DRC-2013-001289 - 0901a0688034e71d

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
February 15,2013
VIA PDF AND FEDEX
Rusty Lundberg,
Director, Division of Radiation Control
Utah Department of Environmental Quality^
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
P0B 20^3
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.1 (a)
Dear Mr. Lundberg: DRC-2013-001289
The White Mesa Mill (the "Mill") performed fourth quarter ("Q4") groundwater monitoring during the
period from October 1, to December 31, 2012 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 January 17,2013.
Pursuant to Part I.G.1.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 then* 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.1 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 Q3 2012 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. ("EFRf), as determined by Utah Department of Environmental Quality ("UDEQ") Staff and
as stated in teleconferences with EFRI on April 27 and May 2, 2011. Based on the assessments noted
below relating to the Q4 exceedances, a plan and schedule for the exceedance of selenium in MW-31 is
required. Regarding other Q4 Exceedances noted herein, a plan and schedule will not be required for the
following reasons. A Plan and Time Schedule will not be prepared for monitoring wells with two
successive exceedances in Q4 2012 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 because the assessment processes and conclusions have not changed since
this previous submission. Additionally, a Plan and Time Schedule will not be prepared for successive
exceedances of nitrate + nitrite, chloride, chloroform, methylene chloride and pH because these
constituents have been the subject of ongoing investigations at the Mill as discussed below.
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Letter to Mr. Rusty Lundberg
February 15, 2013
Page 2
Under the August 24, 2012 revisions of 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
monthly is resampling of the same water and leads to repeat exceedances for accelerated constituents not
due to Mill activities, but due to repeat sampling of the same water.
The following are items of note relevant to all exceedance data presented herein:
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 UDEQ in
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 due to effects from the evolution of carbon dioxide, and
subsequent increase in pH from field to lab. 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 most recent
groundwater pH data from the Q2 of 2011, including accelerated sampling results as recent as
June 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. By the letter dated June 30, 2011, EFRI proposed to submit to DRC a Work Plan and
Schedule to complete investigations to address the site-wide pH issue, following a meeting with
DRC, to discuss EFRI's fmdings to date and to agree upon the steps and milestone dates to be
incorporated in the Work Plan and Schedule. Pursuant to teleconferences with DRC on December
5, and December 19, 2011, EFRI submitted the Work Plan and Schedule on January 20, 2012 and
a revised plan based on DRC comments on April 13, 2012. The Work Plan and Time Schedule
were approved by DRC. Based on the approved Work Plan and Time Schedule, EFRI and DRC
entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. Due to the
completion of the reports which were submitted November 9, 2012 and December 7, 2012 which
evaluated site field pH conditions in the SCA, the 30-day plan and schedule for assessment is not
required for field pH exceedances.
Letter to Mr. Rusty Lundberg
February 15, 2013
Pages
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 Q4 2012. The 30-day plan and schedule contemplated in Part I.G.l c)
of the GWDP will be required only for the consecutive exceedance of selenium in MW-31. The 30-day
plan and schedule contemplated in Part I.G. 1 c) for the remainder of the consecutive exceedances which
occurred in Q4 of 2012, 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 Source Assessment Report submitted to DRC
on October 10,2012.
MW-11
• Manganese concentrations exceeded the GWCL in MW-11 in all of the Q4 sampling events.
Manganese has exceeded the GWCL in MW-11 since the issuance of the January 20, 2010
GWDP, which established intra-well GWCLs. A plan or schedule to address the Q4
exceedances is not necessary and is not being submitted because exceedances have been
addressed in the SAR which was submitted to DRC on October 10,2012.
MW-26
• Nitrate + nitrite has exceeded its GWCL in the October and December monthly sampling events
during Q4 2012. 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 Q4 2012. MW-26 is
used as a pumping well for the ongoing chloroform capture program and is expected to yield
increased concentrations of chloroform. Because analyte values in pumping wells vary wildly
with system operation and are not representative of groundwater conditions EFRI has requested
in the October 10, 2012 SAR that the Director eliminate GWCLs for the pumping wells.
• Methylene chloride has exceeded its GWCL in all of the Q4 2012 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 analyte values in pumping wells vary
wildly with system operation and are not representative of groundwater conditions, EFRI has
requested in the October 10, 2012 SAR that the Director eliminate GWCLs for the pumping
wells.
• Field pH has been slightly outside (slightly lower than) the GWCL for the October and Q4
(November) sampling events. As mentioned above, site-wide pH issues and trends are addressed
in reports submitted on November 9, 2012 and December 7, 2012; therefore a plan and schedule
to address this consecutive exceedance is not necessary and is not being submitted.
MW-26 Note: As stated m 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
Letter to Mr. Rusty Lundberg
February 15, 2013
Page 4
determining compliance for this well." Based on information provided by UDEQ 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. Because analyte values in pumping wells vary widely
with system operation and are not representative of groundwater conditions, EFRI has requested in the
October 10, 2012 SAR that the Dkector eliminate GWCLs for the pumping wells.
• The uranium concentration exceeded its GWCL in the Q4 (November) and December sampling
events. A plan or schedule to address the Q4 exceedances is not necessary and is not being
submitted because exceedances have been addressed in the SAR which was submitted to DRC on
October 10, 2012.
MW-30
• The nitrate + nitrite concentration exceeded its GWCL in all sampling events during Q4 2012 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 in the September and October sampling events.
As mentioned above, a CAP is currently being implemented to address nitrate + nitrite which is
expected to address chloride; therefore a plan to address this consecutive exceedance is not
necessary and is not being submitted.
• The selenium concentration exceeded its GWCL in the October and Q4 (November) sampling
events and during previous quarters. A plan or schedule to address the Q4 exceedances is not
necessary and is not being submitted because exceedances have been addressed in the SAR which
was submitted to DRC on October 10, 2012.
MW-31
• The nitrate + nitrite concentration exceeded its GWCL in all sampling events during Q4 2012 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 in all sampling events during Q4 2012. As
mentioned above, a CAP is currently being implemented to address nitrate + nitrite which is
expected to address chloride; 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 Q4 2012. A plan or
schedule to address the Q4 exceedances is not necessary and is not being submitted because
exceedances have been addressed in the SAR which was submitted to DRC on October 10, 2012.
• The selenium concentration exceeded its GWCL in the Q3 2012 and Q4 2012 sampling events.
This is the first consecutive exceedance for selenium in MW-31. Therefore, a plan and schedule
for assessment will be submitted under separate cover within 30 days of this Exceedance Notice.
Letter to Mr. Rusty Lundberg
February 15, 2013
Page 5
MW-35
The manganese concentration exceeded the GWCL in MW-35 in all of the Q4 sampling events. A
plan and schedule to address the Q4 exceedances is not necessary and is not being submitted
because exceedances have been addressed in the SAR which was submitted to DRC on October
10, 2012. An additional plan or schedule to address the Q4 exceedances is not necessary and is
not being submitted because the assessment processes and schedule have not changed since the
October 10, 2012 submission. It should be noted that background has not yet been established for
MW-35 and that 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 in 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 Q4 sampling events. A
plan and schedule to address the Q4 exceedances is not necessary and is not being submitted
because exceedances have been addressed in the SAR which was submitted to DRC on October
10, 2012. An additional plan or schedule to address the Q4 exceedances is not necessary and is
not being submitted because the assessment processes and schedule have not changed since the
October 10, 2012 submission. It should be noted that background has not yet been established for
MW-35 and that 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 in the second quarter 2013 pending the collection of 8 statistically
valid data points for each constituent. Exceedances of the mterim 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 Q4 sampling events.
A plan and schedule to address the Q4 exceedances is not necessary and is not being submitted
because exceedances have been addressed in the SAR which was submitted to DRC on October
10, 2012. An additional plan or schedule to address the Q4 exceedances is not necessary and is
not being submitted because the assessment processes and schedule have not changed since the
October 10, 2012 submission. It should be noted that background has not yet been established for
MW-35 and that 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 in 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 selenium concentration exceeded the GWCL in MW-35 in the October and Q4 (November)
sampling events. A plan and schedule to address the Q4 exceedances is not necessary and is not
being submitted because exceedances have been addressed in the SAR which was submitted to
DRC on October 10, 2012. An additional plan or schedule to address the Q4 exceedances is not
necessary and is not being submitted because the assessment processes and schedule have not
changed since the October 10, 2012 submission. It should be noted that background has not yet
been established for MW-35 and that 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 in the second quarter 2013 pending
Letter to Mr. Rusty Lundberg
February 15, 2013
Pages
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 thallium concentration exceeded the GWCL in MW-35 in the October and Q4 (November)
sampling events. A plan and schedule to address the Q4 exceedances is not necessary and is not
being submitted because exceedances have been addressed in the SAR which was submitted to
DRC on October 10, 2012. An additional plan or schedule to address the Q4 exceedances is not
necessary and is not being submitted because the assessment processes and schedule have not
changed since the October 10, 2012 submission. It should be noted that background has not yet
been established for MW-35 and that 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 in 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 Q4
Two new exceedances for the Q4 2012 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.
• Molybdenum in MW-35 exceeded the GWCL in the Q4 (November) sampling event.
• Cadmium in MW-25 exceeded the GWCL in the Q4 (November) sampling event.
Relative to accelerated reporting requirements, based on phone conversations with UDEQ on April 5,
2010, reporting of exceedances is required to be completed within 30 days of receipt of the 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 UDEQ,
EFRI proposed modified language for the GWDP, Part I.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 (Q3 and Q4).
MW-3
• Selenium has exceeded the GWCL for both the Q3 sampling event and the Q4 sampling event.
The consecutive selenium exceedances noted in MW-3 were previously addressed in the SAR
submitted to DRC on October 10, 2012. An additional plan or schedule to address the Q4
exceedances is not necessary and is not being submitted because the assessment processes and
schedule have not changed since the October 10, 2012 submission.
Letter to Mr. Rusty Lundberg
February 15, 2013
Page?
• Fluoride has exceeded the GWCL for both the Q3 sampling event and the Q4 sampling event.
The consecutive fluoride exceedances noted in MW-3 were previously addressed in the SAR
submitted to DRC on October 10, 2012. An additional plan or schedule to address the Q4
exceedances is not necessary and is not being submitted because the assessment processes and
schedule have not changed since the October 10, 2012 submission.
MW-3A
Selenium has exceeded the GWCL for both the Q3 sampling event and the Q4 sampling event.
The consecutive selenium exceedances noted in MW-3 were previously addressed in the SAR
submitted to DRC on October 10, 2012. An additional plan or schedule to address the Q4
exceedances is not necessary and is not being submitted because the assessment processes and
schedule have not changed since the October 10, 2012 submission.
MW-18
Thallium has exceeded the GWCL for both the Q3 sampling event and the Q4 sampling event.
The consecutive thallium exceedances noted in MW-18 were previously addressed in the SAR
submitted to DRC on October 10, 2012. An additional plan or schedule to address the Q4
exceedances is not necessary and is not being submitted because the assessment processes and
schedule have not changed since the October 10, 2012 submission. MW-18 is far upgradient
from the Mill site and cannot be impacted by Mill activities. It is therefore not appropriate to
establish compliance standards under the GWDP for this well. EFRI has requested in the October
10, 2012 SAR that the Director eliminate GWCLs for tiiis well.
MW-19
Nitrate + Nitrite have exceeded the GWCL for both the Q3 sampling event and the Q4 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.
MW-24
Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 sampling
event and the Q4 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012; therefore a plan and
schedule to address this consecutive exceedance is not necessary and is not bemg submitted.
MW-27
Nitrate + Nitrite have exceeded the GWCL for both the Q3 sampling event and the Q4 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.
Chloride has exceeded the GWCL for both the Q3 sampling event and the Q4 sampling event and
during previous quarters. As mentioned above, a CAP is currently being implemented to address
Letter to Mr. Rusty Lundberg
February 15, 2013
Pages
nitrate + nitrite which is expected to address chloride; 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 Q3 sampling
event and the Q4 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012; therefore a plan and
schedule to address this consecutive exceedance is not necessary and is not being submitted.
MW-29
• TDS has exceeded the GWCL for both the Q3 sampling event and the Q4 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 is currently being prepared and will be
submitted within 90 days of the February 7, 2012 receipt date; 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 Q4
Seven new exceedances for the Q4 2012 semi-annual well sampling program is listed below. These
exceedances will result in an accelerated sampling frequency from semi-annually to quarterly. It is
important to note that the wells listed below will only be sampled during the first and third quarterly
events for those constituents which exceeded the GWCLs. The wells listed below will be sampled for all
constituents listed in the GWDP during the second and fourth quarterly events as that is the regularly
scheduled sampling for the semi-annual wells.
Manganese in MW-01 exceeded the GWCL in the Q4 (November) sampling event.
Tetrahydrofuran in MW-01 exceeded the GWCL in the Q4 (November) sampling event.
Sulfate in MW-01 exceeded the GWCL in the Q4 (November) sampling event.
Nitrate+nitrite m MW-03A exceeded the GWCL in the Q4 (November) sampling event.
Gross alpha in MW-19 exceeded the GWCL in the Q4 (November) sampling event.
Fluoride in MW-24 exceeded the GWCL in the Q4 (November) sampling event.
Field pH in MW-25 was below the GWCL in the Q4 (November) sampling event.
Relative to accelerated reporting requirements, based on phone conversations with UDEQ on April 5,
2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data
package for a quarterly monitoring event. Similarly, accelerated monitoring is required to conmience 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 UDEQ,
EFRI proposed modified language for the GWDP, Part I.G.l on May 25, 2012, to document DRC
concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012
teleconference.
Letter to Mr. Rusty Lundberg
February 15, 2013
Page 9
If you have any questions or require any further information, please contact the undersigned.
Yoursimly, /
c iler
Manager of jCompliance and Licensing
David Frydenlund
Harold Roberts
David Turk
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