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Whetstone' <br />Associates <br />Technical Memorandum <br />pertinent sampling information (e.g. date, sample ID, sample depth, GPS reading for <br />location, general descriptions and observations). <br />4. Once all samples are collected, analyze them in a small on-site soils laboratory for Ra-226 <br />content as described in the RML decommissioning plan. Compile results and generate depth <br />profiles of soil Ra-226 versus sample depth. Identify any layers of interest, and if possible, <br />create 3 dimensional schematic maps of subsurface contamination. <br />5. Select representative sample aliquots to send to the laboratory for testing, including uranium <br />and Ra-226, and EPA Method 1311 analysis by Toxicity Characteristic Leaching Procedure. <br />6. Develop a report covering the toxic forming potential of alluvial fill source term materials <br />and include a related assessment of potential impacts (hydrologic and any others) of disposal <br />of this material in the mine workings from which they originated, via the Minnesota Portal. <br />7. If supported by the overall assessment, submit a Technical Revision request to dispose of this <br />material in the Minnesota portal, and include provisions for the excavation work such as <br />management of groundwater to protect water quality in the creek, re-grading for stormwater <br />management and final re-vegetation, etc. <br />8. If disposal of source term material in the Minnesota portal is not supported by the <br />assessment, propose alternate disposal options and related assessments to DRMS. If <br />consensus can be reached on an alternative disposal strategy, submit a revised Technical <br />Revision request accordingly. <br />All of the above assessments and approvals must be completed prior to August 1, 2011 in order to <br />allow the planned source term removal to commence on schedule. <br />26) Ground water is likely to be encountered during the alluvial extraction activities, and the water <br />will likely contain radionuclides, molybdenum and other constituents. Describe the management <br />plan for the ground water, including proper disposal, treatment, or other plans. Surface water <br />management plans must also be included. The Operator must also describe the methods to be used <br />to test the soil and evaluate whether the soil excavation/disposal program in the alluvium has <br />successfully removed the contaminants of concern. Because the alluvium contains toxic forming <br />materials, DBMS contends that the alluvium should also be designated as an Environmental <br />Protection Facility and therefore subject to the provisions of Rule 64.20(7)(e). Operator must <br />describe any release response procedures, redundancies, and "backup" measures necessary, <br />appropriate, and economically reasonable, to control, prevent and mitigate releases of the toxic- <br />forming materials from the containment facility (i. e., the alluvium) outside the permit area. <br />Contaminated groundwater encountered during site excavation activities will be treated through the <br />100-gpm ion exchange (IX) water treatment plant that will be operational on site. <br />REFERENCES <br />Adventus Group, 2009. "Dissolved Iron and Manganese Trends in EHC Amended Aquifers:, <br />Technical Note, August 2009. 4 pp. <br />4109C.100731 18