DRC-2021-005847 - 0901a06880e760a4

April 23, 2021
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 www.energyfuels.com DfiC-2o21-005047 Dv of Waste Management
and Radiation Control
APR 2 7 2021
Jalynn Knudsen
Interim 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. Howard:
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 tliat accelerated monitoring cease at this time
for Gross Alpha minus Rn and U ("gross alpha") in MW-28 and Total Dissolved Solids ("TDS") in MW-
26 for the reasons stated below:
• MW-28 gross alpha results have been within the Groundwater Compliance Limit ("GWCL")
specified in the GWDP for eight consecutive sampling events since October 2018. Per the
UDEQ, eight consecutive sample results below the GWCL are needed for the discontinuance of
accelerated monitoring.
• MW-26 TDS results have been within the GWCL range specified in the GWDP since November
2020. Per the Plan and Time Schedule submitted for TDS in MW-26, the exceedance of the
GWCL was due to laboratory errors and the data collected during the third quarter 2020 and
October 2020 were erroneous and not reflective of site conditions. Per the UDEQ letter dated
March 15, 2021, if the TDS results in MW-26 for the first quarter 2021 are below the GWCL,
EFRI could submit a request to return TDS sampling frequency to baseline. This letter serves as
the request to return the TDS sampling in MW-26 to baseline frequency.
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.
VIA PDF AND FEDERAL EXPRESS
Letter to Jalynn Knudsen
Removal of Parameters from Accelerated Monitoring
April 23, 2021
Page 2
The analytical laboratory reports for the foregoing results up to and including December 2020 are
included in the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC.
Copies of the analytical laboratory reports and the field sheets for the results for January 2021 through
March 2021 will be provided in the upcoming 1st Quarter 2021 Groundwater Monitoring Report and are
also included with this letter for your convenience. It is important to note that the 1st 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 1st
Quarter data will be included in the 1st Quarter 2021 Groundwater Monitoring Report, due June 1, 2021.
If you have any questions or require any further information, please contact the undersigned.
Yours truly, Odif kt;41.e.e.
Kathy Weinel
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
ei,tattati
Sarnple Result I-
P.R3 - . MW-28 Gross Alpha
(pCi/L)
2.42 Q4 2018* 2.55
Q2 2019 1.94
Q3 2019 1.20
Q4 2019 <1.00
Q1 2020 1.79
Q2 2020 1.69
Q3 2020 1.60
Q4 2020 1.68
Q1 2021 1.81
MW-26 TDS (mg/L) 3284.19 Q3 2020* 3880
Q4 2020* 4860
November 2020 2980
December 2020 3040
Q1 2021 3100
February 2021 2700
March 2021 3060
*Last sample result outside of GWCL limits.
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Company :
Address :
Contact:
Project:
Certificate of Analysis
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
White Mesa Mill GW
Report Date: February 17, 2021
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
MW-28_01152021
532727001
Ground Water
15-JAN-21 10:20
22-JAN-21
Client
Project: DNMI00100
Client ID: DNMI001
'arameter Qualifier Result Uncertainty MDC RL Units PF DF Analyst Date Time Batch Method
Lad Gas Flow Proportional Counting
iFPC, Total Alpha Radium, Liquid "As Received"
iross Radium Alpha 1.81 +/-0.436 0.881 1.00 pCi/L LXB3 02/09/21 0740 2084848 1
Ile following Analytical Methods were performed:
vlethod Description Analyst Comments
EPA 903.0
'airrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
larium Carrier GFPC, Total Alpha Radium, Liquid "As Received" 103 (25%-125%)
iotes:
;ounting Uncertainty is calculated at the 68% confidence level (1-sigma).
;RL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
he greater of either the adjusted MDL or the CRDL.
2olumn headers are defined as follows:
DF: Dilution Factor Lc/LC: Critical Level
DI,: Detection Limit PF: Prep Factor
VIDA: Minimum Detectable Activity RL: Reporting Limit
VIDC: Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 13 of 28 SDG: 532727
ieat ANALYTICAL LABORATORIES
3440 South 700 West
all Lake City, UT 84119
INORGANIC ANALYTICAL REPORT
Client: Energy Fuels Resources, Inc. Contact: Tanner Holliday
Project: 1st Quarter Groundwater 2021 Groundwater
Lab Sample ID: 2101348-012
Client Sample ID: MW-26_01142021
Collection Date: 1/14/2021 810h
Received Date: 1/15/2021 1030h
Analytical Results
Date Date Method Reporting Analytical
Compound Units Prepared Analyzed Used Limit Result Qual
Ammonia (as N) mg/L 1/19/2021 1459h 1/21/2021 1153h E350.1 0.0500 0.427
Bicarbonate (as mg/L 1/18/2021 620h SM2320B 1.00 352
CaCO3)
Carbonate (as CaCO3) mg/L 1/18/2021 620b SM2320B 1.00 < 1.00
Chloride mg/L 1/23/2021 018h E300.0 10.0 57.4
Fluoride mg/L 1/23/2021 811h E300.0 0.200 0.281
Ion Balance % 1/28/2021 1411h Calc. -100 2.68
Nitrate/Nitrite (as N) mg/L 1/18/2021 17111i E353 2 0.100 0.619
Sulfate mg/L 1/23/2021 018h E300.0 50.0 1,830
Total Anions, Measured meq/L 1/28/2021 1411h Calc. 46.7
Total Cations, meq/L 1/28/2021 1411h Calc. 49.3
Measured
Total Dissolved Solids mg/L 1/18/2021 1200h SM2540C 20.0 3,100
Total Dissolved Solids 1/28/2021 141Ih Calc 1.03
Ratio,
Measured/Calculated
Total Dissolved Solids, mg/L 1/28/2021 1411h Cale. 3,000
Calculated
Phone: [phone]
roll Free: [phone]
Fax: [phone]
-mail : awalaav, al- labs. com
veb: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 2/1/2021 Page 33 of 67
MI analyses applicable to the CWA SDWA. aixl RC RA ate per formed in accordance to NELAC protocols Pertinent sampling Infonnation is located on the attached CDC. Confidential Businass information This report is provided for the exchnive use of the addressee Pi is ileges Isubsequent use of the name of this company. or any inembei of its staff or reproduction of this report in connection with the ad, erusement. promouon or sale of any product or process, or an connection with die re-publication of this report . .
r L mrican v ANALYTICAL LABORATORIES
INORGANIC ANALYTICAL REPORT
Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
February Ground Water 2021
2102346-003
MW-26_02102021
2/10/2021 1300h
2/12/2021 1117h
Contact: Tanner Holliday
Analytical Results
3440 South 700 West
;alt Lake City, UT 84119
Date Date Method Reporting Analytical
Units Prepared Analyzed Used Limit Result Qual
mg/L 2/18/2021 1921h E300.0 5.00 71.3
mg/L 2/17/2021 1524h E353.2 0.100 0.764
mg/L 2/15/2021 1325h SM2540C 20.0 2,700
Compound
Chloride
Nitrate/Nitrite (as N)
Total Dissolved Solids
Phone: [phone]
Coll Free: [phone]
Fax: [phone]
[e-mail]
vveb: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 3/25/2021 Page 11 of 29
All anabses applicable to the CWA. SDWA. and RCRA ate performed m accordance to NELAC piotocols Pertinent sampling information is located on the attached COC Confidential Business Infoimatton This report is provided for the exclusive use or the addresses. Privileges ef subsequent use or lite name of this company or any membei of its staff or reproduction of this report in connection with the advertisement. promotion oi sale of am pi mind or process. at in connection \ vith the re-publication of des report . " ' "
ANALYTtCAL LABORAT,,FitES
INORGANIC ANALYTICAL REPORT
Contact: Tanner Holliday Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Energy Fuels Resources, Inc.
March Ground Water 2021
2103310-003
MW-26_03092021
3/9/2021 1400h
3/11/2021 1055h
Analytical Results
3440 South 700 West
;aft Lake City, UT 84119
Method
Used
E300.0
E353.2
SM2540C
Date Date
Units Prepared Analyzed
mg/L 3/17/2021 001h
mg/L 3/13/2021 1202h
mg/L 3/12/2021 1300h
Reporting Analytical
Limit Result Qual Compound
Chloride
Nitrate/Nitrite (as N)
Total Dissolved Solids
5.00 63.9
0.100 0.617
20.0 3,060
Phone: [phone]
foll Free: [phone]
Fax: [phone]
[e-mail]
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 3/25/2021 Page 11 of 28
All analses applicable to the CWA. SDWA. and RCRA are performed in accordance to NELAC plotocols Pertinent sarnphng information is 1000{00 011 the attached coc. Confidential Business Information. This report is provided for the eyeing, e use of the
addressee Prwilersorsubseauens use of the name or this compaiD or any member of its staff, or reproduction of this report in connection irNith the advertisement. promotion Of sale of any product or process, or in connection wills Ilse re-publication of tills report