.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

SCIENCE ADVISORY BOARD

February 17, 2012

EPA-SAB-12-005

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Subject: Advisory on EPA’s Draft Technical Report entitled Considerations Related to PostClosure Monitoring of Uranium In-Situ Leach/In-Situ Recovery (ISL/ISR) Sites

Dear Administrator Jackson:

The EPA is considering the need to update the environmental protection standards for uranium mining

because current regulations, promulgated in response to the Uranium Mill Tailings Radiation Control 

Act of 1978, do not address the relatively recent process of in-situ leaching (ISL) of uranium from 

underground ore bodies. In the ISL process, an extraction fluid is pumped underground through a set of 

injection wells to solubilize uranium, is retrieved at a central extraction well, and is then processed to 

remove the uranium and recycle the fluid back into the ground for further uranium extraction. Because 

the ISL process affects groundwater quality, the EPA’s Office of Radiation and Indoor Air requested 

advice from the Science Advisory Board (SAB) on issues related to design and implementation of 

groundwater monitoring at ISL mining sites. 

The EPA prepared a draft technical report, Considerations Related to Post-Closure Monitoring of 

Uranium In-Situ Leach/In-Situ Recovery (ISL/ISR) Sites (dated June 2011), that describes a proposed 

general approach to monitoring at ISL sites and provides case studies and key issues associated with 

post-closure monitoring. The agency requested SAB recommendations on the technical aspects of 

designing and implementing the groundwater monitoring networks at ISL uranium mines, including 

wells within the production area to compare post- and pre-operational groundwater quality, and wells 

outside the mine production area to detect the presence or absence of excursions of the leachate solution 

from the production zone.

The SAB makes recommendations concerning monitoring to characterize baseline groundwater quality

prior to the start of mining operations, monitoring to detect any leachate excursions during mining, and 

monitoring to determine when groundwater quality has stabilized after mining operations have been 

completed. The SAB also reviews the advantages and disadvantages of alternative statistical techniques 

to determine whether post-operational groundwater quality has returned to near pre-mining conditions 

and whether mine operation can be predicted not to adversely impact groundwater quality after site 

closure acceptance.
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The EPA draft technical report presents an excellent preliminary framework of considerations applicable 

to groundwater monitoring at ISL uranium mines. It emphasizes the relevance of Groundwater 

Monitoring Requirements for Treatment, Storage, and Disposal Facilities (TSDF’s) in 40 CFR Part 264, 

Subpart F, in response to the Resource Conservation and Recovery Act (RCRA). The draft report also 

gives examples of ISL groundwater monitoring data and of statistical techniques for comparing postand pre-operational monitoring data. However, although all pertinent topics are touched upon in the 

draft report, few topics contain sufficient detail to guide setting and implementing these standards. 

The SAB recommends that the EPA expand greatly this draft technical report so that it is protective and 

realistic in guiding the monitoring program and evaluating its results. To be a guide for decisions that 

are based on knowledge of both the general behavior of groundwater constituents and the conditions at 

the mine under consideration, the draft technical report should include detailed discussion of the 

following critical activities by the EPA: 

• Survey the extensive monitoring data available for ISL uranium mines to identify data sets 

suitable for building an evidence base that could inform EPA’s regulations.

• Compile and systematically analyze these data sets to define the geology and hydrology of the 

site and support modeling of the interactions between pertinent groundwater constituents and

associated geologic media. 

• Apply environmental models to provide realistic predictions of the rates at which groundwater 

constitutents approach stable conditions following the cessation of mining operations, for a range 

of realistic bounding conditions. 

• Describe systematic approaches for determining the optimal number, location, and sampling 

frequency of monitoring wells. 

• Specify criteria for selecting groundwater analytes of primary and secondary importance for 

monitoring by emphasizing the linkages between analytes and monitoring objectives.

• Consider some alternative approaches to the described statistical treatment of differences 

between pre- and post-mining groundwater quality, and recognize that other factors may have 

more influence than statistical uncertainty on the reliability of these differences.

The SAB recommends that the EPA organize the draft technical report by applying the EPA’s Data 

Quality Objectives process. Further, it advises the EPA to optimize the quality and timeliness of the 

draft technical report by inviting cooperation by the other regulators and participation by the scientific 

community in addressing the activities identified in the enclosed report.

The SAB appreciates the opportunity to provide advice on the draft technical report and engage in 

thoughtful dialogue on this topic, and looks forward to your response. 

Sincerely,

/Signed/ /Signed/

Dr. Deborah L. Swackhamer Dr. Bernd Kahn 

Chair Chair, Radiation Advisory Committee

Science Advisory Board Science Advisory Board

Enclosure
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NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board (SAB), a public 

advisory group providing extramural scientific information and advice to the Administrator and other 

officials of the Environmental Protection Agency. The SAB is structured to provide balanced, expert 

assessment of scientific matters related to problems facing the agency. This report has not been reviewed 

for approval by the agency and, hence, the contents of this report do not necessarily represent the views 

and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of 

the Federal government, nor does mention of trade names of commercial products constitute a 

recommendation for use. Reports and advisories of the SAB are posted on the EPA website at 

http://www.epa.gov/sab.
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U.S. Environmental Protection Agency

Science Advisory Board

Radiation Advisory Committee (RAC)

Augmented for Uranium In-Situ ISL/ISR Advisory

CHAIR

Dr. Bernd Kahn, Professor Emeritus, Nuclear and Radiological Engineering Program, and Associate 

Director, Environmental Radiation Center, GTRI, Georgia Institute of Technology, Atlanta, GA 

MEMBERS

Dr. Susan M. Bailey, Associate Professor, Colorado State University, Department of Environmental 

and Radiological Health Sciences, Fort Collins, CO 

Dr. Thomas B. Borak, Professor, Department of Environmental and Radiological Health Sciences, 

Colorado State University, Fort Collins, CO 

Dr. Shih-Yew Chen, Senior Environmental Systems Engineer, Environmental Science Division, 

Argonne National Laboratory, Argonne, IL 

Dr. Faith G. Davis, Senior Associate Dean and Director of Graduate Studies, Professor of 

Epidemiology, Division of Epidemiology and Biostatistics, School of Public Health, University of 

Illinois at Chicago, IL

Dr. R. William Field, Professor, Department of Occupational and Environmental Health, College of 

Public Health, University of Iowa, Iowa City, IA

Dr. Jonathan M. Links, Professor and Deputy Chair, Department of Environmental Health Sciences, 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD 

Dr. William F. Morgan, Director of Radiation Biology and Biophysics, Biological Sciences Division, 

Fundamental & Computational Sciences Directorate, Pacific Northwest National Laboratory, Richland, 

WA 

Mr. Bruce A. Napier, Staff Scientist, Radiological Science & Engineering Group, Pacific Northwest 

National Laboratory, Richland, WA 

Dr. Dale L. Preston, Principal Scientist, Hirosoft International, Eureka, CA 

Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics and 

Genetic Epidemiology, Keck School of Medicine, University of Southern California, Los Angeles, CA 

CONSULTANTS

Dr. Thomas Borch, Associate Professor, Environmental Chemistry & Biochemistry, Department of 

Soil & Crop Sciences, Joint Position in Department of Chemistry, Colorado State University, Fort 

Collins, CO 
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Dr. Douglas B. Chambers, Vice President and Director of Risk & Radioactivity, Senes Consultants, 

Ltd., Ontario, Canada 

Dr. June T. Fabryka Martin, Earth Observations Systems Group, Los Alamos National Laboratory, 

Los Alamos, NM 

Dr. Thomas E. Johnson, Assistant Professor, Department of Environmental and Radiological Health 

Sciences, Colorado State University, Fort Collins, CO 

Dr. Brian A. Powell, Assistant Professor, Department of Environmental Engineering & Earth Sciences, 

L. G. Rich Environmental Laboratory, Clemson University, Anderson, SC 

SCIENCE ADVISORY BOARD STAFF

Dr. K. Jack Kooyoomjian, Designated Federal Officer, Science Advisory Board, U.S. Environmental 

Protection Agency, Washington, DC
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U.S. Environmental Protection Agency

Science Advisory Board

CHAIR

Dr. Deborah L. Swackhamer, Professor and Charles M. Denny, Jr., Chair in Science, 

Technology and Public Policy, Hubert H. Humphrey School of Public Affairs and Co-Director of 

the Water Resources Center, University of Minnesota, St. Paul, MN

SAB MEMBERS

Dr. George Alexeeff, Acting Director, Office of Environmental Health Hazard Assessment, 

California Environmental Protection Agency, Oakland, CA

Dr. David T. Allen, Professor, Department of Chemical Engineering, University of Texas, 

Austin, TX

Dr. Pedro Alvarez, Department Chair and George R. Brown Professor of Engineering, 

Department of Civil & Environmental Engineering, Rice University, Houston, TX

Dr. Joseph Arvai, Svare Chair in Applied Decision Research, Institute for Sustainable Energy, 

Environment, & Economy, Haskayne School of Business, University of Calgary, Calgary, 

Alberta, Canada

Dr. Claudia Benitez-Nelson, Full Professor and Director of the Marine Science Program, 

Department of Earth and Ocean Sciences, University of South Carolina, Columbia, SC

Dr. Timothy J. Buckley, Professor and Chair, Division of Environmental Health Sciences, 

College of Public Health, The Ohio State University, Columbus, OH

Dr. Patricia Buffler, Professor of Epidemiology and Dean Emerita, Department of 

Epidemiology, School of Public Health, University of California, Berkeley, CA

Dr. Ingrid Burke, Director, Haub School and Ruckelshaus Institute of Environment and Natural 

Resources, University of Wyoming, Laramie, WY

Dr. Thomas Burke, Professor, Department of Health Policy and Management, Johns Hopkins 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD

Dr. Terry Daniel, Professor of Psychology and Natural Resources, Department of Psychology, 

School of Natural Resources, University of Arizona, Tucson, AZ

Dr. George Daston, Victor Mills Society Research Fellow, Product Safety and Regulatory 

Affairs, Procter & Gamble, Cincinnati, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Newark, DE
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Dr. Otto C. Doering III, Professor, Department of Agricultural Economics, Purdue University, 

W. Lafayette, IN

Dr. Michael Dourson, President, Toxicology Excellence for Risk Assessment, Cincinnati, OH

Dr. David A. Dzombak, Walter J. Blenko, Sr. Professor of Environmental Engineering, 

Department of Civil and Environmental Engineering, College of Engineering, Carnegie Mellon 

University, Pittsburgh, PA

Dr. T. Taylor Eighmy, Vice President for Research, Office of the Vice President for Research, 

Texas Tech University, Lubbock, TX

Dr. Elaine Faustman, Professor and Director, Institute for Risk Analysis and Risk 

Communication, School of Public Health, University of Washington, Seattle, WA

Dr. John P. Giesy, Professor and Canada Research Chair, Veterinary Biomedical Sciences and 

Toxicology Centre, University of Saskatchewan, Saskatoon, Saskatchewan, Canada

Dr. Jeffrey K. Griffiths, Professor, Department of Public Health and Community Medicine, 

School of Medicine, Tufts University, Boston, MA

Dr. James K. Hammitt, Professor, Center for Risk Analysis, Harvard University, Boston, MA

Dr. Barbara L. Harper, Risk Assessor and Environmental-Public Health Toxicologist, and 

Division Leader, Hanford Projects, and Program Manager, Environmental Health, Department of 

Science and Engineering, Confederated Tribes of the Umatilla Indian Reservation (CTUIR), West 

Richland, WA

Dr. Kimberly L. Jones, Professor and Chair, Department of Civil Engineering, Howard 

University, Washington, DC

Dr. Bernd Kahn, Professor Emeritus and Associate Director, Environmental Radiation Center, 

Georgia Institute of Technology, Atlanta, GA

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, 

Brown University, Providence, RI

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, 

University of Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Senior Executive, Health Research, Inc., Troy, NY

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Floyd Malveaux, Executive Director, Merck Childhood Asthma Network, Inc., Washington, 

DC
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Dr. Judith L. Meyer, Professor Emeritus, Odum School of Ecology, University of Georgia, 

Lopez Island, WA

Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, University of South 

Florida, Tampa, FL

Dr. Christine Moe, Eugene J. Gangarosa Professor, Hubert Department of Global Health, Rollins 

School of Public Health, Emory University, Atlanta, GA

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer Science, and 

Technology, California State University, Los Angeles, CA

Dr. Eileen Murphy, Director of Research and Grants, Ernest Mario School of Pharmacy, Rutgers 

University, Piscataway, NJ

Dr. James Opaluch, Professor and Chair, Department of Environmental and Natural Resource 

Economics, College of the Environment and Life Sciences, University of Rhode Island, Kingston, 

RI

Dr. Duncan Patten, Research Professor, Hydroecology Research Program , Department of Land 

Resources and Environmental Sciences, Montana State University, Bozeman, MT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, 

Department of Applied Economics, University of Minnesota, St. Paul, MN

Dr. C. Arden Pope, III, Professor, Department of Economics, Brigham Young University , 

Provo, UT

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL

Dr. Amanda Rodewald, Professor of Wildlife Ecology, School of Environment and Natural 

Resources, The Ohio State University, Columbus, OH

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive 

Medicine, Keck School of Medicine, University of Southern California, Los Angeles, CA

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, GA

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University of 

Iowa, Iowa City, IA

Dr. Gina Solomon, Senior Scientist, Health and Environment Program, Natural Resources 

Defense Council, San Francisco, CA

Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics, 

University of Southern California, Los Angeles, CA
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Dr. Peter Thorne, Professor and Head, Occupational and Environmental Health, College of 

Public Health, University of Iowa, Iowa City, IA

Dr. Paige Tolbert, Professor and Chair, Department of Environmental Health, Rollins School of 

Public Health, Emory University, Atlanta, GA

Dr. John Vena, Professor and Department Head, Department of Epidemiology and Biostatistics, 

College of Public Health, University of Georgia, Athens, GA

Dr. Robert Watts, Professor of Mechanical Engineering Emeritus, Tulane University, Annapolis, 

MD

Dr. R. Thomas Zoeller, Professor, Department of Biology, University of Massachusetts, 

Amherst, MA

SCIENCE ADVISORY BOARD STAFF

Dr. Angela Nugent, Designated Federal Officer, Science Advisory Board, U.S. Environmental 

Protection Agency, Washington, DC 
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TABLE OF CONTENTS

Acronyms, Symbols and Abbreviations.................................................................................................. x

1. EXECUTIVE SUMMARY.................................................................................................................. 1

2. INTRODUCTION................................................................................................................................ 6

2.1. BACKGROUND ON IN-SITU LEACHING MINING ............................................................................ 6

2.2. THE SAB REVIEW PROCESS......................................................................................................... 7

3. DESIGNING AND IMPLEMENTING A MONITORING NETWORK....................................... 8

3.1. INTRODUCTION ............................................................................................................................ 8

3.2. EVIDENCE-BASED DECISION-MAKING......................................................................................... 8

3.3. GUIDING PRINCIPLES AND ASSUMPTIONS FOR REGULATORY MONITORING................................. 9

3.4. INDICATORS OF INTEREST ............................................................................................................ 9

3.5. CONSTITUENT INTERACTIONS AND ENVIRONMENTAL TRANSFORMATIONS ................................. 9

3.6. SPATIAL AND TEMPORAL SAMPLING DENSITIES ........................................................................ 10

3.7. HYDRO-GEOCHEMICAL MODELING............................................................................................ 11

3.8. ESTABLISHING BASELINE GROUNDWATER CHEMISTRY............................................................. 14

3.9. POST-CLOSURE MONITORING .................................................................................................... 14

3.10. ANALOGOUS SYSTEMS............................................................................................................... 15

3.11. STANDARDIZED TERMINOLOGY ................................................................................................. 15

4. PRE-OPERATIONAL MONITORING.......................................................................................... 17

4.1. BACKGROUND INFORMATION CONSIDERED BY THE SAB .......................................................... 17

4.2. DEFINING DATA QUALITY OBJECTIVES FOR BASELINE CHARACTERIZATION ............................ 17

4.3. BASELINE CHARACTERIZATION PARAMETERS ........................................................................... 18

4.4. DRILLING AND WELL CONSTRUCTION PRACTICES..................................................................... 20

4.5. CHALLENGES FOR BACKGROUND CHARACTERIZATION ............................................................. 20

4.6. FREQUENCY AND DURATION OF MONITORING TO DETERMINE BACKGROUND .......................... 22

4.7. STANDARDIZED DATA COLLECTION .......................................................................................... 23

5. POST-OPERATIONAL MONITORING AND RESTORATION ............................................... 24

5.1. INTRODUCTION AND OVERVIEW ................................................................................................ 24

5.2. DEFINING RESTORATION GOALS................................................................................................ 24

5.3. EVALUATION OF EXISTING DATASETS ....................................................................................... 24

5.4. CRITERIA FOR COLLECTION AND ANALYSIS OF MONITORING DATA.......................................... 26

5.5. DURATION OF POST-MINING/RESTORATION MONITORING ........................................................ 27

5.6. GROUPING CONSTITUENTS FOR MONITORING ACTIVITIES ......................................................... 28

5.7. HAZARD QUOTIENT OR OTHER RISK-WEIGHTING SCHEME FOR DETERMINING RELEVANT 

ANALYTES ............................................................................................................................. 28

6. STATISTICS, DATA REQUIREMENTS AND USE .................................................................... 29

6.1. DESIGN OF WELL PLACEMENT AND SAMPLING PROGRAM......................................................... 29

6.2. STATISTICAL ANALYSIS DISCUSSION......................................................................................... 30

7. ADDITIONAL ISSUES BEYOND THE CHARGE....................................................................... 35

7.1. MONITORING OF OTHER ISL IMPACTS ....................................................................................... 35
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7.2. POTENTIAL IMPACTS ON GROUNDWATER USABILITY ................................................................ 35

7.3. ESTABLISHING DATA QUALITY OBJECTIVES.............................................................................. 36

7.4. INTEGRATION WITH OTHER EPA REGULATORY PROGRAMS APPLICABLE TO 

GROUNDWATER QUALITY ..................................................................................................... 36

7.5. TAPPING EXISTING RESOURCES FOR ENVIRONMENTAL MODELING ........................................... 37

7.6. WORKING RELATIONSHIP WITH THE NUCLEAR REGULATORY COMMISSION.............................. 38

7.7. PROMOTING PREDICTABILITY AND REDUCING UNCERTAINTY IN URANIUM MINING 

STANDARDS........................................................................................................................... 38

REFERENCES........................................................................................................................................ 39

APPENDIX A. EPA CHARGE TO THE SAB .................................................................................. A-1

APPENDIX B. WATER QUALITY PARAMETERS FOR GROUNDWATER 

MONITORING AT ISL URANIUM MINING SITES ................................................................ B-1
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Acronyms, Symbols and Abbreviations

ACLs Alternate Concentration Limits

Ca2UO2-(CO3)3 Calcium uranyl carbonate ternary complex

CFR U.S. Code of Federal Regulations

COC Contaminant of Concern

CREM Council for Regulatory Environmental Modeling

CrunchFlow Software package for multicomponent reactive flow and transport 

∆ Delta (differences) for a given criterion or allowed value; or a null 

value

δ Del; measured difference

DQO Data Quality Objective

Eh Oxidation/reduction potential compared to that of hydrogen

EPA Environmental Protection Agency (U.S. EPA)

EXAFS Extended X-ray absorption fine structure

HA Health Advisories

ISL In-Situ Leach

ISR In-Situ Recovery

MCL Maximum Concentration Level

MCLG Maximum Concentration Level Goals

MIN3P General purpose flow and reactive transport code for variably 

saturated media

MKB Models Knowledge Base

MNA Monitored natural attenuation

NACEPT National Advisory Council for Environmental Policy and 

Technology

NAS National Academy of Sciences

ND North Dakota

NM New Mexico

NRC Nuclear Regulatory Commission (U.S. NRC)

ORIA Office of Radiation and Indoor Air (U.S. EPA/ORIA)

ORNL Oak Ridge National Laboratory

ORP Oxygen/reduction potential

p Probability values (p1, p2, ....pn)

pH Negative Log Concentration of Hydrogen Ions

PHREEQC U.S. Geological Survey computer code for speciation, batchreaction, one-dimensional transport and inverse geochemical 

calculations

PAA Production Authorization Area

RCRA Resource Conservation and Recovery Act

RSL Regional Screening Levels

SAB Science Advisory Board (U.S. EPA/SAB)

SDWA Safe Drinking Water Act

SMCL Secondary Maximum Concentration Level

TAC Texas Administrative Code

TCEQ Texas Commission on Environmental Quality

TSDF Treatment, Storage and Disposal Facilities

TX Texas
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UIC Underground Injection Control

UMTRCA Uranium Mill Tailings Radiation Control Act of 1978

USGS U.S. Geological Survey

XPS X-ray absorption spectroscopy

XRD X-ray fluorescence analysis
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1. EXECUTIVE SUMMARY

The EPA is currently reviewing its regulations that establish environmental protection standards for 

uranium and thorium mill tailings (40 CFR Part 192) to determine if revisions are necessary in light of 

current mining practices. The standards are promulgated by EPA under the Uranium Mill Tailings 

Radiation Control Act of 1978 (UMTRCA). The Nuclear Regulatory Commission (NRC), or the NRC 

Agreement State in which the mine is located, issues and oversees the mine operating licenses. The 

original UMTRCA regulations, written in 1983 and revised in 1995, focused on surface and 

underground mining of uranium, which at that time were the prevalent types of uranium extraction. 

Currently, in situ leaching (ISL) is a common method of uranium extraction. ISL operations involve 

injection of uranium extraction fluids into subsurface ore bodies. Hence, the EPA is considering 

establishing standards applicable to groundwater monitoring systems at and around ISL facilities. 

The EPA’s Office of Radiation and Indoor Air (ORIA) has prepared a draft technical report, 

Considerations Related to Post-Closure Monitoring of Uranium In-Situ Leach/In-Situ Recovery 

(ISL/ISR) Sites, dated June 2011. The draft technical report provides background information concerning 

the objectives, design, and implementation of groundwater monitoring systems for ISL/ISR operations. 

Monitoring wells positioned outside the production area are used to detect excursions of leach solution 

from the production area during the operational phase. Monitoring wells within the production area are 

used pre-operationally to establish baseline conditions and post-operationally to determine when 

physical and chemical conditions in groundwater have been restored and stabilized. Part 1 of the EPA 

draft technical report presents the overall approach, including the regulatory context for EPA’s standards 

under UMTRCA; Part 2 provides details on specific issues associated with the approach, including 

monitoring at existing ISL facilities, establishing post-operational steady state, performing statistical 

analyses to compare pre- and post-operational conditions, and describing encountered post-closure 

performance issues. 

The EPA requested that the Science Advisory Board (SAB) provide feedback on the draft technical 

report and respond to four charge questions. The first charge question requests comments on the 

technical aspects of designing and implementing the groundwater monitoring networks described in the 

report, and identification of any omitted or mis-characterized technical considerations. The remaining 

questions relate to characterization of baseline groundwater quality in pre-operational monitoring and 

the monitoring duration needed; approaches for monitoring post-operational phases and determining 

when groundwater quality has stabilized adequately based on post-operational monitoring data; and 

statistical techniques and data requirements to compare post- to pre-operational (baseline) monitoring 

for determining whether groundwater quality has met the applicable regulatory standards.

The SAB finds the draft technical report to be an excellent framework of considerations applicable to 

groundwater monitoring at ISL uranium mines. Application of statistics and the Resource Conservation 

and Recovery Act (RCRA) regulations to groundwater monitoring is discussed in detail. Other 

important aspects are mentioned, e.g., planning, well location, sampling frequency, selection of analytes

for monitoring, and modeling, but are not discussed in sufficient detail.

The SAB recommends that the EPA greatly expand its discussion of specified topics in the draft 

technical report to provide a more substantive foundation for developing and evaluating EPA standards 

related to ISL uranium mining. The draft technical report should be a guide for effectively and 

realistically protecting the environment and human health by combining general information on the 
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behavior of groundwater constituents with specific information on their concentrations and 

concentration changes at the mine.

Two critical interrelated aspects of the draft technical report that would benefit from enhancement 

concern the availability of environmental data and application of models. To build an evidence base 

adequate for informing EPA’s regulations, the SAB recommends that the EPA survey the extensive data 

collected at ISL uranium mining sites by monitoring, regulatory, and research groups, and that it 

compile systematically those data that are of suitable scope and quality to support modeling interactions 

between pertinent groundwater constituents and associated geologic media. A closely-related topic is the 

application by the EPA of environmental models to predict the groundwater’s approach to stable 

conditions following the end of mining operations. Examples of applying such models for a range of 

realistic bounding conditions would be a useful addition to the draft technical report. Another modeling 

topic is that the EPA apply statistical models to support decisions concerning the optimal number, 

location, and sampling frequency of monitoring wells.

Another topic is identifying criteria for selecting analytes of primary and secondary importance for 

monitoring and listing their required detection limits and data precision. The examples of groundwater 

monitoring data sets presented in attachments to the draft technical report will be far more instructive 

when accompanied by agency comments concerning their virtues, shortcomings, and applicability 

beyond the specific mine to the broad category of monitoring ISL uranium mines. In an integrated 

program of monitoring and modeling with built-in feedback, monitoring results are used to validate the 

model, while model output is used to assure appropriate monitoring system design.

Regarding the discussion in the draft technical report of statistical approaches for evaluating the 

reliability of difference between post- and pre-mining measurements of groundwater constituent 

concentrations, the EPA should address two additional aspects. For certain purposes, parametric models 

and Bayesian methodology can be useful alternatives to the presented non-parametric statistical 

treatment. More broadly, a well-designed sampling program and reliable measurements can be far more 

important than the statistical uncertainty in assuring reliable results.

The EPA is encouraged to address its technical objectives systematically by applying the EPA’s Data 

Quality Objectives (DQO) approach, and to address them efficiently by including participants from 

other regulatory agencies and the research community. In the near term, the EPA can develop a set of 

guiding principles and assumptions to specify its concept of an appropriate groundwater monitoring 

system, within the limitations of the information currently available to the Agency. Over the long term, 

e.g., a 3- to 5-year period, a reasonable target would be to have in place a systematic data base and 

validated models with defined precision and limitations that can be used as a basis for ISL uranium mine 

standards and decisions concerning post-mining stability of groundwater quality.

The SAB offers the following specific recommendations which are discussed in the report in more 

detail.
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Designing and Implementing a Monitoring Network (Charge Question 1):

• Develop a long-term (e.g., 3-5 year) program of data analysis and model development for 

defining the geology and hydrology of the site as a basis for setting evidence-based standards 

(see section 3.2);

• In the near-term, articulate a set of guiding principles and assumptions for standards setting (see 

section 3.3);

• Identify indicators, both chemical and radioactive, for establishing conditions pre- and postoperationally (see sections 3.4, 4.3); 

• Specify criteria by which to distinguish between primary and secondary indicators on basis of 

risk, return to pre-operational or other predetermined conditions, and information concerning 

other constituents (see section 3.4);

• Discuss in detail the many factors that affect interactions and transformations during and after 

operation (see section 3.5);

• Obtain and analyze geological and mineralogical data to support decisions based on groundwater 

monitoring (see sections 3.5, 5.5);

• Before adequate modeling has been developed, specify a sufficiently dense spatial and temporal 

monitoring system to assure collecting sufficient data for pre- and post- mining comparison (see 

section 3.6);

• Consider applying available groundwater models relevant to ISL uranium mines (see sections

3.7, 7.5);

• Support research for providing both empirical values and model coefficients for understanding 

the approach to stability after ISL uranium mining (see section 3.7);

• Develop individual modules if needed to reduce the complexity of groundwater models (see 

section 3.7);

• Devote at least as much effort to defining baseline groundwater conditions as to post-operational 

trend monitoring see sections 3.8, 5.6); and

• Prepare a glossary of uniform definitions for use by pertinent regulatory agencies and mine 

operators (see section 3.11).

Establishing Baseline Conditions (Charge Question 2):

• Define monitoring objectives of baseline characterization within the framework of the Data 

Quality Objective (DQO) approach (see sections 4.2, 7.3);

• Identify groundwater constituents and parameters pertinent for monitoring, not limited to those

with regulatory limits but also including non-hazardous constituents that can affect the behavior 

of, or serve as surrogates for, constituents of interest (see section 4.3);
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4

• Consider challenging and fluctuating ambient circumstances in baseline characterization (see 

sections 4.5, 3.4); 

• Build in flexibility to modify the design and implementation of monitoring programs as new 

information becomes available (see section 4.6); and

• Apply consistent sample collection techniques, record keeping, and data compilation (see section

4.7).

Post-Mining and Restoration Monitoring (Charge Question 3):

• Carefully qualify the meaning of “return to pre-operational groundwater quality” (see sections

5.2, 3.11);

• Develop a set of guiding principles for crafting standards (see sections 5.2, 3.3);

• Combine the extensive existing data sets with knowledge of constituent interactions in the 

rock/water system to model post-mining approach to stability (see sections 5.3, 3.2);

• Match sampling frequency and duration to information needs for model confirmation (see 

section 5.5);

• Collect sufficient pre-operational groundwater monitoring data to support reliable postoperational decision making (see sections 5.6, 3.8);

• Discuss implications of data presented in tables in the Attachments to the draft technical report 

(see section 5.7); and

• Apply a risk-weighting system in determining acceptability of groundwater quality at ISL 

uranium mines (see sections 5.7, 3.4). 

Statistical Techniques (Charge Question 4):

• Present a survey of methods to determine sufficient well number and density (see sections 6.1, 

3.6); and

• Select statistical evaluation approach in terms of strengths and weaknesses to suit questions to be 

answered (see section 6.2).

Additional Advice Beyond the Charge

The SAB also commented on several topics beyond the charge to support preparation of the enhanced 

draft technical report. These topics concerned:

• Monitoring media other than groundwater for potential contaminants (see section 7.1);

• Considering plans for groundwater use that may be impacted by ISL uranium mining (see section

7.2);

• Elaborating on recommendations for applying the DQO framework to establishing technical 

approaches to standard setting (see section 7.3);
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5

• Adding other considerations for integrating EPA requirements with existing EPA regulatory 

programs (see section 7.4);

• Tapping available resources for the recommended modeling (see section 7.5);

• Encouraging the working relation of EPA staff with NRC or state agency staff (see section 7.6);

and

• The importance of this regulatory review and update (see section 7.7).
.

6

2. INTRODUCTION

2.1. Background on In-Situ Leaching Mining 

Uranium mining by in-situ leaching (ISL) was developed during the past 50 years (U.S. Bureau of 

Mines, 1981; Charbeneau 1984; U.S. EPA 2008) and the first commercial ISL mine was licensed in 

1975. Currently, ISL mining is preferred to surface and underground mining for a suitably contiguous 

ore body located in a porous aquifer between effective confining layers. Although uranium mining in the 

United States has been quiescent during the past decade, potential mine operators have expressed 

renewed interest in uranium mining by ISL. Following the July 18-19, 2011 public face-to-face meeting, 

a meeting participant provided a list of 32 former or currently active ISL mines as well as an additional 

16 sites for which ISL license applications had been submitted (John Cash, personal communication, 

September 7, 2011). These estimates appear largely consistent with publicly available information about

uranium recovery licenses and license applications under the purview of the NRC 

(http://www.nrc.gov/materials/uranium-recovery/license-apps.html) and Agreement States, primarily 

Texas, in which licenses are issued by the Texas Commission on Environmental Quality (TCEQ) 

(http://www12.tceq.state.tx.us/crpub/).

In the ISL mining process, a uranium-solubilizing extraction fluid (i.e., lixiviant) is delivered to the 

subsurface ore body through a set of injection wells and is withdrawn at a central recovery well. An ISL

mine consists of many such units. The recovered lixiviant is contacted at a surface facility with ionexchange or solvent extraction media to extract the dissolved uranium, restored to its initial extraction 

strength, and returned through the injection wells for further uranium dissolution and extraction. The 

mining process is terminated after a period of time (that may exceed 10 years) when the operator deems 

that production no longer is profitable. The lixiviant then is replaced by groundwater (possibly

augmented by suitable reagents) that initially is cycled through the injection and recovery wells (“pump 

and treat”) to restore the site groundwater to its pre-operational quality.Water from early restoration

cycles that contains residual lixiviant is most often treated with reverse osmosis and returned to the 

wellfield (John Cash, written communication, December 20, 2011). Brine generated from the reverse 

osmosis treatment is typically sent to an evaporation pond or pumped into a disposal well.

According to a simplified concept, the uranium-solubilizing reagents in the lixiviant function by 

oxidizing uranium(IV) to uranium(VI) and forming soluble complexes with the resulting uranium ion; 

reagents such as oxygen plus carbon dioxide gases are used because they are effective and have less of 

an impact on the aquifer than do other harsher chemicals. Other reagents such as hydrogen peroxide, 

ammonia, bicarbonates, and acids will also leach uranium. Restoring groundwater quality after mining 

by flushing the aquifer with water, with water plus reagents intended to restore water quality, or by 

natural attenuation (without human intervention) are alternatives that have been considered. If additional 

restoration efforts are needed, reagents may be added to reduce uranium to its original insoluble 

uranium(IV) form, and to make insoluble any other ions, such as arsenic and molybdenum, that were 

dissolved or released by the lixiviant. In practice, the ongoing processes in the ground during mining and 

restoration are considerably more complex, as must be the efforts to return the system to its original 

form. 

Regulation of radiological and non-radiological hazards associated with uranium and thorium ore 

processing involves multiple federal agencies. Under the Uranium Mill Tailings Radiation Control Act 

of 1978 (UMTRCA), the EPA has the responsibility to establish health and environmental protection 

standards in 40 CFR Part 192. The NRC in 10 CFR Part 40—or an agency in its Agreement State—

controls mine operation under UMTRCA at active (Title II) sites by license conditions and guidance 
.

7

(U.S. NRC 2003). The U.S. Department of Energy (DOE) is responsible for control of inactive (Title I) 

mining and milling sites.

Before ISL mining operations can begin, the aquifer in which ISL mining is proposed to take place must 

be designated an “exempted aquifer” by the EPA, meaning the aquifer is exempt from the requirements 

for protection of groundwater as an underground source of drinking water under the Safe Drinking 

Water Act (SDWA) (see Section 7.2). Secondly, the ISL mine operator must obtain permits for lixiviant 

injection wells from the EPA’s Underground Injection Control (UIC) program developed pursuant to the 

SDWA (in some cases, the authority to issue UIC permits has been delegated to states) (EPA 2011a).

The mine operator must monitor groundwater before starting mining operations, in order to establish the 

groundwater quality baseline within and around the mine units, and must continue to monitor 

groundwater during and after operational phases in order to detect pollutant excursion beyond the mine 

units. Post-operational groundwater quality then must be monitored on site until it becomes acceptable 

or reaches steady state. This finding signals that no further monitoring is needed to detect constituent 

instability within the mining area. The EPA, in support of revising 40 CFR Part 192, intends to establish 

standards for determining the duration of monitoring for those substances of which steady-state 

attainment and/or return to pre-operational quality is required.

2.2. The SAB Review Process

The EPA requested technical advice in the form of an Advisory Review from the SAB to support 

revision of 40 CFR Part 192 regarding issues relevant to groundwater monitoring for both stable and 

radioactive substances at ISL uranium mining sites. The charge from the EPA (Appendix A) focuses on 

achieving reliable analyte results -- both radiological and non-radiological -- in groundwater monitoring 

before, during, and after ISL mining. In particular, the charge asks for advice on important aspects that 

contribute to confidence in data reliability: (1) monitoring network design; (2) effective baseline 

monitoring; (3) restoration-phase monitoring to define trends in groundwater constituents and ultimate 

arrival at stability; and (4) use of appropriate statistical techniques and data processing for reliable 

conclusions.

As background for the SAB, the agency developed a draft technical report, Considerations related to 

post-closure monitoring of uranium in-situ leach/in-situ recovery (ISL/ISR) sites (dated June 2011), to 

describe the proposed overall approach and specific monitoring issues. The draft technical report 

addresses groundwater monitoring for both stable and radioactive substances. It is concerned principally 

with designing a monitoring program and comparing post- and pre-operational monitoring data. It 

specifies 5 successive phases of groundwater monitoring: baseline (pre-operational), mining 

(operational), restoration (immediate post-operational), steady state attainment (post-treatment) and 

long-term stability assurance (post-closure). For the crucial action of comparing post- and preoperational data, the report discusses applicable statistical techniques for indicating that the two data sets 

are or are not identical. Some data sets submitted by ISL mine operators to the licensing agency are 

attached to the EPA’s draft technical report as examples.

To respond to the EPA charge, the SAB’s Radiation Advisory Committee (RAC)—augmented with 

additional experts in the areas of environmental statistics, geochemistry (including soil chemistry), 

geology, geostatistics, hydrogeology, environmental monitoring, and radiation health science—held 

public meetings on July 12, July 18-19, September 6, and October 5, 2011 to receive technical briefings 

from the agency, hear public comments, and deliberate on the charge questions. Public commenters,

including a hydrogeologist from the NRC, identified useful sources of information related to 

groundwater monitoring at ISL uranium mines. The augmented RAC’s draft advisory report was 

provided to the chartered SAB in November for review and disposition in a December 21, 2011 public 

meeting.
.

8

3. DESIGNING AND IMPLEMENTING A MONITORING NETWORK

Charge Question 1: Comment on the technical areas described in the report and their relative 

importance for designing and implementing a monitoring network. Identify any technical 

considerations that have been omitted or mis-characterized. 

3.1. Introduction

For purposes of this report, the SAB treats the concept of a “monitoring network” as:

• a spatially-distributed network of monitoring wells;

• a time-dependent series of measurements via those wells;

• a set of constituent indicators that are quantified;

• additional geophysical and geochemical measures made or assumed; and

• underlying conceptual and/or kinetic models that:

o provide the technical basis for network design and implementation, and 

o make use of the data collected from wells in the network.

The SAB makes two general recommendations – one long-term (Section 3.2), and one for the near term 

(Section 3.3) – as well as several specific recommendations (Sections 3.4 to 3.11).

3.2. Evidence-Based Decision-Making

The SAB recommends that the scientific/technical approach to designing and implementing a 

monitoring network for ISL uranium mining sites be evidence-based, or at least evidence-informed. The 

discussion with EPA staff, NRC staff, and members of the public associated with ISL uranium mining

operations during the face-to-face meeting suggested that considerable monitoring data pertinent to 

designing and implementing groundwater monitoring networks are available but that only a limited 

fraction of this information was incorporated into the draft technical report. Empirical site-specific 

approaches form the basis of discussions in the draft technical report and were emphasized during the 

presentations. Data would need to be collected, organized, and analyzed in a comprehensive and 

standardized way (e.g., via standardized reporting protocols) in order to build the evidence base to 

inform the regulatory approach, as sketched in a flow chart in Figure 1 (at the end of Section 3). 

Accordingly, the SAB recommends for the long term that EPA initiate and maintain a formal process to 

build this evidence base in, say, 3 to 5 years. Most importantly, the information should contribute to 

defining the geology and hydrology of the site. Ideally, the data to be collected should include (1) the 

constituents used for baseline characterization, (2) constituent concentrations observed immediately 

upon completion of mining but prior to restoration, and (3) concentration trends observed as the 

groundwater approaches acceptable and sustainable conditions following restoration. Data from 

monitoring wells, including information on excursions during operation and subsequent recovery, 

should be gathered to provide examples of the groundwater situation. 

The extensive data reported to be available are not in one place or in one format, nor of equal quality. 

Mining companies have accumulated baseline data to support the mining license applications and to 

justify the proposed monitoring network design to the regulator. These data can be used for validation in 

hydro-geochemical modeling efforts to aid in determining system behavior during baseline, operational, 

and post-operational stages. Even for hydro-geochemical systems that differ widely, physical and 

chemical principles that apply universally will allow application of such modeling. Ready accessibility 

of the available information to the public will facilitate analysis and modeling by the scientific/technical 
.

9

community and enhance public trust. As seen for other data sets (e.g., RadNet following the recent 

nuclear power plant accidents in Japan), the scientific community is eager to perform some of the work 

that the EPA would otherwise be expected to do. Hence, results will be available sooner because of the 

distributed, parallel effort.

3.3. Guiding Principles and Assumptions for Regulatory Monitoring

The SAB recommends for the near term, until the needed large evidence base is accumulated and 

systematized, that the EPA articulate a set of guiding principles and assumptions on which to base

regulations. The proposed standards can be based on these assumptions during the next several years, 

and superseded if evidence of their unsuitability becomes available. For example, assumption of 

seasonality in groundwater quality will require seasonal measurements for more than one year (as 

discussed in Section 6.2.4). If the reviewed data, for example, show that no seasonality is observed, or 

that the concept of seasonality should be replaced by groundwater quality response to monthly rainfall 

or major rain events, the sampling frequency specification would be changed. 

3.4. Indicators of Interest

The SAB recommends that the EPA identify, in addition to pertinent groundwater constituents, sets of 

indicators to assist in establishing baseline conditions and post-closure monitoring conditions, with

direct linkage between the baseline and post-closure indicators. Indicators can include: (1) specific 

radionuclides, by mass concentration or radioactivity, as appropriate; (2) gross radioactivity, by alphaparticle, beta-particle, and gamma-ray activity; (3) water quality (e.g., total dissolved solids); and (4) 

geophysical and geochemical variables. The latter can indicate groundwater status, serve as surrogates 

of status or prognostic indicators, or influence constituent values (e.g., pH, flow). Where appropriate, the 

physico-chemical form (e.g., speciation, oxidation state, solubility) of the constituents should be 

determined. Section 4.3 expands upon this recommendation from the perspective of background 

characterization data.

Because this list of indicators could be extensive, the SAB recommends that the EPA specify criteria by 

which to distinguish between primary and secondary indicators. Such categorization can be helpful in 

risk-weighting the indicators for use in regulatory decision-making (see Section 5.7). Not all indicators 

will behave the same way post-closure compared with baseline conditions. Risk from a given 

groundwater constituent is itself dependent on both its intrinsic toxicity and its concentration, so that 

what constitutes a primary versus secondary indicator may depend on the locality.

Calculating average baseline values on a sitewide basis may be inappropriate for some constituents if, 

for example, the ISL uranium mine is located within a roll-front deposit, where concentrations of some 

constituents show sharp trends over short distances reflecting the onset of reducing conditions that 

precipitate uranium minerals. Hence, baseline measurements should include those made outside the

proposed production zone, e.g., hydraulically upgradient, downgradient or tangential to the direction of 

groundwater flow through the uranium deposit (also see Section 4.2). 

3.5. Constituent Interactions and Environmental Transformations

The SAB recommends that the EPA draft technical report discuss how the composition of groundwater 

and minerals in the production zone may be modified by:

• mass balance issues of the lixiviant/extraction fluid, particularly the fate of excess lixiviant 

injected into production areas;

• changes in microbial communities and activity;
.

10

• environmental transformations associated with lixiviant flow and composition; and

• impacts of external changes caused, for example, by nearby activities or groundwater 

movement.

These effects arise from interactions among constituents, environmental transformations, and other 

processes acting on the constituents and aquifers that produce (potentially linked) changes in indicators 

over time in mining and restoration processes that should be anticipated and documented. Some of this 

information for a site can be derived from experience at other sites, but other information will require

on-site monitoring data and possibly specific studies.

The SAB recommends that geological monitoring information also be obtained from samples of 

formation material collected pre- and post-mining to characterize mineralization because the ability to 

solubilize or oxidize constituents will depend on the geochemistry of the solid phase (e.g., Stewart et al. 

2000). Some surface spectroscopies (e.g., X-ray absorption spectroscopy [XPS], extended X-ray 

absorption fine structure [EXAFS]) and mineralogical analyses (e.g., X-ray fluorescence analysis

[XRD]) can be helpful to characterize the preexisting minerals and their surfaces within the secondary 

pore system. Also collected should be information relevant to modeling the aquifer for understanding 

groundwater flow and predicting future concentrations of constituents both on- and off-site. The 

information collected can be utilized to evaluate the potential for mobilizing constituents off-site that 

may impact human health. 

3.6. Spatial and Temporal Sampling Densities

Ultimately, the purpose of monitoring is to determine the concentration distribution (in space and time) 

of constituents or indicators of interest at baseline, during mine operation, post-closure, and postrestoration. The space and time patterns of the indicators, the sampling scheme, and the regulatory 

requirements must match. That is, monitoring should reflect the expectations implied by the regulations, 

which themselves should reflect the underlying anticipated geo-physico-chemical behavior of the 

constituents.

A crucial aspect of monitoring is the detailed spatial and temporal sampling scheme. Sampling is often 

performed in a regular pattern (i.e., on a grid in space and at equal intervals in time). The optimum 

spacing required in space and time (i.e., that spacing which accurately reflects the underlying 

distribution) – or conversely, the sampling density – is ultimately determined by the distributions of the 

constituents of interest. A fundamental approach to determining sampling is by the Nyquist sampling 

theorem (Oppenheim and Schafer 2010), which states that sampling must occur at twice the highest 

frequency (spatial or temporal) present in the signal. In this case, the “signal” is the spatial and temporal 

distribution of the constituents of interest. If constituent concentration changes slowly across space or 

time, then fewer samples, spaced further apart, are appropriate. If the concentration changes more 

rapidly in space or time, then sampling density must correspondingly increase. 

While the Nyquist sampling theorem will indicate the sampling needed to portray accurately the space 

and time distribution of any constituent, it can result in collecting more data than necessary if the 

regulations do not require fully mapping the space and time distribution of constituents of interest. 

Accordingly, the Nyquist sampling theorem should be viewed as giving the upper bound on sampling 

density, not the required scheme per se.

The above considerations lead to a paradox: to determine the optimum sampling scheme, the space and 

time distributions of the constituents have to be known in advance. In practice, the SAB recommends 

that a combination of existing data and modeling be used to obtain some information about the general 
.

11

behavior of constituents in space and time. That is, models can be developed that incorporate the 

anticipated variation across mine sites; model development will be aided by existing data from a variety 

of active and closed mine sites at hydro-geochemically similar locations. The models can be validated 

initially with those existing data. Models can then be used to predict the range of constituent behaviors 

likely to be observed at subsequent mine sites as a basis for setting sampling requirements.

For example, sampling in time can reflect the anticipated time-varying time constants of the anticipated 

temporal kinetics. Because much of the rapid change in post-closure conditions occurs immediately 

post-closure, more frequent sampling should occur during that initial period. This is consistent with, for 

example, an assumption of first-order rather than zero-order kinetics. 

The SAB recommends that the EPA provide additional discussion in its draft technical report on the 

following important monitoring issues:

• Spatial or temporal hotspots (and distinguishing from random outliers);

• Behavior of individual wells vs. the average behavior of the pooled wells;

• Seasonality or other periodicity;

• Trends related to environmental factors (e.g., groundwater flow, rainfall);

• Measurement accuracy and precision; and 

• Long-time events that can affect baseline or post-closure monitoring, such as extreme 

weather cycles.

3.7. Hydro-geochemical Modeling

3.7.1. Role of Hydro-geochemical Modeling

During the face-to-face meeting and teleconferences, much time was spent discussing the need or desire 

to have a modeling component that can predict the chemical and physical (and possibly biological) 

processes occurring during ISL uranium mining and the post-mining restoration phase. Concern was 

expressed that models capable of capturing the complex kinetic and thermodynamic behavior, 

particularly immediately following the end of active mining, are mentioned but not presented in detail in 

the draft technical report. This issue is particularly significant given the need, ultimately, to rely on 

natural attenuation processes to restore groundwater to an acceptable and sustainable quality within a 

reasonable time frame. 

The SAB recommends that the EPA expand its draft technical report to:

• elaborate on the potential roles of modeling to inform decision-making during each of the

different phases of ISL mining;

• identify best practices for establishing a baseline mineralogical and hydrogeologic model of 

an intended ISL site;

• summarize current capabilities and gaps in the use of models to predict the effectiveness of 

natural attenuation at sites spanning a range of operational conditions (such as type and 

amount of lixiviant injected) and restoration practices (such as sweep volumes); and

• discuss how an ISL uranium mine operator could design a site-specific monitoring strategy to 

confirm that natural attenuation processes are at least as effective as predicted.
.

12

3.7.2. Characteristics of a Baseline Site Model 

As recognized by the draft technical report, ISL operations represent a massive redox/geochemical 

transient perturbation of a spatially complex reduced porous ore body that imposes dramatic changes on 

a mostly equilibrium-governed geochemical condition. How the initial condition is described is essential 

to understanding the eventual rebound. The SAB recommends that the EPA’s draft technical report 

discuss best practices for establishing a baseline mineralogical and hydrogeologic model of an intended 

ISL site. The better the baseline model, the better all subsequent leaching/recovery/monitoring efforts

will be. Ideally, a baseline model includes a three-dimensional understanding of the geologic formation, 

aquifer/aquitard mapping, hydraulic gradients, pump test response at various scales, geotechnical 

fracture mapping at various scales, and transmissivity. 

Reactive transport in the formation can be described on many different scales, but much of the modeling 

focus needs to be on understanding of the primary and secondary fracture surfaces and their existing 

weathered mineralogies in the unperturbed formation. Most sandstones hosting uranium deposits can 

have complex porosities; they can be loosely cemented with significant inter-granular (primary) porosity 

or tightly cemented with secondary fracture (or microfracture) porosity with relatively high surface area 

to volume ratios. The draft technical report can benefit from a section that emphasizes and discusses 

these issues in detail.

3.7.3. Existing Models and Modeling Gaps

The best hope to inform decision making about ISL design, operations, restoration, closure and 

monitoring will come from the application of reactive transport models that are rich in thermodynamic 

databases for redox couples, reactive surfaces, sulfur/iron/carbonate minerals, surface 

sorption/precipitation reactions, and kinetic modules. This is discussed in the draft technical report but 

deserves more attention. The SAB recommends that the EPA’s draft technical report discuss the 

applicability of available models that have been developed and used to address similar situations. Such 

models have been used by the EPA, by industries other than ISL uranium mines, and in different 

applications (see Sections 3.10 and 7.5). For example, numerous geochemical modeling software 

packages are readily available with the capability for modeling equilibrium fluid speciation, and redox, 

sorption, and precipitation reactions for specific hydro-geochemical conditions. Examples of these 

models include PHREEQC (Parkhurst and Appelo 1999), The Geochemist’s Workbench® (Bethke and 

Yeakel 2009) and CrunchFlow (Steefel 2009). New developments in this field and their incorporation by 

the Agency will be of benefit. The reactive-transport code MIN3P is one such example, with common 

heritages to other models, but with particular applicability to pyrite-dominated heterogeneous and 

porous systems (e.g., Mayer et al. 2002).

The SAB recognizes limitations in existing models, such as the inability of most models to capture 

chemical reaction kinetics. At the relatively low groundwater flow-rates for many ISL uranium mines, 

local equilibrium can be assumed with respect to aqueous complexation and sorption reactions, thereby

allowing use of thermochemical modeling databases for those reactions. The kinetics of mineral 

dissolution, precipitation and transformation remain unknown for many systems, but should be 

considered to the extent possible. 

Knowledge gained from modeling the geochemical evolution of a site is valuable and worth the effort to 

the extent that the considerations listed above can be addressed. At a minimum, the EPA can consider 

adapting these existing models for application to the ISL technology to gain technical insight into the 

performance of ISL operations and their associated monitoring networks. The feasibility of modeling 

can be evaluated by comparing predicted results with monitoring data, which appear to be abundant. The 
.

13

modeling efforts will complement the monitoring data to support assessment of the impacts of site 

operations on groundwater quality, and will provide lessons learned for future licensing of similar 

operations. 

The SAB recommends that research be undertaken to obtain empirical values of time-frames and (spatial 

and temporal) rate constants/reaction rates to validate kinetic models. These models should include 

components (both causal and mediating), interconnections, and sensitivity (e.g., by perturbation 

analysis) and consider the following areas (at a minimum level): 

• Geochemical modeling with chemical reaction kinetic equations and equilibrium 

thermodynamic equations, as appropriate;

• Evaluation of an appropriate kinetic model (e.g., first order for both spatial and temporal 

kinetics);

• Incorporating natural attenuation processes such as sorption and the formation of secondary 

minerals, and the effects of redox conditions and microbial activities on these processes 

(Ford et al. 2008, Li et al. 2011, U.S. EPA 2010);

• Need for a conceptual (physical) model; and

• Interplay between data collection and modeling (see Figure 1).

3.7.4. Benefits of a Validated Model

As noted above, the draft technical report should describe in detail the needed efforts, recognizing that

the regulator can provide licensing conditions and guidance for operating a specific mine. The SAB 

views modeling as a tool to assist in the design of remediation and monitoring strategies. For example, a 

reliable model may help identify the areas at risk and in need of monitoring at baseline and after 

restoration attempts, and in interpreting monitoring results. Modeling can assist in developing a good 

monitoring design, but cannot make up for poor design. Modeling also can help to inform and formulate 

the sampling requirements to be included in the regulation, such as consideration of seasonal effects. A 

validated model might also provide a sufficient technical basis for reducing the level of characterization 

needed for a particular site.

The primary comparison between baseline (pre-operational) and post-operational conditions is the 

concentration of various analytes in the groundwater and other water quality parameters. The SAB 

acknowledges that practical considerations must be taken into account when performing baseline 

determinations and evaluating post-closure performance of a site. For example, a complete 

mineralogical characterization of the site during baseline and post-closure periods provides complete 

evidence of long-term site stability, but this level of characterization is impractical from physical and 

economic viewpoints. Therefore, a reliable validated model that can predict the evolution of the 

groundwater chemistry based on the behavior of the entire system (aqueous and solid phase 

components) will be helpful. If a single integrated model cannot be developed to serve this purpose, an 

alternative approach is to develop and test a set of process-scale models or modules that can be used 

collectively to achieve the same objective. 

The SAB recommends that, based on these considerations, the EPA develop or apply a geochemical 

model (or a series of individual modules) that can reproduce observed data from an existing ISL mine.

The intent of this modeling effort will be for the EPA to have a model that can be validated by field 

measurements and then used to predict the likelihood that a site will achieve its restoration objectives 

within a given time frame. An important unknown is how long post-restoration monitoring must occur 

before the site is released for other uses. A reliable model would be capable of making this prediction 
.

14

and, if valid kinetic data are incorporated, show that the groundwater quality at a site will or will not

attain steady-state conditions comparable to that of the baseline. 

This information will give the EPA the ability to set a fixed time or guiding principles for postrestoration monitoring at various sites. The current common practice of setting a default six-month or 

one-year monitoring period, subject to extension if post-closure monitoring goals have not been met

(U.S. EPA 2011a, page 2), is not based on scientific knowledge supporting the adequacy of such a 

requirement. A reliable model also will give the EPA a technically defensible method for establishing 

guiding principles for the number of wells for groundwater characterization and monitoring required at a 

site and the frequency with which the wells must be sampled. 

The power of the modeling efforts described above will be in the knowledge gained to craft the 

regulation. Due to the high degree of variability the modeling programs may have, it seems technically 

burdensome to require a complete hydro-geochemical model of every site and it is unclear at this early 

stage how the parameters of the modeling efforts would be regulated (e.g., the choice of modeling code).

That site-specific considerations must be applied is well understood due to the heterogeneity across ISL 

uranium mines. For this reason, model development has to rely heavily on field information gathered 

from the sites.

The modeling effort is closely related to the effort for ascertaining ground truth; the better the 

information, the more accurate the model prediction. The wealth of site data should be incorporated into 

the modeling effort. Conversely, any limitation identified in modeling should become a topic for future 

research. The real intent is to understand fully the physical/chemical processes occurring within a site. 

To accomplish that, modeling can be used effectively in combination with site characterization and 

environmental surveillance. With such level of understanding, the EPA will be capable of producing a 

consistent set of guiding principles that are technically defensible. 

3.8. Establishing Baseline Groundwater Chemistry

The SAB recommends that at least as much effort should be devoted to establishing baseline conditions 

as is put into post-closure monitoring. Critical considerations include:

• Spatial and temporal patterns (e.g., seasonality, annuality);

• Effects of changes in groundwater volume per se on baseline conditions;

• Key geochemical constituents that control the mobility of hazardous constituents;

• Data needed to estimate the extent to which natural attenuation processes can be expected to 

restore groundwater to an acceptable and sustainable quality after restoration;

• Other data needed to develop and validate hydro-geochemical models to inform decisions on 

characterization, restoration, closure, and monitoring; and

• Drilling and sampling techniques to ensure collection of reliable and representative data.

This topic is discussed in detail in Section 4.

3.9. Post-Closure Monitoring

The issues inherent in establishing baseline conditions also pertain to post-closure monitoring. While the 

restoration process is intended to return the aquifer to its pre-mining or other predetermined state, both 

mining and restoration are dynamic processes that themselves introduce spatial and temporal 

instabilities. Considerations include:
.

15

• Spatial and temporal extent of perturbations to the aquifer;

• Comparability (e.g., same monitoring wells) to baseline;

• Modeling trend of return to stability; and

• Indicators and their concentrations used as acceptability criteria.

This topic is discussed in detail in Section 5.

3.10. Analogous Systems

Sampling, monitoring, analyte selection, and modeling issues have also been considered for analogous 

systems in which massive transient redox/geochemical perturbations occur: landfill leachate plumes, 

acid mine drainage plumes, and subsurface reactive barriers. For these analogues, progress has been 

made in identifying issues around spatially complex and porous geology, time/scale/rebound, 

equilibrium versus kinetic reactions, redox couples that best indicate the dominant redox system, issues 

around groundwater sampling under reduced conditions, and model application. The draft technical 

report would benefit by addressing more fully the applicability of these analogues to monitoring 

groundwater in the vicinity of ISL uranium mining sites.

3.11. Standardized Terminology

The SAB recommends that the EPA pursue cross-agency adoption of standardized definitions for key 

terms such as excursion, contamination, and “return to pre-operational groundwater quality.” For 

example, the term “excursion” has been defined in different regulations and guidance documents related 

to ISL monitoring as:

• transport of contaminants beyond the exempted portion of the aquifer (U.S. EPA 2011a, 

Section 2.3);

• an elevated reading within the mining field (that indicates the potential for contamination)

(U.S. NRC 2011); and

• the movement of mining solutions, as determined by analysis for control parameters, into a 

designated monitor well (Texas Administrative Code, TAC Rule §§331.2).

The SAB similarly found various definitions of the term “contamination” in regulatory requirements, 

guidance, and site operating licenses. The NRC applies this term to the detection of contaminants or 

elevated constituents at a well beyond the boundaries of the mining field (see also Section 5.2).
.

16

Figure 1. Flowchart representing the coupling of data and modeling analyses to generate an evidenceinformed regulatory approach and methodology. (

a The terms “parameters and sampling paradigms” refer to a 

consistent approach or methodology for determining the monitoring requirements at a given site, while 

recognizing that the requirements themselves are site-specific.)

Validate

Build

Collect and collate data on the spatial/temporal patterns of main constituent behaviors 

and other parameters pre-, during, and post-mining. 

Extract information from the data to generate predictors of: 

• Trends (kinetic and thermodynamic),

• Primary vs. secondary constituents and linkages, and

• Hydrologic, geologic, and lithologic parameters.

Build and validate kinetic models.

Build conceptual model with predictive and explanatory power.

Identify measurement parameters of importance (primary and secondary).

Determine data sampling paradigms based on the spatial and temporal patterns of 

main constituent behaviors pre-, during, and post-mining.

Build these parameters and sampling paradigms into the regulatory approach or 

methodology.a

Generate operational guidance on the execution of the approach. 

Feedback
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17

4. PRE-OPERATIONAL MONITORING

Charge Question 2: Comment on the proposed approaches for characterizing baseline 

groundwater chemical conditions in the pre-mining phase and proposed approaches for determining 

the duration of such monitoring to establish baseline conditions.

4.1. Background Information Considered by the SAB

In responding to the EPA discussion of establishing baseline conditions in Section 4.2 of its draft 

technical report (U.S. EPA 2011a), the SAB considered geologic settings of current and potential ISL 

operations and the inter-relationships among geologic, hydrologic and water-quality conditions. The 

following observations about characterization during the pre-mining phase are based upon EPA and 

NRC presentations (e.g., Striz 2011) and regulatory guidance documents (e.g., U.S. NRC 2003), selected 

permit applications for proposed ISL operations, and license conditions established by the NRC (or by 

one of its Agreement States) for ISL uranium mining operations.

4.2. Defining Data Quality Objectives for Baseline Characterization

The SAB recommends that the proposed approach to groundwater monitoring for pre-mining chemical

and radiological characterization be defined in the context of the DQOs for baseline characterization.

For example, the most basic DQO may be to establish zone-specific statistical distributions of baseline 

concentrations for key hazardous constituents that may be released to groundwater during mining or 

restoration operations. Regulations require these distributions to be based on independent and 

representative water samples collected from zones in which baseline wells are located by a statistically 

valid sampling design:

• Mine-area monitor wells completed within the proposed production zone;

• Mine-area nonproduction wells that comprise the monitor well ring to monitor for 

excursions; and

• Mine-area non-production monitor wells completed in any freshwater aquifers that overlie or 

underlie the production zone.

Additional DQOs such as the following also may be appropriate:

• Demonstrate correlations among key geochemical constituents that may support optimization 

of the characterization approach (e.g., identifying and monitoring surrogates, such as 

conductance, for key constituents);

• Identify key geochemical constituents that control the mobility of hazardous constituents 

during the recovery phase (e.g., redox couples that define the Eh-pH field);

• Understand the hydrologic and geologic controls responsible for producing localized 

mineralization of uranium and other hazardous trace metals in the ore deposit;

• Identify optimal physico-chemical indicators for excursions, considering both reliability and 

cost-effectiveness of analytical methods;
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18

• Establish spatial variability of key geochemical constituents as the basis for determining the 

extent to which the mean or upper concentration limit of baseline concentrations is a function 

of well location, e.g., hydraulically upgradient, downgradient or tangential to the mine 

deposit, or in the near-field versus the far-field of structural controls and potential pathways;

• Assess the presence or absence of temporal variations in groundwater chemistry;

• Obtain data needed for geochemical modeling of water/rock interactions to predict reequilibration trends and rates during the recovery phase (e.g., Bain et al. 2001); and

• Identify the critical or most vulnerable pathways (e.g., Striz 2011). Generally, vertical 

excursions into overlying or underlying aquifers are of greater concern than are horizontal 

excursions. Thus, for ISL operations in confined aquifers, the primary consideration should 

be no likelihood of breaching the confining beds conditions.

1

The key point for consideration is that each DQO may require a different approach to the design and 

implementation of a baseline characterization program, as illustrated in the following Section in which 

baseline characterization parameters are mapped to relevant DQOs.

4.3. Baseline Characterization Parameters

The EPA is encouraged to emphasize the importance of evaluating and presenting water-quality data 

within the context of their geochemical interrelationships, not solely as independent variables. The SAB 

recommends that baseline chemical conditions be defined broadly to encompass transport flow paths 

and conceptual models of mineralogic controls not only for hazardous constituents (e.g., trace metals) 

but also for associated parameters. Iron serves as a prime example of the potential complexity of

geochemical interrelationships in an aquifer. Iron-bearing minerals buffer the redox chemistry of the 

groundwater, and iron (oxy) hydroxides not only constitute one of the most important sorbents for trace 

metals but also are one of the most important sources because of their potential to release these 

sequestered constituents into the groundwater when reducing conditions are restored. 

Based on this broad perspective, the SAB recommends that analytes be included in baseline 

characterization to meet the following objectives:

• Establish baseline conditions for key hazardous constituents with the potential to be released 

to the groundwater during mining or recovery operations; 

• Characterize baseline conditions of chemical and secular equilibrium as one measure of 

mineralogic stability (e.g., mineral saturation indices). This is an alternative approach to 

defining concentration ranges as the sole measure of baseline chemistry;

• Collect data needed to define the Eh-pH fields for the mine production area as well as for the 

adjacent aquifers;

 1 Failure of unlined (#S3) ponds at the Oak Ridge National Laboratory (ORNL) provides one example of the consequences of 

failing to recognize the vulnerability of a confining layer serving as a barrier for contaminant transport (Kim et al. 2009; Wu 

et al. 2006). The ponds were unlined because they were situated above a clay layer (saprolite). A fatal flaw in this design was 

that the clay was fractured and allowed releases of constituents into the subsurface. 
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19

• Collect baseline data needed to assess the likely effectiveness of natural attenuation processes 

to achieve site-specific remediation objectives within a reasonable timeframe, and to identify 

indicators that can be used later (post-mining) to monitor attenuation progress;

• Include aluminum in the background characterization suite because of its utility for 

normalizing metal concentrations and fingerprinting trace-metal sources (Myers and 

Thorbjornsen 2004; Thorbjornsen and Myers 2008), which may include formation 

solids/colloids, contamination, or residual annular-fill bentonite in the vicinity of the well 

screen; and

• Apply effective statistical methods and develop effective graphical techniques to delineate 

geochemical fingerprints, such as Piper and Stiff diagrams (Striz 2011) and plots presented in 

the EPA technical support document, “Fingerprint Analysis of Contaminant Data” (Power 

2004).

Tables B-1 and B-2 in Appendix B of this report are intended to illustrate how the above criteria might 

provide a basis for developing site-specific lists of analytes and groundwater quality parameters to be 

monitored during baseline, mining, remediation, and closure operations. Not all parameters listed in 

these tables would be applicable to a specific site; not all applicable parameters would need to be 

measured at a site; nor would all parameters selected for measurement at a given site need to be sampled 

with the same frequency. Although an exhaustive set of data might be desirable to allow evaluation of 

all parameters, a more practical approach is to limit data collection to a set of high-priority primary 

parameters determined for a site, augmented, if necessary, by a second set of lower-priority parameters.

Because this is a site-specific consideration, no attempt has been made to prioritize the parameters listed 

in Tables B-1 and B-2.

The inclusion of redox speciation of the analytes of interest in Table B-2 differentiates this list from a 

typical RCRA analyte list in which only concentrations of the analytes are to be measured. If properly 

sampled and measured, the redox speciation data will provide invaluable information regarding the state 

of the aquifer. This will be important for determining the baseline conditions as well as for 

demonstrating that the aquifer has been restored after mining is complete. For example (see Section 5.3), 

the sulfide/sulfate ratio will help to understand and explain aqueous concentrations of radium; and the 

distribution of uranium between its tetravalent and hexavalent states, uranium(IV) and uranium(VI),

respectively, has a direct relationship to the measured aqueous concentrations of uranium due to the low 

solubility of uranium(IV) relative to uranium(VI). Although measuring analyte redox speciation has

practical limitations, notably in preserving the redox state of a field sample, under most subsurface 

conditions simple pH and redox potential measurements are possible. 

Coupling these field measurements with the hydro-geochemical modeling discussed above can be useful 

for predicting analyte redox speciation. Whenever possible, the redox potential and oxidation state of the 

analytes of interest should be considered based upon the availability of data collected from the analyte 

lists (Tables B-1 and B-2). The stability lines for site-specific redox couples of interest (e.g., 

iron(II)/(III), sulfide/sulfate, molybdenum(II)/(IV), manganese(II)/(IV)/(VII), and uranium(IV)/(VI)) 

should be plotted and analyzed with the relationships described by Borch et al. (2010) and Lindsay 

(1979).

Clarification or guidance is needed concerning whether baseline concentrations should be determined 

for filtered and/or unfiltered samples, particularly in the case of trace metals. Although filtered 

groundwater concentrations are more appropriate for modeling geochemical speciation, mineral/water 

interactions, and mineral saturation indices, unfiltered concentrations also have relevance for 
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20

characterization. For example, comparison of filtered and unfiltered concentrations may establish the 

extent to which samples collected from the well may be biased by formation solids, annular-fill material, 

or metal corrosion products. In addition, some regulatory standards for trace metals apply to total 

concentrations (e.g., arsenic, mercury, selenium).

4.4. Drilling and Well Construction Practices

Little discussion is provided in the draft technical report about potential effects over the life cycle of 

drilling, well construction and development activities on the capability of the monitoring well to provide 

water-quality samples that will be adequately representative of baseline conditions. Regulatory 

requirements and guidance generally focus on the mechanical and physical integrity of the well and 

annular seals to prevent undesirable vertical migration of groundwater from one strata to another. The 

EPA is encouraged to consider how drilling, construction and development activities may affect or bias 

concentrations of water-quality parameters of interest, and to identify protocols that might be used to 

detect or minimize such biases. Three examples are:

• Physical changes to formation minerals induced by drilling may increase concentrations of 

colloids and suspended solids in the vicinity of the screened interval, causing an upward bias 

in concentrations of trace metals in filtered and unfiltered samples. Use of bentonite drilling 

muds or improper placement of bentonite annular-fill and seals also may have the potential to 

bias the concentrations of strongly-sorbing metals. These effects may be minimized by 

proper development of the screened interval while monitoring trends in turbidity. 

• Introduction of oxidizing fluids into the reducing ore zone during drilling, well construction 

or development may chemically alter formation minerals in the vicinity of the screened 

interval, leading to elevated concentrations of, for example, uranium, other trace metals, 

radioactive uranium daughter products, and sulfate (Abitz and Darling 2010). Changes to 

baseline redox conditions may be detected in the field by monitoring trends in redox 

indicators during well development or during purging of the screened interval prior to sample 

collection.

• Oxidizing conditions might also affect groundwater at a monitoring well as a result of new 

exploration boreholes drilled nearby. Collecting representative groundwater samples within 

the proposed production zone thus requires that baseline water quality be established early in 

the exploration phase (Abitz and Darling 2010).

For these reasons, the EPA should consider expanding its draft technical report to include guidance on 

best practices (a) for conducting and documenting drilling, well completion, and development activities 

at wells used to establish baseline conditions, and (b) for evaluating the capability of the well to provide 

reliable and representative groundwater samples. 

4.5. Challenges for Background Characterization

The EPA draft technical report properly emphasizes that the design and implementation of a baseline 

characterization program will be driven by site-specific factors. Some additional discussion and 

guidance may be needed to emphasize that the location of the baseline wells must be based on a 

statistically valid sampling design developed following the DQO process. 

A random selection of wells from a systematic grid is one example of a statistically valid approach for 

locating baseline wells. However, even a statistically valid distribution of sampling wells does not 
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21

eliminate complications for establishing baseline conditions in the context of site-specific factors such as 

those described below.

• Intersecting or adjoining deposits near mine leases. Mining companies often submit 

applications to expand the area of ISL operations or to establish satellite ISL wellfields.

Consequently, environmental impacts of operations may overlap but not be coincident in 

time, and complicate defining baseline groundwater chemistry for a proposed mine. Such 

overlap also may cause ambiguity about which mining operation is the source of any future 

excursions.

• Groundwater contamination in adjacent abandoned mine shafts and tunnels could 

complicate the definition of baseline chemistry and specification of restoration target 

concentrations. If operations at an ISL mine that intersects these mine workings subsequently 

chemically alter the groundwater in the workings, then an argument could be made that less 

restoration effort should be required than for the native sandstone leached in other areas.

• Dewatering effects of old mine workings in or near a proposed ISL operation may subject the

formation to oxidizing conditions that may extend for some distance around the old mine 

workings (i.e., into areas that were not mined by the underground operation). Such 

dewatering may have diminished or eliminated reducing conditions in the aquifer, and

uranium may move a longer distance than would normally be predicted before it encounters 

reducing conditions in the aquifer.

• Improper selection of sampling horizons creates an invalid bias in the water-quality 

parameters, e.g., by collecting samples from ore horizons relative to samples collected from 

the entire thickness of the formation.

• Limited knowledge about site mineralogy, particularly related to trace metals, may undermine

the reliability of geochemical modeling to predict the types and rates of water/rock 

interactions controlling groundwater chemistry and hence post-mining rehabilitation.

Uranium distributions are generally determined from downhole gamma logs; chemical assays 

are not always performed, and presumably performed rarely on cuttings from barren holes. 

• Changes occurring in the groundwater environment during mine operation but for reasons

unrelated to the mine itself could have the potential to invalidate the use of pre-operational 

monitoring data as a comparison for post-operational monitoring data. One approach to 

mitigate this possibility is to utilize data from those monitoring wells that ring the mining 

unit, and that clearly are not impacted by the lixiviant, to provide baseline monitoring data 

throughout the mining operational phase.

The SAB recommends that the EPA discuss in its draft technical report how the above situations can be 

addressed in the context of establishing DQOs (see Section 4.2), sampling protocols (see Section 4.3),

and well drilling and construction practices (see Section 4.4). Corollary topics for consideration in the 

draft technical report are to (1) summarize the various types of mineralogical characterizations desirable 

for baseline characterization (see also Section 3.5); (2) ensure that the approach proposed for baseline 

characterization is sufficiently flexible to accommodate other characteristics encountered at future 

mines; and (3) include models and coefficients for monitoring networks where available.
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4.6. Frequency and Duration of Monitoring to Determine Background

The SAB recommends adopting a phased approach to baseline characterization that takes into account 

the following:

• Need for additional background locations can be informed by the level of uncertainty in the 

range and spatial variability of constituents in the groundwater;

• Need for additional data from a particular well (or the need to resample a well) can be 

informed by the consistency of the data with concentrations predicted from geochemical 

modeling of the site; and

• Need to continue sampling an individual well can be based on testing for trends in the data 

indicating the extent to which the well has recovered from drilling and construction activities.

The adequacy of development and re-equilibration time of baseline wells should be confirmed prior to 

sampling. The EPA is encouraged to consider how best to test for steady-state geochemical conditions at 

baseline wells, and to evaluate whether samples represent water-quality data from these wells. The 

baseline data ultimately will provide the technical basis for establishing action levels for exceedances 

observed during the post-restoration monitoring phase. As such, it is critical that the data represent the 

natural variability of each analyte, unbiased by variability resulting from residual effects of drilling, 

construction and development. Under some conditions, residual impacts from drilling can dominate the 

concentrations of some groundwater constituents (particularly trace metals) in the vicinity of the well 

screen for months (if not years).

The EPA is encouraged to include in its draft technical report guidance on best practices for 

groundwater sampling. In doing so, the agency can reference the extensive work it has already 

performed in this area (e.g., Puls and Barcelona 1989, Yeskis and Zavala 2002), giving emphasis to the 

following aspects:

• Document the volume of water purged before sample collection and field parameter data

measured during purging (e.g., pH, Eh, conductivity, turbidity) to provide a basis for 

assessing whether the groundwater sample is representative of predrilling conditions.

• Collect additional water-quality samples during purging that may provide additional insights 

on well performance issues. For this purpose, a time-series suite could be defined that 

involves collecting water-quality samples in increments of one to two casing volumes during 

purging to be analyzed for major ions, trace metals and nonmetals, and total organic carbon.

These data would then be evaluated for trends that might indicate residual drilling or 

construction products, mixing of groundwaters from different hydrologic zones, or 

disequilibrium with formation mineralogy.

• Other approaches for evaluating representativeness are to plot redox-couple data on phase 

diagrams and to use geochemical modeling to determine the extent to which measured waterquality parameters are in equilibrium or disequilibrium with mineral phases known to be 

present in the formation.

A single sample from each well is insufficient to determine whether water-quality parameters are stable 

and representative of the groundwater at the sample location. Background chemistry should be based on 

a statistical analysis of groundwater chemistry data from a sufficiently large set of wells sampled over a 
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23

period of time. The RCRA requirements (40 CFR 264 Subpart F) for the frequency of sampling are 

appropriate and applicable for this purpose: 

§§192.32(g)(1). A sequence of at least four samples, taken at an interval that assures, to the 

greatest extent technically feasible, that an independent sample is obtained, by reference to the 

uppermost aquifer's effective porosity, hydraulic conductivity, and hydraulic gradient, and the 

fate and transport characteristics of the potential contaminants.

Examples of calculations for determining the length of time (or distance, in the case of neighboring 

wells) required to ensure samples will be independent, and examples of how to test for independence, 

would be useful additions to the draft technical report.

4.7. Standardized Data Collection

The SAB recommends that the EPA adopt a standardized format for compiling groundwater monitoring 

data from ISL uranium mines in order to develop a database that can be made publically available. This 

step will provide the EPA and stakeholders with a more complete and accurate picture of activities in 

response to regulations in this field.
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5. POST-OPERATIONAL MONITORING AND RESTORATION 

Charge Question 3: Comment on the approaches considered for monitoring in the postmining/restoration phase and the approaches considered for determining when groundwater 

chemistry has reached a “stable” level.

5.1. Introduction and Overview

The draft technical report points to two primary objectives for post operation and restoration monitoring. 

The first is to provide comments on how the monitoring program during the post-mining and restoration 

phases should be organized and carried out; the second is to discuss approaches for determining when 

the groundwater chemistry has reached a “stable” state. Considerable reliance is placed on the method

for determining baseline conditions that is addressed in the response to Charge Question 2 (see Section

4). 

5.2. Defining Restoration Goals

The SAB recommends that the EPA provide careful qualification about its meaning of “return to preoperational groundwater quality.” Restoration activities may not fully or precisely restore the aquifer to 

pre-operational quality; consequently some quantitative measure of how close is close enough will have 

to be developed to support a decision. Examples of alternative approaches to defining remedial goals 

include returning the aquifer to pre-operational conditions based on statistical comparison with preestablished criteria versus the use of a risk-informed basis. A glossary of definitions should be included 

in the draft technical report for terms that may have somewhat different definitions within the scientific 

community and hence can be open to interpretation. These words include: colloid, steady state, 

irreversible (in the context of a chemical reaction), stability/stable, baseline, and heterogeneity. 

The SAB recommends that the EPA develop a set of guiding principles that will be used to craft 

restoration standards. The draft technical report suggests that many considerations are highly sitespecific. However, the EPA can provide generic guidance with provisions to be adapted to site-specific 

conditions (i.e., geology, groundwater flow, groundwater chemistry). One critically important aspect for 

which little discussion is provided in the draft technical report concerns guidance on adopting alternative 

concentration limits (ACLs) as restoration goals. Such ACLs are particularly important for postoperational monitoring of ISL facilities because adoption of ACLs appears to be the norm, rather than 

the exception. In a sense, ACLs serve as de facto regulatory standards that vary from site to site (see also 

Section 7.7). Thus, in considering standards that apply to ISL uranium mines, the EPA can provide 

guidance on ACLs (U.S. EPA 1987). 

For effective generic guidance, available data must be analyzed. Many of the specific recommendations 

below are intended for developing a consistent set of physical and chemical parameters to be monitored, 

a uniform database of available data, and public dissemination of the data. The latter will give the 

academic and research community the opportunity to evaluate the data and apply them to hydrogeochemical modeling as a means for predicting post-closure behavior through universally applicable 

principles of chemistry and physics. Modeling will provide an opportunity to combine knowledge of 

physical/chemical processes with what is known about a site. In this way, monitoring data can test the 

model and suggest the likely effectiveness of alternative remediation schemes. 

5.3. Evaluation of Existing Datasets

The SAB recommends that the EPA continue to seek out and collate data sets of sufficient scope and 

quality to provide information relevant for setting the standards under consideration. Such data sets are 
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25

available from existing and former sites during the baseline evaluation, operation, and restoration stages

For example, the U.S.Geological Survey (USGS) compiled this type of information from public records 

to examine the effectiveness of groundwater restoration at legacy ISL mines in Texas (Hall 2009). 

Because geochemical, biological and physical conditions are highly variable among ISL uranium mines,

a corollary activity is to use the existing data to identify fundamental transferable concepts among the 

sites. Some examples to illustrate this point are: 

• Correlations among various chemical and physical parameters may provide general 

descriptions of the systems:

o The valence state of uranium and arsenic should correlate with their total measured 

aqueous concentrations. For uranium, this relationship is due to the increased

solubility of the hexavalent state, uranium(VI), relative to the tetravalent state, 

uranium(IV) (Borch et al. 2010). The measured redox potential (when little or no 

dissolved oxygen is present) should be related to the valence state of uranium and 

arsenic. Rigorous analysis of the redox kinetics and speciation of the system may be 

needed because many geochemical redox reactions do not achieve an equilibrium 

state. Complexation with dissolved ions may provide thermochemical gradients that

favor an oxidized state of a metal or metalloid despite the presence of reducing 

conditions2

o Due to the relatively low solubility of radium sulfate, RaSO4(solid), aqueous 

concentrations of radium-226 (

226Ra) and radium-228 (228Ra) should be inversely 

related to the sulfate concentration; and

;

o Iron (oxy) hydroxides and clay minerals are generally expected to be the dominant 

sorbents of uranium and radium in the ore deposits. Consequently, aqueous uranium 

and radium concentrations should be inversely related to the amount of iron (oxy)

hydroxide and clay minerals in the subsurface (Catalano and Brown 2005; Moyes et 

al. 2000). 

• One key indicator for post-mining/restoration is the ratio of carbonates to sulfides in the 

mined unit. If there is insufficient neutralization potential remaining in the unit, it is likely to 

continue to oxidize from remnant lixiviant and cause mobilization of U(VI) and other 

contaminants.

• The existing datasets can be used to demonstrate use of hydro-geochemical modeling for

predicting behavior of the system during operation, restoration, and post-restoration.

Numerous modeling programs currently are available at varying degrees of sophistication

(see Sections 3.7 and 7.5). These models can incorporate chemical speciation models with 

hydrologic flow models to predict spatial and temporal concentrations of analytes in aqueous 

and solid phases. A feasibility study employing the modeling program PHREEQC was 

commissioned by the NRC (U.S. NRC 2007; also see Parkhurst and Appelo 1999). The study 

 2 An example of this phenomenon has been clearly demonstrated by Wan et al. (2005) during a uranium bioreduction study. 

After amending uranium-contaminated sediments with lactate, uranium reduction was seen up to 80 days but after >100 days 

uranium was reoxidized despite the fact that a microbial population capable of reducing uranium was maintained. It was 

found that the oxidation was due to the formation of thermodynamically favorable aqueous uranyl carbonate ternary 

complexes such as Ca2UO2-(CO3)3. Oxidation of uranium(IV) to uranium(VI) is highly undesirable because of the enhanced 

environmental mobility of uranium(VI) relative to uranium(IV). 
.

26

examined three techniques for estimating the volume of water that must be passed through 

the aquifer system to achieve restoration standards. A model that considers hydrology, 

contaminant transport, and geochemical reactions provided a qualitative estimate of the 

geochemical conditions and estimated the behavior of the system during post-restoration

monitoring. Because in-situ mining is a major perturbation of the system, a quantitative 

model in support of site measurements can provide confidence that the restoration goal of site 

stability after closure has been met. The U.S. NRC (2007) emphasized that development of a 

justifiable conceptual model that captures the major chemical and physical phenomena at 

each site is required. This approach will allow for site-specific flexibility.

• Information on solubility, aqueous speciation, and sorption affinity may be found to guide 

extrapolation to aqueous concentrations near equilibrium. Prediction of temporal trends by

hydro-geochemical modeling is difficult due to the lack of kinetic data for some relevant 

systems. The very act of in situ mining takes a system far from an equilibrium state during 

normal operation. The thermodynamics and kinetics during the early phase of restoration are 

likely to be important. In most cases, aqueous complexation reactions and sorption reactions 

may reach at least a local equilibrium. Therefore, the major focus should be on incorporating 

kinetics of mineral precipitation and dissolution into the modeling efforts. An example is

provided in Attachment B of the draft technical report when discussing transitions from ferric 

(oxy) hydroxides to soluble ferrous iron to ferrous sulfide minerals. 

• The EPA has case studies from sites that have completed restoration (U.S.EPA 2011a, 

Attachments B and C). These may be pertinent to discussions in the draft technical report on

the use of confidence levels for determining if restoration goals have been achieved. 

• A uniform database can be prepared from the collected site data that were used to 

characterize baseline, operation, restoration, and post-restoration conditions. This database 

can be made publically available so that the academic/research community can evaluate the 

data and help to develop conceptual and quantitative models which can be used to further 

refine the regulations and monitoring activities for in-situ mining.

The SAB recommends that the EPA discuss the implications of the data on restoration activities at mines 

included in attachments to the draft technical report. Listing measured analytes and water quality 

parameters without pertinent discussion is of limited utility. For example, would it matter if the calcium 

concentration is above the baseline concentration but uranium and radium concentrations are all at or 

below baseline? 

5.4. Criteria for Collection and Analysis of Monitoring Data

Development of a set of guiding principles discussed above (Section 5.2) for use in forming standards

will be an improvement on the current practices primarily guided by site-specific metrics, which allow 

for a high degree of variability. A set of general principles that considers variable site conditions within 

a broadly consistent approach can ensure that consistent standards are applied for all sites. Several 

relevant principles are:

• The data gathered during restoration will be valuable for determining if the restoration 

activities are effective. A feedback loop should be implemented that requires a change in 

restoration activities if the data indicate that the goals will not be met. This can be a simple 

projection of groundwater chemistry based on the extrapolation procedures outlined in the 
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27

draft technical report or a more complex coupled hydro-geochemical model of the system 

that considers relevant reaction kinetics;

• Pertinent data incorporated into the consistent, publically available, database discussed above 

will encourage interrogation of the data to refine future monitoring during in-situ mining 

activities; 

• Several approaches are available to analyze the large sets of data generated from sites with 

multiple wells at multiple times. While a site-averaging technique is a simple approach, the 

key to understanding outliers and spatial variability is to look at the data for individual wells. 

Therefore, unless specifically guided by a statistical test, chemical parameters should not be 

reported or evaluated as a site-wide average value. (See Section 6.2).

5.5. Duration of Post-Mining/Restoration Monitoring

Mining by ISL alters the subsurface physical (e.g., aquifer porosity and permeability) and chemical 

environment. When mining ends and no further anthropogenic actions influence the groundwater, then 

the groundwater and the minerals with which it is in contact begin to shift toward a new geochemical 

steady state. Proposing methods of returning to baseline hydrological and chemical conditions during 

restoration activities implies that the system will return to steady state conditions comparable to preoperational baseline conditions. However, although groundwater conditions may be sufficient to satisfy 

license requirements, the SAB is not aware of available data indicating that mineralogical and 

hydrological conditions can be fully restored. Examination of post-mining/restoration data from former 

ISL uranium mining units would be useful to determine the extent to which return to baseline conditions 

has indeed been achieved. The examples in the draft technical report appear to focus primarily on 

analyte concentrations.

In addition to water quality data, mineralogical data can be used to evaluate the long-term stability of the 

system. Because complete mineralogical characterization is unrealistic or economically infeasible, 

alternative approaches are needed. Data from existing facilities can be used to propose a technically 

reliable time frame for post-closure monitoring. This is a case in which hydro-geochemical modeling 

can be a valuable tool for predicting how long a system will take to return to baseline conditions. 

Combining a validated model with the data from a relatively limited number of sites that have proceeded 

completely through the restoration and closure process will provide an estimate of technically reliable 

time frames for post-operational and post-restoration phase monitoring.

The SAB recommends the following actions regarding sampling frequency and duration:

• Increased frequency of groundwater monitoring during the initial restoration phase. The 

system is expected to return rapidly from its status far from equilibrium during mining to 

nearer its natural state as the lixiviant is flushed out. Measuring this rapid change with 

sufficient frequency (e.g., weekly or biweekly) will provide valuable data regarding the 

trajectory of aquifer parameters and analyte concentrations for validating and verifying 

hydro-geochemical models;

• Statistical testing to verify that baseline conditions, once reached, are maintained (see Section 

6.2); and
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28

• Application of hydro-geochemical models to data sets from ISL uranium mines that have 

been restored to indicate magnitude of duration needed to attain restoration, as defined by 

consistent criteria. 

5.6. Grouping Constituents for Monitoring Activities

To verify that baseline conditions have been achieved by site restoration activities, the SAB 

recommends that the list of analytes and groundwater parameters to be monitored before, during, and 

after operation be established pre-operationally. The analyte lists provided in Appendix B include the 

analytes and groundwater parameters that the SAB considers potentially relevant for baseline 

determination and evaluation of post-closure stability.

5.7. Hazard Quotient or other Risk-Weighting Scheme for Determining Relevant Analytes

The SAB recommends that the EPA consider developing a risk-weighting scheme to apply to the 

analytes being monitored during baseline and restoration activities. Such weighting can show the 

relative risk from a given analyte that is out of compliance. This will prevent the scenario that a site 

must continue restoration activities even though it has met the goals defined by risk analysis. This 

scheme can be combined with the recommended primary and secondary list discussed above where the 

analytes on the primary list must meet the restoration goals while the secondary list contains analytes of 

little risk that provide information on the extent of restoration. 

One approach to consider is the hazard quotient, which is the ratio of the measured analyte concentration 

to the analyte concentration at which no adverse effect is expected (Fjeld et al. 2007). According to this

approach, constituent concentrations in groundwater are acceptable with regard to health risk provided 

the sum of their hazard quotients is <1. Accordingly, a site at which an analyte has not met a restoration 

goal but does not present an unacceptable health risk can use a hazard quotient approach to demonstrate 

that there is little potential for adverse health effects. In the example above considering calcium, 

uranium, and radium, if the calcium concentration had not attained baseline levels during restoration but 

the overall groundwater composition had a hazard quotient less than one, then the site could be released 

despite the fact that the restoration goal for calcium had not been attained.

An alternative risk-weighting scheme can factor in the economic and associated environmental 

consequences associated with water quality that relate to chemical or physical constituents that do not 

directly impact public health, but would still require adding materials and energy (directly and 

indirectly) to remove the constituents prior to use (see also Section 7.2). Examples include excessive 

levels of boron that may limit its use for irrigation, or elevated concentrations of calcium that may cause 

excessive scaling in pipelines or equipment.
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6. STATISTICS, DATA REQUIREMENTS AND USE 

Charge Question 4: Comment on statistical techniques that would be applicable for use with 

ISL/ISR mining applications (particularly for the areas in Charge Questions 2 and 3), as well as the 

subsequent data requirements for their use.

6.1. Design of Well Placement and Sampling Program 

Many issues concerning the design and execution of monitoring plans for pre- and postmining/restoration are difficult to address in full in a brief technical report. Each site is unique 

geologically, and effects of ISL uranium mining on hydrodynamics and water chemistry are complex. 

The draft technical report presents a reasonable general approach to statistical analysis of data from a 

monitoring program. However, the statistical analysis can only be as reliable as the overall design of the 

study, which must ensure that the monitoring wells will be representative of the aquifers at risk of 

contamination. 

The problem of designing a monitoring system with adequate site locations and densities is not directly 

discussed in the draft technical report, although other EPA reports may cover this issue in other contexts.

The monitoring system must be designed to provide adequate coverage for all aquifers deemed to be 

affected by ISL uranium mining according to the hydrological survey and hydro-geochemical modeling. 

The term”adequate coverage” implies both selecting locations with most affected groundwater (e.g., 

potential hotspots) and overall assessment of pre- and post-mining/restoration aquifer conditions. Any 

“cherry-picking” of affected locations for underestimating long-term changes due to ISL mining and 

recovery operations must be avoided.

 

The SAB recommends that the draft technical report give a summary of methods to determine the

number, density, and location of monitoring wells. A basic approach can specify monitoring an initial 

number of wells that will be adequate under a presumed standard physical model for groundwater 

pollutant concentrations (based on prior standard practice). After an initial (perhaps one year) interval, 

heterogeneity (and periodicity, see below) can be evaluated; if the coefficient of variation (comparing 

different wells) of key potential constituents is unexpectedly high, additional wells can be added to the 

system prior to the start of the ISL operations, in time to collect several months of baseline data for those 

wells before operations begin.

The draft technical report gives a sample size formula (U.S. EPA 2011a, page 52) that is relevant for 

testing whether a single analyte differs in the post-mining versus pre-mining period for a single well; 

this is highly relevant for predicted “hotspot” regions that would be most affected by ISR activities. The

formula should be supplemented with a discussion of finding sample size needed for characterizing 

whether the average value of an analyte of interest over an entire aquifer is comparable in the postmining period compared to the pre-mining period. Here, both the number of wells and the number of 

samples per well are relevant, and the among-well variance in analyte value determines the number of 

wells required. Care must be taken in deciding over how large an aquifer or spatial area to average, 

because including wells in aquifer regions unaffected by ISL activities will attenuate the apparent effects 

of ISL mining. Once the region of interest is defined, standard sample size considerations (similar to the 

formula given in U.S. EPA 2011a, page 52, but with the variance term now involving a sum of withinand among-well variability) can be applied to this problem. 
.

30

6.2. Statistical Analysis Discussion

The statistical analyses discussed in the draft technical report assume that monitoring wells provide 

measurements during both pre- and post-mining/restoration, and describe a set of statistical analyses to 

determine the following:

• whether measurements of a single given pollutant concentration in the pre- and postmining/restoration periods for a single well are temporally stable (e.g., not subject to trends 

in either period);

• whether the data from a given well (if temporally stable in both periods) provide statistical 

evidence that differences in pollutant level (post-mining/restoration versus pre-mining 

periods) are not greater than a given allowed value, ∆;

• whether grouped wells are heterogeneous either in their temporal trends or in their postmining/restoration versus pre-mining differences in concentration levels; and

• whether, in longer follow-up, trends are evident in individual wells or overall in a group of 

wells.

The draft technical report mainly discusses non-parametric statistical methods to test for trends, post–

mining/restoration versus pre-mining differences and heterogeneity, including the following:

• the Mann-Kendall test to test for unexpected trends (U.S. EPA 2011a, Sections 8.3.2, 8.3.3, 

8.5, and Attachment D, Sections D.2 and D.3), 

• the Wilcoxon test for comparing baseline and post-restoration samples for statistical 

differences for a single well (U.S. EPA 2011a, Sections 8.4.1.1, 8.5, and Attachment D, 

Section D.5), and

• a test for heterogeneity among the pooled set of wells based on the Wilcoxon test for trend

(U.S. EPA 2011a, Sections 8.4.1.2, 8.5, and Appendix D, Section D.4).

Also given is an approximation to the sample size needed to test for pre - post differences so that power 

and Type I3

The SAB identifies, however, a larger issue missing from the statistical advice given in the draft 

technical report; specifically, stronger guidance on the overall design of the monitoring program that 

error of the statistical analysis are controlled (U.S. EPA 2011a, Appendix E, Table E-4).

The methods that are described in the draft technical report are reasonable as far as they go, with caveats 

discussed in Section 6.2.1. The charge question asks for guidance on which tests and statistical 

techniques should be used. The SAB agrees with the draft technical report that it is appropriate to utilize 

the Mann-Kendall test for trend to determine for a given contaminant of interest or other analyte whether 

the post-recovery data are stable at a single well location. The use of the Wilcoxon test for post minus 

pre differences (i.e. whether the post-recovery contaminant level is equivalent to that prior to the 

beginning of operations) is also appropriate when data for a single analyte at a single location are 

considered. These methods are robust to outliers and errors and do not require detailed knowledge of 

distributions of contaminants. 

 3 In statistics, a Type I error may be compared with a false positive. It is an error of the first kind and is the wrong decision 

that is made when a test rejects the null hypothesis.
.

31

will provide the data for statistical analysis. By “design,” the SAB is referring to the number, location, 

and density of wells and the timing of measurements both before operations and after recovery. These 

design factors are much less fully discussed in the draft technical report than are the analyses of data 

from a single location. 

Clearly, the locations to be monitored must adequately represent the aquifers at risk of contamination. 

In addition, the required density of monitoring locations depends on the spatial variability of the analytes 

to be monitored: greater variability requires higher monitoring density. The period of monitoring at each 

location depends on the temporal variability of the contaminants of interest at each location (see also 

Section 3.6). These factors will not be the same at each ISL uranium mine so that it is not possible to 

suggest a "one size fits all" design solution. The EPA needs to define a flexible approach to designing 

monitoring systems for the aquifers of interest that (1) is informed by hydrological and geochemical 

analysis of the aquifers and (2) can adapt to unexpected spatial and temporal variability by increasing 

either the density of monitoring locations or the period of time each location is to be sampled.

The SAB recommends that the draft technical report consider the complications that arise in practice 

when applying this relatively simple and straightforward approach to data from ISL uranium mining. A 

few of these complications are discussed in the following subsections.

6.2.1. Strengths and Weaknesses of Non-Parametric Approach

The general non-parametric approach taken has weaknesses as well as strengths. While robustness to 

outliers, non-detects, and data blunders such as mis-recording values is greater with the non-parametric 

procedures, something is lost in terms of modeling flexibility. For example, a linear model framework 

can more readily incorporate correlations between measurements by specifying models for both the 

means and the variances of the measurements. Also, repeated measurements (same well, same time) can 

be properly handled whether or not they are available consistently (taken at each time period) or only 

sporadically. 

As noted above in Section 6.2, non-parametric tests are generally appropriate for testing relatively 

simple hypotheses, such as the Wilcoxon test to determine whether constituent concentrations in specific 

wells post-recovery are comparable to those for baseline conditions, and the Mann-Kendall test for 

trends in constituent concentrations at specific wells during the post-recovery phase. However, 

comparisons involving many wells may become more difficult using non-parametric methods than using 

more flexible parametric models. For example, constructing an estimate of aquifer-wide levels of a 

given contaminant (an average over many wells) and deciding whether such estimates differ in the 

recovery period compared to the pre period when different numbers of measurements are taken at each 

monitoring site in each period and where there is variability of contaminants among sites seems more 

difficult to do using non-parametric techniques than with parametric methods, specifically, mixed effects 

variance component models. Mixed linear models can allow nesting of repeated measurements of the 

same well at the same time, while estimating slopes and intercepts for the response to restoration efforts 

of individual wells, and allow a test for homogeneity time trends. The presence of extreme outliers or of 

highly non-normal data distributions requires caution in interpreting the findings of the analysis, and the 

data should be examined for such outliers.

For example, the proposed test for heterogeneity (across wells) based on using the z-scores

4

 4 In statistics, z-scores are standard scores, normal scores, or standardized variables. The z-score allows comparison of 

observations from different normal distributions.

from the 

Wilcoxon test assumes that all z-scores are constructed to be equally informative about the overall post -

pre differences. This would not be the case if some wells have more measurements than do other wells. 
.

32

Wells with larger z scores may simply have more observations available (and hence more power) to 

detect the post - pre level changes. If all wells have the same number of pre and post measurements then 

the proposed method of testing for heterogeneity should be appropriate. The linear model framework, 

when it applies, provides a more general test for heterogeneity not dependent upon having the same 

number of observations per well.

6.2.2. Implications of Heterogeneity

The draft technical report does not propose what actions might be taken if heterogeneous results are 

found for the post - pre differences for different wells. What actions are likely to be triggered if there is 

evidence of a single well (or of several wells) in which post - pre difference criteria have not been met? 

6.2.3. Grouping of Wells

The draft technical report pays little attention to deciding how wells should be grouped to test for either 

overall patterns or heterogeneity, and whether all wells in a grouping should be treated the same in such 

tests. For example, it makes little sense to analyze distant wells or wells that are up gradient in the same 

way as the wells most proximal to the aquifers or injection locations of interest. Including unaffected 

wells in the analysis tends both to attenuate the overall estimate of post-pre mining differences and to 

reduce the ability to detect heterogeneity. If heterogeneity is detected, it would be reasonable to specify 

additional analyses that relate the levels to factors such as distance from injection points and

groundwater gradients. Again, this can be done more readily in the framework of linear models than 

with nonparametric tests.

6.2.4. Periodic Patterns and Trends

Seasonality, or whatever underlying factor it represents, complicates the proposed analyses. Sufficient 

data must be collected to estimate seasonal trends and account adequately for seasonality in the 

statistical analysis. This requires at least two years of data (a minimum of one year during the preoperational phase plus one year during the post-operational phase) under the assumption that the 

mining/restoration process disturbs only the overall level of contamination but not the seasonal pattern.

Seasonal patterns in concentration levels that are dominated by very short-term but intense events (e.g.,

heavy rainfall events that recharge aquifers with oxygenated water over just a few days in the summer 

months) require both more measurements per year and more years of data to determine the response of 

the post-mining/restoration water system to these events.

The draft technical report should be clear about whether seasonality or extreme short-term events are 

expected to play a role in contaminant levels. Adopting the principle that monitoring locations for at 

least a full year prior to operations as well as after recovery, with consistent timing of observations 

within these years, has the effect of automatically "subtracting out" any consistent seasonal components 

when post-operational recovery periods are compared to the initial conditions. If seasonal patterns are 

either predicted (by hydrological models) or observed to be highly variable from year to year (perhaps 

because of the influence of extreme weather events), then a single year of pre-operational information 

may not be adequate. A design in which pre-operational data are collected for a minimum of two years 

would be preferable for estimating year-to-year variability in the seasonal pattern although this design 

may be “overkill” if, for example, the aquifers are deep enough to be impervious to short-term seasonal 

variability.

At some locations, the effects of longer term events on groundwater flow and quality may also be 

relevant if a mine may be operating for a decade or more. These effects may be instigated by large-scale 
.

33

changes in land use (such as logging), land cover (e.g., resulting from disease or infestation such as the 

pinebark beetle), and climate.

A carefully designed monitoring plan in which each well has equivalently timed measurements 

(quarterly or monthly measurements taken at the same periods in each quarter or month) will largely 

eliminate the need for seasonal adjustment because the seasonality terms can be “subtracted out” when 

statistical tests of post-pre differences are performed. Again, if sporadic but intense events dominate 

seasonal differences, more years of data and/or more measurements per year are required to capture 

differences (post-mining versus pre-mining) in response to these events.

6.2.5. Role of Modeling in Assessment

Modeling of groundwater and geochemical dynamics plays a crucial role in assessing which aquifers are 

at risk, the dimensions of the affected areas, the constituents most affected by the long-term effects of 

ISL mining and restoration, and the time required for restoration. Modeling of aquifer conditions and 

chemical dynamics is crucial in designing an appropriate assessment of pre-mining groundwater 

constituents, including spatial and temporal extent of monitoring. In addition, modeling can define 

constituents that should be monitored closely because of the risk attributed to them directly, and because 

of their role in the underlying chemistry that may be affected by ISL mining and restoration. Modeling 

also plays an important role in interpreting restoration monitoring results, especially when monitoring 

shows that certain analytes are not returned to baseline or predefined concentrations. This can be seen in 

several of the examples given in Attachments B and C to the draft technical report. 

Overall, modeling assists in designing monitoring and interpreting its results, but cannot make up for 

poor monitoring design. A certain margin of safety for each spatial, temporal, and chemical dimension 

of a monitoring program for the pre-mining and post-mining/restoration periods needs to be adopted so 

that the long-term effects of ISL mining and recovery on all chemical constituents of groundwater 

relevant to public health will be well characterized even in situations when models are incomplete or 

assumptions are not met. 

6.2.6. Multiple Comparisons

The hypothesis-testing framework described in the draft technical report gives a rather different context 

for discussions of multiple comparisons than is typical, and the discussion of multiple comparisons 

seems a bit off focus from the hypothesis testing framework. In the draft technical report, the null 

hypothesis is that the post – pre mining differences for a given potential pollutant are at or above a given 

criterion, ∆. In usual multiple comparisons analysis, one is concerned with making the experiment-wide 

Type I error of concluding that ANY of the post – pre differences, δ, are different than the null value ∆, 

when they are all in fact truly at the null value. In such analysis, one is interested in controlling the

probability that the minimum value of a set of p-values {p1, p2, ..., pn} is less than some fixed value 

alpha (each pk corresponds to the overall p-value for some potential pollutant). 

Here, things are a bit different; because the site will not be regarded as suitable for release unless all 

potential pollutants are significantly below each ∆ criteria (which may be different for each pollutant),

an “experiment-wide” error would only occur if all {p1, p2, ..., pn} were below alpha. It is this 

probability that should be controlled under the null hypothesis. However, the null hypothesis of interest 

now is not the global null hypothesis (i.e., that all post – pre differences, δ, are at or above ∆, in which 

case we could allow a very relaxed p-value). Rather, the composite null hypothesis is that at least one of 

the δ are equal or above ∆. In particular, for the null hypothesis that exactly one of the δ is equal to ∆
.

34

and all other δ are so far from ∆ that the power to reject δ=∆ is close to 1, then testing each hypothesis at 

the nominal level alpha does indeed control the experiment-wise false positive rate at this same alpha 

level. 

For all other possible null hypotheses (more than one δ equal to ∆), the nominal level provides a 

conservative test. In this setting, control of the experiment-wide Type I error rate is accomplished by 

simply ignoring the fact that more than one comparison has been made while testing each hypothesis in 

turn. 

In this arrangement, the concern with multiple comparisons is not loss of control of a global Type I error 

rate, but rather, loss of control of power. Because the site is released only if all null hypotheses are 

rejected, then the sample size needs to be set so that a reasonable probability exists that all null 

hypotheses can be rejected, assuming that they are all false.The site operators’ interest lies in performing 

a careful power analysis to provide enough measurements to decrease considerably the nominal Type II5

6.2.7. Bayesian Approaches

error for each test, while keeping the Type I error rate at a traditional (e.g., 5 or 10 percent) value in each 

analysis.

Another option which the EPA might consider is the use of Bayesian methodology to determine the 

efficacy of post-operational restoration. For example, pre-operational monitoring data may lend 

themselves to the formation of robust, realistic and informative prior distributions of groundwater 

constituents. An analysis using these data to estimate parameters of the prior distributions is similar to 

an Empirical Bayes method and can be viewed as an approximation to the complete hierarchical 

Bayesian analysis (Martz 2000; Gelman et al. 2009). If this methodology were to be adopted, then a 

decision-making process that uses Bayesian posterior densities to determine whether or not groundwater 

restoration has been completed would need to be developed.

 5 In statistics, a Type II error may be compared with a false negative. It is an error of the second kind and is the wrong 

decision that is made when a test fails to reject a false null hypothesis.
.

35

7. ADDITIONAL ISSUES BEYOND THE CHARGE

7.1. Monitoring of Other ISL Impacts

The following situations may only indirectly affect post-closure groundwater monitoring, but can impact 

efforts to protect public health and the environment. For this reason, the EPA may wish to summarize 

briefly in the draft technical report these potential events and identify the applicable EPA and NRC 

regulations and guidance on the design and implementation of focused monitoring programs to prevent 

adverse environmental impacts.

• Release of liquid, solid, and airborne contaminants during routine operation from surface 

structures, pipelines, evaporation ponds, waste disposal wells, well drilling, and sample 

collection;

• Vadose-zone modeling to evaluate the potential for surface and near-surface contaminant 

releases to impact groundwater in the uppermost aquifer;

• Effect of accidents, incidents, and natural disasters on distributing lixiviant-borne 

contaminants or disturbing post-closure groundwater contents; and

• Contribution by nearby mining, abandoned mines, and waste sites to the constituents of postclosure groundwater.

7.2. Potential Impacts on Groundwater Usability

The consequences of alterations of the ore body aquifer chemistry are expected to be minor if the aquifer 

is confined (but see footnote to Section 4.2 for an example of confinement failure), is not a potential 

drinking water source, and will be restored to pre-operational baseline quality. The EPA needs to assure 

that environmental protection standards for uranium mining adequately consider potential impacts on the 

current and planned use of aquifers by local populations for domestic water use, livestock watering and 

agricultural uses. Uranium mining by ISL could permanently and significantly alter such use patterns.

More importantly, given the prospect of worsening local and regional water shortages due to increasing 

demands and large-scale climate changes, society arguably places a much higher value on available 

water resources today than was the case in 1978 when the UMTRCA regulations were first promulgated. 

One aspect about post-mining restoration frequently brought to the SAB’s attention is that ISL mining 

occurs in an exempted aquifer. Given this situation, several members of the public stated that the

exempted aquifer does not need protection because the groundwater is too contaminated to ever serve as 

a source of drinking water. According to this perspective, only the non-exempted aquifer needs 

protection and groundwater restoration should be considered successful when it returns the water quality 

to a level that will not degrade the water quality beyond the exempted aquifer (John Cash, written 

communication).

An EPA presentation on the application process for a Underground Injection Control (UIC) permit listed 

specific criteria that must be met for any portion of an aquifer to be designated as an exempted aquifer

under 40 CFR 146.4 (http://water.epa.gov/learn/training/dwatraining/upload/dwaUIC-uicpermit.pdf):

• The aquifer does not currently serve as a source of drinking water; and

• It cannot now and will not in the future serve as a source of drinking water; or
.

36

• The total dissolved solids (TDS) content of the ground water is more than 3,000 mg/l and less 

than 10,000 mg/l, and the aquifer is not reasonably expected to supply a public water supply.

The second criterion listed above for an exempted aquifer requires that EPA determine that the aquifer 

cannot now and will not in the future serve as a drinking water source. The decision may be based on 

any of the following four specific situations regarding the aquifer {40 CFR 146.4(b)(1)-(4)}:

• It produces mineral, hydrocarbon or geothermal energy, or the Class II or III UIC well permit 

applicant can demonstrate it contains minerals or hydrocarbons in quantity and location that are 

expected to be commercially producible;

• It is situated at a depth or location that makes the recovery of the ground water for drinking water 

purposes economically or technologically impractical;

• It is so contaminated that rendering the water fit for human consumption would be economically 

or technologically impractical; or

• It is located over a Class III well mining area subject to subsidence or catastrophic collapse.

According to a representative of the mining industry (John Cash, personal communication), most ISL 

mining applications for an exempted aquifer are based on the criterion that the aquifer cannot and will 

not in the future serve as a drinking-water source due to its mineral-production potential. Thus, there 

does not appear to be evidence substantiating the assumption that all exempted aquifers in which ISL 

operations exist or are proposed necessarily have TDS contents exceeding 3000 mg/L, nor that the 

groundwater is too contaminated to serve as a source of drinking water now or in the future. In fact, one 

might postulate that the basis for an aquifer exemption under the mineral-potential criterion is no longer 

valid once the uranium minerals have been removed by ISL mining operations.

This potential inconsistency in the UIC and UMTRCA regulations, which may be administrative rather 

than technical in nature, warrants clarification in the EPA’s draft technical report.

7.3. Establishing Data Quality Objectives

The SAB recommends in Sections 4.2 and 4.5 that the EPA define explicitly the DQO framework in the 

draft technical report. The adequacy and technical accuracy of information in the EPA’s draft technical 

report—specifically, information related to the four charge questions for this advisory activity—can best 

be assured if the agency implements the DQO process for this project to define its objectives and its 

options for meeting those objectives. The absence of succinct definitions of these critical details 

complicated the SAB’s ability to identify the information and actions needed by the agency to review 

the adequacy of existing regulatory standards in 40 CFR Part 192. For example, the compliance points 

for the standards are not consistently clear, the extent to which the existing standards are being met 

cannot be assessed, and the alternative technical approaches for meeting objectives are not explicit. This 

presents difficulties to relate DQOs to potential options being considered within the existing draft

technical report. 

7.4. Integration with Other EPA Regulatory Programs Applicable to Groundwater Quality

The EPA may wish to address explicitly in the draft technical report how the agency will integrate the 

ISL uranium mining standards with the long-established and well-documented requirements and 

guidance for other EPA regulatory programs that are also applicable to groundwater quality and that 
.

37

address many of the same groundwater monitoring challenges. The discussion in the draft technical

report concerning the applicability of RCRA is a good example.

7.5. Tapping Existing Resources for Environmental Modeling

Modeling is complementary to monitoring in attaining a full understanding of groundwater quality at 

ISL uranium mines and the EPA can draw upon existing modeling efforts for this task. For example, 

ORIA has undertaken cooperative multiagency modeling efforts to support regulatory programs, 

including environmental pathway models for groundwater modeling to inform remediation at sites 

contaminated with radioactive material and hazardous waste (U.S. EPA 1993a, 1993b, 1993c). 

Another source of information is the SAB’s review of the EPA’s 2003 draft guidance on the 

development, evaluation, and application of regulatory environmental models and Models Knowledge 

Base (MKB) (U.S. EPA 2003), prepared by the EPA Council for Regulatory Environmental Modeling 

(CREM). In the SAB review, the panel emphasized a number of ways in which the Draft Guidance and 

MKB can be improved (U.S. EPA SAB 2006). The following points from that review may be relevant to 

technical guidance supporting the regulatory program for uranium ISL sites:

• Care in articulating the audience to which the Draft Guidance is directed;

• The need to develop and apply models within the context of a specific problem;

• Caution in the way that information on modeling uncertainty is evaluated and communicated, 

and the need for Draft Guidance to fully discuss uncertainty and sensitivity analysis 

methods;

• Consistency in conforming the terminology used in the Draft Guidance to previous uses and 

meanings of these terms in other environmental modeling activities; and

• The need to gather, and in many cases to develop, additional information to be included in 

the modeling database, including the framework, evaluation, and limitations of individual 

models; and to implement a mechanism that allows the community of model users to submit 

feedback on their experiences and suggestions for model improvement. 

The EPA (U.S. EPA/ORD Office of the Science Advisor) and the U.S. Department of Transportation 

were co-sponsors of a National Academy of Sciences (NAS) study (NAS 2007) on the use of models to 

inform the regulatory decision-making process. The report prepared by the NAS Committee on Models 

in the Regulatory Decision Process recommended that evaluation of a regulatory model should continue 

throughout the life of a model, including throughout regulatory applications and revisions of the model. 

The NAS committee observed that the one-time peer review of a model that is typically seen in the 

published literature is insufficient for many models used in the environmental regulatory process, and 

that more time, effort, and variety of expertise is required to conduct and respond to peer review at 

different stages of the life cycle, especially for complex models. The NAS committee emphasized the 

need to communicate clearly all of the uncertainties. It also noted that a wide range of possibilities is 

available for performing model uncertainty analysis and that, in some cases, presenting results from a 

small number of model scenarios will provide an adequate uncertainty analysis. In many instances, 

however, probabilistic methods will be necessary to characterize properly at least some of the 

uncertainties. The NAS Committee report touched on communicating uncertainty, the interdependence 

of models and measurements, principles for model development, the selection and application of 
.

38

models, the issue of proprietary models, model management in the rule-making context, improving 

model accessibility, and related topics. 

The EPA CREM published its guidance (U.S. EPA 2009a) following the reviews of modeling 

evaluations by the SAB, the NAS and the National Advisory Council for Environmental Policy and 

Technology (NACEPT) (U.S. EPA NACEPT 2008). The CREM guidance provides an overview of the 

best practices for ensuring and evaluating the quality of environmental models. 

7.6. Working Relationship with the Nuclear Regulatory Commission

During its face-to-face meeting, the SAB observed what appeared to be insufficient communication 

between EPA and NRC staff concerning the accessibility of groundwater monitoring data and its 

regulatory implications for ISL uranium mining. As a result, the EPA draft technical report needs more 

operational details and delineation of present-day guidelines for monitoring. The EPA is encouraged to 

conduct a cooperative dialog and to consider the establishment of a working group—perhaps similar to 

the MARSSIM Working Group—to coordinate its review of the uranium mining standards.

7.7. Promoting Predictability and Reducing Uncertainty in Uranium Mining Standards

As noted in the EPA’s draft technical report, protocols for establishing baseline groundwater quality (as 

well as for monitoring groundwater before, during, and after mining) are established in the facility 

license issued by the NRC or applicable Agreement State (U.S. EPA 2011a, p. 26). Regarding this 

practice, the SAB agrees with the statement made ten years ago by the NRC’s Center for Nuclear Waste 

Regulatory Analyses (U.S. NRC. 2001, p. 1-1):

Widespread use of license conditions is not an optimum regulatory framework. 

Since these license conditions are subject to rejection or modification through 

legal challenge, they add substantial uncertainty and economic and operational 

risk to ISL operations. Ensuring consistency of requirements for all licensees is 

also difficult with widespread use of license conditions.

In summary, the SAB considers that the critical review and update of the EPA ISL uranium mine

standards are necessary and timely. The EPA can implement this task following the key principles in 

Executive Order 13563, Improving Regulation and Regulatory Review (signed January 18, 2011; 

Federal Register, Vol 76, No. 14, pp 3821-3823). Although UMTRCA regulations are not mentioned 

explicitly in EPA’s “Final Plan for Periodic Retrospective Reviews of Existing Regulations” (U.S. EPA 

2011c) developed in response to Executive Order 13563, many of the processes and evaluation criteria 

presented in the EPA’s plan are relevant for addressing the issues and suggestions in the SAB’s advisory 

report. 
.

39

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.

A-1

APPENDIX A. EPA CHARGE TO THE SAB

June 2, 2011

MEMORANDUM

SUBJECT: Advisory Review of the Draft Technical Report: Considerations Related to Post-Closure 

Monitoring of Uranium In-Situ Leach/In-Situ Recovery (ISL/ISR) Sites

FROM: Michael P. Flynn, Director /S/

Office of Radiation and Indoor Air

TO: Vanessa Vu, Director

Science Advisory Board

This is to request that the Science Advisory Board’s augmented Radiation Advisory Committee (RAC) conduct 

an advisory review of the attached draft Technical Report: Considerations Related to Post-Closure Monitoring of 

Uranium In-Situ Leach /In-Situ Recovery (ISL/ISR) Sites (Technical Report). 

Background

In accordance with the Uranium Mill Tailings Radiation Control Act (UMTRCA) section 206, the Environmental 

Protection Agency (EPA) is authorized to develop standards for the protection of public health, safety, and the 

environment from radiological and non-radiological hazards associated with residual radioactive materials. 

Regulatory standards implementing UMTRCA (40 CFR Part 192 Health and Environmental Protection Standards 

for Uranium and Thorium Mill Tailings) were originally issued in 1983, and last revised in 1995. EPA is 

currently conducting a review of its regulations for uranium and thorium milling to determine if the existing 

standards in 40 CFR Part 192 should be updated. 

While the existing regulatory standards apply to both conventional mills and unconventional ore processing 

methods, they were not written in anticipation of new technologies such as heap leaching and in-situ leach/in-situ 

recovery (ISL/ISR). With ISL/ISR operations expected to be the most common type of new uranium extraction 

facility in the U.S., and the potential for these facilities to affect groundwater, EPA has prepared the attached draft 

Technical Report, which addresses considerations involved in establishing groundwater monitoring systems 

around uranium ISL/ISR operations. 

There are several objectives for monitoring an ISL/ISR uranium extraction operation, specifically:

1) to establish baseline (pre-mining) groundwater chemical compositions;

2) to detect excursions of the injected and mobilized components beyond the well field; and

3) to determine when the post-mining/restoration phase groundwater chemistry has “stabilized,” i.e., 

reached concentration levels that are expected to remain constant over time.

EPA is considering including groundwater monitoring requirements as a component of the regulatory standards 

included in any revision of 40 CFR Part 192. The draft Technical Report is intended to support the technical 

considerations about monitoring requirements (e.g., sampling protocols, timeframes, statistical tools and 

techniques) that may be included in revisions to 40 CFR Part 192.
.

A-2

Specific Request 

At this time, EPA is seeking advice from the RAC on the technical considerations relevant to establishing 

monitoring plans to achieve the objectives described above. The Technical Report focuses on these 

considerations for designing and implementing a monitoring network. After receiving the advisory review, EPA 

plans to revise the Technical Report and use the information as a basis for updating 40 CFR Part 192 to explicitly 

address ISL/ISR extraction processes. 

Specifically, EPA requests that the RAC provide comments on the following:

1) The technical areas described in the report and their relative importance for designing and 

implementing a monitoring network. Identify any technical considerations that have been omitted or 

mischaracterized.

2) The proposed approaches for characterizing baseline groundwater chemical conditions in the premining phase and proposed approaches for determining the duration of such monitoring to establish 

baseline conditions.

3) The approaches considered for monitoring in the post-mining/restoration phase and the approaches 

considered for determining when groundwater chemistry has reached a “stable” level.

4) Suitable statistical techniques that would be applicable for use with ISL/ISR mining applications 

(particularly for the areas in Items 2 and 3 above), as well as the subsequent data requirements for 

their use.

If you have any questions about this request, please contact Mary E. Clark of my staff at (202) 343-9348.

Attachment

cc: Carl Mazza, OAR
.

B-1

APPENDIX B. WATER QUALITY PARAMETERS FOR GROUNDWATER 

MONITORING AT ISL URANIUM MINING SITES 

Table B-1. Primary and secondary water-quality parameters (see discussion in Section 4.3)

Parametera,b

Primary Relevance for Baseline 

Determination and Post-Operational 

Monitoringc

Mentioned in NRC guidance 

and/or baseline data 

reported by operator or 

applicant

Mentioned in 

Regulations or EPA 

Screening Level 

Guidance

NRC 2003Crownpoint License (NM)Production Authorization Areas (PAAs) (TX)Dewey-Burdock (ND)Applicable EPA and NRC regulationsd

Other EPAgroundwater standards or screening levelse

Major Ions

Bicarbonate Excursion indicator, geochemical modeling, 

source fingerprint

● ● ● ● ─ ─

Calcium Source fingerprint, geochemical modeling ● ● ● ● ─ ─

Carbonate Geochemical modeling ● ● ● ● ─ ─

Chloride Excursion indicator, geochemical modeling, 

source fingerprint

● ● ● ● ─ SMCL

Fluoride Source fingerprint, geochemical modeling ● ● ● ● ─ SMCL, 

RSL

Magnesium Source fingerprint, geochemical modeling ● ● ● ● ─ ─

Nitrate Redox indicator, source fingerprint ● ● ● ● ─ MCL

Potassium Source fingerprint, geochemical modeling ● ● ● ● ─ ─

Silica Well performance indicator, geochemical 

modeling

─ ─ ● ● ─ ─

Sodium Source fingerprint, geochemical modeling ● ● ● ● ─ ─

Sulfate Excursion indicator, geochemical modeling, 

source fingerprint

● ● ● ● ─ SMCL

Trace Nonmetal Constituents

Ammonia Redox indicator, geochemical modeling ● ● ─ ● ─ RSL, HA

Phosphate Geochemical modeling ─ ─ ─ ─ ─ ─

Sulfide Redox indicator, geochemical modeling ─ ─ ─ ─ ─ ─

General Water Chemistry

Alkalinity Excursion indicator, geochemical modeling, 

source fingerprint

● ● ● ● ─ ─

Total 

Dissolved 

Solids

Excursion indicator, well performance 

indicator

● ● ● ● ─ SMCL

Total Organic 

Carbon

Well performance indicator ─ ─ ─ ─ ─ ─

Total 

Suspended 

Solids

Well performance indicator ─ ─ ─ ─ ─ ─
.

B-2

Parametera,b

Primary Relevance for Baseline 

Determination and Post-Operational 

Monitoringc

Mentioned in NRC guidance 

and/or baseline data 

reported by operator or 

applicant

Mentioned in 

Regulations or EPA 

Screening Level 

Guidance

NRC 2003Crownpoint License (NM)Production Authorization Areas (PAAs) (TX)Dewey-Burdock (ND)Applicable EPA and NRC regulationsd

Other EPAgroundwater standards or screening levelse

Field Parameters

Dissolved 

Oxygen

Redox indicator, well performance indicator ─ ─ ─ ─ ─ ─

Oxidation 

Reduction 

Potential

Redox indicator, well performance indicator ─ ─ ─ ● ─ ─

pH Excursion indicator, geochemical modeling, 

source fingerprint

● ─ ● ● ─ SMCL

Conductivity Excursion indicator, well performance 

indicator

● ● ● ● ─ ─

Temperature Well performance indicator ─ ─ ─ ─ ─ ─

Turbidity Well performance indicator ─ ─ ─ ─ ─ ─

Water level Excursion indicator, well performance 

indicator

─ ─ ─ ─ ● ─

Trace Metals

Aluminum Well performance indicator, geochemical 

modeling, source fingerprint for trace metals

● ─ ─ ● ─ SMCL,

RSL

Antimony ─ ─ ─ ─ ● ● MCLG, 

RSL

Arsenic Mobilized COC, redox indicator ● ● ● ● ● MCL

Barium Mobilized COC, geochemical modeling, 

source fingerprint

● ● ─ ● ● MCL

Beryllium ─ ─ ─ ─ ● ● MCL

Boron Source fingerprint ● ● ─ ● HA, RSL

Cadmium ─ ● ● ● ● ● MCL

Chromium Mobilized COC, redox indicator, 

geochemical modeling

● ● ─ ● ● MCL

Cobalt ─ ─ ─ ─ ─ ─ RSL

Copper Mobilized COC, geochemical modeling ● ● ─ ● ─ MCLG, 

SMCL

Iron Well performance indicator, redox indicator, 

geochemical modeling

● ● ● ● ─ SMCL, 

RSL

Lead Mobilized COC, geochemical modeling ● ● ● ● ● MCL

Manganese Well performance indicator, redox indicator, 

geochemical modeling

● ● ● ● ─ HA, 

SMCL, 

RSL

Mercury Mobilized COC ● ● ● ● ● MCL
.

B-3

Parametera,b

Primary Relevance for Baseline 

Determination and Post-Operational 

Monitoringc

Mentioned in NRC guidance 

and/or baseline data 

reported by operator or 

applicant

Mentioned in 

Regulations or EPA 

Screening Level 

Guidance

NRC 2003Crownpoint License (NM)Production Authorization Areas (PAAs) (TX)Dewey-Burdock (ND)Applicable EPA and NRC regulationsd

Other EPAgroundwater standards or screening levelse

Molybdenum Mobilized COC, excursion indicator, redox 

indicator, geochemical modeling

● ● ● ● ● HA, RSL

Nickel Mobilized COC ● ● ─ ● ● HA, RSL

Selenium Mobilized COC, excursion indicator, redox 

indicator, geochemical modeling

● ● ● ● ● MCL

Silver ─ ● ● ─ ● ● HA, 

SMCL, 

RSL

Strontium Geochemical modeling, source fingerprint ─ ─ ─ ● ─ HA

Thallium ─ ─ ─ ─ ● ● MCL

Thorium Mobilized COC ● ─ ─ ● ● ─

Uranium Mobilized COC, excursion indicator, redox 

indicator, geochemical modeling

● ● ● ● ● MCL

Vanadium Mobilized COC, excursion indicator, redox 

indicator, geochemical modeling

● ● ─ ● ● RSL

Zinc Mobilized COC, geochemical modeling ● ● ─ ● ─ HA, 

SMCL, 

RSL

Radiological parameters

Gross alpha Excursion indicator, mobilized COC ● ● ─ ● ● MCL

Gross beta + 

gross gamma

Excursion indicator, mobilized COC ● ● ─ ● ─ MCL

Radium-226 Excursion indicator, mobilized COC ● ─ ● ● ─ MCL

Radium-228 Excursion indicator, mobilized COC ● ● ─ ─ ● MCL

Radon Mobilized COC ─ ─ ─ ● ─ MCL

Additional site-specific parameters

Constituents in injected solutions, e.g., lixiviants, antiscalants, 

pH adjustment, chemicals used during groundwater 

restoration 

● ─ ─ ─ ─ ●

Constituents likely to be present in spills or leaks, e.g., acids, 

bases, salts, oxidants, reductants, pregnant lixiviantf 

─ ─ ─ ─ ─ ─

a This list was compiled based on examination of parameters listed in EPA’s draft technical report (U.S. EPA 2011a, 

Section 4.2 and Attachment A), 40 CFR Part 192, EPA’s Drinking Water Standards and Health Advisories (U.S. EPA 

2011b), and Table 2.7.3-1 in U.S. NRC 2003.

b Parameters may be added to, or removed from, this list based on site-specific considerations. 

c “Source fingerprint” indicates the parameter is commonly used to distinguish among different types of groundwater, such 

as the field in which the sample is plotted on a trilinear (Piper) diagram. “Geochemical modeling” indicates this parameter 

is commonly used to model the rates and interdependencies of water-chemistry reactions in geologic media, principally 
.

B-4

redox reactions, mineral-dissolution/precipitation reactions, sorption and ion-exchange reactions. “Mobilized COC” 

indicates the parameter is a contaminant of concern (COC) that may be released into the groundwater as a direct or 

indirect result of mining or restoration activites.

d Applicable EPA and NRC regulations include 10 CFR Part 40, 40 CFR Part 192, and 40 CFR Part 264. 

e Other relevant EPA groundwater standards and screening levels include maximum concentrations levels (MCLs), 

secondary MCLs (SMCLs), MCL goals (MCLG) and health advisories (HA) for drinking water (U.S. EPA. 2011b), and 

EPA regional screening levels (RSLs) for tapwater (U.S. EPA Regions 3, 6, and 9. 2011).

f “Pregnant lixiviant” refers to the uranium-bearing leachate solution that is recovered from the production wells.
.

B-5

Table B-2. Other Water-Quality Characterization Parameters (see discussion in Section 4.3)

Parameter Comments

Redox Couples

Ammonia (aqueous)/nitrate ─

Arsenic (III)/(V) ─

Chromium (III)/(VI) ─

Iron (II)/(III) ─

Sulfide/sulfate ratio In addition to providing information about in-situ redox conditions, the 

sulfide/sulfate ratio will also help to understand and explain aqueous 

concentrations of radium.

Manganese (II)/(IV)/(VII) ─

Selenium (-II)/(0)/(IV)/(VI) Data reported for selenium (IV) and selenium (VI) for Dewey-Burdock 

site (U.S. EPA 2011a, Table A-1). Measurement of selenium oxidation 

states would be helpful from an analysis standpoint but due to analytical 

limitations may not be necessary. Also, there are certainly practical 

limitations in sampling frequency.

Uranium (IV)/(VI) ─

Stable Isotope Ratios

Carbon-13/Carbon-12 Potential tracer of sources, groundwater mixing, kinetic rates of 

geochemical processes, microbial activity 

Hydrogen and oxygen isotopes Potential tracer of sources, groundwater mixing

Sulfur-34/Sulfur-32 Potential tracer of sources, groundwater mixing, kinetic rates of 

geochemical processes, microbial activity 

Uranium-decay series

Lead-210 Data reported for Dewey-Burdock site (U.S. EPA 2011a, Table A-1). 

Mentioned in NRC 2003 but discounted

Polonium-210 Data reported for Dewey-Burdock site (U.S. EPA 2011a, Table A-1).

Radon-222 Data reported for Dewey-Burdock site (U.S. EPA 2011a, Table A-1).

Thorium-230 Data reported for Dewey-Burdock site (U.S. EPA 2011a, Table A-1).

Radium-226 ─

Radium-228 ─

Uranium-234/Uranium-238 Activity ratio is an indicator of uranium release and transport processes, 

attenuation.

Other Characterization Parameters

Carbonate/sulfide ratio This ratio is a key indicator for the effectiveness of groundwater 

restoration in the mined unit during the post-mining phase. If there is 

insufficient neutralization potential remaining in the unit, it is likely to 

continue to oxidize from remnant lixiviant and cause mobilization of 

U(VI) and other contaminants.

Microbial community 

composition and activity

Redox control; indicator of potential for microbial processes to contribute 

significantly to monitored natural attenuation (MNA) for long-term 

groundwater restoration (e.g., see Ford et al. 2008, Li et al. 2011, U.S. 

EPA 2010).

Colloid concentration and 

composition

Transport mechanism