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Home My WebLink AboutDRC-2015-008287 - 0901a068805b18f2ENERGYFUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www energyfuels.com November 18, 2015 Div of Waste Management and Radiation Control Mr. Scott Anderson VIA PDF AND FEDERAL EXPRESS NOV 2 0 2015 Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status Dear Mr. Anderson: A number of groundwater monitoring constituents have been placed on accelerated monitoring status under Part I.G.I of the Energy Fuels Resources (USA) Inc. ("EFRI") Ground Water Discharge Permit No. UGW370004 ("GWDP"). Part I.G.I provides that such accelerated monitoring shall continue until compliance status of the facility can be determined by the Director. Based on the accelerated monitoring results to date, EFRI requests the Director make a determination that accelerated monitoring cease at this time for cadmium in MW-25 and ammonia in MW-30 for the reasons stated below: • MW-25 cadmium results have been below the Groundwater Compliance Limit ("GWCL") specified in the GWDP for ten consecutive sampling events since Q4 2014. Per the DWMRC, eight consecutive sample results below the GWCL are needed for the discontinuance of accelerated monitoring. • MW-30 ammonia results have been within the GWCL range specified in the GWDP for eight consecutive sampling events since the Q4 2014 sampling event. Per the DWMRC, eight consecutive sample results below the GWCL are needed for the discontinuance of accelerated monitoring. Once removed from accelerated monitoring status, these constituents, like all other constituents, would be subject to future accelerated monitoring under Part I.G. 1 of the GWDP, should circumstances warrant. To assist in your evaluation of the foregoing, we have included a summary of the accelerated sampling results since the initial sample result that triggered accelerated monitoring in Table 1. The analytical laboratory reports for the foregoing results up to and including June 2015 are included in the Quarterly Groundwater Monitoring Reports, all of which have been provided to DWMRC. Copies of the analytical laboratory reports for the results for July 2015 through September 2015 are provided in the 3rd Quarter 2015 Groundwater Monitoring Report and are also included with this letter for your convenience. It is important to note that the 3rd Quarter 2015 monitoring results included with this letter Letter to Scott Anderson Removal of Parameters from Accelerated Monitoring November 25, 2015 Page 2 have been evaluated per the DWMRC approved QAP and the GWDP and all field and laboratory quality control parameters are acceptable. The evaluations of the 3rd Quarter data are included in the 3rd Quarter 2015 Groundwater Monitoring Report. If you have any questions or require any further information, please contact the undersigned. Kathy Weinel Quality Assurance Manager cc: David C. Frydenlund Harold Roberts Logan Shumway David Turk Scott Bakken Yours truly Analytical Results and Field Sampling Sheets for the Wells that are the Subject of this Request Table 1 Summary of Accelerated Sample Results with Eight or More Results in Compliance Well ID Constituent GWCL Sample Date Sample Result MW-25 Cadmium (ug/L) 1.5 Q4 2014* December 2014 January 2015 Ql 2015 March 2015 Q2 2015 May 2015 June 2015 July 2015 Q3 2015 September 2015 1.57 1.27 1.44 1.33 1.37 1.27 1.38 1.42 1.43 1.41 1.31 MW-30 Ammonia (mg/L) 0.14 Q4 2014* Ql 2015 March 2015 Q2 2015 May 2015 June 2015 July 2015 Q3 2015 September 2015 0.30 <0.05 <0.05 0.0960 0.0824 0.0997 0.0692 <0.05 <0.05 *Last sample result outside of GWCL limits. INORGANIC ANALYTICAL REPORT Client: Energy Fuels Resources, Inc. Project: July Monthly Groundwater 2015 Lab Sample ID: 1507150-002 Client Sample ID: MW-25 07062015 American West „ „ . „ „„, ANAiYTiCAL i.»BoRAToft116 Collection Date: 7/6/2015 1405h Received Date: 7/9/2015 1600h Analytical Results Contact: Garrin Palmer DISSOLVED METALS 3440 South 700 West ComPound Salt Lake City, UT 84119 Cadmium Uranium Units Date Date Method Reporting Prepared Analyzed Used Limit Analytical Result Qua! mg/L 7/10/2015 1054h 7/13/2015 1712h E200.8 0.000500 0.00143 mg/L 7/10/2015 1054h 7/13/2015 1758h E200.8 0.000300 0.00625 Phone: (801)263-8686 Toll Free: (888) 263-8686 Fax: (801) 263-8687 e-mail: awal@awal-labs.com web: www.awal-Iabs.com Kyle F. Gross Laboratory Director Jose Rocha QA Officer Report Date: 7/22/2015 Page 6 of 29 All analyses applicable to the CWA. SDWA. and RCRA arc performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information; This report is provided for the exclusive use of the addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sate of any product or process, or in connection with the rc-publicalion of litis report for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysts in good faith and according to the rules of the trade and of science. INORGANIC ANALYTICAL REPORT American West ANAIYTICA1 L A n OB ATOP I [ s 3440 South 700 West salt Lake City, UT 84119 Phone: (801)263-8686 Toll Free: (888) 263-8686 Fax: (801)263-8687 ;-mail: awal@awal-labs.com web: www.awal-labs.com Kyle F. Gross Laboratory Director Jose Rocha QA Officer Client: Project: Lab Sample ID: Client Sample ID: Collection Date: Received Date: Analytical Results Energy Fuels Resources, Inc. 3rd Quarter Groundwater 2015 1508249-003 MW-25 08102015 8/10/2015 HOOh 8/13/2015 1015h Contact: Garrin Palmer DISSOLVED METALS Compound Arsenic Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Molybdenum Nickel Potassium Selenium Silver Sodium Thallium Tin Uranium Vanadium Zinc Units Date Date Method Reporting Prepared Analyzed Used Limit Analytical Result Qual mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/14/2015 1325h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/13/2015 1328h 8/26/2015 2232h 8/26/2015 2324h 8/26/2015 2232h 8/19/2015 1656h 8/26/2015 2232h 8/26/2015 2232h 8/26/2015 2232h 8/26/2015 2324h 8/26/2015 2324h 8/19/2015 1656h 8/26/2015 2232h 8/19/2015 1247h 8/26/2015 2232h 8/26/2015 2232h 8/19/2015 1754h 8/26/2015 2232h 8/26/2015 2232h 8/19/2015 1656h 8/26/2015 2324h 8/26/2015 2232h 8/26/2015 2324h 8/19/2015 1754h 8/26/2015 2232h E200.8 E200.8 E200.8 E200.7 E200.8 E200.8 E200.8 E200.8 E200.8 E200.7 E200.8 E245.1 E200.8 E200.8 E200.7 E200.8 E200.8 E200.7 E200.8 E200.8 E200.8 E200.7 E200.8 0.00500 0.000500 0.000500 50.0 0.0250 0.0100 0.0100 0.0300 0.00100 50.0 0.0100 0.000500 0.0100 0.0200 1.00 0.00500 0.0100 50.0 0.000500 0.100 0.000750 0.0150 0.0100 < 0.00500 < 0.000500 0.00141 365 < 0.0250 < 0.0100 < 0.0100 < 0.0300 < 0.00100 120 1.46 < 0.000500 0.0132 < 0.0200 10.3 < 0.00500 < 0.0100 300 0.000836 < 0.100 0.00639 < 0.0150 0.0173 Report Date 8/28/2015 Page 10 of 53 All analyses applicable lo theCWA. SDWA, and RCRA are performed in accordance lo NELAC protocols. Pertinent sampling information is located on the attached COC Confidential Business Information: This report is provided lor the exchsn e use of the addressee Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection vvilh the advertisement, promotion or sale of any product or process, or in connection vuth ihe re-puhlicaiion of this repo American West ANALYTICAL I ABORATORICS INORGANIC ANALYTICAL REPORT Client: Energy Fuels Resources, Inc. Project: September Groundwater 2015 Lab Sample ID: 1509381-002 Client Sample ID: MW-25_09152015 Collection Date: 9/15/2015 1130h Received Date: 9/18/2015 1045h Analytical Results Contact: Garrin Palmer DISSOLVED METALS 3440 South 700 West C°mP°und Salt Lake City, UT 84119 Cadmium Uranium Units Date Date Method Reporting Prepared Analyzed Used Limit Analytical Result Qual mg/L 9/21/2015 1405h 9/22/2015 1303h E200.8 0.000500 0.00131 mg/L 9/21/2015 1405h 9/22/2015 1303h E200.8 0.00300 0.00620 Phone:(801)263-8686 Toll Free: (888) 263-8686 Fax:(801)263-8687 e-mail: awal@awal-labs.com web: www.awal-labs.com Kyle F. Gross Laboratory Director Jose Rocha QA Officer Report Date: 10/2/2015 Page 6 of 29 All analyses applicable lo the CWA. SDWA. and RCRA arc performed in accordance toNELAC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information' This report is provided for the exclusive use of the addressee. Privileges of subsequent use of the name of this compam or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with the re-publication of this report for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of the trade and of science. INORGANIC ANALYTICAL REPORT Client: Energy Fuels Resources, Inc. Contact: Garrin Palmer Project: July Monthly Groundwater 2015 Lab Sample ID: 1507150-004 f -.;L""™L Client Sample ID: MW-30 07072015 Arn6nc3n West — AN*ivTiCAt LABORATORIES Collection Date: 7/7/2015 lOOOh Received Date: 7/9/2015 1600h Analytical Results Date Date Method Reporting Analytical 3440 South 700 West Compound Units Prepared Analyzed Used Limit Result Qual Salt Lake City, UT 84119 Ammonia (as N) mg/L 7/21/2015 i253h 7/21/2015 i63ih E350.I 0.0500 0.0692 ' Chloride mg/L 7/20/2015 2347h E300.0 100 145 Nitrate/Nitrite (as N) mg/L 7/15/2015 i438h E353.2 1.00 15.3 Phone' (801) 263 8686 '" ^alr'x SP'^ recovery indicates matrix interference. The method is in control as indicated by the LCS. Toll Free: (888) 263-8686 Fax: (801)263-8687 e-mail: awal@awal-labs.com web: www.awal-labs.com Kyle F. Gross Laboratory Director Jose Rocha QA Officer Report Date: 7/22/2015 Page 13 of 29 Alt analyses applicable to the CWA. SDWA. and RCRA are performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information: This report is provided for OV exclusive use of the addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with die re-publication of this report for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of the trade and of science. INORGANIC ANALYTICAL REPORT American West AHilVTICftL LABORATORIES 3440 South 700 West Salt Lake City, UT 84119 Phone: (801)263-8686 Toll Free: (888) 263-8686 Fax: (801)263-8687 ;-mail: awal@awal-labs.com web: www.awal-labs.com Kyle F. Gross Laboratory Director Jose Rocha QA Officer Client: Energy Fuels Resources, Inc. Project: 3rd Quarter Groundwater 2015 Lab Sample ID: 1508249-005 Client Sample ID: MW-30_08112015 Collection Date: 8/11/2015 1105h Received Date: 8/13/2015 1015h Analytical Results Contact: Garrin Palmer Compound Units Date Date Method Reporting Prepared Analyzed Used Limit Analytical Result Qual Ammonia (as N) Bicarbonate (as CaC03) Carbonate (as CaC03) Chloride Fluoride Ion Balance Nitrate/Nitrite (as N) Sulfate Total Anions, Measured Total Cations, Measured Total Dissolved Solids Total Dissolved Solids Ratio, Measured/Calculated Total Dissolved Solids, Calculated mg/L mg/L mg/L mg/L mg/L % mg/L mg/L meq/L meq/L mg/L mg/L 8/21/2015 1300h 8/21/2015 2306h 8/14/2015 1104h 8/14/2015 1104h 8/24/2015 1845h 8/25/2015 311h 8/26/2015 1501h 8/25/2015 1901h 8/24/2015 1845h 8/26/2015 1501h 8/26/2015 1501h 8/13/2015 1245h 8/26/2015 1501h 8/26/2015 1501h E350.1 SM2320B SM2320B E300.0 E300.0 Calc. E353.2 E300.0 Calc. Calc. SM2540C Calc. Calc. 0.0500 1.00 1.00 100 0.100 -100 1.00 100 20.0 < 0.0500 262 < 1.00 165 0.247 -2.24 17.9 718 25.1 24.0 1,550 1.03 1,510 Report Date: 8/28/2015 Page 21 of 53 All analyses applicable to Ihe CWA, SDWA. and RCRA are performed in accordance to NEL AC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information: This report is provided for the exclusive use of the addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in connection with the re-publication of this report A INORGANIC ANALYTICAL REPORT Client: Energy Fuels Resources, Inc. Contact: Garrin Palmer Project: September Groundwater 2015 Lab Sample ID: 1509381-004 * Client Sample ID: MW-30 09152015 American West ..... ANAiYTtcAi LABOBATORiEs Collection Date: 9/15/2015 1530h Received Date: 9/18/2015 1045h Analytical Results 3440 South 700 West Date Date Method Reporting Analytical Compound Units Prepared Analyzed Used Limit Result Qual Salt Lake City, UT 84119 Ammonia (as N) mg/L 9/22/2015 i530h 9/23/2015 i620h E350.1 0.0500 < 0.0500 Chloride mg/L 9/23/2015 I6i9h E300.0 100 1 65 Nitrate/Nitrite (as N) mg/L 9/30/2015 i544h E353.2 1.00 17.3 Phone:(801)263-8686 Toll Free: (888) 263-8686 Fax:(801)263-8687 e-mail: awal@awal-labs.com web: www.awal-labs.com • Matrix spike recovery indicates matrix interference. The method is in control as indicated by the LCS. Kyle F. Gross Laboratory Director Jose Rocha QA Officer Report Date: 10/2/2015 Page 13 of 29 AH analyses applicable lo the CWA, SDWA. and RCRA arc performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC. Confidential Business Information: This report is provided for the exclusive use of the addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction oflhis report in connection with the advertisement, promotion 01 sale of am product or process, or in connection with the re-publication of this report for any purpose other than for the addressee will be granted only on contact. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith and according to the rules of the trade and of science.