DRC-2019-011696 - 0901a06880b25db3

DRC-2019-011696 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
L. Scott Baird Interim Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director
October 1, 2019 Kathy Weinel, Quality Assurance Manager CERTIFIED MAIL
Energy Fuels Resources (USA) Inc. RETURN RECEIPT REQUESTED
225 Union Blvd, Suite 600 7004 1160 0005 5671 3815 Lakewood, CO 80228 RE: Energy Fuels Resources September 26, 2019, Plan for Installation of Groundwater Monitoring
Well No. MW-24A at the White Mesa Uranium Mill
Radioactive Materials License No. UT1900479 Utah Groundwater Discharge Permit No. UGW370004 (Permit) Dear Ms. Weinel:

The Utah Division of Waste Management and Radiation Control (DWMRC) has reviewed the Energy Fuels Resources (EFR) September 26, 2019 Plan for Installation of Groundwater Monitoring Well MW-24A (EFR Plan). The EFR Plan was submitted in response to a previous DWMRC review of a June 27, 2019 EFR Source Assessment Report for several constituents in the White Mesa Uranium Mill Monitoring Well MW-24 and a follow-up telephone conversation on September 3, 2019.
The intention of the installation of MW-24A is to determine whether MW-24 groundwater constituents in out of compliance status, some of which appear to be showing anomalous increasing trends, are due to issues regarding monitoring well MW-24 design and/or construction issues. Per the EFR Plan, MW-24A will be installed approximately 10 feet northwest of MW-24. The proposed well location is
included as Figure 1 and per DWMRC review the location appears to be appropriate. Installation of MW-24A will allow for tandem sampling comparisons with MW-24 and will allow more monitoring data to be collected for better evaluation of the trending constituents and potential well design/construction issues.
Conditional Approval: The EFR Plan is approved with the following conditions: 1. MW-24A must be properly designed, installed, screened/completed, and developed in
(Over)

accordance with Part I.E.4 of the Permit.
2. The MW-24A well screen will fully encompass the Burro Canyon Formation saturated zone. 3. MW-24A will be designed to be monitored for the full suite of monitoring constituents listed in the Permit Table 2. 4. Per the EFR Plan will be installed and operational within 90 days of EFR receipt of this approval
letter.
5. Per the EFR Plan an As-built report for MW-24A will be submitted to DWMRC within 60 days of well completion as required by the Permit Part I.F.6. The As-built report shall comply with the requirements of the Permit Part I.F.6. 6. EFR shall provide at least a 14 day written notice prior to field drilling and construction of MW-
24A to allow DWMRC to observe all drilling and well installation activities.
7. Per the EFR Plan “Analytical data for MW-24A will be included in the routine quarterly
groundwater monitoring reports. Discussion of the analytical results and the conclusions resulting from the tandem monitoring program will be submitted to DWMRC under separate cover at the end of 8 quarters of sampling.”

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

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

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: Kathy ~inel, Quality Assurance Manager
, Energyk"uels Resources (USA) Inc.
· 225 Union Blvd, Suite 600
. Lakewood, CO 80228 Service 1ype
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Department of Environmental Quality
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P.O. Box 144880
Salt Lake City, UT 84114-4880
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