DRC-2019-001984 - 0901a068809d26b8

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Div of Waste Management February 21, 2019 and Radiation Control
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Phil Goble
Uranium Mills and Radioactive Materials Section Manager
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
FEB 2 6 2019 P72 -21019-0019e+
Re: Energy Fuels Resources (USA) Inc. ("EFRI") Response to Utah Division of Waste
Management and Radiation Control ("DWMRC") February 1, 2019 Letter and Request for
Information ("RFI"), Third Quarter 2018 Groundwater Report, Groundwater Discharge
Permit UGW370004
Dear Mr. Goble:
This letter responds to DWMRC's above-named letter dated February 1, 2019 which Energy
Fuels Resources (USA) Inc. ("EFRI") received on February 11, 2019, regarding the DWMRC
inspection of EFRI' s Third Quarter 2018 Groundwater Report.
For ease of review, this letter provides the DWMRC comments, in italics, below, followed by
EFRI' s response.
Request for Information
DWMRC Comment
A deviation from the Mill Groundwater Monitoring Quality Assurance Plan (QAP) was noted
during review of the 1st Quarter 2018 Report regarding the current method used for gross alpha
analysis by GEL laboratories. Based on a follow-up discussion regarding this issue between
DWMRC and EFR, EFR contacted GEL laboratory and informed them that the analytical method
being used for analysis of gross radium alpha does not conform to the current Utah certified
method listed for GEL. GEL listed the method used as "EPA 900.1 Mod" but per DWMRC review,
only has current Utah certification for method 903.0.
Per the EFR conversation with GEL it was decided that EFR would update the QAP to include
method 903.0 and that GEL would use that method. This approach would not require GEL to
obtain Utah cer4fication for method 900.1. DWMRC concurred with this approach after review
of method 903 .0 and approved an updated QAP which includes an option to use method 903.0 for
gross radium alpha. These actions took place during the second quarter of 2018 and it was
Letter to Phil Goble
February 21, 2019
Page 2 of 3
expected that the laboratory would change to the certified method for analysis of the third quarter
2018 groundwater samples.
Contrary to this, per DWMRC review of the Report, tables G-4A and G-4B, EFR lists the method
used by the laboratory as E900.1. The GEL laboratory data sheets list the method used for "GFPC,
Total Alpha Radium, Liquid" as "EPA900.1 ModIEP A903 .0 Mod." Therefore, it does not appear
that GEL is using the current Utah certified method but is using another modified method which
is unclear.
Please provide a response to this issue within 30 calendar days including;
(1) a summary of the EFR correspondence with GEL regarding the use of an apparent un-certified
method for gross alpha, and
EFRI Response:
A time line of discussions and correspondence regarding the Gross Alpha ("GA") methodology is
as follows:
• June 26, 2018, EFRI/DWMRC discussion regarding GEL method certification for method
900.1.
• July 10, 2018, EFRI/GEL discussions regarding method certification and options to
address issue. EFRI and GEL determined that method 903.0 would provide comparable,
quality data.
• July 23, 2018, EFRI submitted a revised Quality Assurance Plan ("QAP") requesting the
addition of method 903.0.
• August 9, 2018, EFRI received, via e-mail, the DWMRC approval of the revised QAP
incorporating method 903.0.
• August 12, 2018, EFRI submitted the QAP approval letter to GEL. GEL was instructed to
use method 903.0 for analyses completed after the date of the DWMRC approval letter
(August 9, 2018).
It is important to note that while discussions between EFRI and DWMRC were started in the
second quarter (June 26, 2018), the final resolution and approval of the QAP did not occur until
the third quarter 2018.
DWMRC Comment
(2) an explanation as to why method 900.1 is being used for gross alpha after notification that the
current EFR contract laboratory does not have Utah certification for that method.
EFRI Response:
Method 900.1 was not used by GEL after August 12, 2018. Method 903.0 was used by GEL to
analyze the Q3 2018 groundwater samples from the Mill. The data incorrectly lists the method as
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Letter to Phil Goble
February 21, 2019
Page 3 of 3
EPA900.1 Mod/EPA903.0 Mod. In addition, Tables G-4A and G-4B in the Q3 2018 groundwater
report also incorrectly list method 900.1. Both of these method reporting items are typographical
errors and do not accurately reflect the actual method used.
As a result of this RFI, EFRI and GEL discussed reporting the methods as modified ("MOD").
GEL analyzes GA samples using method 903.0 as written, with no changes. The title of method
903.0 is "Alpha-Emitting Radium Isotopes in Drinking Water". It is GEL' s policy to report a
method as "MOD" when the matrix analyzed differs from that specified in the method. In this
case, the matrix specified in the method title is drinking water; the Mill samples are groundwater.
In an effort to address the DWMRC concerns regarding the "MOD" delineation, GEL will report
GA data as Method 903.0. This change will begin with the Q4 2018 data.
Please contact me if you have any questions or require any further information.
Yours very truly, _
-7ttt Ju-“I
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Dave Frydenlund
Terry Slade
Logan Shumway
Scott Bakken
Paul Goranson
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