DRC-2013-003674 - 0901a068803e8d5d

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State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2013-003674
December 18,2013
CERTIFIED MAIL
(Return Receipt Requested)
Kathy Weinel, Quality Assurance Manger
225 Union Blvd.
Suite 600
Lakewood,CO 80228
Subject: Energy Fuels Resources (USA) Inc. December 5, 2013 Transmittal of Plan and Time
Schedule under Utah Ground Water Discharge Permit UGW370004 Part I.G.4(d) White
Mesa Mill: DRC Conditional Approval
Dear Ms. Weinel:
The Utah Division of Radiation Control ("DRC") has reviewed the Energy Fuels Resources (USA) Inc.
("EFR") December 5,2013 Plan and Time Schedule regarding out of compliance status for sulfate in
monitoring well MW-1 and TDS in monitoring well MW-3 A.
Based on findings of the Plan and Time Schedule, EFR attributes the out of compliance status to
background groundwater fluctuations and proposes to submit a Source Assessment Report ("SAR") for the
wells/parameters within 90 days of Director approval of the December 5,2013 Plan and Time Schedule.
Per EFR, the SAR will include a geochemical analysis of indicator parameters (chloride, fluoride, sulfate
and uranium) for the wells/parameters. The intention will be to determine if the behavior of the water has
changed since the time of the New Wells Background Report (Intera, 20071).
EFR notes that ifthe OOC status is determined to be caused by background influences, then no additional
evaluation to determine the extent and potential dispersion of the contamination will be necessary. In the
event that a background determination is made then EFR will submit to the Director, as part of the SAR,
proposed revised GWCL's for sulfate in monitonng well MW-1 and TDS in monitoring well MW-3 A.
If a proposed revised GWCL's are included, then statistical analysis, as described in the Existing Wells
Background Report (Intera, 2007), and according to the Director approved flow sheet for statistical
analysis of GWCL revisions will be used.
Conditional Approval:
The EFR December 5,2013 Plan and Time Schedule is hereby approved with the following conditions:
INTERA Incorporated, 2007. Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp's White Mesa Uranium Mill Site, San Juan County,
Utah
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D [phone]
www deq utah gov
Pnnted on 100% recycled paper
Jo Ann Tischler
Page 2
1. The SAR for Sulfate at groundwater monitoring well MW-1 and TDS at monitoring well MW-
3 A will include all study elements and report structure of the October 10,2012 EFR Source
Assessment Report (approved by the Director through Stipulated Consent Agreement UGW12-
03), including graphs, plots and charts, and;
2. The SAR will be submitted on or before 90 calendar days from EFR receipt of this conditional
approval letter.
If you have any questions regarding this letter or the review findings please contact Tom Rushing at
[phone].
Sincerely,
Rusty Lundberg, Director
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U \MON_WAST\Trushing\Energy Fuels\Groundwater Reports\2013 Groundwater Reports\3rd Quarter 2013U2-5-13 Plan and Time Schedule\EFR
12-5-13 Plan and Time Schedule Conditional Approval docx