DRC-2016-011083 - 0901a0688067f423

DRC-2016-011083 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

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director

November 8, 2016

Kathy Weinel, Quality Assurance Manager CERTIFIED MAIL
Energy Fuels Resources (USA) Inc. RETURN RECEIPT REQUESTED
225 Union Blvd., Suite 600 7003 2260 0003 2353 8457
Lakewood, CO 80228

RE: Energy Fuels Resources, White Mesa Uranium Mill
August 18, 2016, 2nd Quarter 2016 Groundwater Monitoring Report
August 5, 2016 Notice Pursuant to Part I.G.1(a)
August 19, 2016 Request for Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status.
Utah Groundwater Discharge Permit No. UGW370004

Dear Ms. Weinel:

The Division of Waste Management and Radiation Control has completed review of the following
Energy Fuels Resources (USA) Inc. (EFR) documents:

1. EFR August 18, 2016, Transmittal of 2nd Quarter 2016 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, August 5, 2016, State of Utah Ground Water Discharge Permit No. UGW370004 White
Mesa Uranium Mill – Notice Pursuant to Part I.G.1(a).
3. EFR August 19, 2016, Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status.

The review was conducted to ensure compliance with all applicable parts of Utah Groundwater
Discharge Permit No. UGW370004 (Permit) issued for the White Mesa Uranium Mill (Mill).

EFR 2nd Quarter 2016 Groundwater Monitoring Report – Close-out:

Based on review of the EFR August 18, 2016 2nd Quarter 2016 Groundwater Monitoring Report, it
appears that all applicable requirements of the Permit were met, and, with the exception of monitoring
result for well MW-3 as discussed below, the submitted groundwater monitoring data is reliable.
Therefore, the review is hereby closed out.
(Over)
Monitoring Well MW-3 Agreement to Abandon Well

Several groundwater contaminant concentrations have been noted to be highly variable and
unpredictable during recent monitoring events in monitoring well MW-3, including the most recent 2nd
Quarter 2016 results. According to the 2nd Quarter Monitoring Report and the EFR August 5, 2016
Notice Pursuant to Part I.G.1(a), it was reported that manganese and tetrahydrofuran are now in out-of-
compliance status at monitoring well MW-3, and MW-3 is still in out of compliance for other
parameters including selenium, field pH, fluoride, nitrate + nitrite, sulfate, beryllium, cadmium, zinc and
thallium.

These concentration fluctuations are likely due to efforts to isolate a section of blank casing below the
monitoring well screened interval using a well packer at the bottom of the screened interval. It is likely
that the well packer material, although purportedly inert material, is reacting and causing fluctuating
contaminant concentrations. The Division has been aware of the poor well construction issues at MW-3,
and as indicated in past communication, a replacement well, well MW-3A, was installed in close
proximity to MW-3 in order to determine if the inconsistent results were valid. Based on eleven years of
monitoring results for monitoring well MW-3A, which do not show the same issues as MW-3, it has
been determined that the exceedances at monitoring well MW-3 are likely due to poor well construction,
and that based on historical contaminants found in this well, including organic chemicals (THF),
monitoring well MW-3 should be plugged and abandoned according to current State requirements for
well abandonment (Utah Administrative Code R655-4-14) by a licensed well driller. It is recommended
that the well casing be removed to ensure that any filter materials used for the well screen are
appropriately grouted and sealed as part of the abandonment procedure (R655-4-14.8 and R655-4-
14.10).

In a telephone conference between the Division and EFR representatives on November 2, 2016, it was
agreed that a plan and schedule for monitoring well MW-3 abandonment will be submitted for review
and approval within 60 calendar days of receipt of this letter.

EFR August 5, 2016 Notice Pursuant to Part I.G.1(a) – Close-out:

Based on review of the EFR May 2, 2016 Notice, it appears that all requirements of the Permit were met.
Therefore, the review is hereby closed out.

EFR August 19, 2016 Request to Remove Certain Parameters from Accelerated Monitoring

Based on review of the EFR August 19, 2016 Request, EFR requested that certain monitoring well
parameters be returned to baseline monitoring as listed on the table below:

Monitoring Well Parameter Baseline Monitoring Frequency
MW-25 Chloride Quarterly
MW-27 Sulfate
Gross Alpha
Semi-Annually
Semi-Annually
MW-35 Thallium Quarterly

It was noted that the above monitoring well parameters have had sample results below the Permitted
Ground Water Compliance Limits for the most recent eight or more consecutive accelerated sampling
events. IN accordance with past Division protocols, accelerated monitoring may be discontinued if at
least eight consecutive samples show concentrations below the GWCL. Therefore, the request to return
to baseline monitoring for the parameters/wells on the table above is hereby approved.

If you have any questions, please call Tom Rushing at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

STA/TR/ka

c: Rick Meyer, Acting Health Officer/Environmental Health Director, San Juan Public Health
Scott Hacking, P.E., DEQ District Engineer