DRC-2018-002981 - 0901a068807d9444

DRC-2018-002981 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

March 30, 2018

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources (USA) Inc. March 2, 2018, Transmittal of Plan and Time Schedule
Groundwater Discharge Permit No. UGW370004 (Permit)

Dear Ms. Weinel:
The Division of Waste Management and Radiation Control has completed its review of Energy Fuels
Resources’ (EFR) March 2, 2018 Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part I.G.4(c) White Mesa Mill (EFR Plan). The EFR Plan addresses
exceedances of the Ground Water Compliance Limit (GWCL) for fluoride in monitoring well MW-14.
Monitoring Well MW-14 is in out-of-compliance status for fluoride in accordance with Part I.G.2 of the Permit. Fluoride is therefore required to undergo corrective action as required by Part I.G.4 of the
Permit.

The table below summarizes the preliminary findings in the EFR Plan:

Monitoring Well Parameter EFR Noted Preliminary Findings
MW-14 Fluoride
• Indicator parameters chloride and fluoride are
decreasing and sulfate and uranium are not
exhibiting any trend.
• Initial GWCL was set based on eleven data points which did not reflect natural variation.
Sixty-one data points are now available.
• More sensitive analytical method is being used
which detects more variability in more recent
data.

A Source Assessment Report, which should include a more specific source investigation and statistical analysis in accordance with the EFR Plan Section 4, should be submitted to the Director within 90 days after approval of the EFR Plan.

Based on review of the EFR Plan, it appears that the planned activities are appropriate. The EFR Plan is hereby approved. If you have any questions, please call Tom Rushing at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/TR/ka

c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer