DRC-2019-001081 - 0901a068809a30d9

DRC-2019-001081 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 Rusty Lundberg Acting Director
February 1, 2019
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228
RE: Energy Fuels Resources, White Mesa Uranium Mill; November 13, 2018 3rd Quarter 2018
Groundwater Monitoring Report; November 14, 2018 Notice Pursuant to Part I.G.1(a), and; November 14, 2018 Request to Return Certain Groundwater Monitoring Parameters to Baseline Monitoring Frequency. Utah Groundwater Discharge Permit No. UGW370004
Dear Ms. Weinel: The Utah Division of Waste Management and Radiation Control (DWMRC) has completed a review of the following Energy Fuels Resources (USA) Inc. (EFR) documents:
1. EFR, November 13, 2018, Transmittal of 3rd Quarter 2018 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill. 2. EFR, November 14, 2018, State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill – Notice Pursuant to Part I.G.1(a).
3. EFR, November 14, 2018, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill – 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 located in
Blanding, Utah. The following items are provided as a result of completing our review. (Over)

EFR 3rd Quarter 2018 Groundwater Monitoring Report – Request for Information: A deviation from the Mill Groundwater Monitoring quality Assurance Plan (QAP) was noted during review of the 1st Quarter 2018 Report regarding the current method used for gross alpha analysis by GEL laboratories. Based on a follow-up discussion regarding this issue between DWMRC and EFR,
EFR contacted GEL laboratory and informed them that the analytical method being used for analysis of
gross radium alpha does not conform to the current Utah certified method listed for GEL. GEL listed the method used as “EPA 900.1 Mod” but per DWMRC review, only has current Utah certification for method 903.0.
Per the EFR conversation with GEL it was decided that EFR would update the QAP to include method
903.0 and that GEL would use that method. This approach would not require GEL to obtain Utah certification for method 900.1. DWMRC concurred with this approach after review of method 903.0 and approved an updated QAP which includes an option to use method 903.0 for gross radium alpha. These actions took place during the second quarter of 2018 and it was expected that the laboratory
would change to the certified method for analysis of the third quarter 2018 groundwater samples.
Contrary to this, per DWMRC review of the Report, tables G-4A and G-4B, EFR lists the method used by the laboratory as E900.1. The GEL laboratory data sheets list the method used for “GFPC, Total Alpha Radium, Liquid” as “EPA900.1 Mod/EPA903.0 Mod.” Therefore, it does not appear that GEL is
using the current Utah certified method but is using another modified method which is unclear.
Please provide a response to this issue within 30 calendar days including; (1) a summary of the EFR correspondence with GEL regarding the use of an apparent un-certified method for gross alpha, and (2) an explanation as to why method 900.1 is being used for gross alpha after notification that the current
EFR contract laboratory does not have Utah certification for that method.
EFR Notice Pursuant to Part I.G.1(a) – Close-out: Based on a review of the EFR November 14, 2018 Notice, it appears that all requirements of the Permit
were met. Therefore, the review is hereby closed out.
EFR August 3, 2018 Request to Remove Certain Parameters from Accelerated Monitoring Based on review of the EFR November 14, 2018 Request, EFR requests that certain monitoring well
parameters be returned to baseline monitoring as listed on the table below:

Monitoring Well Parameter Number of Consecutive
Sample Results Below the GWCL
Baseline Monitoring
Frequency
MW-14 Fluoride 9 Quarterly
MW-25 Cadmium 9 Quarterly MW-25 Fluoride 9 Quarterly

It was noted that the above monitoring well parameter has had sample results below the Permitted
Ground Water Compliance Limits (GWCLs) for the most recent nine consecutive accelerated sampling events. Per past DWMRC 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 well and associated parameter listed in the table above is hereby approved.

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

Rusty Lundberg, Acting Director Division of Waste Management and Radiation Control RL/TR/kb c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer