DRC-2018-011997 - 0901a06880932617

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Div of Waste Management
November 14, 2018 and Radiation Control
NOV 1 6 2018
RC.-2_016 - Oií7
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 third quarter ("Q3") groundwater monitoring
during the period from July 1, to October 3, 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 October 24, 2018.
Pursuant to Part I.G.1.a) of the GWDP, 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.
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
relating to Q3 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
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
Lette'r to Mr. Scott Anderson
November 14, 2018
Page 2
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
November 14, 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 Q3 2018. A 30-day plan and schedule
contemplated in Part I.G.1 c) of the GWDP will be required for the consecutive exceedances of
thallium in MW-24 as noted 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 SARs submitted August 20, 2017 and June 25, 2018.
MW-26
• Nitrate + nitrite has exceeded its GWCL in all of the Q3 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 Q3 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.
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 all of the Q3 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-30
• Nitrate + nitrite has exceeded its GWCL in all of the Q3 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.
Letter to Mr. Scott Anderson
November 14, 2018
Page 4
• The chloride concentration exceeded its GWCL all of the Q3 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 Q3 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 Q3
2018. 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 all of the Q3 2018 sampling events.
While these exceedances are not consecutive, they 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 Total Dissolved Solids ("TDS") concentration exceeded its GWCL in all of the Q3
2018 sampling events. While these exceedances are not consecutive, they 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 Q3 2018
sampling events. Uranium 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
Letter to Mr. Scott Anderson
November 14, 2018
Page 5
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 Q3
There are no new exceedances for the Q3 2018 quarterly well sampling program.
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 (Q2 2018 and Q3 2018).
MW-24
• Thallium concentrations exceeded the GWCL in MW-24 in the Q2 2018 and Q3 2018
sampling events. This is the first consecutive exceedance for thallium in MW-24 under
the January 19, 2018 GWDP. Therefore, a plan and schedule for assessment will be
submitted under separate cover within 30 days of this Exceedance Notice.
MW-27
• The nitrate+nitrite concentration exceeded its GWCL for both the Q2 2018 sampling
event and the Q3 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 subinitted.
MW-28
• Chloride has exceeded the GWCL for both the Q2 2018 sampling event and the Q3 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.
• Uranium has exceeded the GWCL for both the Q2 2018 sampling event and the Q3 2018
sampling event. This consecutive exceedance is addressed in the Plan and Time
Schedule, dated December 4, 2014. As a result of the Plan and Time Schedule, additional
data will be collected and an assessed. As a result of DWMRC's acceptance of the Plan
and Time Schedule, no additional actions for this consecutive exceedance are necessary
at this time.
MW-32
• Chloride has exceeded the GWCL for both the Q2 2018 sampling event and the Q3 2018
sampling event and during previous quarters. As mentioned above, a CAP has been
Lettbr to Mr. Scott Anderson
November 14, 2018
Page 6
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.
2.2 Semi-annual Wells with New Exceedances Reported in Q3
There were no new single exceedances for the Q3 2018 semi-annual well sampling program.
Yours truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David Frydenlund
Terry Slade
Logan Shumway
Scott Bakken
Paul Goranson
- GWCL Exceedances for Third Ouarter 2018 under the January 19 2018 GWDP
Q1 2018 Results Q2 2018 Results Q3 2018 Results
Monitorine Well - (Water Class) Constituent Exceeding GWCL
GWCL in
January 19,
2018 GWDP
January 2018
Monthly
Sample Date
January
2018
Monthly
Result
Ql 2018
Sample Date
Q1 2018
Result
March 2018
Monthly
Sample Date
March 2018
Monthly
Result
Q2 2018
Sample Date
Q2 2018
Result
May 2018
Monthly
Sample Date
May 2018
Monthly
Result
June 2018
Monthly
Sample Date
June 2018
Monthly
Result
July 2018
Monthly
Sample Date
July 2018
Monthly
Result
August 2018
Monthly
Sample Date
August 2018
Monthly
Result
Q3 2018
Sample Date
W 2018
Result
Required Quarterly Samp ing Wells
MW-11 (Class II) Manganese (ug/L) 164.67 1/24/2018 561 2/20/2018 117 3/6/2018 NA 4/18/2018 174 5/15/2018 NA 6/19/2018 NA 7/24/2018 NA 8/9/2018 154 9/11/2018 171
Sulfate (mg,/L) 1309 1120 1 180 1110 1140 1060 1170 1090 1160
MW-14 (Class 111) Fluoride (mIL) 0.2 1/23/2018 0.153 2/19/2018 0.100 3/6/2018 0.110 4/12/2018 <0.100 5/14/2018 0.135 6/18/2018 0.146 7/24/2018 0.183 8/9/2018 <0.100 9/11/2018 <0.100
MW-25 (Class HI) Cadmium (ug/L) 1/23/2018 1.38 2/19/2018 1.28 3/7/2018 1.45 4/17/2018 1.38 5/14/2018 1.34 6/18/2018 1.38 7/23/2018 1.30 8/9/2018 1.36 9/10/2018 1.35
Fluoride (mg/L) 0.42 NA 0.281 0.318 0.360 0.34 6 0.210 0.128 0.243 0.243
MW-26 (Class III)
Nitrate + Nitrite (as N) (mg/L) 0.62
1/25/2018
0.862
2/22/2018
0.742
3/8/2018
0.691
4/19/2018
0.816
5/15/2018
0.920
6/19/2018
0.815
7/24/2018
0.704
8/10/2018
1.40
9/13/2018
0.825
Chloroform (ug/L) 70 2280 1730 2350 2500 1740 3920 1160 1030 728
Chloride (mg/L) 58.31 57.5 64.3 75.2 62.5 62.4 66.9 66.0 68.8 74.5
Methylene Chloride (ug/L) 5 5.79 9.80 11.6 17.4 8.55 10.3 3.07 2.47 1.58
Field (S.U.) pH 5.61 - 8.5 6.11 6.35 6.73 5.50 6.81 7.00 7.18 6.64 6.57
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
4/12/2018
17.3
5/15/2018
17.7
6/19/2018
16.9
7/24/2018
17.4
8/10/2018
18.7
9/11/2018
18.0
Chloride (mg,/L) 128 152 158 167 145 174 169 177 170 183
Uranium (ug/L) 8.32 8.53 8.23 8.66 7. 98 8.44 8.80 8.69 7.69 8.34
Field (S.U.) pH 6.47 - 8.5 6.18 6.54 6.87 6.33 6.74 6.84 7.39 6.91 6.94
MW-31 (Class III)
Nitrate + Nitrite (as N) (mg/L) 5
1/24/2018
17.0
323
11.4
NA •
2/20/2018
18.8
3/5/2018
19.0
4/17/2018
19.0
5/14/2018
18.8
6/18/2018
18.0
7/23/2018
18.0
8/10/2018
18.3
9/10/2018
20.1
TDS (mg/L) 1700 1930 NA 1980 NA 2010 2000 1980 2100
Chloride (mg/L) 143 292 311 308 326 359 351 336 33
Selen um (ug/L) 86.81 88.7 NA 90.2 NA 87.5 93.8 86.3 83.0
Uranium (ug/L) 9,1 11.2 11.4 11.5 11.5 12.9 12.3 11.7 11.0
Sulfate (in! )
• Uranium (ugiL)
697.60
7 5
835
0.910
NA
NA
857
0.875
NA
NA
976
NA
857
NA
841
NA
893
0.631 MW-05 (Class 11) NS 2/16/2018 NS 4/10/2018 NS NS NS NS 9/11/2018
MW-12 (Class III) Uranium (ug/L) 23.5 NS NA 3/2/2018 23.3 NS NA 4/10/2018 21.1 NS NA NS NA NS NA NS NA 9/12/2018 21.1
MW-24 (Class III)
Beryllium (ug/L) 2
NS
NA
3/2/2018
1.69
NS
NA
4/19/2018
2.78
NS
NA
NS
NA
NS
NA
NS
NA
9/19/2018
1.68
Cadmium (ug/L) 6.43 NA NA NA 6.97 NA NA NA NA 5.59
Thallium (ug/L) 2.01 NA NA NA 2.44 NA NA NA NA 2.18
Field (S.U.) pH 5.03 - 8.5 NA 5.89 NA 4.45 , NA NA NA NA 5.30
MW-27 (Class III) Nitrate + Nitrite (as N) (mg/L) NS NA 2/21/2018 6.19 NS NA 4/18/2018 6.0 9
• NS NA NS NA NS NA NS NA 9/12/2018 6.35
Chloride (mg/L) 38 NA 32.4 NA 34.7 NA NA NA NA 35.6
MW-28 (Class III)
Chloride (mg/L) 105
NS
NA
2/21/2018
121
NS
NA
4/19/2018
138
NS
NA
NS
NA
NS
NA
NS
NA
9/12/2018
148
Cadmium (ug/L) 5.2 NA 4.57 NA 4.99 NA NA NA NA 4.84
4.9 NA 3.94 NA 5.06 NA NA NA NA 7.04
MW-32 (Class III)
Uranium (ug/L)
Chloride (mg/L) 35.39 NS NA 2/16/2018 37.4 NS NA 4/10/2018 37.2 NS NA NS NA NS NA NS NA 9/5/2018 41.1
Sulfate (mg/L) 2556.70 NA 2160 NA 2000 NA NA NA NA 2060
MW-35 (Class 11) Nitrogen, Ammonia as N 0.14 NS NA NS NA NS NA 4/10/2018 0.254 NS NA NS NA NS NA NS NA 9/10/2018 <0.0500
Notes:
NS= Not Required and Not Sampled
NA= Not Applicable
Exceedances are shown in yellow
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 GWas allowed for the cessation of monthly sampling of these parameters a er 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 GWas 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 as required by Part ll.F of the GWDP.
Pursuant to the DWMRC letter of September 28, 2018; these constituents will no longer be monitored on an accelerated schedule. These constituents will be dropped from this report after this quarter,