DRC-2020-013609 - 0901a06880cfb088

DRC-2020-013609 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

August 12, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: DWMRC Conditional Approval Regarding the Energy Fuels Resources, July 20, 2020 White Mesa Uranium Mill Revised Low Flow Sampling Plan Utah Groundwater Discharge Permit No. UGW370004 (Permit) Dear Ms. Weinel:
The Utah Division of Waste Management and Radiation Control (DWMRC) has reviewed the Energy
Fuels Resources (USA) Inc. (EFR) July 20, 2020 White Mesa Uranium Mill Revised Low Flow Sampling Plan (EFR Plan) and cover letter. EFR updated the EFR Plan based on a DWMRC review of the previous May 8, 2020 version and a DWMRC request for additional information letter dated May 27, 2020 (RAI). EFR updates included:
1. Section 4.2 Other Guidance for Low-Flow Sampling – Section 4.2 was added which includes an expanded discussion of Low Flow Guidance documents including more recent information discussing the applicability of low flow sampling for well screen lengths greater than 10 feet in low hydraulic conductivity formations. Findings of M.J. Barcelona, M.D. Varljen, R.W. Puls
and D. Kaminski, Winter 2005, Ground Water Purging and Sampling Methods: History vs.
Hysteria, Ground Water Monitoring & Remediation 25, no. 1, are that low flow sampling can be representative of the entire thickness of the aquifer intercepted by the screen length. As discussed in the RAI, all conclusions regarding the appropriateness of the low flow method for monitoring wells at the White Mesa Mill should be based on the Mill specific sampling and
data evaluation. An objective of the EFR Plan, in addition to investigating erroneous high dissolved oxygen readings at several monitoring wells, is to determine suitability of the White Mesa monitoring well designs and aquifer properties for low flow sampling.
(Over)

2. Section 5.0 Wells Included In This Plan (Inclusion of Figure 1 and Table 5.0) and Section 6.0
Procedures – Section 5.0 was amended to expand the number of wells to be sampled and
Section 6.0 now requires that the low flow purge sampling be conducted, immediately followed by volume based purging and sampling. DWMRC notes that Figure 1 was included which provides a site map showing all monitoring wells which will be sampled for the study. Additionally, Table 5.0 was included which lists the monitoring wells to be sampled, recent dissolved oxygen measurements, well screen and aquifer hydraulic conductivity and
groundwater sampling requirements currently in the Permit. These additions address related issues in the RAI. 3. Section 6.2.1 Low Flow Well Purging – Section 6.2.1 item number 3 has been added which
requires that an additional sample be collected of the standing (stagnant) water in the well “as
soon as the pump tubing has been purged. Although this item was not requested in the RAI, DWMRC agrees that collecting an additional sample of the standing water for data comparison and validation is useful. 4. Section 8.0 Schedule – The schedule has been modified based on the change to collect samples
by low flow and volume-based purging contiguously. The EFR Plan states that the study will be conducted the first even numbered quarter after the DWMRC approval of the EFR Plan. Based on this approval letter, the study will be completed during the 4th Quarter 2020.
5. Section 9.0 Reports – Section 9.0 of the EFR Plan has been expanded to provide more discussion
regarding the submission of a report summarizing the findings of the study. Specifically Section 9.0 of the EFR Report states that data will be verified according the current approved Quality Assurance Plan for all three samples (standing water, low flow sample and volume purge sample) and that the differences in the analytical data will be analyzed as well as overall assessment of the low flow sampling methodology. Section 9.0 clarifies that the low flow
sampling data will not be used for compliance purposes. DWMRC agrees that the low flow data will be used for study objectives only. EFR will submit the study report within 90 days following the end of the study quarter.
DWMRC Conditional Approval of the EFR Plan
Based on review of the EFR Plan it appears that all items in the RAI were addressed and therefore the July 20, 2020 EFR Plan is hereby approved with the following two conditions: 1. EFR will provide at least 2 weeks notification prior to conducting fieldwork/field sampling for
the EFR Plan. This is in order to give DWMRC an opportunity to be present for all or a portion of the sample collection and document field sampling procedures. 2. If, after DWMRC review of the study report, additional information is found necessary to
support conclusions of the study, then EFR and DWMRC will discuss the additional needed
information and schedules to conduct additional study or provide additional data evaluation.

As noted above, per schedules outlined in the EFR Plan, the study will be conducted during the 4th
Quarter of 2020 and the study report will be submitted to DWMRC within 90 days after the end of the
quarter. 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
PG/TR/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