DRC-2017-000941 - 0901a068806ab8df

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

February 22, 2017

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: January 16, 2017 Transmittal of Revised Groundwater Compliance Limits
for Manganese and Cadmium in Monitoring Well MW-3A
Groundwater Discharge Permit No. UGW370004 (Permit)
Dear Ms. Weinel:

The Division of Waste Management and Radiation Control has completed its review of the document
titled “Transmittal of Revised Groundwater Compliance Limits for Manganese and Cadmium in MW-03A” dated January 16, 2017.
The revised Ground Water Compliance Limits (GWCLs) were prepared by EFR by request of the
Division. The Division communicated its concerns via a telephone conversation and an e-mail on
December 20, 2016. Based on a review of the data sets, the Division noted that the current GWCLs for
cadmium and manganese were excessively high as affirmed by statistical evaluation. Additionally, it was noted that in accordance with the 2005 Statement of Basis for the Permit, it was intended that the
MW-3A GWCLs should be revisited after additional data had been collected.

EFR subsequently reviewed the data and submitted a January 16, 2017 Intera memo summarizing EFR’s
recalculated GWCLs for cadmium and manganese in MW-03A (received by the Division on January 18, 2017). The Division, EFR and Intera representatives discussed the memo via telephone
conference on January 11, 2017, prior to submission and agreed that the proposed revised GWCLs
appeared to appropriately reflect the current data sets, were in line with the Division’s evaluation, and
were substantially lower than the previous limits.

(Over)
DRC-2017-000941 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

MW-3A Approved Modified GWCLs

The following table summarizes the GWCLs that will be modified in the White Mesa Uranium Mill Ground Water Permit:

Well Number Parameter Current GWCL Modified GWCL Method of Analysis
MW-3A Cadmium 8.3 ug/L 3.55 ug/L Highest Historical Value
MW-3A Manganese 6,287 ug/L 383 ug/L Mean + 2α

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: Kurt Binge, Health Officer, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department