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HomeMy WebLinkAboutDRC-2019-014447 - 0901a06880b6787dDiv of f and Radiation Control NOV 1 2 2019 Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com November 7, 2019 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 PF—t—ZOtc?-0141`F7 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 third quarter ("Q3") groundwater monitoring during the period from July 1, to September 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 October 17, 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 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. ("EFRr') 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 November 7, 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 Q3 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 November 7, 2019 Page 3 MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in all of the Q3 sampling events. This consecutive exceedance is addressed in the SAR, dated June 27, 2019. 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. MW-26 • Nitrate + nitrite has exceeded its GWCL in all of the Q3 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 Q3 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 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. • The chloride concentration exceeded its GWCL in all of the Q3 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 Q3 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 Q3 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 November 7, 2019 Page 4 • Uranium concentrations exceeded the GWCL in MW-30 in the Q3 and August 2019 sampling events. This consecutive exceedance is addressed in the SAR, dated January 15, 2019. 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. • Selenium concentrations exceeded the GWCL in MW-30 in all of the Q3 2019 sampling events. This consecutive exceedance is addressed in the SAR, dated January 15, 2019. 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. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Q3 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 Q3 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 Q3 Seven new exceedances for the Q3 2019 quarterly well sampling program are listed below. These exceedances will result in an accelerated sampling frequency from quarterly to monthly. The wells listed below will only be sampled during the monthly events for those constituents that exceeded the GWCLs. The wells 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. • Sulfate in MW-11 was slightly above the GWCL in the Q3 (July) sampling event. • Chloride in MW-11 was slightly above the GWCL in the Q3 (July) sampling event. • Sulfate in MW-14 was slightly above the GWCL in the Q3 (July) sampling event. • Fluoride in MW-14 was slightly above the GWCL in the Q3 (July) sampling event. • Total Dissolved Solids ("TDS") in MW-31 was slightly above the GWCL in the Q3 (July) sampling event. • Sulfate in MW-31 was slightly above the GWCL in the Q3 (July) sampling event. • Sulfate in MW-36 was slightly above the GWCL in the Q3 (July) sampling event. Letter to Mr. Ty L. Howard November 7, 2019 Page 5 Relative to accelerated reporting requirements, based on phone conversations with DWMRC on April 5, 2010, 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. Per teleconferences with DW1VIRC, EFRI proposed modified language for the GWDP, Part 1.G.1 on May 25, 2012, to document DWMRC concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 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 rešpective GWCLs for two successive sampling periods (Q2 2019 and Q3 2019). MW-24 • Thallium concentrations exceeded the GWCL in MW-24 in the Q2 2019 and Q3 2019 sampling events. Thallium exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI is installing a collocated well to study potential installation issues associated with MW-24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. • Beryllium concentrations exceeded the GWCL in MW-24 in the Q2 2019 and Q3 2019 sampling events. Beryllium exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI is installing a collocated well to study potential installation issues associated with MW-24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. • Cadmium concentrations exceeded the GWCL in MW-24 in the Q2 2019 and Q3 2019 sampling events. Cadmium exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI is installing a collocated well to study potential installation issues associated with MW-24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. • Fluoride concentrations exceeded the GWCL in MW-24 in the Q2 2019 and Q3 2019 sampling events. Fluoride exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI is installing a collocated well to study potential installation issues associated with MW-24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. Letter to Mr. Ty L. Howard November 7, 2019 Page 6 . Nickel concentrations exceeded the GWCL in MW-24 in the Q2 2019 and Q3 2019 sampling events. Nickel exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI is installing a collocated well to study potential installation issues associated with MW-24. DWIVIRC approved the collocated well strategy by letter dated September 5, 2019. As a result of DWIVIRC's acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. MW-27 • The nitrate+nitrite concentration exceeded its GWCL for both the Q2 2019 sampling event and the Q3 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 Q2 2019 sampling event and the Q3 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 Q2 2019 sampling event and the Q3 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 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. 2.2 Semi-annual Wells with New Exceedances Reported in Q3 No new single exceedances were reported for the Q3 2019 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 kitLa Table 1 - GWCL Exceedances for Third Quarter 2019 under the March 19, 2019 GWDP Q2 2019 Results Q3 2019 Results Monitoring Well (Water Class) MW-11 (Class 11) 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 Monthl y Result Wells Q3 2019 Sample Date Q3 2019 Result August 2019 Monthly Sample Date August 2019 Monthly Result Sept. 2019 Monthly Sample Date Sept. 2019 Monthly Result Chloride (mg/L) 39.16 4/24/2019 34 equired 5/7/2019 Quarterly Sampling 6/3/2019 NA 7/16/2019 48.4 8/5/2019 NA 9/24/2019 NA NA Sulfate (mg/L) 1309 1160 NA NA 1410 NA NA Manganese (ug/L) 164.67 181 210 210 199 202 1 74 MW-14 (Class III) Fluoride (mg/L) 0.22 4/23/2019 <0.100 NS NA NS NA 7/15/2019 0.248 NS NA NS NA Sulfate (mg/L) 2330 1780 NA NA 2450 NA NA MW-25 (Class III) Cadmium (ug/L) 1.5 4/10/2019 1.30 5/8/2019 1.41 6/4/2019 1.47 7/15/2019 1.23 8/6/2019 1 7 9/23/2019 1.38 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 7/16/2019 2.06 8/6/2019 3.10 9/24/2019 1.59 Chloroform (ug/L) 70 4140 1140 778 3110 1090 1540 Chloride (mg/L) 58.3 82.0 73.0 72.6 75.2 83.5 62.1 Me hylene Chloride (ug/L) 5 4.16 1.69 <1.00 10.7 1.12 3.35 Nitrogen, Ammonia as N 0.92 0.104 0.479 0.0919 0.357 0.164 0.496 MW-30 (Class II) Nitrate + Nitrite (as N) (mg/L) 2.5 4/9/2019 18.5 5/7/2019 17.9 6/3/2019 15.8 7/16/2019 19.3 8/6/2019 15.8 9/24/2019 1 7.9 Chloride (mg/L) 128 138 175 165 181 190 176 Selenium (ug/L) 47.2 53.6 47.1 49.9 48.4 50.9 49.1 Uranium (ug/L) 8.32 8.62 8.15 8.88 9.03 9.39 8.12 Field pH (S.U.) 6.47 - 8.5 7.06 7.00 7.12 6.86 7.42 7.00 MW-31 (Class III) Nitrate + Nitrite (as N) (mg/1,) 5 4/10/2019 19.7 5/7/2019 18.9 6/3/2019 19.7 7/15/2019 19.8 8/5/2019 17.0 9/23/2019 19.5 Sulfate (mg/L) 993 9 7 NA NA 1150 NA NA TDS (mg/L) 2132 2080 NA NA 2580 NA NA Chloride (mg/L) 143 294 346 325 374 372 365 MW-36 (Class HI) Sulfate (mg/L) 3146.21 4/18/2019 2470 5/21/2019 NA 6/3/2019 NA 7/16/2019 31 70 8/6/2019 NA 9/23/2019 NA Field .H S.U.) 6.49 - 8.5 7.05 6.73 7 01 6.60 7.33 6.92 MW-05 (Class II) Uranium (uell,) 7.5 4/24/2019 0.959 NS NA -ing Wells NS NA 7/11/2019 0311 NS NA NS NA MW-12 (Class III) Uranium (itg/1.) 23.5 4/25/2019 23.2 NS NA NS NA 7/11/2019 23.1 NS NA NS NA MW-24 (Class III) Beryllium (ug/L) 2 5/2/2019 2.83 NS NA NS NA 7/18/2019 2.94 NS NA NS NA Cadmium (ug/L) 6.43 8.24 NA NA 8.37 NA NA Fluoride (mg/L) 0.47 0.839 NA NA 0.996 NA NA Nickel (mg/L) 50 63.9 NA NA 70.6 NA NA Thallium (ug/L) 2.01 2.73 NA NA 2.61 NA NA Field pH (S.U.) 5.03 - 8.5 4.53 NA NA 5.03 NA NA MW-27 (Class III) Nitrate + Nitrite (as IN) (ng/1,) 5.6 4/23/2019 6.33 NS NA NS NA 7/12/2019 8/15/2019 6.50 NS NA NS NA Chloride (mg/L) 38 32.0 NA NA 30.8 NA NA MW-28 (Class III) Chloride (mg/L) 105 4/24/2019 165 NS NA NS NA 7/12/2019 8/16/2019 133 NS NA NS NA Selenium (ug/L) 11.1 12.4 NA NA 10.6 NA NA Gross Alpha (pCi/L) 2.42 1.94 NA MMMI 1.20 NA NA Uranium (ug/L) 4.9 9.60 NA NA 7.83 NA NA MW-32 (Class III) Chloride (mg/L) 35.39 4/9/2019 34.5 NS NA NS NA 8/15/2019 35.7 NS NA NS NA MW-35 (Class 11) Nitrogen, Ammonia as N 0.14 4/18/2019 0.0634 NS NA NS NA 7/11/2019 0.0935 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 August 6, 2019, these constituents will no longer be monitored on an accelerated schedule. These constituents will be dropped from this report after this quarter.