DRC-2016-003561 - 0901a068806070eb

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
February 11, 2016
VIA PDF AND FEDERAL EXPRESS
Mr. Scott Anderson
Director of Waste Management and Radiation Control DRC State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status
Dear Mr. Anderson:
A number of groundwater monitoring constituents have been placed on accelerated monitoring status
under Part I.G.l of the Energy Fuels Resources (USA) Inc. (“EFR1”) Ground Water Discharge Permit No.
UGW370004 (“GWDP”). Part I.G.l provides that such accelerated monitoring shall continue until
compliance status of the facility can be determined by the Director.
Based on the accelerated monitoring results to date, EFRI requests the Director make a determination that
accelerated monitoring cease at this time for uranium in MW-25 and nitrate+nitrite (as N) (“nitrate”) and
total dissolved solids (“TDS”) in MW-03A for the reasons stated below:
• MW-25 uranium results have been below the Groundwater Compliance Limit (“GWCL”)
specified in the GWDP for ten consecutive sampling events since Q1 2015. Per the DWMRC,
eight consecutive sample results below the GWCL are needed for the discontinuance of
accelerated monitoring.
• MW-03A nitrate results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Q4 2013 sampling event. Per the DWMRC, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
• MW-03A TDS results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Q4 2013 sampling event. Per the DWMRC, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
Once removed from accelerated monitoring status, these constituents, like all other constituents, would be
subject to future accelerated monitoring under Part I.G.l of the GWDP, should circumstances warrant.
To assist in your evaluation of the foregoing, we have included a summary of the accelerated sampling
results since the initial sample result that triggered accelerated monitoring in Table 1.
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ENERGYFUELS
Letter to Scott Anderson
Removal of Parameters from Accelerated Monitoring
February 11, 2016
Page 2
The analytical laboratory reports for the foregoing results up to and including September 2015 are
included in the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC.
Copies of the analytical laboratory reports for the results for October 2015 through December 2015 are
provided in the 4th Quarter 2015 Groundwater Monitoring Report and are also included with this letter
for your convenience. It is important to note that the 4th Quarter 2015 monitoring results included with
this letter have been evaluated per the DWMRC approved QAP and the GWDP and all field and
laboratory quality control parameters are acceptable. The evaluations of the 4th Quarter data are included
in the 4th Quarter 2015 Groundwater Monitoring Report which will be submitted to DWMRC on or
before March 1, 2016.
If you have any questions or require any further information, please contact the undersigned.
Quality Assurance Manager
cc: David C. Frydenlund
Harold Roberts
Logan S humway
David Turk
Scott Bakken
Analytical Results Md Field Sampling Sheets for the Well, ,h„.
this Request U are ,he Snbje.
Table 1
Summary of Accelerated Sample Results with Eight or More Results in Compliance
Well ID Constituent GWCL Sample Date Sample Result
MW-25 Uranium (ug/L)6.5 Q1 2015*
March 2015
Q2 2015
May 2015
June 2015
July 2015
Q3 2015
September 2015
October 2015
Q4 2015
December 2015
6.81
6.43
5.86
6.38
5.88
6.25
6.39
6.20
6.40
6.19
6.00
MW-03A Nitrate+Nitrite
(as N) (mg/L)
1.3 Q4 2013i|
Q1 2014
Q2 2014
Q3 2014
Q4 2014
Q1 2015
Q2 2015
Q3 2015
Q4 2015
1.52
0.849
0.97
1.0
1.11
1.05
1.1
0.435
0.903
MW-03A TDS (mg/L)5805 Q4 2013*
Q1 2014
Q2 2014
Q3 2014
Q4 2014
Q1 2015
Q2 2015
Q3 2015
Q4 2015
5940
5600
5790
5460
5370
5470
5410
5660
5510
*Last sample result outside of GWCL limits.
INORGANIC ANALYTICAL REPORT
i'i
American West
ANALYTICAL LABORATOFMFS
Client: Energy Fuels Resources, Inc.
Project: October Monthly Groundwater 2015
Lab Sample ID: 1510198-002
Client Sample ID: MW-25 10062015
Collection Date: 10/6/2015 1300h
Received Date: 10/9/2015 1030h
Contact: Garrin Palmer
Analytical Results DISSOLVED METALS
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
Salt Lake City, UT 84119 Cadmium mg/L 10/13/2015 I4i3h 10/22/2015 i45ih E200.8 0.000500 0.00150
Uranium mg/L 10/13/2015 I4i3h 10/27/2015 isi7h E200.8 0.000300 0.00640 A
A - Reissue of a previously generated report. Information has been added, updated, or revised. Information herein supersedes that of the
previously issued reports.
Phone:[phone]
Toll Free: [phone]
Fax:[phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 11/3/2015 Page 6 of 30
AH analyses applicable to the CWA, SDWA. and RCRA are performed in accordance to NELAC protocols. Pertinent sampling infonnation is located on the attached COC. Confidential Business Information: This report is prov ided for the exclusive use of the
addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with the re-publication of this report
for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of the trade and of science.
INORGANIC ANALYTICAL REPORT
American West ^ „ANAlYT'CAi LABORATORIES ColleCtlOIl Date:
Client: Energy Fuels Resources, Inc.
Project: 4th Quarter Groundwater 2015
Lab Sample ID: 1511245-009
Client Sample ID: MW-25J1112015
11/11/2015 1040h
Received Date: 11/12/2015 1500h
Contact: Garrin Palmer
Analytical Results DISSOLVED METALS
3440 South 700 West
Salt Lake City, UT 84119
Phone:[phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Compound
Arsenic
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Uranium
Vanadium
Zinc
Units
Date Date Method
Prepared Analyzed Used
Reporting Analytical
Limit Result Qual
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 !353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 !353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/13/2015 1845h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 I353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/16/2015 1353h
11/17/2015 2037h
11/17/2015 2221h
11/17/2015 2037h
11/25/2015 1102h
11/17/2015 2037h
11/17/2015 2037h
11/17/2015 2037h
11/17/2015 2221h
11/17/2015 222 lh
11/25/2015 1102H
11/17/2015 2037h
11/16/2015 1004h
11/17/2015 2037h
11/17/2015 2037h
11/25/2015 1142h
11/17/2015 2037h
11/17/2015 2037h
11/25/2015 1102h
11/17/2015 222 lh
11/17/2015 2037h
11/17/2015 2302h
11/25/2015 1142h
11/17/2015 2037h
E200.8
E200.8
E200.8
E200.7
E200.8
E200.8
E200.8
E200.8
E200.8
E200.7
E200.8
E245.1
E200.8
E200.8
E200.7
E200.8
E200.8
E200.7
E200.8
E200.8
E200.8
E200.7
E200.8
0.00500
0.000500
0.000500
10.0
0.0250
0.0100
0.0100
0.0300
0.00100
10.0
0.0100
0.000500
0.0100
0.0200
1.00
0.00500
0.0100
10.0
0.000500
0.100
0.000300
0.0150
0.0100
<0.00500
<0.000500
0.00138
361
< 0.0250
<0.0100
<0.0100
<0.0300
<0.00100
118
1.52
< 0.000500
0.0129
< 0.0200
9.04
<0.00500
<0.0100
283
0.000828
<0.100
0.00619
<0.0150
<0.0100
Report Date: 12/4/2015 Page 16 of 56
All analyses applicable to the CWA. SDWA, and RCRA are performed in accordance to NELAC protocols. Pertinent sampling information is located on ihe attached COC. Confidential Business Information: This report is provided for the exclusive use of the
addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection w ith the advcrtiscmenL promotion or sale of any product or process, or in connection with the re-publication of this report
for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of the trade and of science.
INORGANIC ANALYTICAL REPORT
American West
ANALYTICAL I ABORATORIES
Client: Energy Fuels Resources, Inc.
Project: December Monthly Ground Water 2015
Lab Sample ID: 1512253-002
Client Sample ID: MW-25J 2082015
Collection Date: 12/8/2015 1050h
Received Date: 12/11/2015 lOOOh
Contact: Garrin Palmer
3440 South 700 West
Salt Lake City, UT 84119
Analytical Results DISSOLVED METALS
Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Cadmium mg/L 12/11/2015 i42ih 12/15/2015 952h E200.8 0.000500 0.00145
Uranium mg/L 12/11/2015 i42ih 12/15/2015 i033h E200.8 0.000300 0.00600
Phone: [phone]
Toll Free: [phone]
Fax:[phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 1/5/2016 Page 6 of 28
All analyses applicable to the CWA. SDWA, and RCRA arc performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information: This report is provided for the exclusive use of the
addressee Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with the re-publication of this report
for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analy sis in good faith and according to the rules of the trade and of science.
INORGANIC ANALYTICAL REPORT
American WestANALYTICAL LA30RAT0RIFS
3440 South 700 West
Salt Lake City, UT 84119
Phone:[phone]
Toll Free: [phone]
Fax:[phone]
e-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Client: Energy Fuels Resources, Inc.
Project: 4th Quarter Groundwater 2015
Lab Sample ID: 1511092-002
Client Sample ID: MW-03A_11042015
Collection Date: 11/4/2015 700h
Received Date: 11 /5/2015 1040h
Analytical Results
Contact: Garrin Palmer
Compound Units
Date Date Method Reporting
Prepared Analyzed Used Limit
Analytical
Result Qual
Ammonia (as N)
Bicarbonate (as
CaC03)
Carbonate (as CaC03)
Chloride
Fluoride
Ion Balance
Nitrate/Nitrite (as N)
Sulfate
Total Anions, Measured
Total Cations,
Measured
Total Dissolved Solids
Total Dissolved Solids
Ratio,
Measured/Calculated
Total Dissolved Solids,
Calculated
mg/L
mg/L
mg/L
mg/L
mg/L
%
mg/L
mg/L
meq/L
meq/L
mg/L
mg/L
11/11/2015 900h 11/12/2015 95lh
11/6/2015 850h
11/6/2015 850h
11/5/2015 2215h
11/6/2015 550h
11/17/2015 1609h
11/7/2015 1829h
11/5/2015 1910h
11/17/2015 1609h
11/17/2015 1609h
11/6/2015 1130h
11/17/2015 1609h
11/17/2015 1609h
E350.1
SM2320B
SM2320B
E300.0
E300.0
Calc.
E353.2
E300.0
Calc.
Calc.
SM2540C
Calc.
Calc.
0.0500
1.00
1.00
10.0
0.100
-100
0.100
1,000
20.0
<0.0500
328
< 1.00
59.5
0.996
0.980
0.903
3,380
78.5
80.1
5,510
1.07
5,150
Report Date: 11/30/2015 Page 18 of 56
All analyses applicable lo Ihc CWA. SDWA. and RCRA arc performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC Confidential Business Information: This report is provided for the exclusive use of the
addressee- Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with the re-publication of litis report
for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of Ihc trade and of science.