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Home My WebLink AboutDRC-2016-005464 - 0901a06880619c9aLLRW/U-Mill Document Scanning Form Document Type _incomings j Outgoing^.. | Internal DRC ProgramLLRWf” 1 GSAI I U-Mill Facility/License # i ____________________PbSh<fi ^ Document Date Document Title Author(s)DOm \j-PMrl-0ivon Check Applicable Folder SelectionApplicatk>n|_( Correspondenci ComplianceL^J Licens GW Permit Check Applicable Document ClassAnalytical^ I Fi Email! [Inspection Report Other Letter Monitoring Report §R C ' Z O \ & - 00 5 A - & 4 - V3AvliOiT> ^89*, State of Utah GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director TO: FROM: DATE: MEMORANDUM DRc-2ou-oos4-£»4 Phil Goble Dean Henderson March 9, 2016 SUBJECT: Review of the 4th Quarter 2015 Nitrate Monitoring Report for the Nitrate Contamination Investigation, Energy Fuels Resources (USA) Inc. (“EFR“) White Mesa Uranium Mill, near Blanding, Utah The Utah Division of Waste Management and Radiation Control (“Division”) has reviewed the EFR February 23, 2016, White Mesa Uranium Mill 4th Quarter, 2015 Nitrate Monitoring (“Report”) for the Nitrate Contamination Investigation. For the review of this Report the following regulatory enforcement documents were used: • Corrective Action Plan for Nitrate White Mesa Uranium Mill near Blanding, Utah, May 7, 2012, (“CAP”) approved December 12,2012. • The EFR Quality Assurance Plan, June 7, 2012, Revision. 7.2 (“QAP”) REVIEW Monitor Well Sampling for the 4th Quarter 2015 In the quarter the following monitor wells were sampled and analyzed for inorganic chloride and nitrate + nitrite (as N) as required in the CAP: TWN-1, TWN-2, TWN-3, TWN-4, TWN-7, TWN-18, TW4-22 (pumping well), TW4-24 (pumping well), and TW4-25 (pumping well), and Piezometer 1, Piezometer 2, and Piezometer 3. In each quarter the monitoring wells were purged using the three approved QAP well purging strategies and meet QAP requirements for each strategy: 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4414 www.deq.utah.goo Printed on 100% recycled paper Page 2 1. Purging two casing volumes with stable field parameters for specific conductivity, turbidity, pH, redox potential, and water temperature (within 10% RPD): Wells: TWN-1, TWN-4, and TWN-18. 2. Purging a well to dryness and stability of field parameters for pH, specific conductivity, and water temperature only after recovery: Wells: TWN-3 and TWN-7 3. Continuously Pumped Wells that are considered sufficiently evacuated to immediately collect a sample: Wells: TWN-2, TW4-22, TW4-24, and TW4-25 Chloride and nitrate + nitrite (as N) were analyzed for methods consistent with the requirements of the QAP. QAQC Holding Times The method holding times for the quarter and parameter for samples collected at each monitor well were received and analyzed within the required holding times in the QAP. Receipt Temperature All samples were received within the required QAP temperature limit of 6° C. Detection Limits All sample sets were measured and reported to the required QAP reporting limits. Sample Duplicates One duplicate sample was collected for the quarter. A duplicate of TWN-18 was the collected and identified as TWN-65. The duplicate sample analytical results for this sample/duplicate pairs were within the 20% acceptance limits as required in the QAP (see Table 2 below). Groundwater Head Monitoring for 4th Quarter 2015 Depth to groundwater was measured in the following wells and/or piezometers as required in Part I.E.3 of the Permit: • • The quarterly groundwater compliance monitoring wells. • Existing monitoring well MW-4 and all of the temporary chloroform investigation wells. • Piezometers P-1, P-2, P-3, P-4 and P-5. • MW-20, MW-22 and MW-34 • Nitrate monitoring wells. Page 3 • The DR piezometers which were installed during the Southwest Hydrologic Investigation. In addition to the above, depth to water measurements are routinely observed in conjunction with sampling events for all wells sampled during quarterly and accelerated efforts, regardless of the sampling purpose. All well levels used for groundwater contour mapping were measured and recorded within 5 calendar days of each other. Estimation of Pumped Nitrate Mass Removal The 4th Quarter 2015 report reported estimated 124.5 lbs. of nitrate was removed from the chloroform pumping wells (MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, and TW4-20) and the nitrate pumping wells (TWN-2, TW4-22, TW4-24, and TW4-25). Of the 124.5 lbs. removed approximately 114.6 lbs. or 92%, was removed by the pumping wells inside the nitrate plume. In the attached Table 3, the DWMRC shows calculations that verify these reported estimates. Reporting Each Report included the following information as required in the CAP: a) Introduction b) Sampling and Monitoring Plan: i. Description of monitor wells sampled; ii. Description of sampling methodology, equipment and decontamination procedures; iii. Identification of all quality assurance samples, e.g. equipment blanks duplicate samples, etc. c) Data Interpretation: i. Interpretation of groundwater levels, gradients, and flow directions. The interpretation will include a discussion on: 1) current site groundwater contour map, 2) hydrographs to show groundwater elevation in each monitor well over time, 3) depth to groundwater measured and groundwater elevation from each monitor well summarized in data table that includes historic groundwater level data for each well, 4) calculations documenting quarterly nitrate mass removed by pumping; ii. Interpretation of all analytical results for each well including a discussion on: 1) a current nitrate isoconcentration map, 2) graphs showing nitrate concentration trends in each well through time and, analytical results for each well summarized in data table that includes historic analytical results for each well; and iii. An electronic copy of all laboratory results for groundwater quality monitoring conducted during the quarter will be provided to the Executive Secretary. d) Conclusions and Recommendations Page 4 e) Copies of EFR field reports, laboratory reports, and chain of custody forms. The nitrate plume is defined to include any monitoring well that has concentration of nitrate in excess of 10 mg/L. Evaluation of the Nitrate Contaminate Plume and Its Associated Contaminants Bounding And Hydraulic Control of the Chloroform Plume Groundwater monitoring data up to the 4th Quarter, 2015 monitoring event appeared to show that the nitrate contaminate plume (“Plume”) is bound by up gradient, cross gradient, and down gradient wells that have a nitrate concentrations of <10 mg/L (GWQS = 10 mg/L). In addition, based on water level data, groundwater contour, and capture zone maps in the Report it appears that upgradient of pumping wells TW4-19, TW4-20, TW4-22, TW4-24, and TW4-37 the Nitrate Plume is being captured. Conclusions on Compliance with the CAP. OAP Per the Division review it appears that the 4th Quarter 2015 Nitrate Monitoring Report for the Nitrate Contamination Investigation, Energy Fuels Resources (USA) Inc. complies with the CAP and QAP. Therefore, a letter will be drafted for the Director Signature, notifying EFR of the review and closing- out of this report. Page 5 References Energy Fuels Resources (USA) Inc., June 7,2012, White Mesa Uranium Mill, Ground Water Monitoring Quality Assurance Plan (Revision 7.2). HYDRO GEO CHEM, INC, May 7,2012, Corrective Action Plan for Nitrate White Mesa Uranium Mill near Blanding, Utah