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HomeMy WebLinkAboutDRC-2022-013561 - 0901a06881094f3f DRC-2022-013561 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) 536-4284 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director June 16, 2022 Kathy Weinel, Quality Assurance Manager Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: Energy Fuels Resources (USA) Inc. March 30, 2022, White Mesa Uranium Mill MW-24A Phase 2 Plan Utah Groundwater Discharge Permit No. UGW370004 Dear Ms. Weinel: The Utah Division of Waste Management and Radiation Control has reviewed the Energy Fuels Resources (USA) Inc. (EFRI), March 30, 2022, White Mesa Uranium Mill MW-24A Phase 2 Plan (Plan). The Phase 2 Plan was received by the Division on April 4, 2022, prepared in association with groundwater compliance activities for the White Mesa Uranium Mill (Mill); including and initiated by continued investigation of Groundwater Compliance Limit (GWCL) exceedances in the Mill groundwater monitoring well MW-24. The Division Phase 1 Report review letter was dated October 5, 2021, and a conference call, held before sending the review letter, regarding Division review findings and agreed upon future actions between EFRI and the Division was held on September 29, 2021. Groundwater compliance activities are conducted as required by the Mill Groundwater Discharge Permit No. UGW370004 (Permit). Phase 2 Monitoring Points and Data Collection Phase 2 of the MW-24A Study will include the evaluation of 8 core samples and the installation of 1 new monitoring well. The Table below summarizes the new monitoring points and data collection included in the Phase 2 Plan. (Over) Location(s) Data Collection New Monitoring Well, New Core Boring MW-41 New Groundwater Compliance Monitoring Well to be installed hydraulically downgradient from MW-24 as shown on Figure 2 of the Phase 2 Plan. General construction and development of the monitoring well is discussed in the Phase 2 Plan to address concerns identified during review and discussion of the MW-24 SAR. Well will be drilled using continuous core. New Core Borings beside existing monitoring wells MW-3A, MW-18, MW-22, MW-32, MW-39, MW-40 Boring locations were selected to be representative of the Mill site and are located upgradient, cross gradient and downgradient from the Mill. Existing Boring (2019) MW- 24A Existing core will be screened and used. Core was collected during monitoring well installation during 2019. Borings Per the Phase 2 Plan borings will be collected from the top of the boring to the bottom to the extent possible. Core will be logged and quarter at collection. The core will be evaluated using methods in 3.2.1 of the Phase 2 Plan [Photoionization Detector (PID) and X-ray fluorescence (XRF)] to identify the presence of pyrite and high metals readings to prioritize sample intervals for whole rock analyses. The Phase 2 Plan outlines potential collection for volatile and semi-volatile organic constituents and briefly describes sample labeling and identification procedures. Groundwater Data The Phase 2 Plan states that routine groundwater sampling data will be used. Samples and analysis are conducted per requirements of the Permit and associated currently approved Groundwater Quality Assurance Plan. Whole Rock Analytical Sample Collection Per the Phase 2 Plan whole rock samples will be collected from the core after field analysis by PID and XRF. A list of constituents to be analyzed for whole rock composition is included in Table 3.4-1. The Phase 2 Plan states that “one metals, and inorganic analytical sample will be collected every 5 feet above the saturated zone and every 2 feet within the saturated zone.” A general description of how samples will be labeled is included. Synthetic Precipitation Leaching Procedure (SPLP) Samples A fraction of the crushed and ground whole rock will be analyzed using SPLP acidic extraction fluid. U.S. Environmental Protection Agency method SW-846 will be used for the SPLP analysis. The Phase 2 plan notes that nitrate and sulfate will not be analyzed as part of the SPLP analysis since the acidic extraction fluid uses nitric and sulfuric acid. SPLP analysis will be used to estimate adsorption- desorption potentials of constituents that may impact groundwater. Bottle Roll Testing Bottle roll tests will be completed by Mill laboratory staff in the Mill laboratory. The tests will consist of bottles filled with known amounts of solid core (approximately 3 to 4 inches) and a pure pyrite sample as a control (in 2 of the 4 bottle roll tests). Samples will be covered with laboratory deionized water as the leaching solution. The Phase 2 Plan includes a summary of the procedure as follows: “A summary of the procedures that will be employed for the core material bottle roll test are as follows: 1. One bottle will be opened for 15 minutes weekly, closed, and then rolled for 15 minutes. 2. One bottle will be opened for 15 minutes weekly (no rolling or agitation). 3. One bottle will have core and water and never be opened or rolled. 4. One bottle will be opened, and air will be bubbled in the liquid for 15 minutes weekly. No rolling or agitation. The control leachability tests performed using solid ‘generic’ pyrite will consist of pyrite covered with lab grade water. The two bottles having pyrite and water will be treated as follows: 1. One bottle will have pyrite and water and never be opened or rolled. 2. One bottle having pyrite and water will be opened and air will be bubbled in the liquid for 15 minutes weekly. No rolling or agitation.” Tab A of the Phase 2 Plan includes the data collection and bottle roll laboratory procedures. This Tab also includes the boring procedures, field data collection procedures and MW-41 installation procedures. Quality Assurance/Quality Control (QA/QC) Section 4.0 of the Phase 2 plan includes a discussion of QA/QC guidance and procedures for the different elements of the plan, including: 1. Groundwater Data, 2. Field Data, 3. Whole Rock Data, 4. Analytical Data Validation, 5. SPLP Data, and 6. Bottle Roll Data. The Division notes that much of the specific information regarding QA/QC will be conducted by the QA Manager and included as part of the final report. The Division will review specific QA/QC findings when the data is submitted to ensure that data appears reliable and usable for the study objectives. Phase 2 Plan Proposed Schedule Part 5.0 of the Phase 2 Plan states that “Phase 2 study drilling will begin in July 2022 if DWMRC approval has been received.” EFRI states that the Division will be given 14 days’ notice prior to drilling/coring activities which are anticipated to take “several weeks depending on weather and drilling contractor schedules.” EFRI also states that 14-day notice will be given to the Division prior to set up of the bottle roll testing. EFRI anticipates that it will take approximately 5 days to set up the bottle roll tests. Additionally, per the Phase 2 Plan Section 5.0, EFRI will prepare and submit a report to the division “on or before 90 days after the receipt of the analytical data from the one year liquid sample analyses.” The Division will review the EFRI report for content at that time. As discussed in correspondence from the Division to EFRI, the MW-24A Phase 1 and expanded Phase 2 studies are good information to support the EFRI statements that OOC parameters at various monitoring wells are due to naturally occurring geochemical processes/reactions in the Dakota/Burro Canyon mineral matrix (naturally occurring trace metal mobilization). Per other findings regarding evaluation of the MW-24 source assessment report (SAR) and Division findings other additional actions, including the installation of an additional downgradient groundwater monitoring well have been agreed upon to evaluate MW-24 OOC constituents. Conclusion Based on Review of the Phase 2 Plan it appears that all agreed upon actions and recommendations in the Division October 5, 2021, letter and September 29, 2021 conference call were included. Therefore, the Phase 2 Plan is approved. If you have any questions, please call Tom Rushing at (801) 536-0080. Sincerely, Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control PRG/TR/wa c: Grant Sunada, Health Director, San Juan Public Health Department Ronnie Nieves, Environmental Health Director, San Juan Public Health Department Russell Seeley, UDEQ District Engineer