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Cimarron Environmental Response Trust Hydrogeologic Pilot Test Report
	ML20213C658
Person / Time
Site:	07000925
Issue date:	02/28/2013
From:	; Burns & McDonnell Engineering Co, Enercon Services, Environmental Properties Management
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, State of OK, Dept of Environmental Quality (DEQ)
Shared Package
ML20213C674	List: ML20213C658; ML20213C662; ML20213C663;
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	Download: ML20213C658 (42)
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Cimarron Environmental Response Trust Hydrogeologic Pilot Test Report prepared for U. S. Nuclear Regulatory Commission Rockville, MD OK Department of Environmental Quality Oklahoma City, OK February 2013 Project No. 65714 prepared by Burns & McDonnell Engineering Company, Inc.

Kansas City, Missouri with consultants Enercon Services, Inc.

Oklahoma City, OK

Hydrogeologic Pilot Test Report Draft Table of Contents TABLE OF CONTENTS Page No.

CHAPTER 1 - INTRODUCTION ................................................................................ 1-1 FACILITY BACKGROUND .......................................................................................... 1-1 DECOMMISSIONING STATUS ................................................................................... 1-1 HYDROGEOLOGIC PILOT TEST ................................................................................ 1-2 Subarea F Confirmatory Survey .......................................................................... 1-3 Extent of Uranium Impact ................................................................................... 1-3 Extent of Nitrate in the Western Alluvial Area ................................................... 1-3 BA #1 Transition Zone Aquifer Parameters ........................................................ 1-3 Western Alluvial Area Aquifer Parameters ......................................................... 1-4 Groundwater Storage and Disposition ................................................................. 1-4 Soil Storage and Disposition ................................................................................ 1-4 CHAPTER 2 - SUBAREA F CONFIRMATORY SURVEY ........................................... 2-1 CHAPTER 3 - EXTENT OF URANIUM IMPACT ......................................................... 3-1 INTRODUCTION ........................................................................................................... 3-1 DRILLING AND WELL INSTALLATION ................................................................... 3-1 GROUNDWATER SAMPLING RESULTS .................................................................. 3-2 EXTENT OF URANIUM IN THE WESTERN AREAS ................................................ 3-3 CHAPTER 4 - EXTENT OF NITRATE AND FLUORIDE IMPACT ............................... 4-1 INTRODUCTION ........................................................................................................... 4-1 DRILLING AND WELL INSTALLATION ................................................................... 4-1 GROUNDWATER SAMPLING RESULTS .................................................................. 4-2 EXTENT OF NITRATE AND FLUORIDE IN THE WESTERN AREAS ................... 4-2 CHAPTER 5 - BA #1 TRANSITION ZONE AQUIFER TESTING ................................ 5-1 INTRODUCTION ........................................................................................................... 5-1 DRILLING AND WELL INSTALLATION ................................................................... 5-1 GROUNDWATER SAMPLING RESULTS .................................................................. 5-2 AQUIFER TESTING ....................................................................................................... 5-3 Pumping Test ....................................................................................................... 5-3 Well Selection ...................................................................................................... 5-3 Slug Test Results .................................................................................................. 5-3 CHAPTER 6 - WESTERN ALLUVIAL AREA AQUIFER TESTING ............................. 6-1 INTRODUCTION ........................................................................................................... 6-1 DRILLING AND WELL INSTALLATION ................................................................... 6-1

Hydrogeologic Pilot Test Report Draft Table of Contents GROUNDWATER SAMPLING RESULTS .................................................................. 6-2 AQUIFER TESTING .................................................................................... .... ......... ...... 6-2 Step-Rate Drawdown Test ................................................................................... 6-2 Constant Rate Drawdown Test ............................................................................ 6-3 Pneumatic Slug Tests ........................................................................................... 6-6 CHAPTER 7 - GROUNDWATER STORAGE AND DISPOSITION ............................. 7-1 INTRODUCTION ........................................................................................................... 7-1 GROUNDWATER SAMPLING RESULTS .................................................................. 7-1 DEMOBILIZATION ....................................................................................................... 7-1 CHAPTER 8 - SOIL STORAGE AND DISPOSITION .................................................. 8-1 CHAPTER 9 - CONCLUSIONS AND RECOMMENDATIONS .................................... 9-1 CONCLUSIONS .............................................................................................................. 9-1 Sub area F Confirmatory Survey .......................................................................... 9-1 Extent of Uranium Impact ................................................ ................................... 9-1 Extent of Nitrate Impact.. ..................................................................................... 9-1 BA #1 Transition Zone Aquifer Testing .............................................................. 9-1 Western Alluvial Area Aquifer Testing ............ ................................................... 9-2 RECOMMENDATIONS ............................................ ..................................................... 9-2 Subarea F Confirmatory Survey .......................................................................... 9-2 Extent of Uranium Impact ................................................................................... 9-3 Extent of Nitrate and Fluoride Impact ................................................................. 9-3 CHAPTER 10 - REFERENCES .............................................................................. 10-1 APPENDIX A - SOIL BORING LOGS APPENDIX B -WELL INSTALLATION FORMS APPENDIX C - BURIAL AREA #1 AQUIFER TEST RESULTS APPENDIX D - WESTERN ALLUVIAL AREA AQUIFER TEST RESULTS APPENDIX E - STORAGE COEFFICIENT SENSITIVITY ANALYSIS

Hydrogeologic Pilot Test Report Draft Table of Contents LIST OF TABLES Table No.

2-1 Laboratory Results for Subsurface Soil Confirmatory Survey 3-1 Laboratory Results for Groundwater 7-1 Laboratory Results for Frac Tank Water 8-1 Laboratory Results for Soil Cuttings

Hydrogeologic Pilot Test Report Draft Table of Contents LIST OF FIGURES Figure No.

1-1 Site Location 1-2 Site Image 1-3 Site Subareas and Areas of Groundwater Impact 2-1 Borings and Wells in Burial Area # 1 3-1 Uranium Exceeding Groundwater Criteria in Burial Area #1 3-2 Uranium Exceeding Groundwater Criteria in Western Alluvial and Upland Areas 4-1 Nitrate and Fluoride Exceeding Groundwater Criteria in Western Alluvial and Upland Areas 9-1 Terrace Deposits and Middle B Sandstone Groundwater Elevations and Proposed Monitor Well Locations in Burial Area #1 9-2 Terrace Deposits and Middle B Sandstone Groundwater Elevations and Proposed Monitor Well Locations in the Western Alluvial and Upland Areas

Hydrogeologic Pilot Test Report Draft Introduction CHAPTER 1 - INTRODUCTION FACILITY BACKGROUND The Site comprises over 500 acres of rolling hills and 200 acres of floodplain at the intersection of Highways 74 and 33, approximately seven miles south of Crescent, OK (Figure 1-1). Grassland and temperate forest covers nearly all the property, and two ponds collect surface water from upland areas.

Several miles of minimally maintained roads and parking areas, and three buildings remain on the property.

The Cimarron facility was formerly operated by Kerr-McGee Nuclear Corporation (KMNC), a wholly owned subsidiary of Kerr-McGee Corporation. The Cimarron facility operated under two Special Nuclear Material Licenses. License SNM-928 was issued for the production of uranium fuel, and License SNM-11742 was issued for the production of mixed oxide fuel. The principal operation under License SNM-928 involved the fabrication of enriched uranium reactor fuel pellets, and eventually fuel rods.

Enriched uranium fuel was produced at the Uranium Plant from 1966 through 1975. Process facilities included a main production building; several one-story ancillaiy buildings, five process related collection ponds, two original sanita1y lagoons, one new sanitary lagoon, a waste incinerator, several uncovered storage areas, and three burial grounds. The main production building was divided into six major areas:

ceramic UO2, pellet, scrap recycle and recove1y, waste treatment, fabrication and the high enriched area.

In addition, space was provided for auxiliaiy services such as office, laboratory, maintenance, and warehousing. Figure 1-2 shows the location of the relevant features of the facility, including the former buildings, roads, burial sites, and impoundments.

The site was divided into 16 "Subareas", designated Subareas A through O (there are two areas, both of which contained uranium waste ponds, designated Subarea 0), to facilitate the decommissioning and final survey process (Figure 1-3). Decommissioning of materials and equipment, buildings and structures, and surface and subsurface soils is complete, and Final Status Survey Reports have been submitted for all these media for all 16 Subareas.

DECOMMISSIONING STATUS Licensed material exceeds decommissioning criteria for unrestricted release only in groundwater. The concentration of uranium in groundwater must be reduced to achieve unrestricted release of the site and license termination. The Derived Concentration Goal Level (DCGL) for the site is 180 picoCuries per Cimarron Environmental Response Trust 1-1 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Introduction liter (pCi/1) total uranium, and the Oklahoma Department of Environmental Quality (DEQ) has approved a toxicological concentration release criterion of 110 micrograms per liter (µg /1) for uranium in groundwater. In addition to uranium, groundwater in portions of the Site contains two non-radiological chemicals of concern (COCs): nitrate and fluoride. DEQ has approved site-specific risk-based concentration limits of 52 milligrams per liter (mg/I) for nitrate and 4 mg/I for fluoride . The intent of this investigation is to enable the Trustee to reduce the concentrations of all COCs in groundwater to less than their release criteria. Post-remediation monitoring will be performed to demonstrate compliance with the release criteria for uranium prior to requesting termination of the license, and with all COCs prior to obtaining release of the site for unrestricted use from DEQ.

Uranium exceeds the license release criterion of 180 pCi/1 in three areas: Burial Area# 1 (BA# 1), the Western Upland (WU) Area and the Western Alluvial (WA) Area (ENSR, 2006a and Cimarron, 2007).

These areas are illustrated in Figure 1-3. Uranium exceeds the DEQ criterion of 110 µg/1 in these same areas, and the extent within those areas roughly matches the extent of uranium exceeding the NRC criterion. The extent of uranium impact to groundwater has been adequately delineated for the development of a groundwater remedy. Years of environmental monitoring have already demonstrated that nitrate and/or fluoride exceed DEQ criteria in the following areas: the WU Area, the WA Area, the Uranium Pond #1 (UPI) Area, the Uranium Pond #2 (UP2) Area, and the uranium plant storage yard (Well 1319 Area). These areas are also illustrated in Figure 1-3. The extent of nitrate and fluoride impact had not been adequately delineated to enable an evaluation of potential alternative groundwater remediation technologies.

HYDROGEOLOGIC PILOT TEST A groundwater remediation system and site decommissioning plan will be submitted to enable EPM to complete decommissioning activities and achieve license termination. The goal of the remediation eff011 is to obtain release of the site for unrestricted use. It was determined that additional information was needed to enable EPM to design a groundwater remediation system and generate a complete site decommissioning plan. This information was obtained through the performance of a hydrogeologic pilot test which involved soil borings, well installations, sampling and analysis, and aquifer testing. The hydro geologic pilot test is the subject of this report.

In addition to the information listed below, it was determined that column testing is needed to enable the water treatment vendor (Clean Harbors) to design a water treatment system or systems for the Cimarron Environmental Response Trust 1-2 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Introduction groundwater remediation plan. Water treatment testing will be performed at the site and reported as a separate activity.

Subarea F Confirmatory Survey NRC has agreed that surface and subsurface soils throughout the site have been decommissioned to comply with criteria for unrestricted release, with one exception. In Subarea F, final status and confirmatory surveys have been performed for the burial ground, and a final status survey report has been submitted for surface and subsurface soil. In its November 2005 comments on the final status survey report, NRC expressed concerns regarding subsurface soil. Analytical results for approximately 2,000 subsurface soil samples were presented in a November 2007 report. As part of the hydrogeologic pilot test, NRC requested that subsurface samples be collected and retained for confirmatory survey purposes.

Section 2 of this report includes a description of the work performed and the analytical results obtained for samples submitted by EPM for laboratory analysis.

Extent of Uranium Impact The extent of groundwater containing uranium exceeding groundwater release criteria in the Western Upland and Western Alluvial Areas was fully delineated prior to the 2012 hydrogeologic pilot test. The only area in which groundwater containing uranium exceeding groundwater release criteria had not been fully delineated is at the northern end of the Burial Area # 1 plume. An additional monitor well (Well 13 61) was installed and sampled in an effmi to complete the delineation of uranium in groundwater in this area. Section 3 of this repmi includes a description of the work performed and the analytical results obtained for the sample collected from the new monitor well.

Extent of Nitrate in the Western Alluvial Area The only area in which groundwater containing nitrate exceeding its reopening criterion has not been fully delineated is at the northern end of the Western Alluvial Area plume. Two additional monitor wells (Wells T-91 and T-92) were installed and sampled in an effort to complete the delineation of nitrate in groundwater in this area. Section 4 of this report includes a description of the work performed and the analytical results obtained for the samples collected from the new monitor wells.

BA #1 Transition Zone Aquifer Parameters No aquifer test had been conducted in the Transition Zone in Burial Area #1 . Soil boring logs from installation of monitor wells indicates that this area typically has alternating layer of sand, silt, and clay from the ground surface to Sandstone C. A groundwater extraction well (Well GE-BAl-01) was installed Cimarron Environmental Response Trust 1-3 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Introduction in close proximity to several monitor wells so an aquifer test could be conducted to obtain hydraulic parameters for the groundwater flow model. Due to the inability of the well to yield sufficient water to conduct a pumping test, slug tests were performed on several monitor wells installed in the Transition Zone in Burial Area #1. Section 5 of this report includes a description of the work performed and the results obtained from aquifer testing.

Western Alluvial Area Aquifer Parameters No aquifer testing had been conducted in the alluvium in the Western Alluvial Area. Soil boring logs from installation of monitor wells indicates that this area typically has sand from grade to Sandstone C, and the sands are coarser than in the alluvium in Burial Area #1. A groundwater extraction well (Well GE-WA-01) was installed in close proximity to several monitor wells so an aquifer test could be conducted to obtain hydraulic parameters for the groundwater flow model. Section 6 of this report includes a description of the work performed and the results obtained from aquifer testing.

Groundwater Storage and Disposition A total of approximately 140,000 gallons of groundwater was produced through the development of newly installed wells, purging of wells for groundwater sampling, and the performance of aquifer pump testing. This water was contained in seven frac tanks, which required pre-mobilization scans and pre-demobilization release surveys. Section 7 of this report includes a description of the work performed and the results obtained from laboratory analysis of collected water, frac tank scans, and release surveys.

Soil Storage and Disposition Cuttings from confirmatory survey borings and borings advanced for monitor well and groundwater extraction well installation were contained in 55-gallon drums. Composite samples of cuttings were collected from each drum, and sent for laboratory analysis for isotopic uranium. Section 8 of this report presents the laboratory data received and the disposition of soil cuttings.

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Hydrogeologic Pilot Test Report Draft Subarea F Confirmatory Survey CHAPTER 2 - SUBAREA F CONFIRMATORY SURVEY Five soil borings were advanced in Burial Area # 1 to collect samples of subsurface soil for confirmat01y survey for Subarea F. Confirmatory sample boring locations were located along what was believed to be the centerline of the groundwater uranium plume to obtain soil samples with the highest uranium concentrations. Three borings were located in transition zone materials to obtain samples from locations containing more silts and clays, and presumably a higher distribution coefficient (Kd). Two borings were located in alluvial material just beyond the transition zone. Locating confirmatory sample borings in areas which the highest uranium concentrations in groundwater and the highest Kd material yields analytical results which are biased high relative to the rest of the subsurface soil in Subarea F. The locations of all boring advanced in Burial Area# 1 are shown on Figure 2-1.

Because the five initial borings were located in areas that were biased high, the activity plan included provisions to offset soil borings that yielded samples exceeding the release criterion of 30 pCi/g total uranium (net of background). The activity plan stated that if a soil sample yielded uranium above the release criterion, additional sampling would be necessmy to perform volumetric averaging to determine if subsurface soil complies with the decommissioning criteria.

All five borings were advanced by hollow stem auger, using a five-foot split barrel sampler to obtain subsurface soil samples. All five borings were advanced until sandstone (representing the top of Sandstone C) was recovered in the sampler shoe. One boring (GE-BAl-01) was later reamed to a larger diameter for installation of a groundwater extraction well. The other four borings (CS-BAl-01 through CS-BAl-04) were backfilled with a cement-bentonite grout in accordance with Oklahoma Water Resources Board (OWRB) regulations.

Lithology was recorded on soil boring log forms, which are included in this report as Appendix A. Soil cores were scanned with a gamma survey meter to identify zones of elevated gamma activity. The range of gamma activity was measured at each one-foot interval along the core; readings in counts per minute were recorded on the soil boring log forms.

Nearly 100% sample recovery was achieved on three of the borings: CS-BAl-01, CS-BAl-02, and GE-BAl-01. These three borings were advanced in the transition zone material, and the presence of more silt and clay in this area enabled the driller to obtain excellent recovery. Less than 50% recovery was achieved in the other two borings (CS-BAl-03 and CS-BAl-04), because these borings were advanced Cimarron Environmental Response Trust 2-1 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Subarea F Confirmatory Survey beyond the first few feet, the soil consisted of saturated, fine to coarse well-rounded sand, and even with the use of a sand catcher in the sampler shoe, only a few inches could be recovered from some of these zones.

Two 500-ml split samples (as recovery allowed) were obtained from each one-foot interval of core.

Samples were labeled with boring number, depth interval, and the suffixes "NRC" for one of the splits and "EPM" for the second split (e.g., CS-BAl-02-9'-1 0'-NRC and CS-BAl-02-9'-10'-EPM). The soil sample with the suffix "EPM" obtained from the one-foot interval yielding the highest gamma scan reading was sent to GEL Laboratory for isotopic uranium analysis.

Table 2-1 provides a tabulation of the laboratory data received for the five samples submitted to the laborato1y. Total uranium activity ranged from a low of 1.61 pCi/g to a maximum of 11.6 pCi/g (gross).

The laboratory results indicated that there was no need to offset any of the initial five borings.

Excluding the soil samples submitted to the laboratmy for analysis, all soil samples have been retained in the site office. NRC selected seven samples for delive1y to the ORAU Radioanalytical Laborato1y for analysis. Cuttings not collected as samples for laboratmy analysis were contained in drums. The sampling and disposition of soil cuttings are discussed in Section 8.

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Hydrogeologic Pilot Test Report Draft Extent of Uranium Impact CHAPTER 3 - EXTENT OF URANIUM IMPACT INTRODUCTION Groundwater assessment activities performed in 2002 and 2004 yielded a picture of the uranium plume (defined as the area within with groundwater exceeding the release criteria for uranium) in Burial Area

l. In 2004, it was believed that plume delineation was complete. Two monitor wells located near the northern end of the uranium plume, 02W43 and 02W44, yielded uranium activity below the release criterion of 180 pCi/1.

Additional data collected during the annual environmental monitoring program in 20 l 0 showed uranium activity decreasing in 02W43 , but increasing in 02W44. To this time, the site environmental monitoring program obtained only uranium activity results for groundwater samples. The decision was made to include uranium concentration data in future environmental monitoring programs so that results could be compared with both the NRC release criterion and the DEQ criterion of 110 µg/1.

During the annual environmental monitoring program performed in 2012, both uranium activity and uranium concentration data was obtained. The uranium activity in 02W43 was approximately half of the NRC release criterion (94 pCi/1), but the uranium concentration was approximately 90 % of the DEQ criterion (98 µg/1). However, in 02W44, uranium activity had increased to 3 73 pCi/1, twice the NRC release criterion and uranium concentration had increased to 363 µg/1, over three times the DEQ criterion.

Prior to the receipt of the 2012 data, EPM had proposed to install an additional monitoring well north of 02W43. Because the 2012 data indicated that the plume had shifted to the east, and that groundwater in 02W 44 significantly exceeded both NRC and DEQ criteria, it was decided to install the additional well nmiheast of 02W 44.

DRILLING AND WELL INSTALLATION Soil Boring 1361 was drilled approximately 125 feet north-northeast of Monitor Well 02W44, as shown in Figure 2-1 . The boring was advanced by hollow stem auger, using a five-foot split barrel sampler to obtain subsurface soil samples. The boring was advanced until sandstone (representing the top of Sandstone C) was recovered in the sampler shoe, at a depth of 29 feet. The total depth of the boring was 3 0 feet below grade. Lithology was recorded on soil boring log forms, which are included in this report as Appendix A. Cuttings not collected as samples for laboratory analysis were containerized in drums.

The sampling and disposition of soil cuttings are discussed in Section 8.

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Hydrogeologic Pilot Test Report Draft Extent of Uranium Impact Groundwater Monitor Well 1361 was installed as described in SAP-I 10, using 2-inch diameter schedule 40 polyvinyl chloride (PVC) well casing with 2-inch diameter schedule 40 PVC, 0.010-inch slotted screen. The well screen extends from the base of the alluvium (29 feet below grade) to unsaturated soil above the water table (estimated at approximately 11 feet below grade). The annular filter pack consisted of 20-40 silica sand. Well construction details were recorded on Well Installation Diagram forms, which are included in this report as Appendix B.

A 4-foot square concrete pad was installed around the monitor well, with a lockable steel protector pipe installed to secure access to the monitor well. A 3/4-inch galvanized steel pipe with cap was installed through the concrete pad, extending approximately five feet above the concrete pad so the well location can be seen when grass in the floodplain is tall. A brass monument was placed in the concrete pad to serve as a reference point for subsequent elevation measurements. Monitor well construction information was recorded on the monitor well installation diagram form.

Monitor Well 1361 was developed by pumping and surging and allowing the water to return to static water levels periodically. This required the production of approximately 150 gallons of groundwater.

Development continued until the field geologist approved termination of development activities.

Development water was transferred to the frac tanks located in the Western Alluvial Area. Well development information was recorded on the monitor well installation diagrams.

GROUNDWATER SAMPLING RESULTS A groundwater sample collected from Monitor Well 1361 was submitted to GEL Laboratory for uranium activity, uranium concentration, and nitrate/nitrite analysis. Analytical results for all groundwater samples collected during the 2012 hydrogeologic pilot test are tabulated in Table 3-1. Monitor Well 13 61 yielded groundwater containing 253 pCi/1 and 271 µg/1. Although both results are estimated values, they are significantly above both the NRC and DEQ criteria.

Figure 3-1 posts analytical results for uranium at locations that were sampled and analyzed in both 2004 and 2010, along with 2012 results for Monitor Well 1361 and other locations sampled during the 2012 hydro geologic pilot test. This figure delineates the uranium plume in Burial Area # 1 to the extent possible based on existing data.

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Hydrogeologic Pilot Test Report Draft Extent of Uranium Impact EXTENT OF URANIUM IN THE WESTERN AREAS No work was performed in the Western Upland Area during the 2012 hydrogeologic pilot test. However, because uranium data obtained for the 2012 annual environmental monitoring program was evaluated in areas where pilot test work would be performed in other areas. That evaluation indicated that changes in plume configuration were occurring, so uranium data obtained for the 2012 annual environmental monitoring program in the Western Upland and Western Alluvial Areas was also considered. Figure 3-2 posts analytical results for uranium at locations that were sampled and analyzed in both 2004 and 2010, along with 2012 results from the 2012 annual environmental monitoring program.

Figure 3-2 shows that, while the uranium plume in the Western Alluvial (WA) Area appears to be relatively stable, uranium activity and concentration in the Western Upland (WU) Area appears to be declining significantly. The uranium activity in Well 1351 (at the south end of the WU plume) and Well 1352 (at the north end of the WU plume) have both declined to less than the NRC criterion. The uranium concentration in Well 1351 has also declined to less than the DEQ criterion, and the uranium concentration in Well 1352 is approaching it. In addition, uranium activity in Well 1356 (in the "heart" of the plume) appears to be declining significantly.

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Hydrogeologic Pilot Test Report Draft Extent of Nitrate and Fluoride Impact CHAPTER 4 - EXTENT OF NITRATE AND FLUORIDE IMPACT INTRODUCTION Groundwater assessment activities performed from 2004 through 2010 were the basis for the delineation of nitrate and fluoride plumes (defined as the area within with groundwater exceeding the DEQ criterion for nitrate or fluoride) in the Western Upland (WU) Area, the Western Alluvial (WA) Area, the U-Pond

1 (UPI) Area, the U-Pond #2 (UP2) Area, in the Well 1319 Area, and near Monitor Well 1348. Nitrate and fluoride concentrations in Burial Area# 1 are within the normal range of background.

In the Western Alluvial Area, nitrate concentrations exceeding the DEQ criterion had not been bounded to the north, and there was a great distance between wells yielding relatively high nitrate concentrations and downgradient wells yielding concentrations below the DEQ criterion. For instance, Monitor Well T-54 yielded 122 mg/I nitrate, and Monitor Well T-53 yielded 36 mg/1 nitrate. However, Monitor Well T-53 is located almost 900 feet downgradient from Monitor Well T-54.

Additional groundwater assessment was performed during 2011 in an effort to better define the extent of nitrate in groundwater exceeding the DEQ criterion. Monitor Wells T-85 through T-88 were installed between the escarpment and the northernmost line of monitor wells. Because Monitor Well T-59 yielded nitrate concentrations more than twice the DEQ criterion, Monitor Wells T-89 and T-90 were installed northeast and n01ihwest of Monitor Well T-59. Data collected from all these wells helped further define the extent of nitrate exceeding the DEQ criterion, but Monitor Well T-89 yielded a nitrate concentration above the DEQ criterion of 52 mg/1, and 2011 data showed nitrate slightly exceeding the DEQ criterion in Monitor Well T-52.

During the annual environmental monitoring program performed in 2012, additional nitrate data was obtained. Because the nitrate concentration in Monitor Well T-89 was significantly above the DEQ criterion, two additional monitor wells (T-91 and T-92) were installed during the hydrogeologic pilot test.

DRILLING AND WELL INSTALLATION Soil Borings T-91 and T-92 were drilled approximately 100 feet north-northwest and 50 feet north-northeast of Monitor Well T-89, as shown in Figure 2-1. The borings were advanced by hollow stern auger, using a five-foot split barrel sampler to obtain subsurface soil samples. The borings were advanced until sandstone (representing the top of Sandstone C) was recovered in the sampler shoe, between 27 and 28 feet. The total depths of the borings were 28 feet below grade.

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Hydrogeologic Pilot Test Report Draft Extent of Nitrate and Fluoride Impact Lithology was recorded on soil boring log forms , which are included in this report as Appendix A.

Cuttings were containerized in drums. Sampling and disposition of cuttings are discussed in Section 8.

Monitor Wells T-91 and T-92 were installed as described in SAP-110, using 2-inch diameter schedule 40 PVC well casing with 2-inch diameter schedule 40 PVC, 0.010-inch slotted screens. The well screens extend from the base of the alluvium (27.5 feet below grade) to unsaturated soil above the water table (estimated at approximately 6 - 7 feet below grade). The annular filter pack consisted of 20-40 silica sand. Well construction details were recorded on Well Installation Diagram forms, which are included in this report as Appendix B.

A 4-foot square concrete pad was installed around each monitor well, with a lockable steel protector pipe installed to secure access to the monitor well. A 3/4" galvanized steel pipe with cap was installed through the concrete pad, extending approximately five feet above the concrete pad. A brass monument was placed in the concrete pad to serve as a reference point for subsequent elevation measurements. Monitor well construction information was recorded on monitor well installation diagrams.

Groundwater monitor wells were developed by pumping and surging and allowing the water to return to static water levels periodically, until the well produces clear water. Development continued until the field geologist approved termination of development activities. Development water was transferred to the frac tanks located in the Western Alluvial Area. Well development information was recorded on the monitor well installation diagrams.

GROUNDWATER SAMPLING RESULTS Groundwater samples were collected from Monitor Wells T-91 and T-92 and submitted to GEL Laboratory for uranium activity, uranium concentration, and nitrate/nitrite analysis. Analytical results for all groundwater samples collected during the 2012 hydrogeologic pilot test are tabulated in Table 3-1.

Monitor Wells T-91 and T-92 yielded groundwater containing 32.2 mg/I and 79.7 mg/I nitrate, respectively.

EXTENT OF NITRATE AND FLUORIDE IN THE WESTERN AREAS Figure 4-1 posts analytical results for nitrate and fluoride at locations that were sampled and analyzed from 2009 through 2011, along with 2012 results for locations sampled during the 2012 annual Cimarron Environmental Response Trust 4-2 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Extent of Nitrate and Fluoride Impact environmental sampling program and the 2012 hydrogeologic pilot test. Figure 4-1 delineates the nitrate and fluoride plumes in the western portion of the Site to the extent possible based on available data.

This figure shows that the nitrate plume in the Western Alluvial (WA) Area appears to be experiencing change. With the exception of T-62 and T-63, it appears that all the wells in the western "lobe" of the plume are dropping below the DEQ nitrate criterion of 52 mg/1. Nitrate in T-84, the northernmost well in this area, was only analyzed one time, in 2011, and then it yielded 51 mg/1, just below the DEQ criterion.

In the center "lobe" of the plume, nitrate concentrations in T-57 and T-85 appear to be declining, but nitrate concentrations in T-52 and T-53 appear to be increasing, and in 2011 nitrate in T-52 exceeded the DEQ criterion. In the eastern "lobe" nitrate concentrations appear to be declining in T-59, T-87, and T-89, but increasing in T-88 and T-60. It appears that the northern extent of nitrate exceeding the DEQ criterion may not be fully delineated in any of the three portions of the Western Alluvial Area plume.

In both of the uranium pond areas (UP 1 and UP2), nitrate concentrations do not appear to show a consistent trend. Concentrations decrease and increase between sampling events. However, data for Well 1352 (in the WU area) appears to show a decreasing trend.

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Hydrogeologic Pilot Test Report Draft BA #1 Transition Zone Aquifer Testing CHAPTER 5 - BA #1 TRANSITION ZONE AQUIFER TESTING INTRODUCTION Groundwater assessment activities performed in Burial Area # 1 from 2000 through 2004 included the performance of 22 slug tests and one pumping test. Burial Area #1 Groundwater Assessment Report (Kerr-McGee, 2003) rep011ed the results of these aquifer tests. At the time this report was written, a distinction had not yet been made between the alluvium and the transition zone. Every boring that did not encounter sandstone within a few feet of grade was categorized as an alluvial boring. The report concluded:

The hydraulic conductivity (K) of the alluvium ranges from 10-2 centimeters per second (cm/sec) to 10-5 cm/sec, with most of the alluvial wells being in the 10-2 cm/sec range

The hydraulic conductivity of Sandstone B is in the range of 10-4 to 10-5 cm/sec

The hydraulic conductivity of Sandstone C is in the range of 10-5 cm/sec Slug tests had been performed on four wells installed in transition zone material and eight wells installed in alluvial material. The four transition zone wells that were tested yielded hydraulic conductivities ranging from 10-3 to 10-5 cm/sec. The eight alluvial wells that were tested yielded 10-2 to 10-3 cm/sec.

It was decided that additional aquifer testing would be needed in the transition zone material to enable hydrogeologists to space wells and predict groundwater extraction rates. Project personnel did not believe it would be w011hwhile to attempt to conduct a pump test in a 2-inch diameter monitor well installed in relatively low permeability material. Consequently, a 4-inch diameter groundwater extraction well was installed in an eff011 to duplicate the type of well that would later be installed. That well was intended to be the pumping well for an aquifer test for Burial Area #1 transition zone material.

DRILLING AND WELL INSTALLATION Soil Boring GE-BAl-01 was drilled approximately 15 feet north-northeast of Monitor Well TMW-09, as shown in Figure 2-1. The boring was advanced by hollow stem auger, using a five-foot split barrel sampler to obtain subsurface soil samples. The boring was advanced until sandstone (representing the top of Sandstone C) was recovered in the sampler shoe, at a depth of 22 feet. The total depth of the boring was 25 feet below grade.

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Hydrogeologic Pilot Test Report Draft BA #1 Transition Zone Aquifer Testing Lithology was recorded on soil boring log forms , which are included in this report as Appendix A.

Cuttings not collected as samples for laboratory analysis were containerized in drums . The sampling and disposition of soil cuttings are discussed in Section 8.

Groundwater Extraction Well GE-BAl-01 was installed as described in SAP-110, using 4-inch diameter schedule 40 PVC well casing with 4-inch diameter schedule 40 PVC, 0.010-inch slotted screen. The well screen extends from the base of the alluvium (23 feet below grade) to unsaturated soil above the water table (estimated at approximately 8.5 feet below grade). The annular filter pack consisted of 20-40 sand.

Well construction details were recorded on Well Installation Diagram forms, which are included in this report as Appendix B.

A 4-foot square concrete pad was installed around the well, with a lockable steel protector pipe installed to secure access to the monitor well. A 3/4" galvanized steel pipe with cap was installed through the concrete pad, extending approximately five feet above the concrete pad. A brass monument was placed in the concrete pad to serve as a reference point for subsequent elevation measurements. Well construction information was recorded on a monitoring well installation diagram form.

The well was developed by pumping and surging and allowing the water to return to static water levels periodically, but it never produced clear water. Over two hours were required to produce 25 gallons of water, and the well would pump dry at extraction rates below 0.5 gallons per minute (gpm). Development continued until the field geologist approved termination of development activities. Development water was transferred to a frac tank, after which it was re-located to the Western Alluvial Area. Well development information was recorded on the monitor well installation diagram form.

GROUNDWATER SAMPLING RESULTS A groundwater sample collected from Groundwater Extraction Well GE-BAl-01 was submitted to GEL Laboratory for uranium concentration and nitrate/nitrite analysis. It would not produce sufficient water to collect a sample for uranium activity analysis. Analytical results for all groundwater samples collected during the 2012 hydrogeologic pilot test are tabulated in Table 3-1. This well yielded groundwater containing 2,300 µg/1 uranium. This result is comparable to data from nearby Monitor Well TMW-09.

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Hydrogeologic Pilot Test Report Draft BA #1 Transition Zone Aquifer Testing AQUIFER TESTING Pumping Test The activity plan for the 2012 hydrogeologic pilot test included the performance of a step-rate drawdown test, followed by a constant-rate drawdown test. The intent was to perform a step-rate drawdown test to determine the optimal pumping rate for a longer-term constant rate drawdown test. The field geologist attempted to perform a step-rate drawdown test, but even at 0.25 gpm, the well would pump dry in less than an hour. Consequently, the idea of performing a constant-rate drawdown test was abandoned, and it was decided that slug testing on wells installed in transition zone material would be more appropriate given the aquifer response observed during the step test.

Well Selection A total of fifteen monitor wells are screened in transition zone material in Burial Area # 1. The field geologist reviewed the boring logs for these fifteen monitor wells. Considering only those depth intervals that were below the groundwater elevation, soil was categorized as coarse (sand or gravel) or fine (silt or clay). A coarse-to-fine ratio was then generated for each well. Wells with a coarse-to-fine ratio below 0.15 were considered low permeability wells. Wells with a coarse-to-fine ratio between 0.15 and 1.0 were considered medium permeability. Wells with a coarse-to-fine ratio greater than 1.0 were considered high permeability. Two wells were selected from each of these three categories for the performance of slug tests, as follows:

Low Permeability Medium Permeability High Permeability TMW-5 TMW-6 02W39 02W10 02W13 02W26 During field work, TMW-6 did not contain sufficient water to perform the slug test. As a result, Monitor Well 02W28 was selected as a replacement. Slug tests were performed on these six wells, plus extraction well GE-BAl-01, in accordance with procedure SAP-117. Data was recorded with pressure transducers for both insertion and extraction of the mechanical slug. Slug test data are presented in Appendix C in Tables C-1 through C-14. Graphs of the slug test data are presented in Appendix C in Figures C-1 through C-14.

Slug Test Results Results of the field hydraulic conductivity (slug) testing performed for the selected well data set were found to be less variable than predicted and did not necessarily follow the relative permeability Cimarron Environmental Response Trust 5-3 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft BA #1 Transition Zone Aquifer Testing designation assigned prior to testing. The calculated hydraulic conductivity (K) values ranged from 1.0 x 10-5 cm/s or 0.0290 feet per day (ft/day) to 2.17 x 10-3 cm/s ( 6.144 ft/day) . Values for the two medium-permeability wells (02Wl3 and 02W28) were calculated using AQTESOLV software and the Bouwer and Rice (1976) solution. Hvorslev (1951) solution was also used as a comparison of calculated values and it was found that the two methods yielded comparable results. These calculated values were comparable to the results of slug test performed, analyzed, and reported in the 2003 Burial Area # 1 Groundwater Assessment Report. The following is a list of the calculated values for the wells tested.

Well K (cm/s} K(ft/da:y}

GE-BA-01 1.0 X 10-5 0.0290 TMW-5 1.0 X 10-5 0.0342 TMW-6 3.0 X 10-5 0.0920 02Wl0 2.17 X 10-3 6.144 02Wl3 1.2 X 10-4 0.351 02W26 1.2 X 10-4 0.351 02W28 1.6 X 10-4 0.458 02W39 2.2 X 10-4 0.615 Cimarron Environmental Response Trust 5-4 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing CHAPTER 6 - WESTERN ALLUVIAL AREA AQUIFER TESTING INTRODUCTION Groundwater assessment activities performed from 2004 through 2011 did not include aquifer testing in the Western Alluvial Area. When groundwater flow modeling was performed for the Groundwater Flow Modeling Report (ENSR, 2006), hydraulic conductivity data obtained for alluvial material in Burial Area

1 was used as input for WA Area alluvial material. Hydrogeologists who installed monitor wells to delineate the uranium and nitrate plumes in the WA Area noted that borings in the alluvial material in this area contained less silt and coarser-grained sand than in Burial Area #1, but did not recommend additional aquifer testing.

Because the material in this area was believed to have a higher hydraulic conductivity, it was decided that aquifer testing was needed to enable hydrogeologists to determine well spacing and predict groundwater extraction rates. Project personnel did not believe a 2-inch diameter monitor well could produce sufficient water to test the alluvial aquifer. Consequently, a 4-inch diameter groundwater extraction well was installed in an effmi to duplicate the type of well that would later be installed. That well was to serve as the pumping well for an aquifer test for WA Area Alluvial material.

DRILLING AND WELL INSTALLATION Soil Boring GE-WA-01 was drilled approximately 40 feet north-nmiheast of Monitor Well T-75 , as shown in Figure 2-1. The boring was advanced by hollow stem auger, using a five-foot split barrel sampler to obtain subsurface soil samples. The boring was advanced until sandstone (representing the top of Sandstone C) was recovered in the sampler shoe, at a depth of 2 7 feet. The total depth of the boring was 27.5 feet below grade.

Lithology was recorded on soil boring log forms, which are included in this report as Appendix A.

Cuttings were containerized in drums. Sampling and disposition of cuttings are discussed in Section 8.

Groundwater Extraction Well GE-WA-01 was installed as described in SAP-110, using 4-inch diameter schedule 40 PVC well casing with 4-inch diameter schedule 40 PVC, 0.010-inch slotted screen. The well screen extends from the base of the alluvium (2 7 feet below grade) to unsaturated soil above the water table (estimated at approximately 7 feet below grade). The annular filter pack consisted of 20-40 sand.

Well construction details were recorded on Well Installation Diagram forms , which are included in this report as Appendix B.

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Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing A 4-foot square concrete pad was installed around the well, with a lockable steel protector pipe installed to secure access to the monitor well. A 3/4" galvanized steel pipe with cap was installed through the concrete pad, extending approximately five feet above the concrete pad. A brass monument was placed in the concrete pad to serve as a reference point for subsequent elevation measurements. Well construction information was recorded on a monitoring well installation diagram form.

The well was developed by pumping and surging the well. The well was very productive and cleared quickly. Approximately 175 gallons of water were produced in less than 30 minutes. Development continued until the field geologist approved termination of development activities. Development water was transferred to a frac tank located near the well. Well development information was recorded on the monitor well installation diagram form.

GROUNDWATER SAMPLING RESULTS A groundwater sample collected from groundwater extraction Well GE-WA-01 was submitted to GEL Laboratory for uranium concentration and nitrate/nitrite analysis. Analytical results for al1 groundwater samples collected during the 2012 hydrogeologic pilot test are tabulated in Table 3-1. This well yielded groundwater containing 339 pCi/1 and 130 µg/1 uranium, and 4.7 mg/I nitrate. This result is comparable to historic data from nearby Monitor Well T-7 5.

AQUIFER TESTING Step-Rate Drawdown Test The activity plan for the 2012 hydrogeologic pilot test included the performance of a step-rate draw down test, followed by a constant-rate drawdown test. The intent of the step-rate draw down test was to determine the optimal pumping rate for a longer-term constant rate drawdown test. The field geologist attempted to perform a step-rate drawdown test, stmiing at 10 gpm and increasing to 25 gpm. After consulting with the project hydrogeologist, the field hydrogeologist conducted a second step-rate drawdown test that ran from 31 to 64 gpm. Even at the maximum pumping rate of 64 gpm, drawdown did not exceed 3 feet in the pumping well. Step-rate drawdown test data are presented in Appendix D in Table D-1. Graphs of the step test data are presented in Appendix Din Figures D-1 and D-2. A summary of the results of the second step-rate drawdown test at GE-WA-01 follows.

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Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing Discharge(gpm) Drawdown(feet) Specific Capacity (gpm/ft) Transmissivity (gpd/ft) 31 1.40 22.1 33,120 40 1.76 22 .8 34,200 50 2.22 22.5 33 ,750 64 2.87 22.3 34,200 All the aquifer tests performed in GE-WA-01 were performed in accordance with procedure SAP-114.

Data was recorded for both groundwater extraction and recovery.

Constant Rate Drawdown Test Because the maximum capacity of the 3-inch pump available for the aquifer test was limited, the decision was made to conduct the constant-rate drawdown test at 63 gpm. A constant-rate drawdown test was conducted over a period of approximately 3 0 hours0 days 0 hours 0 weeks 0 months , at which time all seven frac tanks that had been mobilized had been filled . After 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , the drawdown in GE-WA-01 was approximately 3.1 feet.

Following pump shutdown, water level recovery was monitored for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Following the completion of the aquifer pumping test, both pumping and recovery data collected from the In-Situ© Troll 700 data loggers were downloaded and hydrogeologic properties of the aquifer were calculated using AQTESOLV' software. Conditions observed during drilling and baseline water level measurements indicated that the aquifer exists under unconfined conditions.

Monitoring Wells T-68, T-72, T-75, T-77 and T-78 were selected as observation wells for the pumping test. Groundwater level data was collected with pressure transducers during the constant rate pump test.

The primary solution used to analyze the hydrogeologic data from the aquifer test was the Cooper-Jacob (1946) Solution for Pumping Test in Unconfined Aquifers. The Theis (1935), Neuman (1974), and Moench (1997) Solutions for Pumping Test in Unconfined Aquifers were also used for comparison.

DEQ suggested use of a delayed drainage response analytical solution for the data set using a method such as Boulton ( 1970). This method was evaluated for applicability with the structure and options included in AQTESOLV but after review of the user's guide and review of literature that included Boulton, (1970), (1973); Boulton and Pontin, (1971); Boulton and Streltsova, (1975); and Moench, (1994), it was determined that the use of the Boulton solution was not feasible with the software package.

However, the Moench (1997) method does allow for delayed drainage response, is included in the AQTESOLV solutions, and was used for the data result comparisons. It should be noted that since the Cimarron Environmental Response Trust 6-3 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing aquifer was not fully stressed as a result of the constant rate test, the data set collected and used for the analysis may have been impacted by the under pumping of the aquifer as well as potential heterogeneity and anisotropic conditions in the aquifer that may not have been detected by this test.

A number of solutions were considered for evaluation of this data set but because the constant rate test was determined to have not fully stressed the aquifer during the test period, the calculations of the hydraulic parameters were derived using Cooper-Jacob by looking at late test results as opposed to earlier results. This approach was corroborated by comparisons of the test solutions for the pumping well and associated observation wells with the distance-drawdown analysis performed. For this reason the use of Cooper-Jacob on the late data presented on the response curves are deemed more appropriate solutions for the test analysis.

Use of the Cooper-Jacob Solution was based on the following general assumptions:

Aquifer has infinite areal extent

Aquifer is homogenous, isotropic and of uniform thickness

Aquifer water table surface is initially horizontal

Aquifer is unconfined

Flow is unsteady

Diameter of pumping well is very small so that storage in the well can be neglected Full penetration scenarios were used to evaluate the test data. This solution selection was compared to values derived from the distance-drawdown method and proved to be a more appropriate scenario. As the values presented below show, there is some variability in the calculated values but are within a similar range of probability. The drawdown data from the observation wells were used to calculate transmissivity (1), storage coefficient (S), and K.

Assuming a saturated aquifer thickness of 18.91 feet (measured prior to the start of the test), T, S, and K were calculated using the Cooper-Jacob unconfined aquifer solutions and are presented below.

Calculated Tvalues for the Site range from approximately 5,700 to 9,900 square feet per day (ft2/day) or approximately 43,000 to 74,000 gallons per day per foot (gpd/ft). K values range from 303 .8 to 524.2 ft/day (1.07 X 10-1 to 1.85 X 10- 1 cm/s). S values range from 2.81 x 10-2 to 8.75 x 10- 1 (dimensionless).

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Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing Well T {ft2/day) T(gpd/ft) K{ft/day) s GE-WA-01 5,700 43 ,000 303.8 8.75 X} 0-l T-75 7,000 52,000 368.8 2. 81 X 10-2 T-77 7,200 54,000 381.6 1.03 X 10-l T-78 9,900 74,000 524 .2 1.12 X 10-l T-72 7,800 58,000 411.4 4.20 X 10-2 T-68 7,500 56,000 394.2 1.35 X 10-l In addition to the above mentioned hydro geologic parameters, the radius of influence (ROI) of the pumping tests was also estimated. Based on the plot of distance versus drawdown collected from the observation wells during the constant-rate test, the cone of depression after 1.25 days indicated a ROI of approximately 250 feet. This ROI is shown on Chait 1, the GE-WA-01 Distance-Drawdown Plot. This graphic method (modified after Jacob) is used to estimate T and S as well as determining input values for theoretical ROI calculation (Driscoll, 1989).

The approximate theoretical ROI was calculated using the following equation:

The calculation used the following values:

2

The estimated Tofthe aquifer based on the distance-drawdown curve is 3,738 ft /day (27,896 gallons per day per foot [gpd/ft]);

The duration of the constant-rate test was l .25days (t) ;

The estimated Sis 0.17; and

Theoretical ROI (r0 ) in feet from the pumping well (GE-WA-01).

The calculated theoretical ROI is approximately 250 feet. The Jacob graphic distance-drawdown method calculated theoretical ROI values are generally indicative of greater influence but do provide reasonable theoretical values. Theoretical ROI does not represent the theoretical capture width.

Recovery test data was analyzed using the Neuman method. The calculated Tvalue for the recovery test at GE-WA-01 was approximately 14,100 ft 2/day and the calculated Kvalue was 218.2 ft/day. The data collected during the recovery phase of the GE-WA-01 test solution value for T correlated reasonably well with the approximations made based on the constant rate test data.

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Hydrogeologic Pilot Test Report Draft Western Alluvial Area Aquifer Testing Data from the constant rate drawdown and recovery test are presented in Appendix D in Tables D-2 through D-7 . Graphs of the constant rate drawdown and recovery test data are presented in Appendix D in Figures D-3 through D-7. The analytical software output is also included in this report in Appendix D.

Pneumatic Slug Tests Discussions were held with DEQ and NRC regarding the use of the constant-rate pump test data in the groundwater flow model for the Western Alluvial Area. A sensitivity analysis was performed, and it was determined that the model is nearly totally insensitive to changes in storativity, so a reasonable value for an alluvial aquifer will be used in the groundwater flow model. The evaluation of the groundwater model's sensitivity to storage coefficient variability is included in this report as Appendix E.

However, the hydraulic conductivity assigned to the sandy alluvial material in Burial Area# I was significantly different that the hydraulic conductivity obtained for Well GE-WA-01. Consequently, it was agreed by NRC, DEQ, and Burns & McDonnell hydrogeologists that pneumatic slug tests would be performed on several monitor wells distributed throughout the Western Alluvial Area. Pneumatic slug th tests were performed on the following fourteen monitor wells from February 4 through February ih:

T-51 T-54

T-58 T-59

T-62 T-74

T-81 T-82

T-84 T-86

T-88 T-89

T-91 1343 The data and evaluation of results from these tests will be reported separately. The hydraulic conductivity values obtained from these tests will be utilized in the groundwater flow model for the Western Alluvial Area.

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Hydrogeologic Pilot Test Report Draft Groundwater Storage and Disposition CHAPTER 7 - GROUNDWATER STORAGE AND DISPOSITION INTRODUCTION The nearly 140,000 gallons of well development water, purge water, and pump test water contained in the frac tanks was known to contain low concentrations of uranium and nitrate. DEQ prohibited land application for the disposal of this water because the uranium is a contaminant which would not beneficiate the soil. It was believed the concentration of uranium would be less than NRC's 3,000 pCi/1 limit for discharge of wastewater to a publicly operated treatment works (POTW).

Frac tanks, typically used in the oilfield, could contain naturally occurring radioactive material (NORM).

NORM in frac tanks could prevent their release upon survey after water disposal. Before mobilizing to the site, each frac tank was cleaned by pressure washer and scanned for NORM using a gamma survey meter. No evidence of NORM was present in any of the frac tanks mobilized to the site.

CONTAINERIZED GROUNDWATER SAMPLING RESULTS Groundwater samples were collected from each frac tank, and submitted to GEL Laboratory for uranium activity and nitrate/nitrite analysis. Analytical results for samples of containerized water are tabulated in Table 7-1. The uranium activity recorded for the frac tanks ranged from 263 to 334 pCi/1. The nitrate concentration recorded for the frac tanks ranged from 5 .4 to 6.0 mg/I. Because the water contained in the frac tanks contained an average of 301 pCi/1 (approximately one-tenth of the limit for discharge to a POTW), the water was transported by tank truck to ORI Environmental, Inc.'s (ORIE's) Oklahoma City, OK facility for disposal via their wastewater treatment system.

DEMO Bl LIZA TION All seven frac tanks were cleaned by pressure washing prior to performing release surveys for unrestricted release, prior to being removed from the site. The frac tanks containing development water from GE-BAl-01 and GE-WA-01 had the greatest potential to leave sediment which would contain significantly higher levels of uranium than tanks which only contained groundwater. Neither tank exhibited direct surface contamination levels exceeding stipulated limits for removable contamination.

All tanks were released for unrestricted use and demobilized from the site.

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Hydrogeologic Pilot Test Report Draft Soil Storage and Disposition CHAPTER 8 - SOIL STORAGE AND DISPOSITION Cuttings from confirmatory survey borings, groundwater monitor well borings, and groundwater extraction well borings were contained in 55-gallon drums. One 500-ml sample of cuttings was obtained from each boring by placing small quantities of soil in a jar periodically as the boring was advanced. A total of ten soil samples were collected and submitted to GEL Laboratory to be analyzed for isotopic uranium activity. Drums containing cuttings were left next to the boring from which the cuttings were taken pending the receipt of analytical results from the laborato1y.

Analytical results for the composite samples of cuttings are tabulated in Table 8-1. The total uranium activity (gross) recorded for the cuttings ranged from 0.29 pCi/g to 11.58 pCi/g. All results were less than one-third of the NRC criterion for soil (30 pCi/g net of background). The drums were emptied and spread on the ground around the abandoned borings or newly installed wells.

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Hydrogeologic Pilot Test Report Draft Conclusions and Recommendations CHAPTER 9 - CONCLUSIONS AND RECOMMENDATIONS CONCLUSIONS Subarea F Confirmatory Survey Five borings were advanced in Subarea F where the uranium concentrations in groundwater are near the highest concentrations observed on site. Gamma survey measurements were recorded from recovered core, and laborat01y analysis was performed on the five samples yielding the highest gamma survey measurements. The data indicate that, although subsurface soil may be impacted by contaminated groundwater, the degree of impact does not cause soil concentrations to approach the decommissioning criteria for unrestricted release. Analysis of additional samples by NRC will be performed to confirm or contradict this conclusion.

Extent of Uranium Impact Monitor Well 1361 was installed northeast of Monitor Well 02W44 in an effort to complete the delineation of groundwater exceeding the criteria for unrestricted release. The concentration of uranium in groundwater is increasing in Monitor Well 02W44 and exceeds both dose-based and concentration-based criteria in Monitor Well 1361. The uranium-impacted groundwater appears to be turning to a more northeasterly flow direction as it extends fa1iher n01ih (Figure 3-1). Delineation of uranium exceeding the criteria for unrestricted release is not complete.

Extent of Nitrate Impact Monitor Wells T-91 and T-92 were installed n01iheast and northwest of Monitor Well T-89 in an effort to complete the delineation of groundwater exceeding the criteria for nitrate. The concentration of nitrate in groundwater is decreasing in Monitor Well T-89, but exceeds the criterion for nitrate in Monitor Well T-92, which is n01iheast of Monitor Well T-89. In addition, although samples were not collected from Monitor Wells T-52 and T-53 in 2012, the concentration trend observed for both wells indicates that nitrate is likely to exceed its criterion in both locations. Delineation of nitrate exceeding its criteria is not complete from north of Monitor Well T-52 to north (and possibly east) of Monitor Well T-92.

BA #1 Transition Zone Aquifer Testing Although a 4-inch diameter groundwater extraction well was completed in the transition zone in Burial Area # 1, it could not yield sufficient groundwater to enable hydrogeologists to conduct either a step-rate drawdown or a constant rate pumping test. Slug tests were conducted on six additional wells screened in Cimarron Environmental Response Trust 9-1 Environmental Properties Management

Hydrogeologic Pilot Test Report Draft Conclusions and Recommendations transition zone material, and data was obtained from these tests to enable hydrogeologists to evaluate potential design options for hydraulic containment and extraction alternatives for the transition zon e material.

Western Alluvial Area Aquifer Testing Although the lower than ideal maximum sustainable pumping rate was used during the aquifer test and it did apparently impact the theoretical drawdown and yield of the well, the data collected during the aquifer test provided sufficient yield and radius of influence data for this location. Data from the constant rate test provided information on the hydrogeologic conditions and a radius of influence of approximately 250 feet that could theoretically be maintained at 63 .4 gpm over the test period.

It should be noted that the solution (Tand K) values determined from the analysis of this test seem to be higher than would be expected given the geological material described on the drilling logs. Additionally, some solutions for S are questionable in that they fall outside the range normally observed in unconfined aquifers. These results suggest that the pumping test may not have been performed at a sufficient rate to stress the aquifer. Caution should therefore be used when considering these data; without additional confirmation or testing the results should be considered inconclusive. Additional data will be collected via pneumatic slug tests to assess the validity of the calculated values for K derived from the constant rate pumping test at GE-WA-01.

Specifications relating to design and implementation of remedial alternatives are outside the scope of this rep01i. Fmiher discussion and planning will be required prior to designing and implementing the appropriate remedial options.

RECOMMENDATIONS Subarea F Confirmatory Survey NRC selected seven samples of subsurface soil from Subarea F for analysis by the ORAU Radioanalytical Laboratory, based upon boring logs and gamma scan results for the five confirmatory borings performed during the hydrogeologic pilot test. Laboratory analytical results have not yet been received. If all results comply with the criteria stipulated in License Condition 27(c), EPM requests that NRC issue a letter confinning that all soil in Subarea F complies with release criteria for unrestricted use. This will significantly impact the development of a final status survey plan to be implemented after groundwater decommissioning is complete, because only areas that are impacted by construction or operation may require final status survey.

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Hydrogeologic Pilot Test Report Draft Conclusions and Recommendations Extent of Uranium Impact The extent of uranium impact exceeding either NRC or DEQ criteria is sufficiently defined in the Western Alluvial and Western Upland Areas. Depth to groundwater was measured in all monitor wells in December 2012. Figure 9-1 presents a potentiometric surface map for Burial Area # 1. This figure also shows the extent of uranium exceeding either NRC or DEQ criteria, based on 2012 data. The approximate locations of proposed monitor wells are also shown on Figure 9-1. EPM proposed to install these wells and include collection of groundwater samples from these wells in the groundwater sampling event scheduled for the spring of 2013.

Extent of Nitrate and Fluoride Impact Depth to groundwater was measured in all monitor wells in December 2012. Figure 9-2 presents a potentiometric surface map for the Western Areas. This figure also shows the extent of nitrate or fluoride exceeding the DEQ re-opening criteria, based on 2012 data. The approximate locations of proposed monitor wel1s are also shown on Figure 9-2. EPM proposed to install these wells and include collection of groundwater samples from these wells in the groundwater sampling event scheduled for the spring of 2013.

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Hydrogeologic Pilot Test Report Draft References CHAPTER10-REFERENCES Boulton, N.S., 1970. Analysis of Data from Pumping Tests in Unconfined Anisotropic Aquifers, Journal of Hydrology 10, pp. 396-378.

Boulton, N.S. and Pontin, J.M. A., 1971. An Extended Theory of Delayed Yield from Storage Applied to Pumping Tests in Unconfined Anisotropic Aquifers, Journal of Hydrology 16, pp.53-65.

Boulton, N.S., 1973. The Influence of Delayed Drainage on Data from Pumping Tests in Unconfined Anisotropic Aquifers, Journal of Hydrology 19, pp. 157-169.

Boulton, N.S. and Streltsova, T.D., 1975. New Equations for Determining the Formation Constants of an Aquifer From Pump Test Data, Water Resources Research, vol. 11, no. 1, pp. 148-153.

Bouwer, H. and R.C. Rice, 1976. A slug test method for determining hydraulic conductivity of unconfined aquifers with completely or partially penetrating wells, Water Resources Research, vol. 12, no. 3, pp. 423-428.

Butler, J.J., Jr., 1998. The Design, Performance, and Analysis of Slug Tests, Lewis Publishers, Boca Raton, Florida, 252p.

Cimarron Corporation, 2007, Burial Area # 1 Subsurface Soil Assessment.

Cooper, H.H. and C.E. Jacob, 1946. A generalized graphical method for evaluating formation constants and summarizing well field history, Am. Geophys. Union Trans., vol. 27, pp. 526-534.

Dagan, G., 1978. A note on packer, slug, and recovery tests in unconfined aquifers, Water Resources Research, vol. 14, no. 5. pp. 929-934.

ENSR Corporation, 2006a, Conceptual Site Model (Revision - 01).

ENSR Corporation, 2006b, Groundwater Flow Modeling Report.

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Hydrogeologic Pilot Test Report Draft References Hvorslev, M.J., 1951. Time Lag and Soil Permeability in Ground-Water Observations, Bull. No. 36, Waterways Exper. Sta. Corps of Engrs, U.S. Army, Vicksburg, Mississippi, pp. 1-50.

Kerr-McGee Corporation, 2003, Burial Area #1 Groundwater Assessment Report.

Moench, A.F ., 1997. Flow to a well of finite diameter in a homogeneous, anisotropic water-table aquifer, Water Resources Research, vol. 33, no. 6, pp. 1397-1407.

Moench, A.F., 1995. Combining the Neuman and Boulton models for flow to a we11 in an unconfined aquifer, Ground Water, vol. 33, no. 3, pp. 378-384.

Neuman, S.P., 1974. Effect of partial penetration on flow in unconfined aquifers considering delayed gravity response, Water Resources Research, vol. l 0, no. 2, pp. 303-312.

Theis, C.V., 1935. The relation between the lowering of the piezometric surface and the rate and duration of discharge of a well using groundwater storage, Am. Geophys. Union Trans., vol. 16, pp. 519-524.

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TABLES CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 2 LABORATORY RESULTS FOR SUBSURFACE SOIL CONFIRMATORY SURVEY Collection Uncertainty Sample Parameter Result Units Qualifier MDL Total U Date (2 O")

GE-BA 1-01-9'-1 0'-EPM 09/26/12 Uranium-234 4.02 1.07 PCI/G 0.614 GE-BA 1-01-9'-1 0'-EPM 09/26/12 Uranium-235 0.236 0.339 PCI/G u 0.409 GE-BA 1-01-9'-1 0'-EPM 09/26/12 Uranium-238 2.76 0.867 PCI/G 0.207 7.02 CS-BA 1-01-21 '-22'-EPM 09/26/12 Uranium-234 2.09 0.858 PCI/G 0.758 CS-BA 1-01-21 '-22'-EPM 09/26/12 Uranium-235 0.166 0.327 PCI/G u 0.453 CS-BA 1-01-21 '-22'-EPM 09/26/12 Uranium-238 1.91 0.765 PCI/G 0.229 4.17 CS-BA 1-02-13'-14'-EPM 09/28/12 Uranium-234 5.45 1.3 PCI/G 0.718 CS-BA 1-02-13'-14'-EPM 09/28/12 Uranium-235 0.425 0.457 PCI/G u 0.52 CS-BA 1-02-13'-14'-EPM 09/28/12 Uranium-238 5.7 1.3 PCI/G 0.228 11.575 CS-BA 1-03-2'-3'-EPM 09/27/12 Uranium-234 0.513 0.471 PCI/G u 0.631 CS-BA 1-03-2'-3'-EPM 09/27/12 Uranium-235 0.0876 0.246 PCI/G u 0.263 CS-BA 1-03-2'-3'-EPM 09/27/12 Uranium-238 1.01 0.559 PCI/G 0.433 1.61 CS-BA 1-04-9'-1 0'-EPM 09/25/12 Uranium-234 4.28 1.15 PCI/G 0.606 CS-BA 1-04-9'-1 0'-EPM 09/25/12 Uranium-235 0.283 0.373 PCI/G 0.283 CS-BA 1-04-9'-1 0'-EPM 09/25/12 Uranium-238 3.04 0.961 PCI/G 0.366 7.60 Page 1 of 1

CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 3 LABORATORY RESULTS FOR GROUNDWATER I Sample_No I Coll_date I Parameter I Lab_Result I Uncertainty I Units I Lab_Qual I MDL I Total U I -2a I +2a I 1319B-3 10/16/12 Antimony ND UG/L u 3.5 1319B-3 10/16/12 Arsenic ND UG/L u 5 1319B-3 10/16/12 Beryllium ND UG/L u 1 1319B-3 10/16/12 Cadmium ND UG/L u 1 1319B-3 10/16/12 Chromium 102 UG/L 1 1319B-3 10/16/12 Copper 9.61 UG/L J 3 1319B-3 10/16/12 Lead ND UG/L u 3.3 1319B-3 10/16/12 Nickel ND UG/L u 1.5 1319B-3 10/16/12 Selenium 8.22 UG/L J 6 1319B-3 10/16/12 Silver 1.75 UG/L J 1 1319B-3 10/16/12 Thallium ND UG/L u 5 1319B-3 10/16/12 Zinc 5.05 UG/L J 3.3 1319B-3 10/16/12 Mercury ND UG/L u 0.067 1319B-3 10/16/12 Chloride 8.28 MG/L 0.067 1319B-3 10/16/12 Sulfate 30.4 MG/L 0.133 1319B-3 10/16/12 Nitrogen, Ammonia 0.043 MG/L J 0.017 1319B-3 10/16/12 Phosphorus, Total as P 0.0214 MG/L J 0.017 1319B-3 10/16/12 Total Dissolved Solids 654 MG/L 3.4 1319B-3 10/16/12 pH 7.46 SU H 0.01 1361 10/16/12 Uranium-233/234 139 6.01 PCI/L 0.845 1361 10/16/12 Uranium-235/236 7.39 1.56 PCI/L 0.583 1361 10/16/12 Uranium-238 86.7 4.74 PCI/L 0.443 233 217 249 1361 10/16/12 Uranium 262 UG/L 0.335 1361 10/16/12 Fluoride 0.416 MG/L 0.033 1361 10/16/12 Nitrogen, Nitrate/Nitrite ND MG/L u 0.017 1361 10/16/12 ALPHA 297 34.1 PCI/L 9.41 1361 10/16/12 BETA 101 12.5 PCI/L 7.97 Page 1 of 3

CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 3 LABORATORY RESULTS FOR GROUNDWATER Sample No Coll date Parameter Lab Result Uncertainty Units Lab Qual MDL Total U -2a +2a 1361DUP 10/16/12 Uranium-233/234 152 6.73 PCI/L 0.668 1361DUP 10/16/12 Uranium-235/236 10.4 1.96 PCI/L 0.457 1361DUP 10/16/12 Uranium-238 90.3 5.17 PCI/L 0.427 253 235 270 1361DUP 10/16/12 Uranium 271 UG/L 0.335 1361DUP 10/16/12 Fluoride 0.422 MG/L 0.033 1361DUP 10/16/12 Nitrogen, Nitrate/Nitrite ND MG/L u 0.017 1361DUP 10/16/12 ALPHA 213 28.9 PCI/L 9.63 1361DUP 10/16/12 BETA 93.7 11.9 PCI/L 7.42 GE-WA-01 10/16/12 Uranium-233/234 285 9.33 PCI/L 0.612 GE-WA-01 10/16/12 Uranium-235/236 11.4 2.09 PCI/L 0.295 GE-WA-01 10/16/12 Uranium-238 42.4 3.61 PCI/L 0.486 276 269 284 GE-WA-01 10/16/12 Uranium 130 UG/L 0.335 GE-WA-01 10/16/12 Fluoride 1.26 MG/L 0.033 GE-WA-01 10/16/12 Nitrogen, Nitrate/Nitrite 4.71 MG/L 0.17 GE-WA-01 10/16/12 ALPHA 299 35.3 PCI/L 9.74 GE-WA-01 10/16/12 BETA 52 .8 9.29 PCI/L 8.09 GE-WA-01-2 10/16/12 Uranium-233/234 286 8.47 PCI/L 0.711 GE-WA-01-2 10/16/12 Uranium-235/236 17.3 2.33 PCI/L 0.492 GE-WA-01-2 10/16/12 Uranium-238 45.7 3.38 PCI/L 0.361 349 330 368 GE-WA-01-2 10/16/12 Uranium 156 UG/L 0.335 GE-WA-01-2 10/16/12 Fluoride 1.42 MG/L 0.033 GE-WA-01-2 10/16/12 Nitrogen, Nitrate/Nitrite 5.78 MG/L 0.17 GE-WA-01-2 10/16/12 ALPHA 304 33.8 PCI/L 9.46 GE-WA-01-2 10/16/12 BETA 61.4 9.1 PCI/L 6.16 Page 2 of 3

CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 3 LABORATORY RESULTS FOR GROUNDWATER Sample_No Coll date Parameter Lab Result Uncertainty Units Lab Qual MDL Total U -2a +2a T-91 10/15/12 Uranium-233/234 16.2 2.05 PCI/L 0.631 T-91 10/15/12 Uranium-235/236 0.329 0.4 PCI/L u 0.536 T-91 10/15/12 Uranium-238 8.91 1.51 PCI/L 0.402 25 20 31 T-91 10/15/12 Uranium 26.5 UG/L 0.067 T-91 10/15/12 Fluoride 0.566 MG/L 0.033 T-91 10/15/12 Nitrogen, Nitrate/Nitrite 32.2 MG/L 1.7 T-91 10/15/12 ALPHA 20.6 10.1 PCI/L 9.15 T-91 10/15/12 BETA 14.1 6.82 PCI/L 9.66 T-92 10/15/12 Uranium-233/234 28.6 2.71 PCI/L 0.58 T-92 10/15/12 Uranium-235/236 1.12 0.621 PCI/L 0.391 T-92 10/15/12 Uranium-238 17.7 2.12 PCI/L 0.316 47 40 54 T-92 10/15/12 Uranium 44 UG/L 0.067 T-92 10/15/12 Fluoride 0.385 MG/L 0.033 T-92 10/15/12 Nitrogen, Nitrate/Nitrite 79.7 MG/L 1.7 T-92 10/15/12 ALPHA 44 13.8 PCI/L 9.62 T-92 10/15/12 BETA 22 6.42 PCI/L 7.43 Page 3 of 3

CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 7 LABORATORY RESULTS FOR FRAC TANK WATER Collection Uncertainty Sample Parameter Result Units Qualifier MDL Total U Date (2 a)

WA-TANKl 10/23/12 Fluoride 1.33 MG/L 0.033 WA-TANKl 10/23/12 Nitrogen, Nitrate/I\ 5.97 MG/L 0.17 WA-TANKl 10/23/12 Uranium-234 252 8.61 PCI/L 0.64 WA-TANKl 10/23/12 Uranium-235 13.9 2.25 PCI/L 0.283 WA-TANKl 10/23/12 Uranium-238 43.7 3.59 PCI/L 0.229 310 WA-TANK2 10/23/12 Fluoride 1.35 MG/L 0.033 WA-TANK2 10/23/12 Nitrogen, Nitrate/N 5.55 MG/L 0.17 WA-TANK2 10/23/12 Uranium-234 274 9.06 PCI/L 0.756 WA-TANK2 10/23/12 Uranium-235 13.9 2.28 PCI/L 0.462 WA-TANK2 10/23/12 Uranium-238 44.8 3.67 PCI/L 0.477 333 WA-TANK3 10/24/12 Fluoride 1.31 MG/L 0.033 WA-TANK3 10/24/12 Nitrogen, Nitrate/N 5.4 MG/L 0.17 WA-TANK3 10/24/12 Uranium-234 233 8.17 PCI/L 0.688 WA-TANK3 10/24/12 Uranium-235 9.86 1.88 PCI/L 0.276 WA-TANK3 10/24/12 Uranium-238 42.7 3.5 PCI/L 0.491 286 WA-TANK4 10/24/12 Fluoride 1.33 MG/L 0.033 WA-TANK4 10/24/12 Nitrogen, Nitrate/I\ 5.56 MG/L 0.17 WA-TANK4 10/24/12 Uranium-234 268 9.47 PCI/L 0.769 WA-TANK4 10/24/12 Uranium-235 15.9 2.57 PCI/L 0.515 WA-TANK4 10/24/12 Uranium-238 50.5 4.11 PCI/L 0.481 334 Page 1 of 2

CIMARRON ENVIRONMENTAL RESPONSE TRUST HYDROGEOLOGIC PILOT TEST REPORT TABLE 7 LABORATORY RESULTS FOR FRAC TANK WATER Collection Uncertainty Sample Parameter Result Units Qualifier MDL Total U Date {2 o)

WA-TANKS 10/24/12 Fluoride 1.33 MG/L 0.033 WA-TANKS 10/24/12 Nitrogen, Nitrate/~ 5.67 MG/L 0.17 WA-TANKS 10/24/12 Uranium-234 233 8.64 PCI/L 0.717 WA-TANKS 10/24/12 Uranium-235 12.5 2.24 PCI/L 0.571 WA-TANKS 10/24/12 Uranium-238 45.4 3.82 PCI/L 0.509 291 WA-TANK6 10/24/12 Fluoride 1.28 MG/L 0.033 WA-TANK6 10/24/12 Nitrogen, Nitrate/N 5.81 MG/L 0.17 WA-TANK6 10/24/12 Uranium-234 215 7.35 PCI/L 0.611 WA-TANK6 10/24/12 Uranium-235 10.7 1.83 PCI/L 0.243 WA-TANK6 10/24/12 Uranium-238 37 .2 3.06 PCI/L 0.363 263 WA-TANK7 10/24/12 Fluoride 1.26 MG/L 0.033 WA-TANK7 10/24/12 Nitrogen, Nitrate/N 6 MG/ L 0.17 WA-TANK7 10/24/12 Uranium-234 238 8.51 PCI/L 0.803 WA-TANK7 10/24/12 Uranium-235 12.2 2.15 PCI/L 0.598 WA-TANK7 10/24/12 Uranium-238 38.7 3.43 PCI/L 0.379 289 Page 2 of 2

CIMARRON ENVIRONMENTAL RESPONSE TRUST HVDROGEOLOGIC PILOT TEST REPORT TABLE 8 LABORATORY RESULTS FOR SOIL CUTTINGS Collection Uncertainty Sample Parameter Result Units Qualifier MDL Total U Date (2 a)

CS-BAl-01 DRUM COMP 09/26/12 Uranium-234 0.971 0.622 PCI/G 0.728 CS-BAl-01 DRUM COMP 09/26/12 Uranium-235 0.159 0.313 PCI/G u 0.435 CS-BAl-01 DRUM COMP 09/26/12 Uranium-238 0.953 0.539 PCI/G 0.22 2.08 CS-BAl-02 DRUM COMP 09/28/12 Uranium-234 1.11 0.632 PCI/G 0.655 CS-BAl-02 DRUM COMP 09/28/12 Uranium-235 0.181 0.309 PCI/G u 0.271 CS-BAl-02 DRUM COMP 09/28/12 Uranium-238 0.876 0.517 PCI/G 0.219 2.17 CS-BAl-03 DRUM COMP 09/27/12 Uranium-234 0.99 0.807 PCI/G 0.963 CS-BAl-03 DRUM COMP 09/27/12 Uranium-235 0.132 0.425 PCI/G u 0.651 CS-BAl-03 DRUM COMP 09/27/12 Uranium-238 0.738 0.639 PCI/G 0.369 1.86 CS-BAl-04 DRUM COMP 09/25/12 Uranium-234 0.817 0.528 PCI/G 0.559 CS-BAl-04 DRUM COMP 09/25/12 Uranium-235 0 0.171 PCI/G u 0.255 CS-BAl-04 DRUM COMP 09/25/12 Uranium-238 0.603 0.429 PCI/G 0.33 1.42 GE-BAl-01 DRUM COMP 09/26/12 Uranium-234 5.45 1.2 PCI/G 0.587 GE-BAl-01 DRUM COMP 09/26/12 Uranium-235 0.302 0.355 PCI/G u 0.384 GE-BAl-01 DRUM COMP 09/26/12 Uranium-238 4.35 1.05 PCI/G 0.195 10.10 GE-WA-01 DRUM COMP 09/29/12 Uranium-234 0.283 0.41 PCI/G u 0.658 GE-WA-01 DRUM COMP 09/29/12 Uranium-235 -0.0424 0.188 PCI/G u 0.489 GE-WA-01 DRUM COMP 09/29/12 Uranium-238 0.0543 0.204 PCI/G u 0.343 0.29 1361 DRUM COMP 09/27/12 Uranium-234 0.104 0.376 PCI/G u 0.724 1361 DRUM COMP 09/27/12 Uranium-235 0 0.203 PCI/G u 0.303 1361 DRUM COMP 09/27/12 Uranium-238 0.268 0.366 PCI/G u 0.498 0.37 T-91 DRUM COMP 09/30/12 Uranium-234 0.354 0.437 PCI/G u 0.688 T-91 DRUM COMP 09/30/12 Uranium-235 0.0607 0.228 PCI/G u 0.383 T-91 DRUM COMP 09/30/12 Uranium-238 0.147 0.261 PCI/G u 0.395 0.56 T-92 DRUM COMP 09/30/12 Uranium-234 0.25 0.507 PCI/G u 0.889 T-92 DRUM COMP 09/30/12 Uranium-235 0.0876 0.328 PCI/G u 0.552 T-92 DRUM COMP 09/30/12 Uranium-238 0.119 0.328 PCI/G u 0.569 0.46 Page 1 of 1

ML20213C658

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