DRC-2014-002125 - 0901a0688040fda0

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
March 10, 2014 DRC-2014-002125
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: DRC Review of Energy Fuels Resources (USA) Inc. Documents Dated January 13,
2014 (Source Assessment Report), and January 28,2014 (Removal of Certain
Groundwater Monitoring Parameters from Accelerated Monitoring Status): DRC
Review Findings
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has completed review of the following two
Energy Fuels Resources (USA) Inc. ("EFR") documents:
• 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
January 13, 2014 EFR Source Assessment Report:
The EFR January 13, 2014 Source Assessment Report ("SAR") requests that the Ground Water
Compliance Limit (GWCL) for gross alpha in monitoring well MW-32 be modified based on the
EFR conclusion that gross alpha exceedances in monitoring well MW-32 are due to a limited
background data set (eight data results) when calculating the Ground Water Compliance Limit
("GWCL"). 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 or industrial processes at the White
Mesa Mill.
The SAR includes summaries and data used for statistical tests to calculate a proposed modified
GWCL based on a larger data set (forty-two data results). DRC reviewed the statistical tests and
calculated background calculations as follows:
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
• 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 using the EFR data
set to ensure consistency.
• DRC cross checked the EFR statistical process against the Director approved Statistical
Process Flow Chart to ensure conformance with the required tests.
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 ground water permit modification or renewal, executed
and approved by the Director after fulfilment of public participation requirements outlined in the
Utah Administrative Code R317-6-6.5.
Well No. Parameter Current GWCL EFR Proposed GWCL
MW-32 Gross Alpha 3.33 pCi/L 7pCi/L
January 28, 2014 EFR Request to Return Wells/Parameters to Baseline Frequency Monitoring:
The January 28,2014 EFR letter requested 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 1SI Quarter 2013
MW-23 Manganese 8 - Since 41* Quarter 2011
MW-25 Chloride 8-Since 181 Quarter 2013
MW-11 Field pH 8-Since April 2013
MW-31 Field pH 8-Since April 2013
MW-15 Field pH 8 - Since 4T Quarter 2011
Kathy Weinel
Page 3
DRC also notes that laboratory analytical data sheets and sample collection field sheets were
included with the January 28, 2014 request, in order 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 received by the Division
of Radiation Control on February 14, 2014.
Based on DRC review of the EFR January 28, 2014 request to return the wells/parameters listed in
the table below to baseline momtoring frequency, the EFR request is hereby approved:
Well Numb er . Parameter Baseh^oMomtorihjg Frequency
(Permit ftart LE.l'.o) ' > . '",
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
Note that these monitoring wells/parameters are subject to future accelerated monitoring
requirements per the requirements of the Permit Part I.G. should future exceedances of GWCL's
occur.
If you have any questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Rusty Lundberg, Director
RL:TR:tr
U:\MON_WAST\Trushing\Energy Fuels\SAR Gross Alpha in MW-32\MW-32 SAR DRC Ltr.docx