DRC-2014-002081 - 0901a0688040ddd7

I II inrn 11111
fin ^OT'OSv JWS
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO DRC-2014-002081
THROUGH: Phil Goble, Manager, Compliance Section i/T/^
Tom Rushing, P.G. v-> p FROM:
DATE:
SUBJECT
March 5, 2014
DRC Review of Energy Fuels Resources (USA) Inc. Documents Dated January 13,
2014 (Source Assessment Report for Gross Alpha in Groundwater Monitoring
Well MW-32), and January 28, 2014 (Removal of Certain Groundwater
Monitoring Parameters from Accelerated Monitoring Status)
Summary:
This memorandum is to summarize Utah Division of Radiation Control ("DRC") findings
regarding review of two submittals from Energy Fuels Resources (USA) Inc. ("EFR") and
regarding the White Mesa Uranium Mill ("Mill") as follows:
• EFR January 13, 2014, Source Assessment Report for Gross Alpha in MW-32, White Mesa
Uranium Mill
• EFR January 28, 2014, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status
DRC review findings regarding each of the documents are below.
EFR January 13, 2014 Source Assessment Report for Gross Alpha (MW-32)
DRC review findings regarding the EFR document dated January 13, 2014 (Received by DRC
January 14, 2014) and titled Source Assessment Report for Gross Alpha in MW-32, White Mesa
Uranium Mill ("SAR") are summarized in this section. Monitoring well MW-32 is located at the
southeast corner of tailings cell 2.
When conducting source assessment evaluations, EFR first categorizes the well and out-of-
compliance ("OOC") parameter into one of five categories as follows:
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 2
1. Constituents in wells with previously identified rising trends.
2. Constituents in pumping wells.
3. Constituents potentially impacted by decreasing trends in pH across the site.
4. Newly installed wells with interim GWCLs.
5. Other constituents and wells.
In the case of gross alpha in monitoring well MW-32 EFR conducted the assessment under the
category "other constituents and wells." EFR considers this category to be appropriate since the
proposed cause of the OOC is due to limited data at the time of the GWCL statistical analysis and
development. EFR notes that at the time of the original GWCL calculation only eight sample
results were available; since that time forty-two sample results have been obtained.
In order to determine if the OOC was due to natural background fluctuations or leakage from the
Mill tailings cells, EFR conducted reviews of reports and data results for indicator parameters and
groundwater flow calculations. Findings regarding EFR review and determination of background
are as follows.
Background Report
EFR notes that at the time of the background evaluation for monitoring well MW-32 a small
amount of data was available for statistical evaluation (MW-32 was reviewed based on eight
sample results for most parameters). Since the time of the background evaluation a significantly
larger amount of data has been collected for gross alpha (currently forty two sample results). This
allows for a more representative pool of samples and also allows for evaluation of potential trends
in the data. As shown on the plot below, no apparent upward trend is evident for gross alpha in
monitoring well MW-32.
Figure 1 - Ground water plot and trend data for gross alpha in monitoring well MW-32
u
a. ro
JZ CL
18
16
14
12
10
8
6
4
2
0
MW-32 Gross Alpha pCi/L
Jan-04 May-05 Oct-06 Feb-08 Jul-09
Date
Nov-10 Apr-12 Aug-13 Dec-14
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 3
UofU Study
The SAR notes that the University of Utah ("U of U") Study (Hurst and Solomon, 2008)
concludes that groundwater at the White Mesa Uranium Mill has not been affected by Mill
operations. The SAR additionally notes that monitoring well MW-32 was not specifically
analyzed during the U of U Study; however, site study indicated that groundwater in the vicinity
of the White Mesa Mill is older than the age of the Mill "indicating no mill-related impacts to
groundwater.''''
DRC notes that the U of U Study included monitoring well MW-31 which is located
approximately % mile west of monitoring well MW-32 and is hydraulically cross gradient (per
kriged 4th Quarter 2013 water levels). Per isotopic results for chlorofluorocarbons and tritium, it
was noted that the Burro Canyon Formation ground water at that location predated the Mill and
was not likely impacted by Mill activities (seepage from tailings cell 2). The results of isotopic
sampling, comparison of CFC's and tritium, also indicated slow recharge water velocities through
the vadose zone in the area of MW-31.
Helium isotope ratios indicate tritiogenic helium-3 in shallow zones in monitoring well MW-30
(approximately V% mile west from monitoring well MW-32 and hydraulically downgradient)
indicating a "potential" that some "young" water has been transported to the water table (source
assumed to be the upper wildlife ponds). The study concludes that helium concentrations without
supporting concentrations of other radiological isotopes indicate that the recharge source was not
from the tailing cells.
Indicator Parameters
Per EFR analysis of indicator parameters chloride, fluoride and sulfate and uranium
concentrations in MW-32 are not exhibiting significant trends, with the exception of uranium
which is exhibiting a significantly decreasing trend. DRC plots and trend-lines are included
below:
60
50
40
J 20
5 10
0
MW-32 Chloride Plot
Jan-04 Oct-06 Jul-09 Apr-12 Dec-14
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 4
0.35
0.3
0.25
0.2 <u ? 0.15 o
= 0.1
MW-32 Fluoride
7^ • •••
0.05
0
Jan-04 Oct-06 Jul-09 Apr-12 Dec-14
3,000
2,500
-J
2,000
« 1,500
~ 1,000
vt
500
0
Jan-04
MW-32 Sulfate
Oct-06 Jul-09 Apr-12 Dec-14
E
J4
c re „ •i; 2
0
MW-32 Uranium
Jan-04 Oct-06 Jul-09 Apr-12 Dec-14
Per the EFR report there are some differences between concentration plots at the time of the
background report and current concentration plots for chloride and sulfate. Specifically, chloride
showed a decreasing trend at the time of the background report and now shows a slight increasing
trend. Sulfate concentrations showed a significantly increasing trend at the time of the
background report and are now slightly decreasing. EFR attributes these differences to the small
set of data results which were available at the time of the background report.
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 5
Although some inconsistencies with the EFR background report are evident, it appears that the
EFR conclusion that the differences were caused by a relatively small set of data results at the
time of preparation of that report is likely. Based on DRC review of the SAR and data results it
appears unlikely that the gross alpha results above the GWCL are due to tailings cell leakage.
EFR Proposed Modified GWCL
Based on the EFR conclusion that gross alpha exceedances in monitoring well MW-32 are due to
a small background data set at the time of the background calculation and/or due to background
geochemical influences, the SAR includes statistical tests and calculations for an EFR proposed
revised GWCL. DRC reviewed the statistical tests and calculated background calculations as
follows:
• DRC reviewed the data used in statistical analysis of gross alpha at well MW-32 to ensure
that the data was appropriate (e.g. outliers and autocorrelation removed).
• Shapiro-Wilk Test for Normality of Data was cross checked by DRC (see attachment 1)
using the EFR data set to ensure consistency (comments below).
• DRC cross checked the EFR statistical process against the Director approved Statistical
Process Flow Chart to ensure conformance with the required tests.
Shapiro Wilk Test Cross Check
Per DRC cross check of the EFR Shapiro-Wilk Test for Normality for gross alpha in monitoring
well MW-32, using the EFR data set, it was noted that the results are similar. EFR and DRC
calculations are compared on the table below:
Parameter EFR Calculation DRC Calculation
W (Critical Value 0.922) 0.99 0.93
Mean 3.36 3.36
Standard Deviation (0.01) 1.83 1.78
Calculated GWCL 7.0 6.9
Based on the findings the DRC and EFR calculations are comparable and the EFR calculation
appears to be appropriate. Therefore, DRC staff recommends that the EFR proposed modified
GWCL be approved through inclusion in a permit modification or renewal subject to public
participation and hearing requirement included in the Utah Administrative Code R317-6-6.5.
Well No.
MW-32
Parameter
Gross Alpha
Current GWCL
3.33 pCi/L
EFR Proposed GWCL
7pCi/L
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 6
EFR January 28, 2014 Request to Return Groundwater Monitoring Parameters to Baseline
Monitoring Frequency
A January 28, 2014 EFR letter requests that the following wells/parameters be returned to baseline
monitoring frequency:
• Monitoring Well MW-14/Manganese
• Monitoring Well MW-23/Manganese
• Monitoring Well MW-25/Chloride
• Monitoring Well MW-11/Field pH
• Monitoring Well MW-31/Field pH
• Monitoring Well MW-15/Iron
The January 28, 2014 request is based on the most recent laboratory results for these
wells/parameters showing results less than the Ground Water Compliance Limits ("GWCL's")
listed in the White Mesa Uranium Mill Facility Ground Water Discharge Permit, Permit No.
UGW370004 ("Permit"), for more than eight consecutive monitoring events (monthly accelerated
monitoring).
Per DRC review of the laboratory results it was noted that the requested wells/parameters showed
more than eight consecutive monthly laboratory results below the GWCL as follows:
Monitoring Well No. Parameter # Consecutive Lab Results below the GWCL
MW-14 Manganese 10 - Since lsl Quarter 2013
MW-23 Manganese 8- Since g Quarter 2011
MW-25 Chloride 8-Since 1st Quarter 2013
MW-11 Field pH 8-Since April 2013
MW-31 Field pH 8-Since April 2013
MW-15 Field pH 8-Since 4"^ Quarter 2011
DRC also notes that laboratory analytical data sheets and sample collection field sheets were
included with the January 28, 2014 letter, to provide confirmation of data results which had not
yet been received by DRC in quarterly ground water reports. The 4th Quarter 2013 Groundwater
Monitoring Report for the White Mesa Uranium Mill was also received by the Division of
Radiation Control on February 14, 2014.
Based on DRC review of the January 28, 2014 EFR request and confirmation by DRC that at least
eight consecutive sampling results are below the GWCL's, it is recommended that the following
wells/parameters be authorized to be returned to baseline monitoring frequency, approval by
Director letter, for the listed parameters as follows:
Well Number
MW-14
Parameter
Manganese
Baseline Monitoring Frequency
(Permit Part I.E.l.b)
Quarterly
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 7
Well Number Parameter Baseline Monitoring Frequency
(Permit Part I.E.l.b)
MW-23 Manganese Semi-annual
MW-25 Chloride Quarterly
MW-11 Field pH Quarterly
MW-31 Field pH Quarterly
MW-15 Field pH Semi-annual
The wells/parameters are subject to future accelerated monitoring requirements per the
requirements of the Permit Part LG. should future exceedances of GWCL's occur.
Conclusions
Based on review of the EFR SAR and letter request to return several wells/parameters to baseline
monitoring frequency, and as discussed in findings above, the following conclusions were made:
1. The SAR claim that OOC status for gross alpha in monitoring well MW-32 is due to
premature analysis to set GWCL's, using only eight data points, appears to be appropriate
based on review of subsequent data points, justifications made according to the
background report, U of U study, and indicator parameter concentrations. The statistical
evaluation of gross alpha data appears to be appropriate and in conformance with the
Director Approved statistical flow chart for the White Mesa Uranium Mill facility.
Therefore, it is recommended that the proposed modified GWCL of 7 pCi/L replace the
current GWCL (3.3 pCi/L) and be included in a modified or renewal permit. The current
GWCL is required and enforceable until such time as the Permit modification has been
approved by the Director, after the permitting process including public participation and
hearing requirements set forth in the Utah Administrative Code R317-6-6.5.
2. The EFR request to return the wells/parameters listed in the table below is recommended
to be approved based on at least eight consecutive sample results below the GWCL since
the last exceedance:
Well Number Parameter Baseline Monitoring Frequency
(Permit Part I.E.l.b)
MW-14 Manganese Quarterly
MW-23 Manganese Semi-annual
MW-25 Chloride Quarterly
MW-11 Field pH Quarterly
MW-31 Field pH Quarterly
MW-15 Field pH Semi-annual
EFR January 13, 2014 and January 28, 2014 Submittals
DRC Review Memo
Page 8
References
Denison Mines (USA) Corp., October, 2007, Revised Background Groundwater Quality Report,
Existing Wells for Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah
Energy Fuels Resources (USA) Inc., January 13, 2014, Source Assessment Report for Gross Alpha
in MW-32 White Mesa Uranium Mill, Prepared by INTERA Geoscience & Engineering Solutions
Energy Fuels Resources (USA) Inc., January 28, 2014, State of Utah Ground Water Discharge
Permit No. UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater
Monitoring Parameters from Accelerated Monitoring Status
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 Near Blanding, Utah, Prepared by Department of Geology and Geophysics,
University of Utah
U.S. Environmental Protection Agency, March 2009, Statistical Analysis of Groundwater
Monitoring Data at RCRA Facilities, Unified Guidance
Appendix 1 - DRC Cross Check of the Shapiro-Wilk Test for Data Normality Gross Alpha
Monitoring Well MW-32
Shapiro Wilk (n<50) Method DRC Cross Check Data Entered 3/3/2014 TR
Energy Fuels Monitoring Well MW-32 Gross Alpha Shapiro Wilk
10
11
12
13
14
15
16
17
18
19
20
21
I I x(i) x(n-1+1) xfn-i+I^O) a(n-i+1)
1.4
1.4
1.5
1.6
1.6
1.7
1.8
1.8
1.9
1.9
2.4
2.4
2.5
2.6
2.6
2.7
2.8
2.9
2.9
9.2
8.8
6.46
5.8
5.5
5.3
5.02
4.6
4.5
3.9
3.72
3.7
3.7
3.5
3.5
3.4
3.1
2.97
8.2
7.4
5.06
4.3
3.9
3.7
3.32
2.8
2.7
2.1
2.1
1.9
1.32
1.3
1.2
0.9
0.9
0.7
0.3
0.1
0.07
0.3917
0.2701
0.2345
0.2085
0.1874
0.1694
0.1535
0.1392
0.1259
0.1136
0.102
0.0909
0.0804
0.0701
0.0602
0.0506
0.0411
0.0318
0.0227
0.0136
0.0095
3.21194
1.99874
1.18657
0.89655
0.73086
0.62678
0.50962
0.38976
0.33993
0.23856
0.2142
0.17271
0.106128
0.09113
0.07224
0.04554
0.03699
0.02226
0.00681
0.00136
0.000665
Date
2/20/2008
11/10/2010
7/9/2013
12/9/2008
2/2/2009
1/29/2008
2/19/2013
4/1/2011
4/20/2010
5/14/2008
10/14/2009
1/12/2010
5/13/2013
11/5/2008
10/3/2011
6/5/2008
7/9/2008
4/29/2008
9/22/2005
10/24/2007
11/6/2012
Data Result
pCi/L
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
2.97
3.1
3.4
3.5
3.5
3.7
3.7
3.72
3.9
4.5
4.6
5.02
5.3
5.5
5.8
6.46
8.8
9.2
2.9
2.9
2.8
2.7
2.6
2.6
2.5
2.4
2.4
1.9
1.9
1.8
1.7
1.6
1.6
1.5
1.4
1.4
Standard Deviation Calculation:
-0.07 9/8/2008
-0.1 9/13/2010
-0.3 3/12/2008
-0.7 12/1/2010
-0.9 8/5/2008
-0.9 8/19/2009
-1.2 3/22/2006
-1.3 3/30/2005
-1.32 4/30/2012
-1.9 6/21/2006
-2.1 10/25/2006
-2.1 8/30/2011
-2.7 10/13/2008
-2.8 2/21/2012
-3.32 6/21/2007
-3.7 5/13/2009
-3.9 11/18/2009
-4.3 2/9/2011
-5.06 9/13/2006
-7.4 7/9/2012
-8.2 total = 12/14/2005
10.899343
Mean = 3.358809524 Variables = 131.2630295
Standard Deviation = 1.767854696
W Statistic 0.927093743
DRC Calculated Limit 6.9
.01 Critical n(42) = 0.922
Energy Fuels Calculated Limit