DRC-2017-009162 - 0901a0688077f8a2

tm ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
November 15, 2017
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
Div of Waste Management
and Radiation Control
mum
.DRC-2017-00^162-
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.l 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 selenium in MW-15, nitrate in MW-19, and sulfate in MW-
29, for the reasons stated below:
• MW-15 selenium results have been below the Groundwater Compliance Limit (“GWCL”)
specified in the GWDP for nine consecutive sampling events since the Q2 2015 sampling event.
Per the DWMRC, eight consecutive sample results below the GWCL are needed for the
discontinuance of accelerated monitoring.
• MW-19 nitrate results have been within the GWCL range specified in the GWDP for nine
consecutive sampling events since the Q2 2015 sampling event. Per the DWMRC, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
• MW-29 sulfate results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Q2 2015 sampling event. Per the DWMRC, eight
consecutive sample results below the GWCL are needed for the discontinuance of accelerated
monitoring.
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.
The analytical laboratory reports for the foregoing results up to and including June 2017 are included in
the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC. Copies of
Letter to Scott Anderson
Removal of Parameters from Accelerated Monitoring
November 15, 2017
Page 2
the analytical laboratory reports for the results for July 2017 through September 2017 are provided in the
3rd Quarter 2017 Groundwater Monitoring Report and are also included with this letter for your
convenience. It is important to note that the 3rd Quarter 2017 monitoring results included with this letter
have been evaluated per the DWMRC approved QAP and the GWDP and all field and laboratory quality
control parameters are acceptable. The evaluations of the 3rd Quarter data are included in the 3rd Quarter
2017 Groundwater Monitoring Report, which will be submitted to DWMRC on or before December 1,
If you have any questions or require any further information, please contact the undersigned.
Quality Assurance Manager
cc: David C. Frydenlund
Mark Chalmers
Paul Goran son
Logan Shumway
David Turk
Scott Bakken
2017.
Yours truly
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-15 Selenium
(mg/L)
128.7 Q22015*137
03 2015 104
Q4 2015 107
Q1 2016 123
Q2 2016 126
03 2016 110
Q4 2016 112
Q1 2017 112
Q2 2017 111
Q3 2017 105
MW-19 Nitrate (mg/L)2.83 02 2015*3.58
Q3 2015 2.82
Q4 2015 2.23
Q1 2016 2.44
Q2 2016 2.63
Q3 2016 2.62
Q4 2016 2.68
Q1 2017 2.77
Q2 2017 2.61
Q3 2017 2.45
MW-29 Sulfate (mg/L)2946 02 2015*2960
Q3 2015 Not sampled
Q4 2015 2740
01 2016 2710
02 2016 2730
03 2016 2750
Q4 2016 2290
Q1 2017 2670
Q2 2017 2490
Q3 2017 2780
*Last sample result outside of GWCL limits.
INORGANIC ANALYTICAL REPORT
American WestANALYTICAL LABORATORIES
Client: Energy Fuels Resources, Inc.
Project: 3rd Quarter Ground Water 2017
Lab Sample ID: 1708449-003
Client Sample ID: MW-15 08112017
Collection Date: 8/11/2017 1045h
Received Date: 8/18/2017 1215h
Contact: Garrin Palmer
Analytical Results DISSOLVED METALS
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
salt Lake City, UT 84119 Selenium mg/L 8/22/2017 1150H 8/23/2017 13261i E200.8 0.00500 0.105
Phone: [phone]
Toll Free: [phone]
Fax:[phone]
;-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 9/5/2017 Page 9 of 61
All analyses applicable to ihe CWA SDWA and RCRA are perlormed m accordance to NELAC protocols Pertinent sampling information is located on the attached COC Confidential Business Infoimalion This lepon is provided for the exclusive iBeof Ihe
addressee Privileges of subsequent use of the name of this companv or am membei of its slalT. or reproduction ofthis report in connection vnih the advertisement promotion oi sale of am product or piocess, or in connection with the re-publicaiionof this report
INORGANIC ANALYTICAL REPORT
American WestANALYTICAL LABORATORIES
Client: Energy Fuels Resources, Inc.
Project: 3rd Quarter Ground Water 2017
Lab Sample ID: 1708326-004
Client Sample ID: MW-19_08092017
Collection Date: 8/9/2017 1540h
Received Date: 8/11/2017 1652h
Contact: Garrin Palmer
Analytical Results
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qua!
salt Lake City', UT 84119 Nitrate/Nitrite (as N)mg/L 8/16/2017 1718h E353.2 0.100 2.45
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
3-mail: [e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date. 8/25/2017 Page 8 of 18
All analyses applicable lo the CWA. SOW A and RCRA are performed in accordance io NELAC protocols Penmeni sampling mlbrmauon is located on die aliached COC Confidential Business Information This report is proMded for the exclusive toe of the
addressee Pn\ileges of subsequent use of ihe name of this company or any membei of ns staff or reproducnon of this repon in connection with the advertisement promotion or sale of am product or process or in connection with rhe re-nuhliraiinn ctf ihi< r-imn
INORGANIC ANALYTICAL REPORT
ANALYTICAL LABORATORIES
Client: Energy Fuels Resources, Inc.
Project: 3rd Quarter Ground Water 2017
Lab Sample ID: 1708449-005
Client Sample ID: MW-29 08152017
Collection Date: 8/15/2017 950h
Received Date: 8/18/2017 1215h
Contact: Garrin Palmer
Analytical Results
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qua!
Salt Lake City, UT 84119 Sulfate mg/L 8/21/2017 1342h E300 0 375 2,780
Total Dissolved Solids mg/L 8/18/2017 1455b SM2540C 20.0 3,960
Phone:[phone]
Toll Free: [phone]
Fax: [phone]
:-mail: a\val@a\va!-labs.com
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date 9/5/2017 Page 23 of 61
All anaKses applicable io iheCWA. SDWA. and RCRA are performed in accordance lo NELAC protocols Pertmem sampling inforimtion is located on the attached COC Confidential Business Information This report is provided for the exclusive ice of the
addressee Privileges of subsequent use of the name of this company or am member of its staff or reproduction of this report m connection with the advertisement promouon oi sale of am product or process, or in connection with there-publicaiionorihis reoon