DRC-2013-003422 - 0901a068803d1cdb

Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
October 8,2013
CERTIFIED MAIL
(Return Receipt Requested)
Jo Ann Tischler, Manager, Compliance and Licensing
225 Union Blvd.
Suite 600
Lakewood, CO 80228
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"DRC-2013-003422"
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JOANN TISCHLER doseout 10/8/13 tr
DIRECTOR OF COMPLIANCE
ENERGY FUELS RESOURCES (USA) INC
225 UNION BLVD STE 600
LAKEWOOD CO 80228
City, State, Z1P+4
PS Form 3800. Angus! 2006 See Reverse for Instructions
Subject: Energy Fuels Resources (USA) Inc. 2nd Quarter 2013 Groundwater Monitoring Report for
the White Mesa Uranium Mill, Blanding, UT, Groundwater Discharge Permit No.
UGW370004: DRC Conditional Approval 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, August 26, 2013,2nd Quarter 2013 Groundwater Monitoring Report ("Report")
Groundwater Discharge Permit UGW370004 ("Permit"), White Mesa Uranium Mill;
2. The EFR, August 23,2013, Notice Pursuant to Part I.G. 1 (a) Q2, 2013, and;
3. The EFR September 20,2013 Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part I.G.4(d) for the White Mesa Mill.
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. UGW12-03. Per DRC findings, and as documented in a DRC review memo, dated
April 23, 2013 and transmitted via letter to EFR dated April 25, 2013, it is recommended that; 1.
Specific GWCL parameters for site monitoring wells be modified (12 instances), 2. GWCL's for
pH be modified for all site monitoring wells, and 3. That 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 in 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 written
request for the Permit modification, including redline copies of pertinent pages of the Permit to
reflect the agreements made during the April 5, 2010 conference call. This request is currently
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]
»w deq Utah gov
Pnnted on 100% recycled paper
Jo Ann Tischler
Page 2
being addressed through permit modification.
Report Close out
DRC review of the Report included but was not limited to: j
1. Field Data Worksheets, •
2. Accelerated Monitoring Parameters, . • .
3. Internal Quality Assurance/Quality Control ("QA/QC") Evaluation including review ofthe 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, Fluoride, Sulfate and Uranium
8. Depth to Water & Groundwater Elevation Measurement and Mapping
Based on review of the Report, it appears that all requirements of the Permit have been addressed.
Therefore, the review is hereby closed out.
Conditional Approval for Adjusted Gross Alpha OOCPlan and Time Schedule, Monitoring Well
MW-32
EFR proposes to submit a Source Assessment Report ("SAR") for Adjusted Gross Alpha at monitoring
well MW-32 within 90 days of Director approval ofthe September 20, 2013 Plan and Time Schedule. Per
EFR, the SAR will include a geochemical analysis of gross alpha and indicator parameters (chloride,
fluoride, sulfate and uranium) in monitoring well MW-32. The intention will be to determine if "the
behavior of the water in MW-32 has changed since the time of the New Wells Backgrowid Reporf (Intera,
20071).
EFR notes that if the OOC status is determined to be caused by background influences, then no additional
evaluation to determine the extent and potential dispersion of the contamination will be necessary. In the
event that a background determination is made then EFR will submit to the Director, as part of the SAR, a
proposed revised GWCL for adjusted gross alpha in monitoring well .MW-32.
If a proposed revised GWCL is included, then statistical analysis, as described in the Existing Wells
Background Report (Intera, 2007), and according to the Director approved flow sheet for statistical
analysis of GWCL revisions will be used. EFR additionally notes that groundwater background
concentration determinations at the White Mesa Mill were recently studied per 1) The White Mesa
Background Groundwater Quality Report (Intera 20071), 2) The October 12, 2012 Source Assessment
Report2 for several parameters in OOC status, and 3) The University of Utah Study at the White Mesa Mill
(Hurst and.Solomon 20083). EFR notes that in some cases, such as at monitoring well MW-32, limited
indicator parameter data was available at the time of the past background studies.
INTERA Incorporated, 2007. Revised Background Groundwater Quality Report. Existing Wells
for Dension Mines'(USA) Corp.'s White Mesa Uranium Mill Site, San Juan County,
Utah
2 Energy Fuels Resources (USA) Inc., May. 7, 2013, Source Assessment Report for TDS in MW-29 White Mesa
Uranium Mill • • ,.•>*, .
3 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results.Interpretations and
Recommendations for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa Uranium Mill located
near Blanding Utah Prepared by the University of Utah Department of Geology and Geophysics
Jo Ann Tischler
Page 3
DRC notes that the proposed plan and time schedule for investigation of adjusted gross alpha at monitoring
well MW-32 is consistent with recent investigations for OOC parameters at other wells:
The EFR March 14, 2013 Plan and Time Schedule is hereby approved with the following condition's:
1. The SAR for Adjusted Gross Alpha at groundwater monitoring well MW-32 will include all
study elements and report structure of the October 10, 2012 EFR Source Assessment Report
(approved by the Director through Stipulated Consent Agreement UGW12-03), including
graphs, plots and charts, and;
2. The SAR will be submitted on or before 90 calendar days from EFR receipt of this conditional
approval letter. .
If you have any questions regarding this letter or the review findings'please contact Tom Rushing at
[phone]. . ' '
Rusty Lundberg, Director
RL:TR:tr
U \MON_WAST\Trush)ng\Energy Fuels\Groundwater Reports\2013 Groundwater Reports\2nd Quarter 2013\EFR 2nd 2013 Conditional Approval
and Close out docx
Sincerely,