DRC-2014-005383 - 0901a068804925fd

State of Utah
GARY R. HERBERT
Governor
SPENCER J COX
Lieutenant Governor
September 15, 2014
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-005383
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Energy Fuels Resources (USA) Inc. 2n Quarter 2014 Groundwater Monitoring Report,
Groundwater Quality Discharge Permit No. UGW3 70004
Dear Ms. Weinel:
The Utah Division of Radiation Control (DRC) has reviewed: 1. The Energy Fuels Resources (USA) Inc.
("EFR") August 15, 2014 Td Quarter 2014(April through June) Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill; 2. The EFR August 11,
2014 State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill
("GWDP") - Notice Pursuant to Part I.G.I (a); and, 3. The EFR August 11, 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 below:
EFR August 11, 2014 Request to Return Monitoring Well MW-28 Manganese, MW-29 Manganese, and
MW-25 Fluoride to Baseline Monitoring Frequency:
Per the EFR August 11, 2014 Request, EFR provides information regarding compliance monitoring at
wells MW-28 for manganese, MW-29 for manganese, and well MW-25 for fluoride. These
wells/parameters are currently required to be sampled on an accelerated basis due to out-of-compliance
status.
MW-28 Manganese
The August 11, 2014 request for monitoring frequency reduction for manganese in MW-28 states that
monitoring results "have been below the Groundwater Compliance Limit ("GWCL ") specified in the
GWDP for eight consecutive sampling events since Q2 2012." Per DRC review of the request and past
sampling result it appears that the last eight consecutive accelerated samples for manganese in monitoring
well MW-28 have been below the GWCL. Based on past approvals of return to baseline monitoring, this
request is consistent and return to baseline monitoring is appropriate.
MW-29 Manganese
The EFR August 11, 2014 request for monitoring frequency reduction for manganese in MW-29 is based
on the eight most recent consecutive monitoring results showing concentrations below the GWCL. Per
195 North 1950 West • Salt Lake City, UT
Mailing Address P O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^1097 • T D.D [phone]
www deq Utah gov
Printed on 100% recycled paper
Kathy Weinel
Page 2
DRC review of the monitoring results it appears that return to baseline monitoring frequency is
appropriate.
MW-25 Fluoride
The EFR August 11,2014 request for monitoring frequency reduction for fluoride in MW-25 is based on
the eight most recent consecutive monitoring results showing concentrations below the GWCL. Per DRC
review of the monitoring results it appears that return to baseline monitoring frequency is appropriate.
Therefore, the wells/parameters listed on the table below are approved to be returned to the baseline
monitoring frequency:
MW-28 Manganese Semi-Annual
MW-29 Manganese Semi-Annual
MW-25 1 Fluoride | Quarterly
EFR 2nd Quarter 2014 Groundwater Monitoring Report:
DRC reviewed the following items regarding the EFR 2nd 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 2nd Quarter 2014 Report recognizes the telephone agreement regarding the timeline for EFR
to submit updated compliance notice and initiate accelerated monitoring.
DRC notes that monitoring well MW-28 was damaged prior to groundwater sampling, and that
exceedances of cadmium, uranium and vanadium GWCL's in that well during the 2" quarter 2014 may be
the result of contamination after the damage.
Based on the findings above it appears that the 2nd Quarter 2014 Groundwater Report complies with the
Permit requirements; therefore, the review is hereby closed out.
Kathy Weinel
Page 3
If you have any questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Rusty LundBCTg
Director
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