DRC-2019-011789 - 0901a06880b279b8

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
ENERGY FUELS
September 26, 2019
Sent VIA E-MAIL AND EXPRESS DELIVERY
Ty L. Howard,
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
av 2flt ard R3d;ati3n
OCT -1 2019 c —2019 —Os I 1759
Re: Transmittal of Installation Plan under Utah Ground Water Discharge Permit UGW370004 for
the White Mesa Mill (the "Mill")
Dear Mr. Howard:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI' s") Installation Plan for MW-24A pursuant
the Division of Waste Management and Radiation Control ("DWMRC") letter dated September 5, 2019 under
the State of Utah Groundwater Discharge Permit UGW370004 ("GWDP").
MW-24A is being installed in response to comments from DWMRC in the September 5, 2019 letter on the SAR
for MW-24.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Paul Goranson
Terry Slade
Scott Bakken
David Frydenlund
Logan Shumway
WHITE MESA MILL
State of Utah Ground Water Discharge Permit UGW370004
Plan for Installation of MW-24A
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
NERGY FUELS
September 26, 2019
1. INTRODUCTION AND BACKGROUND
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the "Mill"),
located near Blanding Utah, under State of Utah Ground Water Discharge Permit UGW370004
("GWDP").
A plan and time schedule (the "Plan") required under Part I.G.4(c) of the Permit relating to violations of
Part I.G.2 of the Permit for MW-24 for the third quarter of 2018 was submitted to the Division of Waste
Management and Radiation Control ("DWMRC") on December 5, 2018. Part I.G.2 of the Permit
provides that out-of-compliance ("00C") status exists when the concentration of a pollutant in two
consecutive samples from a compliance monitoring point exceeds a groundwater compliance limit
("GWCL") in Table 2 of the Permit. The Plan summarized assessments that would be completed in a
Source Assessment Report ("SAR"). The Plan was approved by DWMRC by letter dated March 5, 2019.
At the time of the Plan, MW-24 had exhibited a consistently decreasing trend in pH and
increasing trends in cadmium and thallium exceeding GWCLs. The Plan only contemplated the
inclusion of pH, cadmium and thallium in the SAR. However, the SAR also included an analysis
of beryllium, fluoride, and nickel in MW-24 due to increasing trends in concentrations and 00C
status for these constituents after the Plan was submitted on December 5, 2018.
The SAR was submitted to DWMRC on June 27, 2019. As noted in the SAR, the Mill site was recently
thoroughly studied in the Background Reports (INTERA, 2007a, 2007b, 2008), in various SARs,
and in the University of Utah Study (Hurst and Solomon, 2008). The Background Reports
(INTERA, 2007a, 2007b, 2008) and the University of Utah Study concluded that groundwater at
the Mill site has not been impacted by Mill operations. Both of those studies also acknowledged
that there are natural influences at play at the Mill site that have given rise to increasing
concentration trends of some constituents and the general variability of background groundwater
quality at the Mill site.
The focus of the SAR was, therefore, to identify any changes in the circumstances identified in
those studies. Beryllium, cadmium, fluoride, thallium, nickel, and pH are exhibiting significantly
increasing (decreasing for pH) trends. Cadmium and thallium have been recently analyzed in the
2016 SAR (INTERA, 2016). Indicator parameters in MW-24 chloride, sulfate, and uranium
exhibit no trend. Fluoride in MW-24 is significantly increasing. Significantly decreasing pH in
MW-24 has been attributed to the site-wide oxidation of pyrite. Decreasing pH can mobilize
naturally occurring minerals within the Burro Canyon Formation. Due to the lack of trends in
indicator parameters, the trends in beryllium, cadmium, fluoride, thallium, nickel, and pH are not
related to potential tailings seepage and are likely the result of mobilization of natural sources of
metals within the Burro Canyon Formation.
DWMRC reviewed the SAR and discussed the review findings in a conference call with EFRI on
September 3, 2019 and summarized the results of that call in a letter dated September 5, 2019.
During the September 3, 2019 conference call EFRI noted that potential anomalies were noted in
MW-24 during the installation and construction of the well. The September 5, 2019 DWMRC
letter concluded that:
"During the September 3, 2019 telephone conference call it was discussed that based on
review of the GWCL exceedances at MW-24 and well data, it does not appear that
1
tailings wastewater is the source. However, beryllium was measured as non-detectable
from July 2005 until April 2016, and likewise nickel shows a significantly large amount
of non-detect data until the recent rising trend. Based on these data anomalies it was
discussed that problems with the well (e.g. design and installation) may be the cause of
the out-of- compliance status for the SAR parameters."
As a result of the potential anomalies associated with the installation and construction of MW-
24, EFRI suggested that in order to determine whether the well is the cause, an additional well
will be installed close-by the existing MW-24, and monitored in tandem. This is similar to the
approach used at other wells (MW-03 and MW-03A) which showed similar anomalous data.
This approach will also allow more monitoring data to be collected at MW-24 for better
evaluation of data trends.
2. WELLS SUBJECT TO THIS PLAN
This is the installation plan for the installation of MW-24A. As stated above, MW-24A is being
installed in close proximity to MW-24 in response to comments from DWMRC on the SAR for
MW-24.
3. PLAN AND TIME SCHEDULE
MW-24A will be installed approximately 10 feet northwest of MW-24 as shown in Figure 1
attached.
MW-24A will be installed with a screened interval similar to that of MW-24. Assuming that the
Brushy Basin Member contact at MW-24A is encountered at 118.5 feet below land surface (ft
bls), MW-24A would be screened from approximately 99.5 to 119.5 ft bls. If the Brushy Basin
Member contact is encountered at a different depth, MW-24A will be completed with 20 feet of
screen bottoming approximately 1 to 2 feet below the contact. Placing the base of the screen just
below the Brushy Basin Member contact is consistent with the construction of other perched
monitoring wells installed at the site.
3.1 TIME SCHEDULE
The installation of the proposed well and the completion of the as-built report will be completed
in accordance with the required timeframes specified in the GWDP. The proposed well will be
installed and operational within 90 days of director approval of this installation plan schedule
and the as-built report will be completed within 60 days of well completion.
3.2 EXPERTS REPORTS TO BE PREPARED
As required by GWDP Part I.F.6, EFRI will submit an as-built report within 60 days of well
installation for the newly installed well proposed herein. Boring logs for the well and test
borings will be included in the as-built report.
Analytical data for MW-24A, will be included in the routine quarterly groundwater monitoring
reports. Discussion of the analytical results and the conclusions resulting from the tandem
2
monitoring program will be submitted to DWMRC under separate cover at the end of 8 quarters
of sampling.
4. CONCLUSION
Given the varied background groundwater quality at the site, it cannot be assumed that consecutive
exceedances of 4 constituent in a monitoring well means that contamination has been introduced to
groundwater in that well.
With respect to field pH in MW-24, the previously identified trend suggests that the exceedances are a
continuation of the statistically significant decreasing pH trend identified in the SARs and the pH Report.
It has been established that the continued decreasing trend of field pH across the site is not inconsistent
with natural background, and in fact was accepted as natural background for purposes of setting the
revised GWCLs.
The exceedances of cadmium, nickel, beryllium, fluoride, and thallium represent impacts due to a
decreasing pH (statistically significant).
Background at the Mill site was recently thoroughly studied in the Background Reports, the SAR, the pH
report, and the University of Utah Study. The Background Reports, the SAR, the pH report and the
University of Utah Study concluded that groundwater at the site has not been impacted by Mill
operations. All of these studies also acknowledged that there are natural influences at play at the site that
have given rise to increasing water levels and general variability of background groundwater chemistry at
the site.
EFRI maintains that it is not practicable to redo the University of Utah Study and comprehensive
Background Reports each time a monitoring well shows consecutive exceedances, particularly where the
exceedances are consistent with those recent analyses. The focus should be on identifying any changes in
the circumstances identified in those studies. Therefore, EFRI conducted a geochemical analysis of 00C
parameters in MW-24 and assessed indicator parameters and confirmed that the out-of-compliance status
is due to variations in background.
A general discussion of the site-wide pH trend is necessary because decreasing pH is one of the
most important contributors to increasing concentrations of all MW-24 00C parameters. A
decreasing trend in pH has been observed in almost every groundwater monitoring well across
the Mill site, including upgradient and far downgradient monitoring wells (INTERA, 2012b).
The Pyrite Report (HGC, 2012) attributes the decline in pH across the Mill site to the site-wide
existence and oxidation of pyrite in perched groundwater hosted by the Burro Canyon
Formation. This report showed that the MW-24 drill core sample submitted for laboratory
analysis by XRD contained the highest pyrite content among the samples analyzed (HGC, 2012).
Most indicator parameters in MW-24 show no trend (chloride, sulfate, and uranium); whereas
fluoride shows a significant increasing trend. Given the decreasing trend in pH at MW-24,
mineral dissolution is a likely cause for increasing concentrations of the 00C parameters. The
lack of trends in key indicator parameters suggest that the trends in beryllium, cadmium,
fluoride, thallium, nickel, and pH in MW-24 are unlikely to be caused by potential tailings
seepage.
3
FIGURE
5500 perched water level contour
and label (feet amsl)
24A proposed perched monitoring well
(located approximately 10 feet
northwest of MW-24)
MW-29 • perched monitoring well
HYDRO
GEO
CHEM, INC. APPROVED
APPROXIMATE LOCATION OF PROPOSED
NEW WELL MW-24A
(showing kriged Q2 2019 perched water levels)
DATE REFERENCE
R/718000/MW14_24_25/MW24_0919/MW24Aloc.srf
FIGURE
1