DRC-2022-024632 - 0901a0688115a3fc

Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
State of Utah
SPENCER J. COX
Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
DEIDRE HEN DERSON
lieutenant Governor
Douglas J. Hansen
Director
MEMORANDUM
TO: File
THROUGH: Phil Goble, Manager .P/2 6
FROM: Dean Henderson, P.G. #If-n./'Z-1/z_tJ--z .. :z __
December 21, 2022 DATE:
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 2nd Quarter 2022 Groundwater
Monitoring Report for the White Mesa Uranium Mill
Review Summary:
The Utah Division of Waste Management and Radiation Control ("Division") has reviewed the
following documents submitted by Energy Fuels Resources (USA) Inc. ("EFR"):
1. EFR, August 8, 2022, Transmittal of 2nd Quarter 2022 Groundwater Monitoring
Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium
Mill ..
2. EFR, July 13, 2022, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill -Notice Pursuant to Part I G.1 (a) (Received by the
Division on July 15, 2022).
The review was conducted to ensure compliance with all applicable parts of Utah Groundwater
Discharge Permit No. UGW370004 ("Permit") issued for the White Mesa Uranium Mill located in
Blanding, Utah (Mill).
1. Checklist of Significant Findings of the 2nd Otr. 2022 Report and Related Actions at the
White Mesa Uranium Mill:
1. The 2nd Quarter 2022 Report was received before the due date (Permit Part I.F.l -
due date of September 1 ).
2. DWMRC notes that samples were analyzed by Chemtech-Ford Laboratories
("Chemtech") and GEL Laboratories LLC, Charleston, South Carolina (Gross
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.111ah.gov
Printed on I 00% recycled paper
DRC-2022-024632
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page2
2.
Alpha Samples Only). DWMRC verified that the laboratories have current Utah
certification for the parameters analyzed.
3. Laboratory QA/QC flags were documented in the review period analytical data
reports from the contract laboratories and an in-house QA/QC review was
conducted by EFR regarding all field and laboratory data. Per DWMRC review it
appears that all discrepancies were self-reported by EFR.
4. One new compliance parameter went into accelerated monitoring frequency
(POOC) based on sampling during the 2nd Quarter 2022 (Floride in Monitoring
Well MW-27).
Accelerated Monitoring and POC Wells Exceeding GWCL's:
When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL)
set forth in Table 2 of the Permit, it is in Probable Out-of-Compliance (POOC) status. According
to the Permit, EFR is then required to immediately initiate accelerat~d sampling of that pollutant
(see the Permit, Part I.G.1 ). When monitoring wells have parameters that have exceeded the
Ground Water Compliance Limit (GWCL) two or more consecutive times they are in Out-of-
Compliance (OOC) status (see the Permit, Part I.G.2).
In the event a constituent is in OOC status, EFR is required to prepare and submit within 30
calendar days to the Director a plan and time schedule for assessment of the sources, extent and
potential dispersion of the contamination, and an evaluation of potential remedial action to restore
and maintain groundwater quality to ensure that Permit limits will not be exceeded at the
compliance monitoring point and that DMT or BAT will be re-established, in accordance with
Part I.G.4(c) of the Permit.
One new compliance parameter went into accelerated monitoring frequency (POOC) based on
sampling during the 2nd Qu~er 2022 (Floride in Monitoring Well MW-27).
Current Accelerated Monitoring Status:
The table below (Table 1) lists monitoring wells with parameters currently in OOC or POOC
status and therefore required to be sampled under the accelerated monitoring requirements:
a e -e s T bl 1 W II M omtore ua er1y cce erate dQ rt I A I 0 on ly om orm~ d t M thl M "t .
Well Class *Position Parameter Date of First Date Accelerated
Exceedance of Monitoring First
GWCL Required
Chloride 3rd Quarter 2019 November 2019
Sulfate 3rd Quarter 2019 November 2019
MW-11 Class II water D-3 Total Dissolved Solids 3rd Quarter 2021 November 2021
Manganese 3rd Quarter 2021 November 2021
Nitrate+ Nitrite (as N) 1st Quarter 2022 June 2022
MW-25 Total Dissolved Solids 3rd Quarter 2021 November 2021
MW-26<a> Class III water C-2 Nitrate+ Nitrite (as N) February 2010 May 2010
Chloroform February 2010 Mav 2010
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
Well Class *Position Parameter
Chloride
Carbon Tetrachloride
Methylene Chloride
Total Dissolved Solids
Nitrate+ Nitrite (as N)
Chloride
MW-30 Class II water D-2 Uranium
Selenium
Total Dissolved Solids
Nitrate+ Nitrite (as N)
Chloride
MW-31 Class III water D-2 Total Dissolved Solids
Sulfate
Uranium
Date of First Date Accelerated
Exceedance of Monitoring First
GWCL Required
February 2010 May 2010
1st Quarter 2021 2nd Quarter 2021
3rd Quarter 2020 August 2020
3rd Quarter 2021 November 2021
February 2010 May 2010
1st Quarter 2011 May 2011
1st Quarter 2021 2nd Quarter 2021
1st Quarter 2021 2nd Quarter 2021
3rd Quarter 2021 November 2021
1st Quarter 2010 May 2010
1st Quarter 2011 May 2011
3rd Quarter 2019 November 2019
3rd Quarter 2019 November 2019
2nd Quarter 2020 August 2020
D = Down-gradient; U == Up-gradient; C = Cross-gradient; 1,2,3,4A, 4B =Cell#
a = Monitoring well MW-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annually Accelerated to Quarterly Monitorinir
Well Class *Position Parameter Date of First Date Accelerated
Exceedance of Monitoring First
GWCL Required
MW-12 Class III water D-3 Uranium 2nd Quarter 2017 3rd Quarter 2017
Selenium 2nd Quarter 2020 3rd Quarter 2020
MW-24 Class III water D-1 Beryllium 4th Quarter 2017 1st Quarter 2018
Cadmium 2nd Quarter 2018 3rd Quarter 2018
Thallium 2nd Quarter 2018 3rd Quarter 2018
Field pH 2nd Quarter 2018 3rd Quarter 2018
Fluoride 4th Quarter 2018 3rd Quarter 2019
Nickel 4th Quarter 2018 3rd Quarter 2019
Manganese 4th Quarter 2019 1st Quarter 2020
Sulfate 1st Quarter 2020 3rd Quarter 2020
Gross Alpha 4th Quarter 2020 3rd Quarter 2021
Total Dissolved Solids 2nd Quarter 2021 3rd Quarter 2021
MW-27 Class III water U-1 Nitrate+ Nitrite (as N) 2nd Quarter 2010 3rd Quarter 2010
Fluoride 2nd Quarter 2022 3rd Quarter 2022
Chloride 2nd Quarter 2010 3rd Quarter 2010
Cadmium 2nd Quarter 2014 2nd Quarter 2014
MW-28 Class III water D-1 Uranium 2nd Quarter 2014 2nd Quarter 2014
Selenium 2nd Quarter 2019 3rd Quarter 2019
Nitrate+ Nitrite (as N) 4th Quarter 2019 3rd Quarter 2020
MW-29 Class III water D-2 Uranium 4th Quarter 2020 3rd Quarter 2021
MW-32 Class III water C-2 Chloride 1st Quarter 2015 2nd Quarter 2014
* D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A, 4B = Cell#
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page4
Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status
as of the 2nd Quarter of 2022. EFR is required to notify the DWMRC on a quarterly basis
regarding wells and parameters which went into accelerated monitoring during the period [Part
I.G.l(a), Accelerated Monitoring Status Reports (AMSR)].
3. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection:
As stated in Section 6.2.7 of the EFR Quality Assurance Plan (QAP), Rev. 7.6, EFR has a choice
regarding purge volumes as follows:
"I. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within I 0% RP DJ
3. Purging a well to dryness and stability of a limited list of field parameters after recovery"
Per DWMRC review of the Report, the following purge methods were used during the 2nd Quarter
2022 (including accelerated samples). Purge methods and volumes are summarized in Tab G, on
Table G-lA and G-1B of the Report:
Quarter # Purged 2 Casing # Purged to Dryness # Purged 3 Casing Volumes
Volumes
2nd Qtr. 2022 32 7 5 ( continuous pumping)
When purging two casing volumes, the QAP directs EFR to first calculate the amount of time to
evacuate two casing volumes and then to pump for that length of time. Per DWMRC cross-check
of the field data sheets for each of the reports reviewed, it appears EFR correctly calculated the
well casing volumes and evacuated the required two volumes (when 2 casing volume method
selected) in monitoring wells prior to sample collection during the 2nd Quarter 2022 monitoring
period. Volumes are calculated according to measured pump rates and can be verified by
calibration marks on the collection containers.
During the 2nd Quarter 2022 monitoring period three monitoring wells were pumped or bailed to
dryness. In cases where wells are evacuated to dryness the QAP Rev. 7.4 (Attachment 2-3)
requires that:
"(vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is available to fill
sample containers.
Upon arrival at the well after recovery or when sufficient water is available for sampling measure
depth to water and record on the Field Data Worksheet.
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
Take one set of measurements of field parameters for pH, specific conductance, and temperature
only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific conductance and
temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within 10% RP D the
samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not within 10% RP D,
dispose of the sample aliquots, and purge the well again as described above.
Repeat this process, if necessary, for three complete purging events. If after the third purging the
event, the parameters of pH, specific conductance and temperature do not stabilize to within 10%
RP D, the well is considered sufficiently purged and collected samples can be submitted for
analysis."
DWMRC staff verified that in cases where the monitoring well was evacuated to dryness and
samples were collected, the number of gallons evacuated was recorded in compliance with the
QAP. Additionally, depth to water before sample collection was recorded on all applicable field
data worksheets which resolved past DWMRC comments.
4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind
Duplicate Analysis
DWMRC conducted a review of the blind duplicate samples collected during the 2nd Quarter
2022. Per the QAP, one blind duplicate must be collected with each sample batch. DWMRC
confirmed that one blind duplicate was collected for each batch -4 total during the quarterly event
-two with the baseline samples (MW-29/MW-65 on 4/14/2022) and (MW-36/MW-70 on
4/21/2022); and two with the accelerated samples, (MW-30/MW-65 on 5/4/2022) and (MW-
25/MW-65 on 6/7/2022).
The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the
measured concentrations are less than 5 times the required detection limit (Standard Methods,
1998)."
Per the QAP, if any of the samples do not meet the comparison criteria ( and are not qualified
according to the 5 times method detection limit criteria) then EFR is required to conform to the
procedures for corrective action listed as follows:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation errors,
and,
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
If the samples are still within holding time, the QA Manager may request the laboratory re-
analyze the affected samples.
Per DWMRC cross check of the blind duplicate samples collected and analyzed during the 2nd
Quarter 2022 sampling event all results conform to the Permit requirements (within 20% RPD)
with the exception of ammonia and fluoride in MW-29/MW-65 and nitrate in MW-36/MW-70.
However, the sample and duplicate results were not greater than 5 times detection limit and as
such are acceptable.
Radiological duplicate sample results met duplicate counting error requirements in the currently
approved QAP for the 2nd Quarter 2022. No additional action is required. It was noted that a few
of the reported sample results did not meet the radiological counting error requirements of less
than 20% of the result, however, in those cases no further action is required based on the QAP
condition that the 20% criteria do not have to be met if the sum of the result and error is less than
the GWCL. The sum was less than the GWCL in all samples which had a Permit GWCL for
companson.
5. Analytical Laboratories Used by EFR Certified by State of Utah to Perform Analysis
for all Analytes:
The analytical laboratories (GEL Laboratories LLC, Charleston, SC; Chemtech Ford Laboratory,
Sandy, UT) were contracted by EFR to perform analysis on the samples collected during the 2nd
Quarter 2022. Per DWMRC review of the National Environmental Laboratory Accreditation
Management·System Website (cross check of laboratory certification for specific parameters) it
appears that the EFR contract laboratories were certified to perform analysis for the specified
parameters (Per the laboratory data sheets):
GEL Laboratories LLC Current Certification
Basic Details
Name GEL Laboratories, LLC
Type of Lab Not Specified
TNI Lab CodeTNI00188
EPA Code SC000 12
State ID 8037697376
Extended Details.
Primary AB responsible
for lab demographics Utah Department of Health
GIS Location
Description
Comments
Effective Date n/a
Commercial Samples Yes
Active Yes
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
Location Address
Company
Contact
Address 1
Address 2
Carey J. Bocklet
2040 Savage Road
City Charleston
State South Carolina
Zip 29407-
Country USA
Phone [phone]
Fax [phone]
· Email [e-mail]
Chemtech Ford Laboratory Current Utah Certification
Basic Details
Name Chemtech Ford Laboratory
Type of Lab Not Specified
TNI Lab Code TNIO 1969
EPA Code UT00027
State ID 8012627299
Website http://www.chemtechford.com/
Extended Details
Primary AB responsible
for lab demographics Utah Department of Health
GIS Location
Description
Comments
Effective Date n/a
Commercial Samples Yes
Active Yes
Location Address
Company Chem tech Ford Laboratories
Contact David Gayer
Address 1 9632 South 500 West
Address 2
City Sandy
State Utah
Zip 84070-
Country United States
Phone [phone]
Fax [phone]
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
Email [e-mail]
6. Laboratory Report Turn Around Times:
Per DWMRC review of EFR Table 1 included in the 2nd Qtr. 2022 Report, it was noted that
laboratory report turnaround times (from date ofEFR sample submission to the contract
laboratory) for normal frequency monitoring was approximately 30 days for all samples (not
including re-submission/corrected reports). Per DWMRC review it was noted that EFR acted
quickly to identify any deficiencies in the reports and request corrected versions.
Based on DWMRC review the tum-around times for the 2nd Quarter 2022, data tum-around times
and EFR data review timelines appear to be reasonable/appropriate.
7. Sample Holding Times:
Per the Report Section 3.4.2 and Table G-2A in Tab G of the Report, all method holding times
and reporting limits were met for each analyte submitted for laboratory analysis ( for baseline and
accelerated samples). DWMRC staff cross checked all holding time requirements and verified
that all samples/analytes appeared to be analyzed within holding times during the 2nd Qtr. 2022
reporting period.
8. Sample Preservation:
Per review of the 2nd Quarter 2022 Report (Part 3.4.3, Tab G, and Laboratory Check-in Sheets) it
appears that all samples required to be chilled (~6° C) met the temperature preservation
requirements. Per review of the laboratory check in sheets and laboratory QA/QC, no issues
related to sample preservation were noted. Per EFR information and method requirements,
samples for gross alpha analysis do not have a sample temperature requirement.
9. Sample Trip Blank Evaluation:
Per Section 3.4.6 of the Report and Tables in Tab G of the 2nd Quarter 2022 Report all trip blank
results associated with the quarterly, semi-annual, and accelerated samples were nondetect for
volatile organic compounds.
10. Review of Time-Concentration Plots
The Permit Part I.F. l .g requires EFR to submit Time-Concentration Plots for each monitoring
well for primary indicators of cell leakage; chloride, fluoride, sulfate, and uranium. PWMRC
notes that per the discussions with EFR, it was agreed to that EFR need not plot trend lines on the
Time Concentration Plots and that all data is included on the plots (no data culled from the set).
Per DWMRC review of the 2nd Qtr. 2022 Report, the reviewed plots appear to be in conformance
with the agreed upon changes.
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
11. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DWMRC cross checks of groundwater elevation measurement calculations used for the 2nd
Quarter 2022, approximately 5% of wells cross checked, comparing surface casing measured
elevations minus measured static levels with plotted elevations, no errors were noted.
The upper wildlife ponds at the White Mesa Mill were taken offline (pond recharge from
Recapture Reservoir discontinued) during the 4th Quarter 2011 to re-establish groundwater
contours. Hydrographs of the upper wildlife pond ground water piezometers (Water Level
Elevation vs. Time) are included below (Northern piezometers and southern piezometers). It was
also noted that the static water levels in several monitoring wells close to the upper wildlife ponds
showed significant decrease in water levels since the ponds were taken offline. These declines
can be attributed to natural dissipation of the area ground water mound and/or ground water
pumping activities related to corrective action of nitrate and chloroform contamination plumes
(development of cone of depressions around pumping wells).
Nitrate and Chloroform Corrective Action Plan Pumping Wells:
Ground water elevations are being impacted by effects from ground water pumping for the nitrate
and chloroform contamination plume remediation. The following monitoring wells have been
converted to active pumping wells:
Nitrate Pumping Wells -TW4-22, TW4-24, TW4-25, TWN-2 (The nitrate pumping project was
initiated during January 2013).
Chloroform Pumping Wells-MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-
20, TW4-21, TW4-22, TW4-24, TW4-25, TW4-37, TW4-39.
The pumping wells for both the nitrate and chloroform projects are set up with a delay device
wherein the wells purge for a set amount of time then shut off to let the well recharge. All
pumping wells include a flow meter which records the volume of water pumped from the well in
gallons. Quarterly nitrate and chloroform reports are prepared by EFR and include pump volumes
and delineation of pump capture zones based on kriged water contours.
DWMRC expects that ground water elevation contours will continue to adjust in response to the
pumping activities and discontinuance of recharge to the upper wildlife ponds.
12. EFR July 13, 2022, Notice Pursuant to the Permit Part I.G.l(a)
The EFR July 13, 2022, Notice Pursuant to the Permit Part 1 G.1 (a) ("Notice") discusses the
status of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-
compliance ("OOC") status, as updated through the 2nd Quarter 2022. DWMRC notes that the
Notice was submitted timely regarding currently agreed upon schedules, reporting of exceedances
within 30 days after the end of the monitoring quarter, and has been updated based on issuance of
EFR 2nd Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
the current modified GWDP (Issued effective March 8, 2021) in effect during the monitoring
period.
Per the Notice, one new parameter went into POOC or OOC status during the 2nd Quarter 2022
(Floride in MW-27). Based on DWMRC review of the Notice it appears that all requirements of
the Permit were met.
13. Conclusions and Recommendations
Based on DWMRC staff review of the above listed documents and review the following will be
included in a close-out letter:
1. Close-out regarding DWMRC review of the EFR August 8, 2022, 2nd Quarter 2022
· Groundwater Monitoring Report.
2. Close-out regarding DWMRC review of the EFR July 13, 2022, Notice Pursuant to Part
I.G.l(a).
14. References
1 Energy Fuels Resources (USA) Inc., August 8, 2022, 2nd Quarter2022 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., July 13, 2022, State of Utah Ground Water Discharge
Permit No. UGW370004 White Mesa Uranium Mill-Notice Pursuant to Part lG.l(a).
3 Energy Fuels Resources (USA) Inc., May 14, 2019, White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP), Revision 7. 6.
4 INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
5 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison
Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
6 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the July 2007 Sampling Event at the Denison
Mines, USA, White Mesa Uranium Mill located near Blanding Utah. Prepared by University of
Utah Department of Geology and Geophysics.
7 Utah Department of Environmental Quality, March 8, 2021, Modified Utah Ground Water
Discharge Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa
Uranium Mill.