DRC-2022-018842 - 0901a068810b88a8

ENER0YFUELS
jUL i I Ziitl
Energy Fuels Resources (USA) Inc.
225Union Blvd. Suite 600
Lakewood, CO, US' 80228
303 9742140
www.energyfuels.com
July 13,2022
VIA PDF AND OVERNIGHT DELIVERY
Doug Hansen
Director
Division of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.l (a)
Dear Mr. Hansen:
The White Mesa Mill (the "Mill") performed second quarter ("Q2") groundwater monitoring during the
periodfromApril l,toJune 30,2022undertheMarch 8,202I versionof theMill'sGroundwaterDischarge
Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were received during the
period ending lune 22, 2022.
Pursuant to Part I.G.1.a) of the GWDP, please take notice that the concentrations of specific constituents in
the monitoring wells highlighted in yellow and bold italics in the columns for this quarter in the attached
Table 1 exceeded their respective GWCLs. For ease of review, Table I has been formatted to simplify the
tracking of any continued exceedances from one monitoring period to the next by charting ongoing
monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics).
As a result of the issuance of a revised GWDP on March 8,202I, which sets revised GWCLs, requirements
to perform accelerated monitoring for certain constituents under Part I.G.1 of the previous GWDP ceased
effective on March 8,202I, and the effect of the issuance of the revised GWDP was to create a "clean slate"
for certain constituents going forward.
Part I.G.l c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to
the Director a plan and a time schedule for assessment of the sources, extent and potential dispersion of the
contamination, and an evaluation of potential remedial action to restore and maintain gloundwater quality
to ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT
will be reestablished." The summary below relating to exceedances includes, for each exceedance, a brief
discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of
other actions currently being undertaken by Energy Fuels Resources (USA) Inc. ("EFRI") or in light of
other reports submitted by EFRI, and as determined by Division of Waste Management and Radiation
Control ("DWMRC") Staff. A description of the other actions and reports which have affected the
requirement to submit a plan and time schedule are as follows:
DRC-2022-018842
Letter to Mr. Doug Hansen
luly 13,2022
Page2
1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing
investigations at the Mill. Based on the results of the previous investigations, EFRI and the
Director acknowledged that it has not been possible to date to determine the source(s), cause(s),
attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride
in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate +
nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the
activities associated with the CAP are on-going. Based on information provided by DWMRC in
teleconferences on Apr\127, and May 2,2011, due to the ongoing activities and actions, the 30-day
plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at
this time.
2. A Plan and Time Schedule will not be prepared for monitoring wells with two successive
exceedances if those successive exceedances were reported in a previous quarter and/or were
included in a previous Source Assessment Report ("SAR") during the current permit period
beginning March 8,2021. Inclusion in a previous SAR means that the GWCLs were modified
based on conclusions and actions delineated in the previous SAR which were accepted by
DWMRC.
3. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program
and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action
Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket No. UGW-
20-01. As a result, the 30-day plan and schedule for assessment of chloroform and methylene
chloride exceedances is not required.
It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to
reflect background groundwater quality, as defined by the mean plus second standard 'deviation
concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each
monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that,
because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-
impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5Vo of the time.
Therefore, exceedances are expected in approximately 2.5Vo of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a given analyte
will increase the number of exceedances due to statistical variation and not due to Mill activity.
Additionally, given the slow velocity of groundwater movement, accelerated sampling at a monthly
frequency can result in resampling of essentially the same water and can lead to repeat exceedances for
accelerated constituents not due to Mill activities, but due to repeat sampling of the same water.
1.0 Exceedances in Required Quarterly Sampling Wells
1.1 Quarterly Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods inQ22022. A 30-day plan and schedule contemplated in Part I.G.1 c) of
the GWDP will not be required as noted below. One-time exceedances and non-successive exceedances
are noted on Table 1, but not listed below. Consecutive exceedances which occurred in previous reporting
periods are discussed in previously submitted SARs.
Letter to Mr. Doug Hansen
July 13,2022
Page 3
MW-l1
o The chloride concentration exceeded its GWCL in all of the Q2 2022 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination
which is expected to address chloride in groundwater. The actions specified in the CAP are
currently being implemented; therefore, a plan to address this consecutive exceedance is not
necessary and is not being submitted.
MW-26
MW-26 Note: As stated in the Septemb er 2009 Statement of Basis (page 23) in support of the January 20,
2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform
removal, concentrations of all constituents in that well are subject to potential variation over time as a result
of the pumping activity. This will be taken into account by the Executive Secretary in determining
compliance for this well." Based on information provided by DWMRC in teleconferences on April 27 , and
May 2,2011, due to the current pumping status as part of the chloroform investigation program, the 30-day
plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene
chloride in MW-26.
Chloroform has exceeded its GWCL in all of the Q2 2022 sampling events. MW-26 is used as a
pumping well for the ongoing chloroform capture program and is expected to yield increased
concentrations of chloroform. Because this well is used in the chloroform capture program which
is the subject of separate investigations and actions, a plan and time schedule to address the
consecutive exceedances is not necessary and is not being submitted.
Nitrate has exceeded its GWCL in the Q2 and May 2022 sampling events. As mentioned above, a
CAP has been submitted and approved and the specified actions are currently being implemented;
therefore, a plan to address this consecutive exceedance is not necessary and is not being submitted.
MW-30
o Nitrate + nitrite has exceeded its GWCL in all of the Q2 2022 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore, a plan to address this consecutive exceedance is not necessary and is not
being submitted.
The chloride concentration exceeded its GWCL in the Q2 2022 andMay 2022 sampling events.
As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore, a plan to address this consecutive exceedance is
not necessary and is not being submitted.
Selenium has exceeded the GWCL for all of the Q2 2022 sampling events. A SAR was submitted
on January 28,2022. As a result of the SAR, the GWCLs have been recalculated and accepted by
DWMRC. The recalculated GWCLs will become effective upon their publication in the next
revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan
and schedule to address this consecutive exceedance is not necessary and will not be submitted.
Until such time as the new GWCLs become effective. the exceedances will continue to be noted
and reported.
Letter to Mr. Doug Hansen
Iuly 13,2022
Page 4
MW-31
o Nitrate + nitrite has exceeded its GWCL in all of the Q2 2022 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are culrently being
implemented; therefore, a plan to address this consecutive exceedance is not necessary and is not
being submitted.
o The sulfate concentration exceeded its GWCL in all of the Q22022 sampling events. A SAR was
submitted to DWMRC on June 24.2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported.
o The TDS concentration exceeded its GWCL in all of the Q2 2022 sampling events. A SAR was
submitted to DWMRC on June 24,2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessa.ry
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported.
o The chloride concentration exceeded its GWCL in all of the Q2 2022 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination
which is expected to address chloride in groundwater. The actions specified in the CAP are
currently being implemented; therefore, a plan to address this consecutive exceedance is not
necessary and is not being submitted.
o Uranium concentrations exceeded the GWCL in all of the Q2 2022 sampling events. A SAR was
submitted to DWMRC on Aprit 29,2021. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC'S acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported.
1.2 Quarterly Wells with New Exceedances Reported in Q2
There are no new exceedances for the Q2 2022 quarterly well sampling program.
2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly
2.'/-, Semi-annual Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods (Ql2022 and Q2 2022).
Letter to Mr. Doug Hansen
JuIy 13,2022
Page 5
i[/4W-24
Beryllium concentrations exceeded the GWCL in MW-24 in the Ql 2022 andQ22022 sampling
events. Beryllium exceedances are addressed in the SAR dated June 27 , 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
Cadmium concentrations exceeded the GWCL in MW-24 in the Ql 2022 and Q2 2022 sampling
events. Cadmium exceedances are addressed in the SAR dated June 27,2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC'S acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
Fluoride concentrations exceeded the GWCL in MW-24 in the Ql 2022 and Q2 2022 sampling
events. Fluoride exceedances are addressed in the SAR dated June 27 , 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
Nickel concentrations exceeded the GWCL in MW-24 in the Ql 2022 and Q2 2022 sampling
events. Nickel exceedances are addressed in the SAR dated Jlune 2'7 ,2019. As a result of the SAR,
EFRI installed a collocated well to study potential installation issues associated with MW-24.
DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of
DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
Thallium concentrations exceeded the GWCL in MW-24 in the Ql 2022 and Q2 2022 sampling
events. Thallium exceedances are addressed in the SAR dated June 27,2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
Sulfate concentrations exceeded the GWCL in MW-24 in the Ql 2022 and Q2 2022 sampling
events. A SAR was submitted to DWMRC on June 27 ,2019 . As a result of the SAR, EFRI installed
a collocated well to study potential installation issues associated with MW-24. DWMRC approved
the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC's
acceptance ofthe study strategy, a plan and schedule to address this consecutive exceedance is not
necessary and will not be submitted. Until such time as the study is complete, the exceedances will
continue to be noted and reported.
Letter to Mr. Doug Hansen
July 13,2022
Page 6
I0/4W-27
MW-28
The nitrate+nitrite concentration exceeded its GWCL for both the Q1 2022 andQ22022 sampling
events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore, a plan to address this consecutive exceedance is
not necessary and is not being submitted.
Chloride has exceeded the GWCL for both the Q I 2022 and Q2 2022 sampling events and during
previous quarters. As mentioned above, a CAP has been submitted and approved and the specified
actions are cunently being implemented; therefore, a plan to address this consecutive exceedance
is not necessary and is not being submitted.
Uranium has exceeded the GWCL for both the Ql 2022 and Q2 2022 sampling events. A SAR
was submitted to DWMRC on October 19,2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective. the exceedances
will continue to be noted and reported.
Selenium has exceeded the GWCL for both the Q1 2022 and Q2 2022 sampling events. A SAR
was submitted to DWMRC on October 19,2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective. the exceedances
will continue to be noted and reported.
MW-29
r Uranium concentrations exceeded the GWCL for both the Ql 2022 and Q2 2022 sampling events.
A SAR was submitted to DWMRC on September 7,202I. As a result of the SAR, the GWCLs
have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective
upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of
the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not
necessary and will not be submitted. Until such time as the new GWCLs become effective, the
exceedances will continue to be noted and reported.
2.2 Semi-annual Wells with New Exceedances Reported in Q2
One new single exceedance for the Q22022 semi-annual well sampling program is listed below.
o Fluoride in MW-27 was slightly above the GWCL in the Q2 sampling event.
Relative to accelerated reporting requirements, reporting of exceedances is required to be completed within
30 days of receipt of the last data package for a quarterly monitoring event. Similarly, accelerated
monitoring is required to commence the month following the submission of the Exceedance Notice for a
specified quarter for wells that are being accelerated from quarterly to monthly and the quarter following
Letter to Mr. Doug Hansen
July 13,2022
PageT
the submission of the Exceedance Notice for wells that are being accelerated from semiannually to
quarterly.
Yours truly, I,,/ lt- nKffi1 Y1-.o111'l / - '-
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance
cc: Scott Bakken, David Frydenlund, Logan Shumway, Garrin Palmer, Jordan App
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