DRC-2014-001041 - 0901a068803f3a29

Department of
Environmental Quality
Amanda Smith
Executive Director
DRC-2014-001041 GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCERJ COX
Lieutenant Governor
January 7, 2014
Kathy Weinel, Quality Assurance Manger
Energy Fuels Resources (USA) Inc.
225 Union Blvd, Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc. December 17, 2013 Source Assessment and
Literature Search Report, Tetrahydrofuran in MW-1 White Mesa Mill: DRC
Findings and Recommendation
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has reviewed the Energy Fuels Resources
(USA) Inc. ("EFR") December 17, 2013 Transmittal of Source Assessment and Literature Search
Report, Tetrahydrofuran in Monitoring Well MW-1 White Mesa Mill Groundwater Discharge
Permit UGW370004 ("SAR"). The SAR was conducted by Energy Fuels Resources (USA) Inc.
("EFR") in response to a Utah Division of Radiation Control ("DRC") Notice of Violation,
Docket No. UGW13-05 ("NOV") issued on July 23, 2013. The NOV required EFR to submit a
Plan and Time Schedule for investigation of the THF exceedances within 30 calendar days of
receipt ofthe NOV (Letter dated July 25, 2013).
A response to the NOV, which included a Plan and Time Schedule, was subsequently received by
DRC on August 27, 2013 and stated that EFR mistakenly assumed that the Source Assessment
Report requirements of the White Mesa Mill Ground Water Discharge Permit were not required
based on a DRC April 25, 2013 letter which agreed to remove Ground Water Compliance Limits
from monitoring well MW-1. EFR committed to submit a Source Assessment Report within 90
days from DRC Director Approval ofthe Plan and Time Schedule. The August 27,2013 Plan and
Time schedule was approved by the Director on September 17, 2013. The SAR was subsequently
dated and received by DRC on December 17, 2013 (via e-mail), and via mail on December 19,
The SAR provides findings that THF well MW-1 is not due to impact from Mill Discharges as
follows:
• Measured groundwater elevation at monitoring well MW-1 is approximately 9 feet
2013.
Findings:
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
Kathy Weinel
Page 2
higher than the groundwater elevation measured at upgradient portions of the Mill
tailings cells,
• MW-1 is approximately 0.4 miles hydraulically up gradient ofthe Mill facilities.
The SAR additionally includes a summary of three different literature sources which were
reviewed to support the claim that monitoring well glues and solvents, used during well
construction could be the source of THF at monitoring well MW-1. DRC staff additionally
reviewed each ofthe summarized literature sources to support the EFR claims. A discussion of
each of the literature source findings is below:
1. William Martin and C. Chow Lee, 19891: EFR review of Martin and Lee confirmed that
in the case of THF contamination due to well joint glues the concentrations will persist for
extended periods of time. The SAR quotes the Martin and Lee p. 211 as follows: "The
further increase in THF concentration 2 to 4 days after purging suggests that THF may be
rapidly diffusing from the PVC glued joints into fresh formation water entering the well."
DRC further notes that these effects may last for extended periods of time after well
construction as noted on p. 214 "As these investigations have shown (At least for cement
grout and THF contamination) anomalies attributable to well construction can persist for
many years, if not for the lifetime of the monitoring well despite repeated development and
monitoring." Martin and Lee reported groundwater leached concentrations of 460|ig/L at
20 days after monitoring well construction, i
The Martin and Lee reference supports the EFR claim that the THF source in monitoring
well MW-1 is potentially from glues used during well construction. Analytical results for
THF in monitoring well MW-1 are not far outside of concentrations observed by Martin
and Lee 20 days after monitoring well construction.
2. United States Geological Survey, 19952: Reference discusses ground water monitoring
well materials, design, and installation and interferences that occur based on materials and
design. Sections of the reference discuss specific PVC well casing glues and biases that
occur in analysis for volatile organic contaminants including THF, MEK, MIBK and
Hexanone.
3. United States Geological Survey, 20123: THF concentrations detected in monitoring well
samples cannot be attributed to aquifer concentrations due to potential contamination from
organic constituents in joint glue and/or decontamination procedures of sampling
equipment at the Study Reporting Limits.
Martin, William H and C Chow Lee Persistent pH and Tetrahydrofuran Anomalies Attributable
to Well Construction Woodward-Clyde Consultants, Oakland, California 1989 2
U S Geological Survey Open File Report 95-398 Ground-water Date-Collection Protocols and
Procedures for the National Water-Quality Assessment Program Selection, Installation,
and Documentation of Wells, and Collection of Related Data 1995
3
U S Geological Survey Scientific Investigations Report Evaluation of Volatile Organic
Compound (VOC) Blank Data and Application of Study Reporting Levels to
Groundwater Data Collected for the California GAMA Priority Basin Project, May 2004
through September 2010 Pub 2012
Kathy Weinel
Page 3
Conclusions:
Per review of the EFR Source Assessment and Literature Findings regarding THF exceedances at
monitoring well MW-1, DRC concurs that the source of THF contamination does not appear to be
due to any White Mesa Mill tailings solution release or operations. Per DRC review ofthe
literature sources, it appears that monitoring well construction including PVC casings with glued
joints is a potential and likely source of THF in the monitoring well. DRC notes that the literature
sources support long term impacts (organic leaching) due to well construction materials.
Per the SAR, EFR plans to re-evaluate the "status of THF' in well MW-1 after the collection of
additional accelerated samples through the second quarter of 2014. The SAR then states that "if
THF levels remain below the GWCL during the four quarters ending the second quarter of 2014,
EFRIwill resume semi-annual monitoring of MW-1 for THF." This is inconsistent with prior
actions to return wells/parameters to baseline monitoring frequency. DRC does not agree with the
EFR conclusion to automatically return monitoring well MW-1 to baseline frequency based on the
EFR re-evaluation. DRC additionally notes that the planned approach will not provide at least
eight accelerated samples with results below the GWCL.
Accelerated monitoring of THF in monitoring well MW-1 may be discontinued and returned to
baseline semi-annual monitoring only if:
1. EFR submits a request to the Director to return MW-1 to baseline monitoring which
includes at least eight groundwater sample results for THF below Ground Water
Compliance Limits listed in the Permit and the EFR request is subsequently approved, or,
2. GWCL's for monitoring well MW-1 are removed from the Permit by authorization by the
Director (Permit Modification) after public hearing and comments have been received and
addressed.
Recommendation:
As discussed between representatives of DRC and EFR during a January 7,2014 phone
conference, it is recommended that EFR postpone the submission of additional evaluation until an
option for return to baseline monitoring, as listed in the conclusions section above, can be
determined.
If you have questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
RL:TR:tr
U \MON_WAST\Trushing\Energy FuelsYTHF SAR 12-17-13YTHF SAR DRC Findings Ltr docx