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HomeMy WebLinkAboutDRC-2015-007708 - 0901a06880592789GARYR. HERBERT Governar SPENCERJ. COX Lieutenant Gwemor Department of Environmental Quality Alan Matheson Exccutive Director DIVISION OF WASTE MANAGEMENT AND RAD1ATION CONTROL Scott T. Anderson Director November 3,2015 Kathy Weinel, Quality Assurance Manager Energy Fuels Resources (USA) Inc. 225 UnonBlvd., Suite 600 Lakewood, CO 80228 RE: Energy Fuels Resources, White Mesa Uranium Mill August lg,20l5 2nd Quarter 2015 Groundwater Monitoring Report; August 14,2015 Notice Pursuant to Part I.G.l(a) and September 10,2015 Transmittal of Plan and Time Schedule Utah Groundwater Discharge Permit No. UGW37 0004 Dear Ms. Weinel: The Division of Waste Management and Radiation Control has completed its review of the following Energy Fuels Resources (USA) Inc. (EFR) documents: 1. EFR, August 19,2015 -Transmittal of * Quarter 20/5 Groundwater Monitoring Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill. 2. EFR, August 14,2015 - State of Utah Ground lV'ater Discharge Permit No. UGW370004 White Mesa (Jranium MiU - Notice Pursuant to Part 1.G.1(a). 3. EFR, September 10, 2015 - Transmittal of Plan and Time Schedule under Utah Ground water Discharge Permit uGW370004 Part 1.G.4(d) white Mesa Mill. EIiR 2nd Ouarter 2015 Groundwater Monitorine Renort - Close-out: Based on review of the EFR August 19, 2015 7d Quarter 2015 Groundtvater Monitoring Report,it appears that all applicable requirements of the Permit were met. Therefore, the review is hereby closed out. EFR Aueust 14. 2015 Notice Pursuant to Part I.G.l(a): Based on review of the EFR August 14, 2015 Notice, it appears that all requirements of the Permit were met. Therefore, the review is hereby closed out. 195 Norttr 1950 West'Salt Lake City, UT Mailing Address: P.O- Box 1,14880 ' Salt Lake City' UT 841144880 Telephone (801) 536-0200'Fax (S0l) 536-0222 'T.D.D. (801) 5364414 tuww.ileq.utah.gao Printed on l00o/o recycled Paper DRC-2015-007708 (Over) EFR September 10.2015 Plan and Time Schedule for Monitorine Well MW-3 The EFR September 10, 2015 Plan and Time Schedule (EFR Plan) addresses exceedances of the ground water compliance limits (GWCLs) for cadmium and zinc at monitoring well MW-3. These parameters are in "out of compliance stafus" in accordance with Part I.G.2 of the Permit and require corrective action in accordance with Part I.G.4 of the Permit. EFR additionally included an evaluation of beryllium and nickel for monitoring well MW-3 in the EFR Plan since "these two additional constituents have either exceeded the GWCL once, as in the case of beryllium, or have reported results approaching the GWCL, as in the case of nickel." It is noted that these GWCL exceedances were discussed with representatives of the Division and EFR during two conference calls (September 2015). Specifically, it was agreed that it would be appropriate to investigate/verifr whether the MW-3 monitoring well desigrr/construction, which includes nine tol0 feet of blank casing below the screened interval, was the potential cause of the exceedances prior to conducting additional source investigation activities and submitting a full soruce assessment plan to the Division for review. The EFR Plan states that an inert inflatable well packer will be installed directly below the well screened interval in order to isolate the blank screen section and prevent mixing of stagnant water and sediment in the sump with the groundwater sample. EFR will use the normal purging methods listed in the facility quality assurance plan after installation of the packer and will collect four quarters of groundwater samples for all compliance parameters listed in the Permit Table 2. The data will be submitted to the Division with the scheduled quarterly groundwater monitoring reports. After receipt of the analytical data for these samples, EFR will coordinate with the Division regarding a path forward. Based on the Division's review of the EFR Plan, it appears that the plarured activities are as agreed upon during the teleconferences held during September 2015. Please install the inflatable packer in monitoring well MW-3 within 90 calendar days as stated in the EFR plan. If you have questions, please call Tom Rushing at (801) 536-0080. Sincerely, Scott T. Anderson, Director Division of Waste Management and Radiation Control SA/TRlka c: Worthy Glover, Jr., MMHRM, CPM, Health Offrcer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department