DRC-2013-003780 - 0901a068803ee8cb

DRC-2013-003780 Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 ENERGYFUELS
www.energyfuels.com
Mr. Rusty Lundberg
Director
Division of Radiation Control
December 17, 2013
Sent VIA E-MAIL and OVERNIGHT DELIVERY
Utah Department of Environmental Quality ^£7? t r o 1
195 North 1950 West ^
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Transmittal of Source Assessment and Literature Search Report, Tetrahydrofuran in MW-01
White Mesa Mill Groundwater Discharge Permit UGW370004
Conditional Approval of September 17,2013 Plan and Time Schedule
Dear Mr. Lundberg:
Enclosed are two copies of Energy Fuels Resource (USA) Inc.'s ("EFRI's") Source Assessment and Literature
Search Report for Tetrahydrofuran ('THF') in MW-01 at the White Mesa Mill. THF in MW-01 exceeded its
Groundwater Compliance Limit ("GWCL") in the fourth quarter of 20i2 and first quarter of 2013. As required
by Part I.G.4(d) of the Groundwater Discharge Permit ("GWDP"), EFRI submitted a Plan and Time Schedule
for the assessment of THF in MW-01 on August 27, 2013. Conditional approval of the Plan and Time Schedule
was received by EFRI on September 17, 2013. Pursuant to the Plan and Time Schedule, EFRI has prepared this
Source Assessment and Literature Search Report.
This transmittal also includes two CDs each containing a word searchable electronic copy of the report.
If you should have any questions regarding this report please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Harold R. Roberts
David E. Turk
Jo Ann Tischler
SOURCE ASSESSMENT AND LITERATURE
SEARCH REPORT
FOR TETRAHYDROFURAN IN MW-01
WHITE MESA URANIUM MILL
Blanding, Utah
Prepared by:
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
December 17, 2013
EXECUTIVE SUMMARY
This report is an assessment and an investigation of the potential source for tetrahydrofuran
("THF") in MW-01 at the White Mesa Mill, which has exhibited two consecutive exceedances of
the applicable Groundwater Compliance Limit ("GWCL"). This report provides documentation
from published studies and papers that indicate that THF is persistent over many years in
monitoring wells due to solvents and adhesives used for well construction.
Water level and elevation data indicate that the perched groundwater elevation in MW-01 is
approximately 9 feet higher than perched groundwater elevations beneath the Mill's Tailings Cells
and therefore MW-01 cannot be impacted by Mill activities. Additionally, MW-01 is more than
2,200 feet (0.4 miles) upgradient of the Mill facilities. THF concentrations which exceed the
GWCL are likely the result of well construction practices in older monitoring wells that used
adhesives and glues to join the casings.
Several US Environmental Protection Agency ("EPA"), United States Geological Survey
("USGS") and consultant studies have produced data which indicate that THF in older wells is the
result of construction practices. THF has never been used as a reagent, solvent or additive to the
Mill's processes but is found as an additive in kerosene, which is used in the Mill's solvent
extraction circuit. THF is therefore expected to be a constituent in the Mill's tailings system and
tailings wastewater analyses have confirmed that it is present in the tailings system. However, its
presence in tailings does not explain the detection of THF in wells as far up-gradient as MW-01.
As previously stated MW-01 is far upgradient and cannot have been impacted by Mill activities.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah ES-i December 17, 2013
TABLE OF CONTENTS
EXECUTIVE SUMMARY i
ABBREVIATIONS AND ACRONYMS ii
1.0 INTRODUCTION 1
1.1 Source Assessment Report Organization 2
2.0 CATEGORIES AND APPROACH FOR ANALYSIS 3
2.1 Approach for Analysis 3
2.2 Prior Studies and Correspondence 3
3.0 RESULTS OF LITERATURE SURVEY 6
4.0 CONCLUSIONS AND RECOMMENDATIONS 9
5.0 REFERENCES 12
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah i December 17,2013
ABBREVIATIONS AND ACRONYMS
Director Director of the Division of Radiation Control
DRC State of Utah Division of Radiation Control
EFRI Energy Fuels Resources (USA) Inc.
GAMA Groundwater Ambient Monitoring and Assessment
GWCL Groundwater Compliance Limit
GWDP State of Utah Ground Water Discharge Permit UGW370004
GWQS Groundwater Quality Standard
Ug/L micrograms per liter
mg/L milligrams per liter
Mill White Mesa Uranium Mill
Notice Notice of Violation and Compliance Order, Docket No.UGWll-02
NTIS National technical Information Service
PVC polyvinyl chloride
SAR Source Assessment Report
SRLs Study reporting levels
THF Tetrahydrofuran
USEPA United States Environmental Protection Agency
USGS United States Geological Survey
VOC volatile organic compound
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah ii December 17, 2013
1.0 INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the
"Mill"), located near Blanding, Utah under State of Utah Groundwater Discharge Permit
UGW370004 (the "GWDP"). This is the Source Assessment Report ("SAR") required under Part
I.G.4 of the GWDP relating to violations of Part I.G.2 of the GWDP with respect to
tetrahydrofuran ("THF") in groundwater compliance monitoring well MW-01.
Part I.G.2 of the GWDP provides that out-of-compliance status exists when the concentration of
a constituent in two consecutive samples from a compliance monitoring point exceeds a
groundwater compliance limit ("GWCL") in Table 2 of the GWDP. The GWDP was originally
issued in March 2005, at which time GWCLs were set on an interim basis, based on fractions of
State of Utah Ground Water Quality Standards ("GWQSs") or the equivalent, without reference
to natural background at the Mill site. The GWDP also required that EFRI prepare a background
groundwater quality report to evaluate all historical data for the purposes of establishing
background groundwater quality at the site and developing GWCLs under the GWDP. As
required by then Part I.H.3 of the GWDP, EFRI submitted the following to the Director (the
"Director") of the Utah Division of Radiation Control ("DRC") (the Director was formerly the
Executive Secretary of the Utah Radiation Control Board and the Co-Executive Secretary of the
Utah Water Quality Board):
• A Revised Background Groundwater Quality Report: Existing Wells for Denison Mines
(USA) Corp.'s Mill Site, San Juan County, Utah, October 2007, prepared by INTERA,
Inc. (the "Existing Wells Background Report").
• A Revised Addendum: Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells for Denison
Mines (USA) Corp.'s Mill Site, San Juan County, Utah, November 16, 2007, prepared by
INTERA, Inc. (the "Regional Background Report").
• A Revised Addendum: Background Groundwater Quality Report: New Wells for
Denison Mines (USA) Corp.'s Mill Site, San Juan County, Utah, April 30, 2008,
prepared by INTERA, Inc. (the "New Wells Background Report," and together with the
"Existing Wells Background Report" and the "Regional Background Report," the
"Background Reports").
Based on a review of the Background Reports and other information and analyses, the Director
re-opened the GWDP and modified the GWCLs to be equal to the mean concentration plus two
standard deviations or the equivalent. The modified GWCLs became effective on January 20,
2010.
In the October 10, 2012 SAR for multiple wells at the Mill site, EFRI recommended that
GWCLs be removed from up-gradient wells MW-01, MW-18, and MW-19. EFRI reiterated in
the SAR that MW-01, MW-18, and MW-19 are far upgradient from the Mill site and cannot be
impacted by Mill activities, therefore it is not appropriate to establish compliance monitoring
standards under the GWDP for those wells.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 1 December 17, 2013
In a letter of April 25, 2013, DRC concurred with EFRFs determination that constituents in those
wells were not from Mill sources, and that GWCLs in those wells could be removed. Per
discussion with DRC in July 2013, DRC planned to remove the GWCLs from the up-gradient
wells in an interim revision of the GWDP.
The identification of two successive exceedances of the THF GWCL of 11.5 ug/L in MW-01
occurred in fourth quarter 2012 and first quarter 2013, after EFRI's assessment, and DRC's
concurrence that, the GWCLs should be removed from MW-01, and before any revised GWDP
had been published.
The Director issued a Notice of Violation and Compliance Order, Docket No. UGW 13-05 (the
"Notice"), dated July 23, 2013, based on the State of Utah Department of Environmental Quality
("UDEQ"), DRC findings from the review of the Mill's 1st quarter 2013 Groundwater
Monitoring Report. The Notice cited one violation of the Permit under Part I.G.4 of the Permit
for failing to provide to the Director a Plan and Time Schedule for assessment of the source(s),
extent, and potential dispersion of the monitoring well MW-01 THF contamination.
Section E.2 (d) of the Notice ordered EFRI to prepare and submit within 30 calendar days of
receipt of the Notice, a written plan and time schedule for assessment of THF out-of-compliance
status at monitoring well MW-01 in compliance with the Permit Part I.G.4.C. In response to the
Notice, EFRI submitted a Plan and Time Schedule on August 27, 2013.
This SAR addresses THF in MW-01 as described in the DRC-approved August 27, 2013 Plan
and Time Schedule.
1.1 Source Assessment Report Organization
An overview of Sections 2.0 through 5.0 of this Report is provided below.
A description of the approach used for analysis is provided in Section 2.0, and the results of the
analysis are presented in Section 3.0. Conclusions and recommendations are provided in
Section 4.0, and references are included in Section 5.0.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 2 December 17, 2013
2.0 CATEGORIES AND APPROACH FOR ANALYSIS
Generally, out-of-compliance constituents and wells can be grouped into five categories:
1. Constituents in wells with previously identified rising trends.
2. Constituents in pumping wells.
3. Constituents potentially impacted by decreasing trends in pH across the site.
4. Newly installed wells with interim GWCLs.
5. Other constituents and wells.
This SAR addresses THF in MW-01 which falls into category five: other constituents.
2.1 Approach for Analysis
The first step in the analysis is to perform an investigation of the potential source of the
exceedance. EFRI will provide documentation from published studies and papers that indicate
that THF is persistent (over many years) in monitoring wells constructed using solvents and
adhesives. Section 2.2 recaps the history of prior studies and correspondence. Section 2.3
provides results of the literature review.
2.2 Prior Studies and Correspondence
THF is the most common solvent used for commercial Grignard reactions such as the Grignard
reaction used by refineries to produce alkane hydrocarbons for fuels, including kerosene and is
used as a solvent for PVC manufacture (US EPA 2012). Furans and alkoxymethyl furans are
known to be added as conditioners for anti-wear properties and freeze prevention in the
formulation of fuels, including kerosene, diesel and jet fuel. Therefore, although the Mill does
not use THF as a reagent or solvent in the Mill's process, the kerosene used in the Mill's
uranium and vanadium solvent extraction circuits likely contains THF residuals from the refinery
kerosene synthesis or blending process. The Mill's annual tailings characterization data since
approximately 2010 indicate it is present in the Mill's tailings system. Historic information on
chemical and reagent use in the Mill laboratories and circuits do not identify any other use of
THF on the Mill site. Used oils on site are controlled within lined secondary containment
systems consistent with the Mill's Stormwater Pollution Prevention Plan and are, if they contain
any THF, not a source of THF in groundwater.
However, as discussed in EFRI's letter of March 26, 2012 and subsequent correspondence, there
is no plausible scenario that would explain the presence of THF in a perched groundwater
monitoring well (completed in the Burro Canyon Formation) that is more than 2,200 feet (0.4
mile) up-gradient of the tailings system. Perched groundwater elevations in MW-01 are
approximately 9 feet higher than those beneath the upgradient portion of the tailings system,
precluding the possibility that perched groundwater could migrate from the tailings system to
MW-01. Since there is no other source of THF as a reagent, solvent or constituent/contaminant
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 3 December 17, 2013
of reagents or solvents at the Mill, there is no plausible way that Mill operations could release
THF into perched groundwater and that THF could subsequently migrate 2,200 feet up-gradient.
An October 2003 letter from the supervising hydrogeologist who installed the Mill's initial
monitoring wells MW-1 through MW-13, confirms that those wells were constructed of schedule
40 polyvinyl chloride ("PVC") pipe, utilizing the solvent and adhesive coupling method which
was standard practice during the period from 1979 to 1982 when these 13 wells were installed
This letter was provided to DRC as part of a submittal from EFRI on October 17, 2003 and is not
reproduced here. The wells constructed by this method include MW-01, addressed by this SAR
and Literature Review.
As discussed in detail in the literature review in Section 3, below, the most common solvents
used in adhesives or cements for PVC piping are ketones (2-butanone or "MEK", and methyl
isobutyl ketone ["MLBK"]), and THF. THF is used as a softener and carrier for the monomer
component of the glue which hardens and sets in air after application to the prepared pipe joint
surfaces.
THF has a Henry's Law Constant of 7.05E-5 atm m3/mole, very low compared to other ketones,
and most aromatic solvents, indicating that THF is not readily volatilized. As a result, any
solvent contained in the glue or cement applied to a PVC well pipe joint is not vaporized out of
the cement before hardening, and may remain trapped in the pores of the hardened cement. Due
to its solubility in water (up to 1,000,000 mg/L), it may leach from the cement over time as
changing water levels bring the joint into contact with formation water.
The 13 wells indicated above were constructed over a period of 4 years. A number of factors can
vary during the multiple construction dates and conditions under which these first 13 monitoring
wells were installed, specifically:
• Different installation personnel may have used widely differing amounts of adhesive.
• Solvent content of the adhesive may vary from batch to batch.
• Adhesive setting conditions (ambient temperature and humidity) vary the speed at which
the adhesive sets and therefore the quantity of THF and other solvents trapped in the
hardened cement.
Therefore, even wells constructed by the same technology may vary widely in their residual THF
concentration in the adhesive, and in subsequent water samples. As a result, some wells from
that time period may exhibit elevated THF levels in groundwater samples, while others do not.
In December of 2005, EFRI conducted a study of MW-02 to evaluate PVC cement as the source
of THF in a number of the Mill's older monitoring wells constructed with glued PVC. The study
results, submitted in a report on June 26, 2007 were inconclusive because:
a) the trip blank provided by the contract laboratory contained THF at 36 ug/L and
b) THF which was typically present at elevated levels in MW-02 was not detected in well
samples during that December 2005 test event.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 4 December 17, 2013
As discussed above, the presence or absence of THF in samples from any one sampling event
from any one well from the MW-01 to MW-13 series does not mean it was not present in the
well cements of that or any of the other wells in the series. As explained in Section 3.0 below,
given the study demonstrating persistent presence of THF in laboratory water following
installation of glued PVC plumbing (Wang and Brickner, 1979), and the widespread presence of
THF in quality control samples in the USGS Study (USGS 2012) the presence of THF in
laboratory-originated samples is also explainable and not unexpected.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 5 December 17, 2013
3.0 RESULTS OF LITERATURE SURVEY
As committed in the Plan and Time Schedule, EFRI has pursued a literature survey of research
and field studies by US EPA, USGS, and private organizations addressing water quality analyzed
in samples from wells constructed with PVC pipe cemented with adhesives and/or primers
known to contain THF. The results are enumerated below.
Soseby Laboratory Simlulation
(Soseby 1983) In hazardous and Solid Waste Testing (Soseby, 1983.) the authors state, regarding
wells constructed with PVC cements that:
"Standard well construction techniques may lead to the introduction of contaminants into
the groundwater and can lead to incorrect conclusions concerning water quality." With
respect to THF in PVC cements, they stated as a result of their laboratory trials with six
different PVC adhesives and one PVC primer that "PVC constituents added to the well
during construction can be quite tenacious." Every PVC adhesive or primer tested
leached THF. (Most of the adhesives also leached MIBK, MEK among other volatile
organic compounds ["VOCs"]).More importantly, the percent composition of the
organics remained remarkably constant with successive washes with distilled water,
intended to represent repeated well purging.
Other laboratory studies on cements used to join PVC pipe systems also showed leaching of
ketones and tetrahydrofuran (Wang and Brickner 1979) (US EPA 1982), demonstrating an
unexpected persistence of these solvents over time. The Wang and Brickner study was initiated
after high concentrations of 2-butanone and THF continued to be present at high concentrations
in laboratory supply water 6 months after installation of glued PVC laboratory water supply
piping. Samples taken at 6 months and 8 months, at multiple residence times, indicated that
MEK and THF concentrations increased with residence time over 48 hours to an equilibrium
concentration. The samples taken at 8 months had generally higher THF concentrations than
those at 6 months.
Martin and Lee Field Study on Frequently Pursed Wells at Waste Disposal Site
William Martin and C. Chow Lee (Martin and Lee, 1989) evaluated groundwater samples from
monitoring wells with glued PVC well casings, which were known to have extremely slow rates
of recharge, at a chemical waste management facility. The wells evaluated had undergone
repeated development and sampling over a seven year period. They repeatedly detected no THF
during well purging, but increasing THF levels over a period of 2 to 4 days after purging. They
concluded that:
"The further increase in THF concentration in 2 to 4 days after purging suggests that THF
may be rapidly diffusing from the PVC glued joints into fresh formation water entering
the well."
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 6 December 17, 2013
They found that after the initial increase, and 20 days ongoing purging, the THF concentrations
still remained somewhat higher than before the initiation of purging. They concluded that the
source of the THF was within the well casings.
U.S. Geological Survey Study for National Water-Quality Assessment
While developing protocols and standards of practice for the National Water-Quality Assessment
("NAWQA") Program, the USGS noted as early as 1995, that well materials, design and
installation can result in bias in analytical results for certain VOCs, which leach from PVC well
casing glues. These included THF, MEK, MU3K, and hexanone (USGS 1995).
U.S. Geological Survey Study Reporting Levels
For a six year study on over 2,000 groundwater quality control samples for the California Water
Resources Control Board (USGS 2012), the USGS determined that there is no concentration of
THF above which detection in groundwater represents "real" aquifer conditions, as discussed
below.
From May 2004 to September 2010, the USGS study attempted to develop Study Reporting
Levels (SRLs) for VOCs for the Groundwater Ambient Monitoring and Assessment (GAMA)
Program. For eighteen VOCs, including THF, regularly detected in field blanks or source-
solution blanks. The object of the program was to determine whether there were concentration
levels above which a groundwater sample could be considered to represent groundwater quality
rather than sampling-related contamination. The highest concentration of three VOCs, including
THF, occurred in groundwater samples and field blanks collected at sites where contamination of
the methanol used to clean field equipment or the cement used to join PVC piping was
documented.
"The observations that field blanks can contain high concentrations of acetone, 2-
butanone and tetrahydrofuran, and that contamination from PVC cement at well sites can
produce high concentrations of these three VOCs in groundwater samples, indicate that it
is not possible to define a threshold concentration above which detections in groundwater
have an acceptable possibility of being representative of aquifer conditions rather than
due to contamination."
Further, USGS determined that because it is not possible to establish a threshold level of acetone,
2-butanone, and THF above which detection actually represents aquifer conditions, analytical
results data for these three constituents should be discounted and reported detections should be
defined as "having no data available for these three VOCs" by changing the data quality
indicator code to "reviewed and rejected."
Other Studies
The literature review presented above focuses on THF from the cements used on PVC well
casing. These and additional studies, not summarized here, also indicate that:
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 7 December 17, 2013
• Cements used on PVC well casing also leach methyl ethyl ketone (2-butanone) and
methyl isobutyl ketone into groundwater at levels comparable to THF (USGS 2012), and
• PVC piping itself leaches its stabilizers, calcium, zinc, antimony, and tin, into
groundwater samples (US EPA 1981/1982), (US EPA 1991).
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 8 December 17, 2013
4.0 CONCLUSIONS AND RECOMMENDATIONS
Water level and elevation data indicate that the perched groundwater elevation in MW-01 is
approximately 9 feet higher than the perched groundwater elevation beneath the upgradient portion
of the Mill's Tailings Cells and therefore MW-01 cannot be impacted by Mill activities.
Additionally, MW-01 is more than 2,200 feet (0.4 miles) upgradient of the Mill facilities. THF has
never been used as a reagent, solvent or additive to the Mill's processes. THF is used by the
petroleum industry as the solvent for the Grignard reaction used to produce alkane hydrocarbons
such as the kerosene used in the Mill's solvent extraction circuits. THF is therefore expected to
be a constituent in the Mill's tailings system, and tailings wastewater analyses have confirmed
that it is present in the tailings system. However, its presence in tailings does not explain the
detection of THF in wells as far up-gradient as MW-01. As previously stated MW-01 is far
upgradient and cannot have been impacted by Mill activities.
THF concentrations which exceed the GWCL are likely the result of well construction practices
in older monitoring wells that used adhesives and glues to join the casings. The US EPA, USGS
and consultant studies summarized in Section 3 and cited in the references below have produced
data which demonstrate that wells constructed with glued PVC casings continue to leach THF
and other VOCs for months to years after installation, development and repeated purging of the
wells. The reports and studies also conclude that:
• Repeated purging does not reduce the concentration of THF over time in leached from
PVC wells with glued joints.
• THF levels in PVC wells with glued casings may increase for hours or days after
purging/flushing prior to sample collection.
• THF is so ubiquitous in cemented PVC wells that there is no concentration at which
detection of THF can be considered with certainty to represent aquifer conditions.
• Laboratory PVC piping is an additional contributor of THF and 2-butanone to analyzed
samples.
Further, EFRI has identified contamination in at least one THF VOC trip blank (in Q3 2011), far
above the GWCL for THF in MW-01 (as well as the GWCLs for most other wells). This finding
is also consistent with the USGS findings above, that THF is not uncommon in laboratory
supplied blanks and other QC samples, and render positive THF results from field sampling
questionable.
As discussed above, EFRI requested in the October 10, 2012 SAR, that GWCLs be removed
from up-gradient wells MW-01, MW-18, and MW-19. In a letter of April 25, 2013, DRC
concurred with EFRI's determination that constituents in those wells were not from Mill sources,
and that GWCLs in those wells could be removed. Per discussion with DRC in July 2013, DRC
planned to remove the GWCLs from the up-gradient wells in an interim GWDP revision. The
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 9 December 17, 2013
identification of two successive exceedances of the THF GWCL of 11.5 ug/L in MW-01
occurred after EFRFs assessment, and DRC's concurrence, that the GWCLs would be removed
from MW-01, and before any GWDP revision was published by DRC.
Given that:
• the THF detected in samples from MW-01 is suspect, and most likely due to influences of
solvent from the glued joints,
• MW-01, along with other up-gradient wells addressed in the October 2012 SAR are too
far up-gradient to be influenced by Mill activities, and
• DRC has already concurred with removal of the GWCLs from MW-01, along with other
up-gradient wells, then
EFRI believes that no corrective action is necessary or appropriate for THF in MW-01. EFRI
proposes to do the following:
EFRI will continue to monitor THF in MW-01 quarterly beginning from the third quarter of
2013 through the second quarter of 2014, which is consistent with the accelerated schedule for
this semi-annual well. EFRI will re-evaluate the status of THF in this well after those four
quarters of monitoring data are collected. A discussion of the results will be included in the 2nd
quarter 2014 quarterly groundwater report due to DRC on or before September 1, 2014.
If THF levels remain below the GWCL during the four quarters ending the second quarter of
2014, EFRI will resume semi-annual monitoring of MW-01 for THF. If THF exceeds the
GWCL during these four quarters, EFRI will continue accelerated (quarterly) monitoring for
THF in MW-01 until removal of the GWCL occurs with the publication of the revised GWDP.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 10 December 17, 2013
Table 1
Summary of Findings
Well
Out-of-
Compliance
Constituent
Summary Path Forward
MW-01 THF MW-01 is located approximately 2,200 feet
(over 0.4 miles) up-gradient of Mill
operations.
Continue to
monitor THF in
MW-01 for four
quarters. Remove
from accelerated
sampling if THF
concentration does
not exceed the
GWCL. Remove
GWCL (revise
GWDP).
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 11 December 17, 2013
5.0 REFERENCES
Energy Fuels Resources (USA) Inc. (EFRI), 2010-2013. White Mesa Uranium Mill Groundwater
Monitoring Reports
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 Near Blanding Utah. Prepared by Department of
Geology and Geophysics, University of Utah.
Martin, William H. and C. Chow Lee Persistent pH and Tetrahydrofuran Anomalies Attributable
to Well Construction. Woodward-Clyde Consultants, Oakland, California 1989
Michigan Department of Agriculture Groundwater Domestic Supply Well Baseline Study Report
2000
Soseby, J. P. Geiszler, D. Winegartdner, and C. Fisher. 1982 Contamination of Groundwater
Samples with PVC Adhesives and PVC Primer from Monitoring Wells. Environmental
Science and Engineering, Inc. Gainesville, Ha.
U.S. Environmental Protection Agency. EPA 600/1-81-062 Boettner, Edward A., Ball,
Gwendolyn L., Hollingsworth, Zane, and Romulo Aquino. Organic and Organotin
Compounds Leached from PVC and CPVC Pipe Department of Public Health, The
University of Michigan Ann Arbor September 1981 and EPA-600/S1-81-062 February
1982.
U.S. Environmental Protection Agency. EPA 160014-891034. Handbook of Suggested
Practices for the Design and Installation of Ground-Water Monitoring Wells. March
1991
U.S. Environmental Protection Agency. EPA 540/4-91/005 Jose Llopis The Effects of Well
Casing Material on Groundwater Quality October 1991.
U.S. Environmental Protection Agency. EPA 635/R-11/006F Toxicological Review of
Tetrahydrofuran (CAS No. 109-99-9) In Support of Summary Information on the
Integrated Risk Information System (IRIS) February 2012.
U.S. Geological Survey. Open File Report 95-398 Ground-water Date-Collection Protocols and
Procedures for the National Water-Quality Assessment Program: Selection, Installation,
and Documentation of Wells, and Collection of Related Data. 1995.
U.S. Geological Survey. Water Resources Investigation Report 96-4233 Guidelines and
Standard Procedures for Studies of Groundwater Quality: Selection and Installation of
Wells, and Supporting Documentation 1996.
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 12 December 17, 2013
U.S. Geological Survey. Scientific Investigations Report Evaluation of Volatile Organic
Compound (VOC) Blank Data and Application of Study Reporting Levels to
Groundwater Data Collected for the California GAMA Priority Basin Project, May 2004
through September 2010 Pub. 2012.
Wang, T. and J. L. Brickner. 1979 2-Butanone and Tetrahydrofuran Contamination in the Water
Supply. Bulletin of Environmental Contamination and Toxicology. 23:620-623
Source Assessment and Literature Search Report
White Mesa Uranium Mill
Blanding, Utah 13 December 17, 2013