DRC-2023-077720 - 0901a068812c809f

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
MEMORANDUM
TO File
THROUGH: Phil Goble, Manager P26 Vvz'da)
FROM: Christopher Leahy, P.G
DATE: May 10,2023
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 4th Quarter 2022 Groundwater
Monitoring Report for the White Mesa Uranium Mill
Review Sum,marv:
The Utah Division of Waste Management and Radiation Control ("Division") has reviewed the
following documents submitted by Energy Fuels Resources (USA) Inc. ("EFR"):
1. EFR, February 6,2023, Transmittal of 4th Quarter 2022 Groundwater Monitoring
Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium
Mitl. (Received by the Division on February 13,2023).
2. EFR, February 1,2023, State of Utah Ground Water Discharge Permit No.
UGW370004 White Mesa (Jranium Milt - Notice Pursuant to Part 1.G.1(a) (Received
by the Division on February 6,2023).
The review was conducted to ensure compliance with all applicable parts of Utah Groundwater
Discharge Permit No. UGW3 70004 ("Permit") issued for the White Mesa Uranium Mill located in
Blanding, Utah (Mill).
1. Checklist Sisnificant Findinss of the Ath otr.2022 and Related at the
White Mesa ranium Mill:
The 4th Quarter 2022Report was received before the due date (Permit Part I.F.1 -
$1;#f"":#J:1i...............,'];ples were anaryzedby chemtech-Ford Laboratories
("Chemtech"), Sandy, UT. The Gross Alpha Samples were analyzed by GEL
195 North 1950 West' Salt Lake City, UT
Mailing Address: P.O. Box 144880' Salt Lake City, UT 84114-4880
Telephone (S0 I ) 536-0200' Fa,'< (80 I )-536- 0222' T.D.D. (80 I ) 536-44 I 4
www.deq.ulah.gov
Printed on 1007o recYcled PaPer
2.
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page2
Laboratories LLC, Charleston, South Carolina. DWMRC verified that the
laboratories have current Utah certification for the parameters analyzed.
3. Laboratory QAiQC flags were documented in the review period analytical data
reports from the contract laboratories and an in-house QA/QC review was
conducted by EFR regarding all field and laboratory data. Per DWMRC review it
appears that all discrepancies were self-reported by EFR.
2. Accelerated Monitorine and POC WeUs Exceedine GWCL's:
When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL)
set forth in Table 2 of the Permit, it is in Probable Out-of-Compliance (POOC) status. According
to the Permit, EFR is then required to immediately initiate accelerated sampling of that pollutant
(see the Permit, Part I.G.1). When monitoring wells have parameters that have exceeded the
GWCL two or more consecutive times they are in Out-of-Compliance (OOC) status (see the
Permit, Part I.G.2).
In the event a constituent is in OOC status, EFR is required to prepare and submit within 30
calendar days to the Director a plan and 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 groundwater quality to ensure that Permit limits will not be exceeded at the
compliance mtnitoring point and that DMT or BAT will be re-established, in accordance with
Part LG.4(c) of the Permit.
Five new compliance parameters went into accelerated monitoring frequency POOC based on
sampling during the 4th Quarter 2022.
l) The Selenium concentration in monitoring well MW-l1 during the 4th quarter monitoring
event on l0ll0l22was 15.5 uglL, above the GWCL of 12.5 uglL.
2) The Chloride concentration in monitoring well MW-25 during the 4th quarter monitoring
event onl0ll0l22was 35.8 mg/L, just above the GWCL of 35 mg/L
3) The Field pH obtained in monitoring well MW-30 during the November monthly sample
event on l0ll3l22 was 6.37, below the GWCL lower limit of 6.47. Inthe Decembet 2022
sample event on Ill09l22, fieldpH was within the GWCL limits. Therefore MW-30 is
still in POOC status.
4) The Chloride concentration in monitoring well MW-17 during the2"d semi-annual
monitoring event on I0ll7l22 was 54 mglL,just above the GWCL of 46.8 mglL
5) Field pH in monitoring well MW-37 during the 2nd semi-annual monitoring event on
l1lll22 measured at 6.60,just below the GWCL lower limit of 6.61.
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
Current Acceleruted Monitoring Status :
Table I below lists monitoring wells with parameters currently in OOC or POOC status as of the
4th Quarter of 2022. The following wells therefore are required to be sampled under the
acceierated monitoring requirements. EFR is required to notifu the DWMRC on a quarterly basis
regarding wells and parameters which went into accelerated monitoring during the period [Part
I.G. 1 (a), Accelerated Monitoring Status Reports (AMSR)1.
Table 1 - Wells Monitored Accelerated to Mo Mon
Date Accelerated
Monitoring First
Required
Date of First
Exceedance of
GWCL
*Position ParameterClassWell
November 2019
November 2019
November 2021
November 2021
June2022
March2023
3'd Quarter 2019
3'd Quarter 2019
3'd Quarter 2021
3'd Quarter 2021
I't Quarter2022
4th Qtarter 2022
Chloride
Sulfate
Total Dissolved Solids
Manganese
Nitrate + Nitrite (as N)
Selenium
Class II water D,3MW-l1
November 2021
March2023
3'd Quarter 2021
4th Quarter 2022D3Total Dissolved Solids
ChlorideClass III waterMW-25
May 2010
May 2010
May 2010
November 2021
February 2010
February 2010
February 2010
3'd Quarter 2021
c-2
Nitrate + Nitrite (as N)
Chloroform
Chloride
Total Dissolved Solids
Class III waterMW-26c)
May 2010
May 2011
2"d Quarter 2021
2"d Quarter 2027
November 2021
March2023
February 2010
l't Quarter 2011
1't Quarter 2021
l't Quarter 2021
3'd Quarter 2021
4th Quarter 2022
Nitrate + Nitrite (as N)
Chloride
Uranium
Selenium
Total Dissolved Solids
Field pH
Class II water D-2MW-30
May 2010
May 2011
November 2019
November 20i9
August 2020
1't Quarter 2010
1't Quarter 201 I
3'd Quarter 2019
3'd Quarter 2019
2d Quarter2020
Nitrate + Nitrite (as N)
Chloride
Total Dissolved Solids
Sulfate
Uranium
D-2MW-31 Class III water
a : Monitoring well MW-26 is a pumping well for the Chloroform investigation
ito
D : Down-gradient; U - Up-gradient; C : Cross-gradient; 1,2,3,4A, 48 : Cell #
Wells Monitored Accelerated to
Date Accelerated
Monitoring First
Date of First
Exceedance of
GWCL
ParameterClass*PositionWell
3'd Quarter 2017
3'd Ouarter 2020
Zd Quarter 2017
2d Quarter 2020D-3 Uranium
SeleniumClass III waterMW-12
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 4
* D : Down-gradient; U - Up-gradient; C : Cross-gradient; l, 2, 3,4A, 48 : Cell #
3. Monitoring Wqlls Pursed for Two Casing Volumes Before Saqple Collection:
As stated in Section 6.2.7 of theEFR Quality Assurance Plan (QAP), Rev. 7.6, EFR has a choice
regarding purge volumes as f,ollows:
" l. Purging three well casing volumes with a single measurement offietd parameters
2. Purging two casing volumes with stable field parameters (within I0% RPD)
3. Purging a well to dryness and stability of a limited list offield parameters after recovery"
Per DWMRC review of the Report, the following purge methods were used during the 4th Quarter
2022 (rncluding accelerated samples). Purge methods and volumes are summarized in Tab G, on
Table G-lA and G-lB of the Report:
When purging two casing volumes, the QAP directs EFR to first calculate the amount of time to
",ru",rut" two casing volumes and then to pump for that length of time. Per DWMRC cross-iheck
of the field data sheets for each of the reports reviewed, it appears EFR correctly calculated the
well casing volumes and evacuated the required two volumes (when 2 casing volume method
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-17 Class III water D.4A Chloride 4Ih Quarter2022 3'd Quarter 2023
ldw-24 Class III water D-1 Beryllium
Cadmium
Thallium
Field pH
Fluoride
Nickel
Manganese
Sulfate
Gross Alpha
Total Dissolved Solids
4tr'Quarter 2017
2"d Quarter 2018
2"d Quarter 2018
2"d Quarter 2018
4th Quarter 2018
4th Quarter 2018
4th Quarter 2019
1't Quarter 2020
4th Quarter 2020
2d Quarter 2021
1't Quarter 2018
3'd Quarter 2018
3'd Quarter 201 8
3'd Quarter 201 8
3'd Quarter 2019
3'd Quarter 2019
1't Quarter 2020
3'd Quarter 2020
3'd Quarter 2021
3'd Quarter 2021
l'4W-27 Class III water u-1 Nitrate + Nitrite (as N)
Fluoride
2"d Quarter 2010
2d Quarter 2022
3'd Quarter 2010
3'd Quarter 2022
MW-28 Class III water D-1
Chloride
Uranium
Selenium
Nitrate + Nitrite (as N)
2"d Quarter 2010
2"d Quarter 2014
2"d Quarter 2019
4tL Ouarter 2019
3'd Quarter 2010
2"d Quarter 2014
3'd Quarter 2019
3'd Quarter 2020
MW-29 Class III water D-2 IJranium 4th Quarter 2020 3'd Quarter 2021
MW-32 Class III water c-2 Chloride 1't Quarter 2015 2"d Quarter 2015
MW.37 Class III water D-4B Field pH 4th Quarter 2022 3'd Quarter 2023
Quarter # Purged 2 Casing
Volumes
# Purged to Dryness # Purged 3 Casing Volumes
4th Qtr.2022 -1 -t 7 4 (continuous pumpj4g)
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
selected) in monitoring wells prior to sample collection during the 4th Quarter 2022 monitoring
period. Volumes are calculated according to measured pump rates and can be verified by
calibration marks on the collection containers.
During the 4th Quarter 2022 monitoring period, seven monitoring wells were pumped or bailed to
dryneJs. In cases where wells are .uu"uat"d to dryness the QAP Rev. 7.4 (Attachment 2-3)
requires that:
" (vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worltsheet.
The well should be sampled as soon as a sfficient volume of groundwater is available to fitl
sample conlainers.
(Jpon arrival at the well after recovery or when sfficient water is available for sampling measure
depth to woter and record on the Field Data Worksheet.
Take one set of measurements offield parameters for pH, specific conductance, and temperature
only.
Collect the samples into the appropriate sample containers
Take an additional set of measurements offield parameters for pH, spectfic conductqnce and
temperature after the samples have been collected'
If the fietd parameters of pH, specific conductance and temperature are within I 0% RP D the
samples can be shippedfor analysis.
If the field parameters of pH, specific conductance and temperature are not within I 0'% RP D,
dispose of the sample aliquots, and purge the well again as described above'
Repeat this process, if ntecessary, for three complete purging events. If after the third purging the
evint, the parameters of pH, specific conductance and temperature do not stabilize to within I0?6,
RPD, the well is considered sfficiently purged and collected samples can be submittedfor
analysis."
DWMRC staff verified that in cases where the monitoring well was evacuated to dryness and
samples were collected, the number of gallons evacuated was recorded in compliance with the
eAi Additionally, depth to water before sample collection was recorded on all applicable field
data worksheets which resolved past DWMRC comments.
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
4. Analvtical Laboratories Used bv EFR Certified by State of Utah to Pprform Analvsis
for all Analvtes:
The analytical laboratories (GEL Laboratories LLC, Charleston, SC; Chemtech Ford Laboratory,
Sandy, LiT; *.r" contracted by EFR to perform analysis on the samples collected during the 4th
Quarter 2022. Per DWMRC review of the National Environmental Laboratory Accreditation
Management System Website, both laboratories have an active certification within the State of
Utah. Screen prints from the website showing certification status are included in Appendix A.
Upon further Cross checking of laboratory certification for specihc parameters, it appears that the
analytical methods for each parameter used by the contract laboratories met the applicable method
as specified in Table I of the EFR QAP.
5. Laboratorv Report Turn Around Times:
Per DWMRC review of EFR Table 1 included in the 4th Quarter 2022Report, it was noted that
laboratory report tumaround times (from date of EFR sample submission to the contract
laboratory) for normal frequency monitoring was approximately 30 days for all samples (not
including re-submission/corrected reports).
Per DWMRC review it was noted that EFR acted quickly to identi$ any deficiencies in the
reports and request corrected versions.
Based on DWMRC review the turn-around times for the 4th Quarter 2022, data turn-around times
and EFR data review timelines appeffi to be reasonable/appropriate.
6.Samnle Times:
Per review of the 4th Quarter 2022Report (Section 3.4.2, Tab E, Tab F, and Tables G-2A and G-
2B inTab G of the Report, all method holding times were met for each analyte submitted for
laboratory analysis (for baseline and accelerated samples). DWMRC staff cross checked all
holding time requirements and verified that all samples/analytes appeared to be analyzed within
holding times during the 4th Quarter 2022 reporting period.
7. SamplePreservation:
Per review of the 4th Quarter 2022Report (Section 3.4.3, Tab G, and Laboratory Check-in Sheets)
it appears that all samples required to be chilled (.6" C) met the temperature preservation
requirements. Per review of the laboratory check in sheets and laboratory QA/QC, no issues
related to sample preservation were noted. Per EFR information and method requirements,
samples for gross alpha analysis do not have a sample temperature requirement.
8. Analvtical Reportins Limits:
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
Per review of the 4th Quarter 2022Report (Section 3.4.5, Tab E, Tab F, and Tables G-5A and G-
5B in Tab G) it appears that laboratory reporting limits met the reporting limits specified in Table
I of the QAP.
9. Sample Trin Blank Evaluation:
Per Section 3.4.6, Tabs E and F, Table G-6A, and Table G-68 of the 4th Quarter 2022Report, all
trip blank results associated with the quarterly, semi-annual, and accelerated samples were non
detect for volatile organic compounds.
Per Table G-2|and Table G-2B in Tab G of the 4th Quarter 2022Report, all trip blank samples
associated with the quarterly and accelerated samples were analyzed within the allowed holding
time.
Per Table G-3A and Table G-38 in Tab G of the 4th Quarter 2022Report, all trip blank samples
associated with the quarterly and accelerated samples were received by the Laboratory within an
acceptable temperature range.
Per Table G-5A and Table G-5B in Tab G of the 4th Quarter 2022Report, the laboratory reporting
limit for all trip blank samples associated with the quarterly and accelerated samples met the
required reporting limits.
10. Review of centration Plots
The Permit Part I.F.1.g requires EFR to submit Time-Concentration Plots for each monitoring
well for primary indicators of cell leakage; chloride, fluoride, sulfate, and uranium. DWMRC
notes that per the discussions with EFR, it was agreed that EFR nded not plot trend lines on the
Time Concentration Plots and that all data is included on the plots (no data culled from the set).
Per DWMRC review of the 4th Qtr. 2022Report, the reviewed plots appear to be in conformance
with the agreed upon changes.
11. Review of Denth to roundwater Measurements and Water ahle Contour Manst
Per DWMRC cross checks of groundwater elevation measurement calculations used for the 4th
Quarter 2022, approximately 5Yo of wells cross checked, comparing surface casing measured
elevations minus measured static levels with plotted elevations, no elrors were noted.
The upper wildlife ponds at the White Mesa Mill were taken offline (pond recharge from
Recapture Reservoir discontinued) during the 4th Quarter 2011 to re-establish groundwater
contours. Hydrographs of the upper wildlife pond ground water piezometers (Water Level
Elevation vs. Timej are included below (l.lorthern piezometers and southern piezometers). It was
also noted that the static water levels in several monitoring wells close to the upper wildlife ponds
showed signihcant decrease in water levels since the ponds were taken offline. These declines
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
can be attributed to natural dissipation of the area ground water mound and/or ground water
pumping activities related to corrective action of nitrate and chloroform contamination plumes
(development of cone of depressions around pumping wells)'
Nitrate and Chtoroform Coffective Action Plan Pumping lltells:
Ground water elevations are being impacted by effects from ground water pumping for the nitrate
and chloroform contamination plume remediation. The following monitoring wells have been
converted to active pumping wells:
Nitrate Pumping Wells -TW4-22,TW4-24,TW4-25,TWN-2 (The nitrate pumping project was
initiated during January 2013).
Chloroform Pumping Wells - MW-4, MW-26, TW4-1, TW4-2,TW4-4, TW4-11, TW4-19, TW4-
21, TW4-22, TW4-24,TW4-25,TW4-37 , TW4-39.
The pumping wells for both the nitrate and chloroform projects are set up with a delay device
wherein the wells purge for a set amount of time then shut off to let the well recharge. All
pumping wells includi a flow meter which records the volume of water pumped from the well in
gallons.- Quarterly nitrate and chloroform reports are prepared by EFR and include pump volumes
and delineation of pump capture zones based on kriged water contours.
DWMRC expects that ground water elevation contours will continue to adjust in response to the
pumping activities and discontinuance of recharge to the upper wildlife ponds.
12. ConclusionsandRecommeudalliQn!
Per the Division review it appears that the Report complies with Permit and QAP. Therefore' a
letter will be drafted notifiing EFR of the ,.ui.* and closing out the February 6,2023,4th
Quarter, 2022 Groundwater RePort.
13. References
rEnergy Fuels Resources (USA) Inc., February 6,2023,4th Quarter2022 Groundwater
Moniiring Report, Groundwater Discharge Permit UG'|I/370004, White Mesa Uranium Mill'
2 Energy Fuels Resources (USA) Inc., February 1,2023, State of Utah Ground l4/ater Discharge
Permit No. UGW370004 White Mesa (Jranium Mill - Notice Pursuant to Part I.G.l(a).
3 Energy Fuels Resources (USA) Inc., May 14,2019, White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP), Revision 7.6.
4 TNTERA Incorporate d,,2007, Revised Background Groundwater Quality Report; Ex:isting Wells
for Dension Minbs gSA) Corp.'s White Mesa (lranium Mill Site, San Juan County, Utah-
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
s INTERA Incorporate d,2007, Background Groundwater Quality Report: New Wells for Denison
Mines (USA) Corp.'s t(hite Mesa (Jranium Mill Site, San Juan County, Utah.
6 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the July 2007 Sampling Event at the Denison :
Minis, USA, White Mesa (Jranium Mill located near Blanding Utah. Prepared by University of
Utah Department of Geology and Geophysics
7 Utah Department of Environmental Quality, March 8,202I, Modified Utah Ground Water
Dischargi permit No. UGW370004 issuedfor the Energt Fuels Resources (USA) Inc. White Mesa
Uranium Mill.
EFR 4th Quarter 2022 Grottndwater Monitoring Report
DWMRC Review Memo
Page l0
Appendix A - State of Utah Laboratory Certifications
EFR 4th Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page ll
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