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HomeMy WebLinkAboutDRC-2019-006263 - 0901a06880a99a59Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com ENERGYFUELS Div of Waste Management and Radiation Control JUL - 1 2019 June 26, 2019 D RC -zoi 9-00 626,3 VIA PDF AND OVERNIGHT DELIVERY Ty L. Howard Director Division 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. Howard: The White Mesa Mill (the "Mill") performed second quarter ("Q2") groundwater monitoring during the period from April 1, to June 30, 2019 under the March 19, 2019 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 June 18, 2019. 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 March 19, 2019, which sets revised GWCLs, requirements to perform accelerated monitoring for certain constituents under Part I.G.1 of the previous GWDP ceased effective on March 19, 2019, and the effect of the issuance of the revised GWDP was to create a "clean slate" for certain constituents going forward. Part I.G.1 c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to the Director 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 Q2 2019 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: Letter to Mr. Ty L. Howard June 26, 2019 Page 2 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 those successive exceedances were reported in a previous quarter and/or were included in a previous Source Assessment Report ("SAR"). Inclusion in a previous SAR means that the GWCLs were modified based on conclusions and actions delineated in the previous SAR 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. 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 Q2 2019. A 30-day plan and schedule contemplated in Part I.G.1 c) of the GWDP will not be required for the consecutive exceedances for the reasons 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 previously submitted SARs. Letter to Mr. Ty L. Howard June 26, 2019 Page 3 MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in all of the Q2 sampling events. A Plan and Time Schedule was submitted to DWMRC on February 21, 2019. DWMRC approved the plan and schedule by letter dated March 5, 2019. The SAR will be submitted to DWMRC on or before July 3, 2019. MW-26 • Nitrate + nitrite has exceeded its GWCL in all of the Q2 2019 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 Q2 2019 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 prograrn 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. • The chloride concentration exceeded its GWCL in all of the Q2 2019 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-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. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the Q2 2019 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 Q2 2019 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. Letter to Mr. Ty L. Howard June 26, 2019 Page 4 • Uranium concentrations exceeded the GWCL in MW-30 in the March 2019 and Q2 2019 sampling events. These exceedances are addressed in the SAR dated January 16, 2019. A plan or schedule to address the Q2 exceedance is not necessary and is not being submitted because exceedances have been addressed in the SAR which was submitted to DWMRC on January 16, 2019. The exceedances will continue to be noted and reported. • Selenium concentrations exceeded the GWCL in MW-30 in the Q1 2019 and Q2 2019 sampling events. These exceedances are addressed in the SAR dated January 16, 2019. A plan or schedule to address the Q2 exceedance is not necessary and is not being submitted because exceedances have been addressed in the SAR which was submitted to DWMRC on January 16, 2019. The exceedances will continue to be noted and reported. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Q2 2019 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 Q2 2019. 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. 1.2 Quarterly Wells with New Exceedances Reported in Q2 There are no new exceedances for the Q2 2019 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 (Q1 2019 and Q2 2019). MW-24 • Thallium concentrations exceeded the GWCL in MW-24 in the Q1 2019 and Q2 2019 sampling events. Thallium exceedances are addressed in the Plan and Tirne Schedule dated Decernber 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. • Beryllium concentrations exceeded the GWCL in MW-24 in the Q1 2019 and Q2 2019 sampling events. Beryllium exceedances were discussed in the Plan and Time Schedule dated December 5, 2018, however, beryllium did not exceed in two consecutive samples at that time. Since the time of the Plan and Time Schedule, beryllium has exceeded the GWCL in two consecutive sampling events and will therefore be included in the SAR for MW-24. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. Letter to Mr. Ty L. Howard June 26, 2019 Page 5 • Cadmium concentrations exceeded the GWCL in MW-24 in the Q1 2019 and Q2 2019 sampling events. Cadmium exceedances are addressed in the Plan and Time Schedule dated December 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. • Fluoride concentrations exceeded the GWCL in MW-24 in the Q4 2018 and Q2 2019 sampling events. Fluoride exceedances were discussed in the Plan and Time Schedule dated December 5, 2018, however, fluoride did not exceed in two consecutive samples at that time. Since the time of the Plan and Time Schedule, fluoride has exceeded the GWCL in two consecutive sampling events and will therefore be included in the SAR for MW-24. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. • Nickel concentrations exceeded the GWCL in MW-24 in the Q4 2018 and Q2 2019 sampling events. Nickel exceedances were discussed in the Plan and Time Schedule dated December 5, 2018, however, fluoride did not exceed in two consecutive samples at that time. Since the time of the Plan and Time Schedule, Nickel has exceeded the GWCL in two consecutive sampling events and will therefore be included in the SAR for MW-24. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. • Field pH concentrations were below the GWCL in MW-24 in the Q1 2019 and Q2 2019 sampling events. Field pH exceedances are addressed in the Plan and Time Schedule dated December 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. The SAR will be submitted to DWMRC on or before July 3, 2019. MW-27 • The nitrate+nitrite concentration exceeded its GWCL for both the Q1 2019 sampling event and the Q2 2019 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 Q1 2019 sampling event and the Q2 2019 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 Q1 2019 sampling event and the Q2 2019 sampling event. This consecutive exceedance is addressed in the Plan and Time Schedule, dated December 4, 2014. As a result of the Plan and Tirne 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 tirne. Letter to Mr. Ty L. Howard June 26, 2019 Page 6 2.2 Semi-annual Wells with New Exceedances Reported in Q2 One new single exceedance for the Q2 2019 semi-annual well sampling program is listed below. • Selenium in MW-28 was slightly above the GWCL in the Q2 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. Yours truly, ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund Terry Slade Logan Shumway Scott Bakken Paul Goranson Table 1 - GWCL Exceedances for Second Quarter 2019 under the March 19, 2019 GWIW ., - Q2 2019 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in March 19, 2019 GWDP Q2 2019 Sample Date Q2 2019 Result May 2019 Monthly Sample Date May 2019 Monthly Result June 2019 Monthly Sample Date June 2019 Monthly Result MW-11 (Class II) Required QuartejkLapagng Wells Manganese (ug/L) 164.67 4/24/2019 181 5/7/2019 210 6/3/2019 210 MW-25 (Class III) Cadmium (ug/L) 1.5 4/10/2019 1.30 5/8/2019 1.41 6/4/2019 1.47 MW-26 (Class III) Nitrate + Nitrite (as N) (mg/L) 0.62 4/24/2019 3.00 5/7/2019 0.986 6/4/2019 3.16 Chloroform (ug/L) 70 4140 1140 778 Chloride (mg/L) 58.31 82.0 73.0 72.6 Methylene Chloride (ug/L) 5 4.16 1.69 <1.00 Nitrogen, Ammonia as N 0.92 , 0.104 0.479 0.0919 MW-30 (Class 11) Nitrate + Nitrite (as N) (mg/L) 2.5 4/9/2019 18.5 5/7/2019 17.9 6/3/2019 15.8 Chloride (mg/L) 128 138 175 165 Selenium (ug/L) 47.2 53.6 47.1 49.9 Uranium (ug/L) 8.32 8.62 8.15 8.88 Field pH (S.U.) 6.47 - 8.5 7.06 7.00 7.12 MW-31 (Class III) Nitrate + Nitrite (as N) (mg/L) 5 4/10/2019 19.7 5/7/2019 18.9 6/3/2019 19.7 Chloride (mg/L) 143 294 346 325 MW - 36 Class 111 MW-05 (Class II) Field •H S.U. Uranium (ug/L) 6.49 - 8.5 Required Semi-Annual 7.5 4/18/2019 Sampling 4/24/2019 7.05 Wells 0.959 5/21/2019 , NS 6.73 NA 6/3/2019 NS 7.01 NA MW-12 (Class III) Uranium (ug/L) 23.5 4/25/2019 23.2 NS NA NS NA MW-24 (Class III) Beryllium (ug/L) 2 5/2/2019 2.83 NS NA NS NA Cadmium (ug/L) 6.43 8.24 NA NA Fluoride (mg/L) 0.47 0.839 NA NA Nickel (ma/L) 50 63.9 NA NA Thallium (ug/L) 2.01 2.73 NA NA Field pH (S.U.) 5.03 - 8.5 4.53 NA NA MW-27 (Class III) Nitrate + Nitrite (as N) (mg/L) 5.6 4/23/2019 6.33 NS NA NS NA Chloride (mg/L) 38 32.0 NA NA MW-28 (Class III) Chloride (mg/L) 105 4/24/2019 165 NS NA NS NA Cadmium (ug/L) 5.2 5.11 NA NA Selenium (ug/L) 11.1 12.4 NA NA Gross Alpha (pCi/L) 2.42 1.94 NA NA Uranium (ug/L) 4.9 9.60 NA NA MW-32 (Class III) Chloride (mg/L) 35.39 4/9/2019 34.5 NS NA NS NA MW-35 (Class 11) Nitrogen, Ammonia as N 0.14 4/18/2019 0.0634 NS NA NS NA Notes: NS= Not Required and Not Sampled NA= Not Applicable Exceedances are shown in yellow Pursuant to the DWMRC letter of May 22, 2019, this constituent will no longer be monitored on an accelerated schedule. This constituent will be dropped from this report after this quarter.