DRC-2021-020822 - 0901a06880fbfecc

DRC-2021-020822 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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

February 16, 2022

Colin Larrick
Ute Mountain Ute Tribe
Environmental Programs Department
P.O. Box 448
Towaoc, CO 81334-0448

RE: Response to Ute Mountain Ute Tribe (UMUT) Letter Dated October 28, 2021
Regarding the Energy Fuels Resources (USA) Inc. (EFRI) White Mesa Uranium Mill
Radioactive Materials License No. UT 1900479 (License)
Groundwater Discharge Permit No. UGW370004 (Permit)

Dear Mr. Larrick:

The Division of Waste Management and Radiation Control (Division) is writing in response to your
letter dated October 28, 2021 (Letter) regarding the White Mesa Uranium Mill (Mill). The Division
does recognize that the UMUT and its members living in the White Mesa Community have vital,
long-term interests at stake to protect water resources at and around the White Mesa community, and in
particular, the seeps and springs in and around White Mesa and the deep Navajo aquifer which is a
source of drinking water for the White Mesa Community. The protection of groundwater resources is of
primary importance to the Division. In fact, protection of groundwater resources associated with the
Mill was a primary reason the State of Utah became an Agreement State for the NRC’s Uranium Mill
program in August of 2004.

With that understanding the Division has considered the concerns/comments presented in the Letter and
is providing this response accordingly. To provide procedural context for this response, note that the
matters addressed in this Letter do not relate to any open administrative action currently pending before
the Division where there would be an open public comment period. Therefore, the Division has decided
to treat the Letter in the same way it would treat a request for consultation, consistent with Executive
Order EO/2014/005: Executive Agency Consultation with Federally Recognized Indian Tribes. This
response is offered to facilitate government-to-government consultation and collaboration between the
UMUT and the Division.
(Over)

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The Division notes several general concerns brought up by the UMUT in the Letter. The Division has
previously addressed these restated concerns in multiple references. Most recently, the Division
provided responses in the March 2020 public participation summary (PPS) (DRC-2021-002082) for the
Modified Groundwater Discharge Permit No. UGW370004 (DRC-2021-002102). A copy of the PPS is
available online on the Division website: https://documents.deq.utah.gov/waste-management-and-
radiation-control/facilities/energy-fuels-white-mesa/DRC-2021-002082.pdf. Quoted language (shown
in italics) from the PPS that specifically addresses the UMUT’s general concerns is also provided in this
response letter. The permit modification was signed by the Director on March 8, 2021, and was not
appealed by anyone; therefore, the Permit is considered final. The Letter presents no new facts that
would alter the Division’s analysis and determinations.

In addition to the UMUT general comments, the Letter also describes specific concerns regarding:
(1) groundwater compliance limit (GWCL) exceedances in compliance monitoring wells MW-30 and
MW-31, and (2) elevations in the (non-compliance) groundwater monitoring well TW4-24.

Regarding GWCL exceedances, the Division’s review is summarized in memoranda which are available
online as follows: (1) MW-30 Division Review Memorandum (7/8/2019),
https://documents.deq.utah.gov/waste-management-and-radiation-control/facilities/energy-fuels-white-
mesa/DRC-2019-006502.pdf, (2) MW-31 Division Review Memorandum (7/1/2021),
https://documents.deq.utah.gov/waste-management-and-radiation-control/facilities/energy-fuels-white-
mesa/DRC-2021-010482.pdf. The proposed changes to the GWCL’s will undergo public comment as
part of the Permit modification process. The UMUT will have standing to provide comments as to any
such future agency action. For the present time, however, the Permit is unchanged and EFRI is required
to comply with it. As usual, EFRI is also required to monitor for exceedances to ensure that any
potential groundwater contamination is quickly identified and investigated to determine whether the Mill
is the cause and implement any necessary corrective actions.

Overview of Compliance Monitoring Well Exceedance Response Process

To provide additional information about groundwater monitoring permit requirements and GWCL
exceedances, the following is an overview of the compliance monitoring well exceedance response
process.

EFRI (the Permittee) is currently required to monitor for 38 different contaminants in 21 different
compliance monitoring wells. The Division places each well into one of two categories, depending on
the local groundwater average linear velocity, which determines the applicable monitoring schedule that
must be followed:

1. Wells with a local ground water average linear velocity greater than or equal to (≥) 10 feet/year
a. Monitored quarterly (4 times annually).
b. When accelerated sampling is required, monitored monthly.
2. Wells with a local ground water average linear velocity less than (<) 10 feet/year
a. Monitored semi-annually (2 times annually).
b. When accelerated sampling is required, monitored quarterly.

If a contaminant concentration exceeds the applicable GWCL’s defined in Table 2 of the current
Groundwater Discharge Permit for the first time following a contaminant measure that was below the
GWCL, the facility goes into Probable Out-of-Compliance (POOC) status and the following steps are
triggered:

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“1. Accelerated Monitoring Status - is required if the concentration of a pollutant in any compliance
monitoring sample exceeds a GWCL in Table 2 of the Permit; the facility shall then:
a) Notify the Director in writing (the Exceedance Notice) within 30 calendar days of receipt of the
last analytical data report for samples collected within a quarter, including quarterly and
monthly samples, but no later than 60 days after the end of the quarter, and
b) Initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring Wells - for wells defined by Part I.E.1(b) the Permittee
shall initiate monthly monitoring. Monthly monitoring shall begin the month following
the month in which the Exceedance Notice is provided to the Director.
2) Semi-annual Baseline Monitoring Wells - for wells defined by Part I.E.1(c) the Permittee
shall initiate quarterly monitoring. Quarterly monitoring shall begin the quarter
following the quarter in which the Exceedance Notice is provided to the Director.
3) Said accelerated monitoring shall continue at the frequencies defined above until the
compliance status of the facility can be determined by the Director.”

If two sequential contaminant concentrations exceed the applicable GWCL, the facility goes into
Out-of-Compliance (OOC) status and the following steps are triggered:

“4. Facility Out of Compliance Status - if the facility is out of compliance, the following is required:
a) The Permittee shall notify the Director of the out of compliance status within 24-hours after
detection of that status, followed by a written notice within 5 calendar days of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part I.G.1, unless the Director
determines that other periodic sampling is appropriate, until the facility is brought into
compliance.
c) The Permittee shall prepare and submit to the Director within 30 calendar days following the
date the Exceedance Notice is submitted to the Director, a plan and a time schedule for
assessment of the sources, extent and potential dispersion of the contamination, and an
evaluation of potential remedial action to restore and maintain groundwater quality to insure
that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT
will be reestablished.
d) The Director may require immediate implementation of the currently approved contingency plan
in order to regain and maintain compliance with the Permit limit standards at the compliance
monitoring point or to reestablish DMT or BAT as defined in the Permit.
e) Where it is infeasible to reestablish DMT or BAT as defined in the Permit, the Permittee may
propose an alternative DMT or BAT for approval by the Director.”

In first providing an overview of the exceedance response process, the Division hopes to provide further
clarity and an indication of goodwill and transparency to the UMUT in addition to helping address some
of the concerns provided in the Letter.

UMUT General Concern 1 – Protection of the Navajo Aquifer and the Groundwater Seeps and
Springs

As stated above, the protection of groundwater resources is of primary importance to the Division. A
thorough discussion of how the Navajo aquifer is protected from contamination was described in the
most recent March 2020 Permit Modification Public Participation Summary. That same discussion is
also included here for convenience:

“Contamination of the perched Dakota/Burro Canyon Aquifer by the Mill is limited to the
Nitrate/Chloride and Chloroform Plumes, located many miles away from—and cross-gradient from the
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White Mesa community. Also, as studied and documented in the November 7, 2012 EFR “Southwest
Investigation,” (1), the contamination is not affecting any seeps or springs along the margins of the mesa
and would not be expected to impact any of the seeps or springs based on extremely low hydraulic
permeability of the perched aquifer and potential groundwater contaminant travel time on the order of
thousands of years. Additionally, this contamination is rigorously defined and monitored to ensure that
the area of contamination is well defined, and that progress is made to remove the contamination from
the perched aquifer. Therefore, these plumes are contained and under appropriate corrective action.

Based on the Administrative Record, these sources of contaminants do not affect use of the perched
groundwater by any parties, including the Ute Mountain Ute Community. In response to the comment
that the Ute Mountain Ute Community is “downgradient” from the Chloride and Chloroform plumes,
the Division disagrees with this comment. It is not supported by technical evidence. The gradient of the
perched Dakota/Burro Canyon aquifer was addressed in detail during the 2017 renewal process. See
2017 Permit Renewal PPS. Additional data received since the 2017 renewal, including groundwater
gradient information from three new monitoring wells (MW-38, 39, and 40), corroborates the Division’s
longstanding findings that the gradient in the perched Dakota/Burro Canyon aquifer is cross-gradient
from the Ute Mountain Ute White Mesa Community. There is no “preferential” groundwater gradient
or pathway from the Mill operational area to the Ute Mountain Ute Community, as the UMUT contends.
See, e.g., the figure attached to UMUT Comment 28.e. In addition to the gradient, these contaminants
are hydraulically isolated according to the corrective action plans (groundwater pumping) and are
contained within the boundary of land owned and/or operated by the Mill.

The perched Dakota/Burro Canyon aquifer is hydraulically isolated from the deeper Navajo Aquifer.
Any potential discharges from the Mill to groundwater would be isolated in a perched aquifer system
defined as the Burro Canyon Aquifer. The perched Dakota/Burro Canyon aquifer is classified as
“perched” due to the presence of significant, naturally low-permeability formation materials
underneath it. The perched Burro Canyon Aquifer is separated from the deep Navajo Aquifer (which is
locally used as a primary drinking water source), by approximately 1,100 feet of Morrison and
Summerville Formation materials. These formations have unusually low average vertical permeability.
For example, the underlying formation includes more than 200 feet of Brushy Basin Member bentonitic
clay, a material with extremely low vertical permeability. Located directly below the Burro Canyon
Aquifer, the Brushy Basin Member bentonitic clay perches the Burrow Canyon groundwater so well that
it forces lateral flow from the perched aquifer to the margins of the mesa. This stratigraphy effectively
isolates the perched Burro Canyon Aquifer from the Navajo Aquifer, prohibiting the discharge of
potential contaminants from the perched aquifer to the deep aquifer.

These natural conditions were a significant consideration in the siting of the White Mesa Mill in the
1970s. This topic is addressed in more detail in the 2017 Permit Renewal PPS.”

UMUT General Concern 2 – Comments Regarding the Division’s Regulatory Response to GWCL
Exceedances

All Division reviews of source assessment reports (SAR) that result in proposed changes to GWCLs will
be within the scope of any following Permit Modification, which will be subject to public comment in
due course. The UMUT is welcome to provide formal comment regarding the findings of the source
assessments in connection with any future Permit Modifications. Currently, EFRI is meeting the
requirements of the Permit and conducting accelerated monitoring of constituents in out-of-compliance
status per the Permit and will continue to do so until incorporation of revised limits in the Permit.
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In the event of two consecutive exceedances, the Permit requires EFRI to prepare a plan and time
schedule to investigate the OOC status, followed by submission of an SAR. If EFRI provides evidence
that demonstrates that Mill operations are the source of the exceedance then corrective actions would be
required through an administrative order.

The specific methodology used by the Division to evaluate and calculate GWCL’s was discussed in
detail in the March 2020 Permit Modification Public Participation Summary and is included below.
Also, note that the specific Permit requirements associated with groundwater compliance are included in
this letter above:

“The administrative record regarding geological site conditions, groundwater beneficial use, and
groundwater quality and conditions at the Mill and surrounding properties is extensive and growing.
This is due to compliance oversight of the Permit and agreed upon groundwater studies and actions with
EFR and consideration of public concerns and comments. The focus of the March 2020 Permit GWCL
Modifications relate to the use of intrawell statistical evaluation. Since this is the primary topic of the
received public comments, following are general comments on this topic.

The method used by the Division to evaluate and calculate GWCL’s (Intrawell Basis and Statistical
Methods) follows EPA Statistical Guidance. GWCL’s listed in the Permit are in conformance with State
Groundwater Rules (Utah Administrative Code “UAC” R317-6). This general comment/response
summarizes the purpose and guidance used to develop and update background concentrations and
GWCL’s in the Permit and is applicable to the comments received, and responded to below, regarding
the Permit modification.

Permit GWCL’s included in the Permit are based on intrawell statistics and are performed per a
process outlined in the approved flow chart for the White Mesa Uranium Mill (Mill). The flow chart
was originally based on the EPA Interim RCRA Statistical Guidance which was finalized in March 2009
and titled Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities Unified Guidance.
EPA 530/R-09-007 (Unified Guidance). A copy of the approved flowchart is included with this public
participation summary as Attachment 1.

Chapter 5 of the Unified Guidance discusses the importance of background data, use of data to develop
compliance limits (Maximum Contaminant Levels) in Permits, ongoing evaluation of monitoring data
and appropriate revisions to the background data set, and revised statistical analysis of compliance
limits.

The groundwater monitoring required by the Permit for the Mill is extensive. The Permit is highly
protective of groundwater and requires compliance monitoring for 38 compliance constituents at a
comprehensive groundwater monitoring network (designed for 95% + monitoring efficiency) designed
for early detection of potential discharges from the Mill processing and tailings impoundments.
Compliance monitoring wells are sampled monthly or quarterly per groundwater velocity
measurements, to ensure that data is not affected by auto correlation. Additionally, extensive study of
the aquifer hydraulic and geological characteristics has been conducted and is ongoing (e.g., aquifer
spatial permeability differences). The studies are included in the EFR White Mesa Mill Hydrogeological
Report which is required to be updated as part of the Permit renewal application (every 5 years).

The Unified Guidance Chapter 5.2.4 discusses spatial variability in groundwater data and states,
“Evidence of spatial variation should drive the selection of an intrawell statistical approach if observed
among wells known to be uncontaminated (e.g., among a group of upgradient background locations).”

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In the case of the Mill, spatial variability is observed in the groundwater data sitewide, including at
upgradient background wells and far downgradient wells from the Mill (1,000 years plus groundwater
travel time from the Mill). Based on these findings and review of the Mill background reports, intrawell
statistics are appropriate and recommended by the Unified Guidance.

The Unified Guidance Chapter 5 also discusses the identification of concentration trends and evaluation
of groundwater data. As well as the need to continue monitoring and re-evaluate compliance limits
based on expanded data sets. This guidance is reflected in the approved statistical flow chart used for
the Mill and is the basis for Permit requirements related to accelerated monitoring plan, and time
schedules for studying out-of-compliance (OOC) parameters, source assessment reports and statistical
evaluation of OOC data sets.

The Division regularly reviews the monitoring well data (submitted in quarterly reports) and compares
those measured concentrations against their corresponding GWCLs. The GWCLs have been established
with consideration of background monitoring concentrations on an intrawell basis. Again, this is in
recognition of the anisotropic and heterogeneity of the perched aquifer. The Division additionally
recognizes that several of the parameters, in monitoring wells, were identified as having natural pre-
existing upward or downward data trends, not caused by the Mill, in background reviews and formally
documented in EFR background reports. It is expected that these parameters will exceed their Permit
GWCL but that does not necessarily mean Mill activities are now the cause of the increasing trends.
The GWCL’s are based on statistical analysis using an evaluation of historical groundwater monitoring
data for each well and EPA statistical guidance and methods as discussed above.

If any of the monitoring concentrations exceeds the GWCL then the Permit requires EFR to report the
exceedance and commence accelerated monitoring for that well and parameter. If the concentration of a
parameter exceeds the GWCL in two consecutive samples then EFR is required to notify the Director of
the “out of compliance” status, continue accelerated monitoring, and submit a plan and time schedule
for assessment of the source of GWCL exceedances.

EFR submits the plan and time schedules and source assessment reports to the Director according to the
requirements of the Permit for review and approval. Source assessments generally include the following
types of evaluation which serve as lines of evidence when determining whether the GWCL exceedance
was or was not due to Mill activities:

• Evaluation of Tailings Solution Discharge Indicator Parameters (Cl, Fl,
SO4, U) concentration and trends. These indicators are used in comparison
to other compliance parameters since, based on distribution coefficients,
retardation factors and high concentrations in the tailings solution they
would be expected to arrive at the groundwater earlier than other
parameters.

• Mass Analysis – Volumes of tailings wastewater which would be required to
cause the concentration increase.

• Contaminant transport time of arrival to the point of exposure with
consideration of unsaturated transport through the vadose zone and
measured groundwater velocity.

• Pre-identified background concentrations and pre-identified concentration
trends per the groundwater background reports.
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• Groundwater age dating and evaluation of isotopic fingerprint analysis per
the University of Utah Groundwater Study1 at the Mill.

Numerous studies and field measurements have been conducted by EFR for the Mill, including slug
testing and/or pump testing to provide location specific permeability and groundwater velocities in the
perched aquifer. An overview of these studies can be found in the EFR Hydrogeologic Report which is
available on the Division website.

Based on the Permit requirements and stringent methods to calculate and evaluate GWCL’s in the
Permit, and perched aquifer heterogeneity, it is expected that parameters in monitoring wells will
exceed GWCL’s and need to be re-evaluated and adjusted. Particularly in situations where a
pre-identified rising trend was noted in background reports. The Division enforces these stringent
Permit requirements in order to provide a high level of protection in the perched aquifer.”

UMUT General Concern 3 – Comments Regarding the Chloroform and Nitrate/Chloride
Groundwater Plumes, Corrective Action Plans and Contamination Removal Progress
The chloroform and nitrate/chloride plumes in groundwater beneath the Mill are being monitored and
remediated per approved corrective action plans to address the contamination. To date, the groundwater
pumping program has been effective in removing substantial amounts of contamination from
groundwater as measured by EFRI and included in routine monitoring reports as mass removed.
Specifically regarding TW4-24 for example, pumping began at the well during January 2013. Since that
time, through the 3rd Quarter of 2021, a total mass of 1,071.2 lbs. of nitrate has been removed. This is a
substantial amount of contaminant mass to remove during that amount of time. It is an ongoing process
but there has been marked improvement shown in that well as demonstrated through decreased
detections in area monitoring wells.

UMUT Specific Concern 1 – Elevated Constituents in Compliance Monitoring Wells MW-30 and
MW-31

Monitoring wells MW-30 and MW-31 are located on the southern berm of the Mill Tailings Cell 2 and
north of Tailings Cell 3. MW-30 and MW-31 wells are hydraulically downgradient from portions of
Cell 2 and from the Mill processing areas. In addition, both wells are within the defined nitrate/chloride
plume, and non-compliance for nitrate and chloride are regulated through a separate consent order
(UGW12-04) issued by the Director.

As discussed above, copies of the source assessment reports for monitoring wells MW-30 and MW-31
are available on the Division website. The source assessment reports detail the results of data review
and studies which show that the Mill is not the source of GWCL exceedances studied in these reports.
The reviews discuss relative concentrations of monitoring constituents at these wells, comparison of
expected mass of contaminants that would be expected if the source were from tailings wastewater, as
well as indications of impacts from the nitrate/chloride plume. The Division notes that studies to
eliminate the Mill tailings as the source of groundwater contaminant elevations were rigorous and

1 Hurst, T.G. and Solomon, D.K., 2008, Summary of Work Completed, Data Results, Interpretations and Recommendations
for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa Uranium Mill Located Near Blanding Utah,
Prepared by University of Utah Department of Geology and Geophysics.
Page 8 of 9

provide multiple lines of evidence to support review findings. The Permit process regarding constituent
monitoring and compliance is clearly defined in the Permit and is discussed in this letter above. EFRI
has complied with the Permit requirements and provided required information and data to support all
review findings.

UMUT Specific Concern 2 – Elevated Constituents in Monitoring Well TW4-24

Monitoring well TW4-24 is currently used as a pumping well as part of the approved remediation
program for the nitrate/chloride plume. Because it is a pumping well and it is located in the middle of
the nitrate/chloride plume, it is expected to have highly variable monitoring results. It is also expected
that concentrations of some constituents will be above groundwater quality standards. As stated in the
October 28, 2021, UMUT letter, the Division agreed with the UMUT that TW4-24 should be sampled
for all 38 constituents. In the Permit renewal, monitoring well TW4-24 was added as a general
monitoring well and it was clearly stated that the results from this well would not be used for
compliance purposes. The rational for the designation of TW4-24 being a general monitoring well by
the Division can be found in the Permit Renewal Statement of Basis and is also included here:

“As part of the approved chloroform corrective action plan, EFR is required to analyze the groundwater
flow directions and chloroform capture zones on a quarterly basis. This analysis is intended, in a large
part, to ensure full hydraulic capture of the chloroform plume, but also serves to analyze impacts to the
local groundwater flow directions.

DWMRC notes that in the event that a tailings cell were to breach and discharge solution into the
groundwater and if the discharged solution were then transported eastward toward the chloroform
extraction project (due to the extraction wells), then any contamination potentially diverted in that
direction would be captured by the chloroform extraction wells then be discharged either into the
milling process or tailings cells.

Per DWMRC review of the current Facility groundwater contour map, quarterly chloroform reports,
and the Ute Mountain Ute request it was noted that:

• It is understood that the Ute Mountain Ute Tribe requests that all monitoring wells
installed for the GCAP within 500 feet of the Facility boundary be sampled and analyzed
for all compliance parameters; however, monitoring wells should be selected for
compliance monitoring which will provide early detection of potential contamination
from the tailings cells. Requiring that all monitoring wells be required for sampling
within a certain distance of the property boundary is not reasonable in the case of
tailings cell discharge. The purpose of those monitoring wells and current required
parameters is appropriate, since the objective is to determine migration of the
chloroform plume.
• Likewise, it is not reasonable to require that any GCAP monitoring wells which have had
two consecutive exceedances of GCAP concentrations be sampled for the entire list of
compliance parameters. The GCAP monitoring wells have been installed to monitor the
chloroform plume and therefore it is likely that several of the wells will have multiple
consecutive exceedances of the parameters for that objective. This does not necessitate a
full suite of monitoring to detect potential discharges from the tailings cells. As per the
bullet above, any wells selected should be those that will provide early detection of
potential contamination.

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• Per Director review of the groundwater elevation contours, capture zones (chloroform
and nitrate) and monitoring well locations, it does seem reasonable to require that
monitoring well TW4-24 be included in the permit as a general monitoring well and
sampled on a semi-annual frequency for all parameters listed under Table 2 of the
Permit. It is noted that monitoring well TW4-24 is currently being used as a pumping
well for the nitrate corrective action plan, is located within the chloroform plume, and
will exceed GWQS’s for parameters associated with those projects. Therefore, although
the Director agrees that including monitoring well TW4-24 as a general monitoring well
is reasonable based on groundwater contours during pumping, it is also expected that the
monitoring results will be highly variable and should not be used for direct compliance
purposes.”

Conclusion

Based on the Division’s review and evaluation of the Letter, the Division has concluded that EFRI is
currently in compliance with the groundwater monitoring and compliance requirements of the Permit as
well as the applicable Corrective Action Plans, State and Federal rules and regulations. There is no
known groundwater contamination related to a tailing’s solution source. Groundwater contamination
associated with the chloroform and nitrate/chloride plumes are related to legacy sources and are not
related to a tailings source. The contamination related to those plumes is being appropriately monitored
and remediated according to approved Corrective Action Plans, including removal of significant
contaminant mass. This legacy shallow groundwater contamination is confined to the Mill’s operational
footprint and property boundary, and there are no offsite environmental receptors being impacted by the
contamination.

Finally, the Division monitors the financial assurance EFRI has posted with respect to the shallow
groundwater contamination under the approved Corrective Action Plans and has determined that the
financial assurance is adequate to ensure remediation of this contamination.

The Division considers that the matters raised in the Letter have been addressed. If there are future
modifications to the Permit, the UMUT will have the opportunity to provide comments and pursue any
legal rights and remedies as to any future agency actions. The Division does not consider this response
letter to constitute as an agency action. Rather, it is the Division’s attempt to provide consultation by
providing specific, detailed responses to the technical and regulatory issues raised in the Letter.

If you have questions regarding this letter, please call Tom Rushing at [phone].

Sincerely,

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

DJH/TR/wa

c: Grant Sunada, Health Director, San Juan Public Health Department
Ronnie Nieves, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer