DRC-2017-000563 - 0901a068806a0e71

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.ciicravrucls.com
January 16, 2017
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
Dlv of Waste Management
and Radiation Control
JAN 1 7 2017
Re: Transmittal White Mesa Uranium Mill Abandonment Report for MW-3
Dear Mr. Anderson:
Attached please find the Energy Fuels Resources (USA) Inc. (“EFRI”) Abandonment Report for MW-3
at White Mesa Mill as required by the Division of Waste Management and Radiation Control
(“DWMRC”) approved Abandonment Plan, dated November 14, 2016.
Please contact me at [phone] if you have any questions or require any further information.
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
Logan Shumway
David E. Turk
A- A 1
Attachments
I HYDRO GEO CHEM, INC.
Environmental Science & Technology
January 16, 2017
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc
225 Union Blvd., Suite 600
Lakewood, Colorado 80228
Re: Abandonment of Perched Monitoring Well MW-3: White Mesa Uranium Mill Near
Blanding, Utah
Dear Ms. Weinel,
This letter describes the abandonment of perched monitoring well MW-3 pursuant to the letter from
Energy Fuels Resources (USA) Inc. (EFRI) to Mr. Scott Anderson at the State of Utah Division of
Waste Management and Radiation Control (DWMRC) dated November 14,2016 (the abandonment
plan). The abandonment was performed by Bayles Exploration, Inc, a State of Utah licensed driller
under contract to EFRI, in accordance with applicable regulations (State of Utah Administrative
Rules for Water Wells R655-4-14).
Background
At the time of abandonment, the White Mesa Mill site contained a total of 102 perched monitoring
wells, temporary perched monitoring wells, and piezometers (Figure 1), all screened in a relatively
shallow perched water zone hosted primarily by the Burro Canyon Formation. Where saturated
thicknesses are greater, the perched water rises into the overlying Dakota Sandstone. The perched
water is supported by the Brushy Basin Member of the Morrison Formation, a bentonitic shale
(considered impermeable) that underlies the Burro Canyon Formation.
The 31 existing MW-series wells, located within, upgradient, cross-gradient, and downgradient of
the tailings management system at the site, were installed primarily to monitor hydraulic conditions
and groundwater quality in the vicinity of the tailings management system. MW-3, installed in 1979,
was one of the first perched groundwater monitoring wells completed at the site.
51 West Wctmorc, Suite 101 Tutson, Arizona 85705-1678 520.293.1500 520.293.1550-Fax [phone]-Toll Free
Kathy Weinel
January 16, 2017
Page 2
As discussed in the abandonment plan, 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. EFRI installed replacement well MW-3A in 2005 and
has been monitoring MW-3A since installation. The GWDP SOB listed the construction issues in
MW-3 as follows:
1. 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.
2. Lack of Filter Media - well MW-3 was constructed without any filter media or sand pack
across the screened interval.
3. 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.
4. 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,
approximately 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. At intermittent times (up to and including the third quarter of 2016)
concentrations of several monitored constituents at MW-3 have been highly variable and
unpredictable. The mixing of fresh and stagnant water, and/or stining up any sediment accumulating
in the sump, may be responsible for these variable and unpredictable analytical data.
In an effort to determine if the inconsistent analytical results are largely due to the effects of the
sump, an inflatable packer was installed at the top of the blank casing below the well screen to
prevent intermingling of fresh water entering the well through the screen and stagnant water and/or
sediment accumulating in the sump. Normal purging and sampling procedures were followed after
the placement of the packer.
Concentration fluctuations that likely result from construction details noted above may have been
exacerbated by the installation of the packer in an effort to isolate the blank casing below the
screened interval. It is likely that the packer material, although thought to be inert, is reacting and
causing additional fluctuations in contaminant concentrations.
Based on eleven years of monitoring of well MW-3 A, which lacks the construction issues plaguing
MW-3, EFRI has determined (with the concurrence of DWMRC) that the analytical exceedances at
monitoring well MW-3 are likely due to poor well construction and that plugging and abandonment
of MW-3 is appropriate.
H \718000\MW3\MW3_abandonmenc\abandonmem_repon\MW3_Abandonment_Report doc
Kathy Weinel
January 16, 2017
Page 3
Well Construction
Appendix A contains the construction diagram for abandoned well MW-3 and Appendix B the
construction diagram for replacement well MW-3A. Table 1 provides well construction details and
Table 2 provides surveyed well locations and elevations based on both a 2001 survey of MW-3 and a
2015 survey of well MW-3A. The surveyed location of MW-3 based on the 2015 survey of MW-3A
is calculated from the surveyed coordinates of MW-3A and hand measurement of the relative
position of MW-3 with respect to MW-3A. MW-3 is located approximately 10 feet north of MW-
3A. As shown in 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.
The depth to Brushy Basin at MW-3A is approximately 92.5 ft bis (Appendix B).
Well Abandonment
MW-3 was abandoned in accordance with State of Utah regulations R655-4-14.8 and R655-4-14.10
on November 30,2016 by Bayles Exploration Inc, a currently licensed water well driller responsible
for verification of the procedures and materials used. Attempts to pull the packer and the well casing
were unsuccessful so the entire assembly was drilled out.
Details of the abandonment procedures are provided in the well abandonment report prepared and
submitted by Bayles Exploration Inc. The Bayles report is attached as Appendix C.
Please feel free to contact me if you have any questions.
Sincerely,
Hydro Geo Chem, Inc.
fto:'
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fEWART J. SMITH-to
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5336166-2250
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Stewart J. Smith, R.G.
Vice President
Attachments: Tables (2)
Figure (1)
Appendix A
Appendix B
Appendix C
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H \718000\MW3\MW3_abandonment\abandonment_report\MW3_Abandonment_Report doc
ATTACHMENTS
TABLES
1 Well Construction Details
2 Well Survey Data
FIGURE
1 White Mesa Site Plan Showing Locations of Perched Wells and Piezometers
APPENDICES
A Abandoned Well (MW-3) Construction Diagram
B Replacement Well (MW-3A) Construction Diagram
C Well Abandonment Report
TABLES
TABLE 1
Well Construction Details
Well
Total
Drilled Depth
(ft bis)
Bore
Diameter
(inches)
Total
Casing Depth
(ft bis)
Casing
Diameter
(inches)
Screened
Interval
(ft bis)
Screen
Length
(feet)
Screen
Slot Size
(inches)
Filter Pack
Interval
(ft bis)
Filter Pack
Length
(feet)
MW-3 >96 7.88 96 3 67-87 20 0.045 NA NA
1MW-3A 97 6.75 95 4 78-95 17 0.020 71.3-97 25.7
Notes:
ft bis = feet below land surface
1 = not abandoned (replacement of MW-3)
NA = not applicable
H:\718000\MW3\MW3_abandonment\abandonmentj-eport\T1_MW3_Construction xls: Table 1 1/16/2017
TABLE 2
Well Survey Data
Well Northing
(feet)
Easting
(feet)
UTM north
(meters)
UTM east
(meters)
Latitude
(north)
Longitude
(west)
Casing Elev.
(feet amsl)
Ground Elev.
(feet amsl)
1MW-3 (2001)a317341 a2576418 4153727 631154 37.5212 -109.51582 5554.83 5552.88
2MW-3A (2015)b10159668 b2215931 4153701 631188 37.52096 -109.51545 5556.87 5552.65
2MW-3 (2015)C10159678 c2215931 4153704 631188 37.52098 -109.51545 5554.83 5552.88
Notes:
1 2001 LANDesign Survey
2 2015 Survey (Michael Purdy)
3 Site Coordinate System in Feet
b Coordinate System: Modified Utah State Plane - NAD83 - South Zone - US Survey Feet - Using Fisher Survey Vertical Datum
c Assumed to be 10 Feet North of MW-3A
Elev. = Elevation
amsl = above mean sea level
H:\718000\MW3\MW3_abandonment\abandonment_report\T2_MW3_SurveyData.xls: Table 2 1/16/2017
FIGURE
m/
o..TWN-11
abandoned
TWN-15
MW-01 ❖TWN-10
MW-18 TWN-06
abandoned❖TWN-05
❖TWN-07
OTWN-18
IWN-OS
MW-02 MW-24
MW-27 TWN-02 XWn
WILSite
MW-28
TWN-01 *TW4-21© PI^3A
TW4-18I/V4-05
MW-29
MW-30
two16ttVo2j-13
V - JmW-04
DR-05 r,n-nB
^ *■' ®MW-04MW-31 . ^7>4-0^W4-36
MW-32 TW4-01
TW4-040 JW4-14
DR-06 DR-07 MW-35*
©
MW-36#
^ * ■. ■'
PIEZ-01
abandoned
T™-08 MW#19
MW-26® q C) iTW4-10“fW4.03 TW4?285W4-32 1
I-16TW4-11 .............
TW4-26Q o OTW4-30 h TW4-2^OTW4-35 OTW4-34
DR-08
DR-09'■ v
DR-10 DR-11 DR-12
tiKi-'
■ ■; v ■■
.
^ 'y
>* ■ika
MW-21
DR-14 DR-15
DR-17
wm
DR-20 DR-21
:**X' ^DR-23
MlV-3
MW-3A
UiJU.
MW-22
DR-22
DR-24 -tfr-
'‘I;:- V O.r'o
sK£:
■HEXPLANATION
MW-3
• abandoned well MW-3
v’ ' T ,;-‘ % . •> RUIN SPRING
X?V
' ' ‘sJ .1
v v
TWm19 perched chloroform or
© nitrate pumping well
...v -. • jfr * «' %*4>t* *. «
;
•yAaf::'®? :V' . . V;:'
. TW4-38
A temporary perched monitoring well^ installed October, 2016 i*
’IEZ-3APY May, 2016 replacement of^ perched piezometer Piez-03
MW-5
• perched monitoring well
W4-12
O temporary perched monitoring well 1 mile .... ,45.
TWN-7❖temporary perched nitrate monitoring
well
perched piezometer
RUIN SPRING
(!) seep or spring
HYDRO
GEO
CHEM, INC.APPROVED
SJS
DATE
m/1 fi/pm?
: H:/718000/MW3/MW3_abandonment
/ahanrlnnmpnt rpnnrt/MW3 3Alnr..srf
APPENDIX A
ABANDONED WELL (MW-3) CONSTRUCTION DIAGRAM
CM00
2<E
<1 c t ^ : a i. 3 <£ - a z
GROUND
SURFACE
C f'
?tf
CB|®
rS
a£
a. <
o* »<71
WELL DRY (9/14/79)
SCREEN-
(NOTED
BLANK PIPE-
BOTTOM CAP
.87'
■ 96'
NOT TO SCALE
NOTE I = SCREEN CONSISTS OF COMMERCIALLY
SLOTTED PIPE WITH 0.04S IN. WIDE
J SLOTS, 3 ROWS AND 40-42/SLOTS/
T ROW/FT. PIPE.' a M r»•1 tal*T Zl (rt . «OI 5o3
LOCKING CAP
VENTED CAP
PROTECTIVE PIPE
CEMENT SURFACE SEAL
*'OPVC SCHEDULE 40
RISER PIPE
CUTTINGS
77/a" HOLE
CEMENT GROUT
•BENTONITE SEAL
•SAND
p------CEMENT BASKET
FIGURE 4
PIEZOMETER INSTALLATION
WELL NO. 3
CONSTRUCTION DETAILS
PREPARED POR
ENERGY FUELS NUCLEAR, INC.
DENVER,COLORADO
APPENDIX B
REPLACEMENT WELL (MW-3A) CONSTRUCTION DIAGRAM
<ro
NOT TO SCALE
IHYDRO
GEO
CHEM, INC.
MW-3A
AS-BUILT WELL CONSTRUCTION SCHEMATIC
Approved Date Author Date File Name Figure
ss 8/06/15 7180283A 2
APPENDIX C
WELL ABANDONMENT REPORT
WELL ABANDONMENT REPORT
State of Utah
Division of Water Rights
Wed Identification
-»
Owner c^y/^vd$ SAjic)mcj $>iS)\
Contact Person/Engineer: ...SsAXllL .
Well Location Note any changes
&f$ jA5 0«l^- i)S3S0£'
jo' /\/£ o9
-Location Description:-(addressrproximity4o buildings,-landmarks, ground-elevationjocal-well-#)
1%.
liter [JOtbei
.inches
.feet
Existing Well Details I k a WeU Driller's Report Available? □ Yes $ No
WeU Depth 7(7Qfeet WeU Diameter.
Nature of Use: □Dom. □hr. □ Stock □Industrial □Commercial □Municipal □Monitor □Other.
Casing Type: □Steel □Stainless Steel DPVC □ Fiberglass DABS DSR □Other.
Openings: □Screen □Perforations DOpenPipe Screen/Perforation Interval
FUter Pack? DYes DNo Depth of Surface Seal____________________________________
Static Water Levelfeet Flowing WeU? □ Yes J5J No
Other Details (if known)
Abandonment Details| natenf Abandonment ll '30~ii>
Reason for Abandonment fonr CxipifhitdiQA c\,id MATa.Mi/tet/v'f'g’ •fpc,^ j/\ \a) cl(
Method of Abandonment (Include a description of the seal placement and procedures, amount of casing/screen removed, pump/piping removal, termination
of casing at the surface, problems encountered, and other pertinent information).GarviArA. ^StVwj fy/AOritv^ " LJ^ll Ulr. b fi~ )Q0>~ /yii-./licco {Vi^}
pour^c)—\ y\ tA^&ii IaJ\ th—fiZj3 <An.Q—Co ^Aq le^ U/vt? r i jltS fAQL j&-
DEPTH (feet)ABANDONMENT MATERIAL DETAILS
FROM TO
ABANDONMENT MATERIAL USED Quantity of Material Used
(e.g., cubic yards, lbs)
GROUT DENSITY
(Ibs7gal., # bag mix, galisack etc.)
n Mf)f&p/uej &Q Li aooo Us
'sj
Location of a new well (if present) is;ft north/south andft east/west from the abandoned well.
WeU Drfller Statement This well was abandoned under my supervision, according to appUcable rules and regulations, and this report is complete
and correct to the best of my knowledge and beUef.
License No._______________486
Date___J^i ~!(s