DRC-2020-015183 - 0901a06880d24276

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
ENERGY FUELS
Div of Waste Management
August 27, 2020 and Radiation Control
Sent VIA E-MAIL AND EXPEDITED DELIVERY AUG 3 1 2020
Mr. Ty L. Howard
W -2020-01503
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
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 quarters of data. Analysis
of the data, after eight consecutive quarters, and a total of nine data points, indicate that additional data
are required to meet the statistical requirements of the flowsheet. Specifically, eight statistically valid
points (as required by the flowsheet) are not available for Gross Alpha (minus Rn and U) ("Gross
Alpha") and manganese in MW-39 and chloride in MW-40.
' LedEr to Ty L. Howard
August 27, 2020
Page 2 of 2
EFRI would like to request an extension of 90 days on the due date for the Background Report to
accommodate the collection of an additional quarterly sample for MW-38, MW-39 and MW-40 during
the fourth quarter 2020. The revised due date would be January 8, 2021.
If you should have any questions regarding this letter, please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David Frydenlund
Scott Bakken
Logan Shumway
Terry Slade
Garrin Palmer
Tanner Holliday
2
8/27/2020 State of Utah Mail - Fwd: Background Report for MW-38, MW-39 and MW-40
Alyssa Stringham <astringham©utah.gov>
Fwd: Background Report for MW-38, MW-39 and MW-40
1 message
Phillip Goble <[e-mail]>
To: Alyssa Stringham <[e-mail]>
Alyssa,
Please print out the attached and give it to the front desk for scanning.
Thanks,
Phil
Thu, Aug 27, 2020 at 3:01 PM
Div of Waste Menagairon'
and Radiation Control
AUG 2 7 2020
Forwarded message
From: Kathy Weinel <[e-mail]>
Date: Thu, Aug 27, 2020 at 2:58 PM
Subject: Background Report for MW-38, MW-39 and MW-40
To: [e-mail] <[e-mail]>
Cc: Phillip Goble <[e-mail]>, Thomas Rushing <[e-mail]>, David Frydenlund
<[e-mail]>, Scott Bakken <[e-mail]>, Logan Shumway
<[e-mail]>, Terry Slade <[e-mail]>, Garrin Palmer
<[e-mail]>, N. Tanner Holliday <[e-mail]>, Angela Persico ([e-mail])
<[e-mail]>
Mr. Howard,
As noted in the attached letter, MW-38, MW-39, and MW-40 have been sampled quarterly since fourth quarter 2018. The
GWDP requires the completion of a Background Report after the collection of eight quarters of data. Analysis of the data,
after eight consecutive quarters, and a total of nine data points, indicate that additional data are required to meet the
statistical requirements of the flowsheet.
EFRI would like to request an extension of 90 days on the due date for the Background Report to accommodate the
collection of an additional quarterly sample for MW-38, MW-39 and MW-40 during the fourth quarter 2020. The revised
due date would be January 8, 2021.
If you should have any questions regarding this transmittal please contact me at 303-389-4134.
Regards,
Kathy Weinel
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8/27/2020 State of Utah Mail - Fwd: Background Report for MW-38, MW-39 and MW-40
KAt Energy Fuels Resources (USA) lnc.
Kathy Weinel
Quality Assurance Manager
t: 303.389.4134 l f: 303.389.4125
225 Union Blvd., Suite 600
Lakewood, CO 80228
http://www.energyfuels.com
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Background Report Extension request.pdf
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