DRC-2021-009761 - 0901a06880eeb133

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State of Utah
bgL- Wil-OCTH
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Douglas J. Hansen
Director
MEMORANDUM
TO: File
THROUGH: Phil Goble, Manager pit6 627 /-2.„(
FROM: Tom Rushing, P.G. 0/21
DATE: June 3, 2021
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 1 st Quarter 2021 Ground Water
Monitoring Report for the White Mesa Uranium Mill
Review Summary:
The Utah Division of Waste Management and Radiation Control ("DWMRC") has reviewed the
following documents submitted by Energy Fuels Resources (USA) Inc. ("EFR"):
1. EFR, May 6, 2021, Transmittal of 1st Quarter 2021 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill
(Received by DWMRC on May 11, 2021).
2. EFR, April 23, 2021, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill — Notice Pursuant to Part I.G.1(a).
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 (Mill).
1. Checklist of Significant Findings of the 1st Qtr. 2021 Report and Related Actions at the
White Mesa Uranium Mill:
1. The 1st Quarter 2021 Report was received on May 11, 2021, which was before the
due date (Permit Part I.F.1 - due date of June 1).
2. DWMRC notes that samples were analyzed by American West Analytical
Laboratories ("AWAL") with the exception of Gross Alpha, which was analyzed
by GEL Laboratories LLC, Charleston, South Carolina. DWMRC verified that the
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
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 2
laboratories have current Utah certification. It was noted that GEL laboratories has
addressed issues noted on previous reports regarding the method used for gross
alpha radium and is now reporting that method 903.0 is used. This method is now
included in the facility QAP and GEL has current Utah certification to use that
method.
3. Laboratory QA/QC flags were documented in the review period analytical data
reports from the contract laboratories and an in-house QA/QC review was
conducted by EFR regarding all field and laboratory data. Per DWMRC review it
appears that all discrepancies were self-reported by EFR.
4. Three new compliance parameters went into accelerated monitoring frequency
based on sampling during the 1st Quarter 2021: MW-26 (Carbon Tetrachloride),
MW-30 (Selenium) and MW-30 (Uranium).
2. Accelerated Monitoring and POC Wells Exceeding GWCL's:
When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL)
set forth in Table 2 of the Permit, it is in Probable Out-of-Compliance (POOC) status. According
to the Permit, EFR is then required to immediately initiate accelerated sampling of that pollutant
(see the Permit, Part I.G.1). When monitoring wells have parameters that have exceeded the
Ground Water Compliance Limit (GWCL) two or more consecutive times they are in Out-of-
Compliance (00C) status (see the Permit, Part I.G.2).
In the event a constituent is in 00C status, EFR is required to prepare and submit within 30
calendar days to the Director a plan and time schedule for assessment of the sources, extent and
potential dispersion of the contamination, and an evaluation of potential remedial action to restore
and maintain groundwater quality to ensure that Permit limits will not be exceeded at the
compliance monitoring point and that DMT or BAT will be re-established, in accordance with
Part I.G.4(c) of the Permit.
Three new compliance parameters went into accelerated monitoring frequency (POOC) based on
sampling during the 1st Quarter 2021: MW-26 (Carbon Tetrachloride), MW-30 (Selenium) and
MW-30 (Uranium). Due to the issuance of the March 8, 2021 Permit modification two
parameters will be removed from accelerated monitoring, MW-11 (Manganese) and MW-25
(Cadmium).
Current Accelerated Monitoring Status:
The table below (Table 1) lists monitoring wells with parameters currently in 00C or POOC
status and therefore required to be sampled under the accelerated monitoring requirements:
Table 1 - Wells Monitored Quarterly Accelerated to Monthly Monitorin
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-11 Class 11 water D-3 Chloride 3' Quarter 2019 November 2019
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
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Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Sulfate 3rd Quarter 2019 November 2019
Total Dissolved Solids 3rd Quarter 2020 4th Quarter 2020
Nitrate + Nitrite (as N) February 2010 May 2010
Chloroform February 2010 May 2010
MW-26(a) Class III water C-2 Chloride February 2010 May 2010
Total Dissolved Solids 3rd Quarter 2020 4th Quarter 2020
Carbon Tetrachloride 1" Quarter 2021 2" Quarter 2021
Nitrate + Nitrite (as N) February 2010 May 2010
MW-30 Class II water D-2 Chloride
Uranium
1" Quarter 2011
1st Quarter 2021
May 2011
2nd Quarter 2021
Selenium 1" Quarter 2021 2' Quarter 2021
Nitrate + Nitrite (as N) 1 st Quarter 2010 May 2010
Chloride 1st Quarter 2011 May 2011
MW-31 Class III water D-2 Total Dissolved Solids 3rd Quarter 2019 November 2019
Sulfate 3(d Quarter 2019 November 2019
Uranium 2' Quarter 2020 August 2020
D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1,2,3,4A, 4B = Cell #
a = Monitoring well MW-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annually Accelerated to Quarterly 1VIonitorin
Well Class *Position Parameter Date of First 1 Date Accelerated
Exceedance of Monitoring First
GWCL Required
MW-12 Class III water D-3 Uranium
Selenium
2nd Quarter 2017
2nd Quarter 2020
3rd Quarter 2017
3rd Quarter 2020
MW-24 Class III water D-1 Beryllium 4th Quarter 2017 ls( Quarter 2018
Cadmium 2' Quarter 2018 3rd Quarter 2018
Thallium 2' Quarter 2018 3rd Quarter 2018
Field pH 2' Quarter 2018 3rd Quarter 2018
Fluoride 4th Quarter 2018 3rd Quarter 2019
Nickel 4th Quarter 2018 3rd Quarter 2019
Manganese 4th Quarter 2019 1" Quarter 2020
Sulfate 1" Quarter 2020 3rd Quarter 2020
Gross Alpha 4th Quarter 2020 3rd Quarter 2021
MW-27 Class III water U-1 Nitrate + Nitrite (as N) 2nd Quarter 2010 3rd Quarter 2010
Chloride 2nd Quarter 2010 3rd Quarter 2010
Cadmium 2" Quarter 2014 2' Quarter 2014
MW-28 Class III water D-1 Uranium 2" Quarter 2014 2" Quarter 2014
Gross Alpha 4th Quarter 2018 3rd Quarter 2019
Selenium 2nd Quarter 2019 3rd Quarter 2019
MW-29 Class III water D-2 Uranium 4th Quarter 2020 3rd Quarter 2021
MW-32 Class III water C-2 Chloride 1" Quarter 2015 2' Quarter 2014
* D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A, 4B = Cell #
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
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Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status
as of the 1st Quarter of 2021. EFR is required to notify the DWMRC on a quarterly basis
regarding wells and parameters which went into accelerated monitoring during the period [Part
I.G.1(a), Accelerated Monitoring Status Reports (AMSR)]. For the lst Quarter 2021 monitoring,
the AMSR was dated April 23, 2021. Review of the AMSR is included in a separate section
below.
3. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection:
As stated in Section 6.2.7 of the EFR Quality Assurance Plan (QAP), Rev. 7.6, EFR has a choice
regarding purge volumes as follows:
"1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after recovery"
Per DWMRC review of the Report, the following purge methods were used during the 1st Quarter
2021 (including accelerated samples). Purge methods and volumes are summarized in Tab G, on
Table G-1A and G-1B of the Report:
Quarter # Purged 2 Casing # Purged to Dryness # Purged 3 Casing Volumes
Volumes
1st Qtr. 2021 21 3 3 (continuous pumping)
When purging two casing volumes, the QAP directs EFR to first calculate the amount of time to
evacuate two casing volumes and then to pump for that length of time. Per DWMRC cross-check
of the field data sheets for each of the reports reviewed, it appears EFR correctly calculated the
well casing volumes and evacuated the required two volumes (when 2 casing volume method
selected) in monitoring wells prior to sample collection during the 1st Quarter 2021 monitoring
period. Volumes are calculated according to measured pump rates and can be verified by
calibration marks on the collection containers.
During the 1st Quarter of 2021 monitoring period three wells were pumped or bailed to dryness.
In cases where wells are evacuated to dryness the QAP Rev. 7.4 (Attachment 2-3) requires that:
"(vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is available to fill
sample containers.
Upon arrival at the well after recovery or when sufficient water is available for sampling measure
depth to water and record on the Field Data Worksheet.
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
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Take one set of measurements of field parameters for pH, specific conductance and temperature
only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific conductance and
temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within 10% RPD the
samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not within 10% RPD,
dispose of the sample aliquots, and purge the well again as described above.
Repeat this process if necessary, for three complete purging events. If after the third purging the
event, the parameters of pH, specific conductance and temperature do not stabilize to within 10%
RPD, the well is considered sufficiently purged and collected samples can be submitted for
analysis."
DWMRC staff verified that in cases where the monitoring well was evacuated to dryness and
samples were collected, the number of gallons evacuated was recorded in compliance with the
QAP. Additionally, depth to water before sample collection was recorded on all applicable field
data worksheets which resolved past DWMRC comments.
4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind
Duplicate Analysis:
DWMRC conducted a review of the blind duplicate samples collected during the 1st Quarter 2021.
Per the QAP, one blind duplicate must be collected with each sample batch. DWMRC confirmed
that one blind duplicate was collected for each batch — 3 total during the quarterly event — one
with the baseline samples (MW-14/MW-65 on 1/13/2021), and two with the accelerated samples
(MW-30/MW-65 on 2/10/2021 and MW-25/MW-65 on 3/9/2021).
The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the
measured concentrations are less than 5 times the required detection limit (Standard Methods,
1998)."
Per the QAP, if any of the samples do not meet the comparison criteria (and are not qualified
according to the 5 times method detection limit criteria) then EFR is required to conform to the
procedures for corrective action listed as follows:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation errors,
and,
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
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3. If the samples are still within holding time, the QA Manager may request the laboratory re-
analyze the affected samples.
Per DWMRC cross check of the blind duplicate samples collected and analyzed during the 1 st
Quarter 2021 sampling event all results conform to the Permit requirements (within 20% RPD). .
Radiological duplicate sample results met duplicate counting error requirements in the currently
approved QAP for the 15t Quarter 2021. No additional action is required.
5. Analytical Laboratories Used by EFR Certified by State of Utah to Perform Analysis
for all Analytes:
The analytical laboratories (GEL Laboratories LLC, Charleston, SC and American West
Analytical Laboratories, Salt Lake City, UT) were contracted by EFR to perform analysis on the
samples collected during the 15t Quarter 2021. Per DWMRC review of the National
Environmental Laboratory Accreditation Management System Website (cross check of laboratory
certification for specific parameters) it appears that the EFR contract laboratories were certified to
perform analysis for the specified parameters (Per the laboratory data sheets):
GEL Laboratories LLC Current Certification
Basic Details
Name GEL Laboratories, LLC
Type of Lab Not Specified
TNI Lab Code TNI00188
EPA Code SC00012
State ID 8037697376
Website
Extended Details
Primary AB responsible
for lab demographics Utah Department of Health
GIS Location
Description
Comments
Effective Date n/a
Commercial Samples Yes
Active Yes
Location Address
Company
Contact Carey J. Bocklet
Address 1 2040 Savage Road
Address 2
City Charleston
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
State South Carolina
Zip 29407-
Country USA
Phone [phone]
Fax [phone]
Email [e-mail]
American West Analytical Laboratories Current Utah Certification
Basic Details
Name American West Analytical Laboratories
Type of Lab Not Specified
TNI Lab Code TNI01955
EPA Code UT00031
State ID 8012638686
Website www.awal-labs.com
Extended Details
Primary AB responsible
for lab demographics Utah Department of Health
GIS Location
Description
Comments
Effective Date n/a
Commercial Samples Yes
Active Yes
Location Address
Company
Contact Kyle Gross
Address 1 3440 South 700 West
Address 2
City Salt Lake City
State Utah
Zip 84119-
Country USA
Phone [phone]
Fax [phone]
Email kyle @awal-labs.com
6. Laboratory Report Turn Around Times:
Per DWMRC review of EFR Table 1 included in the 1st Qtr. 2021 Report, it was noted that
laboratory report turnaround times (from date of EFR sample submission to the contract
laboratory) for normal frequency monitoring was approximately 30 day for all samples (not
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
including re-submission/corrected reports). Per DWMRC review it was noted that EFR acted
quickly to identify any deficiencies in the reports and request corrected versions.
There is not a turnaround time requirement in the current QAP; therefore, current turnaround
times are judgment based. DWMRC has raised concern over excessive laboratory turn-around
times in the past and the Director may require a turn-around date be included in the facility QAP if
any future concerns regarding analysis turnaround times are noted. Based on DWMRC review the
turn-around times for the 1 st Quarter 2021, data turn-around times and EFR data review timelines
appear to be reasonable/appropriate.
7. Sample Holding Times:
Per the Report Section 3.4.2 and Tables in Tab G of the Report, all method holding times and
reporting limits were met for each analyte submitted for laboratory analysis (for baseline and
accelerated samples). DWMRC staff cross checked all holding time requirements and verified
that all samples/analytes appeared to be analyzed within holding times during the lst Qtr. 2021
reporting period.
8. Sample Preservation:
Per review of the 1st Quarter 2021 Report (Tab G, and Laboratory Check-in Sheets) it appears that
all samples required to be chilled (<6° C) met the temperature preservation requirements. Per
review of the laboratory check in sheets and laboratory QA/QC, no issues related to sample
preservation were noted. Per EFR information and method requirements, samples for gross alpha
analysis do not have a sample temperature requirement.
9. Sample Trip Blank Evaluation:
Per Section 3.4.6 of the Report and Tables in Tab G of the Report the trip blank sample (Lab
Report AWAL 2010348) showed detection of tetrahydrofuran, however, all other samples
associated with the blank were non-detect for THF. Per the Report the Quality Assurance
Manager followed the Quality Assurance Plan and notified the laboratory to verify the sample
results and investigate causes of THF in the trip blanks. The laboratory verified the sample results
and the Quality Assurance Manager determined that the results are usable.
10. Laboratory QA/QC Flags — 1st Quarter 2021:
QA/QC issues and DWMRC findings for the 1st Quarter 2021 are summarized below:
Non-Conformance
Summary
Self-
Identified?
EFR Corrective Action
Summary
DWMRC Findings
Laboratory reporting Y EFR states that the raised The EFR QAP allows for
limits were raised for RL's are due to sample raised RL's if due to the
various dilution and qualifies the need for dilution.
samples/parameters. data based on all sample DWMRC verified that in
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
Non-Conformance
Summary
Self-
Identified?
EFR Corrective Action
Summary
DWMRC Findings
results being above the
raised RL.
all cases when the RL was
raised above the QAP
required RL the sample
result was higher in
concentration.
Radiological counting
error > 20%
Y Per the Permit, if the value
of the result is less than the
appropriate GWCL then
the counting error can be >
20% (Table G-8A).
The EFR QAP Part 9.1.4.b
allows that if the
applicable result is less
than the GWCL then the
counting variance can be
greater than 20%.
Matrix Spike % recovery
outside of range for
various wells/parameters.
Y Per AWAL Data Sheet:
Matrix spike recovery
indicates matrix
interference. The method
is in control as indicated
by the LCS. EFR included
the data qualifiers in the
footnotes of the Report
Tab G.
Per the QAP Part 8.1.2(a)
matrix spikes are required
but there are no
requirements which would
disqualify the laboratory
data. Data was reported
with a qualifier.
Laboratory Duplicate %
Recovery Comparison
Outside of Range for
various wells/parameters.
Y Same AWAL comments as
per the matrix spike %
recovery item above. EFR
included the data qualifiers
in the footnotes of the
Report Tab G.
Data was reported with a
qualifier.
Note: DWMRC reviewed the holding time summary chart; no exceedances of holding times
were noted.
DWMRC reviewed the temperature check charts, all sample batches were received by the
laboratory <6° C.
11. Review of Time-Concentration Plots
The Permit Part I.F.1.g requires EFR to submit Time-Concentration Plots for each monitoring
well for primary indicators of cell leakage; chloride, fluoride, sulfate, and uranium. DWMRC
notes that per the discussions with EFR, it was agreed to that EFR need not plot trend lines on the
Time Concentration Plots and that all data is included on the plots (no data culled from the set).
Per DWMRC review of the 1st Qtr. 2021 Report, the reviewed plots appear to be in conformance
with the agreed upon changes.
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EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
12. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DWMRC cross checks of groundwater elevation measurement calculations used for the 1'
Quarter 2021, approximately 5% of wells cross checked, comparing surface casing measured
elevations minus measured static levels with plotted elevations, no errors were noted.
The upper wildlife ponds at the White Mesa Mill were taken offline (pond recharge from
Recapture Reservoir discontinued) during the 4th Quarter 2011 in order to re-establish
groundwater contours. Hydrographs of the upper wildlife pond ground water piezometers (Water
Level Elevation vs. Time) are included below (Northern piezometers and southern piezometers).
It was also noted that the static water levels in several monitoring wells close to the upper wildlife
ponds showed significant decrease in water levels since the ponds were taken offline. These
declines can be attributed to natural dissipation of the area ground water mound and/or ground
water pumping activities related to corrective action of nitrate and chloroform contamination
plumes (development of cone of depressions around pumping wells).
MC White Mesa MS Hydrographs• Ptezorneters @ North Wildlife Ponds
5.546
5 545 I
5544 5543 5542 r 5541
5 539 7 5,538
9 5537
5.538 5535 1--5534 t 5 533 I.
5 532 - 3 5531 5530 5529
5.528
5527 5.528
5 525 2- .-
5524
5.523
5.522 5521
5 520 5519 ;
5 518
5 517
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
IUC White Mesa Mill Hydrographs• Piezometers @ South WIldhfe Ponds
Nitrate and Chloroform Corrective Action Plan Pumping Wells:
Ground water elevations are being impacted by effects from ground water pumping for the nitrate
and chloroform contamination plume remediation. The following monitoring wells have been
converted to active pumping wells:
Nitrate Pumping Wells — TW4-22, TW4-24, TW4-25, TWN-2 (The nitrate pumping project was
initiated during January 2013).
Chloroform Pumping Wells — MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-
20, TW4-21, TW4-22, TW4-24, TW4-25, TW4-37, TW4-39.
The pumping wells for both the nitrate and chloroform projects are set up with a delay device
wherein the wells purge for a set amount of time then shut off in order to let the well recharge.
All pumping wells include a flow meter which records the volume of water pumped from the well
in gallons. Quarterly nitrate and chloroform reports are prepared by EFR and include pump
volumes and delineation of pump capture zones based on kriged water contours.
DWMRC expects that ground water elevation contours will continue to adjust in response to the
pumping activities and discontinuance of recharge to the upper wildlife ponds.
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 12
13. EFR April 23, 2021 Notice Pursuant to the Permit Part I.G.1(a)
The EFR April 23, 2021, Notice Pursuant to the Permit Part I.G.1(a) ("Notice") discusses the
status of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-
compliance ("00C") status, as updated through the 1s1 Quarter 2021. DWMRC notes that the
Notice was submitted timely regarding currently agreed upon schedules, reporting of exceedances
within 30 days after the end of the monitoring quarter, and has been updated based on issuance of
the modified and renewed modified GWDP's (Issued effective March 19, 2019, and March 8,
2021) in effect during the monitoring period.
Per the Notice, three new wells/parameters went into POOC or 00C status during the 15t Quarter
2021: MW-26 (Carbon Tetrachloride), MW-30 (Selenium), and MW-30 (Uranium). Based on
DWMRC review of the Notice it appears that all requirements of the Permit were met.
14. Conclusions and Recommendations
Based on DWMRC staff review of the above listed documents and review the following will be
included in a close-out and confirmatory action letter:
1. Close-out regarding DWMRC review of the EFR May 6, 2021, 1st Quarter 2021
Groundwater Monitoring Report.
2. Close-out regarding DWMRC review of the EFR April 23, 2021, Notice Pursuant to Part
I.G.1 (a).
15. References
l Energy Fuels Resources (USA) Inc., May 6, 2021, 1st Quarter2021 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., April 23, 2021, State of Utah Ground Water Discharge
Permit No. UGW370004 White Mesa Uranium Mill — Notice Pursuant to Part I.G.1(a).
3 Energy Fuels Resources (USA) Inc., May 14, 2019, White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP), Revision 7.5.
4 INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp.'s White Mesa Uranium Mill Site, San Juan County, Utah.
5 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison
Mines (USA) Corp.'s White Mesa Uranium Mill Site, San Juan County, Utah.
6 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the July 2007 Sampling Event at the Denison
EFR 1st Quarter 2021 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
Mines, USA, White Mesa Uranium Mill located near Blanding Utah. Prepared by University of
Utah Department of Geology and Geophysics.
7 Utah Department of Environmental Quality, March 19, 2019, Modified Utah Ground Water
Discharge Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa
Uranium Mill.
8 Utah Department of Environmental Quality, March 8, 2021, Modified Utah Ground Water
Discharge Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa
Uranium Mill.