Jackpile-Paguate Uranium Mine Site

July 1, 2018

Background

The Jackpile-Paguate Uranium Mine site once operated

between 1953 to 1982 and was perhaps the largest open pit

uranium mine in the world. About 22 million tons of ore were

extracted from 2,656 acres of mined area. Historically, mine

reclamation work was first conducted by the Anaconda Copper

and Mining Company, a predecessor to the Atlantic Richfield

Company. Reclamation was later conducted by the Laguna

Construction Company under a U.S. Department of Interior

Record of Decision (ROD), which is a public document that

explains the remediation plan for a site. Elevated uranium

levels in surface water samples led the Pueblo of Laguna

(POL) to seek potential National Priorities List (NPL) site listing

from the U.S. Environmental Protection Agency (EPA). See

Page 2 for more information on reclamation.

The Jackpile-Paguate Uranium Mine Superfund site was

placed on the NPL on December 12, 2013, making the site

eligible for cleanup under the EPA’s Comprehensive

Environmental Response, Compensation, and Liability Act

(CERCLA) program and authority. “CERCLA”, also known as

EPA’s “Superfund” program, addresses the nation’s most

complex hazardous-waste sites. Superfund responses are

conducted either as emergency response actions to reduce or

eliminate immediate threats to human health, or as permanent

remedial actions for cleanup.

A CERCLA Administrative Order on Consent (AOC) was

issued on July 1, 2017, which requires the Atlantic Richfield

Company to perform a CERCLA Remedial Investigation and

Feasibility Study (RI/FS) under EPA’s technical oversight and

approval. This Newsletter update was produced under EPA’s

Superfund Community Involvement process to update the POL

community on the current RI/FS actions taking place at the

site.

The ”RI” is intended to characterize the nature and extent of

any identified contamination at the site, and to assess any

related potential risks to human health and the environment.

The “FS” identifies, evaluates and recommends technical

options for cleaning up, or remediating, the site. Upon

completion of the RI/FS, a future remedy will be proposed by

EPA, and after public input, the selected remedy will be

confirmed by EPA in a Record of Decision (ROD .

Remedial Investigation / Feasibility Study (RI/FS) Activities

RI/FS Activities Performed to Date

• Atlantic Richfield Company hired TREC Inc. to serve as

their environmental contractor. EPA hired Tetra Tech, Inc.

to provide technical review and oversight support.

• Scoping meeting and site visit with the three technical

teams (EPA, Atlantic Richfield Company, and POL

Environmental and Natural Resources Department) held

on August 2-3, 2017.

• The POL Community meets the technical teams at a “Meet

and Greet” held at the Pueblo Auditorium on September 6,

2017.

• Atlantic Richfield Company developed and submitted Draft

and Draft Final versions of the Preliminary Conceptual Site

Model (PCSM), an important planning document, which

were reviewed by EPA and the POL ENRD. See Page 2

for more information on the purpose of a PCSM.

• AR developed and submitted Draft and Draft Final Interim

Work Plans (IWP) to support the development of RI/FS

Work Plans to be reviewed by EPA and the POL ENRD.

See Page 2 for more information on the goals and

objectives of the IWPs. f w

cc

HO

W T

HE

SU

PE

RF

UN

D P

RO

CE

SS

WO

RK

S F

OR

CO

MM

UN

ITIE

S

Co

ntam

inated sites are

bro

ug

ht

to th

e a

tten

tion o

f EP

A b

y states,

tribe

s or th

e p

ub

lic.

STEP FIVE: P

RO

PO

SE

D P

LAN

/RE

CO

RD

O

F DE

CIS

ION

Afte

r inp

ut fro

m a

ny affecte

d state

or

tribe, and afte

r pu

blic co

mm

en

ts are

rece

ived o

n the

Propo

sed Plan

, a fina

l d

ecision on th

e re

me

dy is m

ad

e by EPA

in th

e R

ecord of D

ecision (RO

D).

T

EP

A cond

ucts a pre

limin

ary assessm

ent (P

A) a

nd a site investigation (SI). A

P

A

involves g

athering histo

rical a

nd cu

rren

t info

rma

tion

. The SI focuses on

samp

ling

to d

ete

rmine if th

ere

is a re

lease o

f hazardous su

bsta

nces. T

his info

rma

tion

is used to d

ete

rmin

e if

a site th

reat exists a

nd if furth

er

inve

stiga

tion is needed

.

STEP SIX: R

EM

ED

IAL

AC

TION

A R

emed

ial Design is developed

with

the

cleanu

p criteria

and

en

gin

ee

ring

req

uire

me

nts fo

r the

rem

ed

y selected in the

RO

D. T

he R

emedial A

ction includes bu

ildin

g th

e rem

edy.

40

• STEP THR

EE: N

PL LIS

TING

EPA

uses its Hazard R

anking S

ystem to

determ

ine

if the site

could be e

ligible for

listing

on

to the N

ational Priorities List

(NP

L) and e

ligible

for clean

up

under

Superfund rem

edial au

tho

rity. Sites are

added to the N

PL by Age

ncy ru

lem

aking

, w

ith public co

mm

en

t.

40

STE

P SEV

EN: C

LOSE O

UT A

ND

R

EM

OV

AL F

RO

M N

PL

Wh

en

Cle

anup Goals have been

me

t by achievin

g all o

bje

ctives, d

ata

is collected to su

pp

ort th

e d

ele

tion

o

f the

Site fro

m th

e N

PL Listing.

Sites a

re d

elete

d fo

rm th

e N

PL by

Agency r ule

ma

king, with

public

co mm

en

t.

INV

ES

TIGA

TION

& FE

AS

IBILITY

S

TUD

Y B

EG

INS

S

amplin

g is cond

ucted to

understand th

e n

atu

re an

d exte

nt o

f the co

nta

min

atio

n. T

he level o

f ri sk to

hum

an health

an

d th

e e

nviro

nm

en

t is qua

ntified

. Clea

nu

p o

ptio

ns are

developed to

address th

e risks. A

P

rop

osed P

lan is cre

ated with

a P

referre

d A

ltern

ative

cleanup plan.

STEP EIG

HT:

FIVE

-YE

AR

RE

VIE

W

An evalua

tion

is perfo

rmed e

very five

yea

rs to d

eterm

ine if the re

medy re

­m

ains p

rote

ctive a

t sites n

ot clea

red fo

r unlimite

d u

se and un

restricted

exposu

re.

AT

AN

Y T

IME

DU

RIN

G T

HE

PR

OC

ES

S, S

ites ca

n be

refe

rred

to th

e Rem

oval P

rog

ram if a

n imm

i­

ne

nt th

rea

t or e

nd

an

ge

rme

nt to

pu

blic h

ea

lth o

r the

env

iron

me

nt is pre

se

nt.

Th

is e

na

cts an imm

ed

i­a

te R

em

ova

l Actio

n.

En

force

me

nt a

nd

Co

mm

un

ity Invo

lve

me

nt A

ctivitie

s o

ccur th

rou

gh

out th

e S

up

erfu

nd

pro

cess.

&EPA

Current RI/FS Activities Following are current RI/FS activities being performed:

Atlantic Richfield Company is finalizing the PCSM for

EPA’s approval. The Final PCSM will be completed

prior to development of, and will serve as a significant

basis for, the development and submittal of the RI/FS

Work Plans. See “What is the Purpose of the

Preliminary Conceptual Site Model?” below for more

details.

Finalize/approve/ Implement Interim Work Plans:

Atlantic Richfield Company is finalizing the IWPs for

EPA’s approval. EPA’s goal is for the field work

associated with the IWPs to be completed before the

end of the Fall 2018 field season. See “What are the

Goals and Objectives for the Interim Work Plans?”

below for more details.

Future RI/FS Activities

Interim Work Plan Field Efforts: EPA and the POL

ENRD are working with the Atlantic Richfield Company

on scheduling field activities associated with the IWPs.

Development of RI/FS Work Plans: Atlantic Richfield

Company will develop the Draft RI/FS Work Plans for

EPA technical review and comment. Atlantic Richfield

Company will then develop and submit the Draft Final

RI/FS work plans.

RI Field Efforts: Upon completion and EPA approval of

the Final RI/FS Work Plans, Atlantic Richfield Company

will initiate the RI field efforts. Work is anticipated to

begin in 2019.

What is the Difference Between

Reclamation and Remediation?

Reclamation restores land that has been mined to a

natural or economically usable state. Reclamation often

does not require quantifiable risk analysis prior to recla-

mation. Remediation addresses contamination-related

risks to human health and the environment to the extent

practicable, or above acceptable and quantifiable can-

cer risk ranges. Site reclamation efforts took place both

while the mine was operational and after the mine

closed. Previous reclamation efforts focused on mitigat-

ing hazards, restoring the areas disturbed by filling and

contouring, and returning it to natural landscape condi-

tions. The results of the RI/FS will help determine any

remediation that may be required.

What is the Purpose of a Preliminary Conceptual Site Model?

The Atlantic Richfield Company is developing a PCSM

to summarize what is presently known about the site

conditions, and to use that knowledge as the basis for

identifying what is not known. Site unknowns identify

what information is needed (“data gaps”) to fully

characterize the site. The RI/FS Work Plans are

developed to describe the RI activities to be performed,

specifically the collection of new site data for the

purposes of addressing the data gaps. The RI/FS Work

Plans outline the investigation goals and methods to be

used to evaluate how much contamination remains, the

sources of contamination, and how it is transported

within various site media, such as soil, sediment,

surface water, groundwater and air. This information is

then used to identify and determine where and how site

contaminants could potentially affect human health or

the environment.

The EPA commonly refers to contaminant migration as

defining the “fate and transport” of site contaminants.

Understanding fate and transport of site contaminants is

a key basis for supporting a remedy evaluation,

selection, design and implementation for a site.

What are the Goals and Objectives

for the Interim Work Plans?

The Atlantic Richfield Company developed five Interim

Work Plans (IWPs) to collect preliminary information

about the site to better inform the development of the

comprehensive RI/FS Work Plans. The following

summaries describe each of the IWPs:

Meteorological System Interim Work Plan: This

IWP describes efforts to identify an appropriate

location for setting up a meteorological monitoring

station (met station), which is comprised of

various instruments for measuring weather-related

information. Collection of long-term meteorological

data from the site, for example, how frequently and

how much rainfall or snowfall is observed on-site,

will help identify how erosion is affecting the site and

how contaminants in surface water and sediments

are moving in, and outside of the site boundaries.

Other weather conditions will be measured and

monitored, including 24-hour wind speed and wind

direction. This information will also better inform

efforts to monitor air for radiological exposure.

Air Monitoring for Radiological Exposure Interim Work

Plan: This IWP will improve the understanding of

current air quality conditions occurring on and near

the site. The initial work step is to determine the best

locations for setting up a network of instruments for

sampling airborne radioactive contaminants and

ambient radiation levels occurring on-site and that

could be migrating off-site.

Monitoring Well Inspection Interim Work Plan: This

IWP describes efforts to locate existing groundwater

monitoring wells on site and to assess their current

condition regarding potential future use in the RI field

efforts. The team will evaluate well construction,

physical integrity, total well depth, and well-screen

interval.

Visual Site Inspection Interim Work Plan: This IWP

describes efforts to visually inspect the entire site to

identify areas of concern related to erosion occurring

from former waste or protore piles. An additional goal

is to develop an initial understanding of the surface

water flow patterns and conditions in relation to

potential contaminant transport in surface water and

sediments.

Unmanned Aerial Vehicle Survey Interim Work Plan:

This IWP describes efforts to collect visual imagery at

the former mine site from an unmanned aerial vehicle

(UAV). The objective of the survey is collect infor-

mation about the disturbed mining areas, including

areas within the former leased boundaries, and in-

cludes the Rio Paguate, Rio Moquino and Mesita

Dam. The UAV can access difficult and inaccessible

terrain more efficiently than land-based vehicles or

foot travel. EPA deferred oversight of this field effort to

the POL ENRD.

Contact US EPA Region 6:

Remedial Project Manager Petra Sanchez (214) 665-6686 sanchez.petra@epa.gov Community Involvement Coordinator Adam Weece (214) 665-2264 weece.adam@epa.gov For more information on the site see the following website: https://www.epa.gov/superfund/jackpile-paguate

Finalize/approve Preliminary Conceptual Site Model: