DRC-2013-002911 - 0901a068803ae4dc

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
_ on^ r\ nnogi 1" 303 974 2140
"DRC"^vJ I J'UUt^ www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
July 29, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
JUL 0>
CO c4
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Re: Utah Groundwater Discharge Permit ("GWDP") UGW370004
Follow-up and response to February 14,2013 Confirmatory Action Letter
Dear Mr. Lundberg:
Energy Fuels Resources (USA) Inc. ("EFRI") has prepared this letter to the Utah Division of Radiation
Control ("DRC") to document our actions to date and discussions with DRC regarding the four
additional wells installed in 2013 for investigation of nitrate in the chloroform monitoring wells TW4-12
andTW4-27.
Completed Actions
As discussed in our telephone conference with Phil Goble and Dean Henderson of DRC on July 25,
2013, EFRI has completed the following steps consistent with the requirements in the above-named
Confirmatory Action Letter ("CAL"):
1. Nitrate contamination investigation was conducted at wells TW4-12 and TW4-27.
2. EFRI installed one well downgradient of TW4-12 and three wells downgradient and cross-
gradient ofTW4-27.
3. EFRI provided the locations of these wells to DRC by February 7, 2013.
4. EFRI performed initial sampling of the four new wells (TW4-28, TW4-29, TW4-30, and TW4-
31) during the 2nd quarter of 2013.
In addition, EFRI:
1. Constructed the new wells in accordance with Part I.E.4 of the GWDP.
2. Submitted the As-Built report for the four new wells.
3. Is conducting ongoing sampling in conformance with the Groundwater Quality Assurance Plan
("QAP").
4. Sampled the four new wells for the parameters in Appendix A of the QAP.
N:\WMM\Well Drilling permits installation reports surveys repairs\TW4-32, 33, 34\07.31.12 chloroform Itr to R
Lundberg.doc
Letter to Rusty Lundberg
July 29, 2013
Page 2 of 3
Initial Findings
The second quarter 2013 monitoring of the four new wells indicated that:
Nitrate results in TW4-29, TW4-30, and TW4-31, of 4.63, 0.948 and 1.26 mg/L, respectively were all
below the standard of 10 mg/L. However, TW4-29 had a chloroform result of 242 ug/L. A repeat
sampling of the well for confirmation produced a result of 262 ug/L, indicting that the chloroform
contamination does not appear to be bounded in the vicinity of TW4-29.
The nitrate result in TW4-28 of 14.9 mg/L was above the nitrate standard of 10 mg/L, indicating that
nitrate contamination is not bounded downgradient (southeast) of TW4-28.
Proposed Action
After reviewing the results with our hydrogeological consultant, HydroGeoChem, our consultant
recommended that EFRI add one additional monitoring well in the vicinity of TW4-28 and two
additional monitoring wells in the vicinity of TW4-29. The proposed locations of the three new wells
are indicated in the attached Figure 1. The additional well proposed in the vicinity of TW4-28 will be
located southeast (downgradient) of TW4-28 in an effort to bound the nitrate contamination in this area.
As EFRI and HydrGeoChem discussed with Mr. Goble and Mr. Henderson, EFRI proposes that one of
the two new wells in the vicinity of TW4-29 be installed in a location suited to bound the chloroform
contamination to the south. EFRI also proposes the second well in this area be installed between TW4-
04 and TW4-29. As discussed during the phone conference, chloroform contamination appears to be
migrating from TW4-04 in a more southerly direction than would be expected based on the hydraulic
gradient alone which is primarily eastward from TW4-4 to TW4-14. However, because of the very low
perched zone permeability in the vicinity of TW4-14 and TW4-27, chloroform that would be expected to
travel primarily eastward from TW4-04 towards TW4-14 may be migrating in a more southerly
direction toward TW4-29. The more southerly direction of migration is reasonable considering that the
general direction of perched groundwater flow in this portion of the site to the south notwithstanding
local variations in hydraulic gradient that are most likely the result of the permeability distribution and
long-term water level rise in this area. TW4-14 and TW4-27 appear to be water level 'sinks' primarily
because water levels at these wells are rising more slowly than in surrounding wells due to the lower
permeability at these wells. The additional well proposed between TW4-4 and TW4-29 is expected to
clarify whether or not chloroform reached TW4-29 via a flow path from TW4-04.
Letter to Rusty Lundberg
July 29, 2013
Page 3 of 3
The schedule for the installation of the proposed three new wells is as follows:
Installation Schedule for Additional Monitoring Wells
Step or Action Date
Complete Request for non-Production Well Construction and submit
to Utah Division of Water Rights 8/5/2013
Drill Cards received 8/12/2013
Drill/install monitoring wells Week of 9/9/2013*
Commence surging and bailing new monitor wells for development Week of 9/16/2013*
Overpump new monitor wells for development Prior to Q4 2013 sampling
Slug test new monitoring wells Prior to Q4 2013 sampling
Collect samples from new monitoring wells Prior to the end of Q4 2013
Complete as-built report for new monitoring wells Within 60 days of installation
* Weather permitting
Also, as agreed to by Mr. Goble and Mr. Henderson, it is premature to prepare a Contamination
Investigation Report ("CIR") based on current information only. The current proposed delivery date in
the CAL is 60 days following receipt of the current data (or August 31, 2013). As we discussed, EFRI
believes it is necessary to collect hydraulic and contaminant concentration data from the proposed three
new wells in order to understand the dynamics of the chloroform contamination in the vicinity of TW4-
29. As we agreed with DRC, EFRI will perform the steps in the above-listed schedule in order to
provide a CIR within 60 calendar days after receipt of analytical data from the three proposed new wells.
Please contact me to indicate your concurrence with this plan or if you have any questions on this
proposed approach.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, Utah DRC
Dean Henderson, Utah DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
TW4 5b 95 o
TWN 01
05592 PiEZ-03
Q /
TW4 21
O
/ T 18
O 85 W4 22 O TW O 572 4-2 O TW4 / 055
\ o
••••>... • •••• • TW4-09
O / M 26 TW4-12
O 4-10 TW4-03
O Nn
564
W4-28
TW4 TW4 TW4 O 6^ 6 TW4-02\
^—O" - •
-MW-04 50 MWX31 TW4 QTW4-08
T 01 5545 MW-32
cm o
5540 TW4*04
w D ^535
TW4-06
Q \TW4J27 ^
TW4-23
055'
30 M 25 rO W4-26 TW4H29 &JW4-30 <^
* \ -—-
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ft 0 ^
feet
PIEZ-04
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\
EXPLANATION
proposed new temporary
perched monitoring well
MW-4 . . #5550 Percnecl monitoring well showing
elevation in feet amsl
TW4-1 n RRRA temP°rary perched monitoring well
showing elevation in feet amsl
PlEZ-2 perched piezometer showing
© 5597 elevation in feet amsl
TW4-28 temporary perched monitoring well
& 5580 installed March, 2013 showing
elevation in feet amsl
NOTE: MW-4, MW-26, TW4-4, TW4-19, and TW4-20 are chloroform pumping wells;
TW4-22, TW4-24, TW4-25, and TWN-2 are nitrate pumping wells
HYDRO
GEO
CHEM, INC.
KRIGED 2nd QUARTER, 2013 WATER LEVELS
AND PROPOSED NEW PERCHED WELLS
WHITE MESA SITE
(detail map)
REFERENCE H:/718000/nitrateast/
round2/prop2013r2.srf