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Effluent Limitation Exceedances <br />November 2008 <br />Parameter Limit Type Effluent <br />Limitation Analytical <br />Result <br />Selenium 30-day average 20 gg/L 28 gg/L <br />A total of 80,000 gallons of water were treated and discharged in November 2008. This <br />is well below the permitted discharge volume of 900,000 gallons (based on the 0.03 mgd <br />permit limit over 30 days). <br />One exceedance occurred for selenium of the 30-day average effluent limitation. As <br />indicated in prior letters, Energy Fuels has employed various treatment processes and <br />continues to research viable selenium treatment alternatives. An ionic-exchange bench <br />test showed some effectiveness, although not as much as expected. Among other <br />alternatives being studied are an iron cementation process, a passive bioreaction process, <br />alternative ion exchange resins, and a nanofiltration process. There are several <br />challenges that a viable alternative must meet to be practical for use at the Whirlwind <br />Mine Treatment Plant. Some of the requirements for a viable alternative are: 1) treatment <br />at or near the design flow rate of 20 gpm, 2) effective in below freezing temperatures, 3) <br />meets the size restrictions of the site, 4) and will not cause failure of other discharge <br />permit limitations such as pH and WET tests. Energy Fuels is currently evaluating which <br />of these processes can best meet these requirements and may conduct further bench tests <br />in January 2009. <br />Dissolved iron, sulfate, and nitrate levels are being monitored in the discharge samples at <br />the request of WQCD and the Division of Reclamation, Mining and Safety. Dissolved <br />iron in the discharge sample was less than 0.03 mg/L, sulfate was detected at 53 mg/L, <br />and nitrate was detected at 4.5 mg/L. <br />Please contact me at (303) 974-2151 if you need any additional information. <br />Sincerely, <br />Zach Rogers <br />Cc: Russ Means (DRMS) <br />Scott Gerwe (BLM - Grand Junction Field Office) <br />Jeff Osborn, Frank Filas, Marty Olson (Energy Fuels) <br />Attachment: November 2008 DMR <br />i ?rgy Fuels, inc. 44 Union Blvd, Sufic 600 <br />et b,vm xticrgyfiicis.eoin Lakewood, Colorado 80228 <br />Phone: 303-974-2140 <br />Pax: 303-974-2141