DRC-2022-022591 - 0901a06881118449

Department of
Environmental Quality
Kimberly D. Shelley
Executive Director State of Utah
SPENCER J. COX
Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
DEIDRE HENDERSON
Lieutenant Governor
Douglas J. Hansen
Director
TO:
FROM:
DATE:
SUBJECT:
MEMORANDUM
Phil Goble If /7 {,,z.--i, f)/U, /7-
Dean Henderson /)41-It/ 7 /zo'2l...
November 7, 2022
Field Inspection and Split Sampling for the 4th Quarter 2022 Nitrate Monitoring Event for
the Energy Fuels Resources
White Mesa Uranium Mill, near Blanding, Utah
This is a Utah Division of Waste Management and Radiation Control ("Division") staff summary on the
inspection of the 4th Quarter 2022 nitrate event ("Monitoring Event") performed on October 25 and 26,
2022, for the Energy Fuels Resources (USA), Inc. ("EFRI") White Mesa Uranium Mill, near Blanding,
Utah. EFRI is required to submit a written groundwater monitoring report of this monitoring event by
March 1, 2023. The monitoring event was inspected against the following enforcement documents:
• White Mesa Uranium Mill Ground Water Quality Assurance Plan ("QAP").
Revision 7.5, dated June 5, 2019.
Summary of Inspection
On October 25 and 26, 2022, Division staff Dean Henderson and Phil Goble observed the EFRI staff
preform groundwater monitoring activities including the collection of water samples from monitor wells
for the nitrate plume groundwater monitoring network. In addition, the Division staff collected a split
sample from monitor wells TWN-1 , TWN-2, TWN-3, TWN-4, TWN-7, TWN-20, and TWN-21. A
duplicate sample was collected at well TWN-4 and is identified as TWN-40. See the photographs of
sampling activities in figures 1 and 2 in Attachment 1 below.
After the monitoring event was completed, a close out meeting was held with the following attendees:
Division staff Dean Henderson and Phil Goble and EFRI staff Tanner Holliday, Deen Lyman, Garrin
Palmer (RSO) and Terry Slade. In the meeting the Division staff told the EFRI staff that they appeared
to follow the QAP. In the meeting the Division staff brought to the attention of the EFRI staff that the
rope used to lower the disposable bailer down the well to collect the groundwater samples was not
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DRC-2022-022591
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changed or decontaminated ( cleaned) between sampling wells/piezometers. Although this procedure is
not written in the QAP the EFRI staff was told to begin this procedure to prevent the chance for cross
contamination.
Conclusion
Based on Division staff observations of EFRI staff performing the sampling and monitoring on October
26 and 27, 2021, it appears that EFRI appropriately followed the field requirements in the QAP and
GCAP. It is recommended that EFRI modify the QAP to include a procedure that outlines changing or
decontaminating the rope between collecting groundwater samples at wells and piezometer locations. As
stated above, EFRI is required to submit a written report of this Monitoring Event on March 1, 2023.
The Division will also review this report and will include split sample analysis for this monitoring event
as part of that review to complete the inspection of the 4th Quarter 2022 nitrate monitoring event.
Page3
References
White Mesa Uranium Mill Ground Water Quality Assurance Plan Revision 7.5, dated June 5, 2019.
Page4
Attachment l
Photographs of Sampling Activities
Page 5
Figure 1. Purging activities at monitor well TWN-7.
Figure 2. With the use of a bailer, EFRI staff collecting a ground water sample from pizometer P-3A.