DRC-2013-003696 - 0901a068803e8d60

State of Utah
Department of
Environmental Quality
Amanda Smith
Executive Director
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2013-003696 SPENCER J COX
Lieutenant Governor
MEMORANDUM
TO: File
THROUGH: Phil Goble, Compliance Section Manager I*
FROM: Tom Rushing, P.G.
DATE: December 17, 2013
SUBJECT: Energy Fuels Resources (USA) Inc., December 5, 2013 Transmittal of Plan and
Time Schedule under Utah Ground Water Discharge Permit UGW370004 Part
I.G.4(d) White Mesa Mill
The December 5, 2013 Plan and Time Schedule addresses out of compliance status under Part
I.G.2 of the Permit for the 3rd Quarter, 2013. Specific constituents which went into out-of-
compliance (OOC) status during the period were 1) Sulfate in monitoring well MW-1, and,
2) Total Dissolved Solids in monitoring well MW-3 A.
The Plan and Time Schedule proposes the following actions for follow up in response to the OOC
status:
Sulfate in Monitoring Well MW-1- Background Determination:
Sulfate in monitoring well MW-1 was recognized to have a slight rising trend per Part 11.2 and
Table 16 of the Existing Wells Background Report (Intera October 2007). Per evaluation of
associated indicator parameter trends, conducted for the Plan and Time Schedule, it was noted
that: chloride and sulfate are exhibiting significant rising concentration trends, uranium is
exhibiting a significant decreasing trend, and fluoride is exhibiting a decreasing trend.
Monitoring well MW-1 is located far upgradient of the White Mesa Mill site and based on
groundwater contour mapping and groundwater flow directions it is highly unlikely that
increasing trends could be due to mill activities or leakage of tailings solutions into the
groundwater. Elevation contours at monitoring well MW-1 are higher than the Burro Canyon
Aquifer beneath the tailings cells. Monitoring well MW-11 is located hydraulically upgradient
from the White Mesa Mill.
Summary:
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax[phone] -TDD [phone]
www deq utah gov
Pnnted on 100% recycled paper
EFR December 5, 2013 Plan and Time Schedule
DRC Review Memo
Page 2
Sulfate in monitoring well MW-1 is therefore attributed to background groundwater
concentrations.
TDS in Monitoring Well MW-3A:
Per evaluation of indicator parameter trends at monitoring well MW-3 A it was noted that fluoride
is exhibiting a significantly decreasing trend, uranium is exhibiting a slight decreasing trend and
chloride and sulfate are not exhibiting statistically significant trends. Trend analysis therefore
indicates no potential tailings cell leakage and TDS in monitoring well MW-3A is attributed to
background groundwater concentrations.
Source Assessment Report:
EFR proposes to submit a source assessment report (SAR) within 90 days after approval of the
Plan and Time Schedule.
Previously identified rising trends (Sulfate in Monitoring Well MW-1):
The SAR will include an assessment of potential sources for sulfate in monitoring well MW-1
including an evaluation of the indicator parameters (chloride, fluoride, uranium and sulfate) to
determine ifthe behavior of the water has changed since the time of the background report. If the
exceedance is determined to be caused by background influences then no additional evaluations
will be conducted. Accelerated monitoring will continue and a revised GWCL will be proposed to
reflect changes in background conditions. Revised GWCL's will be proposed based on statistical
methods described in the background report (Intera October 2007) and the Director approved
statistical flowsheet.
Other Constituents (TDS in Monitoring Well MW-3 A):
EFR notes that the original approved GWCL for TDS in monitoring well MW-3A was developed
using only 9 data points and did not provide for good fitting trend line. Revised analysis will be
conducted using the now available data population, 29 data points. EFR will additionally conduct
a geochemical analysis of TDS and indicator parameters in monitoring well MW-3 A to determine
whether the behavior has changed since the background report (Intera October 2007). If the
additional analysis concludes that TDS concentrations are due to background concentrations, then
accelerated monitoring will continue and EFR will propose a revised GWCL using the same
methods as outlined for sulfate in monitoring well MW-1 discussed above.
Reports to be Prepared:
Per the Plan and Time Schedule the SAR will include discussions, results and conclusions per the
same format as submitted with the October 10, 2012 SAR which is consistent with past conditions
for approval.
EFR December 5, 2013 Plan and Time Schedule
DRC Review Memo
Page 3
Conclusions:
Based on DRC staff review of the December 5, 2013 Plan and Time Schedule, it appears that
sufficient justification that out of compliance status for Sulfate at monitoring well MW-1 and TDS
at monitoring well MW-3 A are attributable to background concentrations/influences in the Burro
Canyon Aquifer has been provided. It is therefore recommended that the Director approve the
proposed SAR which will provide additional justification that the out of compliance status is due
to background influences and, if appropriate, will provide proposed revised GWCL's for the
parameters of concern.
DRC staff additionally recommends that the report formatting, requiring the same format as the
October 10, 2012 SAR, be included as a condition for approval of the December 5, 2013 Plan and
Time Schedule. A conditional approval letter will be prepared for Director Signature.
References:
Energy Fuels Resources (USA) Inc., December 5, 2013, Transmittal of Plan and Time Schedule
under Utah Ground Water Discharge Permit UGW370004 Part I.GA(d) White Mesa Mill
Intera, October 2007, A Revised Background Groundwater Quality Report: Existing Wells for
Denison Mines (USA) Corp. 's Mill Site, San Juan County, Utah, Prepared by Intera Incorporated