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Home My WebLink AboutDRC-2012-001161 - 0901a068802b1551State of Utah GARY R HERBERT Governor GREG BELL Lieutenant Governor Departmentof P R C " 2 0 1 2 " 0 0 1 1 6 1 Environmental Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director TO FROM MEMORANDUM Phil Goble '^/f/z^l'^ Dean Henderson DATE Febmary 7 2012 SUBJECT Review of the White Mesa Mill Evaluation of Deep Water Supply Well WW 2 Utah Groundwater Discharge Permit No UGW370004 for the Denison Mines (USA) Corp (DUSA) White Mesa Uranium Mill near Blanding Utah This is a review of the DUSA White Mesa Mill Evaluation of Deep Water Supply Well WW 2 for the White Mesa Uranium Mill near Blanding Utah ( Report ) This Report is in response to Groundwater Discharge Permit No UGW370004 ( Permit ) Part IH 3 which is quoted below IHS Plan for Evaluation of Deep Supply Well WW 2 the purpose of this plan is to evaluate the annular casing seal in water supply well WW 2 and to ensure adequate well casing and annular seals in compliance with the regulations ofthe Utah State Engineer (UAC R655 4 9) with special emphasis on creating both a physical barrier and hydraulic isolation between the shallow unconfined and the deep confined aquifers On or before January 31 2012 the Permittee shall a) Conduct an investigation ofwater supply well WW 2 to verify that the casing and annular seal is intact and creates both a physical barrier and hydraulic isolation between the shallow unconfined and the deep confined aquifers said investigation shall include one or more of the following investigation techniques performed in accordance with applicable guidance from the U S Environmental Protection Agency well casing video logs cement bond logs and/or temperature logs b) Show that the well casing and annular seal have physical and hydraulic integrity to isolate the two aquifers mentioned above In the event that hydraulic isolation ofthe two aquifers is uncertain or unsubstantiated for any reason the Permittee shall repair the well casing and annular seal(s) to provide well construction that complies with the regulations ofthe Utah State Engineer (UAC R655 4 9) After such repairs are completed the Permittee will conduct repeat testing using the investigation techniques required under Part 1H 3(a) to demonstrate existence ofthe required hydraulic isolation and 195 North 1950 West Salt Lake City UT Maihng Address P O Box 144850 Salt Lake City UT 84114 4850 Telephone (801) 536 4250 Fax (801) 533 4097 TDD (801)536-4414 wwwd q thg Pr ted o 100% y 1 d p p Page 2 c) Submit a written report for Executive Secretary approval to document the investigation and Its findings and any well repair activities Said report shall be certified by a Utah licensed Professional Engineer or Geologist Overview of Report In response to Part IH 3 of the Permit DUSA dnlled a bonng (DR 1) approximately 50 feet southwest of well WW 2 in Apnl 2011 to determine the depth of the contact between the Burro Canyon Formation and the underlying Bmshy Basin Member of the Momson Formation which forms the base of a relatively shallow perched water zone at the site The bonng for DR 1 was dnlled with the use of an air rotary dnll ng and the dnll cuttings were logged every 2 5 feet The lithologic log for DR 1 (see Attachment 1) shows the depth of the Bmshy Basin contact was logged at 101 feet below ground surface ( bgs ) The well dnllers log for well WW 2 (see Attachment 1) shows Mud Stone Blue Gray between 80 and 150 feet bgs suggesting that the contact could be as shallow as 80 feet bgs The lithologic log and dnllmg report of well WW 2 show that the well was grouted from the ground surface to 100 feet bgs with sand filter pack from 100 to 1 250 feet bgs and screened casing from 250 to 1 250 feet bgs There was not an elevation listed m the Report at the location where bonng DR 1 was installed therefore the bgs measurements listed are not associated with an elevation above mean sea level (amsl) Based on the above information the Report concludes the depth of the Bmshy Basin Member/Burro Canyon Formation contact at well WW 2 is between 80 and 101 feet bgs and the bore seal is likely keyed into the Bmshy Basin Member The 80 foot contact depth is based on the dnllers log for well WW 2 and the 101 foot depth is based on the lithologic log for nearby investigation bonng DR 1 Well WW 2 is located upgradient of Mill operations is substantially upgradient of the site tailings cells and is located upgradient of perched chloroform and nitrate plumes identified at the site Furthermore the 1 200 foot deep Navajo/Entrada aquifer beneath the site IS under approximately 800 feet of artesian pressure The potential for seepage of any perched zone water or contaminants mto the gravel filled portion of the annular space at well WW 2 is considered negligible and the water quality of the Navajo/Entrada aquifer would be protected from any seepage that might potentially occur by the artesian pressure in that aquifer DRC Comments Based on the mformation provided in the Report the DRC has concluded that the findings of the Report are inconclusive to prove that well WW 2 s well casing and annular seal have physical and hydraulic integnty to isolate the two aquifers because of the following 1) DR 1 was logged by dnll cuttings and identified strata contacts bgs at 100 feet which may only be accurate withm couple of feet and because these measurements are not associated with an elevation this adds to the confusion of where exactly the Bmshy Basin contact is located at DR 1 m relation to well WW 2 2) Because cement bond logs and/or temperature logs weren t used by DUSA to identify the Bmshy Basm Member/Burro Canyon Formation contact the dnlling report for well WW 2 that shows the well was grouted from the ground surface to 100 feet bgs may be easily off by a few feet or more and Page 3 3) Possible elevations differences between DR 1 and well WW 2 locations Therefore using depth bgs to determine if well WW 2 is keyed mto the Bmshy Basin Member may be misinterpreted Because well WW 2 is a deep water supply well and the water in the well could be used for dnnking water the DRC met with Utah Division of Dnnking Water ( DDW ) to discuss well WW 2 Mr Jim Martin and Ms Patti Fauver both from DDW were familiar with well WW 2 at the Mill and told the DRC that DUSA is required to sample the well and submit the results to DDW DUSA IS currently required to follow a monitonng schedule for well WW 2 and sample for coliform ( TCR ) lead and copper nitrate inorganics metals sodium sulfate TDS and volatile organics (see Attachment 2) DDW descnbed that if any of these constituents exceed a Maximum Contaminant Level ( MCL ) or if there is any detectable concentrations of volatile organic compounds ( VOCs ) observed the DDW will enforce remedial action According to the Public Water System Histoncal IPS Report provided by DDW the only histonc exceedances were TCR (see Attachment 2) DDW concluded that the exceedance in TCR was from the system and not from the groundwater Although the Report is inconclusive m proving that well WW 2 s well casing and annular seal have physical and hydraulic integnty to isolate the two aquifers DDW regulates the groundwater source at this well and will enforce remedial action should the groundwater be impacted Therefore it is appropnate to refer public inquires for well WW 2 to DDW Apparent Violations Part IH 3(a) of the Permit required DUSA to perform one of the following investigation techniques well casing video logs cement bond logs and/or temperature logs to venfy that the casing and annular seal is intact and creates both a physical bamer and hydraulic isolation between the shallow unconfined and the deep confined aquifers Although DUSA did perform an investigation of well WW 2 they failed to perform any of the techniques listed m Part IH 3(a) of the Permit However DRC Staff believes that even though DUSA not perform any of the investigation techniques required m Part IH 3(a) of the Permit the deep aquifer found in well WW 2 is protected for the following reasons • Well WW 2 IS located upgradient of the tailings cells and the Chloroform and Nitrate plumes therefore it is unlikely groundwater m this well has been affected or will be affected by these potential sources • Well WW 2 currently provides the Mill with water for eye wash stations and showers is pumped several times a day and yields about 160 gallons per minute The deeper confined aquifer is protected due to the artesian conditions in the confined aquifer and the repeated removal of water from well WW 2 This active pumping will deliver any potential contaminants back to the ground surface for use m the Mill operations Well WW 2 is regulated by the DDW DUSA is required to sample the well and submit the results to DDW The DDW has assured the DRC that if any samples exceed a MCL Page 4 for any constituent or if there is any detectable concentrations of VOCs observed the DDW will enforce remedial action For the reasons descnbed above DRC Staff recommends the Executive Secretary use enforcement discretion in this matter and close out Part IH 3 of the Permit Page 4 Attachment 1 Lithologic Log for DR 1 and Well Dnller s Log for WW 2 Water Well #2 nrrouT OF \ LI L DWI LCR STATl. OP UTAH \ I CNFU \L STATKMhNT , Th t r port ch«U be f led witK CMita c n Utul m d m r) Coof4lMU K 'V"*".^ J * I' ^'i'l''' iimhr mode nd /ilid with lh« SUte Enrin r tn'MC rd nM with tht I w of Uuh uh lh« SUte (^nslncn within 90 days »Xter th« comnleU n er b ndvnmenL < th w It. F il re te M uch ^^fe gnerov Fuols Huclo^r ^MsSiniiDdijBa. iltah_ 2KL0CA1I0N OF WLLL ow 4 W tiMla. Jlo kU fct e8..^T 37 . " SE (12) WBLLISSTS Dt vAtwi^ k tb* 411 •< la If* tk If^ hUam U tl In l> Wu YliU ^it>u . ' .f" ^ ft"- J III! IL IH .1^^^ (13) WELL LOG ^^Au^^.n IS otpih 4 OM ^ .1fi85.,.. -I,:!;! f.« i>**th t cgi>pi*t*d iftfts 3; NATURE or \VORK (check) ii o •pt m t K n • Otocoiiic Q |Up*l • Ak*ado • ^^^iMkMBb fcMriba rn^KtUl ad BivMdun __________ NOXS f lact* *'X in *c* or saiiiWI itli^ f pn, OHitU Mi.»l • tarUU atoa un4 fat «• h d*etli 1 l*r« L U dar RXUARIwS n k ar oai U MU* M la Mm nac* t «i*t* «ad Ik* <al* liM, Baiur^ aUi f m UtUl cmatend I «Mk d*plk bit«fy*l Uw aMUkwd kMt U *»•<•«. 4) NATURE OP USE (check) •aaalU • TteaUw D ladiutelil ^ XuaUlpd • Mochw Ur • D OUt* O Ttot WaU O 5) TYPE OP CONSTRUCTION (check) kl* v^«tt*4 B«*4 G) CASINO SCdEOULB nmM Q W*U.< a CM*. .. ., Dl m. trvn „ , fwi Tn f»«| i?-f- 7) PERFORATIONS •p* el p«rt Uor ni-t m at pattw Uai Tttn U4T T** O lb O rut h> fnt __.r«*t la iMi i*rt *-> r..t 0} SCREENS nat* m' M«IB*_ }] CONSTPUCTION M « il »nl iMckalT Y M • Bl t iS/StoS/^ ^1 Ic^r m ^lOQ .rtW_J2&P f«t M HT Ira iMi Y d( N • I'T* wh (9i!il IQQ, (Ml u 1*1 imd I Ml Qwsnt 4 wnl IUMWUITMO M W* t U . Drpk I I iOta4 U t* all _______________ **M U M aU tk* m UiM IH I I tfOM YM y** a 10) WATER LE\ ELS k I I f^Q wis I d ( o I jgl*_ « JU, Id rl n b 3C llECbl\l-li (11) l-LOWINC \rELL Co f*l (d k ( kwk) V I • c o ri a M c» ml Q U I «. d «Mt>al T. D fMd _Oct —IQ— (14) PUMP a atah N TJ. t h ta IW ITCI W II » 111 SI t m nt Thl w II w drill d u dcr my »up rv th he t f Bfir hn wl dc nd b Iwl _ CdEShavLOjnlJjJJS Jn<;L* nd thl epo I U tru U Add Add '''#^'No"60'or Cedar Citv UtalTgrfo ' (Signed) "CjQvJJ^^ ^sS^r^ L. MM N D te tW«U O lite ) 10^ WC om n e i»t rou oomot- L R « Date i'jygP^gp// Geolog.st..^.r2z££^ Property >/gs^ MILL project County SAMltttfJ state i^r/t// OriHing Co a»t>z/rs &iPcoetir,iL> A.. Unit No Sec a 25 u 2?S 30o 32.5-1- ^ H. i2T i2S- t>7v «^ • ^ C - 725- .<4 /J -v. -'_ 4il& 4L2JL. 4l&2&_ flL^ iris. JL. 3h ah. .Sii. Hole Mrtl»>i Twp Rqe REMARKS fe5afti»c<. •Srti) wds ktsoi I i \io\ yWn^/a^^ 1^ e caMAA^Bppt^fo I w^tn iismiiiMeEii ~~~ — ^» — kul*. .pp^ —. — «^ ^ 1^ <^ lff»\ io. ±1. 11 4^ 4^ U^i<Jii_L!(!(J^^ I^A n(>^A 4 4^ Mi IVi, 1^ TD. PEKCENTASe COMPOSmON IMAGE Page 5 Attachment 2 Utah Department of Environmental Quality Division of Dnnking Water Monitonng Schedule for Well WW 2 and Public Water System Histoncal IPS Report Page 6 Monitoring Schedule for Well WW 2 Utah Department of Environmental Quality Division of Drinking Water Monitoring Schedule Run Date 02/01/2012 03 02 pm PWS ID UTAH19026 Wame WHITE MESA MILL Legal Contact WHITE MESA MILL DAVID E TURK Address 6425 S HWY 191 BLANDING UT 84511 Phone Number City Served (Area) County SAN JUAN COUNTY Rating Approved Rating Date 11/24/1997 Activity Status Active Gal/Day Gal/Mm System Type Non Transient Activity Status Cd Active Population 95 Lasf Inv Update 07/28/2010 Last Snty Srv Dt 11/24/2009 Surveyor RICK MEYER Oper Period 1/1 to 12/31 Avg Daily Prod Total Dsgn Cap Total Emerg Cap Total Coliform Rule Monitonng Sample Count Sample Type Sample Frequency Effective Begin Date Effective End Date Seasonal Start Seasonal End Analyte Name Routine Quarterly 01/01/2010 1/1 12/31 COLIFORM (TCR) Additional Monitoring RegUirementS CrheSampI Label snotcxwrectfo OsnfectionByproducts TOC TOCAIkalnrty a danytnggeredgroundwate sample ) Last Sample Facility ••iCFacility Name Analyte Name Sample Sample Count Type Sample Frequency Next Sample Between DSOOl UTAHI 9025 DISTRIBUTION SYSTEM Lead & Copper Activity Status A Sample Label UTAHI 9025 DS001 Routine 3 Years 2008 06/01-09/30 2011 WS002 #2 WELL NITRATE Inorg & Metals Sodium Sulfate TDS Volatile Organics Activity Status A Sample Label UTAHI9025 WS002 WS002 Routine Year 06/02/2011 01/01/2012 12/31/2012 Routine 3 Years 06/15/2010 01/01/2011 12/31/2013 Routine 3 Years 06/15/2010 01/01/2011 12/31/2013 Routine Year 06/02/2011 01/01/2012 12/31/2012 Page 1 of 1 02/01/2012 Page 7 Public Water System Historical IPS Report •1 ^' Utah Department of Environmental Quality Division of Drinking Water Public Water System Historical IPS Report UTAH19025 WHITE MESA MILL Run Date 02/06/2012 02 47 pm PWS ID UTAHI 9025 Name WHITE MESA MILL Legal Contact WHITE MESA MILL DAVID E TURK Address 6425 S HWY 191 BLANDING UT 84511 Phone Number City Served (Area) County SAN JUAN COUNTY Rating Approved Rating Date 11/24/1997 Activity Status Active Gal/Day Gal/Min System Type Non Transient Activity Status Cd Active Population 95 Total IPS Points 239 Last Inv Update 07/28/2010 Last Snty Srv Dt 11/24/2009 Surveyor RICK MEYER Oper Penod 1/1 to 12/31 Rating Date 11/24/1997 >^vg Daily Prod Total Dsgn Cap Total Emerg Cap Rating Approved Admin & Physical Facilities Qualtiy & Monitonng Violations Operator Certification -6 255 10 Total Admin & Physical Facilities dement points may not agree with the detail section The detail section shows all open physical deficiencies the Total Admin & Physical Facilities value adjusts for duplicate deficiencies Physical Facility, Administrative, & Source Protection Deficiencies from Site Visits Facility Code * Descnpition " . * _ 0042 REG -I3RE>IYDRA^ USE POUCY INADEQUATE DSOOl UTAH19025 DISTRIBUTION SYSTEM Activity Date Date Point Not Point Status Seventy Determined Resolved Effective Effective 11/24/2009 Code DeiKnption . . ^ r . " , mOO^ OtBFiNANCIAt^WGMn-^tAN THE SYSTEM HAS A CURRENT FINANCIAL MANAGEMENT PLAN Cocte. Desoiiiptioii^'^;>_ ' " ^'^ ' MODI CURREI^^ r THE SYSTEM HAS A CURRENT EMERGENCY RESPONSE PROGRAM Code^ Oesonption i 8002 WEIX HOUSE NOTBECURE WS001 #1 WELL EMAIL FROM DIVID TURK JHO Codfr J)esa1fi^n ^ SOiS^ WE4±tjliCKSAiMEANSTaiyiEASUI^ WS002112 WELL 01/28/2003 01/28/2003 10 11/24/2009 11/24/2009 20 Page 1 of 2 02/06/2012 Utah Department of Environmental Quality Division of Drinking Water Public Water System Historical IPS Report UTAH19025 WHITE MESA MILL Run Date 02/06/2012 02 47 pm Physical Facility, Administrative, & Source Protection Deficiencies from Site Visits Facility Code Descnption S026 NO FLOW MEASURING DEVICE ONDISCHARGE PIPING WS0021t2WELL UPDATED IPS REPORT SUBMITTED BY RICK MEYER FOLLOWING 2009 SANITARY SURVEY JHO Code Descripfion TD60 CL2 STORAGE OR DAY TANKS NOT PROPERLY VENTED 7P002 CHLORINATOR Activity Date Date Point Not Point Status Seventy Determined Resolved Effective Effective 06/28/1999 11/24/2009 Total Admin & Physical Faciity Deficiency Pts Microbial Rule Violations Determin Date Complaince Penod Code Violation Type IPS Points Assessed 10/31/1997 9/1/97 9/30/97 25 MONITORING (TCR) REPEAT MAJOR 40 10/30/1998 7/1/98 9/30/98 23 MONITORING (TCR) ROUTINE MAJOR 35 10/28/1999 7/1/99 9/30/99 23 MONITORING (TCR) ROUTINE MAJOR 35 09/30/2002 7/1/02 9/30/02 23 MONITORING (TCR) ROUTINE MAJOR 35 12/31/2003 10/1/03 12/31/03 23 MONITORING (TCR) ROUTINE MAJOR 35 02/14/2006 10/1/05 12/31/05 22 MCL (TCR) MONTHLY 40 02/08/2010 12/1/09 12/31/09 23 MONITORING (TCR) ROUTINE MAJOR 35 Total Microbial Violation Pts 255 Operator Certification Points Distribution Level Required SS Highest Certificate on Record Dl Treatment Points 10 Total Points 10 Enforcement Actions Descnption Determination Date Status Code Status Date SFJ ST FORMAL NOV ISSUED SFJ ST FORMAL NOV ISSUED 10/28/1999 10/30/1998 10/28/1999 10/30/1998 Page 2 of 2 02/06/2012