DRC-2016-011565 - 0901a068806897c3

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
November 21, 2016
VIA PDF AND FEDERAL EXPRESS
Mr. Scott Anderson
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
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. Anderson:
A number of groundwater monitoring constituents have been placed on accelerated monitoring status
under Part I.G. 1 of the Energy Fuels Resources (USA) Inc. (“EFRI”) Ground Water Discharge Permit No.
UGW370004 (“GWDP”). Part I.G.l 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 uranium in MW-30, vanadium in MW-28, and gross alpha
minus Rn and U (“gross alpha”) in MW-32 for the reasons stated below:
• MW-30 uranium results have been below the Groundwater Compliance Limit (“GWCL”)
specified in the GWDP for eight consecutive sampling events since January 2016. Per the
DWMRC, eight consecutive sample results below the GWCL are needed for the discontinuance
of accelerated monitoring.
• MW-28 vanadium results have been within the GWCL range specified in the GWDP for nine
consecutive sampling events since the Q2 2014 sampling event. Per the DWMRC, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
• MW-32 gross alpha results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Q3 2014 sampling event. Per the DWMRC, 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. 1 of the GWDP, should circumstances warrant.
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.
DRC-ZOIG- 0113^5
^asfe Management
and Radiation Control
NOV 2 5 2M)
Letter to Scott Anderson
Removal of Parameters from Accelerated Monitoring
November 21,2016
Page 2
The analytical laboratory reports for the foregoing results up to and including Q3 2016 are included in the
Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC.
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold Roberts
Logan Shumway
David Turk
Scott Bakken
Analytical Results 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 ID Constituent GWCL Sample Date Sample Result
MW-30 Uranium (ug/L)8.32 January 2016 8.34*
Q1 2016 7.76
March 2016 7.82
April 2016 7.55
02 2016 8.18
June 2016 7.66
July 2016 8.10
03 2016 8.23
September 2016 8.22
MW-28 Vanadium
(ug/L)
30 Q22014*109
Q3 2014 18.5
Q4 2014 29.3
Q1 2015 <15.0
Q2 2015 <15.0
Q3 2015 <15.0
Q4 2015 <15.0
Q1 2016 <15.0
Q2 2016 <15.0
Q3 2016 <15.0
MW-32 Gross Alpha
(pCi/L)
3.33 Q3 2014*3.69
Q4 2014 2.56
Q1 2015 2.19
Q2 2015 1.81
Q3 2015 1.89
Q4 2015 2.19
Q1 2016 2.17
Q2 2016 2.18
Q3 2016 2.56
*Last sample result outside of GWCL limits.