DRC-2018-008207 - 0901a06880899814

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
August 3, 2018
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
AUG - 6 2018 P-Pz-2ne-ooe207
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.1 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 sulfate in MW-11 for the reasons stated below:
• MW-11 sulfate results have been within the GWCL range specified in the GWDP for eight
consecutive sampling events since the Q3 2017 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 March 2018 are included in
the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC. Copies of
the analytical laboratory reports for the results for April 2018 through June 2018 are provided in the 2nd
Quarter 2018 Groundwater Monitoring Report and are also included with this letter for your convenience.
It is important to note that the 2nd Quarter 2018 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 2nd Quarter data are included in the 2nd Quarter 2018
Groundwater Monitoring Report, which will be submitted to DWMRC on or before September 1, 2018.
Letter to Scott Anderson
Removal of Parameters from Accelerated Monitoring
August 3, 2018
Page 2
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
ceeL4f7&( 24
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Paul Goranson
Logan Shumway
Terry Slade
Garrin Palmer
Tanner Holliday
Scott Bakken
Analytical Results for the Wells that are the Subject of this Request
Table 1
Summary of Accelerated Sam le Results with Ei ht or More Results in Com liance
Well ID Constituent GWCL Sample Date Sample Result
MW-11 Sulfate 1309
(mg/L)
Q3 2017* 1560
Q4 2017 1060
December 2017 1130
January 2018 561
Q1 2018 1120
March 2018 1180
Q2 2018 1110
May 2018 1140
June 2018 1060
*Last sample result outside of GWCL limits.
kmencan Wes VALVTICAL l•SORATONIIIIP
INORGANIC ANALYTICAL REPORT
Contact: Garrin Palmer Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
May Groundwater 2018
1805422-001
MW-11_05152018
5/15/2018 1040h
5/17/2018 1030h
Analytical Results
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
Lake City, UT 84119 Sulfate mg/L 5/18/2018 2030h E300.0 150 1,140
'hone: [phone]
Free: [phone]
Fax: [phone]
[e-mail]
): www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 5/25/2018 Page 9 of 29
aalyses apphcable to the CWA. SDWA. and RCRA are performed in accordance to NELAC protocols Pertinau sampling information is located on the attached COC Confidential Business Information: This report is provided for the exclusise use of the Isee Pm lieges of subsequent use of the name of tlus company or any member of its staff or reproduction of this report in connection with the advertisement. promotion or sale of any product or process, or in connection with the re-publication of this report ' '
1merican West 4111,YTICAL
INORGANIC ANALYTICAL REPORT
Contact: Garrin Palmer Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
June Ground Water 2018
1806444-001
MW-11_06192018
6/19/2018 1030h
6/20/2018 1025h
Analytical Results
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
Lake City, UT 84119 Sulfate mg/L 6/28/2018 1322h E300.0 150 1,060
'hone: [phone]
Free: [phone]
Fax: [phone]
[e-mail]
: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 7/5/2018 Page 9 of 30
ses applicable to the CWA. SDWA. and RCRA are performed in accordance to NELAC protocols Pertinent sampltng information is located on the attached COC Confidential Business Information This teport is provided for the exclusive we of the
see Pni lieges of subsequent use of the name of this company or any member of Its stafT or reproduction of this report in connection with the advertisement. promotion or sale of any product or process. or in connection with the re-publication of this report . .
kmerican West MALYTICAL LABORATORIES
INORGANIC ANALYTICAL REPORT
Contact: Garrin Palmer Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
2nd Quarter Groundwater 2018
1804461-001
MW-11_04182018
4/18/2018 1210h
4/20/2018 1030h
3440 South 700 West
Lake City, UT 84119
Analytical Results
Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Ammonia (as N) mg/L 4/24/2018 1220h 4/24/2018 1435h E350.1 0.0500 0.683
Bicarbonate (as mg/L 4/30/2018 612h SM2320B 1.00 306
CaCO3)
Carbonate (as CaCO3) mg/L 4/30/2018 612h SM2320B 1.00 < 1.00
Chloride mg/L 4/26/2018 1324h E300.0 1.00 34.0
Fluoride mg/L 4/26/2018 1414h E300.0 0.100 0.465
Ion Balance % 5/2/2018 1158h Cale. -100 1.48
Nitrate/Nitrite (as N) mg/L 4/27/2018 1101h E353.2 0.100 < 0.100
Sulfate mg/L 4/26/2018 909h E300.0 150 1,110
Total Anions, Measured meq/L 5/2/2018 1158h Cale. 30.1
Total Cations, meq/L 5/2/2018 1158h Calc. 31.0
Measured
Total Dissolved Solids mg/L 4/23/2018 1325h SM2540C 20.0 1,980
Total Dissolved Solids 5/2/2018 1158h Cale. 0.990
Ratio,
Measured/Calculated
Total Dissolved Solids, mg/L 5/2/2018 1158h Calc 2,000
Calculated
'hone: [phone]
1Free: [phone]
Fax: [phone]
[e-mail]
): www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 5/11/2018 Page 15 of 55
al) ses applicable to the CWA. SDWA. and RCRA are performed in accordance to NELAC protocols Pertinent sampling information is located on the attached CDC Confidentud Business Information This report is provided for the =haw e use of the
ssee Pm-lieges of subsequent use of the name of Mrs company or am member of Its staff. or reproduction of this report in connection with the alvertisement. promotion or sale of any product or process, or in cormection with the re-publicatton of tins report " . . . .