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Home My WebLink AboutDRC-2013-001082 - 0901a0688033fb8cEnergy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www energyfuels com 2013-001082 January 11,2013 ^ _ DRC Sent VIA E-MAIL AND OVERNIGHT DELIVERY Mr Rusty Lundberg Director of the Utah Division of Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P O Box 144850 Salt Lake City, UT 84114-4820 Re: Stipulated Consent Order Docket No. UGW12-04, Regarding Energy Fuels Resources (USA) Inc. May 7,2012 Corrective Action Plan ("CAP') for Nitrate, White Mesa Uranium Mill, Operations and Maintenance Plan, Nitrate Pumping System Dear Mr Lundberg Consistent with the Stipulated Consent Order Docket No UGW12-04, Part D 1, and the Nitrate Corrective Action Plan, Section 7 2 2, Energy Fuels Resources (USA) Inc ("EFRI") is submitting the Operations and Maintenance Plan, Nitrate Pumping System, Revision 1 0 If you should have any questions regarding this plan please contact me Yours very truly. ENERGY FUELS RESOURCES (USA) INC. Jo Ann Tischler Manager, Compliance and Licensing CC David C Frydenlund Harold R Roberts David E Turk Kathy Wemel N Tanner HoUiday Garrm Palmer Dan HiUsten White Mesa Mill Operations and Maintenance Plan Nitrate Pumping System Revision 1.0 State of Utah Stipulation and Consent Order Docket Number UGW 12-04 Prepared by. Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 January 11,2013 Table of Contents 10 INTRODUCTION 1 2 0 OPERATIONS 2 21 Groundwater Pumping .... . . .... 2 2 2 Water Level Monitoring . . . . . 2 2.3 Water Quality Monitoring . ..... 2 3 0 WINTERIZATION FOR LONG-TERM OPERATIONS 2 4 0 MAINTENANCE . .3 5.0 MONITORING AND REPORTING 4 operations and Maintenance Plan Nitrate Pumping System Revision 1 0 January 11,2013 1.0 INTRODUCTION The Utah Department of Environmental Quality ("UDEQ") Division of Radiation Control ("DRC") noted m a Request dated September 30, 2008 (the "Request"), for a Voluntary Plan and Schedule to Investigate and Remediate Nitrate Contamination at the White Mesa Uranium Mill (the "Mill") (the "Plan"), that nitrate levels have exceeded the State water quality standard of 10 mg/L in certain monitonng wells in the perched groundwater zone As a result of the Request, Energy Fuels Resources (USA) Inc ("EFRI") entered into a Stipulated Consent Agreement (the "Consent Agreement") with the Utah Water Quality Board in January 2009 which directed the preparation of a Nitrate Contamination Investigation Report ("CIR") A subsequent letter dated December 1, 2009, among other things, recommended that EFRI also address elevated chloride concentration in the CIR The Consent Agreement ("CA") was amended m August 2011 Under the amended Consent Agreement, EFRI submitted a Corrective Action Plan ("CAP"), pursuant to the requirements of the Utah Groundwater Quality Protection Rules [UAC R317-6-6 15(C - E)] on November 29, 2011 and revised versions of the CAP on February 27, 2012 and May 7, 2012. On December 12, 2012, DRC signed the Stipulation and Consent Order ("SCO"), Docket Number UGW12-04, which approved the EFRI CAP, dated May 7, 2012 The SCO ordered EFRI to fully implement all elements of the May 7, 2012 CAP The CAP addresses nitrate + nitrite (as nitrate) (heretofore referred to as "nitrate") contanunation in the shallow perched groundwater zone at the Mill site. It should be noted that while the CAP requires monitoring of chloride concentrations, the CAP does not specify measures for controlling chlonde levels per se, because there is no health standard for chlonde in groundwater However, as discussed and agreed to with DRC dunng meetings in October 2011, chloride appears to be co-located with nitrate in groundwater at the Mill and hydrogeological measures to contain nitrate will also contain chloride The CAP descnbes a phased approach to the nitrate corrective actions The Phases descnbed in the CAP are as follows • Phase I will involve source control in the vicinity of the Mill's ammonium sulfate tanks, • Phase n will involve active remediation of the nitrate contamination by pumping contaimnated water into the Mill's tailings cells for disposal, combined with monitored natural attenuation, • Phase ni, if necessary, will be at the discretion of EFRI and would involve a long term solution for the nitrate contamination, in the event that the continuation of Phase EL is not considered adequate or appropnate Phases I and n are addressed in the CAP and will commence as required by the schedule delineated in the CAP. Phase m is not covered in detail in the CAP and, if determined to be necessary, will be addressed in a separate CAP revision. Operations and Maintenance Plan Nitrate Pumping System Revision 1 0 January 11,2013 This Operations and Maintenance ("O&M") Plan has been prepared to meet the requirements of Phase n as descnbed in the CAP, Section 7 2.2 to address operations (including wintenzation procedures), maintenance (including inspection forms and response to and documentation of system failures), monitoring and data reporting. 2.0 OPERATIONS 2.1 Groundwater Pumping Wells TW4-22, TW4-24, TW4-25, and TWN-2 will be pumped at the maximum practical rates Pumped water will be disposed in the tailings cells The wellfield will be maintained as noted herein. Monitonng will include pumping rates and volumes for each well Monitoring will be documented on the Weekly Inspection Form included as Attachment A to this O&M Plan 2.2 Water Level Monitoring Water level monitoring will consist of weekly water level monitoring of pumping wells TW4-22, TW4-24, TW4-25, and TWN-2, and, for the first twelve months after approval of the CAP, monthly water level monitonng of non-pumped wells MW-27, MW-30, MW-31, TW4-21, TWN-1, TWN-3, TWN-4, TWN-7, and TWN-18 Thereafter, water level monitonng of the non- pumpmg wells will continue quarterly Water level monitonng will be documented on the Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A and B to this O&M Plan Water level contour maps of the data will be generated quarterly 2.3 Water Quality Monitoring Water quality monitonng for pumped wells TW4-22, TW4-24, TW4-25, and TWN-2 will be quarterly. Samples will be analyzed for nitrogen (nitrate and nitrite as N) and chlonde Field parameters will be recorded dunng the sampling as descnbed in the Mill's DRC-approved Groundwater Quality Assurance Plan ("QAP") Water quality momtonng will be reported and documented in the quarterly nitrate reports submitted as descnbed in Section 5 0 of this O&M Plan Water quality monitoring for nitrate, chlonde, and field parameters for all other wells at the site will continue at the frequency required under the Groundwater Discharge Permit ("GWDP") or chloroform investigation, as applicable 3.0 W^INTERIZATION FOR LONG-TERM OPERATIONS The following actions are implemented to provide continuous operations of the pumping well system at the White Mesa Mill dunng cold weather conditions 1) Protective boxes are placed around the wellheads of the pumping wells The protective boxes are lined with insulating foam and heat lamps are installed to maintain the interior of the box at a temperature above freezing dunng the winter months Winter months are generally defined as the months of November operations and Maintenance Plan Nitrate Pumping System Revision 1 0 January 11,2013 through March, but wintenzation of the pumping wells is maintained at any time the outside air temperature is forecast to fall below 20° F for a duration of one (1) day or more. 2) The pump discharge from each of the pumping wells is connected to a 2-inch polypropylene drain line, which discharges to Cell 1 This line is placed in an excavated trench and the lines are covered with a minimum of 3 feet of soil to prevent freezing dunng the winter months 3) During winter weather with potentially freezing conditions (i e less than 20*^), the radiation safety department staff observe the pumping daily to verify that the heat lamps remain functional The Mill maintenance department is immediately notified if anj^hmg unusual is noted with the system, or if a specific well has encountered a problem 4) The protective features, discharge line placement and winter inspections described in Items 1), 2), or 3) above will apply to not only the pumping wells currently in operation, but will apply also to any future pumping wells associated with the nitrate pumping system. 4.0 MAINTENANCE The operation of each of the pumping wells is monitored on a daily basis during the winter under potentially freezing conditions by the Environment, Health and Safety Department Any malfunction or abnormal operation of the pumping wells is immediately reported to the Environment, Health and Safety Manager Environment, Health and Safety Department personnel will penodically inspect the pumps, flow meters and operational controls and perform preventative maintenance to reduce the frequency of unscheduled down time of the pumping system Spare pumps are maintained m the Mill warehouse If a pump is replaced in any of the wells a new spare is promptly ordered When a system failure occurs and is not repaired and fully made operational within 24 hours of discovery, EFRI will call the Director of the Division of Radiation Control ("Director") to verbally report the system failure and will report to the Director in a written report within 5 days of the failure Each written subnussion shall contain the following information a) A description of the pumping system failure(s) and their root causes b) The period of time that the system was not or will not be in operation c) The date by which the pumping system will be repaired and fully operational, d) Steps taken or that will be taken to repair and have the system fully operational, e) Steps taken or that will be taken to eliminate and prevent reoccurrence of system failure (s) In addition, all system failures will be reported in the next quarterly nitrate monitonng report Operations and Maintenance Plan Nitrate Pumping System Revision 1.0 January 11,2013 5.0 MONITORING AND REPORTING Monitonng of the system by the Mill's Environment, Health and Safety Department occurs weekly other than as noted above except for cold weather checks which are done daily dunng freezing weather Monitoring includes well depths, flow rates, pump operating times and gallons pumped These items are recorded on a weekly basis on the Weekly Inspection Report included as Attachment A to this Plan On a quarterly basis, the nitrate investigation wells designated in the CAP are sampled for nitrate and chlonde These data, including copies of chain of custody forms and laboratory analytical reports are included in the Quarterly Nitrate Reports, and are reported to the DRC according to the following schedule. First Quarter - June 1 Second Quarter - September 1 Third Quarter - December 1 Fourth Quarter - March 1 In addition to the quarterly sampling information, the nitrate pumping system information specified in the CAP will be included in the quarterly reports 4 ATTACHMENT A Weekly Inspection Form Date Weekly Inspection Form Name Time Well Depth^ Comments Svstem Operational (if no note any problems/corrective actions) MW-4 Flow Yes No Meter Yes No MW-26 Flow Yes No Meter Yes No TW4-19 Flow Yes No Meter Yes No TW4-20 Flow Yes No Meter Yes No TW4-4 Flow Yes No Meter Yes No TWN-2 Flow Yes No Meter Yes No TW4-22 Flow Yes No Meter Yes No TW4-24 Flow Yes No Meter Yes No TW4-25 Flow Yes No Meter Yes No Operational Problems (Please list well number) Corrective Action(s) Taken (Please list well number) Depth IS measured to the nearest 0 01 feet ATTACHMENT B Monthly Depth Check Form Monthly Depth Check Form Date Name Time Well Depth* Time Well Depth^ MW-4 TWN-1 TW4-1 TWN-2 TW4-2 TWN-3 TW4-3 TWN-4 TW4-4 TWN-7 TW4-5 TWN-18 TW4-6 MW-27 TW4-7 MW-30 TW4-8 MW-31 TW4-9 TW4-10 TW4-11 TW4-12 TW4-13 TW4-14 TW4-15 TW4-16 TW4-17 TW4-18 TW4-19 TW4-20 TW4-21 TW4-22 TW4-23 TW4-24 TW4-25 TW4-26 TW4-27 Comments: (Please note the well number for any comments) Depth is measured to the nearest 0.01 feet