DRC-2021-003202 - 0901a06880e29464

DRC-2021-003202 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
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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 Ty L. Howard Director

March 15, 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. January 25, 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) January 25, 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 total dissolved solids (TDS) in monitoring well MW-26. Monitoring well MW-26 is in out-of-compliance status for TDS per the Permit Part I.G.2. based on 3rd and 4th Quarter 2020 dual exceedances of the Permit GWCL 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-26 TDS
• The 4th Qtr. 2020 TDS exceedance (and probably the 3rd
Qtr. 2020 exceedance) in MW-26 are suspected to be due to problems with TDS sample analysis at American West Analytical Laboratory (AWAL). The EFR Plan discusses issues with AWAL regarding the sample validation and
reporting. AWAL did not discover that the 4th Qtr. TDS
result was inconsistent with historical results in a timely manner and was unable to reanalyze the TDS sample within holding time. The Plan and Time Schedule notes that the calculated TDS and measured TDS were outside of AWAL data review requirements and should have been
flagged for reanalysis sooner. Per the EFR Plan these same

Per review of the EFR Plan it appears to be reasonable that the reported exceedances were likely the result of laboratory error. Per follow up with EFR the Division notes that the MW-26 TDS samples for January and February 2021 were below the GWCL and consistent with historical concentrations.
To be consistent with past actions to return out-of-compliance monitoring wells/parameters to baseline
monitoring frequency, if the three accelerated sample results for TDS during the 1st Qtr. 2021 are below
the GWCL, a separate request (in addition to discussion of findings in the 1st Quarter 2021 Groundwater Report) to return to baseline will need to be made by EFR letter to the Director for review and approval. Based on review of the EFR Plan it appears that the planned activities are appropriate, with the addition
of EFR providing a letter request to return to baseline monitoring if the 1st Quarter 2021 sample results meet criteria, 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 Director, San Juan County Public Health Department Russell Seeley, UDEQ District Engineer
issues should have been evident to AWAL for the 3rd Quarter TDS sample.
• Based on the TDS exceedances being the result of laboratory error, the EFR Plan proposes to continue
accelerated monitoring during the 1st Quarter 2021 and discuss findings in the quarterly groundwater monitoring report. Per the Plan and Time Schedule, if the sample results are below the GWCL during the 1st Quarter then EFR will discuss the results in the report and take no
further action.