DRC-2019-010438 - 0901a06880b03200

DRC-2019-010438 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
L. Scott Baird Interim Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
September 10, 2019
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228
RE: Energy Fuels Resources, White Mesa Uranium Mill, Groundwater Quality Assurance
Plan Revision 7.6 Utah Groundwater Discharge Permit No. UGW370004 Dear Ms. Weinel:

The Utah Division of Waste Management and Radiation Control (Division) has completed review of the Energy Fuels Resources (USA) Inc. (EFR) May 14, 2019 “Revision of Groundwater Quality Assurance Plan (QAP).” Per review the submittal includes a redline strikeout version and a clean copy of the proposed QAP Revision 7.5.

The following changes from the previously approved version were noted: 1. Headers were revised to list the current QAP version and date. 2. The Table of Contents was updated.
3. Analytical Method SW8260D was added to Table 1 (pp. 22 and 23) for all Volatile Organic
Compounds (Acetone, Benzene, 2-Butanone MEK, Carbon Tetrachloride, Chloroform, Chloromethane, Methylene Chloride, Naphthalene, Tetrahydrofuran, Toluene, and Xylenes). 4. Analytical Method SW8260D was added to the QAP Appendix A, Chloroform Corrective Action Monitoring Quality Assurance Program Laboratory Requirements Table (p. 55), for Carbon Tetrachloride, Chloroform, Dichloromethane and Chloromethane.
(Over)

DWMRC Findings Regarding Analytical Method SW8260D Per DWMRC review of the summary of analytical method SW8260D and comparisons with the summary of Methods 8260 B, C, which are currently approved in the QAP, it was noted that SW8260D differs according to preparation methods to introduce sample (volatile compounds) into capillary
columns for gas chromatograph detection; and introduction of eluted analytes into the mass
spectrometer. The method also specifies methods to be used for identification and quantification of target analytes. In general all three methods are applicable to measurement of volatile organic compounds listed in the QAP. Inclusion of method SW8260D may allow the laboratory to avoid test interferences based on expanded test configurations.

QAP Revision 7.6 Approval Based on DWMRC review, the changes appear to be appropriate and the QAP Revision 7.6 is hereby approved. Please refer to and ensure that the requirements of this plan are followed for future
groundwater sampling activities and reports.
If you have any questions please call Tom Rushing at [phone]. Sincerely,

Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control

PRG/TR/kb 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