DRC-2014-007101 - 0901a068804c45c8

ENERGYFUELS
DRC-2014-007101
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyruels.com
December 4, 2014
Sent VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit
UGW370004 Part I.G.4 (d) White Mesa Mill (the "Mill")
Dear Mr. Lundberg:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI's") Plan and Time Schedule
pursuant to State of Utah Groundwater Discharge Permit UGW370004 (the "Permit") Part I.G.4(d) for
Violations of Part I.G.2 of the Permit. Part I.G.2 of the Permit provides that out-of-compliance
("OOC") status exists when the concentration of a pollutant in two consecutive samples from a
compliance monitoring point exceeds a groundwater compliance limit ("GWCL").
On November 14, 2014, EFRI submitted a letter to the Director under Part I.G.I (a) of the Permit
providing notice that the concentrations of specific constituents in groundwater monitoring wells at the
Mill exceeded their respective GWCL's for the 3rd quarter of 2014 and indicating which of those
constituents had two consecutive exceedances during that quarter. This Plan and Time Schedule
addresses constituents requiring a Plan and Time Schedule for the 3rd quarter of 2014.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C Frydenlund
Harold R. Roberts
David E. Turk
Scott Bakken
Dan Hillsten
WHITE MESA MILL
State of Utah Ground Water Discharge Permit UGW370004
Plan and Time Schedule
Under Part I.G.4 (d)
For
Violations of Part I.G.2 for Constituents in the Third Quarter of 2014
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
December 4, 2014
1
1. INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the
"Mill"), located near Blanding Utah, under State of Utah Ground Water Discharge Permit
UGW370004 (the "Permit").
This is the plan and time schedule (the "Plan") required under Part I.G.4(c) of the Permit relating
to violations of Part I.G.2 of the Permit for the 3rd quarter of 2014. Part I.G.2 of the Permit
provides that out-of-compliance status exists when the concentration of a pollutant in two
consecutive samples from a compliance monitoring point exceeds a groundwater compliance
limit ("GWCL") in Table 2 ofthe Permit.
The Permit was originally issued in March 2005, at which time GWCLs were set on an interim
basis, based on fractions of State Ground Water Quality Standards or the equivalent, without
reference to natural background at the Mill site. The Permit also required that EFRI prepare a
background groundwater quality report to evaluate all historic data for the purposes of
establishing background groundwater quality at the site and developing GWCLs under the
Permit.
As required by then Part I.H.3 of the Permit, EFRI submitted the following to the Director of the
State of Utah Division of Radiation Control (the "Director"):
• A Revised Background Groundwater Quality Report: Existing Wells For Denison Mines
(USA) Corp. 's Mill Site, San Juan County, Utah, October 2007, prepared by ENTERA,
Inc. (the "Existing Wells Background Report");
• A Revised Addendum: — Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s Mill Site, San Juan County, Utah, November 16, 2007,
prepared by ENTERA, Inc. (the "Regional Background Report"); and
• A Revised Addendum: -- Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp. 's Mill Site, San Juan County, Utah, April 30, 2008, prepared
by INTERA, Inc. (the "New Wells Background Report, and together with the Existing
Wells Background Report and the Regional Background Report, the "Background
Reports").
Based on a review of the Background Reports and other information and analyses the Director
re-opened the Permit and modified the GWCLs to be equal to the mean concentration of
background for each constituent on an intrawell basis plus two standard deviations or the
equivalent. The modified GWCLs became effective on January 20, 2010.
Part I.G.4 c) of the GWDP states, with respect to exceedances of GWCLs, "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 insure
2
that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT
will be reestablished." Pursuant to this requirement, EFRI has submitted eight Plans and Time
Schedules and associated Source Assessment Reports ("SARs") to address previous dual
exceedances (as required in light of other actions currently being undertaken by EFRI and as
determined by DRC Staff and stated in teleconferences with EFRI on April 27 and May 2, 2011).
2. CONSTITUENTS AND WELLS SUBJECT TO THIS PLAN
The following constituent has been identified in one well in the 3rd Quarter 2014 Exceedance
Notice as being in out-of-compliance status under Part I.G.2 of the Permit:
Table 1
Constituent and Well Subject to this Plan
Constituent Monitoring Event POC Well GWCL Result
Uranium 2nd Quarter 2014
3rd Quarter 2014
MW-28 4.9 pg/L 61.3 u:g/L
10.6 pg/L
It should be noted that the 3rd Quarter 2014 Exceedance Notice identifies a number of wells with
consecutive exceedances of Nitrate + Nitrite and/or Chloride, Chloroform and Dichloromethane,
and pH (less than the respective GWCLs for pH) in a number of wells. However, none of those
constituents are included in this Plan, for the reasons stated in the 3rd Quarter 2014 Exceedance
Notice. Chloroform and Dichloromethane are associated with the Chloroform Plume, and the
August 23, 1999 DRC Notice of Violation and Groundwater Corrective Action Order. Nitrate +
Nitrite and Chloride are associated with the Nitrate/Chloride plume, and are currently covered by
the December 12, 2012 Stipulation and Consent Order. With respect to pH, EFRI and DRC
entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. The SCA required
the completion of the pH Report and the Pyrite Investigation and associated report. The pH
Report and Pyrite Investigation Report were submitted November 9, 2012 and December 7, 2012
respectively. By letter dated April 25, 2013, DRC accepted the conclusions that the out-of-
compliance results for pH are due to background effects within the aquifer matrix and are not
caused by Mill activities.
3. CATEGORIES FOR ANALYSIS
Previously EFRI has categorized wells and constituents in several categories as follows:
• Constituents Potentially Impacted by Decreasing pH Trends Across the Site
• Newly Installed Wells with Interim GWCLs
• Constituents in Wells with Previously Identified Rising Trends
• Pumping Wells
• Other Constituents
Uranium in MW-28 falls within the last category: other constituents. Assessment of uranium in
MW-28 will follow the process noted below.
3
3.1. Other Constituents
On May 28, 2014 EFRI notified DRC personnel of damage to Monitoring Well 28 ("MW-28").
The damage was noted by EFRI Environmental Staff during routine, quarterly sampling
activities. Upon arrival at MW-28, EFRI Environmental Staff noticed that there was evidence
that a vehicle had struck the outer protective metal casing of MW-28 and it was slightly bent and
leaning to the west. Inspection of the inner, 10-inch PVC protective casing and the 4-inch well
casing also showed signs of damage. The concrete seal between the 10-inch casing and the 4-
inch casing was cracked and EFRI Environmental Staff noted that the 2 inner PVC casings were
likely cracked and/or broken. Upon discovery of the damage on May 28, 2014, EFRI
Environmental Staff contacted the EFRI Quality Assurance Manager ("QAM") via text message.
The EFRI QAM notified DRC personnel in person, while at the DRC offices in Salt Lake City.
On June 2, and June 5, 2014 Environmental Staff and Bayles Exploration repaired the well and
removed the debris in the bottom of the well resulting from the damage. The Environmental
Staff then overpumped the well and removed over 4 casing volumes to redevelop the well. The
well was sampled and the routine, second quarter 2014 sample was collected on June 18, 2014.
The repair notification and report are included as Attachment 1 of this Plan.
Three new analytes were reported above the GWCL in the second quarter 2014 data. The
analytes are uranium, vanadium and cadmium. The third quarter 2014 data show a decrease in
all three constituents with vanadium and cadmium below the GWCLs. The one-time
exceedances followed by a sharp decline indicate that the exceedances were temporary and are
the result of the damage to the well and the subsequent activities undertaken to repair the casing
and clean out the debris and soils.
Per the GWDP, EFRI began accelerated monitoring in third quarter 2014 in MW-28 for those
three constituents. The third quarter 2014 MW-28 results for vanadium and cadmium are below
the GWCLs and no further action except accelerated monitoring of those constituents is required.
The uranium result dropped significantly, but remained above the GWCL in the third quarter
2014. As stated above, Part I.G.4 c) of the GWDP a Plan and Time Schedule is required for
constituents exceeding their GWCL in two consecutive monitoring periods.
4. PLAN
4.1. General
This Plan is a plan and 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, to the extent applicable, discharge minimization technology and best
available technology will be reestablished.
Given the historic results (Attachment 2), lack of previous exceedances and the analyses in the
Background Reports, EFRI believes the exceedances are temporary and are the result of the
damage to the well and the subsequent activities undertaken to repair the casing and clean out the
debris and soils.
4
Therefore, the analysis of the exceedance will be to continue monitoring MW-28 on an
accelerated schedule (from semi-annually to quarterly) for uranium, vanadium and cadmium as
required by the GWDP. Based on the sharp decline noted from second to third quarter, EFRI
anticipates that the results for cadmium and vanadium will remain below the GWCL and
uranium will fall below the GWCL. Currently, additional actions beyond accelerated monitoring
are required are not required for vanadium and cadmium because these constituents have only
exceeded their GWCL once. An assessment of the uranium results will be completed after two
more quarters of data are collected (fourth quarter 2014 and first quarter 2015). If the uranium
results continue to exceed the GWCL, EFRI will perform a video inspection of the interior of
MW-28 to investigate the possibility of additional physical damage to the well structure that may
be causing the elevated uranium results. Further actions would be determined after the video
inspection based on the results of any such inspection.
5. TIME SCHEDULE
Accelerated monitoring will continue as required. An assessment of the uranium results will be
completed after the first quarter 2015 results are received. The results of the assessment will be
included in the first quarter 2015 report submitted to DRC on or before June 1, 2015. If
additional video inspections are required based on the results from the fourth quarter 2014 and
first quarter 2015, the schedule and process for completion of the inspection will be discussed
with DRC at the time the first quarter 2015 Exceedance Notice is submitted.
Any further studies identified by the Director as being required in order to fulfill the
requirements of Part I.G.4(c) of the Permit or the Notice, will be prepared and submitted by
EFRI in accordance with a schedule to be approved by the Director.
6. CONCLUSION
As noted above and in the attached Well Repair Notification, MW-28 was struck by a vehicle
and sustained a significant amount of damage to the outer and inner casings. Repairs and clean
out of the well were completed. A large amount of soil, concrete and casing pieces were
removed from the well during the clean out, after the repairs were completed. The repair and
clean out activities were completed less than 2 weeks prior to the second quarter sample
collection. The damage, repair and subsequent clean out activities affected the well and likely
caused the exceedances noted in the second quarter as well as the repeat exceedance of uranium
in the third quarter. The sharp decline of the detections between the second and third quarter
indicates that the exceedances are temporary and are the result of disturbances resulting from the
damage, repairs and cleanout.
MW-28 has not been impacted by Mill activities and the exceedance is not the result of Mill
activities because no other constituents have been detected above their GWCLs. Mill impacts
would be seen through significant increases of the indicator parameters. No increases in the
indicator parameters were noted in the second and third quarter samples.
5
ATTACHMENT 1
Well Repair Notification for MW-28
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
July 2, 2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Energy Fuels Resources (USA) Inc. Monitoring Well Repair Notification for MW-28
at White Mesa Uranium Mill, Blanding Utah
Dear Mr. Lundberg:
On May 28, 2014, Energy Fuels Resources (USA) Inc. ("EFRI") notified Utah Division of Radiation
Control ("DRC") personnel of damage noted to Monitoring Well 28 ("MW-28"). The damage was
noted by EFRI Environmental Staff during routine, quarterly sampling activities. This letter
documents the investigation into the cause of the damage and the repairs completed.
Incident Description
• On May 28, 2014, during routine, quarterly, sampling activities, EFRI Environmental Staff
noted damage to MW-28. Upon arrival at MW-28, EFRI Environmental Staff noticed that the
there was evidence that a vehicle had struck the outer protective metal casing of MW-28 and it
was slightly bent and leaning to the west (see Photograph Number 1). Inspection of the inner,
10-inch PVC protective casing and the 4-inch well casing also showed signs of damage. The
concrete seal between the 10-inch casing and the 4-inch casing was cracked and EFRI
Environmental Staff noted that the 2 inner PVC casings were likely cracked and/or broken.
• The Environmental Staff noted that the metal casing lid was broken off (see Photograph 1) and
a portion of the dedicated pump tubing had slipped into the well. The tubing was retrieved.
When the static water level was measured, approximately 2 feet of the probe and tape were
covered with mud and debris.
Letter to Rusty Lundberg
July 2, 2014
Page 2
• Upon discovery of the damage on May 28, 2014, EFRI Environmental Staff contacted the
EFRI Quality Assurance Manager ("QAM") via text message. The EFRI QAM notified DRC
personnel in person, while at the DRC offices in Salt Lake City.
• An incident investigation was started on May 28, 2014 in response to the damage to MW-28.
Incident Investigation Results
• There was an incident on the weekend on May 17, and May 18, 2014 that involved a pickup
truck. The pickup truck was found with damage to the right passenger side bumper and rear
right tire on May 19, 2014. The bumper was dented and the fiberglass broken. The employee
in possession of the pickup truck stated that a rock had done the damage.
• Immediately upon discovery of the damage to MW-28 on May 28, 2014, the Operation
Superintendent took the damaged truck out to the well and the damage on the bumper matched
the damage on the casing. The employee was contacted for further details to discuss the latest
findings and observations.
• The employee again stated that the damage resulted from hitting a rock. Surveillance video
from May 17 through May 19, 2014 was reviewed. The video confirmed the timeframe of the
damage and indicated that the source of the damage was not a rock. The employee was
terminated.
Summary of Repairs
• On Monday, June 2, 2014 Environmental Staff and Bayles Exploration examined MW-28 to
assess the damage and determine if the well could be repaired.
• On June 2, 2014, a backhoe was used to excavate the perimeter of the well casings to expose
any damage. Damage to the outer steel protective casing, the 2-inner PVC casings, and the
sealing concrete between the 2 PVC casings was noted at approximately 3.5 feet below ground
surface ("bgs"). The broken section of all three casings was removed during the excavation
(see Photograph 2 and Photograph 3).
• Concrete chips and PVC debris fell into the well during the excavation and wedged the
dedicated pump in place.
• The dedicated pump lines were attached to the backhoe bucket in an effort to retrieve the
pump. The pump was successfully retrieved with no additional damage to the well. The pump
and all sampling lines were discarded (see Photograph 2).
Letter to Rusty Lundberg
July 2, 2014 '
Page 3
• After the pump was removed, the well opening was covered to prevent any further debris from
falling into the well (see Photograph 4).
• The 2 PVC casings and the sealing concrete were cut with a utility saw to provide a straight
edge for the repairs (see Photographs 5 and 6).
• The inner 4-inch casing was repaired using a "slip cap" to join the old casing and the new
casing (see Photographs 7 and 8). Glues and adhesives were not used when joining the casings
and slip cap.
• A new piece of 10-inch outer PVC casing was added to the well (see Photograph 9). The new
casing was joined to the old casing using a "bell joint". Glues and adhesives were not used
when joining the casings.
• Well plug (cement) was added between the 4-inch and 10-inch casing (see Photograph 10).
• A new outer steel protective casing was added.
• On June 5, 2014, Bayles Exploration removed the debris in the bottom of the well resulting
from the damage. The Environmental Staff then overpumped the well and removed over 4
casing volumes to redevelop the well (Attachment A).
• The new measuring point on the top of the casing ("TOC") was surveyed by a Registered Utah
Land Surveyor (Attachment B).
• The well was sampled and the routine, second quarter sample was collected on June 18, 2014.
If you should have any questions regarding this submittal please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
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Attachment A
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OVERPUMPING WELL DEVELOPMENT DATA
DTtO
7^ .3o
76.2S
Well Number-
Initial Depth to Bottom (0.01ft): 1 O
Initial Depth to Water (0.01ft): 7 S. ^ <~
Date Installed: Well Number: /AALO - Zff
Pump Tvpe: /Cr^>^-e^P^i Pump Rate:.
Initial Depth to Bottom (0.01ft):.
Final Depth to Bottom (0.01ft):_
Date
WIN
Time
IOCS
II ^7
1HH
Volume of
Water Removed
II
1 <j<^f
ll
pH
f rt- Z
OJJ.
\ I Casing Volume: 13.7^
Specific
Conductance
Sgg'
H2IO
Temp
15-7Z
Turbidity
lg.~7
7. ?.
"20 Jlcci'^cAs
Notes (color, clarity,
particulates etc.)
AA ^/-icXv,
OcH r^^ airy*.
7 C^klloASl
Casing Volume Calculation:
Volume (in gallons) = (h)(cf)
Where:
h = height of the water column m feet
cf = Conversion factor (2 inch = 0.1632, 3 inch = 0.3672, 4 inch = 0.6528, 6 inch = 1.4688)
Attachment B
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
850 East Highway 89A, PO Box 897
Fredonia, AZ 86022
928 643 6185. fax [phone]
www.energyfuels.com
June 12, 2014
Energy Fuels Resources (USA) Inc.
c/o Garrin Palmer
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Garrin,
Attached are the following:
1. Monitoring Wells May 2014
SURVEYOR'S CERTIFICATE
I, Michael W. Purdy a Registered Utah Land Surveyor do hereby certify that I hold a license in accordance
with title 58, chapter 22, professional engineers and land surveyors licensing act, Utah code annotated, 1953
as amended, certificate no. 334571.1 further certify that these reports correctly show a survey made under my
direct supervision.
Energy Fuels Resources - Monitoring WeU Information - June 2014
Coordinate Syitem: Modified Utah State Plane - NAD83 - South Zone - US Survey Feet
Well*
Using Fisher Survey Verticil Datum
Northing Eaitlng Top Casing Elev. Ground Elev.
MW-28 10164465.69 2217615.744 5619.78 5618 33
ATTACHMENT 2
Historic Results for MW-28
MW-28 Historical Data
Parameter Name Date Sampled
Report
Result Report Units
Lab
Qualifier
Cadmium
6/21/2005
9/22/2005
12/14/2005
3/22/2006
6/23/2006
9/12/2006
10/24/2006
3/15/2007
6/20/2007
8/28/2007
10/23/2007
3/12/2008
3/12/2008
6/3/2008
8/6/2008
11/5/2008
2/4/2009
5/12/2009
8/17/2009
10/12/2009
1/19/2010
4/19/2010
11/12/2010
4/11/2011
10/5/2011
5/8/2012
11/14/2012
5/15/2013
12/4/2013
6/18/2014
9/16/2014
3.4
1.58
4.68
4.22
2.68
3.94
3.94
1.84
3.27
3.34
3.36
3.33
3.4
3.22
3.42
3.87
3.66
3.9
3.8
4.39
4.01
4.2
4.11
4.13
3.99
3.85
4.37
4.61
4.74
5.41
4.7
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
MW-28 Historical Data
Parameter Name Date Sampled
Report
Result Report Units
Lab
Qualifier
Uranium
6/21/2005
9/22/2005
12/14/2005
3/22/2006
6/23/2006
9/12/2006
10/24/2006
3/15/2007
6/20/2007
8/28/2007
10/23/2007
3/12/2008
3/12/2008
6/3/2008
8/6/2008
11/5/2008
2/4/2009
5/12/2009
8/17/2009
10/12/2009
1/19/2010
4/19/2010
11/12/2010
4/11/2011
10/5/2011
5/8/2012
11/14/2012
5/15/2013
12/4/2013
6/18/2014
9/16/2014
3.22
3.75
3.46
3.89
4.89
3.36
3.49
2.69
4.56
3.67
3.4
3.21
3.17
3.46
3.15
3.55
3.42
3.34
3.24
3.46
3.51
3.36
3.45
3.29
3.19
3.44
3.45
3.58
3.34
61.3
10.6
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
MW-28 Historical Data
Parameter Name Date Sampled
Report
Result Report Units
Lab
Qualifier
Vanadium
6/21/2005
9/22/2005
12/14/2005
3/22/2006
6/23/2006
9/12/2006
10/24/2006
3/15/2007
6/20/2007
8/28/2007
10/23/2007
3/12/2008
3/12/2008
6/3/2008
8/6/2008
11/5/2008
2/4/2009
5/12/2009
8/17/2009
10/12/2009
1/19/2010
4/19/2010
11/12/2010
4/11/2011
10/5/2011
5/8/2012
1/14/2012
5/15/2013
12/4/2013
6/18/2014
9/16/2014
20
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
109
18.5
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
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