DRC-2014-007084 - 0901a068804c2a10

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
MEMORANDUM DRC-2014-007084
TO: Phil Goble, Section Manager PR.C
FROM: Dean Henderson, Hydrogeologist
DATE: April 7, 2014
SUBJECT: Review of three Reports by HYDRO GEO CHEM, INC for ENERGY FUELS
RESOURCES (USA) INC:
• Installation and Hydraulic Testing of Perched Monitoring Wells TW4-28
Through TW4-31 White Mesa Uranium Mill Near Blanding, Utah.
• Installation and Hydraulic Testing of Perched Monitoring Wells TW4-32
Through TW4-34 White Mesa Uranium Mill Near Blanding, Utah.
• Contamination Investigation Report TW4-12and TW5-27Areas White Mesa
Uranium Mill Near Blanding, Utah.
For the review of this report the following regulatory enforcement documents were used:
• EFR Ground Water Quality Discharge Permit No. UGW370004 ("Permit") on March 8,
2005; last revised on June 8, 2013.
• Nitrate Contamination Investigation. Nitrate Concentrations Exceeding the Groundwater
Quality Standard in Monitor Wells TW4-12 and TW4-27. Confirmatory Action Letter
("CAL").
Review of the report: Installation and Hydraulic Testing of Perched Monitoring Wells TW4-28
Through TW4-31 White Mesa Uranium Mill Near Blanding, Utah. ("IHT1")
On February 14, 2013 the Utah Division of Radiation Control ("DRC") sent a confirmatory action
letter ("CAL") to Energy Fuels Resources (USA) Inc. ("EFR") the required the IHT1 to have the
following:
"EFR will submit within 60 calendar days of completing well installation, an As-Built report
for wells TW4-28, TW4-29, TW4-30, TW4-31 to document said well construction for Director
approval. Said report will to need to comply with the requirements of Part LF. 6 of the
Permit. "
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.dcq.utah.gov
Printed on 100% recycled paper
Page 2
Part I.F.6 requires:
"6. Groundwater Monitoring Well As-Built Reports - as-built reports for new groundwater
monitoring wells shall be submitted for Executive Secretary approval within 60
calendar days of well completion, and at a minimum will include the following
information:
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of
all subsurface materials encountered during drilling Said logs shall be prepared
by a Professional Geologist licensed by the State of Utah, or otherwise approved
beforehand by the Executive Secretary.
b) Well Completion Diagram - that detail all physical attributes of the well
construction, including:
1) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties of well casing and screen,
including well screen slot size,
3) Depth intervals, type and physical properties of annular fdterpack and seal
materials used,
4) Design, type, diameter, and construction of protective surface casing, and
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level
measuring point, as measured to the nearest 0.01 foot.
c) Aquifer Permeability Data - including field data, data analysis, and interpretation
of slug test, aquifer pump test or other hydraulic analysis to determine local
aquifer hydraulic conductivity in each well. "
After reviewing the IHT1 it appears the report meet the requirements in the CAL with the
exception of that Mr. Lary Casebolt who was the geologist that prepared geologic logs is not
Professional Geologist licensed by the State of Utah. However, DRC staff Mr. Dean Henderson
has witnessed Mr. Casebolt geologic logging abilities in the field for the drilling and installation
of wells TW4-28 and TW4-29 and feel his logging skills are professional and acceptable and
meets Part I.F.6(a) of the Permit (DRC Memorandum, March 25, 2013).
Review of the Report: Installation and Hydraulic Testing of Perched Monitoring Wells TW4-32
Through TW4-34 White Mesa Uranium Mill Near Blanding, Utah ("IHT2").
EFR sampled monitor wells TW4-28, TW4-29, TW4-30, and TW4-31 in the 2nd quarter of 2013
monitoring event. In a conference call EFR reported that TW4-29, TW4-30, and TW4-31 had
nitrate concentrations below 10 mg/l. However, TW4-28 had a nitrate concentration of 14.9 mg/l
and TW4-29 had a unexpected chloroform concentration of 262 ug/l. Based on these findings it
was agreed that one (TW4-32) additional well would be installed down gradient of TW4-28 to
continue the nitrate investigation and two (TW4-33 and TW4-34) additional wells would be
installed in the vicinity of TW4-29 to investigate the chloroform plume. The above results were
Page 3
also submitted to DRC a July 29, 2013 letter report: Utah Groundwater Discharge Permit
("GWDP") UGW370004 Follow-up and response to February 14, 2013 Confirmatory Action
Letter
After reviewing the IHT2 it appears the report meets the same requirements in the CAL as stated
above for the IGT1.
Review of the Report: Contamination Investigation Report TW4-12 and TW5-27Areas White
Mesa Uranium Mill Near Blanding, Utah. ("CIR")
The CAL required the following of the CIR:
"5) On or within 60 calendar days of receipt of receiving the analytical data for the 2nd
quarter of 2013 new wells sampling, EFR will submit a Contamination Investigation
Report (CIR) that will include the following, but is not limited to:
• Interpretation of analytical data, groundwater levels, gradients, flow directions, and
well hydraulic properties.
• Copies of EFR field records, laboratory reports and chain of custody forms
• Identification of all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples.
• Groundwater contour and nitrate isoconcentration map with one of the
isoconcentration lines showing the 10 mg/L boundary.
• A discussion of the potential source(s) of the nitrate observed in well TW4-27 and any
nitrate above 10 mg/l in the newly installed wells.
• Conclusions and recommended path forward. "
After reviewing the CIR, it appears the report meets the requirements in the CAL including an
additional chloroform investigation not mentioned in the CAL.
CIR Conclusions and Recommendations for Nitrate at TW4-12 Followed by DRC Response
Conclusions: "Nitrate exceeding 10 mg/L at TW4-12 (and TW4-28) is bounded by
concentrations belowlO mg/L at wells TW4-3, TW4-13, and TW4-32. TW4-32 is downgradient
ofTW4-12and TW4-28, and TW4-3 is cross-gradient ofTW4-12. TW4-13 appears to be
located in a direction generally downgradient to cross-gradient ofTW4-12. "
Recommendations: "Nitrate at TW4-12 and TW4-28 is interpreted to originate potentially
from sources likely related to former cattle ranching operations. Increasing concentrations in
this area are expected to result from reduced dilution caused by cessation of water delivery to
the northern wildlife ponds. Because of the expected containment within the eastern property
boundary (Figure 7), and the expected mitigating impact of natural attenuation, no action
at the present time other than continued monitoring is considered reasonable and is
recommended. Should nitrate concentrations exceed 10 mg/L at TW4-32 (located
Page 4
immediately downgradient of TW4-28), alternate action will be taken that will likely
include installation of additional wells to bound the nitrate. "
DRC Response
There is not enough evidence/data to support that the likely source of nitrate at wells TW4-12 and
TW4-28 is from former cattle ranching operations. Therefore, because of the proximity of the
chloroform plume to TW4-12 and TW4-28 the source of nitrate is more likely come from the
chloroform plume. It does appear that nitrate exceeding 10 mg/L at wells TW4-12 and TW4-28 is
bounded by nitrate concentrations belowlO mg/L at wells downgradient and cross-gradient of
TW4-12 and TW4-28. Therefore, DRC agrees that the only action necessary at this time is
continued quarterly monitoring. Should nitrate concentrations exceed 10 mg/L at TW4-32
(located immediately downgradient of TW4-28), action taken will include installation of
additional well(s) to bound the nitrate plume.
CIR Conclusions and Recommendations for Nitrate at TW4-26 Followed by DRC Response
Conclusions: "Nitrate exceeding 10 mg/L at TW4-26 is bounded by concentrations below 10
mg/L at wells TW4-6, TW4-23, TW4-29, TW4-33, and TW4-34. TW4-29 is downgradient of
TW4-26; TW4-23 is upgradient ofTW4-26; and TW4-6, TW4-33 and TW4-34 are
crossgradient of TW4-26. "
Recommendations: "Because nitrate at TW4-26 is interpreted to originate from a localized
source likely the result of former cattle ranching operations, and is expected to be mitigated
by natural attenuation, no action at the present time other than continued monitoring is
consideredreasonable and is recommended. Should nitrate concentrations exceed 10 mg/L at
downgradient wells (first TW4-29 and then TW4-30), or cross-gradient well TW4-34,
alternate action will be taken that will likely include the installation of additional wells to
bound the nitrate."
DRC Response
There is not enough evidence/data to support that the likely source of nitrate at well TW4-26 is
from former cattle ranching operations. Therefore, because of the proximity of the chloroform
plume to TW4-26 the source of nitrate is more likely come from the chloroform plume. It does
appear that nitrate exceeding 10 mg/L at wells TW4-26 is bounded by nitrate concentrations
below 10 mg/L at wells downgradient and cross-gradient of TW4-26. Therefore, DRC agrees that
the only action necessary at this time is continued quarterly monitoring. Should nitrate
concentrations exceed 10 mg/L at TW4-29 or TW4-34 (located downgradient of TW4-26) action
taken will include installation of additional well(s) to bound the nitrate plume.
CIR Conclusions and Recommendations for Nitrate at TW4-27 Followed by DRC Response
Conclusions: "Nitrate exceeding 10 mg/L at TW4-27 is bounded by concentrations below 10
mg/L at wells TW4-14, TW4-29, TW4-30, TW4-31, andTW4-33. TW4-31 is downgradient of
TW4-27; TW4-33 is upgradient ofTW4-27; and TW4-14, TW4-29, and TW4-30 are
Page 5
cross-gradient ofTW4-27. "
Recommendations: "Because nitrate at TW4-27 is migrating slowly due to low permeability
conditions, is interpreted to originate from a localized source likely the result offormer cattle
ranching operations, and is expected to be mitigated by natural attenuation, no action at the
present time other than continued monitoring is considered reasonable and is recommended.
Contamination Investigation Report should nitrate concentrations exceed 10 mg/L at TW4-31
(located immediately downgradient ofTW4-27), or cross-gradient wells TW4-29 or TW4-30,
alternate action will be taken that will likely include installation of additional wells to bound
the nitrate. "
DRC Response
There is not enough evidence/data to support that the likely source of nitrate at well TW4-27 is
from former cattle ranching operations. Therefore, because of the proximity of the chloroform
plume to TW4-27 the source of nitrate is more likely come from the chloroform plume. It does
appear that nitrate exceeding 10 mg/L at wells TW4-27 is bounded by nitrate concentrations
belowlO mg/L at wells downgradient and cross-gradient of TW4-27. Therefore, DRC agrees that
the only action necessary at this time is continued quarterly monitoring. Should nitrate
concentrations exceed 10 mg/L at TW4-29, TW4-30 or TW4-31 (located downgradient and cross-
gradient of TW4-27) action taken will include installation of additional well(s) to bound the
nitrate plume.
CIR Conclusions and Recommendations for Chloroform at TW4-29Followed by DRC
Response
Conclusions: "Chloroform exceeding 70 fig/L at TW4-29 is bounded by concentrations below
70ug/L at wells TW4-26, TW4-27, TW4-30 and TW4-34. TW4-30 is downgradient ofTW4-29;
TW4-26 is upgradient ofTW4-29; and TW4-27 and TW4-34 are cross-gradient ofTW4-
29.
Chloroform concentrations at TW4-33 that are lower than concentrations at TW4-29, and
the likelihood that a pathway exists from TW4-4 to TW4-33 to TW4-29, suggests that
concentrations in the vicinity of TW4-33 were likely higher prior to initiation ofTW4-4
pumping, and that lower concentrations currently detected at TW4-33 are due to its closer
proximity to TW4-4."
Recommendations: "At present, no action for TW4-29 chloroform other than continued
pumping ofTW4-4 and continued monitoring is considered reasonable and is recommended.
Concentrations at TW4-29 and TW4-33 are expected to diminish under the influence ofTW4-4
pumping by analogy with the concentration behavior at TW4-6 and TW4-26 (Figure 10).
Should chloroform concentrations greater than 70 pLg/L impact downgradient wells (TW4-30
andTW4-31), or cross-gradient well TW4-34, alternate action will be taken that will likely
include installation of additional wells to bound the chloroform. "
Page 6
DRC Response
Copies of two maps from the CIR: 1) Kriged 4th Quarter, 2013 Perched Water Elevations
Showing Inferred Path lines, Figure 7["Figure 7"] and 2) Kriged 4th Quarter, 2013 Chloroform
(ug/L) In The CIR Focus Area With 70 ug/L Isocon Adjusted By Hand, Figure 9b ["Figure 9b"]
are included in Attachment 1.
The DRC feels that chloroform plume in the vicinity of TW4-29 has a wider extent as shown in a
DRC hand drawn red doted 70 pg/L isoconcentration line than the white 70 ug/L isoconcentration
line shown in Figure 9b. Although in Figure 7 the groundwater contour lines show that well
TW4-30 is downgradient of well TW4-29, because of the extent of the chloroform plume it may
continue to migrate through the gap between the well TW4-34 and TW4-30. Therefore, there
needs to be at least one more monitor well to bound the chloroform plume located half way
between well TW4-30 and TW4-34 and 200 feet southeast of TW4-29 (see hand draw location in
red on map in Attachment 1).
Page 7
References
Energy Fuels Resources (USA) Inc., July 29, 2013, Utah Groundwater Discharge Permit
("GWDP") UGW370004 Follow-up and response to February 14, 2013 Confirmatory Action
Letter. (DRC-2013-002911)
Hydro Geo Chem, Inc., April 30, 2013, Installation and Hydraulic Testing of Perched Monitoring
Wells TW4-28 Through TW4-31 White Mesa Uranium Mill Near Blanding, Utah.. (DRC-2013-
002151)
Hydro Geo Chem, Inc., October 30, 2013, Installation and Hydraulic Testing of Perched
Monitoring Wells TW4-32 Through TW4-34 White Mesa Uranium Mill Near Blanding, Utah..
(DRC-2013-003408)
Hydro Geo Chem, Inc., January 23, 2014, Contamination Investigation Report TW4-12and TW5-
27Areas White Mesa Uranium Mill Near Blanding, Utah. (DRC-2014-001301)
State of Utah Division of Water Quality, Energy Fuels Resources (USA) Inc., Ground Water
Quality Discharge Permit No. UGW370004 ("Permit") on March 8, 2005; last revised on June 8,
2013. . (DRC-2013-001822)
Utah Division of Radiation Control, March 25, 2013, Memorandum: Drilling Activities Nitrate
Contamination Investigation in the Vicinity of Monitor Wells TW4-12 and TW4-27 at the White
Mesa Mill near Blanding, Utah, Energy Fuels Resources (USA) Inc. (DRC-2013-001822)
Utah Division of Radiation Control, February 14, 2013, Nitrate Contamination Investigation.
Nitrate Concentrations Exceeding the Groundwater Quality Standard in Monitor Wells TW4-12
and TW4-27. Confirmatory Action Letter. (DRC-2013-001324)
Page 8
Attachment 1
Kriged 4th Quarter, 2013 Perched Water Elevations Showing Inferred Path lines, Figure 7
Kriged 4th Quarter, 2013 Chloroform (ug/L) In The CIR Focus Area With 70 ug/L Isocon
Adjusted By Hand, Figure 9b
PIEZ-02
r T " all
•
ft TW4-25
TWN-01
DNS IEZ-03
TW4-2"
• Q2€l
0%|fyrW4-19
. , 0942
TW4-18 i
TW4-05
O
TW4-09
O
'4-10 TW4-03
O BO OND
MW-26
•1220 TW4-12
OND
•BP OTW4 28
4 .. 1 ND TW4 32
ND
x - • : 174 2^6. TW4-13
OND TW4-02
'' _' 037,40.
^1410 MW-04
TW4-07O* OTW4-08
1U50 TW4-01
O1280 M
1
TW4-04
Sri TW4-14
OND
°t I TW4-33
* # TW4-27
• I 126 O OTW4-31
X ND ND
TVV4^6, TW4-29 OTW4-30
^ *K O , ND
W4-23
OND
260/
*-«.<t /T\ -
TW4-34
ND
/6
ttB
PIEZ-04
A
1000 feet
MW-4
• 1410
TW4-1
o
PIEZ-2
e NS
TW4-32
EXPLANATION
ND = not detected; NS = not sampled
kriged chloroform isocon and label
hand drawn chloroform isocon
perched monitoring well showing
concentration in ug/L
temporary perched monitoring well
showing concentration in ug/L
perched piezometer showing
concentration in ug/L
temporary perched monitoring well
installed September, 2013 showing
concentration in ug/L
NOTE: MW-4, MW-26, TW4-4, TW4-19, and TW4-20 are chloroform pumping wells;
TW4-25 is a nitrate pumping well
HYDRO
GEO
CHEM, INC.
KRIGED 4th QUARTER. 2013 CHLOROFORM (ug/L)
IN THE CIR FOCUS AREA
WITH 70 ug/L ISOCON ADJUSTED BY HAND
REFERENCE
H:/718000/nitrateast/CIR/CIRchlh.srf 9b
P EZ
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M 26 TW4 TTO 10 55 03 4 O o 5580 fo
CO 55
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TW 62
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23 Or
552? W4 553 0 543 27
W4 26 W4 30 O G5539 O 526 534
T 34
5534
P EZ 04
5541 5525 05 isSB o CO to
/ EXPLANATION 1000 feet
/ /
nferred perched
water pathlines
MW-4
• 5553
TW4-1
OS554
PIEZ-2
9 5595
TW4-32
#5564
perched monitoring well showing
water level in feet amsl
temporary perched monitoring well
showing water level in feet amsl
perched piezometer showing
water level in feet amsl
temporary perched monitoring well
installed September, 2013 showing
water level in feet amsl
NOTE: MW-4, MW-26. TW4-4, TW4-19, and TW4-20 are chloroform pumping wells:
TW4-25 is a nitrate pumping well
HYDRO
GEO
CHEM, INC.
KRIGED 4th QUARTER, 2013
PERCHED WATER ELEVATIONS
SHOWING INFERRED PATHLINES
REFERENCE H7718000/
nitrateast/CIR/CIRwl_path.srf 7