DRC-2021-007902 - 0901a06880eb0b9e

DRC-2021-007902 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberley D. Shelley Executive Director
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director June 9, 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. May 11, 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) May 11, 2021, Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part I.G.4(c) White Mesa Mill (EFR Plan). The EFR Plan addresses exceedances of the Ground Water Compliance Limit (GWCL) for uranium in monitoring well MW-29. Monitoring Well MW-29 is in out-of-compliance status for uranium per the Permit Part I.G.2. based on 4th Quarter 2020 and 1st 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 following table summarizes the preliminary findings in the EFR Plan:
Monitoring Well Parameters EFR Noted Preliminary Findings and Source Assessment
MW-29 Uranium
• EFRI notes that uranium concentrations in MW-29 exhibit a statistically significant upward trend first identified during the 2012 pH Report.
• EFRI preliminary analysis of pH and the indicator
parameters shows that pH and chloride are stable and fluoride and sulfate in MW-29 are exhibiting downward trends.
• EFRI notes that water levels in MW-29 have increased
since 2006 and attributes the increases to perched water mounding associated with the northern wildlife ponds.

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 [phone]. Sincerely,
Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control
PRG/TR/as c: Mike Moulton, Interim Health Officer, San Juan County Public Health Department
Ronnie Nieves, Environmental Health Director, San Juan County Public Health Department Russell Seeley, UDEQ District Engineer

• The EFR Plan notes that if the increasing water levels in MW-29 were caused by leakage from the tailings management system then conservative constituents such as
chloride would be orders of magnitude larger than
measured.
• Per the EFR Plan, a source assessment study for uranium in MW-29 will include: 1. A determination of whether there is any new information that would suggest that the previous
analysis conducted in the New Wells Background Report, pH Report and Pyrite Report has changed; 2. Based on preliminary analysis of pH and the indicator parameters which show stable or decreasing trends, EFRI will continue
to conduct accelerated monitoring for uranium in MW-29
while preparing and submitting a geochemical analysis of uranium and indicator parameters and, if appropriate, a proposed revised uranium GWCL using the expanded data set available at the time of the analysis. Per the EFR Plan, the statistical evaluation will follow appropriate guidance
and the Director approved statistical flow chart for the White Mesa Uranium Mill.