DRC-2019-010021 - 0901a06880afa36a

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
August 22, 2019 DRC-201c)-0(0021 Div of Waste Management
Sent VIA OVERNIGHT DELIVERY and Radiation Control
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 144880
Salt Lake City, UT 84114-4820
AUG 2 7 2019
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004 Request to Revise
Groundwater Quality Assurance Plan ("QAP")
Dear Mr. Goble:
Energy Fuels Resources (USA) Inc. ("EFRI") is requesting the addition of an analytical method to Groundwater
Quality Assurance Plan ("QAP"), Revision 7.5 dated May 14, 2019.
EFRI is requesting the addition of Environmental Protection Agency ("EPA") Method 8260D: Volatile Organic
Compounds by Gas Chromatography/Mass Spectrometry (GC/MS) as an option for the analysis of Volatile
Organic Compounds ("VOCs") in groundwater samples collected at the White Mesa Mill (the "Mill").
EFRI believes the addition of this Method will have minimum impacts on the Mill data as Method 8260D will
provide data comparable to EPA Methods 8260B/8260C currently in use. The revisions promulgated by EPA
clarified quality control terminology and requirements and addressed compound specific issues, which do not
affect the Mill data as these are not compounds analyzed under the Mill GWDP. This method change is being
requested to provide the analytical laboratory more flexibility due to updated technology and method
improvements. Lastly, the Method change will not have any change on the Reporting Limits specified in the
QAP.
For ease of review we have provided both redline and clean versions of the QAP.
If you should have any questions regarding this plan please contact me.
Yours very truly,
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ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Terry Slade
Logan Shumway
Scott Bakken
Paul Goranson