DRC-2014-002802 - 0901a0688042798d

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Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
April 10, 2014
CERTIFIED MAIL
(Return Receipt Requested)
Kathy Weinel, Quality Assurance Manger
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc
of Nitrate Contaminated Soils Phase
DRC Request for Information
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DRC-2014-002802
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PS Form 380
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
December 23, 2013, Proposal for Remediation
I of Final Nitrate Corrective Action Plan:
Dear Ms. Weinel:
DRC has completed review of the Energy Fuels Resources (USA) Inc. ("EFR") December 23,
2013 White Mesa Uranium Mill, Proposal for Remediation, Phase I of Nitrate Corrective Action
Plan Ammonium Sulfate Crystal Tank Cover ("Phase I Report").
Per the approved CAP, EFR was required to sample and bound nitrate and ammonia
concentrations in soil according to the calculation of Background + 2o; (as determined during the
nitrate source investigation activities). Specifically those concentrations were:
Ammonia - 4.29 mg/kg ammonia (as N)
Nitrate - 4.38 mg/kg nitrate (as N)
Sample results obtained indicated that nitrate concentrations in soil extended farther beyond the
ammonium sulfate crystal tanks than anticipated, and per the Phase I Report it was determined
that concentrations beyond a certain point could not be attributed to the ammonium sulfate crystal
tanks. This determination was based on the Energy Fuels Resources justification that nitrate soil
contamination from the ammonium sulfate crystal tank would be found in association with
ammonia, since in the case of ammonia sulfate crystal dissolution, the nitrate concentrations are
derived through oxidation of ammonia.
The southwest to northeast cross section shows a combination of contaminants plume (ammonia
and nitrate) extending approximately to boring P4A-05. The EFR proposed Phase I cover is
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
delineated to cover this area, however, using this method is negating other areas with significant
soil nitrate concentrations as depicted on surface contour maps (shallow, middle and deep), e.g. 50
mg/kg in the shallow core sample P7C-03 which may contribute to groundwater contamination.
According to DRC review of the soil sampling results it was noted that significantly higher nitrate
concentrations were found in nearer vicinities of the ammonia crystal sulfate tanks than at areas
farther away (without associated ammonia concentrations). These findings are supported by
Figures 3-1 A, 3-2A and 3-3A of the Phase I Report. Figure 3-1A {Shallow Nitrate
Concentrations) depicts nitrate concentrations with a concentration center at the ammonium
sulfate crystal tanks and decreasing with distance from that location.
Nitrate concentrations extend northeast from the ammonium sulfate crystal tanks toward the area
of the grizzly with relatively high concentrations extending as far northeast as P9C-01
(12.4 mg/kg, Lab Sample ID 1306183-031). DRC notes that these areas are located on a sloped
area which drains south towards the mill building. In order to provide corrective action to prevent
infiltration from these areas with higher than surrounding soil nitrate concentrations, DRC
recommends that the plotted area for concrete installation be extended north to include these areas
(concrete to extend north to soil boring P9C-01) or that other engineering solutions be employed
to ensure that no surface water is impounded in this area (e.g. temporary impoundment from storm
water runoff). This would essentially address all areas with nitrate soil concentrations greater than
10 mg/kg.
Attachment 4-1 of the Phase I Study is an aerial map depicting the area of the proposed concrete
cover and areas of existing asphalt which are proposed to be left in place. Per DRC review of the
Phase I Report and proposed area of concrete cover it was noted that several improvements
regarding engineering specifications, engineering annual inspections, and additional area of
concrete cover (based on high soil concentrations of nitrate) need to be included.
It was noted during DRC inspections of the existing concrete and asphalt that significant erosion,
cracking and spalling has occurred and it has been noted during past inspections that the storm
drain located on the east side of the Mill building does not drain correctly. It appears that
drainage moves from south to north and that storm water and wash water pool around the north
portion of the drain system. Based on these findings the concrete drainage needs to be replaced or
repaired/reconstructed such that these drainage issues are corrected.
DRC also notes that grading and drainage directions relative to the proposed concrete pad need to
be included on the concrete cover plan, including the additional areas recommended for concrete
cover (or engineering controls) as discussed above. Additionally EFR needs to address drainage
from areas surrounding the concrete pad to insure that storm water does not pool in areas outside
of the concrete pad area, which would promote additional infiltration in those areas (controls to
address storm water run-on).
Per DRC review of the Phase I Report, EFR will provide grading such that drainage from the
concrete cover is interior to the mill building process drains, however, the Phase I Report does not
clearly identify how storm water and process water drainage within this area will be managed to
provide efficient drainage and ensure that ponding does not occur. Additionally, as discussed
Kathy Weinel
Page 3
above, areas of existing concrete and asphalt with are planned to be kept are in disrepair and are
incorrectly graded for efficient drainage as discussed above.
The Phase I Report needs to include the following items.
• Elevation contours for the concrete cover need to be included,
• Elevation contours for soil areas need to be included,
• Drainage direction arrows (for the concrete pad) need to be included,
• Drainage inlets and discharge locations need to be included,
• Specifications for concrete seam sealing needs to be included with the attachment
• Specifications for curbing around the margin of the concrete (or other design) needs to be
included,
• Specifications for storm water run-on control needs to be included.
Attachment 5 of the Phase I Report includes EFR redline changes to the White Mesa Mill
Discharge Monitoring Technology ("DMT") Plan for Concrete and Asphalt Inspection and
Maintenance (EFR Revision 12.2). Attachment 5 also includes changes to the DMT inspection
form for the annual decontamination /ammonium sulfate inspection to include the new concrete
cover area.
DRC had the following request for information regarding the DMT inspections:
• The frequency of the proposed DMT Plan changes is annually as included on the revised
DMT inspection form, per discussion during an April 8, 2014 conference call the
frequency needs to be quarterly (at least initially to determine concrete and seam integrity
and to insure that drainage is occurring per specifications of the plan).
Based on a conference call amongst DRC and EFR representatives on April 8, 2014 regarding the
issues/items discussed above, it was agreed that revised Phase I Report construction plans will be
submitted to DRC by May 22, 2014 to address the needed design and construction details.
If you have questions regarding this letter please contact Tom Rushing at [phone].
U:\MON_WAST\Trushing\Energy Fuels\Nitrate Corrective Action PlanU2-23-13 Phase I Report Ammonia Pad\Phase I Report DRC RFI.docx
Conclusion:
Sincerely,
RL:TR:tr