DRC-2016-002121 - 0901a068805f16c7

State of Utah
CARYR. HERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
February 25,2016
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Unron Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources, White Mesa Uranium Mill December 9,2015 3'd Quarter 2015
Groundwater Monitoring Report; November 18, 2015 Notice Pursuant to Part I.G.l(a);
November 18,2015 Request for Removal of Monitoring Parameters from Accelerated
Monitoring, and; December 3,2015 Transmittal of Plan and Time Schedule
Utah Groundwater Discharge Permit No. UGW3 7 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:
l. EFR, November 18, 2015 - Transmittal of 3'd Quarter 2015 Groundwater Monitoring Report
Groundvvater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, November 18, 2015- State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part 1.G.1(a).
3. . EFR" November 18,2015 - State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parametersfrom
Ac c el er at e d Monit oring Status.
4. EFR, December 3, 2015 - Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part 1.G.4(d) White Mesa Mill.
The review was conducted to enswe compliance with all applicable parts of Utah Groundwater
Discharge Permit No. UGW370004 (*Permit") issued to the White Mesa Uranium Mill located in
Blanding, Utah.
195 North 1950 West. Salt Lake City, LrT
Mailing Address: P.O. Box 144880 . Salt Lake City, UT 841144880
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364414
wunu.ileq.utah.goo
Printed on 1007o recycled paper
DRC-2016-002121
EFR 3rd Ouarter 2015 Groundwater Monitorins Report - Close-out:
Based on review of the EFR November 18, 2015 3'd Quarter 2015 Groundwater Monitoring Report, it
appears that all applicable requirements of the Permit were met. Therefore, the review is hereby closed
out.
EFR November 18. 2015 Notice Pursuant to Part I.G.l(a):
Based on review of the EFR November 18, 2015 Notice, it appears that all requirements of the Permit
were met. Therefore, the review is hereby closed out.
EFR November 18.2015 Request to Remove Certain Parameters from Accelerated Monitoring
Based on review of the EFRNovember 18, 2015 Requestfor Removal of Certain Groundwater
Monitoring Parameters from Accelerated Monitoring Status (EFR Request), EFR requests that two
monitoring well parameters be retumed to baseline monitoring as listed on the table below:
Monitorins Well Parameter Baseline Monitoring Frequency
MW-25 Cadmium Quarterly
MW-30 Ammonia QuarterlV
It was noted that cadmium results in monitoring MW-25 have been below the Permitted Ground Water
Compliance Limits (GWCLs) for the most recent ten consecutive accelerated sampling results, and that
ammonia results in monitoring well MW-30 have been below the Permitted GWCLs for the most recent
eight consecutive accelerated sampling results. In accordance with past Division protocols, accelerated
monitoring may be discontinued if at least eight consecutive samples show concentrations below the
GWCL. Therefore, the request to return to baseline monitoring for the parameters/wells on the table
above is hereby approved.
EFR December 3.2015 Plan and Time Schedule for Sulfate in Monitorine Well MW-3
Based on review of the EFR December 3,2015 Plan and Time Schedule ("EFR Plan"), the EFR Plan
addresses exceedances of the current GWCL for sulfate at monitoring well MW-3, which is in out-of-
compliance status in accordance with the Permit PartI.G.z and required to undergo corrective action in
accordance with the Permit Part I.G.4. The EFR Plan notes that a plan was submitted on September 10,
2015 to address exceedances of cadmium and zinc in monitoring well MW-3, the same monitoring well
as addressed in the EFR Plan. As such, EFR proposes to use the same strategy and data collection
procedures for sulfate in monitoring well MW-3 as in the September 10, 2015 Plan.
Specifically, EFR will perform an analysis of sulfate in monitoring well MW-3 to determine if the
exceedance is due to a previously reported increasing trend in MW-3, is due to the construction design
of MW-3 or is due to a combination of these factors.
EFR will utilize an inflatable packer to isolate and eliminate nine to ten feet of blank casing below the
well screen to determine if stagnant water in this interval may be causing mixing of fresh and stagnant
water and accumulated solids in the well groundwater samples. According to the EFR Plan, the packer
installation will be completed by February 8,2016, as is required by the previously approved Plan dated
September 10,2015.
A full suite of samples will be collected for four quarters after the installation of the packer. Data will
be provided to the Division as they are received by EFR. After completion of the four quarters of data
EFR and the Division will discuss the results and reporting requirements concerning the data as well as
a path forward concerning potential additional needs for source assessments in monitoring well MW-3.
Based on review of the EFR Plan, it appears that the planned activities are as agreed upon during
Division/EFR teleconferences.
If you have any questions, please call Tom Rushing at (801) 53G0080.
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/TR/ka
c: Worthy Glover, Jr., MMHRM, CPM, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department