DRC-2020-011504 - 0901a06880cb930a

DRC-2020-011504 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

June 22, 2020

Kathy Weinel, Quality Assurance Manager Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources (USA) Inc. May 21, 2020, 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) May 21, 2020 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 selenium and uranium in monitoring well MW-28. Monitoring Well MW-28 is in out-of-compliance status for selenium and uranium per the Permit Part I.G.2. based on 1st Quarter 2020 dual exceedances of the Permit GWCL’s, and is therefore required to undergo corrective action per the Permit Part I.G.4.

The table below summarizes the preliminary findings in the EFR Plan:
Monitoring Well Parameters EFR Noted Preliminary Findings and Source Assessment
MW-28 Selenium and Uranium
• EFRI believes that exceedances in MW-28 are likely due to background influences (including changing water levels in some wells and other factors), disruption of the aquifer by pumping, and/or the geochemical influences of the existing chloroform
and nitrate/chloride plumes. Per the EFR Plan the new SAR
study will include: (Over)

Monitoring Well Parameters EFR Noted Preliminary Findings and Source Assessment
MW-28 Selenium and
Uranium
o A geochemical analysis that will evaluate the behavior of
constituents in MW-28 to determine if there are any changes in the behavior of indicator constituents, such as chloride, sulfate, fluoride and uranium since the date of the New Wells Background Report that may suggest a
change in the behavior of that well since the date of that
Report;
o If necessary, a mass balance analysis that will evaluate the observed concentrations in light of the concentrations in Mill tailings and the presence or absence of any
ground water mounding;
o An analysis of the extent, if any, to which the constituents may be influenced by geochemical changes caused by migrating nitrate and/or chloride or chloroform from the existing plumes; and
o An analysis of the extent, if any, to which the
constituents may be influenced by changes in other constituents in ground water that have resulted from changes in pH or any other natural phenomenon. A Source Assessment Report which will include a more specific source investigation and statistical analysis, per the EFR Plan Section 4, will be submitted to the Director within 90 days after approval of the EFR Plan.
Based on review of the EFR Plan it appears that the planned activities are appropriate, 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: Kirk Benge, Health Officer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department Russell Seeley, UDEQ District Engineer