EPA 906/9-75-002
             WATER  QUALITY  IMPACTS


                        OF


    URANIUM  MINING  AND MILLING  ACTIVITIES


                     IN  THE
                                         i

       GRANTS  MINERAL  BELT,  NEW MEXICO
                             UJ
                             O
        U. S. ENVIRONMENTAL PROTECTION  AGENCY

            REGION VI, DALLAS, TEXAS  75201

                  September  1975

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EPA 906/9-75-002
               IMPACT OF URANIUM  MINING AND MILLING

           ON WATER QUALITY  IN  THE  GRANTS  MINERAL  BELT,

                          NEW  MEXICO
              U.  S.  ENVIRONMENTAL  PROTECTION AGENCY
                REGION VI,  DALLAS, TEXAS   75201

                         September 1975

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                          TABLE OF  CONTENTS



  I.   Purpose and Scope

 II.   Study Results

        Conclusions

        Recommendations

III.   Action Taken

 IV.   Applicable Laws and Regulations

  V.   Appendices:

         Summary of Ground-Water Quality Impacts  of Uranium
         Mining and Milling in the  Grants Mineral  Belt,  New Mexico,
         U. S.  Environmental  Protection Agency, Office of  Radiation
         Programs, Las Vegas  Facility,  Las Vegas,  Nevada  89114

         Impacts of Uranium Mining  and  Milling on  Surface  and
         Potable Waters in the Grants Mineral  Belt, New  Mexico,
         U. S.  Environmental  Protection Agency, National Enforcement
         Investigations Center, Denver, Colorado


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Purpose and Scope

    In September 1974, Mr. John Wright of the New Mexico Environmental
Improvement Agency requested that the staff of EPA Region VI assist in
implementing a survey of the uranium mining and milling activities of the
Grants Mineral Belt to determine the impact of these activities on surface
and ground water in the area.

    The objectives outlined for the survey were:

    1.  Assess the impacts of waste discharges from uranium mining
        and milling on surface 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 monitoring
        networks, self-monitoring data, analytical procedures and report-
        ing requirements.

    4.  Determine the composition of potable waters at uranium mines
        and mills.

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

    In response to the request by the New Mexico Environmental Improvement
Agency, plans were developed to conduct a joint, cooperative study involving
Region VI, EPA; the Office of Radiation Programs - Las Vegas Facility
(ORP-LV); the National Enforcement Investigation Center, Denver (NEIC-Denver),
and the New Mexico Environmental Improvement Agency (NMEIA).

    A reconnaissance was conducted in January 1975 to view the study areas,
meet with mining/milling company officials, and plan the data collection
effort.  Sample collection began in late February 1975, and was completed in
early March 1975.  Laboratory analyses for trace metals, gross alpha,
radium-226 analysis and other radiological analyses were completed in
July 1975.

Study Results

    The details of the study are presented in two reports which are appended
to this summary report:  Surface Water Quality Impacts of Uranium Mining
and Milling in the Grants Mineral Belt, New Mexico, and Ground-Water Quality
Impacts of Uranium Mining and Milling in the Grants Mineral Belt, New
Mexico.

    Based on the data collected and analyzed, the following conclusions and
recommendations were developed.

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                         SUMMARY AND CONCLUSIONS
I.   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 of ground water 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 in the alluvium
    also occurs in this area.  Principal ground-water development in the
    mining areas at Ambrosia Lake, Jackpile-Paguate, and Churchrock 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
    Gallup Sandstone using well fields located east and west of the urban
    area and 11 kilometers north of the city.

2.  In proximity to the mines and mills and adjacent to the principal
    surface drainage courses, shallow ground-water contamination results
    from the infiltration of (1) effluents from mill tailings ponds;
    (2) mine drainage water that is first introduced to settling lagoons
    and thence to watercourses, and (3) discharge (tailings) from ion ex-
    change plants.  In the case of the Anaconda mill, seepage from the
    tailings ponds and migration of wastes injected into deep bedrock
    formations is observed in the San Andres Limestone and in the
    alluvium, both of which are potable aquifers.  With the exception of
    seepage from the Kerr-McGee Section 36 mine in Ambrosia Lake, signi-
    ficant amounts of wastewater from the remaining mines and mills
    probably does not return to known bedrock aquifers.  Deterioration of
    water quality results from conventional underground mining as a re-
    sult of penetration or disruption of the ore body.  The most dramatic
    changes are greatly increased dissolved radium and uranium.  Induced
    movement of naturally saline ground water into potable aquifers is
    also likely but undocumented.  Similarly, the ground-water quality im-
    pacts of solution (in situ) mining are unknown.

3.  The Grants, Milan, Laguna, and Bluewater municipal water supplies have
    not been adversely affected by uranium mining and milling operations
    to date.  For the Grants and Milan areas, chemical data from 1962 to
    the present indicate that near the Anaconda mill some observation wells
    have increased slightly in total dissolved solids, sulfate, chloride
    and gross alpha but domestic wells have generally remained unchanged.
    Projections made in ]957 of gross nitrate deterioration of ground water
    have not been substantiated by subsequent data.  Of the municipal supply
    wells in the study area, the Bluewater well bears additional monitoring
    because of its location relative to the Anaconda tailings ponds.     |


                                   -2-

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4.  Contamination of the Gallup municipal ground-water supply by
    surface flows, consisting mostly of mine drainage, has not
    occurred and is extremely unlikely because of geologic con-
    ditions in the well field and the depth to productive aquifers.
    Another well field north of the City will, in no way, be af-
    fected by the drainage.

5.  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.  Throughout the study area widespread con-
    tamination of ground water with radium was not observed despite
    concentrations of as much as 178 pCi/1 in mine and mill .effluents.
    Radium removal is pronounced, probably due to sorptive capacity
    of soils in the area.  In the vicinity of the Anaconda mill,
    radium and nitrate concentrations in the alluvial aquifer decline
    with distance from the tailings ponds, but neither parameter ex-
    ceeds drinking water standards.

6.  Ground water in at least part of the shallow aquifer developed
    for domestic water supply downgradient from the United Nuclear-
    Homestake Partners mill is contaminated with selenium.  Alternative
    water supplies can be developed using deep wells completed in the
    Chinle Formation or in the San Andres Limestone.  Potential well
    sites are located in the developments affected or in the adjacent
    area.  A third alternative includes connecting to the Milan
    municipal system.  Further evaluations are necessary to determine
    the best course of action.

7.  Mining practices, per se, have an adverse effect on natural
    water quality.  Initial penetration and disruption of the ore
    body in the Churchrock mining area increased the concentration of
    dissolved radium in water pumped from the mines from 0.05 - 0.62
    pCi/1 to over 8 pCi/1.  According to company data, the concentration
    rose to over 75 pCi/1, or at least 75 times the natural concentra-
    tion in the two-year period during which the mine was being developed.
    The pattern of increasing radium with time, also seen in Ambrosia
    Lake, is being repeated.  Ground-water inflow via long holes in
    the Kerr-McGee Section 36 mine contain a relatively low concentra-
    tion of dissolved radium-226.  Therefore, much of the radium loading
    of mine effluent is apparently a result of leaching of ore solids
    remaining from mucking and transport within the mine.  In some cases,
    this could be reduced by improved mining practices such as pro-
    vision of drainage channels along haulage drifts.

8.  Radium concentrations in Arroyo del Puerto, a perennial stream,
    exceed New Mexico Water Quality Criteria as a result of discharges
    from the Kerr-McGee ion exchange plant and Section SOW and 35 mines,
    and from the United Nuclear-Homestake Partners ion exchange plant.
    Selenium and vanadium concentrations exceed EPA 1972 Water Quality

                                  -3-

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 8.   (Continued)

     Criteria for use of the water for irrigation  and livestock  watering,
     and render the stream unfit for use as  a domestic water  source.

 9.   Company data show that seepage from the Anaconda tailings pond at
     Bluewater averages 183 million liters/year (48.3 million gallons)
     for 1973 and 1974.  The average volume  injected for the  same  time
     period was 348 million liters/year (91.9 million gallons).  Therefore,
     approximately one-third of the total  effluent volume remaining after
     evaporation (531 million liters/year) enters  the shallow aquifer,
     which is a source of potable and irrigation water in Bluewater Valley.
     From 1960 through 1974, seepage alone introduced 0.41  curies  of  radium
     to the shallow potable aquifer.  Adequate monitoring of  the movement
     of the seepage and the injected wastes  is not underway.

10.   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 monitoring wells, completed in the
     shallower San Andres Limestone and/or the Glorieta Sandstone, show a
     trend of increasing 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.

11.   Rainfall and runoff at the Anaconda Jackpile  Mine erode  uranium- and
     selenium-rich minerals into Rio Paguate.  This erosion can  be mitigated
     by waste stabilization and runoff control.

12.   The maximum concentration of radium observed  in shallow  ground water
     adjacent to the Kerr-McGee mill at Ambrosia Lake was 6.6 pCi/1.
     According to company data, seepage from the tailings ponds  occurs  at
     the rate of 491 million liters/year (130 million gallons/year).   This
     is 29 percent of the influent to the "evaporation ponds" and  attests
     to their poor performance in this regard.  Radium and gross alpha  in  the
     seepage are 56 pCi/1 and 112,000-144,000 pCi/1, respectively. Total
     radium introduced to the ground water to date is estimated  at 0.7  curies.
     Wells completed in bedrock and in alluvium, and located near  watercourses
     containing mine drainage and seepage from tailings ponds,  contain
     elevated levels of TDS, ammonia, and nitrate.  One well, which  contained
     1.0 pCi/1 in 1962 now is contaminated with 3.7 pCi/1 of radium.
     Sorption or bio-uptake of radium is pronounced, hence concentrations  now
     in ground water are not representative  of ultimate concentrations.

13.   Water-quality data from 11 wells over a 200-square kilometer  area in
     the Puerco River and South Fork Puerco  River  drainage basins  reveal


                                     -4-

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13.  (Continued)

     essentially no noticeable increase 1n concentrations  of radio-
     nuclides or common inorganic 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 con-
     tent in shallow wells.  Dissolved radium in shallow  ground water
     underlying stream courses affected by waste water is  essentially un-
     changed from areas unaffected by mine drainage.   None of the samples
     contained more than recommended maximum concentrations  for radium-226,
     natural uranium, thorium-230,  thorium-232, or polonium-210 in drink-
     ing water.  However, the paucity of sampling points  and the absence
     of historical data make the foregoing conclusion a conditional  one,
     particularly in the reaches of the Puerco River  within  approximately
     10 kilometers downstream of the mines.

14.  Four wells 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 maximum per-
     missible concentrations (MPC)  for the other common isotopes of  uranium,
     thorium, and polonium.  Ground 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 are expected.

15.  Of the 71 ground-water samples collected for this study, a total  of
     6 had radium-226 in excess of 3 pCi/1 PHS Drinking Water Standard.
     Two of the 6 involved potable water supplies. One containing 3.6
     pCi/1 serves a single family and is located adjacent to Arroyo  del
     Puerto and downgradient from the mines and mills in  Ambrosia Lake.  The
     second contains 3.7 pCi/1 and is used as a potable supply for the labor
     force in the new shop at the Jackpile Mine.

16.  The highest isotopic uranium and thorium, and polonium-210 contents
     for any potable ground-water supplies sampled in the  study area are
     less than 1.72% of the total radionuclide population  guide - MPC as
     established in NMEIA regulations.

17.  The lowest observed concentration (background levels) in ground water
     are summarized as follows:
                                   -5-

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17.  (Continued)

     Radionuclides               Range (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 - 0.051                 0.028
     Thorium-232                 0.010 - 0.024                 0.015
     U-Natural                   14-68                       35

18.  The uranium isotopes (uranium 234, 235 and 238)  are the main  contributors
     to the gross alpha result; however, in several  determinations,  gross
     alpha underestimated the activity present from  natural  uranium.

19.  No correlation was found between gross alpha content of 15 pCi/1
     (including uranium isotopes) and a radium-226 content of 5 pCi/1-

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

21.  Gross alpha determinations also failed to indicate the possible presence
     of lead-210 (primarily a beta emitter) which, because of the  lower MFC
     of 33 pCi/1, may be a significant contributor to the radiological  health
     nazard evaluation of any potable water supply.

22.  Radium-226 in ground water is a good radiochemical indicator  of waste-
     water contamination from mines and mills.  Due  to the low maximum per-
     missible concentration, it also provides a good means for evaluating
     health effects.  Selenium and nitrate also indicated the presence of
     mill effluents in ground water.  Polonium-210,  thorium-230 and thorium-
     232 concentrations in ground water fluctuate about background levels  and
     are poor indicators of ground-water contamination from uranium mining
     and milling activities.

23.  For routine radiological monitoring of potable  ground-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).
                                     -6-

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II.   Task:   Determine if Discharges Comply with all  Applicable Regulations,
            Standards, Permits, and Licenses.

     1.   At the time of sampling, the effluent from  the Kerr-McGee ion
         exchange plant contained dissolved radium-226 at concentrations
         in excess of the applicable NPDES permit and New Mexico uranium-
         milling license conditions.  This radium discharge was partly
         responsible for violations of New Mexico Water Quality Standards
         for Arroyo del Puerto, a perennial stream.   The discharge also
         contained uranium at concentrations in excess of NPDES permit
         criteria.  No treatment other than settling is currently in
         operation.

     2.   The Kerr-McGee Section SOW mine discharge contained dissolved
         radium-226 at concentrations in excess of the applicable NPDES
         permit condition.  No treatment other than  settling is currently
         in operation.  This radium discharge  also was partly responsible
         for violation of New Mexico Water Quality Standards in Arroyo del
         Puerto.

     3.   Kerr-McGee Nuclear Corporation has not applied for a discharge
         permit for their Section 35 mine, although  the effluent reaches
         Arroyo del Puerto, a perennial stream.  The discharge contains an
         average of 51 pCi/1 of dissolved radium-226.   No radium-removal
         treatment is currently in operation.

     4.   Sampling at the United Nuclear Corporation  Churchrock mine was
         conducted when the operation was inactive due to a power failure
         and subsequent mine flooding.  Indications  are that the present
         treatment facility is inadequate to meet existing NPDES permit
         conditions.

     5.   Approximately 15 percent of the total  flow  through the United
         Nuclear-Homestake Partners ion exchange plant is discharged to
         Arroyo del Puerto, with the balance of the  flow returning to the
         mines for in situ leaching.  The discharge  to Arroyo del Puerto
         is not regulated by an NPDES permit,  and contributes to the vio-
         lation of New Mexico Water Quality Standards  for radium-226 in
         this perennial stream.  Uranium is lost from the ion exchange
         facility.  The facility is currently  violating conditions of the
         applicable State license.
                                    -7-

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III.   Task:  Evaluate the Adequacy of Company Water Quality Monitoring
             Networks, Self-Monitoring Data, Analytical  Procedures,  and
             Reporting Requirements.


      1.  Company sponsored ground-water monitoring programs range from
          inadequate to nonexistent.   Actual monitoring  networks are
          deficient in that sampling  points are usually  poorly located  or
          of inadequate depth/location relative to the hydrogeologic sy-
          stem 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, implementation, and level of investment.

      2.  Company radiochemical analytical  methods are inadequate for
          measuring environmental levels of radionuclides and have high
          minimum detectable activities and large error terms.  Incom-
          plete analysis of radionuclide contents prevails.  Few data are
          reported on other naturally occurring 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 radio-
          nuclides 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 engineer-
          ing needs of the companies rather than addressing long-term,
          general environmental concerns.  As a result, overall impacts
          on ground water are not routinely 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 acceptable levels).  Deficiencies of this type  can
          allow contamination to proceed unnoticed.  On-site wells con-
          structed specifically for monitoring are generally not completed
          to provide representative hydraulic and water quality data for
          the aquifer most likely to be affected.

      5.  Proven geophysical and geohydrologic techniques to formulate
          environmental monitoring networks are apparently not used.  Such
          techniques can assist in specifying sampling frequencies, and
          provide the basis for adjustment of monitoring and operational
          practices to mitigate adverse impacts on ground water.
                                     -8-

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6.  Monitoring the effects of the Jackpile and Paguate open pit
    mines on ground-water quality is nonexistent, despite the
    magnitude of these operations.  Drainage water within the
    pits has contained as much as 190 pCi/1.  Two wells, used
    for potable supply and completed in the ore body contain
    elevated levels of radium, further indicating a need for
    data to determine what the future impacts might be when
    mining ceases and before additional programs for heap leach-
    ing and in situ mining are implemented.

7.  Careful analysis of material  and water balances to determine
    seepage input to ground water for the various tailings disposal
    operations is not evident.  For the Anaconda Company^ the
    method utilized has not been  altered in 14 years.   For Kerr-
    McGee, overland flow presents a potential threat to the
    structural integrity of the retention dams.  At the! United
    Nuclear-Homestake Partners Mill, no quantitative estimates'-
    of seepage are available.

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 disorganized.
    No interpretive summary or review-type reports utilizing the
    monitoring data reported by industry are available from either
    the State or the U. S. Atomic Energy Commission files now held
    by the State.  Liberal mill licensing conditions with respect
    to ground-water monitoring and water-quality impacts were
    initially established by the  USAEC.  Subsequently, there has
    been essentially no review, in any critical sense, of company
    operations with respect to ground-water contamination.  The
    uranium mining and milling industry has not been pressed to
    monitor and protect ground-water resources.  The limited
    efforts put forth by industry to date have largely not been re-
    viewed by regulatory agencies at the State and Federal levels.
                               -9-

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IV.   Task:  Determine the Composition of Potable Waters at Uranium
            Mines and Mills.

     1.  Four industry potable water supply systems, obtained from
         mine waters, exceeded 1962 U. S.  Public Health Service  Drinking
         Water Standards for selenium.  Three such potable systems
         exceeded both the existing USPHS and proposed EPA Interim Pri-
         mary Drinking Water Standards for radium.  Such mine water is
         supplied as potable to families of miners at the United Nuclear
         Corporation Churchrock mine.  These conditions are considered
         intolerable as they bear on the long-term health of those     *
         using the supplies.  Non-potable systems at the Kerr-McGee mill
         and Churchrock mine have high radium and selenium concentrations,
         and are not adequately marked as non-potable.
 V.  Task:  Develop Priorities for Subsequent Monitoring and Other Follow-
            up Studies.
                      See RECOMMENDATIONS
                                  -10-

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                             RECOMMENDATIONS
Action Required


1.  Procedures be initiated to require United Nuclear Corporation to
    immediately provide potable water which meets Federal  Drinking Water
    Standards for their Ambrosia Lake and Churchrock operations.

2.  Procedures be initiated to require Kerr-McGee Nuclear Corporation to
    immediately provide potable water supplies which meet Federal Drinking
    Water Standards at their mill and Section 35 and 36 mines; the mill
    and Churchrock mine non-potable water supplies be clearly marked.

3.  NMEIA initiate appropriate action to insure safe industrial  potable
    water supplies at the United Nuclear Corporation's Ambrosia Lake and
    Churchrock operations and at the Kerr-McGee Nuclear Corporation's mill
    and Section 35 and 36 mines.

4.  NMEIA should conduct periodic sampling of potable water supplies at
    operating uranium mines and mills throughout the State.;

5.  Improved industry-sponsored monitoring programs should be implemented
    and the data made available to State and Federal Regulatory Agencies.
    Programs should be designed to detect likely hydraulic and water
    quality impacts from uranium milling and mining (open pit, underground,
    in situ).  Revamped programs, specifically developed by joint con-
    currence of industry and regulatory agencies, should be incorporated
    in licenses, where possible.  Licenses should specify minimal radio-
    chemical analytical methods for detecting specific radionuclides as
    well as requirements for participation 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.  It is essential that
    the programs developed, as well as the data and interpretive reports
    prepared therefrom, be critically reviewed by the State to meet
    continuing regulatory responsibilities.

6.  Because seepage from the Anaconda and Kerr-McGee tailings ponds con-
    stitutes a significant portion of the inflow to the ponds, it is
    recommended that seepage control measures be adopted.   According to
    company records, such seepage presently totals some 674 million liters
    per year.  Water budget analyses of the United Nuclear-Homestake
    Partners tailings pond should be made to determine how much seepage is
    occurring and thereby contributing to contamination of the shallow
    aquifer locally developed for domestic water supplies 1n two adjacent
    privately owned housing developments.


                                     -11-

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 7.   Improved mining practices  should be adopted  to  reduce the  amount  of
     radium leached from ore solids  by ground water  present in  operating
     mines.

 8.   Procedures should be initiated  to require Anaconda  Company to  im-
     prove its present efforts  at stabilizing waste  and  ore piles at the
     Jackpile Mine in order to  prevent water erosion from transporting
     uranium and selenium into  Rio Paguate.

 9.   Procedures be initiated to require Kerr-McGee Nuclear Corporation
     to immediately install necessary treatment systems  to reduce the
     dissolved radium-226 concentration in the Section SOW mine discharge
     to applicable NPDES permit conditions.

10.   Procedures be initiated to require Kerr-McGee Nuclear Corporation
     to file an application for discharge from their Section 35 mine.
     The permit should provide  limits on total suspended solids, radium-
     226 and uranium, consistent with the permit  conditions for the
     Section SOW mine.

11.   Procedures be initiated to require Kerr-McGee Nuclear Corporation to
     immediately install necessary treatment systems to  ensure  that effluent
     from their ion exchange plant meets applicable  NPDES permit and State
     uranium-milling license conditions.  The Company should develop
     operating schedules to guard against undetected uranium breakthrough
     and subsequent discharge of uranium to Arroyo del Puerto.

12.   United Nuclear-Homestake Partners should install necessary pumps  and
     pipe lines necessary to achieve complete recycle of ion exchange  dis-
     charge.  If unable to accomplish this, it will  be necessary to apply
     for an NPDES permit, and immediately install necessary treatment
     facilities to come into compliance with the  applicable State uranium-
     milling license.
                                     -12-

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                  ADDITIONAL STUDIES REQUIRED
1.  Studies should be immediately initiated to verify whether the source
    of ground-water contamination in the Broadview Acres and Murray
    Acres subdivision is from the nearby uranium mill.  A sound monitor-
    ing program should be developed to predict contaminant migration and
    to provide the basis for subsequent enforcement action.  Necessary
    action should be taken to provide potable water for the affected area.
    Studies should be undertaken to determine the means to prevent
    continuing contamination.

2.  With regard to the Anaconda waste 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 their abundance in the injected fluid.  Limited chemical data
    indicating migration of waste beyond the injection interval
    necessitate that a thorough re-evaluation be made of the long term
    adequacy of this method of waste disposal.  Construction of additional
    monitoring wells in the Yeso Formation and the 61orieta-San Andres is
    in order.   Because of low MFC values, this is particularly true if in-
    creasing concentrations of radium-226 and possibly lead-210 are appear-
    ing in the aquifers above the injection zone.  The Anaconda Company
    should also evaluate the current loss of uranium resources to the sub-
    surface through their current disposal technique.

3.  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 Wilcoxson (P. Harris), Bingham, Marquez, and County Line Stock
    Tanks wells are of principal concern.

4.  Water-quality data from the newly completed monitoring wells peripheral
    to the Kerr-McGee mill should be cross-checked using non-industry
    laboratories to determine the extent of contamination in the Dakota
    Sandstone.

5.  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 preliminary 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 determine the hydraulic and water quality responses to
    dewatering and solution mining.


                                    -13-

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6.  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.  It is recommended that concentrations of trace
    metals should also be measured.

7.  Resampling should be scheduled at the United Nuclear Corporation
    Churchrock mine during normal operations.
                                   -14-

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Action Taken

    The study was designed so that immediate action could be taken when
data obtained indicated such was needed.  Therefore, in June 1975, the
participants in the study met to review the results available at that time
and take any action that was deemed necessary to protect the public health.

    The following conclusions were drawn and action taken:

    1.  A review of the gross alpha and radium-226 analytical results
        indicated a possible problem involving drinking water at the
        United Nuclear Churchrock Mine and Kerr-McGee 35 and 36 Mines.

        ACTION:  NMEIA contacted the company officials, indicated the
        data at hand, and requested that action be taken to remedy
        the situation.

    2.  The preliminary data suggested the possibility of high
        selenium concentrations in water used for drinking at the
        United Nuclear Churchrock Mine and trailer park; United
        Nuclear Churchrock office; Kerr-McGee Mill; and Kerr-McGee
        Section 35 and 36 Mines.

        ACTION:  NMEIA notified the companies of the preliminary
        data and suggested using alternate sources of drinking water.

    3.  Possible problems with selenium concentrations were noted in
        samples from shallow ground water downgradient from the United
        Nuclear-Homestake Partners complex.

        ACTION:  NMEIA notified the company and individual well owners
        of the data and suggested using an alternate source of drinking
        water.  A meeting was held by NMEIA in the Grants area to dis-
        cuss the problem with persons living in the area.

        Forty additional wells were sampled to better define the
        problem.

    4.  An analysis of the data indicated a possible violation of radium
        discharge limits by Kerr-McGee and United Nuclear-Homestake
        Partners Mills.

        ACTION:  NMEIA is in the process of reviewing each license to
        determine compliance with license requirements.
                                    -15-

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    5.  Three NPDES permits have been issued in the Grants Mineral Belt:
        Kerr-McGee Churchrock; Kerr-McGee Ambrosia Lake and United
        Nuclear Churchrock.  Kerr-McGee has asked for adjudicatory hear-
        ings on their two permits.

        ACTION;  Region VI, EPA has issued notice of the hearings and
        will be holding the hearings as soon as possible.  Violations of
        permit requirements at the United Nuclear Churchrock facility have
        been reported and appropriate enforcement action is underway.


    Various follow-up actions will be taken by EPA and NMEIA to ensure
that the recommendations as listed are carried out.  The close working
relationship that has been developed between the State and EPA will be con-
tinued to ensure that the surface and ground-water resources in the Grants
Mineral Belt are fully protected.
                                 -16-

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Applicable Laws and Regulations

     There are a number of Federal and State authorities which call  for
the regulation and control of water quality.  Specifically the discharge
of wastes to surface or ground waters from uranium mining and milling
operations are subject to a number of regulations as follows:

    New Mexico Water Quality Standards

    The New Mexico Environmental Improvement Agency maintains that the
    State's general water quality standards that govern radioactive
    discharges applies to uranium milling and mining activity.  This
    regulation sets a maximum concentration of 30 pCi/1 of dissolved
    radium-226 in water.

    National Pollutant Discharge Elimination System (NPDES) Permits

    The Federal Water Pollution Control  Act, as amended, provides
    that discharge of any pollutant by any person into navigable
    waters shall be unlawful except in compliance with various
    sections of the Act.  EPA has consistently interpreted its
    authority over pollutants under this Act to include authority
    over radioactive materials not covered by the Atomic Energy
    Act of 1954, as amended, e.g., radium and accelerator produced
    isotopes.  However, the Agency had determined that it did not
    have authority over radioactive materials within the NRC'.s
    jurisdiction; i.e., source materials - uranium, thorium, and
    other material designated as essential to the production of .
    special  nuclear material and their ores; special nuclear
    material - plutonium, enriched uranium, and other designated
    material capable of releasing substantial quantities of atomic
    energy; and by-product material - material yielded or made
    radioactive in the production or utilization of special nuclear   .
    material.  This determination of limited EPA authority was over-
    ruled on December 9, 1974, by the U. S. Court of Appeals for the
    Tenth Circuit in the case of Colorado Public Interest Research
    Group v. Train.  The Court found that all radioactive materials
    are pollutants under the Federal Water Pollution Control Act and
    subject to EPA's authorities under that Act.  The U. S. Supreme
    Court has agreed to review this decision.

    Uranium Milling Licenses

    Title 10 C.F.R. Part 20 provides that all persons "who receive,
    process, use, or transfer	source material" shall be con-
    trolled by general or specific licenses issued by the U. S.
    Atomic Energy Commission (succeeded by NRC), or any State con-
    ducting a licensing program.  Under this regulation, all ion
    exchange plants and uranium mills are licensed by NMEIA.
                                   -17-

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Uranium Milling Licenses (Continued)

Mining activities, however, do not appear to be licensed by NMEIA
but probably would be covered by the NPDES program.

Potable Water Requirements

Under the Safe Drinking Water Act, EPA has the authority to:

  a.  Propose and promulgate national primary and secondary
      drinking water regulations, including maximum con-
      taminant levels covering radioactive materials.

  b.  Propose and promulgate regulations for State or Federal
      underground injection control programs, including
      requirements concerning underground injection of radio-
      active materials.

The State is primarily responsible for enforcement of the regu-
lations.

The Act extended Federal control over many potable water supply
systems.  Previously only those systems used in interstate
commerce were required to meet U. S. Public Health Service
Drinking Water Standards.  The latest issue of the USPHS
standard sets a limit of 3 pCi/1 for radium-226 and 0.01 mg/1
for selenium.

The Safe Drinking Water Act applies to all public systems
supplying water to fifteen service connections or at least 25
individuals unless the system is exempt under four specific
criteria.  The industrial potable water supply systems in the
Grants Mineral Belt are covered by this Act.  Proposed standards
will call for 5 pCi/1 for radium, 15 pCi/1 gross alpha, and 0.01
mg/1 selenium.

Section 1431 of the Act also provides that the Administrator,
"upon receipt of information that a contaminant which is present
in or is likely to enter a public water system may present an
imminent and substantial endangerment to the health of persons,
and that appropriate State and local authorities have not acted
to protect the health of such persons, may take such actions as he
may deem necessary in order to protect the health of such persons."
                              -18-

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               ENVIRONMENTAL PROTECTION AGENCY
                    OFFICE OF ENFORCEMENT
            IMPACTS OF URANIUM MINING AND MILLING
                ON SURFACE AND POTABLE WATERS
            IN THE GRANTS MINERAL BELT, NEW MEXICO
                       September 1975
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER -  Denver,  Colorado
                             and
                  REGION VI  - Dallas,  Texas

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                          CONTENTS
   I.     INTRODUCTION  	   1

         Background    	   1
         1975 Water Quality Investigation  	   3

  II.     SUMMARY AND CONCLUSIONS 	   5

 III.     RECOMMENDATIONS 	   8

  IV.     DESCRIPTION OF STUDY AREA	11

         Location	11
         Climate   	11
         Industry	12

   V.     REGULATIONS   	15

         New Mexico Water Quality Standards  	  15
         NPDES Permits   	15
         Uranium-Milling Licenses  	  16
         Potable Water Requirements  	  18
         Nuisance Suits  	  19

  VI.     WASTE SOURCE EVALUATION 	  20

         Kerr-McGee Nuclear Corporation  	  20
         Ranchers Exploration and Development Corp.   .  27
         United Nuclear Corporation  	  28
         United Nuclear - Homestake Partners 	  29
         Anaconda	31

 VII.     STREAM SURVEYS	32

         Arroyo del Puerto	32
         Rio Puerco	33
         Rio Paguate, Rio Moquino, Rio San Jose  ...  35

VIII.     INDUSTRIAL WATER SUPPLIES 	  36

         REFERENCES	40

         APPENDICES:
             A - ANALYTICAL QUALITY CONTROL  	  41
             B - CHAIN OF CUSTODY PROCEDURES 	  60
             C - CHEMICAL ANALYSES DATA	69
             D - SELENIUM	85

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                         TABLES
      Summary of NPDES Permit
      Criteria	17

      Summary of Analytical  Data
      for Industrial  Discharges 	   22

      Summary of Analytical  Data
      for Surface Water Sampling  	   33

      Summary of Data for
      Industry Potable Water Supplies 	   37
                         FIGURES
1     Map of Northwestern New Mexico  	    2

2     Ambrosia Lake Mining District
      Surface Water Discharges  	   21
                      ABBREVIATIONS
    AEC        Atomic Energy Commission
    gpm        gallons per minute
    kg         kilograms
    km         kilometers
    1/min      liters per minute
    m3/day     cubic meters per day
    mg/1       milligrams per liter
    NEIC       National Enforcement Investigations Center
    NMEIA      New Mexico Environmental Improvement Agency
    NRC        Nuclear Regulatory Commission
    ORP-LVF    Office of Radiation Programs-Las Vegas Facility
    pCi/1      picocuries per liter
    RIP        resin in pulp (ion-exchange process)
    USPHS      United States Public Health Service

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                           I.  INTRODUCTION
BACKGROUND

     The United States experienced its first uranium "boom" in the early
1950's as a result of cold-war activities and the fabrication of large
numbers of nuclear weapons.  During that time, most of the currently-
known uranium deposits were discovered by massive exploration by the
U.S. government and private citizens.  Many uranium mills were built at
various sites throughout the west to treat the uranium ores to produce a
uranium oxide called yellou cake.

     This uranium milling was not without environmental damage.  Among
the first recognized water-pollution problems was in the Animas River
Basin of Colorado and New Mexico.  A mill at Durango, Colorado was
contributing abnormally high concentrations of radium to the water
supply of Aztec, New Mexico.  To control radiochemical pollution re-
sulting from uranium milling in this area, the Colorado River Basin
Enforcement Conference was convened in 1960 by the states composing the
Colorado River Basin.  Federal, State, and industry cooperative efforts
resulted in pollution control by which streams in the Colorado River
Basin contained near background levels of pollutants resulting from
uranium milling.  Other uranium milling areas, most notably the Grants
Mineral Belt, were not situated on interstate streams and thus not sub-
ject to Federal pollution control before the Federal Water Pollution
Control Act Amendments were passed in 1972.  Little pollution control
effort was expended toward mine and mill discharges within this area.

     The Grants Mineral  Belt [Fig. 1], stretching west from just north-
west of Albuquerque, New Mexico to the New Mexico-Arizona state line,
contains almost half of the United States uranium reserves.  A second
uranium "boom" now underway promises to make the Grants Mineral Belt the

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                         MC KINUEY  CO.
                L_l   -«\VALENCIA CO.
FIGURE I.  location and  G»n«ra( F»atur»t of th» Granti Mineral B«lf in Northwestern  New  MEXICO

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foremost uranium mining and milling site in the United States.  This
"boom" results from the demand for nuclear fuel elements in nuclear
power plants (Guccione, Aug. 1974).
1975 WATER QUALITY INVESTIGATION

     The New Mexico Environmental Improvement Agency (NMEIA) realized
that little information was available on the water discharges from
mining and milling in the Grants Mineral Belt, and the subsequent effect
on ground and surface water resources of the area.  On September 25, 1974
NMEIA requested EPA Region VI to conduct a survey of water-pollution
sources and surface and ground-water quality in the Grants Mineral Belt.
The National Enforcement Investigations Center (NEIC) and the Office of
Radiation Programs-Las Vegas Facility (ORP-LVF) were subsequently asked
by Region VI to conduct a survey in cooperation with the NMEIA.

     Studies conducted from February 24 to March 6, 1975 included
industrial waste source evaluation, potable water sampling, and limited
stream surveys by NEIC, and ground-water evaluations by ORP-LVF.  NMEIA
provided assistance to both NEIC and ORP-LVF during the survey.   The
three mining areas evaluated in the Grants Mineral Belt were [Fig. 1]:

     Area                               Approximate Location
Ambrosia Lake                      32 km (20 mi) N of Milan, N.  Mex.
Churchrock                         32 km (20 mi) NE of Gallup, N. Mex.
Paguate                            16 km (10 mi) N of Laguna, N. Mex.

The mill sites are:
Kerr-McGee                         near Ambrosia Lake
United Nuclear-Homestake
   Partners                        8 km (5 mi) N of Milan
Anaconda                           11 km (7 mi) W of Milan

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United Nuclear Corporation operates an ion-exchange plant in the
old "Phillips" mill near Ambrosia Lake.  No conventional  milling is
currently done at this site.

     As stated in a February 14, 1975 letter from the Director of
NMEIA, the primary tasks of the study were to:
     1.   Assess the impacts of waste discharges from uranium mining
          and milling on surface and ground waters of the Grants
          Mineral Belt.
     2.   Determine if discharges comply with all applicable regu-
          lations, standards, permits and licenses.
     3.   Evaluate the adequacy of company water quality monitoring
          networks, self-monitoring data, analytical procedures and
          reporting requirements.
     4.   Determine the composition of potable waters at uranium
          mines and mills.
     5.   Develop priorities for subsequent monitoring and other
          follow-up studies.

     During the survey, samples were collected from wells, industrial
discharges, drinking water supplies, and surface streams.  The samples
were appropriately preserved to determine the radiochemical, nutrient,
and metals content and shipped to the NEIC and ORP-LVF laboratories for
analyses (Appendix A).  NEIC custody procedures were maintained during
the collection and analyses of the samples (Appendix B).

     This report presents the findings of analyses of surface water
streams, potable water supplies, and industrial discharges.  Appendix C
contains raw data for all samples collected during the survey and an-
alyzed by NEIC.  The NEIC analysis, when combined with the ORP-LVF re-
port, will present an overall study of water quality in the Grants
Mineral Belt.

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                II.  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.   Radium concentrations in Arroyo del Puerto, a perennial
     stream, exceed New Mexico Water .Quality Criteria as a result
     of discharges from the Kerr-McGee ion-exchange plant and
     Sections 30W and 35 mines and from the United Nuclear-Home-
     stake Partners ion-exchange plant.  Selenium and vanadium
     concentrations exceed EPA 1972 Water Quality Criteria for use
     of the water for irrigation and livestock watering, and render
     the stream unfit for use as a domestic water source.

2.   Rainfall and runoff at the Anaconda Jackpile Mine erode
     uranium- and selenium-rich minerals into Rio Paguate.  This
     erosion can be mitigated by waste stabilization and runoff
     control.
Task:   Determine if discharges comply with all applicable regulations,
        standards, permits,  and licenses.
1.   At the time of sampling, the effluent from the Kerr-McGee ion-
     exchange plant contained dissolved-radium 226 at concentrations
     in excess of the applicable NPDES permit and New Mexico
     uranium-milling license conditions.  This radium discharge was
     partly responsible for violations of New Mexico Water Quality
     Standards for Arroyo del Puerto, a perennial stream.   The
     discharge also contained uranium at concentrations in excess
     of NPDES permit criteria.  No treatment other than settling is
     currently in operation.

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2.   The Kerr-McGee Section 30W mine discharge contained dissolved
     radium-226 at concentrations in excess of the applicable NPDES
     permit condition.  No treatment other than settling is currently
     in operation.  This radium discharge also was partly responsible
     for violation of New Mexico Water Quality Standards in Arroyo
     del Puerto.

3.   Kerr-McGee Nuclear Corporation has not applied for a discharge
     permit for their Section 35 mine, although the effluent reaches
     Arroyo del Puerto, a perennial stream.  The discharge contains
     an average of 51 pCi/1 of dissolved radium-226.  No radium-
     removal treatment is currently in operation.

4.   Sampling at the United Nuclear Corportion Churchrock mine was
     conducted when the operation was inactive due to a power
     failure and subsequent mine flooding.  Indications are that
     the present treatment facility is inadequate to meet existing
     NPDES permit conditions.

5.   Approximatley 15 percent of the total flow through the United
     Nuclear-Homestake Partners ion-exchange plant is discharged to
     Arroyo del Puerto, with the balance of the flow returning to
     the mines for in situ leaching.  The discharge to Arroyo del
     Puerto is not regulated by an NPDES permit, and it contributes
     to the violation of New Mexico Water Quality Standards for
     radium-226 in this perennial stream.  Uranium is lost from the
     ion-exchange facility.  The facility is currently violating
     conditions of the applicable State license.
Task:   'Determine the composition of potable waters at uranium
        mines and mills.
1.   Four industry potable water supply systems, obtained from mine
     waters, exceeded 1962 U. S. Public Health Service Drinking

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Water Standards for selenium.  Three such potable systems
exceeded both the existing USPHS and proposed EPA Interim
Primary Drinking Water Standards for radium.  Such mine water
is supplied as potable to families of miners at the United
Nuclear Corporation Churchrock mine.  These conditions are
considered intolerable as they bear on the long-term health of
those using the supplies.  Non-potable systems at the Kerr-
McGee mill and Churchrock mine have high radium and selenium
concentrations, and are not adequately marked as non-potable.

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                    III.   RECOMMENDATIONS
ACTION REQUIRED

1.   Procedures be initiated to require United Nuclear Corporation
     to immediately provide potable water which meets Federal
     Drinking Water Standards for their Ambrosia Lake and Church-
     rock operations.

2.   Procedures be initiated to require Kerr-McGee Nuclear Corporation
     to immediately provide potable water supplies which meet
     Federal Drinking Water Standards at their mill and Sections 35
     and 36 mines; the mill and Churchrock mine non-potable water
     supplies be clearly marked.

3.   NMEIA initiate appropriate action to insure safe industrial
     potable water supplies at the United Nuclear Corporation's
     Ambrosia Lake and Churchrock operations and at the Kerr-McGee
     Nuclear Corporation's mill and Section 35 and 36 mines.

4.   NMEIA should conduct periodic sampling of potable water
     supplies at operating uranium mines and mills throughout the
     State.

5.   Improved mining practices should be adopted to reduce the
     amount of radium leached from ore solids by ground water
     present in operating mines.

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 6.    Procedures should be initiated to require Anaconda Company to
      improve its present efforts at stabilizing waste and ore piles
      at the Jackpile Mine in order to prevent water erosion from
      transporting uranium and selenium into Rio Paguate.

 7.    Procedures be initiated to require Kerr-McGee Nuclear Corporation
      to immediately install necessary treatment systems to reduce
      the dissolved radium-226 concentration in the Section SOW mine
      discharge to applicable NPDES permit conditions.

 8.    Procedures be initiated to require Kerr-McGee Nuclear Corporation
      to file an application for discharge from their Section 35
      mine.   The permit should provide limits on total suspended
      solids, radium-226 and uranium, consistent with the permit
      conditions for the Section SOW mine.

 9.    Procedures be initiated to require Kerr-McGee Nuclear Corporation
      to immediately install necessary treatment systems to ensure
      that effluent from their ion-exchange plant meet applicable
      NPDES permit and State uranium milling license conditions.
      The Company should develop operating schedules to guard against
      undetected uranium breakthrough and subsequent discharge of
      uranium to Arroyo del  Puerto.

10.    United Nuclear-Homestake Partners should install pumps and
      pipelines necessary to achieve complete recycle of ion-
      exchange discharge.   If unable to achieve complete recycle,
      it will be necessary to issue an NPDES permit.  The Company
      should immediately install necessary treatment facilities to
      comply with the applicable State uranium milling license.

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                                                                      10
ADDITIONAL STUDIES REQUIRED

     Resampling should be scheduled at the United Nuclear Corporation
Churchrock mine during periods of normal operation.

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                     IV.  DESCRIPTION OF STUDY AREA
LOCATION

     The Grants Mineral Belt extends west from a point slightly north-
west of Albuquerque, New Mexico, north of the towns of Grants and Gallup,
almost to the New Mexico-Arizona state line [Fig. 1].   The Belt extends
about 48 km (30 mi) north from the routes of U.S. 66 and the Atchison,
Topeka and Santa Fe railroad.  Some mining is conducted in Valencia
County, but the bulk of the Grants Mineral Belt is in  southern McKinley
County.

     The principal centers of population in the area are the towns of
Grants and Gallup, and the villages of Churchrock, Wingate, Milan, and
Laguna.  Population in the area has increased rapidly since 1950, with
the development of extensive uranium mining and milling operations.

     With the exception of the volcanically formed Mt.  Taylor area, most
of the area is plateau topography underlain by sedimentary rocks.
Streams have incised steep-walled valleys in the area,  with broad val-
leys in those areas underlain by easily erodable sediments.

     The eastern half of the Grants Mineral Belt, including the Ambrosia
Lake district, is tributary to Rio San Jose.  The western portion is in
the valley of the Rio Puerco, a tributary to the Little Colorado River.
CLIMATE

     The Grants Mineral Belt area is semi-arid to arid,  with an average
annual temperature of about 10°C (50°F).   Maximum summer temperatures

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                                                                    12
rarely exceed 38°C (100°F) with minimum temperatures occasionally below
-18°C (0°F).  The humidity in the area is usually low,  and moderate to
strong winds are common during the spring.  Precipitation is largely
influenced by elevation, with a positive correlation between increasing
elevation and increasing precipitation.  Annual  average precipitation  at
the Grants Airport is 21 cm (8.3 in), approximately 70% of which occurs
May through September.
INDUSTRY

     Industry in the Grants Mineral Belt used to be largely centered
around farming and ranching, with limited tourism.   Since 1950,  the
economic base of the Grants Mineral Belt area has completely shifted to
industry, based on the mining and milling of uranium ore to produce
yellow cake.

     Underground mining operations in the Grants Mineral Belt are by the
room and pillar method, which consists of driving a number of parallel
development drifts in the ore horizon.  A series of parallel sluicer
drifts are driven at right angles, leaving a grid of ore pillars to sup-
port the overlying rock, or "roof."  As the pillars are mined (robbed),
the roof is rock-bolted and supported by timbers as necessary to prevent
subsidence.  The mined area (stope) is then abandoned.

     The ore horizon in underground mines in the Grants Mineral  Belt is
composed of the Westwater Canyon member of the Jurassic Morrison formation,
which is the main aquifer of the Grants Mineral Belt area.  Therefore,
large quantities of ground water must be pumped from each mine to
prevent mine flooding.  Ore bodies are dewatered by drilling "long
holes" from the development drifts into the ore horizon, and permitting
ground water to flow from the long holes into the drifts and then be
pumped to the surface for discharge.  Water flow is by  gravity to sumps

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                                                                     13
near the mine shaft, with positive pumpage to the surface.  This water
passes through settling basins at each mine to remove solids and then is
either pumped to an ion-exchange plant for removal of contained uranium,
or is discharged directly to surface water courses.  Some of the ion-
exchange water is recycled to the mines for use in solution mining or is
used as a potable water supply for workers in the mines and mills.

     Where the physical and economic situations permit, most mining
companies now collect underground mine water in a single location for
ion-exchange treatment to recover uranium which is dissolved in the mine
water.  Recovery is accomplished by using specific resins which are
extremely selective in the removal of dissolved uranium.  The mine water
is passed through the resin column where the resin becomes loaded until
it reaches its capacity for uranium (breakthrough).  Flow is then
diverted to another barren resin column and the loaded resin is stripped
or eluted with a sodium chloride brine.  The pregnant sodium chloride
brine is then treated in one of the uranium mills to precipitate yellow
cake.  The barren solution is returned and reused for subsequent elution
steps.

     Experience has shown that a carefully operated ion-exchange plant
will yield an effluent containing less than 1 mg/1 uranium in solution
(USEPA, April 1975).  The greatest operating difficulty has been in
monitoring for breakthrough of the uranium, or the loading of ion-
exchange resins.  Both United Nuclear Corporation and United Nuclear-
Homestake Partners return a portion of the ion-exchange effluent, or
tailings, to abandoned mines in the Ambrosia Lake area.  This barren
water is used to leach the ore which remained behind in ore pillars
and rock which was not of ore grade.  By this practice, uranium
resources are recovered which would otherwise be lost.

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     The Anaconda Company operates its Jackpile-Paguate mine mostly as
an open-pit operation.  From 1953 to the present, the operation has
yielded approximately 10 million tons of uranium ore with an average
grade of 0.25% uranium oxide (Graves, Aug. 1974).  Mining is accomplished
with power shovels loading off-highway trucks.   Ore is transported from
the mine to Anaconda's mill by rail.

     No surface discharge of water is reported  from the Jackpile mine.
Rainfall collects in pits and seeps or evaporates.  However, intense
summer thunderstorms erode piles of waste and ore.

     Three uranium mills are currently operating in the Grants Mineral
Belt, and several other mills are in the design or construction phase.
The three operating mills practice different techniques for uranium re-
covery.  All three operate on the basis of zero discharge of waste to
surface waters by utilizing evaporation, seepage and, in one
case, subsurface injection.  To solubilize the  uranium, two of the mills
acid leach the ore while the third uses an alkaline leach circuit.
Uranium is concentrated by solvent extraction at two of the mills.  In
all three mills, uranium is precipitated as yellow cake, a complex
uranium oxide.  Ammonia is used in precipitating or purifying the
yellow cake at all three mills.  Details on milling techniques at the
three facilities are provided in the August 1974 issue of Mining Engineer-
ing (Vol. 26, no. 8).

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                            V.  REGULATIONS
     The discharge of wastes to surface or ground waters from uranium
mining and milling operations are subject to a number of regulations.
Applicable portions of each regulation are discussed below.
NEW MEXICO WATER QUALITY STANDARDS

     Water Quality Standards were adopted by the New Mexico Water
Quality Control Commission under the authority of Paragraph C, Section
75-39-4 of the New Mexico Water Quality Act (Chapter 326, Laws of 1973,
as amended).  The NMEIA has held that general  standards do apply to
receiving waters in the Grants Mineral Belt.  The general standard that
governs these radioactive discharges follows:
     Radioactivity - The radioactivity of surface waters shall be
     maintained at the lowest practical level  and shall in no case
     exceed the standards set forth in Part 4 of New Mexico Environ-
     mental Inprovement Board Radiation Protection Regulations,
     adopted June 16, 1973.
These regulations set a maximum concentration of 30 pCi/1 of dissolved
radium-226.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITS

     Congress, with the passage of the Federal Water Pollution Control
Act Amendments of 1972 (PL92-500, Oct. 18, 1972) established the re-
quirement for NPDES permits for discharge of pollutants to waters of the
United States.  Discharge of pollutants without a valid NPDES permit is
illegal.

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                                                                    16
     To date, three permits have been written covering four sources in
the area studied.

Permit No.      Outfall No.                  Source
NM0020532         001         Kerr-McGee Nuclear Corp. Sec. 30W Mine
NM0020532         002         Kerr-McGee Nuclear Corp. Ion Exchange Facility
NM0020524         001         Kerr-McGee Nuclear Corp. Churchrock Mine
NM0020401         001         United Nuclear Corp. Churchrock Mine

     The first three sources are currently pending adjudication with
respect to the need for an NPDES permit to discharge to Puertecito Creek
or Rio Puerco.

     Specific numerical limits are set for the concentration of total
suspended solids (TSS), total uranium, and dissolved radium-226 [Table 1].
In addition, each permit contains the following statement: ,
     Provision shall be made to assure the elimination of all
     seepage, overflow or other sources which may result in any
     direct or indirect discharge to surface waters other than that
     authorized by this permit.

URANIUM-MILLING LICENSES
     U.S. Regulation 10CFR20 provides that all persons "who receive,
possess, use or transfer ... source material" shall be controlled by
general or specific license issued by the U.S. Atomic Energy Commission
(now called the Nuclear Regulatory Commission) or any state conducting a
licensing program.  Source materials are defined as ores which contain
more than 0.05% of combined uranium and thorium.  Under the regulation,
all ion-exchange plants and uranium mills are licensed by the New Mexico
Environmental Improvement Agency.

     The regulations set forth the maximum concentration of various
radionuclides which are permitted in effluents to "unrestricted areas."
An unrestricted area is defined as any area to which access is not

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                                                             Table 1

                                                 SUMMARY OF NPDES PERMIT CRITERIA
Parameter
Company/Discharge


Kerr-McGee Corporation
Churchrock Mine

Section 30W Mine
(Ambrosia Lake)

Ion-Exchange Plant
(Ambrosia Lake)

United Nuclear Corporation
Churchrock Mine


Period of
Limitation


1/28/75-6/30/77
7/1/77-1/27/80
1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80
1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80

1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80
TSS (rag/1)
Daily
Avg. Max.

20 30
20 30
20 30
20 30
20 30
20 30
20 30
20 30

100 200
20 30
20 30
Total Uranium (mg/1)
Daily
Avg. Max.

2
2
2
2
2
1
1
1

2
2
2
Dissolved Radium-226
Daily
Avg. Max.

30
3.3
150
30
3.3
100
30
3.3

30
30
3.3
(PCI/1) PH
Range


6.0-9.5
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0

6.0-9.5
6.0-9.5
6.0-9.0
In addition to these parameters, the companies are required to monitor flow, temperature, total molybdenum, total selenium
and total vanadium.                                                                  •   •

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                                                                    18
controlled by the licensee to protect individuals from exposure to
radiation and radioactive materials.   Personnel  badge monitoring is  not
required in unrestricted areas.  The  maximum allowable concentration of
radium-226 in a water effluent to an  unrestricted area is 30 pCi/1.   All
uranium mills and ion-exchange plants are controlled by this regulation
from the initial start-up of the facility.

POTABLE WATER REQUIREMENTS

     Congress, with the passage of the Safe Drink-ing Water Act (PL93-523,
Dec. 16, 1974) extended Federal control over many potable water supply
systems.  Previously, only those systems used in interstate commerce
were required to meet USPHS Drinking  Water Standards.  The latest issue
of the USPHS Standards set a limit of 3 pCi/1 for radium-226, and
0.01 mg/1 for selenium.

     The Safe Drinking Water Act applies to all  public systems supplying
water to fifteen service connections  or at least 25 individuals unless
the system is exempted by four specific criteria.  The industrial po-
table water supply systems in the Grants Mineral Belt are thus covered
by the Safe Drinking Water Act.

     As required by Sections 1412, 1414, 1415, and 1450 of the Safe
Drinking Water Act, the EPA Administrator, on March 14, 1975, proposed
Interim Primary Drinking Water Standards.  These proposed regulations
include a limit of 0.01 mg/1 selenium.  The Interim Primary Drinking
Water Standards are to be promulgated within 180 days of the enactment
of the Act, and they become effective 18 moriths after their promulga-
tion, or Dec. 1977.  The EPA has proposed standards of 5 pCi/1 radium
(226 and 228) and 15 pCi/1 gross alpha (exclusive of uranium) under  the
Act (Appendix D quotes the EPA Water Quality Criteria, 1972 on selenium).

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                                                                       19
     The New Mexico Environmental Improvement Agency (Sections 4 and 12,
Chapter 277, New Mexico Laws of 1971) is vested with authority to main-
tain, administer, and enforce the "Regulations Governing Water Supplies
and Sewage Disposal" adopted in 1937 by the former New Mexico State
Board of Public Health.

     Section 1 of the aforementioned 1937 Water Supply Regulations
states:

          No person, firm, corporation, public utility, city, town,
          village or other public body or institution shall  furnish
          or supply or continue to furnish or supply water used or
          intended to be used for human consumption or for domestic
          uses or purposes, which is impure, unwholesome, unpotable,
          polluted or dangerous to health, to any person in  any county,
          city, village, district, community, hotel, temporary or
          permanent resort, institution or industrial camp.
     It is from this and other sections of the 1937 regulations that the
NMEIA has authority to regulate public water supply systems.   However,
individual residential sources used for private consumption  are not
covered by the 1937 regulations.  Therefore, the NMEIA can only advise
as to the quality of the water in the case of such residential sources.
NUISANCE SUITS

     New Mexico is given specific authority to take enforcement action
against a polluter under the Nuisance statute (40A-8-1  through 40A-8-10,
1953 Compilation).  A section titled Polluting Water (40A-8-2) allows
the New Mexico Environmental Improvement Agency to seek remedial  action
against any wastewater discharger that pollutes any water of the  state
whether it is public or private, surface or subsurface  water.   In 1973
the NMEIA successfully prosecuted the City of Hobbs for polluting ground
water by land disposal of the city's sewage effluent.   The court  order
required the City to remove the polluted water and supply potable water
to affected parties.

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                     VI.  WASTE SOURCE EVALUATION
     Five companies are currently engaged in mining and/or milling
operations in the Grants Mineral Belt, and several other companies are
presently in design or construction phases.  The results of waste-source
evaluations at each of the operating companies are presented below.
KERR-MCGEE NUCLEAR CORPORATION

     Kerr-McGee operates mines in both the Ambrosia Lake and Churchrock
Mining Districts of the Grants Mineral Belt.  Water from five of the
Ambrosia Lake mines (Sections 17, 22, 24, 30 and 33)* is pumped to an
ion-exchange plant at the Kerr-McGee mill [Fig. 2].  The majority of
ion-exchange discharge (also referred to in the mining industry as
tailings) is used in the mill as process water and non-potable water.  A
small remainder receives additional ion-exchange treatment for potable
water use within the mill.  Excess ion-exchange tailings are discharged
into Arroyo del Puerto.  The NPDES permit** and State uranium milling
license for this discharge requires that the radium 226 concentration
not exceed 100 pCi/1 and 30 pCi/1, respectively.  The data [Table 2]
shows that this discharge contained an average of 151 pCi/1 radium-226
during the survey.  This exceeds both the NPDES permit immediate limi-
tations and the State license.  This latter license has been in effect
since the time of the construction of the ion-exchange plant.  The
  *  The names of mines are based on the section in which they are located;
     all of these are in T14N3 R9W, McKinley County, New Mexico.
 **  Kerr-McGee has requested an adjudicatory hearing on its permits for
     the ion-exchange plant and Section SOW mine.  The company contends
     that an NPDES permit is not required to discharge to Arroyo del
     Puerto.  The Kerr-McGee State license is effective for the Kerr-McGee
     ion-exchange plant.

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                                                                                 21
KEftt-Mc OEE SECTION 30 W MINE
                         UNITED  NUCLEAR COBP
                          lON'EXCHANGE  PLANT
 flgurt 1.  Ambroifo loir* Mining DIHrlcl Svrfac*  Wol.r Dlicherg**

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                       Table r.
SUMARY OF ANALYTICAL DATA FOR INDUSTRIAL DISCHARGES
             GRANTS MINERAL BELT SURVEY
              February SB-March 6,  1375
Station Average
Description Flow
(mgd)
Kerr-McGee
I-X Tailings
Bypass 0.64
Kerr-McGee
Sec 30W
Mine Dischg 1.36
Kerr-McGee
Sec 19 Mine
Discharge 0.15
Kerr-McGee
Sec 35 Mine
Discharge 3.77
Kerr-McGee
Sec 36 Mine West
Discharge 2.07
Kerr-McGee
Sec 36 Mine East
Discharge 0.14
Kerr-McGee
Seppago bolow
Tailings Pond -
Ranchers Exploration-
Johnny M Mine
Discharge 0.46
United Nuclear Corp.
Ion-Exchange
Discharge 0.08
United Nuclear-
HOITX": t.oko P.irtnors
Ion Exchange
Discharge 0.60
United nuclear-
Homes take Partners
Tailings Pile Decant
Number
Composite Gross
Samples Max


3 600


3 1 .400


1


3 3,000


3 850


3 580


1


1


3 2,300



3 970


1

Alpha (pCi/1)
M1n. Avg.


430 510


1,300 1.400


72


2,400 2.7'00


570 680


510 560


- 144,000


20


1,400 1,800



760 830


- 29.000

Radium 226 (pC1/l) Uranium (mg/1)
Max. M1n. Avg. Max. M1n. Avg.


157 148 151 4.2 1.3 2.5


174 154 163 6.7 5.9 6.2


9.3 - - 0.23


68 32 51 26 14 19


178 101 131 3.4 2.6 3.0


72 59 65 2.5 2.3 2.4


65 - - 160


- 1.6 - - 0.12


39 14.3 31 11 5.9 7.8



111 101 108 5.8 2.3 3.7


52 - - 150
Total Suspended
Sol Ids (mg/1)
Max. M1n. Avg.


31 16 25


26 17 22


16


120 86 100


44 33 38


32 27 29


38


7


735



16 7 10


5

Selenium (mg/1)
Max. Min. Avg.


0.07 0.03 0.05


0.04 0.03 0.03


- <0.01


0.08 0.04 0.07


0.01 <0.01 <0.01


0.03 <0.01 0.01


0.70


- <0.01


0.12 0.02 0.08



0.33 0.30 0.32


0.92

Vanadium (mg/1)
Max. Min. Avg.


1.0 0.7 0.9


0.8 0.7 0.7


0.6


1.0 0.6 0.8


1.0 0.8 0.9

•
0.8 0.4 0.6


5.6


- <0.3


0.5 <0.3 0.3



0.5 <0.3 0.3


6.8
Anaconda Co. Injection
Well Food 0.16
United Nuclear Corp.
Churchrock Mine
Discharge 2.06
Kerr-McGee
Churchrock Mine
Discharge 2.18


1


3 870


3 240


- 62,500


730 010


210 230


53 - - 130


27.3 19.8 23.3 7.6 6.5 7.2


8.7 6.8 7.9 0.97 0.72 0.81


3


71 33 50


58 38 47


0.03


0.06 <0.01 0.04


0.01 0.01 0.01


6.3


0.5 0.4 0.4


0.9 0.7 0.8
ro
ro

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                                                                      23
concentration of radium in the ion-exchange discharge could be reduced
to meet permit conditions with the relatively simple addition of barium
chloride.  The New Mexico Water Quality Standards for Arroyo del Puerto,
a perennial stream, limits radium concentrations to a maximum of 30
pCi/1.  The Kerr-McGee ion-exchange discharge to Arroyo del Puerto
contributes to violations of these standards (see Section VII. STREAM
SURVEYS).

     The NPDES permit for the Kerr-McGee ion-exchange discharge limits
uranium to a daily maximum concentration of 1 mg/1.  During the three
days of composite sampling, the uranium concentration in the discharge
ranged from 1.3 to 4.2 mg/1 for an average of 2.5 mg/1, or 2.5 times the
permitted maximum concentration.  This violation of the permitted level
probably resulted from overloading of the resin and failure to switch
resin columns.  The Company should adopt a regeneration cycle that will
prevent resin saturation by uranium (breakthrough) which results in
permit violation.

     Selenium is an extremely toxic substance which behaves very simi-
larly to arsenic.  It is present in the ore of the Grants Mineral Belt,
and thus it could reasonably be expected to be present in water from
processing plants.  The Kerr-McGee ion-exchange tailings contained from
0.03 to 0.07 mg/1, an average of 0.05 mg/1.  These tailings also con-
tained almost 1 mg/1 vanadium, which has been shown to be toxic to
plants when present in irrigation water.  The high selenium and vanadium
concentration precludes the use of Arroyo del Puerto for irrigation
(discussed in Section VII).

     Mine water from other Kerr-McGee Ambrosia Lake mines (Sections 19,
30W, 35, and 36) does not receive ion-exchange treatment.  Section 19
Mine, currently under development, discharges approximately 378 1/min
(100 gpm) of wastewater which contains 9.3 pCi/1 of radium on the land
surface.  Since this discharge does not reach a surface water course, the
Company has not applied for an NPDES permit.

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                                                                      24
     The NPDES permit for the Kerr-McGee Section 30W mine imposes im-
mediate limits on the radium-226 content of this discharge.   The initial
maximum limit is 150 pCi/1, with a final limit of 3.3 pCi/1  [Table 1].
During the survey, this discharge contained an average concentration of
163 pCi/1 of radium-226 [Table 2] which exceeds permit conditions.  The
discharge enters Arroyo del Puerto upstream of the Kerr-McGee ion-
exchange discharge and contributes to the water quality standards viola-
tion in Arroyo del Puerto (see Section VII).  The 30W discharge also
contained selenium and vanadium [Table 2] and contributes to the high
concentration of these elements in Arroyo del Puerto.

     The uranium concentration of Section 30W mine discharge is limited
to 2 mg/1 daily maximum by the NPDES permit.  During the survey, the
uranium concentration of this discharge ranged from 5.9 to 6.7 mg/1, for
an average of 6.2 mg/1, a violation of the NPDES permit conditions.  The
company reportedly plans to pipe this discharge to their ion-exchange
plant.

     During the Grants Mineral Belt survey, 14,300 m /day (3.77 mgd) of
water was discharged from Kerr-McGee Section 35 mine settling ponds into
a marshy area south of the mine.  Company officials claim this discharge
does not reach any surface water and therefore an NPDES discharge
permit is not required.  Visual observations by NEIC personnel showed
that this discharge, estimated at several hundred gallons per minute,
does enter Arroyo del Puerto.  The flow rate was highly variable, de-
pending on climatic conditions.  The radium concentration in this waste-
water ranged from 32 to 69 (average 51) pCi/1 which exceeds limitations
currently specified in permits for similar discharges. The radium con-
centrations can be reduced to less than 30 pCi/1 with the addition of a
barium chloride treatment system:  Gross alpha concentrations were high,
ranging from 2,400 to 3,000 pCi/1.  ORP-LVF conducted analyses for the
alpha emitters other than radium contained in this discharge.  The
analyses indicated that lead-210 may be significant in this and other
discharges; however, the data are not available at this time.  Uranium,

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                                                                      25
selenium, and vanadium are also present in this discharge [Table 2] and
contribute to high values in Arroyo del Puerto.  Suspended solids in
the Section 35 mine discharge were high, ranging from 86 to 120 mg/1
with an average of 100 mg/1.  Analysis of incoming mine water from long
holes within the area indicates that the radium concentrations in natural
ground water are less than 10 pCi/1.  However, water moves over the
entire floor of the drift, and it is subject to agitation by passage of
haulage trains and during mucking.  Accordingly, the suspended solids
concentration in the mine water is high, producing a high dissolved
radium concentration.  The suspended solids and radium concentrations in
the effluent could be greatly lowered by improved housekeeping in the
mining operations, such as providing drainage channels along the sides
of the mine workings.

     Section 36 mine has two discharges, identified as the east and west
discharges in relation to the mine shaft.  Samples from each discharge
were collected and analyzed.  Except for a minor amount of water used by
drilling rigs in the area, the entire mine pumpage receives treatment in
sedimentation basins before discharge into a large closed basin over the
San Mateo fault.  During the survey, all the water was sinking into the
subsurface and moving as ground water.  Survey results [Table 2] show
                                                                3A
the west discharge contained an average of 131 pCi/1 radium-226 compared
to 65 pCi/1 in the east discharge.  These concentrations exceed license
criteria (10 CFR20) for discharge to an unrestricted environment.  The
discharge also contained from 0.4 to 1.0 mg/1 vanadium, which precludes
use of this water for crop irrigation on acid soils, or long-term use on
any soil (Committee on Water Quality Criteria, 1972).

     Company officials stated that the Section 35 and 36 mine discharges
will be diverted to a new set of treatment ponds for biological removal
of radium 226, utilizing algal  growth and radium incorporation.  If

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                                                                      26
necessary, radium-226 concentrations can be further reduced by barium
chloride treatment.  These new ponds, to be constructed sometime during
1975, will discharge into the closed basin currently receiving the
Section 36 mine discharge.  The increased flow into this closed basin
may result in a surface discharge to San Mateo Creek.  In this case, an
NPDES permit will be required which should specify an immediate radium-
226 limit of 30 pCi/1.

     Kerr-McGee Nuclear Corporation is developing a new mine in the
Churchrock mining district.  The mine water receives treatment in two
sedimentation ponds.  Some of the effluent from the pond is used in the
mine change-house for non-potable uses such as showers and commodes, and
the remainder is discharged into Rio Puerco.  The immediate NPDES permit
limitations for this discharge include 100 mg/1 daily average and 200
mg/1 daily maximum total suspended solids concentration, 2 mg/1 daily
maximum uranium concentration and 30 pCi/1 dissolved radium-226.  The
lack of ongoing mining activities in the mine is reflected in the
relatively low radiochemical concentration in the water from this mine
[Table 2], with an average radium-226 concentration of 7.9 pCi/1.

     The  Kerr-McGee Nuclear Corporation mill near Ambrosia Lake removes
uranium from the ore by an acid leach technique, followed by solvent
extraction to concentrate the uranium, and by ammonia precipitation of
yellow cake.  A molybdenum byproduct recovery is also practiced at the
Kerr-McGee mill.  Approximately 75% of the mill water is recycled, while
the other 25% is lost through seepage and evaporation.  Because of
dissolved solids buildup, it is thought to be impossible to practice
100% recycle without dissolved solids removal techniques.  Process water
for the Kerr-McGee mill is obtained from the Kerr-McGee ion-exchange
treatment plant.  Tailings are discharged to a single large tailings
pond on the company property.  Seepage from the pond is collected in a
catchment basin and is then pumped to a pond upgradient from the tail-
ings pond.  Overflow from this pond is pumped upstream to another pond.

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                                                                     27
In this way, all seepage from the evaporating ponds should be captured
by the catchment basin.  However', physical inspection of the area
indicated that a quantity of seepage is lost to the subsurface, with a
portion of the seepage possibly appearing in the flow in Arroyo del
Puerto.  This will require control under proposed NMEIA ground-water
regulations, or regulations to be proposed under the U.S. Safe Drinking
Water Act.

     An 8-hr composite was collected from the catchment basin and
analyzed to determine the quality of waste which might enter the ground
water.  The sample contained 144,000 pCi/1 and 65 pCi/1, respectively,
of gross alpha and radium-226.  The radium concentration exceeds the AEC
license criteria (30 pCi/1) for discharge to a nonrestricted environ-
ment.  The gross imbalance which exists between gross alpha and radium
indicates high concentrations of other alpha emitters.  Identification
and quantification of these emitters, and the effect on ground water, is
discussed in the report by ORP-LVF.  This water is extremely high in
sulfate (15,000 mg/1) due to the use of sulphuric acid for leaching  the
Kerr-McGee ore.  Suspended solids concentration in the seepage was
approximately 38 mg/1.  Selenium was present in 0.70 mg/1 concentration,
or 70 times the drinking water standard.  Vanadium was present in the
seepage at a concentration of 5.6 mg/1.
RANCHERS EXPLORATION AND DEVELOPMENT CORPORATION

     Ranchers Exploration is currently developing the Johnny M.  mine.
Mine water is treated in two settling ponds before being discharged into
San Mateo Creek.  An NPDES permit application was filed by Ranchers
Exploration, however the permit had not been issued at the time  of the
survey.  The data [Table 2] show that the gross alpha and radium-226
concentrations were 20 and 1.6 pCi/1, respectively.  This reflects the

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                                                                    28
lack of ongoing mining activities in the operation.   Uranium concen-
tration in the water was 0.12 mg/1, while the suspended solids con-
centration was 7 mg/1.


UNITED NUCLEAR CORPORATION

     United Nuclear Corporaton has three mines (two  active and one on
standby) in the Ambrosia Lake area.  All mine water  is pumped to an ion-
exchange plant for uranium recovery.  Over 99% of the ion-exchange
effluent is used for solution mining.  The remainder is either used as
potable water or is discharged into a holding pond for use in sand
backfill operations.  There was no discharge from the pond at the time
of the survey.  Although an application has been filed, company of-
ficials stated that wastewater does not reach Arroyo del Puerto; there-
fore an NPDES permit is not required.

     Samples were collected from the ion-exchange effluent at a point
ahead of its return to the underground mines.  The ion-exchange effluent
contained an average of 31 pd'/l radium-226 and 1,800 pCi/1 of gross
alpha.  Suspended solids concentration in the ion-exchange discharge
were from 3 to 7 mg/1.  As shown in Table 2, selenium concentration
ranged from 0.02 to 0.12 mg/1, for an average of 0.08 mg/1.

     United Nuclear Corporation also operates an underground mine in the
Churchrock mining district.  The NPDES permit limits the radium-226
concentration to a maximum of 30 pCi/1.  Other NPDES permit criteria
include 100 mg/1 of suspended solids daily average,  200 mg/1 suspended
solids daily maximum, and 2 mg/1 uranium daily maximum.  A power failure
at the mine during the la'st week in February resulted in flooding of
work areas.  During the survey, company personnel were pumping out the
mine and repairing underground equipment.  Composite samples collected
during the clean-up operations contained an average  radium-226 con-
centration of 23.3 pCi/1.  After the survey, NMEIA personnel collected

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                                                                    29
a grab sample on 14 March 1975 following the resumption of mining
activities.  This sample contained 57 pCi/1 of radium-226 which exceeds
the permit limitation.  The composite samples contained from
33 to 71 mg/1 suspended solids concentration, while the later grab
sample contained 320 mg/1 suspended solids.  Uranium was present in the
discharge at an average concentration of 7.2 mg/1.   Additional  sampling
is suggested to check for NPDES compliance, once the mine returns to
typical operation.
UNITED NUCLEAR-HOMESTAKE PARTNERS

     The United Nuclear-Homestake Partners joint venture operates four
underground mines (Sections 15, 23, 25 and 32) in the Ambrosia Lake
mining district.  Uranium in the mine water is removed in an ion-exchange
plant.  About 85% of the effluent is recycled through the mines and used
for in situ leaching (solution mining).   The remaining 15% (0.08 mgd)  of
the ion-exchange effluent is discharged  into Arroyo del  Puerto upstream
of the Kerr-McGee mill.  An NPDES application has recently been filed
for this discharge.  During this survey, the radium-226  concentration  in
this discharge exceeded 100 pCi/1.  The  radium-226 concentration in this
discharge can be reduced to 30 pCi/1 or  less with the addition of a
barium chloride treatment system.  These high concentrations exceed the
NPDES permit issued for similar discharges and the State uranium milling
license currently in effect for this facility.  This discharge contri-
butes to the violation of the New Mexico Water Quality Standards for
Arroyo del  Puerto (see Section VII).

     Suspended solids concentration in the United Nuclear-Homestake
Partners ion-exchange discharge are low, ranging from 7  to 10 mg/1.
Selenium concentrations range from 0.30  to 0.33 mg/1, more than 30 times
the drinking water standard for selenium.   These concentrations would
pose a health hazard if the water were used for a potable supply.

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                                                                      30
The presence of a large supply of clear water suggests an attractive
alternative to plant personnel bringing their own drinking water to the
plant.  Uranium concentrations averaged 3.7 mg/1, indicating a need for
closer monitoring of resin loading, or more frequent resin regeneration.

     The United Nuclear-Homestake Partners Uranium mill recovers uranium
by alkaline leaching of the ore, followed by ammonia precipitation of
yellow cake.  No ion-exchange or solvent extraction is practiced.
Tailings-pile decant water is recycled through the mill.  Seepage from
the pile also enters ground water as determined by visual observation
and ORP-LVF sampling.  A sample of the decant, which is indicative of
the quality of the seepage, contained 29,000 pCi/1 and 52 pCi/1, respect-
ively, of gross alpha and radium-226.  The radium concentrations exceed
the 10CFR20 criteria for discharge to a nonrestricted environment.
The seepage also was found to contain 0.92 mg/1 of selenium, or 92 times
the drinking water standard.  This is indicative of the geochemistry of
selenium, which is found to be highly mobile in alkaline solutions.
Results of the seepage on ground water are discussed in the ORP-LVF
report.

     Additional samples have  been collected from a number of wells in
the area downgradient from the United Nuclear-Homestake Partners tail-
ings pond and are currently undergoing analyses.  Problems of inter-
laboratory agreement are being resolved by appropriate Analytical Qual-
ity Control (AQC) programs.  AQC data for the NEIC determinations are
included in Appendix A.  Results to date indicate that alkaline leaching
of uranium milling tailings or uranium ore produces water high in a
mobile form of selenium, and  it presents definite problems of ground-
water pollution.  Seepage control measures should be required at this
facility.  Additional laboratory analysis of existing samples, and
additional sampling to define the extent of the problem are planned for
the near future.

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                                                                     31
ANACONDA COMPANY

     The Anaconda Company operates the world's largest open pit uranium
mine, the Jackpile Mine on the Laguna Indian Reservation.  There is no
discharge of mine water to Rio Paguate or Rio Maquino.  Precipitation
runoff from the disturbed land surface, however, adds radiochemical-
bearing solids to these streams.  Stream samples [Table 3] show a
definite increase in radium-226 and selenium concentrations downstream
from the mining operation.  The data show the need for stabilization of
waste material and improved handling of storm runoff.

     The Anaconda Company uranium mill at Bluewater uses a Resin In Pulp
(RIP) ion-exchange process on an acid leach operation (Anon, Aug. 1974).
In this circuit, baskets of ion-exchange beads are agitated in a crushed
slurry ore.  The beads, when loaded, are eluted with a dilute solution
of sulfuric acid and sodium chloride.  Uranium is precipitated in two
steps, with the addition of calcium hydroxide during the first step and
magnesium hydroxide during the second step.  This precipitate is then
washed with ammonium sulfate to remove sodium and produce a saleable
yellow cake.

     Process wastes from the Anaconda mill  are discharged into a 70-acre
tailings pond constructed on a highly permeable basalt flow.  The water
which does not seep from this pond is decanted, filtered to remove
suspended solids, and fed at a rate of 1,100 1/min (300 gpm) to an
injection well.  A sample of the well feed, which is indicative of the
seepage to the ground water, contained 62,500 pCi/1 and 53 pCi/1, re-
spectively, of gross alpha and radium-226 [Table 2].  Vanadium was
present in a concentration of 6.3 mg/1.  The well feed contained 150
mg/1 uranium, which corresponds to a uranium loss of 245 kg (540 lb)/day.
At present values of yellow cake, this would have a market value of
$8,100 to $10,800/day.   This uranium could  be recovered by the instal-
lation of an ion-exchange plant between the present filter and injection
well.

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                         VII.  STREAM SURVEYS
     When the mines and mills were evaluated, selected stream stations
were sampled to determine the effect of mine and mill discharges on
water quality.  The New Mexico Water Quality Standards limit the radium
concentration in surface streams to a maximum of 30 pCi/1.  Data on the
samples collected from surface streams are. provided in Table 3.
ARROYO DEL PUERTO

     Arroyo del Puerto receives waste from the United Nuclear-Homestake
Partners and Kerr-McGee ion-exchange plants and from Kerr-McGee Section
SOW and 35 mines.  There is no flow in the creek upstream of these
discharges.

     Radium-226 concentrations of samples collected downstream from the
Kerr-McGee mill were from 45 to 50 pCi/1.  These concentrations not only
violate the New Mexico Water Quality Standards, but exceed the AEC
criteria (30 pCi/1) for radium in water discharged to an unrestricted
environment.  Radium concentrations in Arroyo del Puerto decreased near
the mouth to levels ranging from 6.1 to 7.2 pCi/1.  This decrease is due
to the adsorption  of radium on sediment and/or vegetation.  During
periods of heavy run-off, the radium concentration can be expected to
increase due to scouring of the stream bed.

     The selenium  concentration of Arroyo del Puerto downstream from the
Kerr-McGee mill was 0.15 mg/1, decreasing to 0.04 mg/1 near the mouth.
Vanadium concentrations in Arroyo del Puerto near the Kerr-McGee mill
averaged 0.8 mg/1, increasing to 1.1 mg/1 near the mouth.  Selenium and

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       fable 3

     OF ANALYTICAL DATA
         FOP
SURFACE WATER SAMPLING
Number.
Station Description of Gross Alpha (pCi/1)
SamPles Max. Mln. Avg.
Arroyo del Puerto downstream
of Kerr-McGee Mill
Arroyo del Puerto near the mouth
San Mateo Creek
at Highway 53 Bridge
Rio Puerco downstream of
Churchrock Mines
Rio Puerco upstream
of Wingate Plant
Rio Puerco at Highway 666 Bridge
Rio Paguate at Paguate
Rio Moquino upstream of
Jackpile Mine '
Rio Paguate at Jackpile Ford
Rio Paguate at Paguate
Reservoir Discharge
Rio San Jose at Interstate Bridge
3
3
1
3
3
3
1
1
1
1
1
1,700 1,400 1,500
1,500 750 1,100
- 1 ,000
500 470 490
510 720 440
350 210 260
2.8
11.2
270
230
, - - 38
Radium-226 (pCi/1)
Max. Min. Avg.
50 45 47
7.2 6.1 6.5
1.09
2.60 0.97 2.04
1.63 0.36 0.81
0.42 0.09 0.22
0.11
0.17
4.8
1.94
0.37
Uranium (mg/1)
Max. Min. Avg.
12 5.0 7.7
6.6 4.7 5.8
4.7
5.0 3.8 4.2
4.8 3.7 4.2
2.5 1.7 2.0
- <0.02
- <0.02
- 1.2
- , - T-l
0.10
Selenium (mg/1)
Max. Min. Avg.
0.16 0.13 0.15
0.07 0.01 0.04
0.02
0.07 0.03 0.04
0.01 0.01 0.01
<0.01 <0.01 <0.01
- <0.01
- <0.01
- <0.05
- <0.01
- <0.01
Vanadium (mg/1)
Max. Min. Avg.
1.0 0.6 0.8
1.9 0.5 1.1
- <0.3
0.6 0.5 0.6
0.9 0.3 0.6
0.6 0.3 0.5
0.6
1.8
0.5
0.6
0.3
                                                                                    CO
                                                                                    CO

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                                                                      34
vanadium have harmful effects when present in high concentrations in
water used for irrigation or livestock watering.  The 1972 EPA Water
Quality Criteria (Committee on Water Quality Criteria, 1972) suggests
that irrigation waters not exceed 0.02 mg/1 selenium and 0.1 mg/1 va-
nadium, while livestock waters should not exceed 0.05 mg/1 selenium and
0.1 mg/1 vanadium.  On this basis, Arroyo del Puerto is rendered unfit
for irrigation and livestock watering by the uranium mining discharges
throughout its entire length.  This is contrary to New Mexico Water
Quality Standards which require that discharges not render a water unfit
for a beneficial use.

     The flow of Arroyo del Puerto enters San Mateo Creek where the
entire flow enters the aquifer within three miles of the confluence.
This recharge adds a large loading of radium and selenium to the ground
water.  Ground-water evaluations by ORP-LVF will address this question.
RIO PUERCO

     The Rio Puerco receives drainage from Kerr-McGee and United Nuclear
Corporation Churchrock mines.  Samples collected downstream from these
discharges contained a maximum radium-226 concentration of 2.6 pCi/1
[Table 3].  The concentration decreased to 0.4 pCi/1 at the town of
Gallup.  These concentrations meet the New Mexico Water Quality Criteria
of 30 pCi/1, as well as the PHS Drinking Water Standard of 3 pCi/1 for
radium-226.  Selenium concentrations downstream from the mine discharges
ranged from 0.03 to 0.07 mg/1 for an average of 0.04 mg/1, or four times
PHS Drinking Water Standards.  The selenium concentration decreased
downstream to 0.01 mg/1 at the Wingate plant and to less than detection
limits at Gallup.

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                                                                      35
RIO PAGUATE. RIO MOQUINO, RIO SAN JOSE

     The Rio Paquate and Rio Moquino flow through the Anaconda open pit
mines on the Laguna Indian Reservation.  The combined flow enters Rio
San Jose near Laguna, New Mexico.  Samples collected from these three
streams had radium concentrations of less than 5 pCi/1, which is less
than the Water Quality Standard of 30 pCi/1 set by the State of New
Mexico.  An increase in the selenium concentration of Rio Paguate was
noted downstream from the Jackpile Mine.  However, the concentration of
selenium at Paguate reservoir and in Rio San Jose were less than de-
tection limits.

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                   VIII.  INDUSTRIAL WATER SUPPLIES
     The majority of the mines and mills in the Grants Mineral  Belt use
mine water as a potable supply.  The present PHS Drinking Water Stan-
dards specify that the radium concentrations not exceed 3 pCi/1, and the
selenium not exceed 0.01 mg/1.  The Safe Drinking Water Act (Public Law
92-523, Dec. 16, 1974) requires establishment of national drinking water
standards.  The proposed standards limit selenium to 0.01 mg/1.  Also,
EPA has proposed standards of 5 pCi/1 for radium-226 and -228 and
15 pCi/1 for gross alpha (40 CFR 141).

     Data from potable water supplies in the Grants Mineral Belt are
summarized in Table 4.  All but one of the water-supply systems contain
radium-226 in concentrations greater than the PHS Drinking Water Stan-
dard of 3.0 pCi/1.  Severe violations of the 0.01 mg/1 selenium standard
are also present.  Kerr-McGee Nuclear Corporation supplies water to mill
workers and to several mobile homes within the area;  the source is ion-
exchange water from the mines, subsequently treated for radium removal.
As shown in Table 4, the radium concentration in this water was at an
acceptable level of 0.5 pCi/.  The selenium in the water supply was 0.05
mg/1, or 5 times the drinking water standard.  Treatment or an alternate
source of supply will be required to meet the selenium standards.

     Kerr-McGee operates a dual water supply system within the mill and
the office facility -- a potable system described above, and a non-
potable system used for washing and sanitary facilities.  The latter
uses ion-exchange tailings without further treatment.  Radium concen-
trations in this water are extremely high, averaging over 150 pCi/1.
Company personnel are largely uninformed about the existence of the dual
water supply system and have admitted to drinking from the non-potable

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                                                                     37
                                Table 4

                         SUMMARY OF DATA FOR
                    INDUSTRY POTABLE WATER SUPPLIES
Description
Kerr-McGee - Mill Water Supply
Kerr-McGee - Sec. 35 and 36 Mines
Kerr-McGee - Churchrock Mine
United Nuclear Corporation -
Ambrosia Lake Area
United Nuclear Corporation -
Churchrock
United Nuclear Corporation -
Mobile Home Supply at the
Churchrock Mine
Gross Alpha
(pCi/1)
510
3,000
120
1,500
620
1,110
Radium 226
(pCi/1)
0.5
43
6.5
23.5
12.6
39.7
Selenium
(mg/l)
0.05
0.05
0.01
0.11
0.06
0.06
t  Reportedly used only for showers, stools, etc.  and not for drinking
   water.

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                                                                    38
source.  Warning signs should be posted on the non-potable water system
to prevent subsequent potable use of this radioactive water.

     Water from the Kerr-McGee Section 35 mine is treated by  ion-exchange
and used for a potable system for workers in Section 35 and 36 mines.
This water contained a radium concentration of 43 pCi/1 and a gross
alpha concentration of 3,000 pCi/1.  This exceeds existing and proposed
standards for radiochemistry in the potable supply.   The selenium in
this supply was 0.02 mg/1, twice the level which constitutes  grounds for
rejection as a water supply under Drinking Water Standards.

     Clarified water from the settling ponds at the Kerr-McGee Church-
rock mine are pumped into the Kerr-McGee change house for use in sani-
tary facilities.  The water contained concentrations of radium-226
approximately twice the Drinking Water Standards.  It also contained
selenium at a concentration of 0.01 mg/1, or the concentration which
constitutes grounds for rejection as a potable water supply.   The supply
is not intended as potable, but it is not adequately marked as non-
potable.

     United Nuclear Corporation maintains a potable water supply system
for its Churchrock mine as well as for mobile homes within the area.
Water from the mine is pumped into a holding pond on Sunday,  when mining
activities are not under way.  Water from this holding pond is then
passed through a filter for removal of suspended solids.  No  further
treatment is given.  A sample collected from a water fountain within the
United Nuclear Corporation change-house contained 12.6 pCi/1  radium-226
and 0.06 mg/1 selenium.  These levels exceed PHS Drinking Water Standards
and proposed standards under the Safe Drinking Water Act.  The system is
supplied to a number of private trailers in the area, and it  clearly
will come under the provision of the Safe Drinking Water Act.

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                                                                     39
     A sample was collected on March 5, 1975 from one of the mobile
homes supplied by the United Nuclear Corporation Churchrock mine water-
supply system.  The sample contained 39.7 pCi/1 radium-226 and 0.06 mg/1
selenium.  The trailer was occupied by the wife and three children of
one of the uranium miners.  These concentrations grossly exceed the
proposed and present drinking water standards and pose a health hazard
to the employees and their families.  The United Nuclear Corporation
should take immediate action to improve the quality of this domestic
supply or locate an alternate source of water.

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                                                                 40
                         REFERENCES
1.   Anon, Aug. 1974.  Anaconda's Resin-in-Pulp Process:   Another
     Route to Yellowcake, Mining Engineering,  SME-AIME,  26,  8_:31-36.

2.   Committee on Water Quality Criteria, Environmental  Studies
     Board, NAS and NAE, 1972.  Water Quality Criteria 1972,
     USEPA-R3-73-033, 594 p.

3.   Graves, John A., Aug. 1974, Open Pit Uranium Mining,  Mining
     Engineering, SME-AIME 26,  8^:23-25.

4.   Gucci one, Eugene, Aug. 1974. Fuel Shortages Trigger a New
     Uranium Rush in New Mexico, Mining Engineering, SME-AIME,
     26, 8:16-19.

5.   U. S. Environmental Protection Agency, Apr. 1975. Draft
     Development Document for Effluent Limitations, Guidelines,  and
     Standards of Performance for the Ore Mining and Dressing
     Industry Point Source Category, USEPA Contract No.  68-01-2682.

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          Appendix A

  ANALYTICAL QUALITY CONTROL
FIELD AND LABORATORY PROCEDURES

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                      ANALYTICAL QUALITY CONTROL
                    FIELD AND LABORATORY PROCEDURES
WASTE SOURCE EVALUATIONS

     Mining and milling operations operated by five companies were
investigated during the Grants Mineral Belt survey.  Information was
obtained through in-plant surveys, review of NPDES permit applications,
and interviews with industry personnel, on water pollution control
practices at each site.

     Sampling was conducted in accord with a previously prepared Study
Plan (attached).  Sampling proceeded as planned, except that conditions
at United Nuclear Corporation's Churchrock mine were atypical due to
power failure and subsequent mine flooding.  Daily composite samples
were collected manually into large cleaned containers on an equal volume
basis.  The composite sample was then returned to a central sample
preparation site where individual samples were prepared in accord with
Table 4 of the Study Plan.  Company sample splits were prepared where
requested.  Filtering was done through a 0.45 u filter, using stainless
steel pressure filtering equipment.

     Where available, industry flow-measurement equipment was used.  In
other cases, various standard flow measurement techniques such as "V"
notch weirs and stage recorders were used.

     The samples were maintained under custody procedures and trans-
ported to the NEIC laboratory in NEIC vehicles.

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STREAM SURVEYS

     Limited stream surveys were conducted to determine the effects of
mining and milling discharges on surface waters of the Grants Mineral
Belt.  Sampling was generally in accord with the Study Plan, except
where there was no flow.  Sampling in the Paguate area was restricted to
one-time grab sampling.  Sample preparation was in accord with the
discussion in the previous section.


INDUSTRY WATER SUPPLIES

     Grab samples were collected from industry potable and non-potable
(sanitary) water supplies, in accord with the Study Plan.  Sampling
sites were at water fountains, faucets, or showers.  The source was
permitted to run for a time before sample collection.  Samples were
subsequently split and preserved, as discussed in the section on waste
source evaluation.


ANALYTICAL PROCEDURES AND QUALITY CONTROL

     Samples collected during this survey were, for the most part,
analyzed according to procedures outlined in the EPA Manual, Methods for
Chemical Analysis of Water and Wastes, 1971.  Gross alpha and radium-226
levels were measured according to procedures described in Standard
Methods for Water and Wastewater Analysis, 13th Ed.  Uranium was measured
by the fusion/fluorescence procedure described as Method #02907-701 in
the ASTM Manual, Part 31, 1975.   Selenium was analyzed by a fluorometric
procedure developed by Crenshaw and Lakin (Journal Research U.S. Geo-
logical Survey, ?_ (4), 483 (1974)); the fusion step was omitted, however,
since the samples were non-geological in origin.  These analytical
procedures are summarized below.

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Parameter
                   Method
Reference
Co, Cu, Fe    Atomic Absorption1
V, Mo
Na            Atomic Emission1
As            Colorimetric
TSS, IDS      Gravimetric
SO.           Turbidimetric
Cl            Titrimetric
NH-           Automated Colorimetric
N02 + N03     Automated Cadmium
              Reduction
Gross         Internal Proportional
              Counting
Radium-226    Radon emanation2
Uranium       Fusion/Fluorescence1
Se            Fluorometric
                                      EPA Methods for Chemical Analysis, 1971

                                      EPA Methods for Chemical Analysis, 1971
                                      EPA Methods for Chemical Analysis, 1971
                                      EPA Methods for Chemical Analysis, 1971
                                      EPA Methods for Chemical Analysis, 1971
                                      EPA Methods for Chemical Analysis, 1971
                                      EPA Methods for Chemical Analysis, 1971

                                      EPA Methods for Chemical Analysis, 1971

                                      Standard Methods, Section 302.4.a.
                                      Standard Methods, Section 305
                                      ASTM, D290F
                                      Crenshaw and Lakin, J. Res. U.S. Geol.
                                      Survey, Vol. 2, No. 4, July-August,
                                      1974, p. 483-487
1  Digest-Ion of samples per Sec. 4.2.4.  EPA Methods
2  RaSo./BaS04 precipitate collected by centrifugation, dissolved in
   diethylenetriamine pentaacetic acid, and placed directly in bubbler.
     Reliability of the analytical results was documented through an
active Analytical Quality Control (AQC) Program.  As part of this
program, replicate analyses were normally performed with every tenth
sample to ascertain the reproducibility of the results.  In addition,
every tenth sample was spiked with a known amount of the constituents to
be measured and reanalyzed to determine the percent recovery.  These
results were evaluated in regard to past AQC data on the precision,
accuracy, and detection limits of each test.  As an example, AQC results
for Ra-226 and Se are tabulated on the following page.

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   Parameter            Radium-226                  Selenium

Detection Limit         0.05 pCi/1                0.005 mg/1
Percent Difference in   0-1 pCi/1: 0-52%          0-0.1; 0-30%,
 Duplicate Measurements    22% Avg*                   21% Avg.
                        1-200 pCi/1: 0-8%,        0.1-1.0: 9-32%,
                           5% Avg.                    15% Avg.
Percent Recovery from   1-200 pCi/1: 79-104%,     0-0.1 mg/1: 60-134%,
 Spiked Samples            93% Avg.                    109% Avg.
t  0-1 pCi/l represents the concentration range being considered^ 0-52%
   represents the range of the percent difference between duplicates3
   and 22% represents the average of these variations.

     On the basis of these findings, all analytical results reported for
the survey were found to be acceptable with respect to the precision and
accuracy control of this laboratory.

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                               STUDY PLAN
                  NEW MEXICO URANIUM MINING AND MILLING
                      WATER QUALITY INVESTIGATIONS
OBJECTIVES
     1.  Determine the impact of previous and existing discharges to
ground and surface waters of the Grants-Mineral Belt and establish a data
base for future  National Pollutant Discharge Elimination System (NPDES) permits
and uranium mining and milling license guidelines due to expanded mining
and milling activities.
     2.  Determine whether the discharges from uranium mines and mills
comply with existing and proposed NPDES permits and uranium-milling
licenses.
     3.  Determine the composition of potable waters at uranium mines
and mills.
     4.  Determine if NPDES non-filers exist in the study area.
     5.  Evaluate the adequacy of company monitoring networks; self-
monitoring data, analytical procedures and reporting requirements.
BACKGROUND
     Uranium ore was discovered in the Grants Mineral Belt in 1950
resulting in the construction of four processing mills, three of which
are still operating.   The early mining started in the shallow deposits
of the Bluewater area and has progressed into the Ambrosia Lake area
where shaft mines of greater than 1000 ft have been developed.  Ground
water from the overlying Dakoata aquifer and Westwater Canyon member of
the Morrison Formation is pumped from these mines and discharged to
surface waters.  The industry is currently experiencing a major expansion
with design and/or construction of three new mills and numerous mines.

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     Since the discovery of ore and the construction of uranium mills,
only a limited amount of company data has been developed on the chemical
and radiochemical characteristics of the mining and milling wastes.   The
surface discharges from the mines receives only minimal treatment and
companies have not made a concerted effort to prevent seepage from mill
tailings ponds from entering subsurface water.
     The NMEIA requested EPA, Region VI (letter dated September 25,  1974)
to conduct a "definitive survey of the Grants Mineral Belt".  Through
meetings and subsequent correspondence, it was decided that the study
will be conducted jointly by New Mexico Environmental Improvement Agency
(NMEIA), National Field Investigations Center (NFIC) and Office of
Radiation Programs-Las Vegas Facility (ORP).
     The three uranium mills (Kerr-McGee, United Nuclear-Homestake
Partners and Anaconda) and three mine (Kerr-McGee, United Nuclear and
United Nuclear-Homestake Partners) water treatment facilities (ion
exchange units or IX) operate under AEC licenses.  These licenses have
been transferred to NMEIA.  The licenses require meeting conditions
set forth in 10 CFR 20 of which the most significant is that liquid
waste discharged to areas with controlled access have radium 226 levels
equal to or less than 30 picocuries per liter (pCi/1).
     NPDES permits have been issued for the Kerr-McGee mine discharges
at Ambrosia Lake (ion exchange unit and Section SOW mine) and Churchrock,
and the United Nuclear Corporation mine at Churchrock.  The permit limitations
are summarized in Table 1.  Kerr-McGee has requested adjudicatory hearings
on their permits.

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     General New Mexico Water Quality Standards for perennial reaches
of streams, including those formed by wastewater discharges, apply to
the streams in the study area.  The most significant provision of these
standards is that radium 226 concentrations must be less than 30 pCi/1.
REQUIRED STUDIES
A.   Reconnaissance Survey
     A reconnaissance survey was conducted by personnel of NMEIA, ORP
and NFIC during the period January 27-31, 1975,  Company officials were
contacted to obtain existing data and facility inspections were conducted
at each of the mills and mines.  A number of mine discharges, which are
not covered by an NPDES permit, are believed to be reaching San Mateo
Creek and its tributaries.  Seepage from the Anaconda, Kerr-McGee and
United Nuclear-Homestake Partners mill tailings piles has an extremely
high potential of degrading water in the study area.  Potable water
supplies at the mines and mills is, for the most part, obtained from
mine water treated by sedimentation followed in a few cases by selective
ion exchange units which may not remove radium and most heavy metals,
if present, from the mine water.
B.   Industrial Waste Survey
     Effluent monitoring of mine wastewaters will be conducted.  Samples
will also be collected of the mill tailings pond water to ascertain the
type of pollutants which can enter the ground water.
     Operating (active) mine discharges will be sampled for three
consecutive days with 24-hour composite samples being collected.  Mines
currently under development and mill tailing piles will be monitored

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for 8 hours one day [Table 2 lists the stations and parameters which
. .1 11 U-	1 J	i	AUx» 	.-..,1
will uc nicaaui cu uui iny me ouivcjrj.
C.   Stream Surveys
     In conjunction with the industrial survey, selected stream stations
will be sampled to determine possible water quality violations [Table 3].
These stations are located in San Mateo Creek upstream and downstream
from the Johnny M Mine discharge and downstream from the confluence
of Puertecito Creek; Puertecite Creek upstream of all discharges (upstream
of United Nuclear-Homestake Partners IK discharge), downstream from
Kerr-McGee Mill, and near the mouth at Rancho del Puerto; Rio Puerco
downstream of United Nuclear and Kerr-McGee mines, upstream of Wingate
plant, and in Gallup at Highway 666 Bridge; Rio Moquino upstream of
                                                     c~
Jackpile Mine; Rio Paguate at Paguate, at the Jackpile Mine Ford and
at the Paguate Reservoir discharge; and the Rio San Jose at 1-40 bridge
east of Laguna.
     The Rio Moquino, Rio Paguote and Rio San Jose are influenced by
storm run-off of tailings and ore piles.  These streams will be sampled
during run-off.
D.   Ground-Water Survey
     Ground-water related activities will emphasize definition of the
hydrogeologic environment and sampling of selected wells and springs to
characterize existing water quality and relate it to uranium mining
and milling waste discharge.
     A separate study plan for this portion of the study has been
prepared by ORP.

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LOGISTICS
     All industrial, stream and well samples will  be sent to the NFIC
laboratory for analysis.  Industrial samples will  be split with the
appropriate company.  All samples will be field split for radiochemical
analysis with ORP.  Alpha and radium 226 screening tests at NFIC will
be considered for further analyses by ORP for Th-230, Pb-210, Po-210,
Th-228, and possibly Ra-228.  All samples will be  collected and analyzed
following established NFIC Chain-of-Custody procedures.   The size of
sample and preservative required are summarized in Table 4.
TIME SCHEDULE*
     January 27-31, 1975               Reconnaissance Survey
     February 3-21, 1975               Develop sampling schedule and
                                       notify industries
     February 24-25, 1975              Start setting up flow monitoring
                                       equipment
     February 26-March 8, 1975         Sample industries and streams
     February 24-March 14, 1975        Sample ground water
PERSONNEL
A.   Field Survey
     NFIC                              1 Supervisory Engineer (coordinator)
                                       1 Geologist
                                       3 Technicians
     NMEIA                             3 Technicians
*Report on the study findings will be completed within 2-3 weeks
 following receipt of final analytical data.

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     ORP

     Region VII (Kerr Water Lab)
B.   Report Preparation
     NFIC

     NMEIA
     ORP
1  Hydro-Geologist
1  ii*.-n.i.i_ nL..--->~.i-
               i 3 c
   ..._
i  i ica i en
1  Technician
1 Technician (part-time)
1  Engineer
1  Geologist
1  Technician (limited time)
1  Hydro-Geologist
1  Health Physicist
1  Hydro-Geologist
1  Health Physicist
1  Nuclear Chemist
EQUIPMENT
     Gaging equipment
     Peristaltic pump
     Sampling and metering equipment
     Pressure filtering units
     Vehicles
           4 Four-Wheel drive - 2 Denver and 2 Albuquerque  (NFIC)
           1 Sedan - Albuquerque (NFIC)
           1 Van - Las Vegas (ORP)
           1 Panel Truck - Kerr Center, Ada (ORP)

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                                                          TABLE 1

                                             SUMMARY OF NPDES PERMIT CRITERIA
Company/Discharge
Kerr-McGee Corp.
-Churchrock Mine
Discharge
-Section 30W Mine
Discharge
(Ambrosia Lake)
-Ion Exchange
Discharge
(Ambrosia Lake)
United Nuclear
Corporation
-Churchrock Mine
Period of
Limitation
1/28/75-6/30/77
7/1/77-1/27/80

1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80
1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80
1/28/75-12/31/75
1/1/76-6/30/77
7/1/77-1/27/80

TSS-mq/1
Daily Avg.
20
20

20
20
20
20
20
20
100
20
20


Daily Max.
30
30

30
30
30
30
30
30
200
30
30
Parameters!/
Total Uranium-mg/1
Daily Avg. Daily Max.
2
2

2
2
2
1
1
1
2
2
2

Dissolved Radium 226-pCi/l
Daily Avg. Daily Max.
30
3.3

150
30
3.3
100
30
3.3
30
30
3.3
PH
Range
6.0-9.5
6.0-9.0

6.0-9.0
6.0-9.0
6.0-9.0
6.0-9'.0
6.0-9.0
6.0-9.0
6.0-9.5
6.0-9.5
6.0-9.0
  Discharge
 V  In addition to these parameters,  the companies are required to monitor flow,  temperature, total  molybdenum,
'     total selenium and total  vanadium.

-------
                                                                    TABLE 2. Page 2
Number
Station Days Type
Number Station Description Sampled Sample
9016

9017

9018


9019


9021

9023

9024


9025

9026
United Nuclear Corp.
IX Discharge
UnUiid Nuclear Corp.
Potable Water Supply
Unltiid Nuclear-Home-
staki> Partners IX
Discharge
United Nuclear-Home-
stake Partners
Tall Ings Pile Decant
Anaconda Co. Injection
Well Feed
United Nuclear
Churchrock Mine
United Nuclear
Churchrock Potable
Water Supply
Kerr-McGee Church-
rock Mine
Kerr-McGee Church-
_— _l. UJ __ n_a._ L 1 _
y

i

3


i


i

3

1


3

1
24-Hr.
8-Hr.
Grab

24-Hr.


8-Hr.


24-Hr.

24-Hr.

Grab


24-Hr.

Grab
Comp.
Comp.


Comp.


Comp.


Comp.
,
Comp.




Comp.



Flow
By TSS SO,,
Weir or X
Gage
None

Calculate X
from com-
pany meters
None X X


Company X X
Meter
Parshall X

None


Weir S X
Recorder
None
Analysis
Requirec
&
Cl Cu Fe Mo Na NH, & NO, Se V As Mn Co U-Nat
X XX

X

X XX


X X X X X


X X X X X

X XX

X


X XX

X
X

X

X


X


X

X

X


X

X
XXX X

X X

XX X X


X X X X X X


X X X X X X

XX X X

X X


XX X X

X X

Gross
Alpha
X

X

X


X


X

X

X


X

X

Ra,,c
X

X

X


X

,
X

x

x


X

x .
         rock Mine Potable
         Water Supply
]J  pH, conductivity and temperature will be measured periodically at all stations.
2/  Additional radlochemlcal (Th-230. pb-210. Po210, Th 228. Ra 228) will be required 1f gross alpha and radium 226 analysis Indicate these compounds are
    present.
I/  Two separe.te discharges, sample will be flow composited from both sources.
4/  Three 24-liour composite samples will be collected If discharging; If however, all water 1s being used for solutions mining (I.e.. recycled  to the mines)
    then one fi-hr. composite will be collected.

-------
                                                              TABLE  2      ,.
                                                        INDUSTRIAL  SAMPLING!/
Number
Station Days Type
Number Station Description Sampled Sample
9001


9003

9005

9007

9009

9011


9012


9013


9C14

9015
Kerr-McGee Ion E»-
change Tailings
• By-Pass
Kerr-McGee Sec.
30 H Mine Water
Kerr-McGee Sec.
19 Mine Water
Kerr-McGee Sec.
35 Mine Water
Kerr-McGee Sec.3/
36 Mine Water
Kerr-McGee Seepage
below tailings
pond
Kerr-McGee Mill
Potable Water
Supply
Kerr-McGee Sec.
35 Mine Potable
Water Supply
Ranchers Exploration
Johnny M. Mine Water
Ranchers Exploration
3


3

1

3

3

1


1


1


1

1
24-Hr. Comp.
'

24-Hr. Comp.

8-Hr. Comp.

24-Hr. Comp.

24-Hr. Comp.

8-Hr. Comp.
1

Grab


Grab


8-Hr. Comp.

Grab
Analysis Required^
Flow
By TSS SO,,
Parshall X


Gage 1n X
Control Str.
Bucket and X
Stopwatch
Rectangular X
Weir
Gage or Buc-X
ket & Stopwatch
None X X


None


None


Gage X

None
Cl Cu Fe Mo 'Na NH? & NO? Se V As Mn Co U-Nat
X XX


X XX

X XX

X XX

X XX

X X XXX


X


X


X XX

X
X


X

X

X

X

X


X


X


X

X
XX X X


XX X X

XX X X

XX X X

XX X X

X X X X X X


XX


X X


XX X X

X X
Gross
Alpha
X


X

X

X

X

X


X


X


X

X
,Ra226
X


X

X

X
.
X

X


X


X

•
X
•
X
Johnny M. Mine
Potable Water Supply

-------
                                                        TABLE 3    I/
                                                    STREAM STATIONS-17
                                  Number                                     Analysis  Required^/
Station                            Days      Type                                                          Gross
Number     Station Description    Sampled    Sample   C1    Mo    Na   .  NO^ & NHj  Se     V   Mn     U-Nat    Alpha
9030       San Mateo Creek at       3
           Highway 53 Bridge
           West of San Mateo

9032       San Mateo Creek up-      3
           stream of Puertecito
           Creek

9034       Puertecito Creek         3
           upstream of Partner's
           IX Plant

9036       Puertecito Creek         3
           Downstream from
           Kerr-McGee Mill

9038       Puertecito Creek         3
           Near the Mouth of
           Rancho del Puerto

,9040       San Mateo Creek          3
           at Highway 53 Bridge
           North of Grants

9050       Rio Puerco at Highway    3
           Bridge Downstream from
           United Nuclear and
           Kerr-McGee Mines

9052       Rio Puerco Upstream      3
           of Wingate Plant
Grab      XXX
Grab      XXX
Grab      XXX
Grab      XXX
Grab      XXX
Grab      XXX
Grab      XX     X
Grab      XXX
XXX      X
XXX      X
XXX      X
XXX      X
XXX      X
XXX      X
XXX      X
XXX      X

-------
                                                    TABLE 3, Page 2
Station
Number
Station Description
Number
 Days
Sampled
Type
Sample   Cl   Mo    Na
                                                                         Analysis  Required^/
                                                                                                Gross
N03 & NH3  Se    V   Mn    U-Nat   Alpha
9054       Rio Puerco at Highway    3        Grab
           666 Bridge, Gallup,
           N. Mex.

9060       Rio Paguate at Paguate   3/       Grab

9062       Rio Moquino Upstream     3/       Grab
           of Jackpile Mine

9064       Rio Paguate at           3/       Grab
           Jackpile Ford

9066       Rio Paguate at           37       Grab
           Paguate Reservoir
           Discharge

9068       Rio San Jose at          3/       Grab
           1-40 Bridge East
           of Laguna
                                            XXX

                                            XXX
                                                  XXX      X

                                                  XXX      X
                                                                X

                                                                X


                                                                X


                                                                X
                                            X

                                            X


                                            X


                                            X
V  pH, conductivity and temperature v/i 11  be measured periodically at all  stations.
2J  Additional radiochemical (Th-230, Pb-210, Po 210, Th-228, Ra-228) will be required if gross alpha and radium 226
    analysis indicate these compounds are  present.
3/  This station will be sampled for 1 to  3 days if surface run-off occurs.

-------
                 PRESERVATIVES AND SAMPLE SIZE REQUIRED
Size of .Sample

1 liter (unfiltered)


1 liter (unfiltered)
125 ml (unfiltered)


2 1 (filtered)

8 1 (filtered)*
Preservative

Iced


5 ml HN03/1





40 mg HgCl2/l - Iced


5 ml HN03/1

5 ml Hcl/1
Parameter

IDS, TSS, Sulfate,
Chloride

Copper, iron, Moly,
Sodium, Silenum,
Vanadium, Arsenic,
Manganese, Cobalt,
Total Uranium

Nitrate + Nitrite,
Ammonia

Gross alpha

Dissolved Radium 226
Th-230, Pb-210, Po-210,
Th-228, Ra-228
*4 liters each to NFIC and ORP.

-------
        Appendix B





CHAIN OF CUSTODY PROCEDURES

-------
                      CHAIN OF CUSTODY PROCEDURES


General:

The evidence gathering portion of a survey should be characterized by the
minimum number of samples required to give a fair representation of the
effluent or water body from which taken.   To the extent possible, the quan-
tity of samples and sample locations will be determined prior to the survey.

Chain of Custody procedures must be followed to maintain the documentation
necessary to trace sample possession from the time taken until  the evidence
is introduced into court.  A sample is in your "custody" if:

     1.  It is in your actual  physical possession, or

     2.  It is in your view, after being  in your physical  possession, or

     3.  It was in your physical possession and then you locked it up in
         a manner so that no one could tamper with it.

All survey participants will receive a copy of the survey study plan and will
be knowledgeable of its contents prior to the survey.  A pre-survey briefing
will  be held to re-appraise all  participants of the survey objectives, sample
locations and Chain of Custody procedures.  After all Chain of Custody samples
are collected, a de-briefing will  be held in the field  to determine adherence
to Chain of Custody procedures and whether additional evidence type samples
are required.

Sample Collection:

     1.  To the maximum extent achievable, as few people as possible should
         handle the sample.

     2.  Stream and effluent samples shall be obtained, using standard field
         sampling techniques.

     3.  Sample tags (Exhibit  I) shall be securely attached to the sample
         container at the time the complete sample is collected and shall
         contain, at a minimum,  the following information:   station number,
         station location,  date  taken, time taken, type of sample, sequence
         number (first sample  of the day  - sequence No. 1,  second sample -
         sequence No.  2,  etc.),  analyses  required and samplers.  The tags
         must be legibly  filled  out in ballpoint (waterproof ink).

-------
Chain of Custody Procedures (Continued)


Sample Collection  (Continued)

     4.  Blank samples shall also be taken with preservatives which will
         be analyzed by the laboratory to exclude the possibility of
         container or preservative contamination.

     5.  A pre-printed, bound Field Data Record logbook shall be main-
         tained to record field measurements and other pertinent infor-
         mation necessary to refresh the sampler's memory in the event
         he later  takes the stand to testify regarding his action's
         during the evidence gathering activity.  A separate set of field
         notebooks shall be maintained for each survey and stored in a
         safe place where they could be protected and accounted for at
         all times.  Standard formats (Exhibits II and III) have been
         established to minimize field entries and include the date, time,
         survey, type of samples taken, volume of each sample, type of
         analysis, sample numbers, preservatives, sample location and
         field measurements such as temperature, conductivity, DO, pH,
         flow and any other pertinent information or observations.  The
         entries shall be signed by the field sampler.  The preparation
         and conservation of the field logbooks during the survey will
         be the responsibility of the survey coordinator.  Once the
         survey is complete, field logs will be retained by the survey
         coordinator, or his designated representative, as a part of the
         permanent record.

     6.  The field sampler is responsible for the care and custody of the
         samples collected until properly dispatched to the receiving lab-
         oratory or turned over to an assigned custodian.  He must assure
         that each container is in his physical possession or in his view
         at all times, or locked in such a place and manner that no one can
         tamper with it.

     7.  Colored slides or photographs should be taken which would visually
         show the outfall  sample location and any water pollution to sub-
         stantiate any conclusions of the investigation.  Written documenta-
         tion on the back of the photo should include the signature of the
         photographer, time, date and site location.  Photographs of this
         nature, which may be used as evidence, shall also be handled
         recognizing Chain of Custody procedures to prevent alteration.

Transfer of Custody and Shipment:

     1.  Samples will be accompanied by a Chain of Custody Record which
         includes the name of the survey, samplers signatures, station
         number, station location, date, time, type of sample, sequence
         number, number of containers and analyses required (Fig. IV).
         When turning over the possession of samples, the transferor and
         transferee will sign, date and time the sheet.  This record sheet

-------
Chain of Custody Procedures (Continued)


         allows transfer of custody of a group of samples in the field,
         tu trie mobile lauOratOry Or "wrieTi Samples aTe ulspatcheu to the
         NFIC - Denver laboratory.  When transferring a portion of the
         samples identified on the sheet to the field mobile laboratory,
         the individual samples must be noted in the column with the
         signature of the person relinquishing the samples.  The field
         laboratory person receiving the samples will acknowledge receipt
         by signing in the appropriate column.

     2.  The field custodian or field sampler, if a custodian has not
         been assigned, will have the responsibility of properly pack-
         aging and dispatching samples to the proper laboratory for
         analysis.  The "Dispatch" portion of the Chain of Custody Record
         shall be properly filled out, dated, and signed.

     3.  Samples will  be properly packed in shipment containers such as
         ice chests, to avoid breakage.  The shipping containers will be
         padlocked for shipment to the receiving laboratory.

     4.  All packages will be accompanied by the Chain of Custody Record
         showing identification of the contents.  The original  will accom-
         pany the shipment, and a copy will be retained by the  survey
         coordinator.

     5.  If sent by mail, register the package with return receipt request-
         ed.  If sent by common carrier, a Government Bill of Lading should
         be obtained.   Receipts from post offices and bills of  lading will
         be retained as part of the permanent Chain of Custody  documentation.

     6.  If samples are delivered to the laboratory when appropriate person-
         nel are not there to receive them, the samples must be locked in
         a designated  area within the laboratory in a manner so that no
         one can tamper with them.  The same person must then return to the
         laboratory and unlock the samples and deliver custody  to the
         appropriate custodian.

Laboratory Custody Procedures:

     1.  The laboratory shall  designate a "sample custodian."  An alternate
         will  be designated in his absence.  In addition, the laboratory
         shall  set aside a "sample storage security area."  This should be
         a clean, dry, isolated room which can be securely locked from the
         outside.

     2.  All samples should be handled by the minimum possible  number of
         persons.

     3.   All incoming  samples  shall  be received only by the custodian, who
         will  indicate receipt  by signing the Chain of Custody  Record Sheet

-------
Chain of Custody Procedures (Continued)
         accompanying the samples and retaining the sheet as  permanent
         records.  Couriers picking up samples at the airport,  post
         office, etc. shall sign jointly with the laboratory  custodian.

     4.  Immediately upon receipt, the custodian will place the sample
         in the sample room, which will  be locked at all  times  except
         when samples are removed or replaced by the custodian.  To the
         maximum extent possible, only the custodian should be  permitted
         in the sample room.

     5.  The custodian shall ensure that heat-sensitive or light-sensitive
         samples, or other sample materials having unusual  physical
         characteristics, or requiring special handling,  are  properly
         stored and maintained.

     6.  Only the custodian will distribute samples to personnel  who are
         to perform tests.

     7.  The analyst will record in his  laboratory notebook or  analytical
         worksheet, identifying  information describing the sample,  the
         procedures performed and the results of the testing.   The  notes
         shall be dated and indicate who performed the tests.   The  notes
         shall be retained as a  permanent record in the laboratory  and
         should note any abnormalities which occurred during  the testing
         procedure.  In the event that the person who performed the tests
         is not available as a witness at time of trial,  the  government
         may be able to introduce the notes in evidence under the Federal
         Business Records Act.

     8.  Standard methods of laboratory analyses .shall be used  as described
         in the "Guidelines Establishing Test Procedures  for  Analysis of
         Pollutants," 38 F.R. 28758, October 16, 1973.  If laboratory
         personnel deviate from  standard procedures, they should be prepared
         to justify their decision during cross-examination.

     9.  Laboratory personnel are responsible for the care and  custody of
         the sample once it is handed over to them and should be prepared
         to testify that the sample was  in their possession and view or
         secured in the laboratory at all times from the  moment it  was
         received from the custodian until the tests were run.

    10.  Once the sample testing is completed, the unused portion of the
         sample together with all identifying tags and laboratory records,
         should be returned to the custodian.  The returned tagged  sample
         will be retained in the sample  room until it is  required for trial.
         Strip charts and other  documentation of work will  also be  turned
         over to the custodian.

-------
Chain of Custody Procedures (Continued)


    11.  Samples, tags and laboratory records  of  tests  may  be  destroyed
         only upon the order of the laboratory director, who will  first
         confer with the Chief, Enforcement Specialist  Office,  to  make
         certain that the information is  no longer  required or the samples
         have deteriorated.

-------
                        EXHIBIT I
/
o
EPA, NATIONAL FIELD INVESTIGATIONS CENTER • DENVER
Station No. Date Time Sequence No.
Station Location
	 BOD 	 Metals
Solids .. ., Oil and Grease
COD no
Nutrients 	 	 	 ,Q*hef

Samplers:
\
_, 	 ._,,,Gn»h
Comp

RemarKs/ Preservative:
                         FRONT
O
   ENVIRONMENTAL PROTECTION AGENCY
          OFFICE OF ENFORCEMENT
NATIONAL FIELD INVESTIGATIONS CENTER — DENVER
 BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
          DENVER, COLORADO 80225
                         BACK

-------
                                                                                   EXHIBIT II
FOR
SURVEY,  PHASE.
DATE
TYPE OF SAMPLE.
                                                                       ANALYSES    REQUIRED
STATION
NUMBER











STATION DESCRIPTION











TOTAL VOLUME











TYPE CONTAINER











PRESERVATIVE











NUTRIENTS I











O
0
CO











Q
O
U











U
o











V)
O
6
in
<
8











SUSPENDED SOLIDS |











ALKALINITY ]











O
O











»
a.











CONDUCTIVITY" |











TEMPERATURE' |











TOTAL COIIFORM |


•








FECAL COLIFORM ]











TURBIDITY |











UJ
V)
2
OC.
O
Q
<
O











METALS 1











D
<
CD









•

PESTICIDES 1











BQ
(X
UJ
X








•


TRACE ORGANICS |











PHENOL |











CYANIDE |











REMARKS

-------
                                        EXHIBIT III
                        Samplers:.
FIELD  DATA RECORD
STATION















NUMBER















DATE















TIME















TEMPERATURE
•C















CONDUCTIVITY
/x mhos. ''cm









•





pH
S.U.















D.O.
mg/1















Gage Hi.
or Flow
Ft. or CFS
















-------
               EXHIBIT  IV

  ENVIRONMENTAL PROTECTION AGENCY
           Office Of Enforcement
 NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
       Building 53, Box 25227, Denver Federal Center
               Denver, Colorado B0225

      CHAIN  OF  CUSTODY  RECORD
SURVEY
STATION
NUMBER












STATION LOCATION












DATE












Relinquished by: (signature)
Relinquished by: (Signature)
Relinquished by: (signature)
Relinquished by: (signature)
Dispatched by: (sionoru»j
Method of Shipment:
Date/
TIME












SAMPLERS: (Signature)
SAMPLE WE
Water
Comp.












Crab.












Ait












SEO.
NO.












NO. OF
CONTAINERS












ANALYSIS
REQUIRED





•






Received by: (signature)
Received by: (Signature)
Received by: (signal*,,)
Received by Mobile Laboratory for field
analysis: (signature)
Time
Received for Laboratory by:

Date/Time
Date/Time
Date/Time
Date/Time
Date/Time

Distribution:  Orig.—Accompany Shipment
           I Copy—Survey Coordinator Field Filet
                                                            OPO »»4-80»

-------
      Appendix C

CHEMICAL ANALYSES DATA
   NEW MEXICO SURVEY
 Feb.  26-Mar. 14, 1975

-------
                                                 CHEMICAL ANALYSES DATA
                                                    NEW MEXICO SURVEY
                                                  Feb. 26-Mar. 14, 1975
Sample No.
9001-30-0227
9001-30-0228
9001-30-0301
9003-30-0227
9003-30-0228
9003-30-0301
9005-30-0227
9007-30-0227
9007-30-0828
9007-30-0301
9009-30-0227
9009-30-0228
9009-30-0301
9010-30-0227
9010-30-0228
9010-30-0301
9011-01-0227
9012-01-0226
9013-01-0226
9014-30-0228
9016-30-0227
9016-30-0228
9016-30-0301
9017-01-0226
9018-30-0227
9018-30-0228
9018-30-0301
9019-30-0228
9021-30-0228
9023-30-0304
9023-30-0305
Station Description
KM I-X TAILINGS BY-PASS
KM I-X TAILINGS BY-PASS
KM I-X TAILINGS By-PASS
KM SEC 30W MINE WATER
KM SEC 30W MINE WATER
KM SEC 30W MINE WATER
KM SEC 19 MINE WATER
KM SEC 35 MINE WATER
KM SEC 35 MINE WATER
KM SEC 35 MINE WATER
KM SEC 36 MINE WATER
KM SEC 36 MINE WATER
KM SEC 36 MINE WATER
KM SEC 36 MINE WATER
KM SEC 36 MINE WATER
KM SEC 36 MINE WATER
KM SEEPAGE BELOW T POND
KM POTABLE WATER SUP
KM SEC 35 WATER SUP
RE JOHNNY M MINE WATER
UNC I-X DISCHARGE
UNC I-X DISCHARGE
UNC I-X DISCHARGE
UNC POTABLE WATER SUP
UN-HP I-X DISCHARGE
UN-HP I-X DISCHARGE
UN-HP I-X DISCHARGE
UN-HP T PILE DECANT
ANAC INJ WELL FEED
UNC CHURCHROCK MINE D
UNC CHURCHROCK MINE D

Dis. Grossct
Analyse
±95%CL
s Performed
Dis. Ra-226
±95«C1
(pCi/1)
600
490
430
1300
1400
1400
72
3000
2400
2800
570
630
850
580
510
580
144000
510
3000
20
1600
2300
1400
1500
760
770
970
29000
62500
730
840
60
60
50
100
100
100
19
100 -
100
100
60
60
70
70
60
60
3000
60
150
10
100
100
100
100
70
70
70
1000
- 1300
60
70
149
148
157
174
161
154
9.3
32
52
69
113
178
101
59
72
.65
65
0.54
43
1.6
14.3
39
39
23.5
111
101
111
52
53
19.8
22.9
1
1
1
1
1
1
0.1
1
1
1
1
1 .
1
1
1
1
1
0.02
1
0.1
0.4
1
1
0.5
2
2
1
1
1
0.5
0.5
Total U
(mg/i )
4.2
2.0
1.3
1.3
6.1
6.7
0.23
17
14
26
2.6
3.4
3.0
2.5
2.3
2.3
160
_
-
0.12
6.6
11
5.9
_
2.3
3.0
5.8
150
. 130
7.6
6.5
t  Sample numbers are presented by station number-sequenoe-date

-------
Sample No.
9023-30-0306
9023-01-0314
9024-01-0303
9025-30-0304
9025-30-0305
9025-30-0306
9026-01-0303
9036-01-0226
9036-01-0227
9036-01-0228
9038-01-0226
9038-01-0224
9038-01-0225
9040-01-0226
9050-01-0303
9050-01-0304
9050-01-0305
9052-01-0303
9052-01-0304
9052-01-0305
9054-01-0303
9054-01-0304
9054-01-0305
9060-01-0228
9062-01-0228
9064-01-0228
9066-01-0228
9068-01-0228
9080-01-0304
9081-01-0304
Station Description Date
UNC CHURCHROCK MINE D
UNC CHURCHROCK MINE D
UNC CHURCHROCK POTABLE WATER SUP
KM CHURCHROCK MINE DIS
KM CHURCHROCK MINE DIS
KM CHURCHROCK MINE DIS
KM CHURCHROCK H POTABLE WIS
PUERTECITO CK DS KM
PUERTECITO CK DS KM
PUERTECITO CK DS KM
PUERTECITO CK G> RAN D PUERTO
PUERTECITO CK G> RAN D PUERTO
PUERTECITO CK G> RAN D PUERTO
SAN MATED CK AT HWY 53
RIO PUERCO DS.UN & KM
RIO PUERCO DS UN & KM
RIO PUERCO DS UN & KM
RIO PUERCO US WINGATE
RIO PUERCO US WINGATE
RIO PUERCO US WINGATE
RIO PUERCO G> HWY 666
RIO PUERCO @ HWY 666
RIO PUERCO @ HWY 666
RIO PAGUATE 
-------
Sample No. Station Description Date
9082-01-0305 UNC CHURCHROCK POT WS
@ SOWERS TR
9101-01-0224
9102-01-0224
9103-01-0225
9104-01-0225
9105-01-0225
9106-01-0225
9107-01-0225
9108-01-0225
9109-01-0225
9110-01-0225
9111-01-0225
9112-01-0225 GRANTS POTABLE
9113-01-0226
9114-01-0226
9115-01-0226
9116-01-0226
9117-01-0227 MONITOR, ANAC.
9118-01-0227
9119-01-0227
9120-01-0227
9121-01-0227
9123-01-0227
9123-01-0228
9124-01-0228
9125-01-0228
9126-01-0228
9127-01-0228
9128-01-0228
9129-01-0228
9130-01-0301
9131-01-0301
9132-01-0301
9133-01-0302

Dis. Grossa

1110

9.
<3f
7
13
140
12
2500
47
39.

-------
Sample No. Station Description
9134-01-0303
9135-01-0303
9136-01-0303
9137-01-0303
9138-01-0303
9139-01-0305
9140-01-0305
9141-01-0305
9142-01-0305
9143-01-0305
9201-01-0226
9202-01-0226
9203-01-0226
9204-01-0226
9205-01-0226
9206-01-0226
9207-01-0227
9208-01-0227
9209-01-0227
9210-01-0227
9211-01-0227
9212-01-0303
9213-01-0303
9214-01-0303..
921 5-01 -0303TT
9216-01-0303
9217-01-0303
9218-01-0303
9219-01-0303
9220-01-0305
9221-01-0305

Dis. Grossa
Date
8
400
22
10
6
14
6
3
9
14
110
86
33
8
170
56
410
49
<2f
45
<3f
T 12000
8
14
104
45
70
20
67
12
17
A n a 1 y s
±95«CL

11
70
16
9
. 8
11
10
7
9
9
40
31
15
13
40
25
120
35
10
29
15
3000
32
34
37
25
38
24
42
10
10
e s P e r f o
Dis. Ra-226
(pCi/1)
0.24
1.92
0.27
0.68
0.64
0.22
0.10
0.12
0.16
0.83
3.6
0.30
0.07
0.14
0.18
0.60
1.15
4.0
1.95
0.26
0.20
4.9
6.6
1.18
2.5
0.64
0.94
0.34
0.59
0.12
0.56
r m e d
±95%C1 Total U
(mg/1)
0.01 0.04
0.04 2.6
0.02
0.03
0.02
0.01
0.01
0.01 0.02
0.01
0.04
0.1 1.0
0.02
0.01
0.01
0.01
0.02
0.03
0.1
0.04
0.02
0.01
0.1
0.1
0.03
0.2
0.02
0.03
0.02
0.02
0.01
0.02

-------


Sample No.
9222-01-0305
9223-01-0305
9224-01-0305
9225-01-0305
9230-01-0228
9231-01-0228
9232-01 -0228
9233-01-0228
t .Minimum
tt Groaa a't

Dis. Grossa
Station Description Date
2
. . .. 	 4
24
12.
<2f
10
18
2
detectable concentration
Ipha sample used for radium determination
A n a 1 y s
±95*CL

9
9
12
15
6
10
13
4


e s P e r f o
D1s. Ra-226
(PC1/1)
0.57
0.37
0.13
0.29
0.31
1.7
3.7
0.18


r m e d
±952C1

0.02
0.02
0.01
0.01
0.02
0.05
0.08
0.02



Total U
(mg/1)

_
-
_
_
_
0.02
0.04



-------
   Sample No.
Station Description
Date
                                                                   Analyses   Performed
                                                              Cu
                                                        Fe
                                        As
                                                                                 mg/1
               Co
9011-30-0227
9012-01-0226
9013-01-0226
9017-01-0226
9019-38-0228
9021-30-0228
9024-01-0303
9026-01-0303
                                         1.9
                          1,500
                                         0.1
                                         0.5
                           0.22
                           200
 1.1
<0.05
<0.05
<0.05
 3.0
 0.15
<0.05
<0.05
0.94
0.10
0.62

-------
Sample No.
9001-30-0227
9001-30-0228
9001-30-0301
9003-30-0227
9003-30-0228
9003-30-0301
9005-30-0227
9007-30-0227
9007-30-0228
9007-30-0301
9009-30-0227
9009-30-0228
9009-30-0301
9010-30-0227
9010-30-0228
9010-30-0301
9011-30-0227
9012-01-0226
9013-01-0226
9014-30-0228
9016-30-0227
9016-30-0228
9016-30-0301
9017-01-0226
9018-30-0227
9018-30-0228
9018-30-0301
9019-30-0228
9021-30-0228
9023-30-0304
9023-30-0305
9023-30-0306
9023-01-0314
9024-01-0303
Station Description Date
KM I-X TAILINGS BYPASS
KM I-X TAILINGS BYPASS
KM I-X TAILINGS BYPASS
. KM Sec 30W MINE WATER
KM Sec 30W MINE WATER
KM Sec 30W MINE WATER
KM Sec 19 MINE WATER
KM Sec 35 MINE WATER
KM Sec 35 MINE WATER
KM Sec 35 MINE WATER
KM Sec 36 MINE WATER
KM Sec 36 MINE WATER
KM Sec 36 MINE WATER
KM Sec 36E MINE WATER
KM Sec 36E MINE WATER
KM Sec 36E MINE WATER
KM SEEPAGE BELOW T POND
' KM POTABLE WATER SUP
KM Sec 35 WATER SUP
RE JOHNNY M MINE WATER
UNC I-X DISCHARGE
UNC I-X DISCHARGE
UNC I-X DISCHARGE
UNC POTABLE WATER SUP
UN-HP I-X DISCHARGE
UN-HP I-X DISCHARGE
UN-HP I-X DISCHARGE
UN-HP T PILE DECANT
ANAC INJ WELL FEED
UNC CHURCHROCK MINE D
UNC CHURCHROCK MINE D
UNC CHURCHROCK MINE D
UNC CHURCHROCK MINE D
UNC CHURCHROCK POTABLE WATER SUP

Mo

2.5
2.3
2.4
2.8
2.6
2.6
0.6
5.2
5.0
4.7
0.3
0.3
0.3
0.2
0.5
0.3
11
3.3
8.2
0.3
4.4
4.4
4.4
6.0
1.3
1.5
1.3
70
0.2
0.2
0.2
0.1
0.2
1.9
Anal
Na

180
180
180
160
160
• 160
120
190
200
210
190
190
180
170
170
170
1,500
-
_
60
310
360
360
_
140
140
140
4,300
1,200
100
100
90
90
-
y s e s P e
Se
mg/1
0.06
0.03
0.07
0.03
0.04
0.03
<0.01
0.08
0.08
0.04
0.01
<0.01
0.01
<0.01
0.03
0.01
0.70
0.05
0.02
<0.01
0.11
0.12
0.02
0.11
0.33
0.33
0.30
0.92
0.03
0.06
0.06
<0.01
0.05
0.06
r f o
V

0.7
1.0
1.0
0.8
0.7
0.7
0.6
0.6
0.7
1.0
1.0
0.8
0.8
0.8
0.6
0.4
5.6
-
-
<0.3
<0.3
0.4
0.5
-
0.4
<0.3
0.5
6.8
6.3
0.5
0.4
0.4
0.7
-
r m e d
Mn

0.03
0.03
0.03
0.15
0.18
0.17
0.03
0.09
0.04
0.06
0.12
0.10
0.12
0.10
0.08
0.08
120
-
_
0.01
0.22
0.18
0.28
• -
0.05
0.05
0.04
<0.01
340
0.05
0.06
0.07
0.18
-

-------
Sample No.
9025-30-0304
9025-30-0305
9025-30-0306
9026-01-0303
9036-01-0226
9036-01-0227
9036-01-0228
9038-01-0226
9038-01-0227
9038-01-0028
9040-01-0226
9050-01-0303
9050-01-0304
9050-01-0305
9052-01-0303
9052-01-0304
9052-01-0305
9054-01-0303
9054-01-0304
9054-01-0305
9060-01-0228
9062-01-0228
9064-01-0228
9066-01-0228
9068-01-0228
9080-01-0304
9081-01-0304
9082-01-0305
9101-01-0224
9102-01-0224
9103-01-0225
9104-01-0225
9105-01-0225
9106-01-0225
Station Description Date
KM CHURCHROCK MINE DIS
KM CHURCHROCK MINE DIS
KM CHURCHROCK MINE DIS
KM CHURCHROCK MINE POTABLE WATER SUP
PUERTECITO CK DS KM
PUERTECITO CK DS KM
PUERTECITO CK DS KM
PUERTECITO CK G> RAN d PUERTO
PUERTECITO CK @ RAN d PUERTO
PUERTECITO CK (? RAN d PUERTO
SAN MATED CK 9 HWY 53
RIO PUERCO DS UN & KM
RIO PUERCO DS UN & KM
RIO PUERCO DS UN & KM
RIO PUERCO US WINGATE
RIO PUERCO US WINGATE
RIO PUERCO US WINGATE
RIO PUERCO @ HWY 666
RIO PUERCO G> HWY 666
RIO PUERCO G> HWY 666
RIO PAGUATE P PAGUATE
RIO MOQUINO
RIO PAGUATE @ JACKPILE FORD
RIO PAG G> PAG RES DIS
RIO SAN JOS.£
KM Sec 36 3000 DRIFT
KM Sec 36 0900 DRIFT
UNC CHURCHROCK POT WS @ SOWERS TR

G WILCOX - MURRAY ACRES





Mo

0.2
0.2
0.2
1.4
1.4
1.5
1.5
2.1
0.3
1.5
1.3
0.5
0.3
0.3
0.2
0.2
0.2
0.1
0.2
0.2
<0. 1
0.2
0.2
0.2
0.1
0.1
0.4
<0.1






Ana
Na

90
100
100
_
180
180
180
160
130
130
130
110
100
100
100
90
90
90
90
90
30
70
120
160
230
220
260
100






lysis P
Se
mg/1
0.01
0.01
0.01
0.01
0.13
0.16
0.16
0.07
0.04
0.01
0.02
0.07
0.03
0.03
0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.05
<0.01
<0.01
0.01
<0.01
0.06
_
1.06
_
_
_
-
e r f o
V

0.7
0.8
0.9
_
1.0
0.8
0.6
0.5
1.9
0.8
<0.3
0.5
0.6
0.6
0.9
0.5
0.3
0.3
0.6
0.6
0.6
1.8
0.5
0.6
<0.3
<0.3
<0.3
0.6
_
<0.3
-
_
-
-
r m e d
Mn

0.07
0.08
0.10
_
0.25
0.24
0.26
0.08
0.13
0.11
1.8
1.9
0.19
0.19
1.7
0.61
1.1
0.12
2.1
2.0
0.11
0.15
0.28
0.14
0.09
0.02
0.06
0.03







-------
Sample No. Station Description Date
9107-01-0225 C WORTHEN. BROADVIEW ACRES
9108-01-0225
9109-01-0225
9110-01-0225
9111-01-0225
9112-01-0225
9113-01-0226 C MEADOR - BROADVIEW ACRES
9114-01-0226
9115-01-0226
9116-01-0226
9117-01-0227
9118-01-0227
9119-01-0227
9120-01-0227
9121-01-0227
9122-01-0227
9123-01-0228
9124-01-0228
9125-01-0228
9126-01-0228
9127-01-0228
9128-01-0228
9129-01-0228
9130-01-0301
9131-01-0301
9132-01-0301 MARCUS WINDMILL
9133-01-0302
9134-01-0303
9135-01-0303 UNHP WELL P
9136-01-0303
9137-01-0303
9138-01-0303
9139-01-0305
9140-01-0305
Analysis P
Mo Na Se
mg/1
1.06





0.20



.0.01
0.01
<0.01
0.01
o.ol

0.01

_
_
_

0.02

_
0.13

• 
-------
Sample No.
9141-01-0305
9142-01-0305
9143-01-0305
9201-01-0226
9202-01-0226
9203-01-0226
9204-01-0226
9205-01-0226
9206-01-0226
9207-01-0227
9208-01-0227
9209-01-0227
9210-01-0227
9211-01-0227
9212-01-0303
9213-01-0303:
9214-01-0303
9215-01-0303
9216-01-0303
9217-01-0303
9218-01-0303
9219-01-0303
9220-01-0305
9221-01-0305
9222-01-0305
9223-01-0305
9224-01-0305
9225-01-0305
9230-01-0228
9231-01-0228
9232-01-0228
9233-01-0228
Analysis P
Station Description Date Mo Na Se
mg/1
<0.01
<0.01
_
<0.01
_

-
-
.
<0.01
06 KM 43 14N, 9W Sec 32 0.29
n.oi
'
<0.01
-
<0.01
0.02
<0.01
-
.
-
0.01
'
0.01
-
<0.01
.
-
<0.01
'
<0.01
<0.01
erformed
V Mn

<0.3
<0.3
-
<0.3
_
. -
-
-
_
0.4
0.8
<0.3
-
0.5
_
0.6
<0.3
<0.3
-
-
-
<0.3
_
<0.3
-.
<0.3
-
-
<0.3
-
<0.3
0.3

-------
Sample No. Station Description
Date

TSS
A n a 1 y
so4
ses Perfor
Cl
NH3f
m e d
N02 + N03f
-.•-,.< mg/1
9001
9003

9005
9007

.'•'

9009



9010



9011

9012
9013
9014

9016



9017
9018



KERR-MCGEE I-X TAILINGS BYPASS
KERR-MCGEE Sec 30W MINE WATER

KERR-MCGEE Sec 19 MINE MATER
KERR-MCGEE Sec 35 MINE WATER



KERR-MCGEE Sec 36 W MINE WATER



KERR-MCGEE Sec 36 E MINE WATER



KERR-MCGEE SEEPAGE BELOW
TAILINGS POND '
KERR-MCGEE POTABLE WATER SUPPLY
KERR-MCGEE Sec 35 '/ATER SUPPLY
RANCHERS EXPL JOHNNY M MINE
WATER '
UNITED NUCLEAR CORP 1-X DISCHG



UNC POTABLE WATER SUPPLY
UNC-HP I-X DISCHARGE



Feb.
Feb.
Feb.
Mar.
Feb.
Feb.
Feb.
Mar.
Feb.
Feb.
Feb.
Feb.
Mar.
Feb.
Feb.
Feb.
Mar.
Feb.
Feb.
Feb."
Mar.
Feb.
Feb.
Feb.
Feb.
Feb.

Feb.
Feb.
Feb.
Mar.
Feb.
Feb.
Feb.
Feb.
Mar.
26
27
28
1
26
27
28
1
27
26
27
28
1
26
27
28
1
26
27
28
1
27
27
26
26
28

26
27
28
1
26
26
27
28
1
16
31
29
26
23
17
16
_
120
93
86
_
36
44
33
-
32
29
27
COMP 38
GRAB 48
-
.
7

_
5
7
3.

_
7
16
7
-
_
_
_
_
_
_
_
13
13
13
_
14
17
14
2,200
2,200

_
' 6.1

_
-.•:_•
_'•
-_
\ '
_
_
_
-
45
68
20
52
49
53
7.9
_
9;4
7.6
8.4
_
_
_
_
_
_

-'
15,000
16,000
-'
_
_

_
190
200
190

_
49
49
49
0.06
0.06
0.05
0.19
0.21
0.18
_
0.13
0.11
0.15
0.06
-
0.07
0.04
0.04
_
0.04
0.03
1.8
.
•-
460
0.13
0.18
_

0.07
0.04
0.01
_
0.08
0.05
0.06
0.10
—
0.88
0.79
0.90
1.3
1.2
0.94
_
1.4
0.22
0.39
0.44
-
0.30
0.21
0.26
_
0.34
0.26
0.28
-
-
16
1.0
0.32
_

0.28
0.07
0.06
.
0.06
2.1
2.1
2.2
-
t  Grab Samples

-------
Analyses Per
Sample No. Station Description
Date
TSS S04 Cl
N
for
H3f
m e d
N02 +

N03f
mg/1
9019
9021

9023




9024
9025



9026
9036


9038


9040
9050


9052


9054


9068
9062
9064
9066
9068
UNC-HP TAILINGS PILE DECANT
ANACONDA CO INJECTION WELL FEED

UN CHURCHROCK MINE DISCHARGE




UNC POTABLE WATER SUPPLY
KM CHURCHROCK MINE DISCHARGE



KM CHURCHROCK MINE POTABLE WS
PUERTECITO CREEK


PUERTECITO CREEK


SAN MATED CREEK
RIO PUERCO 9 HWY BRIDGE


RIO PUERCO UPSTREAM OF WINGATE
PLANK

RIO PUERCO @ HWY 666


RIO-PAGUATE
RIO MOQUINO
RIO PAGUATE
RIO PAGUATE
RIO SAN JOSE
Feb.
Feb.
Feb.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Feb.
Feb.
Feb.
Feb.
Feb.
28
27
28
3
4 '
5
6
14
3
3
4
5
6
3
26
27
28
26
27
28
26
3
4
5
3
4
5
3
4
5
28
28
28
28
28
5 4,300 .1.5
4,900
3 - 65
_
33 5.2
47 4.5
71 5.0
320
_
_ • -
38 0
45 0.5
58 3.2
_ _
72
83
71
42
48
48
39
5.9
3.8
3.8
6.9
6.8
6.5
23
20
17
0.6
8.3
2.0
15
154
4.
4
69
-
0.
0.
_
0.
-
0.
0.
0.
-
0.
0.
0.
0.
0.
0.
0.
• 0.
-















04
03

07.

05
03
06

07
02
38
40
26
10
13
11















4.
7.
-
0.
0.
-
0.
-
0.
0.
0.
-
0.
0.
2.
1.
2.
0.
0.
0.
-














4
4

23
24

20

25
34
45

79
42
3
8
9
22
06
25















t  Grab Samples

-------
Sample No. Station Description
Anal
Date TDS . S04

yses Perfo
Cl NH3
mg/1
r m e d
N02 + N03

9101       MT TAYLOR MILL WORKS
           OLD RTE 66
9102       G WILCOX - MURRAY ACRES
9103       Q CONNERLY - ZUNI TRAILER PARK
9104       T SIMPSON - MURRAY ACRES
9105       SCHWAGERTY - MURRAY ACRES
9106       J PITMAN - BROADVIEW ACRES
9107       C WORTHEN - BROADVIEW ACRES
9108       PITNEY - MURRAY ACRES
9109       T A CHAPMAN - MURRAY ACRES
9110       1-X WATER HOLIDAY INN - GRANTS
9111       C&E CONCRETE - GRANTS
9112       GRANTS CITY HALL-CITY WATER SUP
9113       C MEADOR - BROADVIEW ACRES
9114       BELL - TRAILER PARK
9115       COWELL - SE OF ANACONDA
9116       MILAN WELL #1 CITY WATER
9117       ANACONDA - MONITOR WELL
9118       ANACONDA - WELL 2
9119       ANACONDA - WELL 4
9120       ANACONDA - MEXICAN CAMP
9121       ANACONDA - GERRYHILL Sec 5
9122       ANACONDA - NORTH WELL
9123       ANACONDA - ENGINEERS' WELL
9124       ANACONDA - BEF.RYHILL HOUSE
9125       ANACONDA - LOS BLUEWATER
9126       ANACONDA - ROUNDY
9127       ANACONDA - FRED FREAS
9128       ANACONDA - LEROY CHAPMAN
9129       ANACONDA - JACK FREAS
9130       N MARQUEZ - HOUSE WELL
9131       C SANDOVAL - WINDMILL
9132       N MARQUEZ - WINDMILL
9133       G ENYV\RT - GRANTS
Feb.  24
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Mar.
Mar.
Mar.
Mar.
24
25
25
25
25
25
25
25
25
26
26
26
26
26
26
27
29
27
27
27
27
28
28
28
28
28
28
28
1
1
1
2
 780

2,300
 880
1,400
1,300
1,300
3,800
2,200
1,300
 430
 560
 730
1,600
 970
1,100
 500
2,300
1,900
 880
 490
2,000
1,900
 960
 940
1,000
1,100
 540
 490
 780
 720
 660
2,200
1,600
25

180
 33
 37
 46
 39
260
110
9.5
 55
 30
 32
120
 34
6.2
 14
 11
270
 42
 10
4.2
4.2
 61
 65
 12
110
 18
 18
 54
4.8
 27
"43
 50
 0.04

 0.01
<0.01
<0.01
<0.01
<0.01
 0.01
 0.01
 0.01
 0.01
 0.05
 0.02
 0.01
<0.01
 0.02
 0.02
 0.03
 0.64
 0.13
 0.04
 0.14
 0.08
 0.09
 0.05
 0.05
 0.04
 0.03
 0.03
 0.04
 0.04
 0.06
 0.22
 0.26
4.2

5.5
6.2
0.08
1.00
0.33
14
3.3
2.5
0.11
3.4
0.47
2.9
0.08
3.9
1.6
1.5
9.0
5.7
0.73
0.05.
1.3
3.20
0.80
0.95
6.5
0.03
1.4
2.5
0.06
1.2
24
0.97

-------
Analyses Performed
Sample No
Station Description
Date
TDS S04 Cl
NH3
N02 + N03
mg/1
9134
9135
9136
9137
9138
9139
9140
9141
9142
9143
9201
9202
9203
9204
9205
9206
9207
9208
9209
9210
9211
9212
9213
9214
9215
9216
9217
9218
9219
9220
9221
UN HP SUPPLY WELL 2
UN HP WELL D
UN HP SUPPLY WELL 1
ERWIN WELL - GALLUP
BOARDMAN TRAILER PARK - GALLUP
G HASSLER - GALLUP
DIXIE WELL - GALLUP
CHURCHROCK VILLAGE
WHITE WELL - GALLUP
TOGAY WELL - GALLUP
PHIL HARRIS (WILCOXSON) KM 46
COUNTY LINE STOCK TANK KM 52
NAVAHO WIND MILL KM 45
INGERSOLL RAND KM 49
BINGHAM (RAGLAND) KM 47
MARQUEZ (RAGLAND) KM 63
KM-S-12
KM-43
KM- 44
KM-51
KM- 48
KM SEEPAGE RETURN
KM B-2
KM 36-2
KM 46
KM 47
KM 50
KM 51
KM 52
HARDGROUND FLATS WELL CRKM 2
E PUERCO R WELL CRKM 11
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Feb.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
Mar.
3
3
3
5
5
5
5
5
5
5
26
26
26
26
26
26
27
27
27
27
27
3
3
3
3
3
3
3
3
5
5
1,600
4,500
2,000
740
930
880
1,500
720
620
340
1,900
2,100
400
2,200
2,000
1,900
14,000
7,800
2,700
6,300
4,100
36,000
8,900
9,100
3,200
2,600
4,700
4,800
6,700
850
340
0.2
340
<0.2
14
<0.2
98
<0.2
0.5
630
14
23
56
6.8
36
40
34
3,100
38
17
44
31
3,100
3,400
1,700
100
74
470
61
1 ,300
0.2
14
0.03
1.0
0.07
0.09
0.50
0.02
0.30
0.50
0.01
0.02
0.14
0.06
0.02
0.05
0.04
0.05
0.50
NS
0.66
0.30
0.80
590
0.12
2.9
10
0.80
9.1
0.16
0.08
0.03
0.04
0.42
2.6
0.28
0.02
1.2
27
0.16
0.18
0.02
8.0
0.09
14
4.0
18
4.7
44
0.04
NS
11
79
1.3
12
0.25
8.0
2.0
2.6
16
0.40
1.3
0.28
14

-------

Sample No

Station Description



Date

Ana
1 y s e s
P e r f
TDS S04 Cl
NH
o r
3
m e
N02
d
+ N03
mg/1
9222
9223
9224
9225
9230
9231
9232

9233
PUERCO WELL CRKM 16
PIPELINE ROAD WELL CRK M
NOSEROCK WELL CRKM 3
NORTHEAST PIPELINE WELL
ANACONDA JACKPILE WELL 4
ANACONDA JACKPILE WELL P
ANACONDA JACKPILE WELL -
SHOP
PUGUATE MUNICIPAL WELL

5

CRK M10

10
NEW


Mar.
Mar.
Mar.
Mar.
Feb.
Feb.
Feb.

Feb.
5
5
5
5
28
28
28

28
1,600
880
980
2,300
540
1,200
1,400

340
-<0
<0
<0
8.
•
-------
          Appendix D

           SELENIUM
EPA WATER QUALITY CRITERIA 1972

-------
                                                SELENIUM4
 • The toxicity of selenium resembles that of arsenic and
 can, if exposure is sufficient, cause death. Acute selenium
 toxicity is characterized by nervousness, vomiting, cough,
 dyspnea, convulsions,  abdominal  pain, diarrhea,  hypo-
 tension, and respiratory failure. Chronic exposure leads to
 marked pallor, red staining  of  lingers, teeth and  hair,
 debility, depression, epistaxis, gastrointestinal disturbances,
 dermatitis,  and irritation  of  the  nose  and throat.  Both
 acute and chronic exposure can cause odor on the breath
 similar to garlic (The Merck Index of Chemicals and Drugs
 1968}.1" The  only documented case of selenium toxicity
 from a water source, uncomplicated with selenium in the
 diet, concerned a three-month exposure  to well water con-
 taining 9 mg/1 (Death  1962).IM
  Although previous evidence suggested that selenium was
 carcinogenic (Fitzhugh et  al. 1944),ln  these observations
 have not been borne  out  by  subsequent data (Volganev
and  Tschenkes 1967).*"  In  recent years,  selenium  has
 become recognized as a dietary essential in a number of
species (Schwarz I960,"1 Nesheim and Scott 1961,"« Old-
field et al. 1963'").
  Elemental selenium  is highly insoluble and requires oxi-
dation to selenite or selenate before appreciable quantities
 appear in water (Lakin and Davidson  1967).'" There is
 evidence that  this reaction  is catalyzed  by  certain  soil
 bacteria (Olson 1967)."°
  No systematic investigation of the forms of  selenium in
excessive concentrations in drinking water sources has been
carried out. However, from what is known of the solubilities
of the various compounds of selenium, the principal in-
organic  compounds of selenium would be selenite  and
selenate. The ratio of their individual  occurrences would
depend primarily on pH.  Organic forms  of selenium oc-
curred in sclcnifcrous  soils and had sufficient  mobility in
an aqueous environment to be preferentially absorbed over
selenate in certain  plants (Hamilton and Bcath 1964)."4
 However, the extent to which these compounds might occur
 in source waters is essentially unknown. Toxicologic exami-
 nation of plant sources of selenium revealed that selenium
 present in seleniferous grains was more toxic than inorganic
 selenium added to the diet (Franke and Potter 1935).'"
   Intake of selenium from foods in seleniferous areas (Smith
 1941),"1 may range from 600 to 6,340 pg/day, which ap-
 proach estimated levels related to symptoms  of selenium
 toxicity in man  based  on urine samples (Smith et  al.
 1936,"1 Smith and Wcstfall 1937'"). If data on selenium
 in foods (Morris and Lcvander 1970)'" are applied to the
 average consumption  of foods (U.S. Department of Agri-
 culture, Agriculture Research Service, Consumer and Food
 Economics Research Division  1967),"* the normal dietary
 intake of selenium is about 200 pg/day.
  If it is assumed that two liters of water are ingested per
day, a 0.01 mg/1 concentration of total  selenium would
increase the normal  total dietary intake  by 10 per cent
 (20 pg/day). Considering the range of selenium  in food
associated with symptoms of toxicity in man, this would
provide a safety factor of from 2.7 to 29. A  serious weakness
in these calculations is that their validity depends on  an
assumption of equivalent toxicity of selenium in food and
water, in  spite  of the fact that a considerable portion of
selenium associated with plants is  in  an organic form.
Adequate toxicological data that specifically examine the
organic and the  inorganic  selenium compounds are  not
available.

Recommendation
  Because the denned treatment process has little
or no effect  on removing selenium, and  because
there is a lack of data on its toxic effects on humans
when ingested  in water, it  is recommended that
public water supply sources contain  no more than
0.01 mg/1 selenium.
    Water Quality Criteria,  1972,  Environmental Protection Agency,  Washington,  B.C.

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                                   Technical Note
                                   ORP/LV-75-4
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

-------
This report has been reviewed by the Office of
Radiation Programs-Las Vegas Facility, Environmental
Protection Agency, and approved for publication.
Mention of trade names or commercial products does
not constitute endorsement or recommendation for
use.

-------
                        PREFACE
     The Office of Radiation Programs of the Environmental
Protection Agency carries out a national program designed
to evaluate population exposure to ionizing and non-ionizing
radiation and to promote development of controls necessary
to protect the public health and safety.

     Within the Office of Radiation Programs, the Las Vegas
Facility (ORP-LVF) conducts in-depth field studies of vari-
ous radiation sources (e.g., nuclear facilities, uranium
mill tailings, and phosphate mills) to provide technical
data for environmental impact statement reviews as well as
needed information on source characteristics, environmental
transport, critical pathways for population exposure, and
dose model validation.

     This report summarizes the results of the ground-water
study conducted by ORP-LVF during February and March 1975
in the Grants Mineral Belt area of New Mexico.  The final
technical report, "Ground-Water Ouality Impacts of Uranium
Mining and Milling in the Grants Mineral Belt, New Mexico",
will be published at a later date as EPA-520/6-75-013.

     Readers of this, report are encouraged to inform the
Office of Radiation Programs of any omissions or errors.
Comments or requests for further information are also invited.
                            Donald W. Hendricks
                            director, Office of
                          Radiation Programs, LVF
                           m

-------
                   TABLE OF CONTENTS

                                                        Page

PREFACE                                                 iii

TABLE OF CONTENTS                                         v

FIGURES                                                 vii

TABLES                                                   ix

PURPOSE OF STUDY                                          1

SUMMARY AND CONCLUSIONS                                   3

RECOMMENDATIONS                                          10

ADDITIONAL STUDIES REQUIRED                              11

AREAL DESCRIPTION                                        13

     Location and Description of Study Area              13
     Principal Industries                                15

GEOLOGY AND HYDROLOGY                                    17

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                              35
     United Nuclear-Homestake Partners Mill and
      Surrounding Area                                   45
     Ambrosia Lake Area                                  51
     Churchrock Area                                     55
     Jackpile-Paguate Area                               57

SIGNIFICANCE OF RADIOLOGICAL DATA                        59

     Regulations and Guidelines                          59
     Radium-226                                          60
     Other Radionuclides                                 63

REFERENCES CITED                                         67

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                        FIGURES
Figures                                               Page

  1.  Map of Northwestern New Mexico Showing
       General Location of Sampling Areas in
       the Grants Mineral Belt                          14
  2.  Generalized Structure Section from
       Bluewater to Ambrosia Lake                       18
  3.  The Anaconda Company Uranium Mill and
       Tailings Pond-Bluewater                          37
  4.  Radium and Nitrate Concentrations in
       Ground Water in the Grants-Bluewater Area        40
  5.  Summary of Waste Volumes Injected                 43
  6.  The United Nuclear-Homestake Partners
       Uranium Mill and Tailings Ponds-Milan            46
  7.  Radium, TDS and Chloride in Ground Water
       Near the United Nuclear-Homestake Partners
       Mill                                             48
  8.  Water Table Contours and Well Locations at
       the United Nuclear-Homestake Partners Mill
       Site                                             49
  9.  Kerr-McGee Nuclear Corporation                    52
 10.  Radium Concentrations in Ground Water in
       the Ambrosia Lake Area                           53
 11.  Radium Concentrations in Ground Water in
       the Churchrock-Gallup Area                       56
 12.  Radium Concentrations in Ground Water in
       the Paguate-Jackpile Area                        58
                           VII

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                         TABLES


Tables
  1.  Uranium Economy of New Mexico                     16
  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 Ground-Water Radionuclide
       Concentrations 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                 36
  7.  Locations with Radium-226 in Excess of the
       PHS Drinking Water Standard                      62
  8.  Radium and Gross Alpha Concentrations for
       Municipal Water Supplies                         62
  9.  Maximum Permissible Concentrations in Water       64
                            IX

-------
                    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 in the Grants Mineral Belt of New Mexico were unknown,
Whether a problem existed was questionable but worthy of
investigation because of the toxic nature of the effluents
and their persistence in the environment'.  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 loca-
tions and collection schedules were finalized after reviewing
company monitoring programs.  Study plans were prepared by
both ORP-LVF and NEIC defining study participants, responsi-
bilities, 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
monitoring networks, self-monitoring data, analytical pro-
cedures, and reporting requirements.

     4.  Determine the composition of potable waters at
uranium 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 objec-
tives were pursued by NEIC.

     Actual sample collection began in late February 1975
in the Ambrosia Lake-Bluewater area.  It proceeded to Paguate-
Jackpile and was finally completed in the Rallup-Churchrock
area in early March 1975.  Laboratory analyses for the trace
metals, gross alpha, and radium-226 were completed by NEIC.
The other radiological analyses were completed by the Environ-
mental Monitoring and Support Laboratory (EMSL), Las Vegas.
Radiometric analyses were assigned the highest priority at
each laboratory and were completed in July 1975.

-------
                SUMMARY AND CONCLUSIONS
TASK I:  Assess the Impacts of Waste Discharges from Uranium
         Mining and Milling on Ground Waters of the Grants
         Mineral Belt.
     1.  Ground water is the principal source of water supply
in the study area.  Extensive development of ground water
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 in the alluvium also occurs in
this area.  Principal ground-water development in the mining
areas at Ambrosia Lake, Jackpile-Paguate, and Churchrock 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 Gallup Sandstone using well
fields located east and west of the urban area and 11 kilo-
meters north of the city.

     2.  In proximity to the mines and mills and adjacent to
the principal surface drainage courses, shallow ground-water
contamination results from the infiltration of (1) effluents
from mill tailings ponds, (2) mine drainage water that is
first introduced to settling lagoons and thence to water-
courses, and (3) discharge (tailings) from ion exchange plants.
In the case of the Anaconda mill, seepage from the tailings
ponds and migration of wastes injected into deep bedrock
formations are observed in the San Andres Limestone and.in the
alluvium, both of which are potable aquifers.  With the
exception of seepage from the Kerr-McGee Section 36 mine in
Ambrosia Lake, significant amounts of wastewater from the
remaining mines and mills probably does not return to
known bedrock aquifers.  Deterioration of water quality
results from conventional underground mining as a result ,
of penetration or disruption of the ore body.  The most
dramatic changes are greatly increased dissolved radium
and uranium.  Induced movement of naturally saline ground
water into potable aquifers is also likely but undocumented.
Similarly, the ground-water quality impacts of solution
(in situ) mining are unknown.

     3.  The Grants, Milan, Laguna, and Bluewater municipal
water supplies have not been adversely affected by uranium
mining and milling operations to date.  For the Grants and
Milan areas, chemical data from 1962 to the present indicate
that near the Anaconda mill some observation wells have

-------
increased slightly in total dissolved solids, sulfate,
chloride and gross alpha but domestic wells have generally
remained unchanged.  Projections made in 1957 of gross
nitrate deterioration of ground water have not been sub-
stantiated by subsequent data.  Of the municipal supply
wells in the study area, the Bluewater well bears addi-
tional monitoring because of its location relative to the
Anaconda tailings ponds.

     4.  Contamination of the Gallup municipal ground-water
supply by surface flows, consisting mostly of mine drainage,
has not occurred and is extremely unlikely because of geo-
logic conditions in the well field and the depth to produc-
tive aquifers.  Another well field north of the City will,
in no way, be affected by the drainage.

     5.  With the exception of the areas south and southwest
of the United Nuclear-Homestake Partners mill, widespread
ground-water contamination from mining and milling was  not
observed in the study area.  Throughout the study area  wide-
spread contamination of ground water with radium was not
observed despite concentrations of as much as 178 pCi/1 in
mine and mill effluents.  Radium removal is pronounced,
probably due to sorptive capacity of soils in the area.
In the vicinity of the Anaconda mill, radium and nitrate
concentrations in the alluvial aquifer decline with distance
from the tailings ponds, but neither parameter exceeds  drink-
ing water standards.

     6.  Ground water in at least part of the shallow aquifer
developed for domestic water supply downgradient from the
United Nuclear-Homestake Partners mill is contaminated  with
selenium.  Alternative water supplies can be developed  using
deep wells completed in the Chinle Formation or in the  San
Andres Limestone.  Potential well sites are located in  the
developments affected and in the adjacent area.  A third
alternative includes connecting to the Milan municipal  sys-
tem.  Further evaluations are necessary to determine the
best course of action.

     7.  Mining practices, per se, have an adverse effect
on natural water quality.  Initial penetration and disrup-
tion of the ore body in the Churchrock mining area increased
the concentration of dissolved radium in water pumped from
the mines from 0.05 - 0.62 pCi/1 to over 8 pCi/1.  According
to company data, the concentration rose to over 75 pCi/1, or
at least 75 times the natural concentration, in the two-year
period during which the mine was being developed.  The  pat-
tern of increasing radium with time, seen in Ambrosia Lake,
is being repeated.  Ground-water inflow via long holes

-------
in the Kerr-McGee Section 36 mine contains a relatively low
concentration of dissolved radium-226.  Therefore, much of
the radium loading of mine effluent is apparently a result
of leaching of ore solids remaining from mucking and trans-
port within the mine.  In some cases this could be reduced
by improved mining practices, such as provision of drainage
channels along haulage drifts.

     8.  Company data show that seepage from the Anaconda
tailings pond at Bluewater averages 183 million liters/year
(48.3 million gallons) for 1973 and 1974.  The average volume
injected for the same time period was 348 million liters/year
(91.9 million gallons).  Therefore, approximately one-third
of the total effluent volume remaining after evaporation
(531 million liters/year) enters the shallow aquifer which
is a source of potable and irrigation water in Bluewater
Valley.  From 1960 through 1974, seepage alone introduced
0.41 curies of radium to the shallow potable aquifer.
Adequate monitoring of the movement of the seepage and the
injected wastes is not underway.

     9.  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
monitoring wells, completed in the overlying San Andres
Limestone and/or the Glorieta Sandstone, show a trend of
increasing chloride and uranium with time.  Positive cor-
relations of water quality fluctuations with the volumes
of waste injected are a further indication of upward move-
ment.  The absence of monitoring wells in the injection
zone is a major deficiency in the data collection program.

     10.  The maximum concentration of radium observed in
shallow ground water adjacent to the Kerr-McGee mill at
Ambrosia Lake was 6.6 pCi/1.  According to company data,
seepage from the tailings ponds occurs at the rate of
491 million liters/year (130 million gallons/year) .  This
is 29 percent of the influent to the "evaporation ponds"
and attests to their poor performance in this regard.
Radium and gross alpha in the seepage are 56 pCi/1 and
112,000-144,000 pCi/1, respectively.  Total radium intro-
duced to the ground water to date is estimated at 0.7
curies.  Wells completed in bedrock and in alluvium, and
located near watercourses containing mine drainage and seep-
age from tailings ponds, contain elevated levels of TDS,
ammonia, and nitrate.  One well, which contained 1.0 pCi/1
in 1962, now is contaminated with 3.7 pCi/1 of radium.
Sorption or bio-uptake of radium is pronounced; hence, con-
centrations now in ground water are not representative of
ultimate concentrations.

-------
     11.  Water-quality data from 11 wells over a 200-square
kilometer area in the Puerco River and South Fork Puerco
River drainage basins reveal essentially no noticeable
increase in concentrations of radionuclides or common
inorganic 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 essentially unchanged from that in areas unaffected
by mine drainage.  None of the samples contained more than
recommended maximum concentrations for radium-226, natural
uranium, thorium-230, thorium-232, or polonium-210 in drink-
ing water.  However, the paucity of sampling points and the
absence of historical data make the foregoing conclusion a
conditional one, particularly in the reaches of the Puerco
River within approximately 10 kilometers downstream of the
mines.

     12.  Four wells 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 maximum permis-
sible concentrations (MPC) for the other common isotopes of
uranium, thorium, and polonium.  Ground 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 are expected.

     13.  Of the 71 ground-water samples collected for this
study, a total of 6 had radium-226 in excess of the 3 pCi/1
PHS Drinking Water Standard.  Two of the 6 involved potable
water supplies.  One containing 3.6 pCi/1 serves a single
family and is located adjacent to Arroyo del Puerto and
downgradient from the mines and mills in Ambrosia Lake.
The second contains 3.7 pCi/1 and is used as a potable supply
for the labor force in the new shop at the Jackpile Mine.

     14.  The highest isotopic uranium and thorium, and
polonium-210 contents for any potable ground-water supplies
sampled in the study area are less than 1.72% of the total
radionuclide population guide - MPC as established in NMEIA
regulations.

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     15.  The lowest observed concentration (background
levels) in ground water are summarized as follows:

Radionuclides         Range (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- 0.051                0.028
Thorium-232           0.010- 0.024                0.015
U-Natural             14 - 68                     35

     16.  The uranium isotopes (uranium 234, 235 and 238) are
the main contributors to the gross alpha result; however, in
several determinations, gross alpha underestimated the activity
present from natural uranium.

     17.  No correlation was found between gross alpha content
of 15 pCi/1 (including uranium isotopes) and a radium-226
content of 5 pCi/1.

     18.  It is doubtful that the gross alpha determination
can even be used as an indicator of the presence of other
alpha emitters (e.g., U-natural and polonium-210).  Further-
more, since the gross alpha results have such large error
terms, no meaningful determination of percentage of radio-
nuclides to gross alpha can be implied.

     19.  Gross alpha determinations also failed to indicate
the possible presence of lead-210 (primarily a beta emitter)
which, because of the lower MFC of 33 pCi/1, may be a sig-
nificant contributor to the radiological health hazard
evaluation of any potable water supply.

     20.  Radium-226 in ground water is a good radiochemical
indicator of wastewater contamination from mines and mills.
Due to the low maximum permissible concentration, it also
provides a good means for evaluating health effects.
Selenium and nitrate also indicated the presence of mill
effluents in ground water.  Polonium-210, thorium-230 and
thorium-232 concentrations 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
ground-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 II:  Evaluate the Adequacy of Company Water Quality
          Monitoring Networks, Self-Monitoring Data,
          Analytical Procedures, and Reporting Requirements.


     1.  Company sponsored ground-water monitoring programs
range from inadequate to nonexistent.  Actual monitoring
networks are deficient in that sampling points are usually
poorly located or of inadequate depth/location 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, implementation,
and level of investment.

     2.  Company radiochemical analytical methods are inade-
quate for measuring environmental levels of radionuclides
and have high minimum detectable activities and large error
terms.  Incomplete analysis of radionuclide contents pre-
vails.  Few data are reported on other naturally occurring
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 routinely 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 contamina-
tion to proceed unnoticed.  On-site wells constructed speci-
fically for monitoring are generally not completed to provide
representative hydraulic and water quality data for the
aquifer most likely to be affected.

     5.  Proven geophysical and geohydrologic techniques to
formulate environmental monitoring networks are apparently
not used.  Such techniques can assist in specifying sampling

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frequencies and provide the basis for adjustment of monitor-
ing and operational practices to mitigate adverse impacts
on ground water.

     6.  Monitoring the effects of the Jackpile and Paguate
open pit mines on ground-water quality is nonexistent
despite the magnitude of these operations.  Drainage water
within the pits has contained as much as 190 pCi/1 of radium,
Two wells, used for potable supply and completed in the ore
body, contain elevated levels of radium, 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
to determine seepage input to ground water for the various
tailings disposal operations is not evident.  For the
Ananconda Company, the method utilized has not been altered
in 14 years.  For Kerr-McGee, overland flow presents a
potential threat to the structural integrity of the
retention dams.  At the United Nuclear-Homestake Partners
Mill, no quantitative estimates of seepage are available.

     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 incom-
plete and disorganized.  No interpretive summary or review-
type reports utilizing the monitoring data reported by
industry are available from either the State or the U.S.
Atomic Energy Commission files now held by the State.
Liberal mill licensing conditions with respect to ground-
water monitoring and water-quality impacts were initially
established by the USAEC.  Subsequently, there has been
essentially no review, in any critical sense, of company
operations with respect to ground-water contamination.
The uranium mining and milling industry has not been pressed
to monitor and protect ground-water resources.  The limited
efforts put forth by industry to date have largely not been
reviewed by regulatory agencies at the State and Federal
levels.

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                     RECOMMENDATIONS
Action Required

     1.  Improved industry-sponsored monitoring programs
should be implemented and the data made available to
State and Federal regulatory agencies.   Programs should
be designed to detect likely hydraulic  and water quality
impacts from uranium milling and mining (open pit,
underground, in situ).   Revamped programs, specifically
developed by joint concurrence of industry and regulatory
agencies, should be incorporated in licenses, where
possible.  Licenses should specify minimal radiochemical
analytical methods for detecting specific radionuclides
as well as requirements for participation 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.  It is
essential that the programs developed,  as well as the
data and interpretive reports prepared  therefrom, be
critically reviewed by the State to meet continuing regu-
latory responsibilities.

    - 2.  Because seepage from the Anaconda and Kerr-McGee
tailings ponds constitutes a significant portion of the
inflow to the ponds, it is recommended  that seepage con-
trol measures be adopted.  According to company records,
such seepage presently totals some 674  million liters
per year.  Water budget analyses of the United Nuclear-
Homestake Partners tailings pond should be made to deter-
mine how much seepage is occurring, and thereby contributing
to contamination of the shallow aquifer locally developed
for domestic water supplies in two adjacent privately
owned housing developments.

     3.  Improved mining practices should be adopted to
reduce the amount of radium leached from ore solids by
ground water present in operating mines.
                           10

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              ADDITIONAL STUDIES REQUIRED


     1.  Studies should be immediately initiated to verify
whether the source of ground-water contamination in the
Broadview Acres and Murray Acres subdivision is from the
nearby uranium mill.  An improved monitoring program should
be developed to predict contaminant migration and to
provide the basis for subsequent enforcement action.
Necessary action should be taken to provide potable water
for the affected area.  Studies should be undertaken to
determine the means to prevent continuing contamination.

     2.  With regard to the Anaconda waste injection
program, all available chemical and water level data for
pre-injection and post-injection periods should be evalu-
ated 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 their abundance in the injected fluid.  Limited
chemical data indicating migration of waste beyond the
injection interval necessitate that a thorough re-evaluation
be made of the long term adequacy of this method of waste dis-
posal.  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 and possibly lead-210 are
appearing in the aquifers above the injection zone.  The
Anaconda Company should also evaluate the current loss of
uranium resources to the subsurface through their current
disposal technique.

     3.  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
Wilcoxson (P. Harris), Bingham, Marquez, and County Line
Stock Tanks wells are of principal concern.

     4.  Water-quality data from the newly completed
monitoring wells peripheral to the Kerr-McGee mill should
be cross-checked using non-industry laboratories to deter-
mine the extent of contamination in the Dakota Sandstone.

     5.  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
                           11

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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
stages.  Site specific investigations are necessary to
determine the hydraulic and water quality responses to
dewatering and solution mining.

     6.  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.  It
is recommended that concentrations of trace metals should
also be measured.
                           12

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                      AREAL DESCRIPTION
Location and Description of Study Area

    The Grants Mineral Belt, located in the southeastern
part of McKinley County and the north-central portion of
Valencia County, is a rectangular shaped area in north-
western 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 1)
(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 physiographically sepa-
rated, 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 (Dutton, 1885).  Nearly all the streams in the
area are intermittent and flow only during periods of in-
tense precipitation (Cooper and John, 1968; Gordon, 1961).

    The Grants Mineral Belt of northwestern New Mexico
is within the Navajo 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 predominant landmarks of the Datil
section (Fenneman, 1931).
                             13

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                                                   RIO ARRIBA
   SAN JUAN  McKinley Co.
                             Ground water
                             sampling area
                                                   Los Alamos
JValencia Co.
    NEW MEXICO
....	i
                                           Existing or proposed
                                           mill locations
                                                              SANDOVAL
       Ambrosia Lake


    Thoreau
Fort
Wingate
                                                                   SANTA FE
               Grants
                 McCartys
                                                     ALBUQUERQUE
                                                     BERNALILLO


                                                    os Lunas
        VALENCIA
                O  1O 2O  3O 4O  5O km
                                                                TORRANCE
                          SOCORRO

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     Prior to uranium mining and the discharge of mine and
mill effluents, there were no perennial streams in south-
eastern McKinley County.  In this period, the arroyos and
wash channels and other natural depressions such as Ambro-
sia Lake, Casamero Lake and Smith Lake contained water only
after heavy rains.  There are intermittent ponds and lakes
in the volcanic craters of the Cebolleta Mountains.  The
only perennial source of water is part of Bluewater Lake at
the junction of Azul and Bluewater Creeks (Cooper and John,
1968).
Principal Industries

     Until relatively recently, the principal industries
in McKinley and Valencia Counties of northwestern Mew Mexico
were farming and ranching.  Tourism and small-scale logging
were secondary.  The land is mostly used for livestock graz-
ing, while some irrigated farming is done 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 widespread
throughout the Grants Mineral Belt, the uranium mining and
milling industry predominates.  What was a rural agricul-
tural economy has partly become an industrial one.  The
figures on Table 1 indicate the importance of the uranium
industry in the economy of New Mexico, especially the north-
west 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 construction
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 (University
of New Mexico, Bureau of Business Research, 1972).
                           15

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                                                      Table   1
   Year end ing
   June 30,  1962
       1970
       1974
                                            Uranium  Economy of New Mexico
Year
1956
1959
Production
(tons or metric tons)
1,105,000 tons
3,269,826 tons
Value
$ 24,086,000
$ 53,463,000
Reserve
4! mi 1
55 mi 1
1 1 ion tons
1 1 ion tons
Percent of U. S.
Total Reserve
66 2/3$
63$
I 1,574,000 tons
 7,527 metric tons
      U308
McKinley Co. only
  $ 57,431,391
  $ 69,970,000
  $102,060,000
42%
O\
                             «I974 Production Capacity of Uranium Mills  in New Mexico
                   Company
                             Plant  Location
                                      Nominal Capacity Tons
                                           Ore Per Day
      The Anaconda Co.

      Kerr-McGee Nuclear Corp.

      United Nuclear-Homestake Partners
                            Grants,  New  Mexico

                            Grants,  New  Mexico

                            Grants,  New  Mexico
                                             3,000

                                             7,000

                                             3,500
                                                                                Total           13,500
                                                                                Total  U.S.      28,550
                                                                                Percentage  in
                                                                                N.M.                47$
      References:  Midwest  Research  Institute  (1975)
                   Health & Social Services, State of New Mexico  (1975)
                   WASH  1174-74, The Nuclear Industry, USAEC  (1974)

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                    GEOLOGY AND HYDROLOGY
    The principal bedrock and alluvial stratigraphic units
in the Grants Mineral Belt range in age from Pennsylvanian
to Recent (Hilpert, 1963).  Figure 2, which is a general-
ized geologic cross section 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 weather-
ing.  The concave slopes and bottom lands form on less
resistant units, typically shales and thin-bedded sandstones
interbedded  with shale.  Although geographically less exten-
sive, lava beds and limestone strata also function as cap-
rocks .

    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 constitutes 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 the shallow, unconfined aquifer.   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 inter-
bedded basalt layers (Dinwiddie et al., 1966).

    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
                             17

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0)
8 2500
ra
01
a 2400
§

E 2300
o 2200
2  2100
oj


.0
1
.3!
LU
       sw
                                                               N 56.6° E-
                                                                                                                 NE
                                                                                                              POINT LOOKOin
                                                                                                              SANDSTONE
                                                                                                              AND MENEFEE
                                                                                                              FORMATION
                    Tailings  Anaconda
                     Pond  Disposal Well
 p \
MADERA
LIMESTONE
SAN ANDRES. GLORIETA.
    ABO, AND YESO
     FORMATIONS
                                 WINGATE SANDSTONE AND CHINLE FORMATION
                                                                                           DAKOTA SANDSTONE AND MANGOS SHALE
   300-

   200-

   100

     0
Altitude (m)

      SCALE


       Distance (km)
          1
                     Figure  2t    Heneralized  Structure  Section  from  Bluewater
                                     to  Ambrosia  Lake

-------
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,
chief of which is the Westwater Canyon Member of the Mor-
rison Formation.  To a lesser extent, the overlying strata
such as the Dakota Formation are also affected by dewatering.

     The impacts of ground-water pumping and discharge to
surface water courses are varied.  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 meter per month due to dewatering at the
United Nuclear and Kerr-McGee mines.  Discharge of the mine
water has transformed 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.

     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 Forma-
tions has increased radioactivity and salinity levels therein.
Strictly speaking, these are considered aquifers despite the
mineralized water naturally present.  Should the contamination
                           19

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move upward into potable aquifers and extend too far later-
ally, injection would likely be terminated.  Widespread
contamination of the shallow aquifer adjacent to the tail-
ings 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 un-
known.  It is unlikely that seepage returns to the deep, bed-
rock 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
(Westwater Canyon Member).  A possible exception to this
occurs in the vicinity of the Kerr-McGee Section 36 mine where
drainage enters a nearby holding pond and seeps .out the bottom
at a rate of about 400 liters/minute.  Seepage may move along
the underlying San Mateo fault and enter potable aquifers.
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 con-
taminated to varying degrees by industrial effluents.  The
long-term infiltration of radium-laden water along the stream
channel of San Mateo Creek, both above and below the conflu-
ence with Arroyo del Puerto, may adversely affect the quality
of shallow ground water now developed for stock watering.

     The potential for future problems of water availability
for ore processing in Ambrosia Lake has been cited by
Cooper and John (1968).  jn 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.
                           20

-------
     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 municipal wells along the Rio
Puerco, particularly on the east and west fringes of Gallup,
is unlikely.

   INDUSTRY-SPONSORED WATER QUALITY MONITORING PROGRAMS

Introduction

     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.
                           21

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     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 was 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, delib-
erate 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

     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-Homestake Partners
                           22

-------
The latter's monitoring of a single well at the mill site 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.
Therefore, any changes due to disruption of natural conditions
cannot be assessed.  In the case of the Anaconda waste manage-
ment program, for example, there is no information concerning
pre-disposal concentrations of stable and radioactive chemical
species in overlying potable reservoirs 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 surrounding region.  This
is laudable with respect to current water use, but not espe-
cially 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 monitoring points.  With the exception
of a portion of the Kerr-McGee on-site net, wells specifically
constructed for monitoring are commonly too few in number and
improperly situated with respect to depth and (or) location.
Compared to the multi-million dollar uranium industry, pro-
ducing multi-billion liters of toxic effluents, the ground-
water sampling and monitoring programs represent minimal ef-
forts 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 scrutinized.  In other instances, expected adverse im-
pacts of seepage on shallow ground water have not been found
because they have either not been sought or have been sought
in unlikely locations.

     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,
                           23

-------
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 isotopic 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 doubtful that the various company laboratories
have the analytical capabilities to accurately analyze for
environmental levels of the common radionuclides associated
with uranium mining and milling.

    During February 11 and 1.2, 1975, a brief review of avail-
able 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:
                    i
    1.  The available records are disorganized and incomplete.
A complete copy of each company's radioactive material license
and supporting correspondence could not be. found.  Radiological
monitoring data reports were often missing or incomplete.  At-
tachments and maps referred to-,ih correspondence in the records
could not be found.

    2.  Except for the license condition requiring monitoring
data related to the Anaconda waste injection program, USAEC
licenses for the other uranium mills have never specifically
required the establishment of ground-water monitoring net-
works or reporting of any data pertaining to such monitoring.
(Some limited programs have, however, been diescribed in
company license applications •)

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

    4.  Almost no information has been reported by the com-
panies describing their radiochemical analytical procedures,
quality assurance programs, or the accuracy and precision
of reported results.
                              24

-------
     5.  Review by State and Federal regulatory agencies of
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 seep-
age and total pond 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 cataloged 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.
                           25

-------
               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 constitu-
ents, were determined for 71 wells in the study area.  These
data are presented in Tables 2 through 5.  In certain loca-
tions, these data relate to surface water phenomena such as
natural streams or to manmade features, foremost of which are
tailings disposal ponds or streams originating as mine dis-
charge.

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

     Table 5 summarizes ground-water data from the present
study and categorizes the data according to study area and
aquifer.  These reported values are the lowest concentra-
tions 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 activities in this area.  For the most part, the
values shown for bedrock aquifers are not from the princi-
pal ore-producing formations, namely the Westwater Canyon
Member of the Morrison Formation.  In the Grants-Bluewater
area, "bedrock" refers primarily to the San Andres Lime-
stone, 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
                           26

-------
                                                                             Table  2
                                                      Sampling Point Locations and  Gross  Chemical  Data  for
                                                  Ground-water Samples from the Grants m'neral lielt,  New  Mexico
                                                                        STATIC
                                                                  WELL  WATER
                                                                                      SAMPLE
CONCENTRATION, ng/1
NUMBER DESCRIPTION
Paguate-Jackpile
9230 Well #4 (Anaconda Co.)
9231
9232
9233
Well P-10 (Anaconda Co.)
New Shop Well (Anac. Co.)
Paguate Municioal Well
LOCATION
T R S Q LAT7"
11 5 27 421
10 5 4 413
10 5 9 224
11 5 32 241
350909
350716
350653
350828
LONG.
1072054
1072214
1072152
1072302
DEPTH
(m)
210.
—
184.
iJ2.S
LEVEL
(n)

fii!e
--
Art.
DATE
MEAS.
2/75
2/75
—
2/75
POINT,
TYPE1

s>
3
3
DATE
SAMPLED2
2/2P
2/28
2/2«
2/28
WATER
USE3
PI
PI
PI
M
TEMP.
°C
17.4
36.1
13.6
15.2
pH
8.8
8.3
8.1
7.5
SP. COND
umhos/cm
lion
2500
2500
675
TDS
540.
1200!
1400.
340.
CL
<0.2
0.5
0.5
6.6
NH3
0.05
0.08
0.14
0.08
.NO*
as N
0.05
0.04
0.05
0.20
Grants-Bluewater
9021
91C1

9103
9111
9112

9115

11 IP
9117
9118
9119
9120
9121

9122
5123
"124
9125
9126
"127
9123
9129
Injection Well (Anac. Co.)
Mt. Taylor Mill Works
Old Rt. 66
C,. Connerly
CSE Concrete
Grants City Hall ,
Municipal water supply
Auro's Bar ft Motel ,
Cowell House
Milan Well #1
Monitor Well (Anac. Co.)
Well n (Anac. Co.)
Well *4 (Anac. Co.)
Mexican Camp
Eerryhill, Sec. 5
(Anac. Co.)
North Well (Ar3c. Co.)
Engineer's Hell
ferryhill House
LDS Church-Bluewater
Roundy House Veil
Fred Frees
Leroy Chapran
Jack Freas
12 10 8 314

11 10 5 442
11 10 9 221
11 10 22 341

11 10 26 244

12 11 24 334
11 10 21 221
12 1C 3 332
12 11 24 234
12 11 25 214
12 10 30 112

12 10 5 341
12 10 7 143
12 11 14 213
12 11 11 334
12 11 22 234
12 11 23 231
12 10 30 433
12 10 32 211
12 10 30 242
351649

351224
351212
350950

350914

351449
351029
351650
351527
351*36
351443

351813
351731
351643
351659
351521
351532
351347
351338
351424
1075519

1075422
H75331
1075257

1075117

1075718
1075333
1075518
1075648
107565n
1075617

1075512
1075611
1075301
1075323
1075859
1075300
1075552
1075450
1075530
547.4

58.5
37.2
36.6

fl/A

45.7
45.7
191.4
118.
69.
85.3

221.
76.2
35.1
45.7
71.2
91. t
41.1
41.1
48. P
72.2

—
24.4
24.4

N/A

—
16.5
58.3
"T.2
42.1
43. f-

74.9
53.1
26. S
37.1
?7.c
21.2
—
23.
32.5
4/59

--
?/75
2/75

--

--
in/47
3/60
5/72
5/72
2/47

I/ 5ft
10/55
2/75
P/FF
12/46
1/47
--
1/47
2/55
9

1
3
3

1

1
3
1
3
3
3

4
4
2
1
1
1
3
i
1
2/28

2/21
7/?l
2/26

?./?f

2/26
2/26
2/27
2/27
2/27
2/27

2/27
2/27
2/2P.
2/2P
2/2G
2/28
2/28
2/28
2/2F.
W

PI
P
PI

M

P
M
0
IP
IP
0

S
P
0
P
M
P
P
P
P


12.
12.
14.

11.

14.
17.
20.
18.5
17.
15.

20.
17.5
11.5
11.
t;
io!s
13.
11.
11.5


6.25
7.4
7.6

7.3

7.1
7.5
6.8
7.1
7.2
7.5

7."
7.4
7.T
7 .c
7.5
7.3
7.7
7.6
7.5


1050
1200
775

1000

1425
700
2900
2550
1225
720

2900
2200
lf 2C
1800
130n
1975
1025
950
1325


730.
880.
560.

730.

1100.
500.
2300 !
1900.
CSO.
49C.

2000.
1900.
95°.
940 !
1000.
lino.
540.
490.
7"0.
65.

25.
33.
30.

32.

6.2
14.
11.
270.
42.
10.

4.2
4.2
f.l.
65.
12.
110.
13.
13.
54.
69.0

0.04
<0.01
0.05

0.02

0.02
0.02
C.03
0.64
0.13
0.34

0.14
0 rjp
0.09
0.05
n.05
0.04
0.03
C.03
0.04
32.8

4.2
6.2
3.4

0.47

3.9
1.6
1.5
39.9
5.7
0.73

0.05
1.3
3.2
O.S
0.95
6.5
0.03
1.4
2.6
(Continued)

-------
                                                                                  (continued)
                                                                                    Table  2
                                                             Sampling Point Locations and uross Chemical Data for
                                                         nround-water Samples from the Grants Mineral Belt, New Mexico
CO
NUMBER DESCRIPTION
LOCATION
T R S Q LAT7~
LONG.
WELL
DEPTH
(m)
STATIC
WATER
LEVEL DATE
(m) MEAS.
SAMPLE
POINT DATE WATER TEMP
TYPE1 SAMPLED2 USE3 °C
CONCENTRATION, nig/1 ..„
PH
SP. COND.
umhos/cm TDS
CL
NH3
HUo
+MO 3
as n
United Nuclear-Homestake Partners
9102
9104
9105
9106
9107
9108
9109
9113
9114
9133
9134
9135
9136
G. Wilcox
T. Simpson
Schwagerty
J. Pitman
C. Horthen
Pitney
T. A. Chapman
C. Meador
Bell
G. Enyart
Well *?. (UNHP)
Well D (UNHP)
Well *1 (UNHP)
12 IT 27 442
12 10 21 444
12 10 34 224
12 10 35 332
12 1C 35 332
12 10 27 431
12 10 34 121
12 in 35 144
12 10 25 133
12 10 27 331
12 10 26 311
12 10 26 31.3
12 10 26 242
351410
351*03
351351
351345
351341
351406
351352
351336
351427
351408
351422
351417
351431
1075217
1075217
1075218
1075214
1075208
1075246
1075255
1075150
1075108
1075312
1075146
1075208
1075117
32.6
87 . 5
77.7
89.0
26^2
54.9
38.1
36.6
152.4
64.0
121.9
26. R
298.7

..
-.
—
5 r'
__
13.1
__
__
15.2
21.6
16.1
4n.8




2/75
__
?/75


3/75
5/56
3/75
5/58
•3
1
1
1
3
6
6
1
1
1
3
7
3
2/24
Z/25
2/25
2/25
2/25
2/25
2/2F
7/26
2/26
3/0?
1/03
1/03
3/03
P
P
P
P
P
P
P
P
P
P
pr
P
PI
14.
10.
11.
14-
14
14!
14.5
c .
17.
18.
15.
12.
18.
6.5
P &
7. "5
8.8
7.4
7.6
7.5
7.8
8.3
7.6
6.95
7.2
6.9
2850
2050
1950
1725
4000
2775
1700
2025
1475
3000
1600
3500
1 850
2300.
1100.
1 300 .
1300.
3800.
2200.
1300.
1600.
970.
1600.
1COO.
450"'.
2000.
130.
37.
46.
39.
260.
no.
9.5
120.
34.
50.
0.2
340.
<0.2
0.01
<0.01
<0.01
ROOO
7000
3 10n
6000
420Q
»8000
»8000
720.
660.
2200.

1900.
2100.
400.
2200.
2000.
1900.
14000.
7300.
2700.
6300.
4100.
36000.
8900.
4.8
27.
43.

23.
56.
6.8
36.
40.
34.
3100.
2.8
17.
44.
31.
310Q.
3400.
0.04
0.06
0.?2

0.14
C.06
0.02
0.05
0.04
0.0?
C.5C
NS
0.66
0.3C
0.°.°
590.
0.12
0.06
1.2
136.3

0.09
62
4.0
79.7
4.7
4.4
0.04
ftS
43. 7
350
1.3
53
O.ZE
        (Continued)

-------
                         (continued)
                           Table  2
    Sail pi ing Point Locations and Gross Chemical Data for
drounu-water Samples from the Grants Mineral Belt, New Mexico
NUMBER DESCRIPTION
Ambrosia Lake (Continued)
9214 KM-36-2
9215 KM-46
9216 -'KM-47
9217 KM-50
9218 KM-5-1
9219 KM-5-2
Gallup-Churchrock
9137 Erwin well
9138 • Boardman Trailer Park
9139 G. Hassler
9140 Dixie well
9141 Churchrock Village
9142 White well
9220 CRKM-2, Hardqround Flats
well
9221 CRKM-11, E. Puerco River
well (=Togay well, 9143)
9222 CRKM-16, Puerco well
9223 CRKM-5, Pipeline Rd well
9224 CRKM-3, Nose Rock well
9225 CRKM-10, N.E. Pipeline
well
Explanation
1 - Sampling Point
1 -outside faucet
,2-hand bailed
3-pumped (well head)
4rwindmill
5-mobile pump
6,- kitchen faucet
7-holding tank
8-wash room
STATIC
WELL WATER SAMPLE
LOCATION DEPTH LEVEL DATE POINT, DATE
T R S Q LAT. LONG. (m) (m) MEAS. TYPE1 SAMPLED

14 10 36 422
14 9 30 331
14 9 30 341
14 9 32 114
13 9 5 214
13 9 5 141

16 18 7 433
15 18 14 243
15 17 3 133
15 17 9 413
15 17 12 333
16 16 16 422
Navajo
Reservation

16 16 15 431
16 17 25 113
16 15 33 422
16 17 15 131
Navajo
Reservation

2 - Date Sampled
1Q75








352352 1075026 17.4 fn.l
352430 1075017 11..6 10.1
352430 1074959 in. 9 7.3
352414 1074901 16. f 14.0
352316 1074835 10.4 7.3
352311 1074856 10.4 6.0

353730 1084524 610. 221.0
353159 108*237 91.4 45.7
353242 1084008 91.4 4.6
353227 1083835 — 1.2
353222 1083553 65.6 —
353701 1083147 — 2.1

353958 1083404 189.6

353633 1083059 96.9 —
353533 1083551 42.7 7.04
353420 1083810 37.2 10.7
353709 1083720 207.3 31.4

354015 1082841 284.1 >SOOO
3250
31^0
5750
5000
>pnoo

1225
1450
1400
2400
1375
1000

1350

550
2200
1350
15^0

2650











9100.
3200.
2600.
4700.
4800.
6700.

740.
930.
880.
1500.
720.
620.

850.

340.
1600.
880.
980.

2300.










CL

1700.
100.
74.
470.
61.
1300.

14.
<0.2
98.
<0.2
0.5"
630.'.

0.

14.
0.
0.
0.

8.1










NH3

2 '.9
10.
0.80
9.1
0.16
0.08

0.09
0.50
0.02
0.30
' 0.50
0.01

0.03

0.04
34.
1.4
0.07

0.12










N02
as n
8.0
2.0
2.6
70.9
0.40
1.3

0.02
1.2
119.6
0.16
0.18.
0.02 ;

0.28

52
0.01
1.6
0.03

0.01










9-pre-injection filter discharge ...

-------
                               Table 3
                Selenium and Vanadium Concentrations
                   in  Selected Ground-water Samples '
NUMBER DESCRIPTION Se (mg/1)
United Nuclear-Homestake Partners
9102 G. Wilcox
9107 C. Worthen
9113 C. Meador
9134 Well #2 (UNHP)
9135 Well D (UHNP)
Grants Bluewater
9117 Monitor well (Anaconda)
9118 Well #2
9119 Well #4
9120 Mexican Camp
9121 Berryhill, Section 5
9123 Engineer's well
9129 Jack Freas
Ambrosia Lake
9132 N. Marquez windmill
9201 KM-46, P. Harris (Wilcoxson)
9207 KM-S-12
9208 KM-43
9209 KM-44
9211 KM-48
9213 KM-B-2
9214 KM-36-2
9215 KM-46
9219 KM-5-2
Gal lup-Churchrock
9138 Boardman Trailer Park
9140 Dixie well
9141 Churchrock Village
9142 White well
9221 CRKM-11, E. Puerco
9222 CRKM-16, Puerco well
Paguate-Jackpile
9230 Well #4
9232 New Shop well
923-3 Paguate Municipal well

1.06
1.06
0.20
<0.01
1.52

0.01
0.01
<0.01
<0.01
<0.01
0.01
0.02

.13
<0.01
<0.01
.29
.01
<0.1
<0.1
.02
<0.01
0.01

<0.01
<0.01
<0.01
<0.01
0.01
<0.01

<0.01
<0.01
0.01
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

< .3
< .3
0.4
0.8
<0.3
0.5
0.6
<0.3
<0.3
<0.3

<0.3
<0.3
<0.3
<0.3
<0.3
<0.3

<0.3
<0.3
<0.3
Analyzed by National Enforcement Investigations Center, Denver, Colorado,
                               30

-------
                         Table 4
Radiological  Data for Selected Ground-water Samples
            trar.tr; i.'inor.il. belt,  ,\.-:w Mexico
Location
ijmber Description
"aquat^-Jackoi 1»
3230-Usll ,M
9231-W311 P-10
9232-. tew S 10? Well
^.•JS-^auat;- Municipal !Vr:ll
Grants — Bluewater Area
90zi Injection /.el 1
3101 .-It. Taylor :•',! 1 1 ,'.crks
• Jlu -.t. 1.6
9103 v. Connerly
9111 C4E Concrete
3112 Grants City hi 1 1
9115 Cowel 1 House
9116 Mi Ian *ell No. 1
9117 r-'onitor net 1
Anaconda Corrpory
91 Is ,',el 1 No. 2
Anaconad Con-pan •/
) \ 1 9 we 1 1 .'Jo . 4
Anaconda Cor.p^ny
9120 i.fexica'n Carp
9121 serryhl 1 1 iecrk.n :;
5V22 North wel 1
9123 engineer's .'.el 1
9124 Berryni 1 1 nc^ie
9125 LDi Church — Bluewater
JI26 Kujndy 'Mouse
9127 Fred Freas
912c L. Cnapnan
"<125 JaCK. Freas
Gross
Alpha

< ?.0 i 5
10 ? 10
18 ' 13
2 t 4

62, 500*1, 3CG
9* 11

7* 10
7* 9
19* 13
7* 12
12* 10
130* 40

290* 50

12* 11

21* 12
12* i4
30* 17
''20* 13
16* 12
;.* 10
5* 9
10* 1C
11* 11
<1.6* 7
Ra-226
NEIC

0.31 f. .02
1.7 i .03
3.7 i .03
0.13 i .02

33 *1
0. 13* .01

C.09* .01
0.24* .01
0.«2± .0.?
0. 18* .01
0.14* .01
2.6 * . 1

0.50* .02 '

0.20* .01

C.^7* .02
6.3 * .1
0 .17* .01
0.26* .01
0 . 06 * . C 1
G. 22* ,01
C.ll* .01
0.21* .01
0.15* .01
0. 14* .01
EMSL

0.23 ±.095


0.10 -.072

27 *C.=»5




0.10* .098


2.6 * .30

0.21= .09

O.iS* .Cb9




0.36* .11



0.28* ..11

O.h7* .29
U-234






10,000*750







100* 7.7












^


U-235






420 =67 .







3.C* .;b















U-238






1,000*770







74* 5.7















U-nat.



0.02
0.04

130







0.56

1 .3
















14
27

Bfi.nnr







379

3cC













Th-230

< 0.029
< 0.015
< 0.016
-• 0.018

3200C±1200




-------
                                                                    (cont^ued)
                                                Radiological Data for Selected Ground-water  Samples1
                                                         Grants  Mineral Belt, New Mexico
Location
Number Description
I'nrwd Nuclear - Homestake P
9102-1. Wilcox
9104-T. Sinn-en
9105- Schwagert1/
9106-,). Pitman
9107-C. Wortien
9108 Pitney
9109-T. A. Chaoman
9113-C. "eadnr
9114 B?ll
9133-'. Cnvart
9134- We'll ^2 U'JHP
9135- Well 0 U.'JHP
9136- W?ll *1 UNHP
".' .L P^'3 i J Ljr^O
,-ijl \. i-'ar .ue^ r\.-uS5
5131 C. £anauv-j| A'incwill
i-IJ2 i.. ('-iar'.,jez i.' i ii 'Jrr, i 1 1
3.1 Ji P. narrij
.'2 32 2-Ounty Lirifc 27--JK 7ar>K
9203 );.,-vc:jo v;inc'';i 1 1
9i34 1 n-,ersol 1 har _
^IwiJ b i M^r.Oirn ; KM- 4 7
520c '-'idr^Lez ; ro'.-'23
>i07 K.'.'-5-12
l-zC-J. rU-43
3i39 rvV-44
92 1 : <:•:-:- 1
9^11 Ki.'-4c
•>z'^> Ki'i-oaopage i-.tsiurr,
.-21> KM---2
,-214 r-v-i-ie-i.
Gross
Alpha
artners
< 3 ± 13
13 i 14
140 i 30
12 ± 11
2500 ±200
47 ± 23
_ 39 ± 17
31' ± 17
42 ± 18
10 ± 12
3 ± 11
400 ± 70
22 ± 16

W o
1d± 1 J
< 1.0± 9
110± 40
G6± Jl
iii 15
8± 13
I7J± 4';
56: 2!;
410:; 12:
4^± 55
< 2. Or 10
45r 29
< -.;i 15
1 12,03013,300
ii 32
14± 34
Ra-226
NEIC

0.19 t .01
0.08 t .01
0.05 ± .01
0.05 ±'.01
0.72 ± .02
0.34 ± .02
0.13 .'. .01
0.17 ± .02
0.26 i .01
0.61 i .03
0.24 i .01
1.92 t .04
0.27 ± .02

C. 1 1 » .01
G.C!; i .01
0.31 i .02
5.6 i '. 1
C . 30 - . 02
c.o? - . :i
0. 14 ± .01
C . i 
<0.025

-------
                                                                                (continued)
                                                                                Table 4
                                                         Radiological  Datd for Selected  Cround-wntor

                                                                    Grants Mineral  Belt, New Mexico
O-i
Location
,;!mber Description

Ambrosia Lake (Continued)
32 IS KM-4c
92 1 6 i\M-4 7
9217 .-\l-i-30
9213 KM-5-1
92 1 9 KM-^-2
Gallup-Churchrock
5137-: >viiri •.•!<•: 11
llSS-Boardnan Trailer °ar<
3139-1. !!a3:;lc;r
91 40- Dixie /bll
9141-OhurchroCK Villaga
9142-'''hi t-? 'v2l 1
9143-Toqav '.•I3ll(-,an3 as 922'
9220-Hardqround Hats
'.•.'all-CRKM-2
9221-E.^rco P.ivor
Mil 1-CRKl-ll
9222 --^rco M?n Cc,K:i-15
""" ~>U-nR:<':-5?
9224- ;o-- ''.ock W--11 CP.KH-3
9225- i.?.. "incline Well
:?K"-in
Gross
Alpha


104i 37
45± 25
70- 38
20± 24
67± 42

10 ± 9
6 ± 3
14'± 11
6 - 10
3 i 7
9 •'- 9
) 14 t 9

12 i 10

17 ' 10
2 i 3
4 - 9
24 i 12

12 •.' 15
i. -.. • uc.'i!.''j:io;is •• cwu sijnii. couiiiii
Ra-226
NEIC


2.5 + .2
C.64 t .02
0.94 ± .03
0.34 ± .02
0.59 ± .02

0.63 ± .03
0.64 i .02
•0.22 i .01
0.11 ? .01
0.12 ± .01
0.1 -S •' .01
0.83 i .04

0.12 t .01

0.56 i .02
0.57 ± .02
0.37 i .or;
0.13 ' .01

0.29 .- .01
EMSL


2.7 i .30

0.72 i .16
Q.34 1.11
0.78 i .17




0.15 ± .OD2
0.26 ' .10
T.I? * .13
0.33 ± .12



0.21 .'. .093





U-234






12 t. .63




1.8 ± .16












iij error in pLi/1 . u-riatural reported'
U-235






0.27i .039




0.053^.022












U-238






6.7 ± .37




1.4 ' .14












as i.'ic,/l and in pLi/1, res]
U-nat.












0.02











>ective












14











iy.
Th-230


0.17 +.057
C.079i.C3>:
0.0i5-.035
<0.021

-------
                       Tvpical  Background Ground Water  Radionuclirle Concentrations  fpCi/l)  hv Geographic Arpa & Aauifer  '

                                                           ~r-iots-Blu<»'.v3t->r        i            |: IMP             j       Amuro'ia  Lak?
226Ra Bedrock
Alluvium
21 OPT C<_>rJrOCk
Al luvium
2307!- p,;.droci;
Alluvium
232Th B5:iroc:,
M luvi:im
0

-------
bedrock aquifers in the Churchrock mining area mostly include
the Dakota Sandstone.  In the Paguate-Jackpile area, three of
the four wells examined are in the Morrison Formation
(Jackpile Sandstone Member).
     Table 6 is a compilation of uranium, radium, and gross
     Table 6 is a compilation of 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 are intended
to show natural concentrations of these radionuclides.
Despite the wide variations,  radium rarely exceeds 10 pCi/1
and 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 associated with mining and
milling activity, may be evidence of degradation.

Bluewater-Mi Ian-Grants

     The relationship of the  Anaconda Company mill and
tailings pile to local geologic and cultural features is
shown in Figure 3.  Cultivated areas in the photograph  are
situated in Bluewater Valley  which contains the town of
Bluewater on the western edge.  The irregularly shaped
landforms northeast and east  of the mill are basalt lava
flows which are also the substrate for a portion of the
tailings ponds.  Also shown is the proximity of the San
Andres Limestone to the tailings ponds.  The light colored
areas in the tailings pond are composed of sand, whereas
the darker gray and black patterns indicate wet slimes  and
free water surface, respectively.

     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 mill.  It  is
unlikely that the United Nuclear-Homestake Partners mill
could adversely affect ground water in this area.

     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 migra-
tion of nitrate from the ponds (New Mexico Department of
Public Health, 1957).  Changes in the milling process greatly
                           35

-------
                                             Table 6

                                Summary of Reported Concentrations
      for  Radium,  Gross  Beta  and Natural  Uranium  in Ground Water  in
                                                      the  Grants  Mineral  Belt1
Loco
T K
9
12
12
12
12
13
13
13

15
14
14
14
14
14
14
14
14
14
14
14
14
14
14
15
17
17
17
17
17

23

1.

12
1 1
1 1
12
10
o
d
9

9
9
9
9
9
9
9
Q
9
9
9
9
9
9
10
12
12
ID
16
16
16

14

t ion
S Q
11
24
24
4
8
30
30
29

29
28
32
32
17
Id
28
29
30
32
32
34
36
36
24
17
20
35
55
35
35

3

Data


222
4
4
343
3
100
200
144

41
441
413
221
400
400
143
312
200
122
314
422
313
313
100
123
11
14
14
14
12

13

source Depfh Aquifer^
Paxton Spring Spring
Industrieil Wei 1
Anacondd Well (Injection)
bluewater Lake Sur
Wei 1
El Puso Natural Gas Co.
El Paso Natural Gas Co.
Westvdco Mineral Development
Co.
Mi ne Ur i tt
Wei 1
Wei 1
Mine Dr i ft
Kermac Nuclear Fuels Corp.
Kermac Nuclear Fuels Corp.
Kermac Nuclear Fuels Corp.
Ph i 1 1 ips Petroleum Co.
Kermac Nuclear Fuels Corp.
Homestake-Nei-,1 Mexico Partners
Homestake-New Mexico Partners
United Nuclear Company
United Nuclear Company
United Nuclear Company
Kennac Nuclear Fuels Corp.
Homestake-Sapin Partner
Crownpo i nt We 1 I 1
UNC-NE Churchrock Mine
UNC-NE Churchrock Mine
UNC-NE Churchrock i-iine
KM-Section 35, Churchrock
i-i i ne
Gas Company Burnham Well 1
Pond in South Patjuate pit
109
109
face
442




137

174



216
224

19u
168
306

457

372
714
457
51d
549
549

1585
Poncj
Qb

Ps

Pym
Jmw
Kd
Jt

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

Jmw

Rad i urn
pCi/l
4.
0.
0.
^O.
0.
8.
2.
5.

5.
1.
10
42
2.
5.
1 .
10
2.
42
1 .
1 .
27
1 .
2.
0.
c.
0,
0.
8


0.
190
3
4
36
1
2±0.1
5+1.7
9iO.G
1

1
1
±2

7+0.5
oil. 1
1
+ ""?
0+0.4

1+0.2
4±0.3
±5
2+0.2
3+0.5
.210. 1
05
.62
.09
.10


.24

gross
e
PCi/l





36 i 5
12 i 2
150





18+3
37 i 6
69
39 ± 7
12 12
49
18+4
9.0+ 1.3
75 ±1 1
6.5± 0.9
56 i 8
9.8+ 1.4








U natural
d issol ved
DCi/l
1.82
4.27

0.84
1.96




13Q
<.07
8.4
16. 1












<0.28
185
22
847


0.05
170
sources are as follows:
Aiiibro
sid Lake area: Cooper and John
. 1966





Laguna-Paguate: Lyford, 1075
Churchrock: Hiss and Kelley
Grants-Blue^ater- : Stow, 1961
, 1975





         Grants-bluewaler-Prew irt:
2.  Aquifers:
        gb
        Kd
        Jmw
        Jt
        Ps
        Pym
basalt flow
Dakota Fm.
Morrison Fm.,  Wostwater Canyon Mbr.
TodiI to Fm.
San Andres Ls.
Yeso Fm, t'ieiietd Ulancha Mbr.
                                              36

-------
Figure 3.   The Anaconda Company Uranium Mill and
           Tailings Pond-Bluewater
                      37

-------
reduced the nitrate content in the effluent, but seepage
has continued 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 10" liters.
Therefore, the seepagerinjection 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 fraction was probably larger, but is unknown.  Dis-
counting this seven-year period and assuming an average radium
concentration of 125 pCi/1, seepage has introduced 0.41 curies
of radium to the shallow aquifer, which is very definitely
potable.

     The New Mexico Department of Public Health (1957) com-
pared pre-1955 and 1956-1957 nitrate data for nearby wells
completed in alluvium and in the San Andres Limestone.  It
was concluded that nitrate contamination occurred between
1955 and 1957 after only two years of milling.  At the time
of the field study (June-Nov., 1956) , it was estimated that
87 percent of the effluent leaked from the 28.4 hectare
pond at a rate of about 10,000 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 nitrate
concentrations of 66 to 84 mg/1 (15-19 mg/1 NOs-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 con-
centrations 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 also concluded that
high nitrate within 4.5 kilometers of Grants was a result
of waste disposal.  This would imply movement of 10 kilo-
meters in 2 to 3 years, which is extremely unlikely.

     To evaluate ground-water quality trends, 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 investigation),
were plotted to determine changes in ground-water quality with
respect to distance from the tailings ponds and with time.
                           38

-------
These data show that 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 (TDS)
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 3).  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
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.

     Radium and nitrate concentrations in ground water are
depicted in Figure 4.  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,
radium in the alluvial aquifer decreases as a function of
distance from the tailings ponds. The elevated radium level
in well #9123 is postulated on the basis of a radial flow
pattern centered on the tailings ponds and superimposed on
the natural ground-water flow which is southeastward.  In
                           39

-------
                                           6.3
                                           • 121
                                           0.05
            O.O6
            •124
           0.8
Bluewater
       O.26
      •123
       3.2
       I Tailings
         Pond

^Anaconda Mill
™0.50
  •118
   9.0
            0.18       Q27
            •115  0.2   «i20
             3.9  fll!  g.V3
                  5.4
                          1-40
                                        0.14
                                        •129
                                        2.5
                                    0.21
                                    • 127
                                    0.03
QUALITY OF WATER INJECTED
Period
1960 to
1965
1966 to
1969
Radium
292
pCi/l
115pCi/l
Nitrate
23.7
mg/l
as N

Source
West;
1972
MRI;
1975
                            4 km
                                    0.15
                                    •128
                                     1.4
                                                  O.13
                                                   •101
                                                   4.2
              SCALE
                                                O.O9
                                                •103
                                                 5.5
            Principal water bearing unit

          •  ALLUVIUM/BASALT

          •  SAN ANDRES LIMESTONE

          A  6LORIETA  SANDSTONE

          X  YESO FORMATION (injection)
         Map  symbols

       radium, pCi/l
 .
•127 — location of well #9127

       nitrate  plus nitrite, mg/l  as N
          O Q
                                           0.14
                                             116'
                                            1.6
                                     Milan
                                                                O.24
                                                                    3.4
                                                                Grants
      Figure  4.   Radium  and  Nitrate  Concentrations in  Ground
                    Water in the Grants-Bluewater Area
                                      40

-------
this direction, wells #9115, #9129, #9128, #9101, and
#9103 could also be affected.  The gradually reduced con-
centrations along the flow path may reflect dilution and
sorption effects or they may simply be coincidental.  For
unknown reasons, the trend reverses in the Milan-Grants
area, and concentrations begin to increase along the flow
path.  With the exception of wells #9101 and #9103, essen-
tially the same pattern is true for nitrate.  Variations in
chloride, which is also a likely indicator of mill effluent,
do not fit the pattern for radium and nitrate and, to some
extent, weaken the conclusion that contaminants are recog-
nizable in the alluvium.

     In the San Andres Limestone and Glorieta Sandstone,
radium concentrations range from 0.11 to 2.6 pCi/1 (0.11 to
0.50 if well #9117 is excluded) and show no pronounced
lateral trends.  The highest concentrations (2.6 pCi/1) are
in the Anaconda monitor well (#9117) and may indicate con-
tamination (or this may simply be a naturally elevated level
in the Glorieta Sandstone).  Very few wells tap this forma-
tion and water quality is poorly known.  Anaconda well #2
(#9118) is also relatively high in radium, nitrate, and
polonium-210.   It is quite possible that the well is con-
taminated by downward seepage of wastes from the tailings
pond.

     The Berryhill Section 5 well (#9121) is listed in the
Anaconda Company records as being completed in the alluvium.
It is equipped with a windmill and is used for stock water-
ing.  However, Gordon (1961) indicates that as of January
1958 there were two wells in the area.  The active well,
221 meters deep and completed in the San Andres Limestone,
replaced an .older well, 107 meters deep and completed in the
Chinle Formation.  Therefore, contamination of either the
Chinle Formation or the San Andres Limestone by injected
wastes is occurring insofar as the radium-226 concentration
of 6.3 pCi/1 in the Berryhill Section 5 well greatly exceeds
normal concentrations in either formation (see also Table 4)

     Because of excessive seepage from the tailings ponds,
the Anaconda Company developed an injection well to dispose
of decanted effluent.  According to company and U. S. Geo-
logical Survey reports (Fitch, 1959; West, 1972), favorable
geologic, hydraulic and water quality conditions exist to
allow this disposal method.  However, subsequent evaluation
of the monitoring data and inadequacies in the number and
location of monitoring wells make this conclusion question-
able.
                           41

-------
     From 1960 to date, injection has been into the Yeso
and Abo Formations at depths of 289.6 to 433.7 meters.
Between the injection zone and the lowermost potable
aquifer, there is reportedly a relatively impervious
sequence of sedimentary rocks, including numerous anhydrite
and gypsum beds (Fitch, 1959; West, 1972).  When the in-
jection program was conceived in 1960, this sequence was
considered sufficient protection for the overlying potable
aquifers.  Also, it was reasoned that when the waste fluid
contacted the gypsum or anhydrite, as well as other dis-
posal zone rocks, an ion exchange occurred between radium
(in the fluid) and calcium (in the reservoir rocks), thereby
reducing somewhat the radium concentration in the injection
fluid.

     Based on laboratory tests of the drill cores from the
disposal zones, neutralization of the waste effluent was
expected to occur. The pH of the formation waters ranges
from 7.4 to 8, while the effluent has a pH of about 2.2.
It was thought that the acid effluent becomes neutral
or slightly basic due to the preponderance of disposal
zone waters.  Radium solubility would, therefore, decline.
The disposal zone waters have been shown to be non-potable
due to their brackish quality.  Chemical analyses indicate
a very high concentration of total dissolved solids, and
it was reasoned that contamination of the deeper formations
would not deny foreseeable use for the contained water.

     Evidence of leakage from the injection zone is shown in
Figure 5, which summarizes Anaconda Company data on the
volumes of wastes injected from 1960 through 1973.  Also
shown are trends in natural uranium and chloride from the
monitor well  #9117, Roundy windmill, and North well (#9122)
for the period 1969 through 1973.  It is readily apparent
that both chloride and uranium concentrations in all three
monitoring wells are increasing with time and vary directly
with the volumes of waste injected.  The concentration of
polonium-210 in the Monitor well exceeds that in all other
wells in the Bluewater-Grants area and is well above the
average of 0.33 pCi/1 for six wells in bedrock.  Concentra-
tions of chloride and natural uranium in the waste water
average 2010 ppm and 7340 pCi/1, respectively, for the period
1960 to 1965 (West, 1972).  Radium from 1960 through 1969
averages 221 pCi/1 (Clark, 1974).  According to the partial
chemical data for these three monitoring wells and contrary
to original projections, contamination apparently extends
into the San Andres Limestone.
                           42

-------
"611962   1963  1964  1965   1966   1967   1968   1969   1970   1971   1972   1973
xlO*
^
*•"• ,
1
1
i
                                                                             230
                                                                             210
                                                                            ISO
                                                                            150
                                                                              TJ
                                                                              TJ
                                                                              3
                                                                            130
                                                                            110
                                                                            90
                                                                            70
                                                                            M
Figure  5.
               Summary of Waste Volumes  Injected via the
               Anaconda Disposal Well  and Water Quality in
               Selected Monitoring Wells

-------
     Sulfate, IDS, and gross alpha in North well (#9122)
and in the Monitor well (#9117) are increasing slightly
with time.  For North well, IDS 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.  Cross alpha is
apparently 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.

     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 (9118, 9119, 9124, 9125, 9126, 9127 and
9129) completed in bedrock and in alluvium and generally-
located peripheral to and within 4 kilometers of the tail-
ings 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 de-
creasing trends for IDS and sulfate are present whereas
chloride, nitrate and gross alpha results are rather stable.
Because of its proximity to the Anaconda tailings ponds and
because of its use as a public water supply, the LDS well
in Bluewater should be more routinely monitored for nitrate
and radium.

     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 1956 to 1969 may bear out the earlier pre-
dictions of gross contamination; but, if so, water quality
since 1969 is only slightly changed,  ^or widespread ground-
water contamination 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. It is a matter of conjecture whether the
earlier data were faulty or were misinterpreted.  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 distributions and waste density con-
siderations add further complications.  However, seepage is
occurring and it is possible that the Company estimates
stated above are conservative.
                          44

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     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 predic-
tions of contamination, is not apparent.  The major quali-
fication of these conclusions is that wells properly located
and completed for sampling purposes are not available; hence,
the extent of contamination is not well understood.  Con-
tamination 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 further confirm
or deny the trends shown in Figure 5.  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. Such measures are particularly important if
increasing concentrations of radium-226 (and possibly
lead-210) are appearing in the aquifers above the injection
zone.

United Nuclear-Hpmestake Partners Mill and Surrounding Area

     The mill is partially surrounded on the southwest or
downgradient side by housing developments and irrigated
farm lands, both of which depend on local ground-water
supplies.  Also obvious in Figure 6 is a darker seepage
area around the base of the tailings pile.  The seepage
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
Homestake-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 pumping 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 permea-
bility of the Chinle Formation is low, and actual vertical
                           45

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                               AMBROSIA LAKE
                                          GRAVEL PITS
                                ORE STORAGE AREA
                                        UNITED NUCLEAR-HOMESTAKE
                                        PARTNERS URANIUM MILL
          PONDED
          TAILING PILES

       / DIRECTION OF f
       AGROUND WATERX,
            FLOW
                  SUBDIVISIONS
            GATED AREA
                                            (CHINLE  FORMATION)
                                       GRANTS
Figure  6.   The  United Nuclear-Homestake  Partners  Uranium
            Mill and Tailings Ponds-Milan
                             46

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water transfer is probably 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.  Water quality
in the Chinle Formation and the still deeper San.Andres
Limestone is likely to be unaffected.

     Radium concentrations in groundwater (Figure 7) 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
single active monitoring well (#9135).  Although below the
PHS drinking water standard of 3 pCi/1, this value does in-
dicate movement of contaminants away from the tailings pond.
Attenuation due to sorption may mask a very sharp concentra-
tion 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 re-
flect plumes or fronts of contaminants that have advanced
ahead of the main body.  The water table map (Figure 8),
prepared by Chavez (1961) , portrays an elongated, northeast-
trending lobe or mound centered on the smaller tailings pile
from the now inactive Homestake-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
monitoring wel.ls completed in the alluvium contained from
0.8 to 9.5 pCi/1 radium despite the fact that ore had been
processed for less than two years.  These concentrations
are 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 7) support
the idea of a tongue of contaminated ground water in the area
between this well and the tailings pile.  Nitrate in this
well was 62 mg/1 and, therefore, does not meet the PHS Drink-
ing Water Standard of 45 mg/1.  Infants and fetuses are
particularly susceptible to nitrate poisoning at concentra-
tions above 45 mg/1, and alternate sources of potable water
should be utilized.  Heterogeneities in sediment permeabili-
ties, coupled with irregular induced flow gradients resulting
                           47  '

-------
                                                       (
                                                            /
                                                          (
         Principal water bearing unit
        • ALLUVIUM/BASALT
        A CHINLE FORMATION
        • SAN ANDRES LIMESTONE
      •107
     2200/90
   Map symbols
 radium, pCi/l
• location  of well  #9107
'TDS/chloride, both in mg/l
                                                        ^
                                                       V
                                         «i7
                                         •!<
                                         Ui
                                       2
                                      *y
                                               &
4
J\
 O.61
•>133
1600/50
  ||2200/110
  II
    Murray
     Acres
                                3800/260     O.17
                              "  Broadview   41
        O.13
        • 109
       1300/9.5
                                                                     1 km
   Figure 7.    Radium, TDS  and  Chloride in  Ground Water Near
                 the United Nuclear-Homestake Partners Mill
                                    48

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                                                                       #9

                                                                        •70
                                                                    6532. fg
                                                                o«
                                                               •60  #1 Supply

                                                                41  •
                                                             Mtit AREA
 • 120

   110
6514.35
                                                     6JJO


                                                     65   ««
                                                         #13

                                                          • |)_—Total Depth, m

                                                      651O  14—Top of Chinle, m
                                                      Static water level elevation,

                                                      feet above MSL
                                                        • CASED WELL
                                                        O UNCASED WELL
                                                 O   1OO  2OO  3OO 4OO meters
     BROADVIEW ACHES SUBDIVISION
   Figure  8.   Water Table Contours and Well  Locations  at the

                United Nuclear-Komestake Partners  Mill  Site

                                   49

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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
anomalously high and are, perhaps, the best indicator of
ground-water contimination.  Nearby wells (#9102, #9107,
and #9113) contain from 20 to 106 times the recommended
maximum selenium concentration of 0.01 mg/1 (National
Academy of Sciences-National Academy of Engineering,
1972) .  Two of the wells contain approximately two-thirds
of the concentration 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 mg/1.  Because of analytical difficulties
and differences between laboratories, the selenium data are
most useful to show elevated trends rather than necessarily
an absolute concentration in the ground-water system.  Addi-
tional sampling is necessary to more accurately define the
extent of contamination.

     Elevated levels of polonium-210 are present in well D
(#9135) and in other wells (#9102, #9106, #9107, and #9113)
downgradient from a suspected contamination front in the
shallow aquifer.  Background for polonium-210 is approxi-
mately 0.34 pCi/1 (Table 5) in wells tapping either the
Chinle Formation or the alluvium, whereas concentrations
range from 1.0 to 2.3 pCi/1 in wells suspected to be con-
taminated.  The highest value for polonium-210 was from
well D (#9135).  The elevated level of polonium-210 in sup-
ply well #2 (#9134) cannot be explained.

     Provision of an alternative water supply is strongly
recommended to avoid consumption of shallow ground water
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.  Other alternatives include
the construction of high capacity wells nearby, but away
from the developments, or placing the developments on the
Milan municipal water system.
                           50

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Ambrosia Lake Area

     The Kerr-McGee mill is located on the dip slope of
a southeast-facing cuesta in an area underlain by a
thin veneer of silt and clay alluvium over the Mancos
Shale.  Shown in Figure 9 is the large network of tailings
ponds and water storage reservoirs 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
vegetation present in the formerly dry washes.  Shown in
the upper right corner of the photograph, taken in September
1973, is the inactive tailings pile at the United Nuclear
Corporation mill.  The ponded water shown on the pile has
since evaporated or seeped into the tailings.

     Ground-water sampling in the Ambrosia Lake area focused
on the Kerr-McGee tailings disposal operation and the com-
bined impact of various ion exchange plant and mine water
discharges into San Mateo Creek and Arroyo del Puerto.  Be-
cause of influent stream conditions, these surface water
bodies represent line sources of recharge to the shallow
ground-water reservoir.  Of the 22 wells sampled in the area
(see Figure 10), 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 pre-
cluded study in these areas.  Poorly understood are the
effects of seepage from settling ponds and from open channels
leading to the two principal streams in the area.  The dis-
position of solutions involved in situ leaching is also
unknown.

     Nevertheless, the conservative parameters clearly indi-
cate 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 nitrate (as N) go from an average
of less than 1 mg/1 to 24 mg/1.  The recommended maximum
in drinking water is 10 mg/1.  Selenium and vanadium
concentrations in ground water do not markedly increase
near the tailings ponds.  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 en-
riched in selenium which further substantiates the TDS,
chloride, ammonia, and nitrate data results which show con-
tamination of the shallow aquifer.  Nitrate, derived from
                           51

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    SETTLING PONDS FOR MINE DRAINAGE
                                            UNITED NUCLEAR
                                      CORPORATION  TAILINGS
                                     PILE AND MILL (INACTIVE)
                         STORAGE AREA
KERB McGEE MILL
                                     PROCESS WATER STORAGE POND
                                           SEEPAGE CATCHMENT BASIN
               PONDED WATE.
         ^TAILINGS PONDS
                    EARTHEN RETENTION DAM
                                   Arroyo del Puerto
                                                   — NM 509
                                                         DRAINAGE FROM
                                                           KERR-McGEE
                                                          SEC 35 MINE
     Figure  9.   Kerr-McGee  Nuclear Corporation  Uranium  Mill,
                 Tailings Ponds, and Mines-Ambrosia Lake
                                 52

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                                            United Nuclear Mill
                                Tailings Pond
                             (1.95) (inactive)
 Storage Pond'
Kerr-McGeeMill
     21
    (1.18)
                               ©- LOCATION OF WELL #9201
                              (0.35)
                                  Radium concentration, pCi/l
Figure  10.   Radium  Concentrations in Ground Water  in  the
               .Ambrosia  Lake  Area
                                   53

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very high concentrations of ammonia in the mill effluents,
persists in shallow ground water.  This is particularly
true for shallow wells located east of the ponds and
along San Mateo Creek, both above and below the county line.
The range of concentration exceeding the PHS Standard is
48.7 to 350 mg/1.  One of these wells (#9204-Ingersoll
Rand) is used for a potable supply, whereas well #9202 is
for stock watering.

     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
characterizes the quality of ground-water seeping beneath
and through the retention dam.  Water in the basin, per
se, contains 65 pCi/1 radium.  Note that high TDS, chloride,
ammonia, and nitrate plus nitrite appear in the seepage.
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.

     The foregoing general pattern is in agreement with
the migration 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 immediately 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-McGee 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 would be
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 are additions to storage in the third quarter
of each of three years (1972, 1973, 1974).  The writers
interpret this as overland flow related to thunderstorm
activity prevalent at this time of year.  The rapid influx
                           54

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of overland flow into the ponds prompts questions concerning
their stability and overall company management practices.
The ponds are operated with very little freeboard and the
berms or dikes are composed of sandy tailings that are readily
eroded, particularly if overflow conditions develop.  Cata-
strophic failure of the tailings ponds could occur.

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 11, is about 16 x 10^
liters/day and characterized by 8 to 23 pCi/1 radium,
700 to 4900 pCi/1 uranium, 0.01 to 0.04 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 represents a remote threat to potable ground water
in the vicinity of the Puerco River and possibly part of the
Gallup municipal supply.  In part, the present study examines
whether noticeable ground-water quality deterioration has
occurred to date.

     Ground-water sampling in the Churchrock area involved
13 wells located along the Puerco River and South Fork
Puerco River.  For control purposes, an adjacent watershed
tributary to the Rio Puerco was also sampled.  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 consti-
tute a health problem.  The radiochemical, 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.  However, two of the wells (#9139, #9221)
contain 119.6 and 62 mg/1 nitrate,, respectively, and, there-
fore, do not meet the PHS Drinking Water Standard of 45 mg/1.
The mine drainage waters contain less than 4 mg/1, hence this
is not the source.   Consumption of water this high in nitrates
is particularly dangerous to infants and the unborn and alter-
nate supplies should be utilized.   More suitably located
                           55

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              NAVAJO INDIAN RESERVATION
                                                       A220
                                                      O.12
                                                                       £
                    err-McGee.
                       Mine
                           O29
                                                        United Nuclear Mine
 J37
 VO.68
3.86 Km west
               /
            142,
            A^
         °-       AA21'143
                   ' 0.56-0.83
                 Principal water-bearing unit

              •  ALLUVIUM
              •  GALLUP SANDSTONE
              A  DAKOTA SANDSTONE
              A  WESTWATER CANYON  MBR.,
                  MORRISON FM.
              4-  JURASSIC STRATA BELOW
                  MORRISON FM.
142
O.41
  \
     O  1  2   3  4 km
          SCALE
LOCATION OF WELL #9142
                                                     RADIUM CONCENTRATION, pCi/l
                    Radium  Concentrations  in  Ground  Water  in  the
                    Churchrock-nallup Area
                                         56

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sampling points, together with revised analytical programs
are strongly recommended improvements to the existing indus-
trial efforts.

     By comparison, the effects of mining on the concentra-
tion or radium in ground water are pronounced.  Present
discharge from the Kerr-McGee mine, which is in the develop-
ment versus mining stage, averages 7.9 pCi/1 as compared to
23.3 pCi/1 for the United Nuclear mine.  The latter is pro-
ducing 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 penetration 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.  Similar trends also seen in the Ambrosia Lake
area prevail, indicating that ultimate radium concentrations
on the order of 50 to 150 pCi/1 are likely.  This has been
tentatively confirmed by company, self-monitoring data.

Jackpile-Paguate Area

     Sampling in the vicinity of the Jackpile-Paguate open
pit uranium mine included four wells located as shown in
Figure 12.  One of these (#9233) is the Paguate municipal
supply which is a flowing artesian 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.  Continued consumptive
use of this water is not recommended because the radium
exceeds the PHS Drinking Water Standard of 3 pCi/1.
                           57

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                                   Anaconda Co.
                                   Jackpile-Paguate
                                   Open Pit
   (0.6)
       s
LOCATION OF WELL #9230

Radium concentration, pCi/l
Figure  12.
     Radium Concentrations  in Ground  Water  in the
     Paguate-Jackpile Area

                    58

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     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 would
be 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.

Significance of Radiological Data

Regulations and Guidelines

     On August 14, 1975, the U.S. EPA 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.  Gross 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.
                           59

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     Therefore, with respect to these proposed radioactive
contaminant levels, the following conclusions were reached:

     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 back-
ground 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 equilib-
rium 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 loca-
tions sampled have radium-226 concentrations in excess of
5 pCi/1.  Therefore, the proposed new standard of 5 pCi/1
for combined radium-226 and radium-228 contents is therefore
exceeded at these two locations.

     4.  Sixty 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
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.  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, PHS Publication
                           60

-------
No. 956; 1962).  The population guide--maximum permis-
sible concentration (10CFR, Part 20, Table II, column 2,
unrestricted areas) is 10 pCi/1 for radium-226.  Table 7
lists the 6 locations and presents the gross alpha and
radium-226 results.

     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 concentration
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.

     Samples from two Kerr-McGee monitoring wells (#9208
and #9213) , located within 800 meters of the main tailings
retention dam, contain radium in excess of 3.0 pCi/1.  These
wells are not fitted with pumps, are in a restricted area,
and contain water otherwise unfit for comsumption.  For
example, TDS varies from 7500 to 8900 mg/1.  Therefore, these
wells do not constitute a health hazard in terms of dis-
solved radium.  Similarly, station #9212 consists of seepage
return water collected at the base of the retention dam.
Aside from the radium content of 4.9 pCi/1, the water
is in a restricted area, is not used for any purpose, and
contains 36,000 mg/1 TDS.  Therefore, consumptive use and
creation of a health hazard is extremely unlikely.

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

     A radium concentration of 0.68 pCi/1 from the Erwin
well north of Gallup (#9233) was the highest radium concen-
tration for the municipal supplies.  It appears that, on
the whole, municipal water supplies in the-Grants Mineral
Belt area do not exceed 23% percent 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-Homestate Partners
mill.  The highest radium concentration was 0.72 pCi/1
                           61

-------
                                Table  1
                   Locations with  Radium-226 in Excess of
                     the PHS Drinking  Water Standard'
Location
Description
'9121-Berryhill
Section 5
Bluewater
'9201-P. Harris
Grants KM-46
'9208-KM-43
Grants
»9212-KM Seepage
Return-Grants
'9213-KM-B-2
Grants
»9232-Jackpile-
New Shop Well
Paguate
Radium-2262
Dis solved
pCi/1
6.3

3.6

4.0

4.9
6.6

3.7
Two Sijjma
PCi/1
0.1

0.1

0.1

0.1
0.1

0.08
pross A pha2
Dissolved
pCi/1
12

110

49

112,000
8

18
Two Sigma
pCi/1
14

40

35

3,000
32

13
Remarks
Windmill Steel
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  NI-IC-Denvcr.
      Radium ma uross Alpha Concentrations for lunicioal Water Supplies
! Location
] Description
#9112-Grants
i City Hall
! 09116-Milan City
1 Well #1
i S9125-LDS
Bluewater
: #9137-Erwin Well .
1 . Gallup
f/9233-Municipal Well
' Paguate
. #9141-Churchrock
Village
Radium- 226
Dissolved
pCi/1
U.4J
0.14
0.22
0.68
0.18
0.12
| Two Sigma
pCi/1
t: . '.; J
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  alpha results by NEIC-Denver.

-------
at the Worthen well (#9107), and the lowest concentration
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.

Other Radionuclides

     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 NRC 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 0.06% 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 con-
centration of 0.99 pCi/1.  However, this is less than 0.15%
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.  These are 0.006% and
0.98% of the population guide - MFC, respectively.
                           63

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                          Table 9

        Maximum Permissible Concentrations  in Water'
                 (Above Natural Background)
   Radionuclide
     Appendix  B
 Table  II,  Column  2
(Unrestricted  Areas)
        pCi/1
Population Guide
      pCi/1
226
226
2 1 0
2 1 0
230
232
23"*
235
238
Ra
Ra
Po
Pb
Th
Th
U
U
U
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
Soluble
Insoluble
U-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
,000
,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
10 +
,000
10
,000
233
,000
33
,667
667
,000
667
,333
,000
,000
,000
,000
,333
,333
,000
,000
   lOCFR-Part 20--Standards for Protection Against Radiation
   U.S.N.R.C.(April 30, 1975).
   Population Guide = 1/3 times Unrestricted Area
                      MPC--Table II Values.
                                                         226,
+  A maximum permissible concentration of 3.33 pCi/1 for
   is the Handbook 69 population guide (i.e., l/30th of the
   HB69 continuous occupational exposure limits).
                             64

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     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 the Municipal well
at Paguate  (#9233) with 0.39 pCi/1 (0.17% of the population
guide - MFC).  In summary, exclusive of the radium-226 con-
tent, the highest isotopic uranium, thorium, and
polonium-210 contents for any potable water supply in the
Grants Mineral Belt area is less than 1.72% of the total
radionuclide population guide - MFC.  Exclusive of the
Kerr-McGee seepage return sample (#9212) and the Anaconda
injection well sample (#9107) , the Worthen private well
(#9107) had the highest gross alpha result of 2500 pCi/1.
This gross alpha result underestimates the U-natural con-
tent reported as 9800 pCi/1 (i.e., 98% of the allowable MFC).
There are other examples of inconsistencies between gross
alpha and natural uranium data.  For example, samples #9102
and #9113 have gross alpha results of 3 pCi/1 and 31 pCi/1,
respectively.  Comparable U-natural contents are 49 and
56 pCi/1 (less than 0.56% of the U-natural MFC).  In
general, it appears that the uranium isotopes represent
the greatest contributor of alpha activity.  Considering
the total radionuclide values to be the summation of urani-
um isotopes, thorium-230, thorium-232, and polonium-210
concentrations, the percentage of total radionuclides com-
pared to gross alpha ranged from 31% (#9219) to 639%
(#9102) , exclusive of #9132 which has an extremely
large discrepancy of results.  Therefore, it appears that
the gross alpha determinations have underestimated the
natural uranium contents.  It is doubtful that the gross
alpha determination can even be used as an indicator of
the presence of other alpha emitters (e.g., U-natural and
polonium-210).   Since the gross alpha results have such
large error terms, no meaningful determinations of percent-
age of other radionuclides to gross alpha result can be
implied.

     With respect to the use of 15 pCi/1 gross alpha
(including uranium isotopes) as a "scan level" to indicate
radium contents in excess of 5 pCi/1, only 2 locations fall
in this category.  Location #9121 had a gross alpha of
12 ± 14 pCi/1 and a radium-226 content of 6.3 ± 0.1 pCi/1.
Because of the large error term in the gross alpha determin-
ation (8 ± 32 pCi/1) for location #9213, this sample would
be included in the group of locations having a gross alpha
                           65

-------
result greater than 15 pCi/1.  This location had the highest
radium-226 content of all the ground-water locations sam-
pled (6.6 pCi/1).  Of the 58 remaining ground-water loca-
tions with gross alpha results greater than 15 pCi/1
(range: <3 ± 13 to 2500 ± 200 pCi/1), the radium-226
contents ranged from 0.19 to 0.72 pCi/1, respectively.  For
ground-water samples with gross alpha greater than 15 pCi/1,
the radium-226 concentration ranged from 0.06 to 6.6 pCi/1.
Therefore, there appears to be no correlation between a
gross alpha level of 15 pCi/1 (including uranium isotopes)
and a radium-226 content of 5 pCi/1.

     It is appropriate to conclude that for routine radio-
logical 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
for each sample yield the most information for radiological
evaluations of drinking water conditions.
                           66

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                    REFERENCES CITED
Bond, A. L. , 1975, N» Mexico Environmental Improvement Agency,
     Letter of February 14, 1975, to J. Thornhill, U.  S.
     Environmental 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.

Dutton, C. E., 1885 „ Mount Taylor and the Zuni Plateau: in_
     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.

Fitch, A. J., 1959, October 9 letter from the Anaconda Company,
     Grants, New Mexico, to H. L. Price, Director, Division of
     Licensing and Regulations, U.S. Atomic  Energy Commission,
     16 p.
                           67

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

Gray, W. E., 1975, Environmental Engineering, N. Mexico Opera-
     tions, Uranium Division, The Anaconda Company,  February 14
     letter to Robert F. Kaufmann, U.S. Environmental Protection
     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.

Hiss, W. , and T. Kelley, 1975, U.S. Geological Survey, WRD,
     Albuquerque, NM, February 14 written communication to
     John Dudley, New Mexico Environmental Improvement Agency.

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 lT7 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: in  N. Mexico
     State Bureau of Mines and Min. Res. Memoir 13"7 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 ConTerence,
     Guidebook of the Defiance-Zuni-Mt. Taylor Region of
     Arizona and New Mexico, p. 173-183.

Lyford, F. P., 1975, U. S. Geological Survey, WRD,  Albuquerque,
     NM, February 12 letter to John Dudley, New Mexico Environ-
     mental Improvement Agency.

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.
                           68

-------
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.

National Bureau of Standards, 1959, Maximum permissible body
     burdens and maximum permissible concentrations of radio-
     nuclides in air and in water for occupational exposure,
     Handbook 69, National Bureau of Standards, 95 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 eenvironmental aspects of
     radiation: New Mexico Environmental Improvement Agency,
     Santa Fe, New Mexico.

Public Health Service, U.S. Department of Health, Education,
     and Welfare, 1962, Drinking water standards--1962: PHS
     Publication No. 956, 61 p.

Stow, J. M., 1961, U.S. Geological Survey, WRD, Albuquerque,
     NM, April 14 letter to Eugene Chavez, State Engineer
     Office, Roswell, NM.

Tsivoglou, E. C., and R. L. O'Connell, 1962, Waste guide for
     the uranium milling industry: U.S. Department of Health,
     Education, and Welfare, Technical Report W62-12,
     Cincinnati, Ohio, 78 p.

U.S. Atomic Energy Commission, 1974, The Nuclear Industry:
     U.S. Atomic Energy Commission, Washington, D.C.
     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 Surveys, 1975, Unpublished data received via
     written communication from WRD, New Mexico District,
     Albuquerque, file number 08350500.
                           69

-------
U.S. Nuclear Regulatory Commission, 1975, Standards for
     protection 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.

Wright, J., 1974, New Mexico Environmental Improvement
     Agency, September 25 letter to G. J. Putnicki, U.S.
     Environmental Protection Agency, Region VI, Dallas,
     Texas.
                           70

-------
                             TECHNICAL REPORT DATA
                       (Please read Instructions on the reverse before completing)
i. REPORT NO.
   ORP/LV-75-4
                         2.
4. TITLE AND SUBTITLE Technical Note!
   Summary-Ground  Water Quality Impacts of
   Uranium Mining  and Milling in the Grants
   Mineral Belt, New Mexico	
                                                 3. RECIPIENT'S ACCESSIOI»NO.
                                                 5. REPORT DATE
                                                   August 1975
                                                 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
   Robert F. Kaufmann,  Gregory G. Eadie,
   Charles R. Russell
                                                 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   U.S. Environmental  Protection Agency
   Office of Radiation Programs
   Las Vegas Facility,  P.  0.  Box 15027
   Las Vegas, Nevada   89114
                                                 10. PROGRAM ELEMENT NO.
                                                 11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
   Same as above
                                                 13. TYPE OF REPORT AND PERIOD COVERED
                                                   Final	
                                                 14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16.ABSTRACT  Ground-water contamination from uranium mining  and  milling
 results  from the infiltration  of radium-bearing mine, mill,  and ion-
 exchange  plant effluents.  Radium,  selenium, and nitrate were  of most
 value  as  indicators of contamination.   In recent years,  mining has
 increased radium in mine effluents  from several picocuries/liter (pCi/1)
 or  less,  to 100-150 pCi/1.  The  shallow aquifer in use in  the  vicinity
 of  one mill was grossly contaminated with selenium, attributable to
 the mill  tailings.  Seepage from two other mill tailings ponds averaged
 674 x  10° liters/year and, to  date, has contributed an estimated 1.1
 curies of radium to ground water.   At  one of these, an injection well
 was used  to dispose of over 3400 x  106 liters of waste from  1960-1973.
 The wastes have not been properly monitored and have apparently migrated
 to more  shallow, potable aquifers.   No adverse impacts on  municipal
 Water  quality in Paguate, Bluewater, Grants, Milan, and  Gallup were
 observed.  No correlation was found  between gross alpha greater than
 15pCi/l and radium-226 in excess of 5  pCi/1.  Company-sponsored moni-
 toring and reporting programs  do not describe the full impact  of mining
 and milling operations on ground-water quality.  Review  by State and
 Federal agencies has generally been superficial.  Improvements in these
           a Hfl 11~ i on a i ttronncl ~v 3 t?r 5 ampl inp ar0 recommflndod.
17.
                          KEY WORDS AND DOCUMENT ANALYSIS
Ground water,
water pollution,
               DESCRIPTORS
               hydrogeology,
                                      b.lDENTIFIERS/OPEN ENDED TERMS
 Grants Mineral Belt
 New Mexico
•Uranium mining and
 milling.
                      c. COSATI Field/Group
Radioactive
contaminants,
Radioactive
waste process
ing, waste
disposal.
uranium,
                  waste disposal, in-
jection wells,  wastes, natural radio
activity, radium, radiation hazards,
radioactive wastes,  mining, milling,
tailings ponds.
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                          71
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EPA Form 2220-1 (9-73)

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA 906/9-75-002
                                                           3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
                                                           5. REPORT DATE
  Water Quality  Impacts of Uranium Mining  and Milling
  Activities
               SPp
              i. PEF/F
                          1Q75
                  FORMING ORGANIZATION CODE
7. AUTHOR(S)

  EPA, Region VI;  ORP-Las Vegas; NEIC-Denver
                                                           8. PERFORMING ORGANIZATION REPORT NO.
              EPA 906/9-75-002
9. PERFORMING ORG \NIZATION NAME AND ADDRESS
  Environmental Protection Agency
  Region VI
  1600 Patterson  Street, Suite 1100
  Dallas. Texas   75201	
              10. PROGRAM ELEMENT NO.

              2FH192	
             11. CONTRACT/GRANT NO.
              N/A
 12. SPONSORING AGENCY NAME AND ADDRESS
  N/A
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            Final
              14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
  Ground water in  the  study area is affected by mining and waste  disposal  associated
  with mining and  milling.   Contamination  appears in close proximity to the mining
  and milling centers  with  the exception of  more widespread selenium contamination
  of shallow ground water adjacent to the  United Nuclear-Homestake  Partners .Mill.
  Contamination of municipally operated water supplies in the study area is not
  evident.  Potable supplies derived from  mine water at four industrial sites exceed
  applicable limits for selenium in drinking water.  Three such systems exceed
  limits for Radium 226.

  Recommendations  developed are designed to  assist the State in future regulation of
  uranium mining and milling for the purpose of safeguarding public health and in-
  suring future environmental quality.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                           c. COS AT I Field/Group
 Uranium Radioisotopes
 Ground Water

 Water Quality
 Surface Water
 Potable Water
JT Radioisotopes
RT Aquifers; water  wells;
  water table
RT Water Pollution
   Lagoons
JF Drinking Water
RT Public Health
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  Release unlimited
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                              188
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        significant bibliography or literature survey, mention it here.

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        (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms that identify the major
        concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

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    18.  DISTRIBUTION STATEMENT
        Denote reusability to the public or limitation for reasons other than security for example "Release Unlimited."  Cite any availability to
        the public, with address and price.  /

    19.&20. SECURITY CLASSIFICATION
        DO NOT submit classified reports to the National Technical Information  service.

    21.  NUMBER OF PAGES
        Insert the total number of pages, including this one  and unnumbered pages, but exclude distribution list, if any.

    22.  PRICE
        Insert the price set by the National Technical Information Service or the Government Printing Office, if known.
EPA Form 2220-1 (9-73) (Reverse)

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