AC 2012-4915: VALIDITY OF THE METHODOLOGY FOR ESTABLISH-ING BASELINE WATER QUALITY FOR URANIUM

Mrs. Marisa Hamilton, Riviera Kaufer High SchoolDr. Lee Clapp, Texas A&M University, Kingsville

Lee Clapp is an Associate Professor in environmental engineering.

Prof. Mohamed Abdelrahman, Texas A&M University, Kingsville

Mohamed Abdelrahman received the B.S. and M.S. degrees in electrical engineering and engineeringphysics from Cairo University, Egypt in 1988 and 1992, respectively. He received an M.S. and a Ph.D.in measurement and control and nuclear engineering from Idaho State University in 1994 and 1996, re-spectively. He is currently the Associate Dean of Engineering at Texas A&M University, Kingsville.Abdelrahman’s research focus is industrial applications of sensing and control with major research fund-ing from the U.S. Department of Energy, National Science Foundation, and industry. He has also focusedon collaborative and innovative educational research. Abdelrahman is passionate about outreach activitiesfor popularizing engineering research and education. His activities in that arena included NSF funded sitesfor research experience for undergraduates and research experience for Teachers. He has published hisresearch results in more than 90 papers in refereed journals and conference proceedings and 30+ technicalreports.

c©American Society for Engineering Education, 2012

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Validity of the Methodology for Establishing Baseline Water

Quality for Uranium In Situ Recovery (ISR) Mining

Abstract

This paper examines the research a teacher completed during the Research Experience for

Teachers in Manufacturing for Competitiveness in the United States (RETainUS) summer

project and the implementation of the research in a high school science classroom. The research

involved the importance of establishing a baseline water quality level prior to in situ recovery

mining for uranium. Water is the life line of many and the quality of that water is being

questioned by many. In South Texas there is a clash between private citizen groups and uranium

mining companies regarding ground water quality in uranium mining sites. Private citizens’

groups are claiming that uranium mining companies are contaminating the ground water with

drilling and uranium production processes and that the baseline well locations and averages are

not randomly selected. However, research findings show that the drilling process is similar to

that of other drilling processes. There is not a clear variation between drilling for baseline water

wells and drilling for identification and production of uranium deposits. The claims that uranium

companies are polluting the ground water may be valid but the phenomenon needs to be better

understood before conclusions can be made on the causes of uranium contamination in ground

water. There are many improvements that can be made by private citizens, uranium companies,

and the regulatory agencies to maintain better water quality. Using this research experience, the

teacher created a thematic unit using the question of “Is your water safe to drink?” for a high

school aquatic science class following the legacy cycle format. Students will explore what

makes water safe to drink, where well water comes from, drilling water well practices, and the

uranium mining process. Students will test their own water samples for basic water

contaminants. Student learning will be gauged by a scenario of the student working at an

environmental lab and lastly sharing their new found knowledge with local publications.

Students in this community are aware of uranium in the ground water, as the area has been

plagued with water quality problems. This legacy cycle will give the students information need

to become informed citizens.

Summer Research

With a summer experience at Texas A&M University-Kingsville’s Research Experience for

Teachers (RET) project, the teacher conducted research on baseline water quality prior to in situ

recovery (ISR) mining for uranium. This research was instrumental to the understanding of

water quality in our community, both personally and professionally. The teacher moved to an

area that has been riddled with ground water quality and uranium mining controversy. Prior to

this research, the teacher knew nothing of the importance water quality. The teacher was one of

many that will drink water; as long as it tastes, looks, and smells good. After this research, that

is no longer the case. There is much more than aesthetic qualities when it comes to quality

water.

Most of the summer included finding water standards, learning drilling standards and uranium

mining processes via computer research, and interviewing professionals in the field. Practical

Page 25.1458.2

field experience was gained collecting water samples from a well. Visits to ISR uranium mining

sites in various stages provided even more insight to this process.

Aquifers

Different materials allow different fluids to travel through them at different rates. If the

substance does not allow a fluid to travel though it, the substance is known as impermeable. If a

substance allows a fluid to travel through it, the substance is known as permeable. These

different properties can be applied to underground sediments, creating areas ideal for fluids (i.e.

water, oil, and gas) to collect. An underground layer of porous rock, sand, or gravel, makes an

excellent storage space for ground water; while, clay and shale do not retain water very well. If

layers of impermeable and permeable of sediment form, water may become embedded between

these layers. The water and porous sediment become known a confined aquifer, as seen in

Figure 1. The water reaches a maximum level, which is referred to as the water table. The

water is not stagnant, but moves due to the pressure of the rock formation itself. The water table

will rise and fall depending on the rate of ground water recharge.

Figure 1: Anatomy of an aquifer

1

Uranium Deposits

Formation of Uranium Deposits

Approximately 48 million years ago, South Texas underwent an enormous amount of volcanic

activity, leaving the area rich in dispersed uranium.2 As precipitation filtered through the soil,

uranium dissolved and eventually mixed with groundwater, which flowed downgradient. When

the ground water came into contact with a “reducing environment” containing chemical

compounds such as coal, oil, natural gas or sulfides, the uranium precipitated out of solution and

deposited in an ore body known as a “roll front” as seen in Figure 2. The uranium then

concentrated in these roll fronts trapped between oxidized and reducing.3

Page 25.1458.3

Figure 2: Uranium ore roll front

3

Drilling of a private water well

Private land owners may have a water well drilled on their property. The private owner contracts

with a drilling company to drill the water well. The driller will bring a drilling rig onto the

property and begins drilling several feet into the ground. At this point, a casing then follows the

drill bit to prevent the hole from collapsing. The rod that is connected to the drill bit is hollow,

allowing for a lubricant to be added to the drill bit. This minimizes friction, prevents

overheating, and lifts rock cuttings to the surface. Figure 3 shows the circulation of mud during

the drilling process. This lubricant is commonly known as drilling mud. This mud is a mixture

of water, clay, weighting material and chemicals.4 During the drilling process samples of the

formation are taken and analyzed.5

Figure 3: Mud circulation in the hole

4

When the well is completed, the drilling company will submit a report detailing the description

of the formation materials. There is a section in the report on water quality that indicates if any

of the drilling samples contained undesirable constituents. If the answer is no, then no water

quality testing is needed. If the answer is yes, then a “Report of Undesirable Water” must be

submitted. The original report contains a section with a question asking if a chemical analysis of

the water was completed and is answered by a checked “yes” or “no”. Once this is completed,

the well is ready for private use.6

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Private Well Regulations

There are no regulations in the State of Texas that regulate the quality of water from a private

water well (Texas Groundwater Protection Committee, no date). The quality of the water could

be tested using the guidelines set by the United States Environmental Protection Agency’s (U.S.

EPA) Safe Drinking Water Act (SWDA). However, the SDWA rules only applies to “public

drinking water systems;” that is governmental or privately run companies that supply water to

more than 25 people or 15 service connections. It is at the discretion of the private land owner to

have the water sample tested to see if it meets current SWDA standards.6

Uranium Mining

In-situ Mining

Uranium is first located by exploratory drilling which involves the drilling of boreholes. The

drilling of these boreholes is similar to that of drilling personal water wells. The difference is

that you are not drilling to hit water, but drilling to take soil samples. The soil samples are

examined for different levels of oxidation and reduction. The soil samples will be different

colors, as shown in Figure 4. The process is continued until it is determined whether the

amounts of uranium detected make it economically feasible to recover. The operation then goes

from exploration to the beginning of ISR mining.3

Figure 4: Soil samples

3

The first stage of ISR begins with establishing groundwater quality that will be deemed the

baseline values. These baseline values are an important part of the restoration process after

mining has been completed. After the wells are drilled, oxygenated water is pumped into the

aquifer formation containing the insoluble uranium deposits. The uranium undergoes a chemical

oxidation reaction allowing it to become soluble in water. The water, now containing soluble

uranium, is pumped to the surface and transferred to an ion exchange column, as shown in Figure

5. Here the water is pumped through resin beads that exchange the uranium for chloride ions.

The water now depleted of most uranium (but enriched in chloride) is returned to the aquifer to

start the cycle again. The resin is then shipped to the processing plant to be stripped of uranium

to make yellow cake and the resin is recycled.3

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Figure 5: ISR mining process

7

ISR Mining Regulations

The uranium mining process is regulated by several governmental agencies. Exploration for

uranium deposits is governed by the Texas Railroad Commission (RRC). An RRC exploration

permit consists of maps, descriptions of drillings methods, the estimated number of boreholes,

and the methods for marking the drilled boreholes. The methods for well construction and

plugging of the well, once exploration is completed, must also be noted. Samples from the bore

wells are examined to determine if uranium recovery mining is feasible. This will also give the

geologist an idea of where to drill for the uranium once the recovery process begins.8

Once the recovery of uranium is deemed viable, a new permit must be obtained from the Texas

Commission of Environmental Quality (TCEQ) and its Underground Injection Control (UIC)

program. Some included items are: the core data report, a map of the area, financial assurance,

and a technical report. The map must denote the lease boundaries, the proposed production areas

(PAAs), and the location of baseline wells, along with the location of existing wells within a

quarter of a mile of the PAA and their purposes.11

The technical report of the application focuses on the PAAs. Groundwater analyses for each

baseline well in both production and non-production aquifers must be submitted. A summary

page for the analysis of the ground water must also be submitted as part of the required report.11

The aquifer to be drilled (i.e., for production purposes) must also qualify for an aquifer

exemption from the U.S. EPA.

“An aquifer may be exempted if it is not currently being used — and will not be used in

the future — as a drinking water source, or it is not reasonably expected to supply a

public water system due to a high total dissolved solids content.” 10

If the aquifer does not meet the qualifications for an exemption, then uranium mining will not be

allowed. If the aquifer does meet the exemption qualifications, meaning it does not meet SWDA

standards, then the aquifer is granted an exemption. Once an aquifer is granted an exemption,

Page 25.1458.6

the exemption cannot be revoked. The water is deemed as unsafe forever. However, only parts

of an aquifer may be classified as unsafe, while other areas of the aquifer are safe to drink from.

This could happen around an ore deposit. The water will also have a different taste depending

upon which side of the ore deposit you are on. On the oxidized side of the ore body, the water

will have a much nicer taste. On the reduced side of the ore body, the water may have the smell

of rotten eggs, due to the presence of sulfides. Figure 6 exhibits this situation.

Figure 6: Water quality surrounding ore body11

Baseline Water Quality

To establish baseline levels, water samples are taken from baseline wells in the production zone

in PAA.12

The water is tested for 26 constituents are listed in Table 1 below. There are standards

for collecting, preserving, and analyzing the samples.

Table 1: Baseline Groundwater Sample Constituents12

Nitrate as in N Calcium Alkalinity

Fluoride Magnesium pH

Silica Sodium Arsenic

Total Dissolve Solids Potassium Cadmium

Molybdenum Carbonate Iron

Uranium Bicarbonate Lead

Ammonia as N Sulfate Manganese

Radium-226 Chloride Mercury

Selenium Conductivity

Page 25.1458.7

Placement of Baseline Wells

The placement of baseline wells is not determined or regulated by the TCEQ. Baseline wells are

installed in areas of ore bodies.13

In the production area, a minimum of five baseline wells or

one baseline well for every four acres is needed. The location of these wells must be noted on

the map of the production area that is to be included with the application.12

Creating the Restoration Table

A restoration table is a list of ground water quality parameter values that companies must return

the aquifer to after ISR mining is completed. This table is based upon the baseline ground water

analysis that was submitted with the application. It is calculated by using the mean

concentrations for the 26 parameters based on all groundwater samples collected from baseline

wells prior to mining, or by an alternative statistical analysis approved by the executive director

that yields representative baseline ground water quality.12

Amending the Restoration Table

If a company has been trying to restore the ground water to pre-mining values and has stabilized

reduced concentrations, the company will seek an amendment to the restoration table. There are

various factors that are considered in determining whether the restoration table should be

amended. They include the uses of groundwater at baseline levels, existing use of groundwater,

future use of groundwater at baseline quality and proposed restoration quality, effort made to

reach baseline quality, technology available, ability of technology to restore the groundwater,

cost, consumption of groundwater resources, and the harmful effects of levels of a particular

parameter. More specifically an amendment may be made if a reasonable effort has been taken

to restore the groundwater quality, the value for the parameter has been stabilized for one year,

the water is currently suited for the same use as it was prior to mining, and further efforts would

consume energy, water, and other natural resources without providing benefit to the state. Once

an amendment is made to the table, monitoring must continue for a time period of two years.14

Criticism of ISR Mining

Some argue that “the water needed to drill test wells liberates these two radioactive elements

(uranium and radium)”.15

Or that “it [oxygen] can be introduced by human activities (oxygen-

rich groundwater used to drill exploratory boreholes … in situ mining activities that introduce

oxygen into the deposit…)”.16

In Uranium Mining in Texas: Why Is It Done That Way, it is mentioned that during the recovery

phase of the pump test 99% of the amount of water was returned to the formation, thus allowing

the introduction of “large quantities of oxygenated water, resulting in the elevated values of

uranium observed shortly after the pump test”.17

The water in the PAA may have met SWDA

standards prior to the drilling and testing of the water, but now fail due to the methods used.

Baseline wells are drilled to establish the quality of the groundwater prior to the recovery

mining, but the placement of the baseline wells is not prescribed, as are monitor well placements.

The location of these wells is being criticized. Opposition groups are stating that results of the

boreholes, completed during exploration, could influence where the baseline wells are drilled

Page 25.1458.8

yielding higher levels of uranium allowing the mining companies to “cherry-pick” the locations

of the baseline wells.18, 19

When submitting baseline water samples, companies are required to submit a report with water

quality information. This report asks for the high, low, and average measurement of 26

constituents. The Coastal Bend Sierra Club commented on TCEQ’s Draft Rules for Uranium

Mining in Texas that calculating the average for the restoration table must be scrutinized more

closely. Using an arithmetic mean based is not legitimate if there are outlier values, meaning the

numerical value is very different than the other numbers. The second concern is the use of a

statistical mean. For this to be valid, the sample set must be randomly chosen, whereas in reality

the sample sets are not random.18

Others are criticizing companies for not returning their groundwater to pre-mining conditions.20

Dr. Richard Abitz conducted a workshop for the Coastal Bend Sierra Club and the “South Texas

Opposes Pollution” organization on May 17, 2008, during which he said that “I have never seen

mining companies even come close to pre-mining levels”.20

A report by the Unites States

Geological Society recently stated that “All PAAs in Texas have received amended restoration

goals for at least one element…” 21

Findings

The argument that the drilling process alone is contaminating the water source is a reasonable

argument. However that argument cannot be made true for only drilling with regards to ISR

uranium mining. The same process is used for the drilling of other types of wells, private

drinking wells, public drinking wells, oil and gas wells, and ISR uranium wells. If the water is

being contaminated for baseline values for ISR mining, then the groundwater could also become

contaminated during drilling of public and private drinking wells. More specifically, if uranium

is present then it will be liberated in all locations, not just at uranium mining fields.

According to the Uranium Exploration in the Côte-Nord Region website “there is not enough

volume of material mobilized during exploration work to significantly increase this natural

contamination rate”. The amount of oxygen that may be added during drilling is minimal and

may influence a radius of about three feet.13

This quantity of oxygen is not comparable to the

amount of oxygen that is added to the well once it is in production. It may take as long as a

week for the uranium to peak.14

Some private citizens have had water wells on their private property for years, and point out that

“this water has been used by people for years.” 25

However, it must be recognized that, although

these water wells have been used for years, the water quality has been unregulated. Unless the

water is tested, no one can say for certain that the water meets current drinking water standards.

Uranium was not regulated under the SDWA until 2000 and changed to its current standard of 30

mg/L in December of 2003.26

Prior to this date, uranium had a recommendation level.

Uranium cannot be detected by smell, taste, or sight. As long as the water smells good, tastes

good, and looks good, people drink it. The only way to detect uranium in the water is to have the

water tested. The costs of the tests can be expensive and the ramifications of the test could be

Page 25.1458.9

significant. One EPA-certified company would test for uranium at a cost of $200.28

If test

results reveal undesirable results, the land owner would have to disclose that fact if the property

were ever sold. For this reason, many land owners are not going to have the water tested after a

well is drilled.

The Texas Mining and Reclamation Association (TMRA) researched a database from the

National Uranium Resource Evaluation (NURE) program. The NURE program was established

in the 1970’s to identify uranium resources in the United States. As shown in Figure 7, TMRA

found 108 South Texas wells with levels of uranium higher than the EPA standards. These

wells were tested from 1975 to 1980 and prior to uranium ISR mining.29

Figure 7: Historic water wells in South Texas that contained

uranium above the EPA drinking water standard 29

During the staging of the well field, pump tests are conducted to establish hydraulic

communication between wells. More specifically pump tests are used to define the hydrological

characteristics of the ore zone, obtain information about the ground water flow, and to determine

if the surrounding strata are suitable to prevent movement of the recovery solution into the

underlying or overlying aquifers.30

There are no standards on conducting pump tests or when

these pump tests are to be conducted. Pumps tests involve the pumping of water out of the

aquifer to ensure that the water is going to flow in the correct direction. Well types can be

modified, meaning an injector well becomes an extractor well or the reverse. This ensures that

the next phase of the process, circulating oxygenated water, remains in the mining field. At no

time during the pump test is oxygenated water introduced to the aquifer. The water table is

allowed to rise naturally, filling in with surrounding ground water.

Page 25.1458.10

The question then becomes the location of a well. Some wells are naturally going to show a

higher level of uranium than others. That has more to do with the geology of the well, not the

methodology of the drilling or mining. The mining companies are in the business of making

money by recovering uranium. Legally the mining companies are following the procedures set

forth by the TCEQ and the UIC program. However, there are going to be differences in the

amount of uranium found in baseline water samples, simply because of the geology of the

aquifer and the uranium roll front. The mining companies are going to want areas of high

uranium. Uranium concentrations found in a baseline well in a “hot spot” can dramatically alter

an average.

One suggestion given by Scheurich was to have samples “obtained from wells that are located on

a systemic grid across the entire mining area surrounded by the monitor well ring or randomly

selected with an appropriate statistical procedure”.18

Water samples are typically taken from

existing well sites. Questions are raised concerning how close the wells have to be and whether

baseline wells really provide representative statistical data if they are not systematic in location

but are rather drilled as a means to locate pockets of uranium.

Lastly is the problem of the restoration of the aquifer to the baseline quality. A company will ask

for an amendment to the restoration table. How much work does a company need to do to return

the levels to pre-mining conditions? I should be noted that if an amendment is granted the

company must monitor that well for an additional two years. Maybe the answer is not in just

monitoring and reaching a consistent level, but what other techniques can be employed to lower

the current level to the original baseline levels.

Conclusions of Summer Research

Private citizens should have their water tested for health and safety reasons. This testing should

be independent of uranium mining or uranium exploration. Merely stating that drilling wells

during uranium exploration is causing contamination of the water supply is not justified. If the

drilling process contaminates water with uranium then the same would have to be true for all

contaminants that behave similarly and all wells that are drilled in areas rich with uranium

deposits. The quality of water has to do more with the location than the drilling process.

Unfortunately, it appears that the selection of wells for establishing baseline groundwater quality

is governed by the uranium exploration process, as opposed to a more rational geostatistical

approach. Groundwater in a uranium ore body will naturally differ from groundwater quality

that is not in a uranium ore body. The two types of groundwater quality are currently not clearly

segregated when establishing baseline groundwater quality and they should be distinguished.

There is also the problem of calculating the “average” constituent concentration that is site

specific since each site is different with respect to well spacing and aquifer characteristics. Each

ore body and mine field must be examined closely to determine which statistical method is best

suited for the site. Geology is also plays a large role in baseline concentration values and some

areas are going to have a naturally higher concentration than others.

Page 25.1458.11

Legacy Cycle

Mrs. Hamilton, the teacher-researcher, teaches in a rural community of approximately 2,000

people. Schools in the surrounding school districts only enroll students up to either grades six or

eight. At the time of implementation, the high school enrollment was 240 students, including

transfer students from surrounding communities. The lesson cycle was implemented with 21

students. With the exception of one tenth grader, all the students are seniors. The demographics

of the students are split between 11 Hispanics and 10 Caucasians, with 14 males and 7 females.

The learner abilities vary greatly as the class is an elective course. Students range from gifted

and talented to modified-curriculum due to special needs. Five students are identified as At-Risk

and 11 students are economically disadvantaged. With this new wealth of information and the

importance of what was learned from the research, a lesson cycle was developed for the teacher’s

students to share in this new perspective of water quality. The implementation of the legacy

cycle will have meaning to students in this community, as many families have private water

wells and know of the uranium controversy occurring in their own backyard.

The students will go through the learning process of the legacy cycle. The legacy cycle is

comprised of six stages: challenge question, generate ideas, multiple perspectives, research and

revise, test your mettle, and go public. Students will be challenged with the question of “is your

water safe to drink?” Students will have to determine what makes water safe to drink. During

class discussions, students will bring up the topic of uranium in the ground water. At this point,

the teacher will integrate her experience from the RET summer experience. Students will then

research how wells are drilled, how aquifers work, how to mine uranium using in situ recovery

mining, and how it affects ground water quality. Students will hear different perspectives from

various people dealing with ground water quality. Students will test their own well’s water using

various test strips and hand-held data collectors. Students will determine whether their own

drinking water meets standards, based on the constituents that were tested. Students will share

this information by writing articles for the school newspaper and local newspaper.

Finally, students will test their understanding of the project by taking on the task of being

“employed” by an environmental lab that tests water quality. Each group of students will be

given different water samples. Each group must create a report to submit to clients summarizing

the water quality. The report must be consumer-friendly and easily deciphered.

Conclusions and Summary

With the implementation of this legacy cycle a greater understanding of water quality should be

gained by those that need it most. Providing a community with the knowledge of the geology

and science behind their drinking water source will alleviate many misconceptions. Student will

become informed consumers and will not perpetuate false science. In a community where

uranium mining has occurred to the north and may also begin to the south, the knowledge of

scientific principles is vital. The town has had its problems with uranium in the water.

Therefore the community needs to be educated so that decisions are made based on science

rather than fear. This lesson was designed to give a basic understanding of uranium and water

quality. The greater result will be an understanding of asking the right questions and seeking

answers to those questions.

Page 25.1458.12

Acknowledgement

This material is based upon work supported by the National Science Foundation under Grant No.

EEC-1106529, Research Experience for Teachers in Manufacturing for Competitiveness in the

United States (RETainUS). Any opinions, findings, and conclusions or recommendations

expressed in this material are those of the author(s) and do not necessarily reflect the views of

the National Science Foundation.

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