DRC-2019-005975 - 0901a06880a8f40c

DRC-2019-005975 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
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
June 26, 2019 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 13, 2019, 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 13, 2019 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 cadmium in monitoring well MW-25. Monitoring Well MW-25 is in out-of-compliance status for cadmium per the Permit Part I.G.2. based on 1st Quarter 2019 dual exceedances of the GWCL. Cadmium 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 Parameter EFR Noted Preliminary Findings DWMRC Notes
MW-25 Cadmium
•Preliminary analyses show that chloride, fluoride and sulfate are not
exhibiting significant increasing trends. Uranium is exhibiting an increasing trend.
•The 2008 background report noted a decreasing pH trend. The EFR Plan states that increases in concentrations
of cadmium in MW-25 are likely attributed to geochemical processes related to the decreasing pH trend.
•The cadmium data shows a higher variability and shift starting 2012,
coinciding with a change in laboratory by EFR. •No upward trend is noted for
cadmium in MW-25; however, higher concentrations have been measured post 2012 coinciding with the higher
data variability likely due to higher method sensitivity used by the new laboratory. •EPA Statistical Guidance recommends that the data after the shift be statistically analyzed to represent current conditions.
(Over)

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 (EFR Plan Section 5).
Based on review of the EFR Plan it appears that the planned activities are appropriate, with consideration of the additional DWMRC comments noted on the table above, 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/kb
c: Kirk Benge, Health Officer, San Juan Public Health Department Rick Meyer, Environmental Health Director, San Juan Public Health Department Scott Hacking, P.E., DEQ District Engineer