DRC-2014-002341 - 0901a06880415e81

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
March 19,2014
DRC-2014-002341
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd, Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc. February 12, 2014, Transmittal of 4th Quarter
2013 Groundwater Monitoring Report Groundwater Quality Discharge Permit
UGW370004 White Mesa Uranium Mill: Close out
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has completed review of the following Energy
Fuels Resources (USA) Inc. ("EFR") documents which are required by Utah Ground Water
Quality Discharge Permit No. UGW370004 ("Permit"):
1. EFR February 12, 2014, Transmittal of 4th Quarter 2013 Groundwater Monitoring Report,
Groundwater Quality Discharge Permit UGW3 70004 White Mesa Uranium Mill (received
by DRC on February 14, 2014).
2. EFR February 10, 2014, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I.(a).
The review was conducted with consideration of the following related actions:
1. An October 10, 2012 EFR Source Assessment Report, an April 13, 2012 EFR pH
Report, and a December 12, 2012 EFR Pyrite Investigation Report for previously
documented out-of-compliance parameters (multiple parameters) which were required
per DRC Stipulated Consent Agreement, Docket No. UGW12-03. Per DRC findings,
and as documented in a DRC review memo, dated April 23, 2013 and transmitted via
letter to EFR dated April 25, 2013, it is recommended that; 1. Specific GWCL
parameters for site monitoring wells be modified (12 instances), 2. GWCL's for pH be
modified for all site monitoring wells, and 3. GWCL's be removed from the Permit for
3 monitoring wells up gradient from the site. These requests are currently being
addressed through the permit modification process.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq. utah.gov
Printed on 100% recycled paper
Kathy Weinel
Page 2
2. A May 25, 2012 EFR Permit Modification Request - DRC notified EFR by letter
(dated April 16, 2012) that in order to formalize an April 5, 2010 telephone discussion
between DRC and EFR representatives, allowing a change to accelerated monitoring
requirements, a written request was required for Director review and approval.
Subsequently, EFR submitted a May 25, 2012 written request for the Permit
modification, including redline copies of pertinent pages of the Permit to reflect the
agreements made during the April 5, 2010 conference call. This request is currently
being addressed through permit modification.
Blind Duplicate Comparison — Advisory
Per DRC cross check of the blind duplicate samples collected and analyzed during the 4th Qtr,
2013 (See Appendix 1 for comparisons), all sample results conform to the Permit requirements
(within 20% RPD) with the exception of Gross Alpha in the November 20, 2013 duplicate sample
and Tetrahydrofuran ("THF") in the December 11, 2013 duplicate sample.
The Gross Alpha duplicate sample is not required to conform to the RPD <20% criteria of the
Quality Assurance Plan, but is required to conform to the equation listed in 9.1.4.C Per DRC
calculation, the November 20, 2013 duplicate is in compliance with the Quality Assurance Plan,
with a result of 1.349 (Required to be <2).
DRC noted that the THF Replicate Percent Difference ("RPD") was not calculated in the EFR 4th
Quarter Monitoring Report (Samples MW-03 and MW-70). Per DRC calculation the RPD
calculation result for THF was 27.9 %. Per Part 9.1.4.a. of the Quality Assurance Plan ("QAP")
"RPDs will be calculated in comparisons of duplicate and original field sample results. Non-
conformance will exist when the RPD >20%, unless the measured activities are less than 5 times
the required detection limit (Standard Methods, 1998) T
For purposes of compliance with the EFR QAP, DRC has historically considered the term
"detection limit" to be synonymous with "reporting limit." The sample result for THF in MW-3
was 4.86 u.g/L, and the sample result for duplicate MW-70 was 3.67 jug/L. The reporting limit,
per the American West Laboratory Data Sheet was 1.0 u.g/L. Therefore, the blind duplicate
appears to meet conformance by the result being less than 5 times the reporting limit.
Please ensure that all comparable blind duplicate parameters are compared and included in the
Report. In the case of quality assurance for radiological duplicate samples, please ensure that
comparisons are made per section 9.1.4.c.
Close out
Based on DRC review of the EFR 2013 4th Quarter Groundwater Monitoring Report, it appears
that the requirements of the Permit have been met and that the data results for the quarter appear
to be reliable. DRC review of the Report is hereby closed out.
Kathy Weinel
Page 3
If you have questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Crai^M 7. Jones
Actinff'Director
CWJ:TR:tr
U:\MON_WAST\Trushing\Energy Fuels\Groundwater Reports\2013 Groundwater ReportsUth Quarter 2013\EFR 4th 2013 GW Report DRC
Ltr.docx