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DRC-2021-021142 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4284
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Douglas J. Hansen
Director
December 7, 2021
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources (USA) Inc. November 16, 2021, Transmittal of Plan and Time Schedule
Groundwater Discharge Permit No. UGW370004 (Permit)
Dear Ms. Weinel:
The Division of Waste Management and Radiation Control (DWMRC) has reviewed the Energy Fuels
Resources (EFR) November 16, 2021, Transmittal of Plan and Time Schedule under Utah Groundwater
Discharge Permit UGW370004 Part I.G.4(c) White Mesa Mill (EFR Plan). The EFR Plan addresses
exceedances of the Groundwater Compliance Limits (GWCLs) for manganese and sulfate in monitoring
well MW-11. Monitoring Well MW-11 is in out-of-compliance status for manganese and sulfate per the
Permit Part I.G.2. based on 3rd and 4th Quarter 2021 dual consecutive exceedances of the Permit
GWCL’s and is therefore required to undergo corrective action per the Permit Part I.G.4.
The table below summarizes the preliminary findings in the EFR Plan:
Monitoring
Well Parameters EFR Noted Preliminary Findings and Source Assessment
MW-11 Manganese
Sulfate
• EFRI notes that manganese and sulfate concentrations in
MW-11 have been noted as having statistically significant
trends in previous studies (Groundwater Background
Report and the 2008 University of Utah Study).
• EFRI notes that monitoring well MW-11 is directly
downgradient of the Nitrate/Chloride plume and that low
nitrate concentrations and increases in chloride “are
consistent with ongoing (but slow) migration of the
nitrate/chloride plume.
• EFRI notes that concentrations of indicator parameter
fluoride show a decreasing trend and uranium displays a
A Source Assessment Report which will include the EFR Plan discussed source investigation and
statistical analysis, will be submitted to the Director within 90 days after approval of the EFR Plan.
Based on review of the EFR Plan it appears that the planned activities are appropriate, and the EFR Plan
is hereby approved.
If you have any questions, please call Tom Rushing at (801) 536-0080.
Sincerely,
Phil Goble, Uranium Mills and Radioactive Materials Manager
Division of Waste Management and Radiation Control
PRG/TR/wa
c: Grant Sunada, Health Director, San Juan Public Health Department
Ronnie Nieves, Environmental Health Director, San Juan Public Health Department
Russell Seeley, District Engineer, UDEQ
stable trend. EFR additionally notes that although the
indicator parameter sulfate is showing an increasing trend,
the trend was previously identified before the 2008
University of Utah Study. The study subsequently found
that there was no contribution of tailings waste water to the
groundwater sampled at MW-11.
• Per the EFR Plan, the source assessment study for
manganese and sulfate in MW-11 will include an
assessment of the potential sources for each exceedance to
determine whether the exceedance is due to background
influences or Mill activities.