DRC-2021-010465 - 0901a06880efe120

Div of Waste Management
and Radiation Controš
Energy Fuels Rescaes OANZt.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC—.20Z1-01 o 4 65 www.energyfuels.com
July 28, 2021
VIA PDF AND FEDERAL EXPRESS
Doug Hansen
Director
Division of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
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. Hansen:
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 Division of Waste Management
and Radiation Control ("DWMRC") make a determination that accelerated monitoring cease at this time
for Total Dissolved Solids ("TDS") in MW-11 for the reasons stated below:
• MW-11 TDS results have been within the Groundwater Compliance Limit ("GWCL") specified
in the GWDP for nine consecutive sampling events since July 2020. Per the UDEQ, 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.
The analytical laboratory reports for the foregoing results up to and including March 2021 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 2021 through June 2021 will be provided in the
upcoming 2nd Quarter 2021 Groundwater Monitoring Report and are also included with this letter for
your convenience. It is important to note that the 2nd Quarter 2021 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 will be included in the
2nd Quarter 2021 Groundwater Monitoring Report, due September 1, 2021.
Letter to Doug Hansen
Removal of Parameters from Accelerated Monitoring
July 28, 2021
Page 2
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
411 giL/1--te
Kathy einel
Quality Assurance Manager
cc: David Frydenlund
Logan Shumway
Terry Slade
Tanner Holliday
Scott Bakken
Analytical Results and Field Sampling Sheets 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
4`572, of",71,
Sample Result
,,,,,. MW-11 TDS (mg/L) 2528 Q3 2020* 2590
Q4 2020 992
November 2020 2040
December 2020 1990
Q1 2021 2010
February 2021 2160
March 2021 1950
Q2 2021 2110
May 2021 2190
June 2021 1960
*Last sample result outside of GWCL limits.
ANM.YTICAL. LASORATOStES
3440 South 700 West
>alt Lake City, UT 84119
INORGANIC ANALYTICAL REPORT
Client: Energy Fuels Resources, Inc.
Project: 2nd Quarter Ground Water 2021
Lab Sample ID: 2104696-002
Client Sample ID: MW-11_04202021
Contact: Tanner Holliday
Collection Date: 4/20/2021 1135h
Received Date: 4/23/2021 1200h
Analytical Results
Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Ammonia (as N) mg/L 5/5/2021 1348h 5/6/2021 821h E350.1 0.0500 0.647
Bicarbonate (as mg/L 4/27/2021 650h SM2320B 1.00 308
CaCO3)
Carbonate (as CaCO3) mg/L 4/27/2021 650h SM2320B 1.00 < 1.00
Chloride mg/L 5/4/2021 I937h E300.0 10.0 47.7
Fluoride mg/L 5/5/2021 207h E300.0 0.200 0.392
Ion Balance % 5/7/2021 845h Calc. -100 -0.960
Nitrate/Nitrite (as N) mg/L 4/25/2021 1428h E353.2 0.100 0.948
Sulfate mg/L 5/11/2021 949h E300.0 50.0 1,290
Total Anions, Measured meq/L 5/7/2021 845h Calc. 35.1
Total Cations, meq/L 5/7/2021 845h Calc. 34.4
Measured
Total Dissolved Solids mg/L 4/26/2021 1300h SM2540C 20.0 2,110
Total Dissolved Solids 5/7/2021 845h Calc. 0.917
Ratio,
Measured/Calculated
Total Dissolved Solids, mg/L 5/7/2021 845h Calc. 2,300
Calculated
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
[e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 5/13/2021 Page 19 of 59
All analyses applicable to the CWA. SDWA. and RCRA are performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC Confidennal Business Information This report is provided for the exclusive use of the
addressee Pnvileges of subsequent use of the name of this company or any rnember 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 . . . . . — . . . .
INORGANIC ANALYTICAL REPORT
Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
May Ground Water 2021
2105352-001
MW-11_05102021
5/10/2021 1330h
5/13/2021 1200h
Contact: Tanner Holliday
Analytical Results
3440 South 700 West
;alt Lake City, UT 84119
Method
Used
E300 0
E300.0
SM2540C
Date Date
Units Prepared Analyzed
mg/L 5/21/2021 1828h
mg/L 5/21/2021 1534h
mg/L 5/14/2021 1200h
Reporting Analytical
Limit Result Qual Compound
Chloride
Sulfate
Total Dissolved Solids
2.00 46.4
50.0 1,280
20.0 2,190
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
t-mail: [e-mail]
web: www.awal-labs.corn
Jennifer Osborn
Laboratory Director
Jose Rocha
QA Officer
Report Date: 6/3/2021 Page 8 of 27
All analyses applicable to the CWA_ SDWA. and RCRA ere performed in accordance to NELAC motocols Pertinent samplang information Is located on the attached COC. Confidential Busmess Inforrnatton Thas report as movaded for the e‘closia e use of the
addressee Prn lieges of subsequent use of the name of this company or any membei of its staft or reproduction of ties report an connection math the advertisement. promotion or sale of any product or paocess, or in connectlon web the re-publication of this tenon
INORGANIC ANALYTICAL REPORT
Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
June Ground Water 2021
2106299-001
MW-11_06082021
6/8/2021 1230h
6/10/2021 950h
Contact: Tanner Holliday
Analytical Results
3440 South 700 West
>alt Lake City, UT 84119 E300.0
E300.0
SM2540C
Method
Used
Date Date
Units Prepared Analyzed
mg/L 6/17/2021 6I3h
mg/L 6/17/2021 6I3h
mg/L 6/11/2021 1110h
Reporting Analytical
Limit Result Qual Compound
Chloride
Sulfate
Total Dissolved Solids

10.0 52.1

50.0 1,270

20.0 1,960
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
mai l: [e-mail]
web: www.awal-labs.corn
Jennifer Osborn
Laboratory Director
Jose Rocha
QA Officer
Report Date. 6/29/2021 Page 7 of 26
All anal) ses applicable to the CWA. SDWA. and RCRA ale performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC Confidential Business Information, This leport is provided for the eyclusive use of the addressee Privileges of subsequent use of the name of this company or any member of its staff, or reproductton of this report in connection with the advertisement. promotion or sale of am product or process, or in connection with the re-publication of this sepon , . — . , . — .