DRC-2019-003763 - 0901a06880a29652

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 April 22, 2019 and Radiation Control
VIA PDF AND FEDERAL EXPRESS
Mr. Ty L. Howard
Director
Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
APR 2 5 2019
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill — Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status
Dear Mr. Howard:
A number of groundwater monitoring constituents have been placed on accelerated monitoring status
under Part I.G.1 of the Energy Fuels Resources (USA) Inc. ("EFRI") Ground Water Discharge Permit No.
UGW370004 ("GWDP"). Part I.G.1 provides that such accelerated monitoring shall continue until
compliance status of the facility can be determined by the Director.
Based on the accelerated monitoring results to date, EFRI requests the Division of Waste Management
and Radiation Control ("DWMRC"). make a determination that accelerated monitoring cease at this time
for cadmium in MW-28 for the reasons stated below:
• MW-28 cadmium results have been within the Groundwater Compliance Limit ("GWCL")
specified in the GWDP for eight consecutive sampling events since Q1 2017. Per the UDEQ,
eight consecutive sample results below the GWCL are needed for the discontinuance of
accelerated monitoring.
Once removed from accelerated monitoring status, these constituents, like all other constituents, would be
subject to future accelerated monitoring under Part I.G.1 of the GWDP, should circumstances warrant.
To assist in your evaluation of the foregoing, we have included a summary of the accelerated sampling
results since the initial sample result that triggered accelerated monitoring in Table 1.
The analytical laboratory reports for the foregoing results up to and including December 2018 are
included in the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC.
Copies of the analytical laboratory reports for the results for January 2019 through March 2019 will be
provided in the upcoming 1st Quarter 2019 Groundwater Monitoring Report and are also included with
this letter for your convenience. It is important to note that the 1st Quarter 2019 monitoring results
included with this letter have been evaluated per the DWMRC approved QAP and the GWDP and all
field and laboratory quality control parameters are acceptable. The evaluations of the 1st Quarter data
will be included in the 1st Quarter 2019 Groundwater Monitoring Report, due June 1, 2019.
DRC-2019-003-73
Letter to Ty L. Howard
Removal of Parameters from Accelerated Monitoring
April 22, 2019
Page 2
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
ti-t iVmat4
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Paul Goranson
Logan Shumway
Terry Slade
Tanner Holliday
Scott Bakken
Analytical Results and Field Sampling Sheets for the Wells that are the Subject of
this Request
Table 1
Summary of Accelerated Sam le Results with Ei ht or More Results in Com liance
Vell ID Constittient GWCL • Sample Date Sarnple Result
.-.) ,ImAkii,,,,ic.
MW-28 Cadmium (ug/L) 5.2 Q1 2017* 5.23
Q2 2017 5.10
Q3 2017 4.95
Q4 2017 4.97
Q1 2018 4.57
Q2 2018 4.99
Q3 2018 4.84
Q4 2018 4.61
Q1 2019 4.76
*Last sample result outside of GWCL limits.
American Wes ANALYTIC L LABOPIATORIO
INORGANIC ANALYTICAL REPORT
Client:
Project:
Lab Sample ID:
Client Sample ID:
Collection Date:
Received Date:
Analytical Results
Energy Fuels Resources, Inc.
1st Quarter Ground Water 2019
1901565-004
MW-28_01222019
1/22/2019 1115h
1/25/2019 940h
Contact: Garrin Palmer
DISSOLVED METALS
Date Date Method Reporting Analytical
3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual
>aft Lake City, UT 84119 Cadmium mg/L 1/25/2019 1122h 2/7/2019 123h E200.8 0.000500 0.00476
Uranium mg/L 1/25/2019 1122h 2/7/2019 1914h E200.8 0.000300 0.00712
Phone: [phone]
Toll Free: [phone]
Fax: [phone]
awalaawal-labs.com
web: www.awal-labs.com
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Report Date: 2/13/2019 Page 8 of 44
All analyses applicable to the C'WA. SDWA. and RCRA are performed m accordance to NELAC protocols Pertinent sampling mformation is located on the attached COC Confidential Business Information This report IS prolhded for the exclusti e use of the addressee. Pm tleges of subsequent use of the name of this company or am member of its stafT. or reproduction of this report in coonecttonwsth the WI erusement. promotion or sale of am product or process, or III connection with the re-publication of this report