DRC-2015-001888 - 0901a06880514151

in OS
State of Utah
GARY R HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
March 25, 2015
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2015-001888
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources, White Mesa Uranium Mill 4l Quarter 2014 Groundwater
Monitoring Report; February 9, 2015 Request for Removal of Certain Groundwater
Monitoring Parameters from Accelerated Monitoring Status, and; February 5, 2015
Notice Pursuant to Part I.G.I (a): DRC Findings, Notice of Enforcement
Discretion, and Close-out
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has completed review of the following Energy
Fuels Resources ("EFR") documents:
1. EFR, February 19, 2015, Transmittal of 4th Quarter 2014 Groundwater Monitoring
Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium
Mill ("Report").
2. EFR, February 5, 2015, State of Utah Ground Water Discharge Permit No.
UGW370004 White Mesa Uranium Mill ("Permit") - Notice Pursuant to Part I.G.J (a)
regarding groundwater compliance limit exceedances.
3. EFR, February 9, 2015, Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status.
EFR 4th Quarter 2014 Groundwater Monitoring Report:
Notice of Enforcement Discretion
Method Blank Detections for all 4th Quarter ammonia results were reported in violation of the
White Mesa Uranium Mill Quality Assurance Plan ("QAP") ParF97l-3r--Rart 9.h^of the^QAP—
states that "non-conformance conditions will exist when contaminant levels in the samples are not
an order of magnitude greater than the blank results. "
The violations were self-identified by EFR in section 3.4.9 of the Report. Per EFR, "Ammonia
was reported in the method blanks in several analytical groups. The samples associated with
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
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Printed on 100% recycled paper
Kathy Weinel
Page 2
these method blanks were not an order of magnitude greater than the blank results as required by
the QAP. Blank detections are indicative of a false positive or high bias to the sample results as
the laboratory contribution increases the concentration of the sample results. A comparison of
the fourth quarter results to historic results indicates that the ammonia results reported by
Chemtec-Ford are in fact caused by blank contamination. The QAP requirement to analyze a
method blank with each batch and evaluate the results has been completed as required. As
previously stated, this issue is a result of EFRI using Chemtec-Ford for the ammonia analyses due
to a catastrophic fire at A WAL in July. This issue will be resolved in the first quarter 2015, when
the Mill samples are analyzed by A WAL.''''
DRC noted that ammonia results exceeded the ammonia ground water compliance limit
("GWCL") in one monitoring well, MW-30, during the monitoring period. Enforcement
discretion is being used regarding the violations per the following justifications:
1. Ammonia results were below the GWCL's for all but one monitoring well sample and
were below the Ground Water Quality Standard for all samples. Furthermore, historically
the ammonia results for all on-site groundwater monitoring wells have been below their
respective GWCL.
2. The violations were likely the result of the necessity for EFR to use a different laboratory
due to a fire at the previous used laboratory.
3. Data review by EFR indicates that elevated sample results are due to the blank
contamination and there is no apparent increasing trend in ammonia concentrations.
4. Ongoing violations will be subject to future enforcement actions.
Close-out
Based on DRC review of the EFR November 5, 2014 4th Quarter 2014 Groundwater Monitoring
Report, it appears that all applicable requirements of the Permit were met. Therefore, DRC
review of the Report is hereby closed out.
EFR February 5.2015 Notice Pursuant to Part I.G.l(a):
Per DRC review of the EFR February 5, 2015 Notice it appears that all requirements of the Permit
were met. Therefore, DRC review of the Notice is hereby closed out.
EFR February 9,2015 Proposal for Removal of Certain Groundwater Monitoring
Parameters from Accelerated Monitoring Status:
The EFR February 9, 2015 submission requests that the following wells/parameters be returned to
baseline monitoring frequency:
• MW-26/Carbon Tetrachloride
• MW-31/FieldpH
• MW-1/Manganese
• MW-19/Gross Alpha
Kathy Weinel
Page 3
The 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 Permit. Per DRC
review of the laboratory results it was verified that the requested wells/parameters showed eight
consecutive monthly laboratory results below the GWCL's.
Based on DRC review of the request, the following wells/parameters are authorized to be returned
to baseline monitoring frequency as follows:
Monitoring Well Parameter Baseline Monitoring Frequency
MW-26 Carbon Tetrachloride Quarterly
MW-31 Field pH Quarterly
MW-1 Manganese Semi-Annual
MW-19 Gross Alpha Semi-Annual
Note that these wells/parameters are subject to future accelerated monitoring requirements per the
requirements of the Permit Part I.G.
If you have questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Rusty Lundberg, Director
RL: TR:tr
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