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HomeMy WebLinkAboutDRC-2018-004380 - 0901a0688080c998re ENERGY FUELS Div of Waste Management and Radiation Control MAY 0 3 20I8 Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com C zo iööL Oi-30 May 1, 2018 VIA PDF AND OVERNIGHT DELIVERY Scott Anderson, Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill — Notice Pursuant to Part I.G.1 (a) Dear Mr. Anderson: The White Mesa Mill (the "Mill") performed first quarter ("Ql") groundwater monitoring during the period from January 1, to March 31, 2018 under the January • 19, 2018 version of the Mill's Groundwater Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were received during the period ending April 2, 2018. Pursuant to Part I.G.1.a) of both of the GWDPs, please take notice that the concentrations of specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this quarter in the attached Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been formatted to simplify the tracking of any continued exceedances from one monitoring period to the next by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics). As a result of the issuance of a revised GWDP on January 19, 2018, which sets revised GWCLs, requirements to perform accelerated monitoring under Part I.G.1 of the previous GWDP ceased effective on January 19, 2018, and the effect of the issuance of the revised GWDP was to create a "clean slate" for all constituents in all wells going forward. Some additional data were collected and are included on Table 1. The additional data are highlighted on Table 1 and details are provided in the notes. Part I.G.1 c) of the GWDP states "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 ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT will be reestablished." The summary below Letter to Mr. Scott Anderson May 1, 2018 Page 2 relating to Q1 2018 exceedances includes, for each exceedance, a brief discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of other actions currently being undertaken by Energy Fuels Resources (USA) Inc. ("EFRI") or in light of other reports submitted by EFRI, and as determined by Division of Waste Management and Radiation Control ("DWMRC") Staff. A description of the other actions and reports which have affected the requirement to submit a plan and time schedule are as follows: 1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing investigations at the Mill. Based on the results of the previous investigations, EFRI and the Director acknowledged that it has not been possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate + nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the activities associated with the CAP are on- going. Based on information provided by DWMRC in teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30-day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at this time. 2. A Plan and Time Schedule will not be prepared for monitoring wells with two successive exceedances if successive exceedances were reported in a previous quarter under a previous revision of the GWDP and were included in a previous Source Assessment Report ("SAR"). A Plan and Time Schedule will not be submitted for those constituents reported under previous GWDP revisions and included in previously submitted SARs, because the GWCLs were modified based on conclusions and actions delineated in those reports which were accepted by DWMRC. 3. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and methylene chloride exceedances is not required. It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to reflect background groundwater quality, as defined by the mean plus second standard deviation concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that, because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a given analyte will increase the number of exceedances due to statistical variation and not due to Mill activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a monthly frequency can result in resampling of essentially the same water and can lead to repeat exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same water. Letter to Mr. Scott Anderson May 1, 2018 Page 3 1.0 Exceedances in Required Quarterly Sampling Wells 1.1 Quarterly Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods in Q1 2018. A 30-day plan and schedule contemplated in Part I.G.1 c) of the GWDP will not be required for the reasons stated below. One-time exceedances and non-successive exceedances are noted on Table 1, but not listed below. Consecutive exceedances which occurred in previous reporting periods are discussed in the SAR submitted August 20, 2017. MW-26 • Nitrate + nitrite has exceeded its GWCL in all of the Q1 2018 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • Chloroform has exceeded its GWCL in all of the Q1 2018 sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of chloroform. Because this well is used in the chloroform capture program which is the subject of separate investigations and actions, a plan and time schedule to address the consecutive exceedances is not necessary and is not being submitted. • Methylene chloride has exceeded its GWCL in all of the Q1 2018 sampling events. MW- 26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of methylene chloride. Because this well is used in the chloroform capture program which is the subject of separate investigations and actions, a plan and time schedule to address the consecutive exceedances is not necessary and is not being submitted. MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January 20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform removal, concentrations of all constituents in that well are subject to potential variation over time as a result of the pumping activity. This will be taken into account by the Executive Secretary in determining compliance for this well." Based on information provided by DWMRC in teleconferences on April 27, and May 2, 2011, due to the current pumping status as part of the chloroform investigation program, the 30-day plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene chloride in MW-26. • The chloride concentration exceeded its GWCL in in the Q1 2018 and March monthly sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in Letter to Mr. Scott Anderson May 1, 2018 Page 4 groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the Q1 2018 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL all of the Q1 2018 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Q1 2018 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL in all of the monitoring periods for Q1 2017. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The sulfate concentration exceeded its GWCL in the January monthly and the Q1 2018 sampling events. Sulfate exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The selenium concentration exceeded its GWCL in the January monthly and the Q1 2018 sampling events. Selenium exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. Letter to Mr. Scott Anderson May 1, 2018 Page 5 • The Total Dissolved Solids ("TDS") concentration exceeded its GWCL in the January monthly and the Q1 2018 sampling events. TDS exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC' s acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The uranium concentration exceeded the GWCL in MW-31 in all of the Q1 2018 sampling events. TDS exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC' s acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. 1.2 Quarterly Wells with New Exceedances Reported in Q1 One new exceedance for the Q1 2018 quarterly well sampling program is listed below. This exceedance will result in an accelerated sampling frequency from quarterly to monthly. The well listed below will only be sampled during the monthly events for those constituents that exceeded the GWCLs. The well listed below will be sampled for all constituents listed in the GWDP during the quarterly events as that is the regularly scheduled sampling for the quarterly wells. Accelerated monthly monitoring will continue pursuant to the requirements described below. • Field pH in MW-30 was slightly below the GWCL in the January 2018 monthly sampling event. Relative to accelerated reporting requirements, reporting of exceedances is required to be completed within 30 days of receipt of the last data package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the month following the submission of the Exceedance Notice for a specified quarter for wells that are being accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice for wells that are being accelerated from semiannually to quarterly. 2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly 2.1 Semi-annual Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods (Q4 2017 and Q1 2018). Letter to Mr. Scott Anderson May 1, 2018 Page 6 MW-27 • The nitrate+nitrite concentration exceeded its GWCL for both the Q4 2017 sampling event and the Q1 2018 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-28 • Chloride has exceeded the GWCL for both the Q4 2017 sampling event and the Q1 2018 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-32 • Chloride has exceeded the GWCL for both the Q4 2017 sampling event and the Q1 2018 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. 2.1 Semi-annual Wells with New Exceedances Reported in Q1 There were no new exceedances for the semi-annual well sampling program. Yours truly, ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund David Turk Logan Shumway Scott Bakken Paul Goranson Table 1 - GWCL Exceedances for First Quarter 2018 under the January 19, 2018 GWDP ' 1"1111111111r Monitoring Well (Water Class) Constituent Exceeding GWCL , GWCL in January 19, 2018 GWDP January 2018 81 onthly Sample Date January 2018 Monthly Result Ql 2018 Sample Date Q1 2018 Result March 2018 Monthly Sample Date Mardi 2018 Monthly Result MW-11 (Class II) Manganese (sig/L) Regal : Wells 164 67 1/24/2018 561 2/20/2018 117 3/6/2018 NA Sulfate (ing/L) 1309 1120 1189 MIN-14 (Class III) Fluoride (rng/L) 0.2 1/23/2018 0.153 2/19/2018 0.100 3/6/2018 0.110 MW-25 (Class 111) Cadmium (ug/L) 1.5 1/23/2018 1.38 2/19/2018 1.28 3/7/2018 1.45 Fluoride (mg/L) 0.42 NA 0.281 0.318 Uranium (ug/1) 7.25 5.74 NA MW-26 (Class II) Nitrate + Nitrite (as N) (mg/14 0.62 1/25/21118 0.862 2/22/2018 0.742 3/8/2018 0.691 Chloroform (ug/L) 70 2280 1730 2350 Chloride (ma/L) 58.31 57.5 64.3 75.2 Methylene Chloride (ug/L) 5 5.79 9.80 11.6 Uranium (tig/L) 119 60.1 21.3 NA MW-30 (Class II) Nitrate + Nitrite (as N) (mg/L) 2.5 1/23/2018 15.2 2/22/2018 17.6 3/8/2018 17.0 Chloride (rng/L) 128 152 158 167 Uranium (ug/L) 8.32 8.53 8.23 8.66 Field pH (S.U.) 6.47 - 8.5 6.18 6.54 6.87 Selenium (ug/L) 47.2 IF 45.5 NA MW-31 (Class III) Nitrate + Nitrite (as N) (mg.) 5 1/24/2018 17.0 I.U.1 323 2/20/2018 18.8 3/5/2018 19.0 TDS (mg/L) 1700 1930 NA Chloride (rng/L) 143 292 311 Selenium (ug/L) 86.81 INV --- 88.7 NA Uranium (ug/L) 9.1 11.4 11.2 11.4 Sulfate (mg/1-) 697.60 813 835 NA MW-35 (Class II) Manganese (ug/L) 290.68 1/23/2018 2(17 N ', NA NS NA Selenium (tig/L) 25 8.42 NA NA Uranium (ug/L) 26.76 20.9 NA NA Gross Alpha minus Rn & U ( .Ci/1) 7.5 5.7 NA NA MW-05 (Class 11) Uranium (ug/L) 7.5 NS NA 2/16/2018 0.910 NS NA MW-12 (Class III) Uranium (ug/L) 23.5 NS NA 3/2/2018 23.3 NS NA MW-24 (Class III) Beryllium (ug/L) 2 NS NA 3/2/2018 1.69 NS NA MW-27 (Class 111) Nitrate + Nitrite (as N) (ma/L) 5.6 NS NA 2/21/2018 6.19 NS NA Chloride (mg/1.) 38 NA 32.4 NA MW-28 (Class III) Chloride (mg/1.) 105 NS NA 2/21/2018 121 NS NA Cadmium (ug/14 5.2 NA 4.57 NA Uranium (ug/L) 4.9 NA 3.94 NA 1191 - -', 2 c C(ass 111) Chloride (mg/L) 35.39 NS NA 2/16/2()18 37.4 NS NA Sulfate (mg/L) 2556.70 NA 2160 NA Notes: NS= Not Required and Not Sampled NA= Not Applicable Exceedances are shown in yellow These sample results were collected as a result of exceedances of the GWCLs in the previous GWDP. A new GWDP was issued on January 19, 2018 and these GWCLs were revised as specified in the DWMRC-approved SARs. Pursuant to the January 19, 2018 GWDP these parameters are no longer in exceedance and accelerated sampling is no longer required. These parameters will no longer be included in the exceedance notice after the first quarter 2018. NA - Pursuant to the January 19, 2018 GWDP these parameters were no longer in exceedance after January 19, 2018 and accelerated sampling was no longer required. The reset of the GWCLs allowed for the cessation of monthly sampling of these parameters after the issuance of the GWDP including during the March monthly event. The exceedances noted during the first quarter event will begin accelerated monitoring with the June monthly event, as required by the revised GWDP. These GWCLs were reset with the issuance of the January 19, 2018 GWDP. These parameters were no longer in exceedance and these accelerated samples were not required under the January 19, 2018 GWDP. These data were collected and are reported es required by Part II.F of the GWDP.