DRC-2013-002485 - 0901a06880390779

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
II DRC-2013-002485' II
VIA EMAIL AND OVERNIGHT DELIVERY
June 18, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill Groundwater Discharge Permit ("GWDP") UGW37004
Renewal Applications Submitted 2009 and 2012 - Response to May 23,2013 Utah
Division of Radiation Control E-Mail Request for Information ("RFI")
Dear Mr. Lundberg:
Reference is made to the Utah Division of Radiation Control ("DRC") memorandum dated December
23, 2009 regarding comments on the Energy Fuels Resources (USA) Inc. ("EFRI") 2009 GWDP
renewal application, and the DRC e-mail dated May 23, 2013 regarding comments on the EFRI 2012
GWDP renewal application. This letter responds to both the memorandum dated December 23, 2009
and the DRC e-mail correspondence dated May 23, 2013.
The December 23, 2009 DRC memorandum specifically delineated which attachments and/or
appendices to the 2009 GWDP renewal application were required to be resubmitted and listed the reason
for the resubmission. Attached to this letter is the table from the DRC memorandum which provided
the resubmission list, and the EFRI response or action in resulting from the comments. A word-
searchable CD containing the resubmitted documents from the 2009 GWDP renewal application is
included with this letter.
The May 23, 2013 e-mail from DRC noted that some of the appendices or attachments to the 2012
GWDP renewal application were not word-searchable, without providing a specific list of those
documents which were not word-searchable. In response, EFRI has provided a CD containing all of the
appendices and attachments from the 2012 GWDP renewal application in a word searchable format.
N:\WMM\Groundwater Discharge Permit\2012 GWDP Renewal Application\2012 Application Appendices, Tables, and
Figures - OCRYTrans ltr for CDs for RFI 06.18.13.doc
Letter to Rusty Lundberg
June 18, 2013
Page 2 of 2
If you have any questions, please contact me at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
John Hultquist, Utah DRC
David Edwards, Utah DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
Table 1 - List of Groundwater Discharge Permit Renewal Application Supplementary
Information from 2009 and 2012
Document
Number1
Document Title Discrepancies Noted in DRC Letter,
dated December 23,2009
Actions Taken to
Correct Discrepancies
White Mesa Uranium Mill Permit
Renewal Application State of Utah
Ground Water Permit No.
UGW370004, September 1, 2009
Section 2.58 Well Logs - Lists a
number of well logs that were provided
in documents attached to the Renewal
Application. However, a number of
well logs were not included with the
Application, including:
MW-20, MW-22, TW4-1, TW4-2,
TW4-3, TW4-4, TW4-5, TW4-6,
TW4-7, TW4-8, TW4-9, TW4-10,
TW4-11, TW4-12, TW4-13, TW4-14,
TW4-16, TW4-18, TW4-19, TW4-20,
TW4-21, TW4-22, TW4-23, TW4-24.
TW4-25, P-1, P-2, P-3, P-4, P-5, and
well logs of any Nitrate wells recently
installed.
CD #1 - All available
well logs have been
included
a(iv) Reclamation Plan White Mesa Mill
Blanding, Utah, Source Material
License No. SUA-1358 Docket No.
40-8681 Revision 3.0, July 2000
This is not the most recent version of
the Reclamation Plan. Figures A-5.1-
1, A-5.1-2, and A-5.1-3 were updated
(as a result of Cell 4A construction) on
July 25, 2008 and were approved by
the DRC on August 4, 2008.
CD #1 - The most
recent, approved
Reclamation Plan, Rev.
3.2 is included as a
word-searchable PDF
a(v) UMETCO Minerals Corporation:
White Mesa Mill Drainage Report
for Submittal to NRC, January 1990
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
b(i) Revised Background Groundwater
Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s
White Mesa Mill Site, San Juan
County, Utah, October 2007,
prepared by INTERA, Inc.
From the PDF, Figure 15 has been
omitted from the document.
CD #1 - Figure 15 is
now included
b(ii) Revised Addendum: ~ Evaluation
of Available Pre-Operational and
Regional Background Data,
Background Groundwater Quality
Report: Existing Wells For Denison
Mines (USA) Corp.'s White Mesa
Mill Site, San Juan County, Utah,
November 16, 2007, prepared by
INTERA, Inc.
From the PDF, Figures 9 - 27 are
missing data when compared to the
"hard-copy" version of the document,
The charts on Figures 5-8 and 28 - 29
are also missing data.
CD #1 - Figures 9-27
are now included as
searchable PDFs.
Figures 5-8 now
include all missing data
b(iii) Revised Addendum: ~ Background
Groundwater Quality Report: New
Wells For Denison Mines (USA)
Corp.'s White Mesa Mill Site, San
Juan County, Utah, April 30, 2008,
prepared by INTERA, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
1
Document
Number1
Document Title Discrepancies Noted in DRC Letter,
dated December 23,2009
Actions Taken to
Correct Discrepancies
b(iv) Summary of work completed, data
results, interpretations and
recommendations for the July 2007
Sampling Event at the Denison
Mines, USA, White Mesa Uranium
Mill Near B landing Utah, May
2008, prepared by T. Grant Hurst
and D. Kip Solomon, Department of
Geophysics, University of Utah
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
c(i) Environmental Report, White Mesa
Uranium Project San Juan County,
Utah, January 30, 1978, prepared by
Dames & Moore
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
c(ii) Final Environmental Statement
related to operation of White Mesa
Uranium Project Energy Fuels
Nuclear, Inc., May 1979, Docket
No. 40-8681, prepared by the
United States Nuclear Regulatory
Commission
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(ii) Hydrogeological Evaluation of
White Mesa Uranium Mill, July
1994, prepared by TITAN
Environmental Corporation
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(iv) Update to report Investigation of
Elevated chloroform concentrations
in Perched Groundwater at the
White Mesa Uranium Mill Near
Blanding, Utah, 2001, prepared by
Hydro Geo Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(v) Hydraulic Testing at the White
Mesa Uranium Mill Near Blanding,
Utah During July 2002, August 22,
2002, prepared by Hydro Geo
Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(vi) Letter Report dated August 29,
2001 prepared by Hydro Geo Chem,
Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(vii) Perched Monitonng Well
Installation and Testing at the White
Mesa Uranium Mill April Through
June 2005, August 3, 2005,
prepared by Hydro Geo Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
d(viii) Site Hydrogeology and Estimation
of Groundwater Travel Times In
The Perched Zone White Mesa
Uranium Mill Site Near Blanding,
Utah, August 27, 2009, prepared by
Hydro Geo Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
This document is also not certified by a
Utah Licensed Professional Geologist
as required.2
CD #1 - included as
word-searchable PDF2
See Comment #2
below
e(i) Engineers Report: Tailings
Management System, White Mesa
Uranium Project Blanding, Utah,
June 1979, prepared by
D'Appolonia Consulting Engineers,
Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
Document
Number1
Document Title Discrepancies Noted in DRC Letter,
dated December 23,2009
Actions Taken to
Correct Discrepancies
e(ii) Engineer's Report: Second Phase
Design - Cell 3 Tailings
Management System, White Mesa
Uranium Project Blanding, Utah,
May 1981, prepared by
D'Appolonia Consulting Engineers
Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(iii) Construction Report: Initial Phase -
Tailings Management System,
White Mesa Uranium Project
Blanding, Utah, February 1982,
prepared by D'Appolonia
Consulting Engineers, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(iv) Construction Report: Second Phase
Tailings Management System,
White Mesa Uranium Project,
March 1983, prepared by Energy
Fuels Nuclear, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(v) Cell 4 Design, White Mesa Project
Blanding, Utah, April 10, 1989,
prepared by Umetco Minerals
Corporation
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(vi) Construction Report: Tailings Cell
4A, White Mesa Uranium Mill -
Tailings Management System,
August 2000, prepared by Denison
(then named International Uranium
(USA) Corporation).
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(vii) Cell 4A Lining System Design
Report For The White Mesa Mill
Blanding, Utah, January 2006,
prepared by GeoSyntec Consultants
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
e(vni) Cell 4A Construction Quality
Assurance Report, White Mesa Mill
Blanding, Utah, July 2008, prepared
by Geosyntec consultants (disk
only)
This document is partially text
searchable; however pages 63, 65 -
1255 and 1346 - 1377 are not text
searchable as required by R313-12-111
CD #1 - this document
is now included as a
complete word-
searchable PDF
f(0 Preliminary Corrective Action Plan,
White Mesa Mill Near Blanding,
Utah, August 20, 2007, prepared by
Hydro Geo Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
f(ii) Preliminary Contamination
Investigation Report, White Mesa
Mill Near Blanding, Utah,
November 20, 2007, prepared by
Hydro Geo Chem, Inc.
This document is not a searchable PDF
document as required by R313-12-111.
CD #1 - included as
word-searchable PDF
White Mesa Uranium Mill Renewal
Application, State of Utah
Groundwater Discharge Permit No.
UGW370004 - Appendices, Tables,
and Figures
Per David Edward's e-mail on May 23,
2013, half of the appendices included
in the 2012 renewal application were
not searchable PDF documents.
CD #2-all ofthe
appendices, tables, and
figures are included as
work-searchable PDFs
1. Data obtained from the September 1, 2009 Re: Application to Renew State of Utah
Ground Water Discharge Permit No. UGW370004 for the White Mesa Uranium Mill
Letter.
2. The report entitled Site Hydrogeology and Estimation of Groundwater Travel Times in
the Perched Zone, White Mesa Uranium Mill Site near Blanding, Utah, August 27, 2009,
prepared by Hydro Geo Chem Inc. was not certified by a Professional Geologist at the
time of submission in 2009. The data contained in the report were current at the time of
the report submission, however, due to the delay in the review process the data have been
superseded by updated information and data collected from 2009 to present. The most
current information related to groundwater travel times is included in the Second Revision
Hydrogeology of the Perched Groundwater Zone in the Area Southwest of the Tailings
Cells, White Mesa Uranium Mill Site, dated November 7, 2012, prepared by Hydro Geo
Chem Inc. The most recent report is certified by a Professional Geologist. A copy of this
report is included as a word-searchable PDF on CD #1 with this response for your
convenience.