DRC-2014-002441 - 0901a06880418d4e

Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONT
Rusty Lundberg
Director
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
March 26, 2014
CERTIFIED MAIL
(Return Receipt Requested)
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228-1815
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DRC-2014-002441
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Quality Assurance Manager
Energy Fuels Resourses (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228-1815
iMmkumwrnmmammmum 1111 m n i in m i II n m 111 Subject: Energy Fuels Resources (USA) Inc. August 27, 2009 Hydrogeologic Report for the
White Mesa Uranium Mill: Request for Information
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has reviewed the Energy Fuels Resources
(USA) Inc. ("EFR") August 27, 2009 document titled Site Hydrogeology and Estimation of
Groundwater Travel Times in the Perched Zone White Mesa Uranium Mill Site near Blanding
Utah ("Report"). The Report was prepared to comply with the Utah Ground Water Discharge
Permit, No. UGW370004 ("Permit") Part I.F.10 which requires the preparation and submission of
a revised hydrogeological report to be submitted within 180 days prior to Permit expiration and
which was reviewed by DRC as part of the Permit renewal application.
DRC noted, as part of the review, that several additional studies have been conducted since the
submission of the Report which have added a significant amount of information regarding
characterization of the site hydrogeology, and which would be beneficial inclusions in the Report.
Specifically, DRC notes that the following studies have been conducted:
1. The Southwest Investigation Report (Final Report Dated November 7, 2012) which
included installation of a well network down-gradient from the tailings cells and extending
to the southern margin of the White Mesa. EFR utilized the well network to collect
ground water head data and improve the ground water elevation map and site ground water
gradients hydraulically down gradient from the Mill. EFR additionally performed slug
testing to provide estimated hydrologic parameters (Hydraulic Conductivity and Specific
Storage) for each well in the network and delineated proposed areas of the Burro Canyon
which appeared to have no saturated zone. Based on the data, ground water travel times
and ground water flow paths were calculated for potential discharges from the tailings
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. Utah, gov
Printed on 100% recycled paper
Kathy Weinel
Page 2
cells to seeps and springs on the margins of the White Mesa. The Southwest Investigation
also included a survey of site geology (field and literature) and development of a more
detailed description of the geology, and discussed impacts of localized recharge to the
Burro Canyon Aquifer at the White Mesa in the vicinity of the Mill.
2. EFR Nitrate Contaminant Investigation Activities (Activities through September 2011)
which included; Soil borings to boring refusal within and outside of the confines of the
White Mesa Mill Facility; Installation of an up-gradient monitoring well network, and;
Ground water head monitoring and hydraulic testing. It is noted that the Nitrate
Contaminant Investigation included activities to more accurately map the depth and extent
of the Mancos Shale Paleoridge in the vicinity of the White Mesa Mill. The investigation
additionally provided calculations of regional background soil concentrations of ammonia
and nitrate (based on depth profiles).
3. Implementation of a Nitrate Contamination Corrective Action Plan (May 7, 2012 EFR
CAP Approved by the Director) and ongoing activities. Recent activities include but is not
limited to; The drilling of additional soil borings and soil sampling to delineate ammonia
and nitrate soil contamination in the area of the ammonium sulfate crystal tanks;
Conversion of groundwater monitoring wells to active pumping wells and measurement of
pump performance data and groundwater capture zones, and; preparation of quarterly
performance reports.
4. Continued implementation of corrective actions related to remediation of the chloroform
plume including collection of additional pump performance data. Recent activities include
the installation, hydraulic testing and sampling (chloroform and nitrate) of additional
monitoring wells along the eastern margin of the EFR property.
5. The October 12, 2012 Source Assessment Report for groundwater monitoring wells with
parameters in out-of-compliance ("OOC") status as defined by the Permit. The Source
Assessment Report included proposed modifications to Permit ground water compliance
limits (GWCL's) deemed appropriate after determination that the OOC status was due to
changes in background concentrations of the parameters of concern.
6. Preparation of a November 9, 2012 pH Report which included proposed revised GWCL's
for all monitoring wells (MW series) after determination that certain wells in OOC status
for pH were not due to cell leakage. EFR proposed that declining pH trends in monitoring
wells was due to site-wide dissolution of pyrite in the Burro Canyon Formation
mineralogy as discussed below.
7. Preparation of a December 7, 2012 Pyrite Investigation Report which included
mineralogical analysis of core samples from the White Mesa Uranium Mill (to determine
% pyrite) and groundwater modeling to determine whether the observed pH values were
geochemically possible through that mechanism (aeration of the formation due to
discharges from the upper wildlife ponds and/or monitoring well development and
overpumping).
Kathy Weinel
Page 3
8. Infiltration and Contaminant Transport Modelling ("ICTM") - EFR is engaged in
continued evaluation of the Mill area geology/hydrogeology and geochemistry in order to
estimate contaminant transport times from the tailings cells to local receptors based on
proposed tailings cell engineered covers (leakage rates of proposed cover and liner
designs). The ICTM evaluation includes mineralogical and hydrogeological evaluation of
the vadose zone using empirical evaluation of core samples and ground water modeling
(two dimensional finite difference model with geochemical evaluation of surface
complexation in response to discharges from the tailings cells).
9. Collection of additional groundwater head data and ground water samples (and data
results) since the submission of the Report from all of the White Mesa Uranium Mill
groundwater monitoring wells.
10. Discontinuance of recharge to the two upper wildlife ponds in order to dissipate the local
groundwater mounding in that area.
DRC notes that the above listed studies provide additional characterization of the White Mesa
hydrogeology since the EFR Report submission (2009). Per a telephone conference amongst
DRC representatives (Phil Goble and Tom Rushing), EFR representatives (Kathy Weinel and
Jaime Massey), and EFR contractor Stewart Smith (Hydro Geo Chem) it was discussed that the
Report will be updated to reflect the results of the more recent data and that an updated Report
will be submitted to DRC by June 16, 2014. Additionally EFR may submit an outline of the
Report for DRC review and agreement prior to June 16, 2014.
DRC notes that the Permit Part I.F.lO.b requires that EFR submit "temporal contaminant
concentrations and trends from each monitoring well; statistical tests for normality of each
contaminant and well, including univariate or equivalent tests; calculation of the mean
concentration and standard deviation for each well and contaminant.'''' DRC notes that a revised
background groundwater report1 was submitted to DRC by EFR in October 2007. The revised
background report presented statistical evaluation and proposed GWCL's for all of the monitoring
wells at the White Mesa Uranium Mill Site (MW series wells). Additionally, EFR submitted a
Source Assessment Report for monitoring wells and parameters in out of compliance status (dated
October 12, 2012) which included statistical evaluation and proposed GWCL's for the affected
wells. DRC notes that the GWCL's for the White Mesa Uranium Mill groundwater monitoring
network were set on an intrawell basis allowing for the continual assessment of background
concentrations at each individual well location.
Therefore, EFR currently conducts source assessments according to a plan and time schedule
approved by the Director whenever a monitoring well parameter enters OOC status per the
requirements of the Permit Part I.G.4.C, including evaluations of increasing concentration trends
and ensurance that all concentrations exceeding GWCL's were not caused by leakage of tailings
solution or other mill related processes. Based on this continual assessment of background
concentrations in the Burro Canyon Aquifer it is not necessary for EFR to submit a reassessment
1 Denison Mines (USA) Corp. (Prepared by Intera) October 2007 Revised Background Groundwater Quality Report:
Existing Wells for Denison Mines Corp's White Mesa Mill Site, San Juan County, Utah
Kathy Weinel
Page 4
of temporal concentration trends and calculations of mean concentration and standard deviation
for each of the wells and monitoring parameters. However, in cases where a decreasing data trend
is noted for a given monitoring well concentration, the Director may request a background
evaluation be conducted by EFR to determine if a GWCL adjustment (lowering) is appropriate.
If you have questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Rusty Lundberg
Director
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U:\MON_WAST\Trushing\Energy FuelsVEFR 2009 Hydro ReportVEFR Hydro Report DRC RFI.docx