DRC-2013-002247 - 0901a0688037d1d9

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA PDF AND FEDEX
May 10,2013
Rusty Lundberg,
Director, Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
M DRC-2013-002247' M
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a)
Dear Mr. Lundberg:
The White Mesa Mill (the "Mill") performed first quarter ("Ql") groundwater monitoring during the
period from January 1, to March 31, 2013 under the August 24, 2012 version of the Mill's Groundwater
Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were
received during the period ending April 10, 2013.
Pursuant to Part I.G.I.a) of the GWDP, (August 24, 2012) please take notice that the concentrations of
specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this
quarter in the attached Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been
formatted to simplify the tracking of any continued exceedances from one monitoring period to the next
by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in
color and bold italics).
Part I.G.I c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to
the Executive Secretary a plan and a 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 reestablished." The summary below relating to Ql 2013 exceedances
includes, for each exceedance, a brief discussion of whether such a plan and schedule is or is not required
or appropriate at this time in light of other actions currently being undertaken by Energy Fuels Resources
(USA) Inc. ("EFRI") or in light of other reports submitted by EFRI, as determined by Division of
Radiation Control ("DRC") Staff. A description of the other actions and reports which have affected the
requirement to submit a plan and time schedule are as follows:
1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing
investigations at the Mill. Based on the results of the previous investigations, EFRI and the
Director acknowledge that it has not been possible to date to determine the source(s), cause(s),
attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride
in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate
+ nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the
activities associated with the CAP are on-going. Based on information provided by DRC in
Letter to Mr Rusty Lundberg
May 10, 2013
Page 2
teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30-
day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances
at this time.
2. As discussed in previous quarterly groundwater sampling reports, the background levels and
GWCLs for pH were established based on eight or more quarters of laboratory data, which are
historically higher than field data. EFRI's letter to the Director dated January 31, 2011 proposed
the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by
EFRI's geochemical consultant, INTERA, Inc., EFRI compared the Mill's groundwater pH data
from Q2 2011 and noted that all of the June 2011 groundwater results, and many of the other
results from Q2, were already outside the revised GWCLs that were to be proposed in the June
30, 2011 letter. Pursuant to teleconferences with DRC on December 5, and December 19, 2011,
EFRI submitted a Work Plan and Schedule on January 20, 2012 and a revised plan based on DRC
comments on April 13, 2012. Based on the approved Work Plan and Time Schedule, EFRI and
DRC entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. The SCA
required the completion of the pH Report and the Pyrite Investigation and associated report. The
pH Report and Pyrite Investigation Report were submitted November 9, 2012 and December 7,
2012 respectively. By letter dated April 25, 2013, DRC accepted the conclusions that the out-of-
compliance results for pH are due to background effects within the aquifer matrix and are not
caused by Mill activities. DRC also approved the recalculation of the GWCLs. As a result, the
30-day plan and schedule for assessment is not required for field pH exceedances.
3. A Plan and Time Schedule will not be prepared for monitoring wells with two successive
exceedances in Ql 2013 if successive exceedances were reported in a previous quarter and were
included in the Source Assessment Report ("SAR"), submitted October 10, 2012. A Plan and
Time Schedule will not be submitted for those constituents covered by the October 10, 2012
SAR, because the conclusions and actions delineated in that report were accepted by DRC as
documented in DRC correspondence dated April 25, 2013.
4. A Plan and Time Schedule for the constituent covered by the May 8, 2013 SAR (Total Dissolved
Solids ["TDS"] in MW-29) will not be submitted because the assessment processes and
conclusions have not changed since submission of the May 8, 2013 SAR.
5. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program
and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective
Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket
No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and
methylene chloride exceedances is not required.
It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to
reflect background groundwater quality, as defined by the mean plus second standard deviation
concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each
monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that,
because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-
impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the
time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not
necessarily represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a
given analyte will increase the number of exceedances due to statistical variation and not due to Mill
activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a
monthly frequency can result in resampling of essentially the same water and can lead to repeat
Wf ENBXSYFVn
Letter to Mr Rusty Lundberg
May 10, 2013
Page 3
exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same
water.
1.0 Exceedances in Required Quarterly Sampling Wells
1.1 Quarterly Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods in Ql 2013. The 30-day plan and schedule contemplated in Part I.G.I c)
ofthe GWDP will not be required for the consecutive exceedance of tetrahydrofuran ("THF") in MW-1
as discussed below. The 30-day plan and schedule contemplated in Part I.G.I c) for the remainder of the
consecutive exceedances which occurred in Ql of 2013, will not be required for the reasons stated below.
One-time exceedances and non-successive exceedances are noted on Table 1, but not listed below.
Consecutive exceedances which occurred in previous reporting periods are discussed in the SARs
submitted to DRC on October 10,2012 and May 8, 2013.
MW-11
• Manganese concentrations exceeded the GWCL in MW-11 in the Ql 2013 and March monthly
sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
MW-26
• Nitrate + nitrite has exceeded its GWCL in all of the Ql 2013 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• Chloroform has exceeded its GWCL for all of the monitoring periods for Ql 2013. MW-26 is
used as a pumping well for the ongoing chloroform capture program and is expected to yield
increased concentrations of chloroform. Because this well is used in the chloroform capture
program which is the subject of separate investigations and actions, a plan and time schedule to
address the consecutive exceedances is not necessary and is not being submitted.
• Methylene chloride has exceeded its GWCL in all of the Ql 2013 monitoring periods. MW-26 is
used as a pumping well for the ongoing chloroform capture program and is expected to yield
increased concentrations of methylene chloride. Because this well is used in the chloroform
capture program which is the subject of separate investigations and actions, a plan and time
schedule to address the consecutive exceedances is not necessary and is not being submitted.
• Field pH has been slightly outside (slightly lower than) the GWCL in all of the Ql 2013
monitoring periods. As mentioned above, site-wide pH issues and trends are addressed in reports
submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012
report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
me
Letter to Mr Rusty Lundberg
May 10, 2013
Page 4
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January
20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for
chloroform removal, concentrations of all constituents in that well are subject to potential variation over
time as a result of the pumping activity. This will be taken into account by the Executive Secretary in
determining compliance for this well." Based on information provided by DRC in teleconferences on
April 27, and May 2, 2011, due to the current pumping status as part of the chloroform investigation
program, the 30-day plan and schedule for assessment is not required at this time for exceedances of
chloroform and methylene chloride in MW-26.
• The uranium concentration exceeded its GWCL in all of the Ql 2013 monitoring periods. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result ofthe SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
• The chloride concentration exceeded its GWCL in all of the monitoring periods for Ql 2013. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
MW-30
• Nitrate + nitrite has exceeded its GWCL in all of the Ql 2013 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The selenium concentration exceeded its GWCL in all of the Ql 2013 sampling events. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result ofthe SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
MW-31
• Nitrate + nitrite has exceeded its GWCL in all of the Ql 2013 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL in all of the monitoring periods for Ql 2013. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
mc
Letter to Mr Rusty Lundberg
May 10, 2013
Page 5
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
• The sulfate concentration exceeded its GWCL in all sampling events during Ql 2013. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result ofthe SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
• The selenium concentration exceeded its GWCL in the Ql and March monthly sampling events.
A Plan and Time Schedule for this consecutive exceedance was submitted on March 14, 2013.
Upon DRC approval, EFRI will implement the requirements of the Plan and Time Schedule. No
other plan is necessary at this time.
• TDS concentration exceeded its GWCL in Ql and March monthly sampling events. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result ofthe SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
MW-35
• The manganese concentration exceeded the GWCL in MW-35 in all of the Ql sampling events. A
plan and schedule to address the Ql exceedances is not necessary and is not being submitted
because, as discussed in the October 10, 2013 SAR, background has not yet been established for
MW-35 and the interim GWCLs for MW-35 have been set at a fraction of the Groundwater
Quality Standards pending the determination of background. The background report for MW-35
is scheduled to be submitted after the second quarter 2013 pending the collection of 8 statistically
valid data points for each constituent. Exceedances of the interim GWCLs do not necessarily
represent impacts to groundwater from Mill activities.
• The uranium concentration exceeded the GWCL in MW-35 in all of the Ql sampling events. A
plan and schedule to address the Ql exceedances is not necessary and is not being submitted
because, as discussed in the October 10, 2013 SAR, background has not yet been established for
MW-35 and the interim GWCLs for MW-35 have been set at a fraction of the Groundwater
Quality Standards pending the determination of background. The background report for MW-35
is scheduled to be submitted after the second quarter 2013 pending the collection of 8 statistically
valid data points for each constituent. Exceedances of the interim GWCLs do not necessarily
represent impacts to groundwater from Mill activities.
• The Gross Alpha concentration exceeded the GWCL in MW-35 in all of the Ql sampling events.
A plan and schedule to address the Ql exceedances is not necessary and is not being submitted
because, as discussed in the October 10, 2013 SAR, background has not yet been established for
MW-35 and the interim GWCLs for MW-35 have been set at a fraction of the Groundwater
Quality Standards pending the determination of background. The background report for MW-35
Letter to Mr Rusty Lundberg
May 10, 2013
Page 6
is scheduled to be submitted after the second quarter 2013 pending the collection of 8 statistically
valid data points for each constituent. Exceedances of the interim GWCLs do not necessarily
represent impacts to groundwater from Mill activities.
1.2 Quarterly Wells with New Exceedances Reported in Ql
Two new exceedances for the Ql 2013 quarterly well sampling program are listed below. These
exceedances will result in an accelerated sampling frequency from quarterly to monthly. It is important to
note that the wells listed below will only be sampled during the monthly events for those constituents
which exceeded the GWCLs. The well listed below will be sampled for all constituents listed in the
GWDP during the quarterly events as that is the regularly scheduled sampling for the quarterly wells.
• Chloride in MW-25 exceeded the GWCL in the Ql sampling event.
• Uranium in MW-30 exceeded the GWCL in the Ql sampling event.
Relative to accelerated reporting requirements, based on phone conversations with DRC on April 5, 2010,
reporting of exceedances is required to be completed within 30 days of receipt ofthe last data package for
a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the month
following the submission of the Exceedance Notice for a specified quarter for wells that are being
accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice
for wells that are being accelerated from semiannually to quarterly. Per teleconferences with DRC, EFRI
proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DRC concurrence
with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 teleconference.
2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly
2.1 Semi-annual Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods (Q4 2012 and Ql 2013).
MW-1
• THF has exceeded the GWCL for both the Q4 2012 sampling event and the Ql 2013 sampling
event. In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far
upgradient wells (MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill
activities. In correspondence dated April 25, 2013, DRC noted "DRC agrees with the
justification provided by EFR, that far upgradient wells are not likely to be impacted by current
Mill activities..." and has recommended the removal of GWCLs for MW-1 from the next
revision of the GWDP. A plan and schedule is not necessary because the exceedance is not
caused by Mill activities. Until such time as the GWCLs are removed, the exceedances will
continue to be noted and reported.
MW-3
• Selenium has exceeded the GWCL for both the Q4 2012 sampling event and the Ql 2013
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
ENERGY FUELS
Letter to Mr. Rusty Lundberg
May 10, 2013
Page 7
• Fluoride has exceeded the GWCL for both the Q4 2012 sampling event and the Ql 2013
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
MW-18
• Thallium has exceeded the GWCL for both the Q4 2012 sampling event and the Ql 2013
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells
(MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In
correspondence dated April 25, 2013, DRC noted "DRC agrees with the justification provided by
EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has
recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan
and schedule is not necessary because the exceedance is not caused by Mill activities. Until such
time as the GWCLs are removed, the exceedances will continue to be noted and reported.
MW-19
• Nitrate + Nitrite have exceeded the GWCL for both the Q4 2012 sampling event and the Q1 2013
sampling event and during previous quarters. As mentioned above, a CAP has been submitted and
approved and the specified actions are currently being implemented; therefore a plan to address
this consecutive exceedance is not necessary and is not being submitted.
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2012 sampling
event and the Ql 2013 sampling event. In the October 10, 2012 SAR, EFRI requested the
removal of GWCLs for the far upgradient wells (MW-1, MW-18, and MW-19) at the Mill which
cannot be impacted by Mill activities. In correspondence dated April 25, 2013, DRC noted "DRC
agrees with the justification provided by EFR, that far upgradient wells are not likely to be
impacted by current Mill activities..." and has recommended the removal of GWCLs for MW-19
from the next revision of the GWDP. A plan and schedule is not necessary because the
exceedance is not caused by Mill activities. Until such time as the GWCLs are removed, the
exceedances will continue to be noted and reported.
MW-24
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2012 sampling
event and the Ql 2013 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result ofthe
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
wlfie
Letter to Mr Rusty Lundberg
May 10, 2013
Page 8
MW-27
• Nitrate + Nitrite have exceeded the GWCL for both the Q4 2012 sampling event and the Q1 2013
sampling event and during previous quarters. As mentioned above, a CAP has been submitted and
approved and the specified actions are currently being implemented; therefore a plan to address
this consecutive exceedance is not necessary and is not being submitted.
• The chloride concentration exceeded its GWCL for both the Q4 2012 sampling event and the Ql
2013 sampling event and during previous quarters. As mentioned above, a CAP has been
submitted and approved to address nitrate+nitrite contamination which is expected to address
chloride in groundwater. The actions specified in the CAP are currently being implemented;
therefore a plan to address this consecutive exceedance is not necessary and is not being
submitted.
MW-28
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2012 sampling
event and the Ql 2013 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• The chloride concentration exceeded its GWCL for both the Q4 2012 sampling event and the Ql
2013 sampling event. As mentioned above, a CAP has been submitted and approved to address
nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions
specified in the CAP are currently being implemented; therefore a plan to address this
consecutive exceedance is not necessary and is not being submitted.
MW-29
• TDS has exceeded the GWCL for both the Q4 2012 sampling event and the Ql 2013 sampling
event. A plan and schedule for assessment was submitted under separate cover on December 13,
2012. Approval of the plan and time schedule was received from DRC in a letter dated February
4, 2013 and received by EFRI on February 7, 2013. A SAR was submitted on May 8, 2013;
therefore a plan and schedule to address this consecutive exceedance is not necessary and is not
being submitted.
2.1 Semi-annual Wells with New Exceedances Reported in Ql
There were no new exceedances for the semi-annual well sampling program.
ENERGYFUELS
Letter to Mr. Rusty Lundberg
May 10, 2013
Page 9
If you have any questions or require any further information, please contact the undersigned.
Yours truly, -
JO Ann Tischler
Manager, Compliance and Licensing
cc: David Frydenlund
Harold Roberts
David Turk
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