DRC-2022-000677 - 0901a06880ffa619

Ute Mountain Ute Tribe
Environmental Programs Department
P.O. Box 448
Towaoc, Colorado 81334-0448
[phone]
Div of Waste Management
and Radiation Control
JAN 1 4 2022
D C-2o22-- 000677
Doug Hansen
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Transmitted via email to: dwmrcpublicutah.gov
January 14, 2022
Re: Rare Earth Elements (REEs) as tracers for assessing radionuclide and metals migration in groundwater,
Request to require REEs characterization sampling for tailings liquids (Cell 1, 4B, Cell 2 LDS) and groundwater at
TW4-24, MW-5, MW-12, MW-30, MW-31, MW-28, MW-24, MW-24A, MW-39 and MW-22 under Groundwater
Discharge Permit (GWDP) No. UGW370004
Rare earth elements (REEs) can be used as natural geochemical tracers for contaminant migration and inform understanding
of whether groundwater is impacted by mine waste material. (1-5)
According to Energy Fuels Resources (USA) Inc. ("EFRI"), ore material from the Colorado Plateau region, monazite sands,
and other materials being processed at its White Mesa Mill facility ("Mill") have been characterized to have distinctive REE
characteristics. (6) However, REEs are not parameters currently required to be analyzed under the Mill's Groundwater
Discharge Permit No. UGW370004 ("GWD Permit"), and EFRI has not provided any actual data characterizing REEs in
tailings liquids or in the shallow Burro Canyon aquifer beneath the Mill.
The shallow groundwater in the vicinity of the Mill has been declining in quality precipitously over the past decades and
many of the Mill's Point of Compliance (POC) wells are in exceedance of their Groundwater Compliance Limits (GWCLs)
even after many of these limits have been raised multiple times during this period. (7)
The increasing levels of acidity (which would increase the mobility and transport of REEs in groundwater) and
concentrations of uranium, other toxic metals, like beryllium and cadmium, as well as ions including chloride and sulfate in
the groundwater downgradient of the Mill are coming from some source. Whether that source is the Mill's process and
tailings solutions which include these constituents in great abundance, other Mill activities, the natural geology at the site,
or a mixture of these potential sources is a key question that remains to be determined.
We are requesting the Division add a stipulation to the Mill's GWD Permit requiring EFRI to characterize REEs in tailings
liquids (Cell 1, 4B, Cell 2 LDS) and in shallow groundwater at wells TW4-24, MW-5, MW-12, MW-30, MW-31, MW-28,
MW-24, MW-24A, MW-39 and MW-22. This stipulation should also require comprehensive isotopic characterization
including tritium, sulfur and oxygen isotopes of sulfate, hydrogen and oxygen isotopes of water and isotopes of nitrate and
chloride.
We appreciate the Division's consideration of our request and believe that obtaining this important characterization data on
REEs in tailings liquids and in site groundwater will provide useful information for determining a positive source
identification which is the first step towards the effective protection of human health and the environment from the long-
term risks associated with uranium and other toxic metals loading to the Burro Canyon aquifer.
Sincerely,
Colin Larrick
Water Quality Program Manager
Ute Mountain Ute Tribe
c: Kim Shelly, Executive Director of Utah Department of Environmental Quality
Kimberly Varilek, Chief, Tribal Affairs Branch, Environmental Protection Agency
References
(1) Stille, P.; Gauthier-Lafaye, F.; Jensen, K. A.; Salah, S.; Bracke, G.; Ewing, R. C.; Louvat, D.; Million, D. REE
mobility in groundwater proximate to the natural fission reactor at Bangombe (Gabon). Chem. Geol. 2003, 198, 289
— 304.
(2) Prudencio, M. I; Valente, T.; Marques, R.; Braga, M. A. S.; Pamplona, J. Geochemistry of Rare earth elements in a
passive treatment system built for acid mine remediation. Chemosphere 2015, 138, 691 — 700
(3) Grawunder, A.; Lonchinski, M.; Handel, M.; Wagner, S.; Merten, D.; Mirgorodsky, D.; Buchel, G. Rare earth
element patterns as process indicators at the water-solid interface of a post-mining area. Appl. Geochem, 2018, 96,
138 — 154
(4) Verplank, P. L.; Nordstrom, D. K.; Taylor, H. E.; Kimball, B. A. Rare earth element partitioning between hydrus
ferric oxides and acid mine water during iron oxidation. Appl. Geochem. 2004, 19, 1339 — 1354.
(5) Wilkin, T. R.; Lee, R. T.; Ludwig, D. R.; Wadler, C.; Brandon, W.; Mueller, B.; Davis, E.; Luce, D.; Edwards, T.;
Rare-earth elements as natural tracers for in situ remediation of groundwater. Environ. Sci. Technol. 2021. 55, 1251
— 1259.
(6) Energy Fuels Resources (USA) Inc.; September 9, 2020 letter to Ty Howard, Director, Division of Waste
Management and Radiation Control. Re: Response to Utah Division of Waste Management and Radiation Control
("DWMRC") Request for Additional Information (RAI) regarding the Energy Fuels Resources (USA) Inc.
("EFRI"), June 25, 2020 Letter Regarding Receipt and Processing of Ores from Chemours at the White Mesa
Uranium Mill (the "Mill"); Groundwater Discharge Permit No. UGW37004 ("GWDP") and Utah Radioactive
Materials License UT 1900479
(7) Energy Fuels Resources (USA) Inc. October 28., 2021. 3rd Quarter 2021 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill
Div of Waste Management
and Radiation Control From: Colin Larrick <[e-mail]>
Date: Fri, Jan 14, 2022 at 9:44 AM JAN 1 4 2022 Subject: [DWMRC Public] UMUT_GWDP_UGW370004_ModificationRqst_WMM
To: [e-mail] <[e-mail]>
Cc: [e-mail] <[e-mail]>, [e-mail] <[e-mail]>, Peter Ortego
<[e-mail]>
Good morning, attached please find our request for an amendment to the Groundwater Discharge Permit for
the White Mesa Uranium Mill (Permit No. UGW370004).
We appreciate the Division's consideration of our request and believe that obtaining this important
characterization data on Rare Earth Elements in tailings liquids and in site groundwater will provide useful
information for determining a positive source identification of pollution at the site which is the first step
towards the effective protection of human health and the environment from the long-term risks associated
with uranium and other toxic metals currently loading the Burro Canyon aquifer.
Thank you
Colin Larrick
Water Quality Program Manager
Ute Mountain Ute Tribe
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