DRC-2016-011442 - 0901a06880685dae

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ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
November 14, 2016
SENT VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Scott Anderson
Director of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Re: Transmittal White Mesa Uranium Mill Abandonment Plan for MW-3
Dear Mr. Anderson:
Pursuant to the Division of Waste Management and Radiation Control (“DWMRC”) letter dated
November 8, 2016 attached is Energy Fuels Resources (USA) Inc.’s (“EFRI’s”) Abandonment Plan for
MW-3 at White Mesa Mill. This plan was prepared consistent with the requirements of State of Utah
Regulations R655-4-14.
EFRI will complete abandonment as soon as possible after DWMRC concurrence is received, weather
permitting.
Please contact me at [phone] 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
Logan Shumway
David E. Turk
Div of Waste Management
and Radiation Control
NUV 16 2®
P ftC-2016- Oil
Attachments
White Mesa Uranium Mill
ABANDONMENT PLAN FOR MW-3
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
November 14, 2016
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Background
The 2005 Groundwater Discharge Permit (“GWDP”) Statement of Basis (“SOB”) noted several
construction issues associated with MW-3. The GWDP required the completion of a
replacement well, MW-3A. Energy Fuels Resources (USA) Inc. (“EFRI”) installed replacement
well MW-3A in 2005 and has been monitoring MW-3A since its installation. The GWDP SOB
listed the construction issues in MW-3 as follows:
A. Missing Geologic Log - review of the MW-3 well as-built diagram shows that no
geologic log is available for MW-3. Consequently, it is impossible to ascertain if the
screened interval is adequately located across the base of the shallow aquifer, i.e., at or
below the upper contact of the Brushy Basin Member of the Morrison Formation.
B. Lack of Filter Media - well MW-3 was constructed without any filter media or sand pack
across the screened interval.
C. Excessively Long Casing Sump - a 9 or 10-foot long non-perforated section of well
casing was constructed at the bottom of this well. This blank casing acts as a “sump” in
the bottom of the well.
D. Two weeks after installation of well MW-3, mill staff found the well to be dry. However,
in late September, 1979 mill staff measured the static water level at a depth of 83.4 ft.
This equates to an approximate water level water level of only about 5 feet above the base
of the well screen.
The low water level has been fairly consistent over the life of the well. The sump water becomes
stagnant between sampling events. Purging prior to sampling eliminates most of the stagnant
water present in the sump, but it is not possible to remove all water within the sump during
purging. During sampling, groundwater enters the well through the screen and mixes with the
remaining stagnant water in the sump. The mixing of fresh and stagnant water, and/or stirring up
any sediment accumulating in the sump, may be affecting the analytical results as seen in the
variable analytical data over time. At intermittent times (up to and including Q3 2016) several
constituent concentrations monitored at MW-3 have been highly variable and unpredictable..
In an effort to determine if the majority of the inconsistent results are due to the effects of the
sump, a packer was installed below the well screen to prevent any mixing of the stagnant water
and/or sediment which accumulates in the sump with the fresh water entering the well through
the screen. Normal purging and sampling procedures were followed after the placement of the
packer.
Concentration fluctuations are likely due to the construction issues noted above and exacerbated
by the installation of the well packer in an effort to isolate a section of blank casing below the
monitoring well screened interval. It is likely that the well packer material, although thought to
be inert, is reacting and causing additional fluctuating contaminant concentrations.
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Based on eleven years of monitoring results for monitoring well MW-3A, which does not show
the same issues as MW-3, it has been determined that the exceedances at monitoring well MW-3
are likely due to poor well construction, and that based on historical contaminants found in this
well, including organic chemicals (THF), monitoring well MW-3 should be plugged and
abandoned.
Well Construction
Appendix A contains the well construction diagram. As can be seen from Appendix A, MW-3 is
constructed within a 7 7/8 - inch diameter borehole, is screened from 67 to 87 feet below land
surface (ft bis), and has no filter pack. Approximately 9 feet of capped blank casing extends
beneath the screen to a depth of 96 ft bis. A cement basket located at approximately 65 feet
supports an overlying bentonite and cement grout seal. The well casing consists of 3-inch
diameter schedule 40 PVC and 0.045-inch slot factory slotted PVC screen. Casing joints are
glued.
Because no geologic log is available, the actual depth of the Brushy Basin Member of the
Morrison Formation, which underlies the perched groundwater zone at the site, is unknown at
MW-3. The depth to the Brushy Basin has been assumed to be the base of the screen at
approximately 87 ft bis.
Well Abandonment
MW-3 will be abandoned by a licensed well driller in accordance with State of Utah regulations
R655-4-14.8 and R655-4-14.10. EFRI will make every effort to completely remove the well
casing during abandonment by either pulling or drilling out the casing. If drilling is required to
remove the casing, an 8-inch (or larger) diameter drill bit will be used.
After removing the casing, in accordance with Utah regulations R655-4-14.8 and R655-4-14.10,
MW-3 will be “pressure grouted throughout the perforated or screened section of the well”. The
remainder of the well will be filled with sand cement grout, neat cement grout, bentonite
abandonment products, or bentonite grout.
With regard to placement of materials within the well, neat cement grout will be “introduced at
the bottom of the well” and “placed progressively upward to the top of the well”. The sealing
material will be “placed by the use of a grout pipe, tremie line, dump bailer, or equivalent in
order to avoid freefall, bridging, or dilution of sealing materials or separation of aggregates from
sealants”.
With regard to any bentonite-based abandonment products that may be used, “bentonite-based
abandonment products” will be “mixed and placed according to manufacturer’s specifications”
to ensure a seal free of voids or bridges. Granular or powdered bentonite will “not be placed
under water”. When placing unhydrated bentonite, a sounding or tamping tool will “be run in the
sealing interval during pouring to measure fill-up rate, verify a continuous seal placement, and to
break up possible bridges or cake formations”.
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Schedule
Upon DWMRC approval of this plan, EFRI will proceed with the abandonment of MW-3. MW-
3 will be abandoned as soon as possible after approval, weather permitting.
Reporting
A well abandonment report will be prepared by the licensed driller performing the abandonment.
As specified in State of Utah Administrative Code R655-4, “within 30 days of the completion of
abandonment work on any well, the driller shall file an abandonment log with the state engineer.
The blank abandonment log will be mailed to the licensed well driller upon notice to the state
engineer of commencement of abandonment work as described in Subsection R655-4-4(4.2.4)”.
As per R655-4, “the water right number or non-production well number, owner name/address, and
the well location (if available) will be preprinted on the blank abandonment log provided to the well
driller. The driller is required to verify this information and make any necessary changes on the
abandonment log prior to submitting the log. The driller must provide the following information on
the abandonment log:
a. Existing well construction information;
b. Date of abandonment;
c. Reason for abandonment;
d. A description of the abandonment method;
e. A description of the abandonment materials including depth intervals, material type,
quantity, and mix ratio;
f. Replacement well information (if applicable);
g. The well driller's statement to include the driller name, license number, signature, and
date.”
EFRI will provide 14-days advance notice to DWMRC of abandonment activities. In addition to
the driller’s report, and after the completion of abandonment activities, EFRI will provide a letter
report to DWMRC. The report will be signed by a state of Utah Licensed Professional Geologist
and will be submitted within 60 days after the completion of abandonment activities.
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APPENDIX A
WELL CONSTRUCTION DIAGRAM FOR MW-3
4u.s
n
CM
00
2<rE
J: 3 v 5 s 3 a z
r§
o£
a. <CJ
^ D
GROUND
SURFACE
WELL DRY (9/14/79)
SCREEN•
(NOTE l)
BLANK PIPE-
BOTTOM CAP
-87'
-96‘
NOT TO SCALE
NOTE I -SCREEN CONSISTS OF COMMERCIALLY
~ SLOTTED PIPE WITH 0.045 IN. WIDE H SLOTS, 3 ROWS AND 40-42/SLOTS/v 3 n CJIVTO
-r ROW/FT. PIPE.
1 QC<
LOCKING CAP
VENTED CAP
PROTECTIVE PIPE
CEMENT SURFACE SEAL
*'OPVC SCHEDULE 40
RISER PIPE
CUTTINGS
7 VH0LE
CEMENT GROUT
BENTONITE SEAL
SAND
CEMENT BASKET
FIGURE 4
PIEZOMETER INSTALLATION
WELL NO. 3
CONSTRUCTION DETAILS
PREPAflEO FOR
ENERGY FUELS NUCLEAR, INC.
DENVER,COLORADO