DRC-2014-002281 - 0901a0688041506c

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCER J. COX
Lieutenant Governor
March 19,2014 DRC-2014-002281
Kathy Weinel
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
Subject: Review of the July 13, 2012 Energy Fuels Resources Revised Renewal Application for
Ground Water Quality Discharge Permit UGW3 70004: Request for Information
Dear Ms. Weinel:
On January 16, 2012, the Utah Division of Radiation Control (DRC) received the Revised
Renewal Application for the Energy Fuels Resources Ground Water Quality Discharge Permit No.
UGW370004. The submittal was in response to a DRC May 23, 2013 e-mail that included a
December 23, 2009 Request for Information memorandum. The DRC has completed its review of
the revised Renewal Application and is requesting additional information. The requested
information can be found in the attached document. If you have any questions please contact Phil
Goble at [phone].
Sincerely,
CWJ/PRG/prg
CC: John Hultquist
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D. [phone]
www.deq.ulah.gov
Printed on 100% recycled paper
Request for Information
Concerning
Denison Mines (Now Energy Fuels)
White Mesa Uranium Mill
Renewal Application
State of Utah Ground Water Discharge Permit No. UGW37004
July 2012
This is a Request for Information (RFI) concerning the July 2012 White Mesa Uranium Mill
Renewal Application, State of Utah Ground Water Discharge Permit No. UGW37004. The July
2012 White Mesa Uranium Mill Renewal Application (also referred to herein as the "Renewal
Application" or RA), was submitted to the Utah Division of Radiation Control (DRC) by the
Permittee, Denison Mines (now Energy Fuels Resources (USA) Inc.), on July 2012. The July
2012 submittal is an updated RA superseding an earlier version of the document submitted by
the Permittee in September of 2009. The questions that follow collectively constitute the RFI for
the new RA.
SECTION: 1.1 and many subsequent sections
INTERROGATORY STATEMENT(S): Page 5 of the Renewal Application (RA) refers to the
mill operator as Denison Mines (USA) Corp. Because the owner and operator of the mill has
changed, please use the new name here and throughout the RA.
BASIS FOR INTERROGATORY: The names of the owner and operator of the mill need to be
changed throughout the RA text to the new name of Energy Fuels Resources (USA) Inc.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 1.2
INTERROGATORY STATEMENT(S): Page 5 of the Renewal Application (RA) states that
In accordance with discussions between Denison management and State of Utah Division
of Radiation Control ("DRC") staff on March 12, 2009, this Application includes the
information required under R313-6-6.3.
Similarly, Page 6 refers to R313-6-6.4C. However, the Utah Code designations applied in these
cases are not correct. Please correct them.
1
BASIS FOR INTERROGATORY: The code that provides language identical or nearly
identical to that quoted in the RA is found in UAC R317-6-6.4C. No rules labeled as R313-6-6.3
or R313-6-6.4C exist in the UAC.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 1.2 (cont'd)
INTERROGATORY STATEMENT(S): On Page 6, the following wording from R317-6-6.4C
is quoted (but misattributed):
The Director may issue (or renew) a ground water discharge permit for an existing
facility, such as the Mill, provided:
a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, ground water quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
Please demonstrate within the renewal application (and summarize here) that all four conditions
iisted above are being met as is required for the Director to renew a groundwater discharge
permit.
BASIS FOR INTERROGATORY: Currently, there are two groundwater plumes identified at
the White Mesa Mill property. Please explain how these plumes are being addressed and justify
why a groundwater discharge permit should be renewed for the facility in light of these
conditions.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6
REGULATORY GUIDANCE REFERENCE(S): N/A
2
SECTION: 2.1
INTERROGATORY STATEMENT(S): Please update the Applicant and Owner name and
address.
BASIS FOR INTERROGATORY: Since the company has recently changed ownership, please
provide the following information required by UAC R317-6-6.3.A:
The name and address of the applicant and the name and address of the owner of the
facility if different than the applicant. A corporate application must be signed by an
officer of the corporation. The name and address of the contact, if different than above,
and telephone numbers for all listed names shall be included.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.3
INTERROGATORY STATEMENT(S): Page 14 says,
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium
milling and tailings disposal facility, which operates under a Radioactive Materials
License issued by the Director of the Utah Division of Radiation Control under UAC
R313-24. In addition to uranium in the form of U3O8, the Mill also produces vanadium, in
the form of vanadium pentoxide (V2O5), ammonia metavanadate (AMV) and vanadium
pregnant liquor (VPL), from certain conventional ores and has produced other metals
from certain alternate feed materials. Alternate feed materials are uranium bearing
materials other than conventionally mined ores.
Please describe what "other metals from certain alternate feed materials" have been produced.
BASIS FOR INTERROGATORY: The license granted under UAC R313-24 limits production
of minerals to certain specified types.
APPLICABLE RULE(S) OR REGULATION(S): UAC R313-24; License UT1900479
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.7.1
INTERROGATORY STATEMENT(S): It is stated on Page 27 that "Immediately below the
FML, each Cell has a nominal 6-inch thick layer of crushed sandstone that was prepared and
3
rolled smooth as an FML sub-base layer." Please correct this statement to include the other two
types of sub-base reported by EFR to exist in places beneath the tailings cells.
BASIS FOR INTERROGATORY: Materials underlying the FML of Cells 2 and 3 apparently
consist of crushed sandstone in most locations. However, characterization of all sub-base or
underlay materials beneath the cell liners in Cells 2 and 3 as crushed sandstone is not correct. In
some locations, the underlay materials are said to consist of either concrete sand or bare rock.
Page 23 of 58 in Denison Mines (2012) says of the underlay materials:
The material installed beneath the liners in Cells 2 and 3 consists of crushed Dakota
sandstone that was compacted with a smooth drum roller, but in some locations, in which
a smooth base grade was available, portions of the liner were placed over in-situ Dakota
sandstone (H. Roberts, 2012) (emphasis added).
This same document also states that
The Second Phase Tailings Management system Construction Report generally is
consistent with this observation: Energy Fuels Nuclear Inc. (1983) noted that a gravel-
sand mixture derived from crushing of loose [Dakota] sandstone, with some washed
concrete sand in some areas, was used to construct the compacted bedding layer
immediately beneath the liner in Cell 3; and that a similar process and materials were
used for the liner bedding material in Cell 2" (emphasis added).
Thus, it is seen that the thickness of crushed sandstone is appreciably less than six inches, being,
in fact, zero, in some locations. In some locations, FML is laid directly upon the Dakota
Sandstone. In other locations, washed concrete sand is substituted for or added to crushed
sandstone. Acknowledgment of these variant types of materials used in the sub-base of the liner
in the RA is important since each type of material potentially has different hydraulic properties
and has a bearing on the modeling of whether or not "the discharge can be controlled and wiii
not migrate into or adversely affect the quality of any other waters of the state."
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.G
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.7.2.4
INTERROGATORY STATEMENT(S): Page 29 indicates that "Denison submitted an
Infiltration and Contaminant Transport Modeling ("ICTM") Report, White Mesa Mill Site,
Blanding, Utah ... to fulfill the requirements of Part I.H.I 1 of the Permit."
Please revise the sentence above to show the correct part of the Permit.
4
BASIS FOR INTERROGATORY: The requirements for the ICTM in the Permit are found in
Part I.H.2 in the current version of the Permit.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.7.6
INTERROGATORY STATEMENT(S): Relative to Roberts Pond, Page 35 says that "an
appropriate DMT operation standard", as referenced in Permit, includes "a stipulation that the
Mill maintain a minimal wastewater head in this pond based on a 2-foot freeboard limit and a 1-
foot additional operating limit." Please rewrite this statement to correct it and render it consistent
with provisions in the Permit.
BASIS FOR INTERROGATORY: The statement quoted above uses the phrase "minimal
wastewater head," but this is incorrect. In the existing context, that phrase neither makes sense
nor corresponds to the Permit language.
What would work in the statement would be language similar to either "minimum distance
between the wastewater surface and the pond-bank crest" or "maximal wastewater head." The
minimum distance between the wastewater surface and the pond-bank crest is equal to the
minimum freeboard of two feet, as required by the Permit, plus an additional one foot of
freeboard as determined by the Permittee, these together constituting the operating limit
employed by the Permittee for safety purposes. The maximal wastewater head should not exceed
the elevation of the pond-bank crest minus three feet, which is the sum of the two feet of
freeboard and the one foot of additional operating distance.
The language of the Permit itself is as follows:
The Permittee shall operate this wastewater pond so as to provide a minimum 2-foot
freeboard at all times. Under no circumstances shall the water level in the pond exceed an
elevation of 5,624 feet amsl. In the event that the wastewater elevation exceeds this
maximum level, the Permittee shall remove the excess wastewater and place it into
containment in Tailings Cell 1 within 72-hours of discovery.
It is important to make the distinctions above since a literal interpretation of the existing
language would constrain the level in the pond to exceed the limits set by the Permittee and
possibly exceed the limits stated in the Permit.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
5
SECTION: 2.7.7.1
INTERROGATORY STATEMENT(S): On Page 35, it says
The Permit requires the Mill to continue its existing practice of limiting open air storage
of feedstock materials to the historical storage area found along the eastern margin of the
Mill site (as defined by the survey coordinates found in Permit Table 4); and one of the
following three practices: 1) Store feedstock materials in water-tight contains, or 2) Place
feedstock containers in water-tight overpack containers, or 3) place feedstock containers
on a hardened surface that conforms to the requirements spelled out in the permit part
I.D.I Id) 1 through 5.
Please correct that part of the statement following the phrase "one of the following three
practices" since that is at variance with the Permit.
BASIS FOR INTERROGATORY: The Permit, portions of which are now quoted, actually
requires two practices (see Part I.D.I 1), as follows: (1) "Feedstock materials will be stored at all
times in water-tight containers, and" (2) compliance with one of the following options is
required:
(b) Aisle ways will be provided at all times to allow visual inspection of each and every
feedstock container, or
(c) Each and every feedstock container will be placed inside a water-tight overpack prior
to storage, or
(d) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical requirements . .
. [emphasis added]
which physical requirements are listed specifically in the Permit.
Thus, the Permit requires two practices. This is a different requirement from (and twice the
number of) "one of. . . three practices", which is incorrectly referenced in the RA. The first of
the required two practices included in the Permit is that "feedstock materials will be stored at all
times in water-tight containers." This first practice is thus mandatory regardless of which option
is selected for a second practice.
As indicated in the Permit, a second required practice is then selected from one of three available
options. These three are the options labeled as (b), (c) and (d) shown above.
An additional significant point is that only two of the three options for the second practice stated
in the Permit as being available are currently listed in the RA. The option about "(b) Aisle ways
will be provided at all times to allow visual inspection of each and every feedstock container" is
not listed in the RA. It needs to be, since that is one of the options provided in the referenced
Permit.
6
Using a different, somewhat more symbolic approach, the RA perspective of (the first practice
listed or c or d) needs to be replaced by Permit perspective of (the first practice listed and (b or
c or d)).
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.7.7.2
INTERROGATORY STATEMENT(S): On Page 35, the RA states "For new facilities
constructed at the Mill, or reconstruction of existing facilities, Part I.D.3(e) requires the higher
standard of secondary containment that would prevent contact of any potential spill with the
ground surface." Please correct the reference made in this sentence to the Permit.
BASIS FOR INTERROGATORY: The correct reference should be Part I.D.3(g).
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.9.1.3
INTERROGATORY STATEMENT(S): Page 39 of the RA says
Part I.E. 1(d) of the Permit requires that each point of compliance well must be sampled
for the constituents listed in Table 2.9.1.3-1.
Further, Part I.E.l.(d)l) of the Permit, requires that, in addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
• Specific conductance
The Permittee needs to add to the list of parameters referenced with respect to Part I.E. 1(d)(1)
the following parameter: redox potential (Eh).
BASIS FOR INTERROGATORY: Part I.E. 1(d) of the Permit states the following:
d) Compliance Monitoring Parameters - all groundwater samples collected shall be
analyzed for the following parameters:
1) Field Parameters - depth to groundwater, pH, temperature, specific conductance,
and redox potential (Eh).
7
From this, it is seen that redox potential (Eh) is a field parameter currently left out of the
description in the RA. It is important to include Eh as a field parameter in order to estimate redox
conditions in the perched water zone.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.12.1
INTERROGATORY STATEMENT(S): Reference is made to the Tailings and Slimes Drain
Sampling Program, Revision 0, November 20, 2008 as Appendix H. Please change the appendix
name to Appendix I.
BASIS FOR INTERROGATORY: Appendix H is not the correct appendix name for this
document. The correct appendix name is Appendix I. The name needs to be changed to
correspond with the actual paper and electronic copies of the RA.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: 2.15.2.2
INTERROGATORY ST ATEMENT(S): As stated in the RA, "Part I.D.3(b)(l) of the Permit
requires that Denison must at all times maintain the average wastewater head in the slimes drain
access pipe to be as low as reasonable achievable (ALARA) in each tailings cell, in accordance
with the approved DMT Plan." However, no data are provided in the RA in support of a
demonstration of compliance to this objective.
In addition, the RA states in Part I.D.3(b)(3) that
Compliance will be achieved when the average annual wastewater recovery elevation in
the slimes drain access pipe, determined pursuant to the currently approved DMT Plan
meets the conditions in Equation 1 specified in Part I.D.3(b)(3) of the Permit.
Again, the RA provides no relevant information about the current approach to compliance. For
each cell, accordingly please provide the following, where feasible:
(1) Historical records over the past four years (2009 to 2012, inclusive) chronicling
measurements of "the average wastewater head in the slimes drain access pipe" for Cells 2 and 3,
listed by date. Elevations can be obtained by subtracting quarterly measurements of depth to the
wastewater, as required by Part I.E.7(b) of the Permit, from the reference elevation (e.g., top of
pipe elevation).
8
(2) Data demonstrating how well, to date, "the average annual wastewater recovery elevation in
the slimes drain access pipe, determined pursuant to the currently approved DMT Plan meets the
conditions in Equation 1 specified in Part I.D.3(b )(3) of the Permit." This Equation basically
tests each current year's 3-year average slime drain elevation against the previous year's to see if
the current year's is less.
(3) Plans for decreasing "the average wastewater head in the slimes drain access pipe" for Cells 2
and 3 in the future, along with a planned schedule for reducing the head to the closure goal of no
more than three feet above the FML within the next several years. These plans should include
efforts to accelerate drawdown to meet ALARA criteria.
BASIS FOR INTERROGATORY:
Part I.E.7(b) of the Permit states
Quarterly Slimes Drain Water Level Monitoring: Cells 2 and 3 - the Permittee shall
monitor and record quarterly the depth to wastewater in the slimes drain access pipes as
described in Part I.D.3 of this Permit and the currently approved DMT Monitoring Plan at
Tailings Cells 2 and 3 to determine the recovery head. For purposes of said monitoring,
the Permittee shall at each tailings cell:
1) Perform at least 1 separate slimes drain recovery test at each-disposal cell in each
quarterly period of each calendar year that meets the requirements of Part I.D.3,
2) Designate, operate, maintain, and preserve one water level measuring point at the
centerline of the slimes drain access pipe that has been surveyed and certified by a
Utah licensed engineer or land surveyor,
3) Make all slimes drain recovery head test (depth to fluid) measurements from the
same designated water level measuring point, and
4) Record and report all fluid depth measurements to the nearest 0.01 foot.
5) For Cell 3 these requirements shall apply upon initiation of tailings de-watering
operations.
Part I.D.3(b)(3) states that
Annual Slimes Drain Compliance - shall be achieved when the average annual
Wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to the currently approved DMT Monitoring Plan, meets the conditions in Equation 1
below:
Equation 1:
[EEy + EEy-l + _£y.2] / [Ny + Ny.| + Ny.2] < [ZEy., + __Ey.2 + £Ey.3] / [Ny., + Ny.2 + Ny-3]
9
Where:
EEy = Sum of all monthly and quarterly slimes drain tailings fluid elevation measurements that
meet the test performance standards found in the sub-paragraphs of Part I.D.3(b)(2), during the
calendar year of interest. Hereafter, these water level measurements are referred to as slimes drain
recovery elevations (SDRE). Pursuant to the applicable frequency and method of the approved DiViT
Monitoring Plan at the time of each SDRE test, these recovery tests are to be conducted and the SDRE
values reported in units of feet above mean sea level (amsl). However, when monthly and quarterly
measurements are combined in the above equation, the quarterly values shall be multiplied by a
coefficient of three (3).
ZEy-i == Sum of all SDRE measurements made in the year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
_-Ey_2 - Sum of all SDRE measurements made in the second year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
_-Ey-3 = Sum of all SDRE measurements made in the third year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
Ny = Total number of SDRE tests that meet the test performance standards found in Part
I.D.3(b)(2), conducted during the calendar year of interest. However, when monthly and quarterly
measurements are used in the equation above, each quarterly test shall be counted as three (3) separate
tests.
Ny.| = Total number of SDRE tests that meet the test performance standards found in Part
l.D.3(b)(2), conducted in the year previous to the calendar year of interest. However, when monthly
and quarterly measurements are used in the equation above, each quarterly test shall be counted as
three (3) separate tests.
Ny.2 = Total number of SDRE tests that meet the test performance standards found in Part I.D.3(b)(2),
conducted in the second year previous to the calendar year of interest. However, when monthly and
quarterly measurements are used in the equation above, each quarterly test shall be counted as three (3)
separate tests.
Ny.3 = Total number of SDRE tests that meet the test performance standards found in Part
I.D.3(b)(2), conducted in the third year previous to the calendar year of interest. However, when
monthly and quarterly measurements are used in the equation above, each quarterly test shall be
counted as three (3) separate tests.
Prior to January 1, 2013, the following values for E and N values in Equation 1 shall
be based on SDRE data from the following calendar years.
Report for Calendar Year Source of Data by Calendar Year for Equation 1 Variables (right side)
Ey ' Ey.l Ey.2 Ny Ny.J Ny-2
2010 2009 2009 2009 2009 2009 2009
2011 2010 2009 2009 2010 2009 2009
2012 2011 2010 2009 2011 2010 2009
10
Failure to satisfy conditions in Equation 1 shall constitute DMT failure and
noncompliance with this Permit. For Cell 3, this requirement shall apply after initiation
of de-watering operations [Emphasis added].
If recent performance on reducing the wastewater heads in the cells indicates that the current rate
of drawdown may not be sufficient to attain dewatering performance objectives within the next
several years, as has recently been indicated by the DRC during ICTM and REC Plan
discussions, then plans for remedial activities for the slimes drain will be needed. Equation 1
above will be used to address requirement (2) above.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTIONS: 2.15.3.1, 2.15.3.2, 2.15.4
INTERROGATORY STATEMENT(S): Please fix the wording in these sections in reference
to Part I.H.I9.
BASIS FOR INTERROGATORY: I.H. sections only extend to Part I.H.7. There is noPart
I.H.I9 in the current Permit. Similar problems appear in other parts of Section 2.15.3.1 and in
Sections 2.15.3.2 and 2.15.4. Please adjust the references so they are consistent with the current
Permit.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTIONS: 2.19.2 and 2.19.3
INTERROGATORY STATEMENT(S): Page 78 of the RA states in Part 2.19.2 that: "The
Mill's Reclamation Plan, Revision 4.0, was approved by the DRC under the Mill License in
January 2011." This statement is incorrect. The currently approved reclamation plan is 3.2B,
which was approved by the DRC on January 26, 2011.
Section 2.19.2 and 2.19.3 also describe the Denison Mines submittal of Revision 5.0 of the
Reclamation Plan in September 2011" and that "submission of responses to all first round
interrogatory questions will be completed by August 14, 2013." Additional information about the
Reclamation Plan is provided in Section 2.19.3 on Page 79. Please update this information to
include concepts and data in a new version of the Reclamation Plan modified in response to
information shared at recent meetings between the Permittee and the DRC.
BASIS FOR INTERROGATORY: A meeting was held in Denver Colorado on April 29, 2013
concerning the version of the Reclamation Plan and the related version of the Infiltration and
11
Contaminant Transport Model report then extant. Participating in the meeting were
representatives of the Permittee, its consultant (M WH Americas), the DRC, and its consultant
(URS Professional Solutions). A number of issues concerning the then-extant version of the
Reclamation Plan were raised at this meeting, many were resolved verbally, and others were left
as being yet to be resolved. Decisions were made at the meeting related to the Permittee
undertaking additional work and responding to questions raised by the DRC. These issues, their
resolutions and additional work to be done will help finalize a new version of the Reclamation
Plan. The changes in the new version of the Reclamation Plan have need of being discussed in
the RA to make it current.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: Appendix A
INTERROGATORY STATEMENT(S): A number of apparent discrepancies exist between
well locations shown in San Juan County plats in Appendix A and well locations shown in
Figure 10, White Mesa Site Plan Showing Locations of Perched Wells and Piezometers. Please
reconcile these, or provide explanations, if information provided is believed to be correct as is.
BASIS FOR INTERROGATORY: There are several types of discrepancies noted when
comparing well locations in San Juan County plats in Appendix A of the RA and well locations
shown in Figure 10 of the RA, entitled White Mesa Site Plan Showing Locations of Perched
Wells and Piezometers.
• A San Juan plat for Section 22, T37S, R22E is missing. This plat is important, and it
needs to be included in the RA, because wells TWN-12, TWN-16 and TWN-19 are
located in Section 22.
• The San Juan plats show what appear to be duplicate locations for each of the '
following pairs of wells, in which each well in each pair is placed in different
sections.
TW4-19 (two locations: one in Section 28 and one in Section 33 of T27S, R22E.)
TW4-22 (two locations: one in Section 28 and one in Section 33 of T27S, R22E.)
MW-21 (two locations: one in Section 32 of T37S, R22E and one in Section 5 of
T38S, R22E.)
Please work with San Juan County to correct these apparent discrepancies, in case a
mis-mapping could otherwise cause legal or other problems down the road, or even if
it only might cause confusion. If the San Juan County plats are corrected, then please
include the correct plats in the RA once this is accomplished.
12
• The following abandoned wells are shown as wells in San Juan County plats but are
not shown in Figure 10:
MW-16 (Section 32 of T37S, R22E)
DR-2 (Section 32 of T37S, R22E)
DR-16 (Section 5 of T38S, R22E)
DR-18 (Section 5 of T38S, R22E)
DR-25 (Section 5 of T38S, R22E)
While it is not necessary from the perspective of the DRC for EFR to take any action
on mapping of these wells, since they are abandoned, the DRC does point out the
apparent discrepancy between the county plats and Figure 10 with respect to their
apparent existence.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: Appendix L
INTERROGATORY ST ATEMENT(S): The first listing of'Aluminum Powder" in Appendix
L is out of order alphabetically, and the quantity shown for it, 0 g, is incorrect. Please remove
this first listing, inasmuch as there is also a later listing that is ordered alphabetically, which has
an entry for the correct quantity.
BASIS FOR INTERROGATORY:): In the alphabetical listing of laboratory chemicals on
site, the item 'Aluminum Powder", when first introduced, is listed between "Aluminum Metal,
granular" and "Aluminum Nitrate, Nona hydrate." Furthermore, the quantity given, 0 g, appears
to be incorrect, since a subsequent listing for "Aluminum Powder", the one that is listed between
"Aluminum Potassium Sulfate 12 Hydrate Crystal" and "Aluminum Reagent 2," has an entry for
quantity of 300 g.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): N/A
SECTION: Appendix L
INTERROGATORY STATEMENT(S): Is the chemical inventory list provided in the RA
(Appendix L) complete, listing every chemical either stored or used (either now or in the past) at
the facility? If not, then please discuss each exception and indicate why it is not listed, or,
alternatively, add it to the inventory list.
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BASIS FOR INTERROGATORY: The text of the RA refers to Part I.H.I of the Permit. The
text states that Part I.H.I "requires that Denison" (now EFR) "complete a historical review and
conduct an inventory of all chemical compounds or reagents stored, used, or current in use at the
facility, including the types of chemicals and the total volumes present, and historically used, as
data is available." It says that, in application to renew the Permit, the Permittee "shall submit an
updated inventory report."
However, while the requirements are stated, the list currently submitted as Appendix L of the RA
is entitled simply "Laboratory Chemical Inventory." This title by itself conveys the impression,
whether rightly or wrongly, of possible insufficient compliance with Permit requirements. Part
I.H.I of the Permit refers not to a "laboratory chemical inventory" (which might exclude
chemicals used in places at the facility other than in a laboratory) but refers to an "on-site
chemicals inventory." The latter title suggests an inventory potentially more comprehensive than
simply a laboratory chemical inventory. The Permit says of this on-site chemicals inventory that
it must report the names of "all chemical compounds and reagents stored, used or currently in
use at the facility". The text of the Permit later specifies that the Permittee "identify all
chemicals used in the milling and milling related processes at White Mesa" (emphasis added). If
there are chemicals that are currently being used, or that have been used in the past, at the
facility, that are not that are not listed in the "Laboratory Chemical Inventory", then these need to
be specified at this point by the Permittee in an updated inventory.
The current submittal does not discuss chemicals formerly used at the facility but not currently
found in the laboratory nor does it mention their estimated volumes. This needs to be done.
Furthermore, as part of the new inventory to be submitted, the Permittee needs to include a
statement attesting that, according to the best information to be had, the listing contained therein
includes the names and quantities of every chemical either stored or used (either now or in the
past) at the facility. Such a statement is needed to confirm that the requirements of the Permit
that names and quantities of all chemicals are being reported.
REFERENCES
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Amonette, J.E., Jeffers, P.M., Qafoku, O., Russell, C.K., Humphrys, D.R., Wietsma, T.W., and
Truex, M.J. (2012) Abiotic degradation rates for carbon tetrachloride and chloroform: Final
report. PNNL-22062; RPT-DVZ-AFRI-012, Pacific Northwest National Laboratory, Richland,
WA.
Baker, A.A. (1936) Geology of the Monument Valley-Navajo Mountain region, San Juan
County, Utah, U.S. Geological Survey Bulletin, No. 865, 106 pp.
Denison Mines (2012) Responses to Interrogatories - Round 1 for the Revised Infiltration and
Contaminant Transport Modeling Report, March 2010 (dated May 31, 2012).
Gloyne, R.W., Morgan, CD., Tabet, D.E., Blackett, R.E., Tripp, B.T. and Lowe, M. (1995)
Energy and Ground-Water Resources of San Juan County, Utah.
Lowe, M. (1996) Ground-Water Resources of San Juan County, Geology and Resources of the
Paradox Basin, p. 389-394.
Naftz, D.L., Ranalli, A.J., Rowland, R.C., and Marston, T.M. (2011) Assessment of potential
migration of radionuclides and trace elements from the White Mesa uranium mill to the Ute
Mountain Ute Reservation and surrounding areas, Southeastern Utah: U.S. Geological Survey
Science Investigations Report 2011-5231, 146 pp.
Truex, M.J., Murray, C.J., Cole, C.R., Cameron, R.J., Johnson, M.D., Skeen, R.S., Johnson, CD.
(2001) Assessment of Carbon Tetrachloride Groundwater Transport in Support of the Hanford
Carbon Tetrachloride Innovative Technology Demonstration Program, PNNL-13560, Pacific
Northwest National Laboratory, Richland, WA, July 2001.
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