DRC-2015-002396 - 0901a06880529ea1

ENERGYFUELS t- I v
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
May 7, 2015
VIA PDF AND FEDERAL EXPRESS
DRC-2015-002396
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
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. Lundberg:
A number of groundwater monitoring constituents have been placed on accelerated monitoring status
under Part I.G.I of the Energy Fuels Resources (USA) Inc. ("EFRI") Ground Water Discharge Permit No.
UGW370004 ("GWDP"). Part I.G.I 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 tetrahydrofuran ("THF") in MW-01 and field pH in MW-23
for the reasons stated below:
• MW-01 THF results have been below the Groundwater Compliance Limit ("GWCL") specified
in the GWDP for eight consecutive sampling events since Ql 2013. Per the UDEQ, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
• MW-23 field pH results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Ql 2013 sampling event. Per the UDEQ, 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.I of the GWDP, should circumstances warrant.
Field pH measurements will continue to be recorded for all samples collected, including any accelerated
monitoring completed for other constituents as required. Upon DRC approval of this request, field pH
measurements will no longer be tracked and reported as part of the quarterly Exceedance Notice, but will
return to the routine reporting in the Quarterly Groundwater Monitoring Reports.
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.
Letter to Rusty Lundberg
Removal of Parameters from Accelerated Monitoring
May 7, 2015
Page 2
The analytical laboratory reports for the foregoing results up to and including December 2014 are
included in the Quarterly Groundwater Monitoring Reports, all of which have been provided to DRC.
Copies of the analytical laboratory reports and the field sheets for the results for January 2015 through
March 2015 will be provided in the upcoming 1st Quarter 2015 Groundwater Monitoring Report and are
also included with this letter for your convenience. It is important to note that the 1st Quarter 2015
monitoring results included with this letter have been evaluated per the DRC approved QAP and the
GWDP and all field and laboratory quality control parameters are acceptable. The evaluations of the 1st
Quarter data will be included in the 1st Quarter 2015 Groundwater Monitoring Report, due June 1, 2015.
If you have any questions or require any further information, please contact the undersigned.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold Roberts
Dan Hillsten
David Turk
Scott Bakken
Yours truly,
Analytical Results and Field Sampling Sheets for the Wells that are the Subject of
this Request
Table 1
Summary of Accelerated Sample Results with Eight or More Results in Compliance
Well LD Constituent GWCL Sample Date Sample Result
MW-01 Tetrahydrofuran
(ug/L)
11.5 Ql 2013*
Q22013
Q32013
Q4 2013
Ql 2014
Q2 2014
Q3 2014
Q4 2014
Ql 2015
12.6
3.26
1.86
5.51
3.25
3.39
< 1.0
< 1.0
1.63
MW-23 Field pH (S.U.) 6.50-8.5 Ql 2013*
Q22013
Q32013
Q4 2013
Ql 2014
Q2 2014
Q3 2014
Q4 2014
Ql 2015
6.37
7.23
6.61
7.21
6.52
6.67
6.56
6.69
6.53
*Last sample result outside of GWCL limits.
ORGANIC ANALYTICAL REPORT
Client:
Project:
Lab Sample ID:
Energy Fuels Resources, Inc.
1st Quarter Groundwater 2015
1502236-001C
Contact: Garrin Palmer
• . -, i""* Client Sample ID: MW-01 02102015
American West „ ~ MtATORtCS
3440 South 700 West
Salt Lake City. UT 84119
Phone:[phone]
Toll Free: [phone]
Fax: [phone]
e-mail: [e-mail]
Collection Date:
Received Date:
Analytical Results
2/10/2015
2/13/2015
1330h
930h Test Code: 8260-W-DEN100
VOAs by GC/MS Method 8260C/5030C
Analyzed: 2/13/2015 1441h
Units: ug/L Dilution Factor: Method: SW8260C
Compound
CAS
Number
Reporting
Limit
Analytical
Result Qual
Tetrahydrofuran 109-99-9 .00 1.63
Surrogate CAS Result Amount Spiked % REC Limits Qual
SUIT: l,2-Dichloroethane-d4
Surr: 4-Bromofluorobenzene
Surr: Dibromofluoromethane
Surr: Toluene-d8
17060-07-0
460-00-4
1868-53-7
2037-26-5
56.6
51.5
53.4
48.9
50.00
50.00
50.00
50.00
113
103
107
97.8
72-151
80-128
80-124
77-129
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 2/27/2015 Page 19 of 32
All analyses applicable lo the CWA, SDWA. and RCRA arc performed in accordance lo 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 an\ member of its SUIT, or reproduction of this report in connection with the advertisement, promotion or sale of at!) product or process, or in connection with the re-publication of this report
for any purpose oilier 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 m good faith and according lo the rules of the trade and of science.
Mill - Groundwater Discharge Permit
Groundwater Monitoring Quality Assurance Plan (QAP)
Description of Sampling Event:
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
Date: 06-06-12 Rev. 7.2 - Errata
t See instruction
Location (well name): M^J- Z.3
Field Sample ID
Sampler Name .
and initials: \~1+nncr H<>]\ A+^/TH
rAvj-Z2>_o-Z\oz.O]S
Date and Time for Purging
Well Purging Equip Used: D3 pump or | • | bailer
Purging Method Used: Dj 2 casings | • |3 casings
Sampling Event Q^rxr^o^M
pH Buffer 7.0 1.0
and Sampling (if different)
Well Pump (if other than Bennet)
Prev. Well Sampled in Sampling Event
pH Buffer 4.0
AM-36
Specific Conductance uMHOS/ cm Well Depth(0.0lft): \32.QQ
Depth to Water Before Purging rRTTT Casing Volume (V) 4" Well:
3" Well:
: 1.6-7 (.653h)
(.367h)
Weather Cond.
Time Gal. Purged
554
Conductance 32 65 pH
Temp. °C 17. 03
Redox Potential Eh (mV) | 23*1
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged
PH
Redox Potential Eh (mV)
Turbidity (NTU)
Ext'l Amb. Temp. °C (prior sampling event) 15
Time 15SS Gal. Purged | -z<-j
Conductance
Temp. °C
pH | 4.53
H.Q3
Redox Potential Eh (mV) | -z.5D
Turbidity (NTU) | p
Time
Conductance
Temp. °C
Gal. Purged
pH
Redox Potential Eh (mV)
Turbidity (NTU)
White Mesa Mill
Field Data Worksheet for Groundwater 1 of 2
Mill'- Groundwater Discharge Permit
Groundwater Monitoring Quality Assurance Plan (QAP)
Date: 06-06-12 Rev. 7.2 - Errata
Volume of Water Purged Z.1-) gallon(s)
Pumping Rate Calculation
Flow Rate (Q), in gpm.
s/60= I ~&=r-.\Hii \ .m
Time to evacuate two casing volumes (2V)
T = 2V/Q =
Number of casing volumes evacuated (if other than two)
If well evacuated to dryness, number of gallons evacuated
Name of Certified Analytical Laboratory if Other Than Energy Labs /J/h
Type of Sample Sample Taken
Y N
Sample Vol (indicate
if other than as
specified below)
Filtered
N
Preservative Type Preservative Added
Y N
VOCs • 3x40 ml • • HCL
Nutrients 100 ml • • H2S04 • •
Heavy Metals • 250 ml • HN03 • •
All Other Non Radiologics • 250 ml • No Preserv. •
Gross Alpha • 1,000 ml • HN03 • •
Other (specify) • • Sample volume • • •
If preservative is used, specify
Type and Quantity of Preservative:
Final Depth YL~1. )*?-Sample Time
Comment a See instruction
MW-23 02-10-2015 Do not touch this cell (SheetName)
White Mesa Mill
Field Data Worksheet for Groundwater 2 of 2