DRC-2015-001084 - 0901a068804d896a

TtFfZf's' Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
GARY R. HERBERT Rusty Lundberg
Governor Director
SPENCER J. COX
Lieutenant Governor
January 8, 2015
DRC-2015-001084 Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources, White Mesa Uranium Mill 3r Quarter 2014 Groundwater
Monitoring Report and December 14, 2014 Transmittal of Plan and Time
Schedule: DRC Findings and Closeout
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has completed review of the following Energy
Fuels Resources ("EFR") documents:
1. EFR, November 5, 2014, Transmittal of 3rd Quarter 2014 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, November 14,2014, State of Utah Ground Water Discharge Permit No. UGW3 70004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a).
3. EFR, December 4, 2014, Transmittal of Plan and Time Schedule under Utah ground Water
Discharge Permit UGW370004 Part I.G.4(d) White Mesa Mill.
EFR 3rd Quarter 2014 Groundwater Monitoring Report:
Based on DRC review of the ERFR November 5, 2014 3rd Quarter 2014 Groundwater Monitoring Report,
it appears that all applicable requirements of Utah Groundwater Permit No UGW370004 ("Permit") were
met. Therefore, DRC review of the report is hereby closed out.
EFR November 14, 2014 Notice Pursuant to the Permit Part I.G.I (a):
The EFR November 14,2014 Notice Pursuant to the Permit Part I. G. 1 (a) ("Notice") discusses the status
of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-compliance
("OOC") status, as updated through the 3rd Quarter 2014. DRC notes that the Notice was submitted timely
regarding currently agreed upon schedules.
The Notice summarizes wells/parameters with OOC status which have been resolved by either separate
corrective actions plans or approved modified GWCL's (pending inclusion in the renewal Permit). The
Notice also lists one new monitoring well/parameter (MW-28 Uranium) which went into OOC status
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
during the 3rd Quarter and is subject to requirements of the Permit Part I.G.4(c), which requires an
assessment of the sources of the contamination and potential remedial action to restore compliance. The
assessment for MW-28 was received by DRC, dated December 4, 2014, and is discussed in the section
below.
Based on DRC review of the Notice it appears that all requirements of the Permit were met.
EFR December 4, 2014 Transmittal of Plan and Time Schedule:
The EFR December 4, 2014 Transmittal of Plan and Time Schedule under Utah Ground Water Discharge
Permit ("Plan") documents planned actions regarding monitoring well parameters which went into out-of-
compliance ("OOC") status during the 3rd quarter of 2014 and were subject to the requirements of the
Permit Part I.G.4(c) which requires the Plan to be submitted to DRC within 30 calendar days. Uranium in
monitoring well MW-28 was the only constituent identified in the Plan.
The Plan notes that monitoring well MW-28 was struck by a vehicle during May 2014 which damaged the
monitoring well outer and inner casings. The Plan includes an attached Well Repair Notification for well
MW-28 which was dated July 2, 2014 and was sent to the DRC Director. The Notification documents well
damage, pump retrieval, and well repair activities which occurred at the site. The Plan notes that
monitoring violations at the well may have been caused by debris entering the well due to the damage and
the repair activities. DRC notes that EFR provided overpumping at the well for redevelopment on
June 5,2014.
Per DRC comparison of 2nd Quarter 2014 and 3rd Quarter 2014 Uranium data, it appears that all
concentrations noted as in probable-out-of-compliance status (Cadmium, Uranium, Vanadium) or with
elevated concentrations when compared to background (Manganese) as reported for the 2nd Quarter,
decreased during the 3rd Quarter. Based on these decreases, DRC agrees that the damage was a likely
cause of the exceedances and that some residual material, still present after overpumping acitivities, may
be present in the well. If this is the case then the material will potentially be removed by continued purging
activities during sampling events.
DRC additionally notes that EFR accelerated monitoring (semi-annual to quarterly) for the parameters
exceeding GWCL's at MW-28 during the 2nd Quarter 2014 (Cadmium, Uranium, Vanadium) was initiated
by EFR in compliance with the Permit requirements.
Based on the likely cause of the MW-28 uranium OOC status, EFR proposes that the corrective action will
be to continue accelerated monitoring to determine if the uranium concentrations decrease to below
compliance limits. DRC agrees that this action is sufficient, at this time, to determine if compliance at the
monitoring well will be re-established by continued purging and sampling.
If you have questions regarding this letter please contact Tom Rushing at [phone].
Rusty Lundberg, Director \j
RL:TR:tr
U \MON_WAST\Trushing\Energy Fuels\Groundwater Reports\2014 Groundwater Reports\3rd Quarter 2014 Groundwater ReportAEFR 3rd Qtr
2014 Closeout Ltr docx
Sincerely,