DRC-2020-017448 - 0901a06880d5e47c

DRC-2020-017448 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
Printed on 100% recycled paper
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
October 28, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: Energy Fuels Resources, White Mesa Uranium Mill August 17, 2020, 2nd Quarter 2020 Groundwater Monitoring Report, and July 13, 2020 Notice Pursuant to Part I.G.1(a). Utah Groundwater Discharge Permit No. UGW370004 Dear Ms. Weinel:
The Division of Waste Management and Radiation Control (DWMRC) has completed review of the
following Energy Fuels Resources (USA) Inc. (EFR) documents: 1. EFR, August 17, 2020, Transmittal of 2nd Quarter 2020 Groundwater Monitoring Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill (Received by DWMRC on August 20, 2020).
2. EFR, July 13, 2020, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill – Notice Pursuant to Part I.G.1(a) (Received by DWMRC on July 15, 2020).
The review was conducted to ensure compliance with all applicable parts of Utah Groundwater
Discharge Permit No. UGW370004 (Permit) issued for the White Mesa Uranium Mill located in Blanding, Utah. EFR 2nd Quarter 2020 Groundwater Monitoring Report Close-out:
Based on review of the EFR August 17, 2020 2nd Quarter 2020 Groundwater Monitoring Report, it appears that all applicable requirements of the Permit were met. Therefore, the review is hereby closed out. (Over)

Monitoring Wells MW-24 and MW-24A, Evaluation of Groundwater Monitoring Data:
Per DWMRC review of the 1st and 2nd Quarter 2020 Monitoring Data at MW-24A it was noted that the
same monitoring constituents showed elevated concentrations as observed in MW-24 groundwater data. DWMRC review of the 1st Quarter 2020 MW-24/MW-24A groundwater monitoring results noted that MW-24A results show the same data constituent exceedances and trends as MW-24. The 2nd Quarter 2020 results further confirm that the monitoring results at MW-24 were not caused by well construction problems, as was suspected by EFR, since the same data pattern of constituent exceedances and high
concentrations is evident and continuing. Based on review of the 2nd Quarter Report it is appropriate to collect additional MW-24/MW-24A tandem samples for comparison and better evaluation of indicator parameters and heavy metals:
1. Additional quarterly pH, sulfate, and chloride data points at MW-24/MW-24A to provide more
information of concentrations and trends. Two additional quarterly samples will provide an additional full year including potential seasonal variation. 2. Additional data for other heavy metals (beryllium, cadmium, manganese, nickel and thallium) to evaluate the degree (steepness of curve) of upward concentration trends.
Based on current groundwater monitoring data and trends it may be appropriate for EFR to consider additional information and data points (e.g. new monitoring wells) to evaluate the observed concentrations in MW-24 and MW-24A. It is noted that groundwater concentrations of nearby and downgradient monitoring well MW-02 are not currently indicating the same exceedances or trends.
However, additional data at point(s) downgradient and near MW-24/MW-24A would be useful to better
evaluate the exceedances. Based on DWMRC review of the 2nd Quarter Report it is appropriate for EFR to collect at least two additional quarterly samples to better understand the need for additional data to evaluate the exceedances.
EFR Notice Pursuant to Part I.G.1(a) – Close-out: Based on review of the EFR July 13, 2020 Notice it appears that all requirements of the Permit were
met. Therefore, the review is hereby closed out.
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: Kirk Benge, Health Officer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department Russell Seeley, DEQ District Engineer