DRC-2020-020545 - 0901a06880dbdf11

Bikepacking Roots 101 W Goodwin St #3849 Prescott AZ 86302 www.bikepackingroots.org

July 9, 2020

DWMRC
195 N 1950 W
Salt Lake City UT

Kurt Refsnider, Ph.D.
Bikepacking Roots
101 W Goodwin St #3849
Prescott, AZ 86302
[e-mail]

RE: Public Comment on White Mesa RML Renewal: Modification to Groundwater Quality
Discharge Permit No. UGW370004 and Amendment #10 of the 11e.(2) Byproduct License No.
UT1900479 for Energy Fuels Resources, Inc. White Mesa Uranium Mill

To whom it may concern:
I write on behalf of the Bikepacking Roots not-for-profit organization and our 5,000+ members
in expressing dismay at the interpretations of monitoring well data from down hydraulic gradient
of the White Mesa Mill site. These analyses and interpretations would never stand up in peer
reviewed scientific journals, and that is absolutely unacceptable when there exists the potential
long-term poisoning of local communities and the broader landscape. DEQ completely neglects
equally viable interpretations of data specifically from monitoring well MW-30 that could
legitimately show groundwater contamination from at least one of the tailings impoundments
beginning around 2010. Thus, without further scrutiny of these and other data, no discharge
permit amendments or byproduct license amendments should be made for the White Mesa Mill –
no increases in groundwater compliance limits (GWCLs), no increase in materials to be added to
tailings impoundments, and no acceptance of materials from other countries for processing.

Our mission at Bikepacking Roots is to advocate for the bikepacking experience and for the
landscapes through which we ride on behalf of the bikepacking community and our members.
The Bears Ears and Grand Canyon regions are both popular among bikepackers, and the
potential for future uranium mining in these region’s futures, as well as any related
contamination of the landscape, are especially concerning. We also have worked extensively
with colleagues and organizations on Navajo Nation, and the long-term toxic impacts of uranium
mining are all too real there. Given that Energy Fuels Resources owns the uranium mines in the
Grand Canyon region (currently flooded with contaminated groundwater) and lobbied heavily
for areas underlain by uranium-bearing bedrock to be removed from the original boundaries of
Bears Ears National Monument, we find it important to engage in this current process related to
the White Mesa Mill.

In writing this comment, I am representing the Bikepacking Roots organization and our
members. As a geologist with a background in geochemistry, I personally have the expertise to
delve into the data from the White Mesa Mill.

What is particularly dismaying is that in DRC-2019-006502, the DEQ memo reviewing the 2019
Source Assessment Report for MW-30, the DEQ

1. Accepts the linear regression fits through the 2005-2018 groundwater chemistry data
despite the fact that the data show a clear change in behavior around 2010. Forcing a
linear regression through this full dataset is nothing more than sloppy and deceptive
statistical analysis.
2. Accepts the argument that a minor decrease in pH (less than 0.5 pH units) could alter
uranium concentrations. This would only be the case if the groundwater was nearly
saturated with respect to uranium, and that is very much not the case. Minor changes in
pH in the historic range of groundwater pH values will not change uranium
concentrations.
3. Accepts that tailings solution indictor parameters conclusively do not suggest
contamination. Below I share an equally plausible interpretation of the same data and
plots that point to contamination being able to just as easily explain the geochemistry
trends at MW-30
4. Points to “long-standing upward trends” in SAR parameters. Again, uranium, sulfate,
chloride, and pH all show a marked change in any trends around 2010. Forcing a linear
regression through a longer period does not prove the existence of a long-standing trend.
5. Points to a 2008 University of Utah study that dated the groundwater in MW-30 to being
older than the mill construction date of 1980. That may in fact be completely correct. But
it is still possible to contaminate “old” water.

Each of these points on their own raises flags about the veracity of the interpretations of
groundwater chemistry data coming from any of the monitoring wells at the White Mesa Mill
site. But the fact that the validity of five of the six primary conclusions of the 2019 SAR
summarized in the DRC-2019-006592 DEQ memo can be called into question is hugely
problematic. The statistical analyses and interpretations of the 2019 SAR data from MW-30 (and
likely other wells) would not stand up to any sort of scientific peer review, and DEQ’s seemingly
unquestioning acceptance of those analyses and interpretations does nothing to inspire faith in
DEQ oversight.

Let’s explore a bit of the geochemistry data from MW-30 over the years in a bit more depth,
including some past interpretations of those data.

An analysis of historic chloride concentrations in a variety of wells at the White Mesa Mill site
using data from 1983 to 2006 demonstrates that “chloride values are similar from 1983 to 2005-
2006, indicating that, in spite of the variable magnitude of concentrations across the site, these
comparative snap shots demonstrate that there has been little change in concentrations in samples
from each well” (BGQR12292006). It was not until 2010 that chloride concentrations in MW-30
began to rise steadily (see MW-30 data plots at the end of comment with pre- and post-2010
periods highlighted for clarity; plots are taken directly from DRC-2019-000747). This increase in
chloride concentrations around 2010 occurred at roughly the same time as uranium
concentrations in MW-30 began to rise. It was also around 2010 that a steady decrease in sulfate
concentrations at MW-30 leveled out. And no notable change in pH at MW-30 occurred at this
time. Since 2010 at MW-30, the data show a steady rise in uranium and chloride concentrations
and generally steady sulfate concentrations and pH; fluoride trend interpretation is hampered by
high scatter pre-2010.

What might all this mean, and how should each of these indicators be interpreted? In the
discussion of the merits of various “indicators of potential impact” in BGQR1229-2006 (a 2006
Background Groundwater Quality Report for the White Mesa Mill), chloride is identified as a
“primary indicator of potential tailings impact.” Fluoride, which has similar chemical properties
as chloride, can have solubility controlled along ground water flow paths by the trace mineral
apatite, resulting in fluoride being considered secondary to chloride in terms of reliability as an
indicator of impact. Similarly, solubility differences between calcium chloride and calcium
sulfate mineral species complicates the interpretation of sulfate data.

Returning to the MW-30 data, the steady decrease in sulfate concentrations at MW-30 between
2005 and 2010 levels off. 2010 is approximately the year that uranium and chloride
concentrations at MW-30 began to increase steadily. If the steady decrease in sulfate
concentrations between 2005 and 2010 was due to influences external to the mill site (as argued
in the 2019 MW-30 SAR), groundwater contamination from mill operations could responsible
for the relatively steady sulfate concentrations since 2010 as sulfate from tailings could have
offset that prior decrease in sulfate concentrations (or in other words, the longer-term decrease in
sulfate concentration due to environmental factors external to the mill site is masking
contamination since 2010).

To summarize this simply, all the trends observed in uranium, chloride, and sulfate
concentrations at MW-30 could potentially be explained by groundwater contamination from the
mill site. The conclusions from the 2019 MW-30 SAR accepted by DEQ are not the only viable
explanation for these trends, and I would argue that what I have presented is arguably a more
viable explanation.

As explained in detail in BGQR12292006, the interpretation of indicators of potential impact is
complicated by environmental variability in groundwater geochemistry. Thus, if interpretation of
monitoring well data shows any potential sign of contamination, the onus is on the DEQ to
require a far more thorough analysis and investigation than has been done. Decisions regarding
potential uranium contamination must not be based on difficult to interpret data, shoddy and
deceptive statistical analyses or conclusions that ignore other viable explanations. Far too much
is at stake.

Based on all this, we request that

1. No changes be made in the uranium GWCLs be made. It has not been demonstrated
convincingly that the increasing trends in uranium are not due to contamination.
2. No license amendment be issued for an increase in the annual limit of material added to
the tailings impoundments be granted.
3. No license amendment be issued for the acceptance of alternate feed material from
Estonia be granted.

The toxic legacy of uranium contamination is all too visible today across the Colorado Plateau,
and particularly on Navajo Nation where so many families face the realities of cancer, birth
defects, poisoned wells, and so much more as a result of past uranium mining. And just down
hydraulic gradient a few miles from the White Mesa Mill sits the White Mesa Community,
poised to intercept any groundwater contamination from the mill. One undetected leak is all it
would take. And it has not been convincingly demonstrated that the changes in groundwater
geochemistry at MW-30 are not evidence of a contamination that began around 2010.

Respectfully,

Kurt Refsnider, Ph.D.
Executive Director