DRC-2022-021187 - 0901a068810eb3e0

DRC-2022-021187 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

September 23, 2022

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228

RE: Energy Fuels Resources (USA) Inc., White Mesa Uranium Mill September 21, 2022,
Monitoring Well MW-41 Reinstallation Proposal, White Mesa Uranium Mill.
Utah Groundwater Discharge Permit No. UGW370004

Dear Ms. Weinel:

The Utah Division of Waste Management and Radiation Control (Division) has reviewed the
Energy Fuels Resources (USA) Inc. (EFRI), September 21, 2022, document titled “Monitor Well
MW-41 Reinstallation Proposal White Mesa Uranium Mill” (Letter). The reinstallation of recently
installed monitoring well MW-41 is warranted since the constructed well screen includes approximately
7.9 feet of open screen above the static water level. Per previous planning and discussions between
EFRI and the Division, it was agreed that the MW-41 well screen should be completely below the static
water level to eliminate potential geochemical impacts from aeration/oxygenation of the groundwater in
the vicinity of the well. Monitoring Well M-41 has been installed as part of the source investigation of
out-of-compliance (OOC) parameters at monitoring well MW-24 (located directly upgradient from
MW-41); and to provide an additional groundwater compliance monitoring point.

The Letter states that the existing well casing will be removed by over drilling the borehole with a larger
bit. EFRI will leave the borehole open for 48-72 hours to ensure that water level in the well stabilizes
and can be measured. The well will be completed with a new screened interval completely below the
static water level. Additionally, an evaluation of the filter pack material and pore size will be done to
ensure that the material used is appropriate and effective.

Division Advisory – The Letter notes that hydraulic testing (slug test) of the currently installed MW-41
was completed by EFRI and is included in an as-built report dated September 8, 2022. That as-built
report was submitted to the Division (DRC-2022-020926). The Letter states that hydraulic testing will
not be repeated on the reinstalled MW-41 since the slug testing is a measure of the formation properties
(Over)
which will not change. Please be advised that the Division will conduct a review of the
September 8, 2022, MW-41 as built report, and the revised as built report at the same time. If it is
determined that additional activities need to be conducted, including potential re-testing of hydraulic
properties, then comments will be made during that review.

Based on Division review of the Letter, the planned MW-41 reinstallation is approved.

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

Sincerely,

Phil Goble, Uranium Mills and Radioactive Materials Section Manager
Division of Waste Management and Radiation Control

PRG/TR/wa

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