DRC-2020-015924 - 0901a06880d345a9

DRC-2020-015924 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
GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor
Department of Environmental Quality
L. Scott Baird Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
September 28, 2020
Kathy Weinel, Quality Assurance Manager CERTIFIED MAIL Energy Fuels Resources (USA), Inc. 7005 0390 0000 7508 7146
225 Union Blvd., Suite 600
Lakewood, CO 80228 RE: White Mesa Uranium Mill - Notice of Violation and Corrective Action Order UDEQ Docket No. UGW-20-01 Notice Pursuant to the Chloroform Pumping Well Operations and Maintenance Plan. Chloroform Contamination Investigation.
Abandonment and Hydrogeologic Investigation for Pumping Well TW4-20. Confirmatory Action Letter Dear Ms. Weinel:

In a letter dated August 5, 2020 from Energy Fuels Resources (USA), Inc. (“EFRI”) provided the Division of Waste Management and Radiation Control (“DWMRC “) written Notice concerning the pumping failure at pumping well TW4-20. The Notice also described EFRI efforts in removing the pump from TW4-20 using a drilling contractor only to discover that both silica sand and PVC material were present, indicating that the well had collapsed and no longer could be used as a pumping or
monitoring well. Based on these findings, in the Notice EFRI proposed to: “…to abandon TW4-20 in
accordance with the Utah Division of Water Rights regulations, using a Utah licensed drilling contractor. In addition, EFRI will assess if any impacts resulting from the abandonment of TW4-20 are evident in the next scheduled chloroform Corrective Action Comprehensive Monitoring Evaluation
("CACME"), due on or before March 31, 2022. If adverse impacts are noted due to the abandonment of
TW4-20, EFRI will propose actions to mitigate the situation.”
During a DWMRC and EFRI conference call on September 21, 2020, DWMRC accepted the EFRI proposal regarding TW4-20 on the following conditions:
1. Within 30 calendar days of receiving this letter, EFRI will provide a schedule when well TW4-20 will be abandoned. The abandonment will be completed in accordance with the Utah Division of Water Rights regulations, using a Utah licensed drilling contractor.
(Over)

2. A New hydrogeologic investigation to determine the overall effect on the chloroform
remediation strategy with the loss of pumping well TW4-20. If the hydrogeologic investigation determines that the loss of pumping well TW4-20 does not meet the same overall effectiveness (i.e. chloroform removed) of the chloroform remediation strategy, then ERFI will propose a strategic location for a new pumping well that will compensate for the loss of well TW4-20. This hydrogeologic investigation shall be included with the next Chloroform Corrective Action
Comprehensive Monitoring Evaluation ("CACME"), due on or before March 31, 2022. The hydrogeologic investigation shall include but not be limited to:
• Interpretation and evaluation of analytical data, pumping data, and groundwater level
data from pumping wells TW4-19, TW4-37, TW4-39 collected during the 3rd quarter 2020 to the 4th quarter 2021 chloroform monitoring events (6 quarterly chloroform monitoring events).
• Interpretation and evaluation of, groundwater levels, gradients, flow directions, and well hydraulic properties.
• Groundwater contour and chloroform isoconcentration map(s) showing hydraulic capture zones.
• If necessary, proposed location for a new pumping well to replace pumping well TW4-
20.
Please respond in writing within three calendar days of receiving this letter if you have concerns with the above actions and compliance schedule.
Thank you for your cooperation. Please contact Dean Henderson at 801-536-0046 with any questions. Sincerely,

Ty L. Howard, Director Division of Waste Management and Radiation Control TLH/DCH/as
c: Kirk Benge, Health Officer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department Russell Seeley, UDEQ District Engineer