DRC-2014-003861 - 0901a06880447575

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
June 11,2014
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-003861
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc. 1st Quarter 2014 Groundwater Monitoring Report, 1st
Quarter 2014 Accelerated Monitoring Status Report, and May 19, 2014 Request to
Remove Certain Monitoring Wells/Parameters from Accelerated Monitoring Frequency:
DRC Findings
Dear Ms. Weinel:
The Utah Division of Radiation Control (DRC) has reviewed the Energy Fuels Resources (USA) Inc.
("EFR") March 19, 2014 "Transmittal of Is' Quarter 2014 Groundwater Monitoring Report Groundwater
Quality Discharge Permit UGW370004 White Mesa Uranium Mill;" the EFR May 5, 2014 "State of Utah
Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part
I.G. 1(a);" and, the EFR May 19, 2014 "State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters from Accelerated
Monitoring Status." A summary of findings is found below.
EFR Request to Return Monitoring Well MW-12 Selenium and MW-27 Gross Alpha to Baseline
Monitoring Frequency:
Per the May 19, 2014 Request, EFR provides information regarding compliance monitoring at well MW-
12 for selenium and well MW-27 for Gross Alpha. These wells/parameters are currently required to be
sampled on an accelerated basis due their out-of-compliance status.
The May 19, 2014 request for monitoring frequency reduction for selenium in MW-12 states that
monitoring results "have been below the Groundwater Compliance Limit specified in the GWDP for eight
consecutive sampling events since Q2 2012." Per DRC review of the request and laboratory results, it
appears that the most recent eight consecutive accelerated samples for selenium in monitoring well MW-12
have been below the GWCL. Based on past approvals of return to baseline monitoring, this request is
consistent and a return to baseline monitoring is appropriate.
The EFR May 19, 2014 request for monitoring frequency reduction for gross alpha in MW-27 is likewise
based on the eight most recent consecutive monitoring results showing concentrations below the GWCL.
Per DRC review of the monitoring results, it appears that a return to baseline monitoring frequency is
appropriate.
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
Printed on 100% recycled paper
Kathy Weinel
Page 2
Therefore, the wells/parameters and monitoring frequencies listed on the table below are approved:
Well No.
MW-12
MW-27
Parameter
Selenium
Gross Alpha
Baseline Monitoring Frequency
Semi-Annual
Semi-Annual
EFR Is' Quarter 2014 Groundwater Monitoring Report:
DRC reviewed the following elements of the EFR 1st Quarter 2014 Groundwater Monitoring Report:
1. Accelerated Monitoring (wells and parameters),
2. Field Sample Collection Sheets (well purging and field parameter collection),
3. Blind Duplicate Analysis (Relative Percentage Difference),
4. Analytical Laboratory Certification,
5. Laboratory Report Turn Around Times,
6. Sample Holding Times,
7. Sample Preservation,
8. Analytic Reporting Limits,
9. Laboratory Quality Assurance and Quality Control Reports and Flags,
10. Time Concentration Plots of Data,
11. Depth to Groundwater Measurements,
12. Water Table Contour Maps (Burro Canyon Aquifer),
13. Relative dewatering of the groundwater mound around the wildlife ponds,
14. Laboratory data and comparison with the Permit Ground Water Compliance Limits.
The review was conducted with consideration of a May 25, 2012 EFR Permit modification request which
was made in order to document accelerated reporting and monitoring agreements made during a
teleconference with the Utah Division of Radiation Control (DRC). Per DRC staff discussions with EFR
the May 25, 2012 request will be included with the White Mesa Mill Ground Water Permit Renewal. DRC
review of the 1st Quarter 2014 Report recognizes the telephone agreement regarding the timeline for EFR
to submit updated compliance notice and initiate accelerated monitoring.
Per review, it appears that the 1st Quarter Groundwater Report complies with the Permit requirements;
therefore, the review is hereby closed out.
If you have any questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Craifw'Jones \J
Acting Victor
CWJ:TR:tr
U:\MON_WAST\Trushing\Energy Fuels\Groundwater Reports\2014 Groundwater ReportsUst Quarter 2014 Groundwater Report\EFR 1st Qtr
2014 GW Report DRC Ltr.docx