCi/1
13
10
10
9
4
7
1  Radium  and  gross  ajpha  results  by NEIC-Denver.

-------
                                                          55

                                                    »
 Other RadionucljLd.es

      Table  9  entitled "Maximum Permissible Concentrations
 in  Water" presents the unrestricted area - MFC and the popu-
 lation guide - MFC for selected radionuclides.  The PHS
 drinking water standard of 3 pCi/1 for radium-226 is more
 restrictive  than the population guide - MFC; therefore,
 the radium  content evaluations were based on the 3 pCi/1
 drinking water standard.  ..The other radionuclide content
 evaluations  are based on-the soluble MFC value since fil-
 tered ground-water samples were analyzed.  The MFC values
 listed are  from the  NRG regulations which are also con-
 sistent with the NMEIA regulations (June 16, 1973).


     Only 3 potable  water  supplies  had  complete  isotopic
uranium analysis  - Wilcox  (#9102),  Enyart  (#9133)  and  Dixie
Well  (#9140).  The highest reported results  (for  the Wilcox
Well)  indicate less  than 0.1%,  0.002% and  0.061  of the
population guide  - MFC  for uranium-234,  uranium-235, and
uranium-238, respectively.

     Of all the potable water  supplies  analyzed  for thorium-230,
the Worthen Well  (#9107) had  the highest  concentration  of
0.99 pCi/1,  less  than  0.151 of the  population  guide - MFC.
The Meador Well  (#9113) had the highest  thorium-232 content
of 0.042 pCi/1 and polonium-210 content  of  2.3 pCi/1 which
are, respectively, 0.006% and  0.98%  of  the population
guide  - MFC.

      All  6  municipal water supplies were analyzed for
 thorium-230, thorium-232,  and polonium-210.   The  highest
 thorium-230  content  was for  Grants  (#9112),  with  0.046
 pCi/1 (0.007%  population  guide - MFC).   The  highest
 thorium-232  content  was for  the Churchrock  Village, with
 <0.016 pCi/1 (0.002% of the  population  guide - MFC).  The
 highest polonium-210 content  was for t^e Municipal Well
 at  Paguate  (#9233) with 0.39  pCi/1  (,0.17%  of the  population
 guide - MFC).   The Paguate sample  (#9233)  also had the
 highest lead-210 content  of  less than 8.7  pCi/1  (26.36%
 of  the population guide -  MFC).

      In summary, exclusive of the  radium-226 content,  the
 highest isotopic uranium  and  thorium, polonium-210, and
 lead-210  contents for any  potable  water supply in the Grants
 Mineral Belt area is less  than 28.08% of the total radio-
 nuclide population guide  - MFC.

      It,  therefore,  seems appropriate to conclude  that for
 routine monitoring of potable water supplies, isotopic
 uranium and thorium, polonium-210, and radium-228  analyses
 are not necessary.  Accurate radium-226_and lead-210 analyses
 /•      1      1    * *t 1 .4- 1   __ f. n *• -I •»-• £ r*. ~"»•«•» rt, 4- -i r* *>  J- n -y ^» *"i *-3 "I O ' OTT ^"* 1 I
 for eacu  sample yield LJJ.C. mo^u J..iJLuijpo.L.j.on  xor i 0.^.10^0^-^^.
 evaluations of drinking water conditions.

-------
                                                           56
                          Table- 9

        Maximum Permissible Concentrations in Water '
                 (Above Natural Background)
   Radionuclide
     Appendix B
 Table  II,  Column  2    Population Guide^
(Unrestricted Areas)         pCi/1
        pCi/1
2 2
2 2
2 1
2 1
2 3
2 3
2 3
2 3
2 3
u-
6 Ra
8 Ra
0 Po
0 Pb
0 Th
2 Th
* U
5 U
8 U
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Natural
Soluble
Insoluble
30
30
30
200
2
30
2
40
30
30
30
30
40
40
30
30
30 -
,000
30
,000
700
,000
100
,oao
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
10
10
10
66
10
13
10
10
10
10
13
13
10
10
io3
,000
10
,000
233
,000
33
,667
667
,000
667
,333
,000
,000
,000
,000
,333
,333
,000
,000
1   lOCFR-Part 20--Standards for Protection Against Radiation--
   U.S.N.R.C. (April  30,  1975).

2   .Population Guide = 1/3 times Unrestricted Area
                      MFC--Table II Values.
                         '    '                            O O f '
3   A maximum permissible concentration of 3.33 pCi/1 for    Ra
   is the Handbook 69 population guide (i.e., l/30th of the
   HB69 continuous occupational exposure limits).

-------
                                                            57
                        REFERENCES CITED
-Bond,  A.  L.,  1975,  N.  Mexico Environmental Improvement  Agency,
     Letter of February 14,  1975,  to J. .Thornhill,  U.S.  Envi-
     ronmental Protection Agency,  Region  VI,  2 p.

 Chavez,  E.  A.,  1961,  Progress report on  contamination of
     potable  groundwater in  the Grants-Bluewater area, Valencia
     County,  New Mexico:  N.  Mexico State Engineer  Office,
     Roswell,  New Mexico.

 Clark,  D.  A., 1974,  State of -the  art - uranium mining,  milling,
     and  refining industry:   U.S.  Environmental Protection
     Agency,  Office  of  Research and Development,  Corvallis,
     Oregon,  Technology Series, Report No.  EPA-660/2-74-038,
     113  p.

••Cooper,  James B.  and  Edward  C. John,  1968,  Geology and  ground-
     water  occurrence  in Southeastern McKinley County, New
     Mexico:   N.  Mexico State Engineer, Technical Report 35,
     prepared  in cooperation  with  the U.S.  Geological Survey,
     108  p.

 Dinwiddie,  George A.,  W.  A.  Mourant,  and J.  A.  Easier,  1966,
     Municipal water  supplies and  uses, Northwestern New Mexico:
     N. Mexico State  Engineer Technical Report 29C,  prepared
     in cooperation with the  U.S.  Geological  Survey, 197 p.

 Dudley,  John, 1975, Water Quality Division,  the  N.  Mexico
     State  Health and  Social  Services  Department, July 15
     memorandum reply  to Robert Kaufmann,  Office  of Radiation
     Programs, U.S. Environmental  Protection  Agency.

-Button,  C.  E.,  1885,  Mount  Taylor and the Zuni Plateau: rn
     the  Sixth Annual  Report  of the U.S.  Geological Survey,
     1884-85,  p. 113-198.

- Fenneman, N. M., 1931, Physiography  of western United  States:
     New York, McGraw  Hill,   534 p.


-Gordon, Ellis  D-. , 1961,  Geology  and  ground-water  resources
     of the Grants-Bluewater area,  Valencia  County, New Mexico:
     N. Mexico  State Engr. Technical  Report  20, prepared in
     cooperation  with  the U.S.  Geological  Survey,  109 p.

-------
                                                          58
Gray, W. E.,  1975, Environmental Engineering, N. Mexico Oper-
    ations,  Uranium Division, The Anaconda Company, February 14
    letter to Robert F,  Kaufmann, U.S.  Environmental Protec-
    tion Agency, ORP, Las Vegas, Nevada, response to request
    for data.


Hilpert, Lowell S.,  1963, Regional and  local stratigraphy of
    uranium-bearing  rocks:'  N. Mexico State Bureau of Mines
    and Min.  Res. Memoir 15, p.  6-18.


John, Edward C., and S. W. West, 1963, Ground water in the
    Grants District:  in_ N.  Mexico State Bureau of Mines and
    Min. Res. Memoir 15, p.  219-221.

Keefer, D. H., 1974, Radiological Evaluation of Region VI
    National Pollution Discharge Elimination System Permits:
    unpublished briefing statement, U.S. Environmental Pro-
    tection Agency, Region VI, Dallas, Texas, 9 p.

Kelley, Vincent C., ed. , 1963, Tectonic setting: i_n N. Mexico
    State Bureau of Mines and Min. Res. Memoir 15, p. 19-20.

Kittel, Dale F., Vincent C.  Kelley, and Paul E. Melancon,
    1967, Uranium deposits of the Grants Region: in the New
    Mexico Geological Society Eighteenth Field Conference,
    Guidebook of the Defiance-Zuni-Mt. Taylor Region of Ari-
    zona and New Mexico, p.  173-183.


Midwest Research Institute,  1975, A study of waste generation,
    treatment and disposal in the metals mining industry:
    Review draft of  Final Report, Contract No. 68-01-2665
    for Office of Solid Waste Management, U.S. Environmental
    Protection Agency, Washington, DC,  2 vol., 520 p.

National Academy of Sciences --National Academy of Engineering,
    1972, A Report of the Committee on Water Quality Criteria:
    Environmental Studies Board, at the request of and funded
    by U.S.  Environmental Protection Agency, 594 p.

New Mexico Department of Public Health and U.S. Public Health
    Service,  1957, Report of an  investigation of ground water
    pollution, Grants-Bluewater, New Mexico.

New Mexico Environmental Improvement Agency, 1973, Regulations
    for governing the health and environmental aspects of
    radiation: New Mexico Environmental Improvement Agency,
    Santa Fe, New Mexico.

-------
                                                            59
  Public Health Service, U.S. Dept. of Health, Education, and
      Welfare, 1962, Drinking water standards--1962:  PHS Publi-
      cation No.  956, 61 p.

  Tsivoglou, E. C., and R.  L. 0'Connell,. 1962, Waste  guide for
      the uranium milling industry: U.S.  Dept. of Health, Educa-
      tion, and Welfare, Tech.  Report W62-12, Cincinnati, Ohio, 78 p

  U.S. Atomic Energy Commission,  1974, The Nuclear Industry:
      U,S. Atomic Energy Commission, Washington,  DC,  WASH-1174-74,
      p. 39-45.

  U.S. Environmental Protection Agency, 1974, Compliance moni-
      toring procedures:  Office  of Enforcement,  National Field
      Investigations Center,  Denver, Colorado, 37 p.


—U.S. Geological Survey, 1975, Unpublished data, New Mexico
      District.


  U.S. Geological Survey, 1975, unpublished data  received via
      written communication from  WRD,  New Mexico  district,
      Albuquerque,  file number  08350500.

  U.S. Nuclear Regulatory Commission,  1975, Standards  for pro-
      tection against radiation:  10CFR, Part 20  (April 30, 1975).

  University of New Mexico, Bureau of Business Research, 1972,
      "New Mexico Statistical Abstract, 1972."

-West,  S. W. , 1972, Disposal of  uranium-mill effluent by well
      injection in the Grants area, Valencia County,  New Mexico,
      U.S. Geological Survey  Professional Paper  386-D, prepared
      in cooperation with the N.  Mexico State Engineer office
      and the U.S.  Atomic Energy  Commission, 28  p.

-------
                                                              86
CHLORIDE, ppm
   S
                                                                •H
                                                              
                                                              ,C X
                                                              •M -P
                                                                •H
                                                              OJ r-4
                                                              •H rt
                                                              > ^
                                                                O'
                                                              -O
                                                                   C
                                                                 rH -H
                                                              (1) C3  ^
                                                              +-> 10  O
                                                              V) C -t-)
                                                                •H  O
                                                                   -XJ
                                                              J_j £* ^_J
                                                              rt o u
                                                              E O (D
                                                              £ CO rH
                                                              3 £ o
                                                              tO «< C/5
                                                              bO
                                                              •H
   'Q3iD3rNI  3WH1OA 30V83AV

-------
                                                               87
 r                      _         *                 *
 liters/minute.   The plant manager at the time  expected
 that slimes in  the waste would seal the bottom of  the
 lagoon in about a year.   However, the present  loss rate
 of 347 liters/minute from a ponded area of about 14.4
 hectares shows  that leakage continues.

      As of May  1957, two wells in the shallow  aquifer and
 three in the deep (San Andres-Limestone) aquifer had nit-
 rate concentrations of 66 to 84  mg/1 (15-19 mg/1  N03-N)
 and elevated nitrate levels were  present as far as 10
 kilometers downgradient  from the  lagoon or 4.5 kilometers
 from the Grants supply wells.   At the present  time,  the
 maximum nitrate concentrations in the bedrock  and  alluvial
 aquifers within 4 kilometers of the ponds are  39 and 17.3
 mg/1.  Concentrations in two wells midway between  the ponds
 and Grants average 21.5  mg/1.   In the 1956 study it  was
 concluded that  high nitrate within 4.5  kilometers  of Grants
 was a result of waste disposal.  This would imply  movement
 of 10 kilometers in 2 to 3 years, which is extremely unlikely


      Available  nitrate  (expressed as  nitrate),  TDS,  chloride,
 sulfate and gross  alpha  data  from the foregoing  study, from
 the Anaconda Company (Gray,  1975)  and from the  present in-
 restigation were plotted to  determine changes  in ground-
rwater quality with respect  to  distance  from the  tailings
 ponds and with  time.   There  is  a  general  lack  of marked
 deterioration in ground-water  quality with time  and,  with
 the exception of gross alpha,  there  is  close agreement
 between the company data and  those  from the present  study.
 For example, the Fred Freas well  (#9127)  completed in al-
 luvium and the  Mexican Camp well  (#9120)  which  taps  the
 San Andres Limestone show essentially no  change  in TDS,
 sulfate,  chloride,  or nitrate  for the period 1956  to  1975.
 The slight decline  in TDS in  the  Fred Freas well is  con-
 trary to  what would be expected if  gross  contamination was
 present.   However,  the similarity between gross  alpha and
 sulfate fluctuations for the Mexican  Camp well  suggest that
 wastes are within  the well's  area of  influence.

      The  selenium, vanadium, and total  dissolved  solids  ('!].'?)
 data  for  the Bluewater-Grants  area generally  substantiate
 the  foregoing interpretation and hint  at  the possibility of
 contamination of the alluvial  aquifer.   Selenium  ranges  from
 less than  0.01  mg/1  to  0.02 mg/1, with most values  being
 0.01 or less.  Vanadium  ranges from  0.3  to 1.3 mg/1  and  is
 lowest in  the Anaconda monitor well  (#9117).   Concentrations
 for  seven wells adjacent to the  Anaconda  mill,and tailings
 ponds average 0.89 mg/1, which is two  to  three  times  higher
 than the average for the remainder of  the  study area  (see
 'Table yj.   it is suspected that  these  elevated  levels are
 indicative of contamination, but they may  simply reflect
 the normal concentration of vanadium in  the alluvial  and

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                                                           87A
 San  Andres  Limestone  aquifers.   Water  supply  well  #2  at  the
'United  Nuclear-Homestake  Partners  mill  is"also  completed in
 this formation  and  contains  1.3  mg/1.   Additional  sampling
 is recommended  to characterize background  and contaminated
 levels  before definite  conclusions  are  drawn.   With the
 exception of the Jack Freas  well (#9129),  which is used  for
 domestic supply, the  selenium and  vanadium concentrations
 are  within  recommended  drinking  water  standards.

      Chloride and IDS trends are not well  defined.  The  range
 for  IDS is  from 490 mg/1  (Mexican  Camp)  to 2300 mg/1  (Monitor
 well),  whereas chloride varies from 6.2  to 270  mg/1.  The
 peak chloride value of  270 mg/1  is  from  Anaconda well #2
 (#9118) which also contains  1900 mg/1 TDS.  Nearby wells  in
 the  San Andres Limestone  (#.9119, #9120,  and #9126) average
 823  mg/1 TDS and 54 mg/1  chloride.  Cones  of  depression
 created by  the Anaconda wells may  induce downward movement
 of wastewater in the  alluvial  aquifer.   Farther north,  TDS
 and  chloride in the San Andres-Glorieta interval averages
 2067 mg/1 and 6.5 mg/1.   If  the  increase in TDS is from
 purely  natural  causes,  chloride  would  be expected  to  rise,
 hence the increase  in TDS and'decline  in chloride  may be
 indicative  of contamination.


      Sulfate, TDS,  and gross alpha in North well (#9122)
 and  in  the Monitor well (#9117) are increasing slightly
 with time.   For North well, TDS increased at a rate'of
 about 13 mg/1 per year and has gone from 1680  mg/1 in  June
 1956 to 1900 mg/1 in  February 1975.  Gross alpha is appar-
 ently increasing about 0.1 pCi/liter per year, but the
 company analytical results of about 2 pCi/1 are markedly
 below the 30 pCi/1 reported herein.

      The EPA gross alpha  data reported herein  for all  of the
 wells in the vicinity of  the Anaconda mill are generally
 15 to 20 times greater than company results.  Although only
 the  latter  are useful for defining long-term trends,  the
 disparity of analytical results warrants further work  to
 determine absolute versus relative concentrations and  trends.
 Of note is  the fact that  the February 1975 gross alpha data
 for  both wells exceed the proposed 15 pCi/1 limit for  potable
 water supplies.

      At the present time, ground water developed for potable
 use  does not appear to be adversely affected by the Anaconda
 disposal practices.   This conclusion is based on analyses
 for  seven wells (#'s  9118, 9119, 9124,  9125, 9126, 9127,

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                                                             87B
      completed in bedrock and in alluvium and generally
        peripheral to and within 4 kilometers of the tailings
ponds.  Anaconda supply wells #2 and #4, which show slightly
increasing trends for IDS, chloride, or sulfate, are closest
to the ponds and are used for potable and mill feed purposes.
For the remaining wells, increasing and decreasing trends for
IDS and sulfate are present whereas chloride, nitrate and
gross alpha results are rather- stable".

      In summary, the interpretation of  ground-water quality
offered by  the New Mexico Health Department  (1957) is not
supported by subsequent data.  Concentrations of nitrates
and chloride, in particular, are not markedly different today
than  in the base period from 1953 to 1956.  Data for the period
from  1956 to 1969 may bear out the earlier predictions of
gross contamination, but if so, water quality since 1969 is
only  slightly   changed.  For i^idespread ground-water con-
tamination  to quickly occur from 1955 to 1956 and then rapidly
attenuate is very unlikely considering  the dynamics of ground-
water flow  and • the continuing history of waste disposal.
Whether the earlier data were faulty or ^^^ere misinterpreted
is a matter ^of conjecture.Ground-water  flow patterns in the  '
 vesicular basalt and interbedded alluvium underlying the
 northwest pond and portions of the main pond are'not described
  Ln the available references.  Complex  permeability  distri-
  butions and density considerations add further  complications.
 However, seepage is occurring and  it is possible  that  the
 Company estimates stated above are conservative.

      The  foregoing  comments do not imply that ground-water
 contamination  is absent.   Gross  contamination of nearby wells,
 or a continuation of the  earlier,  perhaps  erroneous  pre-
 dictions  of contamination,  is  not  apparent.   The  major
 qualification  of these  conclusions is  that wells  properly
 located and completed  for sampling purposes are not  avail-
 able, hence,  the extent of contamination is not well  under-
 stood.   Contamination  is  evident  in the North and Monitor
 wells but is not_yet a  problem.  Available chemical data
for pre- and post-injection periods should be evaluated.
 together  with  monthly  or  quarterly injection volumes  to fur-
 there confirm  or deny  the trends  shown  in Figure 12.   If
 the trends shown are valid, thorough reevaluation of the
 injection method of waste disposal and  construction of  addi-
 tional monitoring wells in the Yeso Formation and the
 Glorieta-San  Andres is  in order.   Because of low MFC values,
 this is particularly true if increasing concentrations  of
 radium-226 (and possibly  lead-210) are  appearing in the
 aquifers  above the injection zone.            „

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                                                            88
United Nuclear-Homestake Partners Mill and Surrounding Area

     As shown in Figure 13, the mill is partially surrounded
on the southwest or downgradient side by housing develop-
ments and irrigated farm lands, both of which depend on
local ground-water supplies.  Also obvious in the photograph
as a dark tan  band around the base of the tailings pile
is extensive seepage.  This is collected and pumped back
to the pond above the sandy tailings, but seepage from the
pile proper and from the encircling moat can enter the
ground-water reservoir.  The five-sided polygon adjacent
to the mill buildings is an inactive tailings pile that
was formerly part o'f the Honiestake-New Mexico Partners
mill.  In the upper left-hand portion of the photograph
is shown the terminus of the San Mateo Creek drainage
from the San Mateo and Ambrosia Lake areas.

     Three distinct aquifers are present in the area of the
mill and surrounding developments.  In ascending order, these
include the San Andres Limestone, the Chinle Formation, and
the alluvium.  Water table conditions and a southwestward
lateral flow gradient prevail in the latter, with static water
levels about 15 meters below land surface.  The San Andres
Limestone originally was under artesian head, but heavy pump-
ing for irrigation and for industry has removed much of the
head once present.  Data presented by Gordon (1961) indicate
a downwind flow gradient, but the permeability of the Chinle
Formation is low and actual vertical water transfer is prob-
ably minimal.  The chief significance of these hydrogeologic
conditions is that liquid effluents produced by the uranium
milling operation are likely to infiltrate at t-he mill site
and travel in a south-southeast direction toward the nearby
subdivisions.  On the other hand, water quality in the Chinle
Formation and the still deeper San Andres Limestone is likely
to be unaffected.

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                                                          HOa
     Significance of Radiological Data

     Regulations and Guidelines

     On August 14, 1975, the U.S. E.P.A. published in the
Federal Register (40 FR158, p. 34323-34328) a "Notice of
Proposed Maximum Contaminant Levels for Radioactivity" to
be included in 10 CFR Part 141 - Interim Primary Drinking
Water Regulations.  The following are the proposed maximum
contaminant levels for radium-226, radium-228 and gross
alpha particle radioactivity:

     (1.)  Combined radium-226 and radium-228 not to exceed
5 pCi/1
     (2.)  Cross alpha particle activity (including
radium-226, but exclusive of radon and uranium contents)
not to exceed 15 pCi/1

The proposed regulations also discuss maximum contaminant
levels of beta particle and photon radioactivity from
man-made radionuclides.

     Therefore, with respect to these proposed radioactive
contaminant levels, the following conclusions may be ob-
tained from this study:

     1.)  Additional analysis for radium-228 and lead-210
will proceed and be reported in a separate report at a
later date.
     2.)  Since radium-228 is a daughter product of
thorium-232, and thorium analyses of these waters fluctuated
around background concentrations, it appears that the
radium-228 content should also be at background levels;
i. e., less than 0.02 pCi/1; hence, the radium-228 content,
under assumed equilibrium conditions, should be less than
0.042 pCi/1, the highest reported thorium-232 content.
     3.)  Only two locations, out of the 71 ground water
locations sampled, have radium-226 concentrations in excess
of 5 pCi/1.  The proposed new standard of 5 pCi/1, combined
radium-226 and radium-228 contents, is therefore exceeded
at these two locations.
     4.)  Sixty (60)  of the 71 ground water locations had
gross alpha results in excess of the proposed 15 pCi/1
limit; however, the gross alpha results reported here include
uranium isotopes.   Included in the list of sixty locations

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                                                        HOb
are several locations where the gross alpha results are less
than 15 pCi/1, but consideration of the 2 sigma confidence
level would then indicate a gross alpha possibly in excess
of the 15 pCi/1 limit.
     5.)   The proposed maximum gross beta limit excludes
naturally occurring radionuclid.es (e. g., lead-210); there-
fore, there is no presently proposed maximum contaminant
level for lead-210; and the NMEIA population guide MFC of
33 pCi/1 appears to be the only current applicable guide-
line for lead-210 content.

     Since the above radioactivity contaminant levels are
proposed and not final interim primary drinking water
regulations, the following discussions of the radiological
analyses  of water samples obtained during this study will
be based on the U.S.P.H.S. Drinking Water Standards (1962)
and current NRC/NMEIA maximum permissible concentration
levels.

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