DRC-2013-003618 - 0901a068803e0311

Department of
Environmental Quality
Amanda Smith
Executive Director
DRC-2013-003618
State of Utah
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
December 9, 2013
Jo Ann Tischler, Manager, Compliance and Licensing
225 Union Blvd. Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc. 3rd Quarter 2013 Groundwater Monitoring Report for
the White Mesa Uranium Mill, Blanding, UT, Groundwater Discharge Permit No.
UGW370004: DRC Advisory and Close out
Dear Ms. Tischler:
The Utah Division of Radiation Control ("DRC") has reviewed the following Energy Fuels Resources
(USA) Inc. ("EFR") documents:
1. The EFR, November 20, 2013, 3rd Quarter 2013 Groundwater Monitoring Report ("Report")
Groundwater Discharge Permit UGW370004 ("Permit"), White Mesa Uranium Mill, and,
2. The EFR, November 15, 2013, Notice Pursuant to Part I.G.l(a) Q3, 2013.
The review was conducted with consideration of the following related actions:
1. An October 10,2012 EFR Source Assessment Report, an April 13, 2012 EFR pH Report, and a
December 12, 2012 EFR Pyrite Investigation Report for previously documented out-of-compliance
parameters (multiple parameters) which were required per DRC Stipulated Consent Agreement,
Docket No. UGW 12-03. Per DRC findings, and as documented in a DRC review memo, dated
April 23, 2013 and transmitted via letter to EFR dated Apnl 25, 2013, it is recommended that; 1.
Specific GWCL parameters for site momtonng wells be modified (12 instances), 2. GWCL's for
pH be modified for all site momtonng wells, and 3. GWCL's be removed from the Permit for 3
monitoring wells up gradient from the site. These requests are currently being addressed through
the permit modification process.
2. A May 25, 2012 EFR Permit Modification Request - DRC notified EFR by letter (dated April 16,
2012) that m order to formalize an April 5, 2010 telephone discussion between DRC and EFR
representatives, allowing a change to accelerated monitoring requirements, a written request was
required for Director review and approval. Subsequently, EFR submitted a May 25, 2012 wntten
request for the Permit modification, including redline copies of pertinent pages of the Permit to
reflect the agreements made dunng the April 5, 2010 conference call. This request is currently
being addressed through permit modification.
Blind Duplicate Sample Collection — Advisory
Per DRC staff review of the blind duplicate sample collection and analysis dunng the 3rd Quarter 2013,
four blind duplicate samples were collected (2 routine ground water monitonng samples and 2 accelerated
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D [phone]
www deq Utah gov
Printed on 100% recycled paper
Jo Ann Tischler
Page 2
monitoring samples), however only eight parameters were analyzed and compared since all four samples
constituted accelerated monitoring with a limited list (OOC parameters only). The White Mesa Facility
Quality Assurance Plan does not require that blind duplicate samples be collected from groundwater
monitoring wells dunng routine baseline monitoring events for the compliance parameters required at each
well; however, when done this allows for a more comprehensive comparison of laboratory analytical
precision and accuracy. The DRC notes that none of the duplicate samples were submitted to GEL
Laboratones for analytical comparison (no radiological samples were split). Historically in past EFR
sampling events, the duplicate samples were analyzed for all parameters.
In order to provide a comprehensive review of all laboratory analyses for all compliance parameters, DRC
advises that future blind duplicate samples should be collected from wells during baseline frequency
monitoring. This issue was discussed between DRC and EFR staff dunng a December 5,2013 phone call,
at which time it was agreed that baseline monitonng blind duplicates will be submitted for analysis
beginning dunng the 4th Quarter 2013.
Report Close out
DRC review of the Report included:
1. Field Data Worksheets,
2. Accelerated Monitoring Parameters,
3. Internal Quality Assurance/Quality Control ("QA/QC") Evaluation including review of the EFR
Blind Duplicate Samples (Relative Percent Difference Calculations),
4. Laboratory Analysis Results,
5. Laboratory Sample Turn Around Times (Receipt of Reports by EFR),
6. Conformance with Sample Holding Times,
7. Time/Concentration Plots for Chloride, Fluonde, Sulfate and Uranium, and,
8. Depth to Water & Groundwater Elevation Measurement and Mapping
Based on review of the Report, it appears that all requirements of the Permit were addressed in the 3rd Qtr.,
2013 Groundwater Monitoring Report. Therefore, the review is hereby closed out.
If you have any questions regarding this letter or the review findings please contact Tom Rushing at
[phone].
Sincerely,
RL:TR:tr
U \MON_WASTATrushing\Energy Fuels\Groundwater Reports\2013 Groundwater Reports\3rd Quarter 2013\EFR 3rd 2013 GW Report Advisory
and Close out docx