DRC-2020-019842 - 0901a06880daaa0b

Energy Fuels Resources (USA) inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.coni
NERGY FUELS
2.020 -01 9b42.
December 9, 2020
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Ty L. Howard
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Div of Waste Management
and Radiation Control
DEC 1 4 2020
Re: Background Report for Monitoring Wells MW-38, MW-39, and MW-40
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill
Dear Mr. Howard:
Section I.H.2 of the Groundwater Discharge Permit ("GWDP") required the installation of three new
monitoring wells (MW-38, MW-39, and MW-40). As required by the GWDP, the wells were installed
in February 2018. Section I.H.3 requires that within 30 days of the Director approval of the As-Built
Report, Energy Fuels Resources (USA) Inc. ("EFRI") shall commence quarterly sampling. The As-
Built report was approved by letter dated October 2018. Section I.H.3.c) of the GWDP requires the
submission of a Background Report for MW-38, MW-39, and MW-40 after the completion of eight
consecutive quarters of sampling and analysis. The wells were sampled consecutively beginning the
fourth quarter 2018. The eighth consecutive quarter of data was collected in the third quarter 2020.
Please note that an additional non-consecutive quarter of data were collected prior to submission and
approval of the As-Built Report. Those data will be included in the Background Report for these wells
and have been included in the assessment of the number of statistically valid data points discussed
below.
As noted above, these wells have been sampled quarterly since fourth quarter 2018. The GWDP
requires the completion of a Background Report after the collection of eight consecutive quarters of
data. In August 2020, analysis of the data, after eight consecutive quarters, and a total of nine data
points, indicated that additional data were required to meet the statistical requirements of the
flowsheet. Specifically, eight statistically valid points (as required by the flowsheet) were not available
for Gross Alpha (minus Rn and U) ("Gross Alpha") and manganese in MW-39 and chloride in MW-
40. As a result of the insufficient number of valid data points, an extension to the due date was
requested and granted.
Analysis of the data after the fourth quarter 2020 sampling event indicates that at least eight valid data
points are now available for all constituents. However, due to the inefficiency of teleworking and the
concurrent data review and data management associated with the Low Flow Sampling Program, which
was conducted in the fourth quarter 2020, EFRI would like to request a 60 day extension to the due
...
Letter to Ty L. Howard
December 9, 2020
Page 2 of 2
date for the Background Report. The Background Report is due January 8, 2021 and EFRI is
respectfully requesting the due date be revised to March 9, 2021.
If you should have any questions regarding this letter, please contact me.
Yours very truly,
z)}ad,i ,)e
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David Frydenlund
Scott Bakken
Logan Shumway
Terry Slade
Garrin Palmer
Tanner Holliday