DRC-2015-002483 - 0901a0688052e3c9

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
ENERGY FUELS 303 974 2140
DRC-201 5-002483 www.energYfuels.com
OF
May 13, 2015
VIA PDF AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Rnvironmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Dear Mr. Lundberg:
Re: State of Utah Ground Water Discharge Permit ("the Permit") No. UGW370004 White Mesa
Uranium Mill - As-Built Report Pursuant to Part I.F.6 of the Permit
This letter transmits the As-Built Report for Energy Fuels Resources (USA) Inc.'s ("BLRI's") perched
groundwater monitoring well TW4-37.
TW4-37 was installed during the week of March 23, 2015. TW4-37 was installed to enhance the rate of
extraction of chloroform-bearing perched water within that portion of the chloroform plume historically
containing the highest chloroform concentrations.
The enclosed As-Built Report includes the items required for As-Built Reports in the Permit Part I.F.6, and is
being submitted for TW4-37.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydcrthind
Harold R. Roberts
David E. Turk
Dan Hillsten
Scott Bakkcn
Logan Shumway

HYDRO GEO CHEM, INC.
Environmental Science & Technology

INSTALLATION AND HYDRAULIC TESTING OF
PERCHED WELL TW4-37
WHITE MESA URANIUM MILL
NEAR BLANDING, UTAH
(AS-BUILT REPORT)

May 12, 2015

Prepared for:

ENERGY FUELS RESOURCES (USA) INC
225 Union Blvd., Suite 600
Lakewood, Colorado 80228

Prepared by:

HYDRO GEO CHEM, INC.
51 West Wetmore Road, Suite 101
Tucson, Arizona 85705
[phone]

Project Number 7180000.00-01.0

Installation and Hydraulic Testing of Perched Well TW4-37
White Mesa Uranium Mill (As-Built Report)
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TABLE OF CONTENTS
1. INTRODUCTION .............................................................................................................. 1
2. DRILLING AND CONSTRUCTION ................................................................................ 3
2.1 Drilling and Logging Procedures ............................................................................ 3
2.2 Construction ............................................................................................................ 3
2.3 Development ........................................................................................................... 3
3. HYDRAULIC TESTING ................................................................................................... 5
3.1 Testing Procedures .................................................................................................. 5
3.2 Hydraulic Test Data Analysis ................................................................................. 5
4. CONCLUSIONS................................................................................................................. 9
5. REFERENCES ................................................................................................................. 11
6. LIMITATIONS ................................................................................................................. 13

TABLES

1 Well Survey Data
2 Slug Test Parameters
3 Slug Test Results

FIGURES

1 Location of TW4-37 and Kriged 1st Quarter 2015 Water Levels, White Mesa Site
2 TW4-37 As-Built Well Construction Schematic

APPENDICES

A Lithologic Log
B Well Development Field Sheets
C Slug Test Plots
D Slug Test Data

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Installation and Hydraulic Testing of Perched Well TW4-37
White Mesa Uranium Mill (As-Built Report)
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1. INTRODUCTION
This report describes the installation, development, and hydraulic testing of perched well TW4-
37 at the White Mesa Uranium Mill (the “Mill” or the “site”) near Blanding, Utah. TW4-37 is
located between existing chloroform pumping wells TW4-20 and TW4-22 as shown on Figure 1.
TW4-37 was installed with the approval of the State of Utah Division of Radiation Control
(DRC) to enhance the rate of extraction of chloroform-bearing perched water within that portion
of the chloroform plume historically containing the highest chloroform concentrations.
TW4-37 was installed during the week of March 23, 2015. Development consisted of surging
and bailing on March 25, followed by overpumping on April 1, 2015. Hydraulic testing consisted
of a slug test conducted on April 15, 2015.

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2. DRILLING AND CONSTRUCTION
Well installation procedures were similar to those used previously at the site for the construction
of other perched zone wells (Hydro Geo Chem, Inc. [HGC], 2005). Drilling and construction
were performed by Bayles Exploration, Inc., and the boring logged by Mr. Lawrence Casebolt
under contract to Energy Fuels (USA) Corporation (EFRI). An as-built diagram for the well
construction, based primarily on information provided by Mr. Casebolt, is shown in Figure 2.
The depth to water shown in the as-built diagram was based on water level measurement just
prior to development. TW4-37 was surveyed by a State of Utah licensed surveyor and the
location and elevation data are provided in Table 1.
2.1 Drilling and Logging Procedures
A 12¼ -inch diameter tricone bit was used to drill a boring of sufficient diameter to install an
8-inch-diameter, Schedule 80 poly vinyl chloride (PVC) surface (conductor) casing. The surface
casing extended to a depth of approximately 6 feet below land surface. Once the surface casing
was in place, the borehole was drilled by air rotary using a 6¾ inch diameter tricone bit. The
borehole penetrated the Dakota Sandstone and the Burro Canyon Formation and terminated in
the Brushy Basin Member of the Morrison Formation.
Drill cuttings samples used for lithologic logging were collected at 2½-foot depth intervals and
placed in labeled, zip-sealed plastic bags and labeled plastic cuttings storage boxes. A copy of
the lithologic log submitted by Mr. Casebolt is provided in Appendix A.
2.2 Construction
TW4-37 was constructed using 4-inch diameter, Schedule 40, flush-threaded PVC casing and
0.02-slot, factory-slotted PVC screen. Colorado Silica Sand was used as a filter pack and
installed to a depth of approximately 5 ½ feet above the screened interval. The annular space
above the filter pack was sealed with hydrated bentonite chips. The well casing was fitted with a
4-inch PVC cap to keep foreign objects out of the well and a lockable steel security casing was
installed to protect the well.
2.3 Development
TW4-37 was developed by surging and bailing followed by overpumping. Development records
are provided in Appendix B.

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3. HYDRAULIC TESTING
Hydraulic testing consisted of a slug test conducted by HGC personnel using a methodology
similar to that described in HGC (2005).
3.1 Testing Procedures
The slug used for the test consisted of a sealed, pea-gravel-filled, schedule 80 PVC pipe
approximately three feet long that displaced approximately 3/4 gallons of water as described in
HGC (2002). A Level TrollJ 0-30 pounds per square inch absolute (psia) data logger was
deployed below the static water column in the well and used to measure the change in water
level during the test. A Baro-Troll was used to measure barometric pressure and was placed in a
protected environment near the well for the duration of the testing. Automatically logged water
level data were collected at 3-second intervals and barometric data at 5-minute intervals.
Prior to the test, the static water level was measured by hand using an electric water level meter
and recorded in the field notebook. The data logger was then lowered to a depth of
approximately ten feet below the static water level in the well and background pressure readings
were collected for approximately 95 minutes prior to beginning the test. The purpose of
collecting the background data was to allow correction for any detected water level trend.
Once background data were collected, the slug and electric water level meter sensor were
suspended in the well just above the static water level. The test commenced by lowering the slug
to a depth of approximately two feet below the static water level over a period of a few seconds
and taking water level readings by hand as soon as possible afterwards. Hand-collected data
recorded in the field notebook were obtained more frequently in the first few minutes when
water levels were changing more rapidly, then less frequently as the rate of water level change
diminished. Upon completion of the test, automatically logged data were checked and backed up
on the hard drive of a laptop computer.
3.2 Hydraulic Test Data Analysis
Data from the test were analyzed using AQTESOLVETM (HydroSOLVE, 2000), a computer
program developed and marketed by HydroSOLVE, Inc. In preparing the automatically logged
data for analysis, the total number of records was reduced. All data collected in the first 30
seconds were retained, then every 2nd, then 3rd, then 4th, etc. record was retained for analysis.
For example, if the first 10 records were retained (30 seconds of data at 3-second intervals), the
next records to be retained would be the 12th, the 15th, the 19th, the 24th, etc.

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Data were analyzed using two solution methods: the KGS unconfined method (Hyder et al.,
1994) and the Bouwer-Rice unconfined method (Bouwer and Rice, 1976). When filter pack
porosities were required by the analytical method, a value of 30 percent was used. The saturated
thickness was taken to be the difference between the depth of the static water level measured just
prior to the test and the depth to the Brushy Basin Member contact as defined in the drilling log
(Appendix A). The static water level was below the top of the screened interval and the saturated
thickness was taken to be the effective screen length.
Background (pre-test) automatically logged water level data were relatively constant during the
hour prior to testing. Data were corrected for barometric pressure changes although changes were
small due primarily to the brevity of the test.
The KGS solution allows estimation of both specific storage and hydraulic conductivity, while
the Bouwer-Rice solution allows estimation of only the hydraulic conductivity. The Bouwer-
Rice solution is valid only when a straight line is identifiable on a plot of the log of displacement
versus time (indicating that flow is nearly steady), and is insensitive to both storage and the
specified initial water level rise. Typically, only the later-time data are interpretable using
Bouwer-Rice.
The KGS solution accounts for non-steady flow and storage, is sensitive to the specified initial
water level rise, and generally allows a fit to both early- and late-time data. Both solutions were
used for comparison. Automatically logged and hand-collected data were analyzed separately
using both solution methods. The hand-collected data therefore served as an independent data set
and a check on the accuracy of the automatically logged data.
Table 2 summarizes test parameters and Table 3 and Appendix C provide the results of the
analyses. Appendix C contains plots generated by AQTESOLVEJ that show the quality of fit
between measured and simulated displacements, and reproduce the parameters used in each
analysis. Appendix D provides displacement data. Estimates of hydraulic conductivity range
from approximately 1.4 x 10-4 centimeters per second (cm/s) to 2.2 x 10-4 cm/s using
automatically logged data, and from approximately 1.9 x 10-4 cm/s to 2.3 x 10-4 cm/s using hand-
collected data. Estimates are within the range previously measured at the site (approximately 2 x
10-8 cm/s to 0.01 cm/s) and are similar to estimates obtained for nearby well TW4-22, which
ranged from 1.1 x 10-4 cm/s to 1.3 x 10-4 cm/s (HGC, 2014).
In general, the agreement between solution methods and between estimates obtained from
automatically logged and hand-collected data is good, and within a factor of 2 Although there
was generally good agreement between the KGS and Bouwer-Rice results, because the KGS

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solution accounts for non-steady flow and aquifer storage, the results obtained using KGS are
considered more representative than those obtained using Bouwer-Rice.

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White Mesa Uranium Mill (As-Built Report)
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4. CONCLUSIONS
Procedures for the installation, hydraulic testing, and development at new perched well TW4-37
are similar to those used previously at the site for the construction, testing, and development of
other perched zone wells.
Automatically logged and hand-collected slug test data from TW4-37 were analyzed using KGS
and Bouwer-Rice analytical solutions. Estimates of hydraulic conductivity range from
approximately 1.4 x 10-4 centimeters per second (cm/s) to 2.2 x 10-4 cm/s using automatically
logged data, and from approximately 1.9 x 10-4 cm/s to 2.3 x 10-4 cm/s using hand-collected data.
Estimates are within the range previously measured at the site (approximately 2 x 10-8 cm/s to
0.01 cm/s) and are similar to estimates obtained for nearby well TW4-22, which ranged from 1.1
x 10-4 cm/s to 1.3 x 10-4 cm/s (HGC, 2014).
In general, the agreement between solution methods and between estimates obtained from
automatically logged and hand-collected data is good, and within a factor of 2 Although there
was generally good agreement between the KGS and Bouwer-Rice results, because the KGS
solution accounts for non-steady flow and aquifer storage, the results obtained using KGS are
considered more representative than those obtained using Bouwer-Rice.

Installation and Hydraulic Testing of Perched Well TW4-37
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5. REFERENCES
Bouwer, H. and R.C. Rice. 1976. A Slug-Test method for Determining Hydraulic Conductivity
of Unconfined Aquifers with Completely or Partially Penetrating Wells. Water Resources
Research, Vol. 12, No. 3, Pp. 423-428.
Hyder, Z, J.J. Butler, Jr. C.D. McElwee, and W. Liu. 1994. Slug Tests in Partially Penetrating
Wells. Water Resources Research, Vol. 30, No. 11, Pp. 2945-2957.
Hydro Geo Chem, Inc. (HGC). 2002. Hydraulic Testing at the White Mesa Uranium Mill Near
Blanding, Utah During July 2002. Submitted to International Uranium Corporation.
August 22, 2002.
HGC. 2005. Perched Monitoring Well Installation and Testing at the White Mesa Uranium Mill,
April through June 2005. Submitted to International Uranium Corporation.
August 3, 2005.
HGC, 2014. Hydrogeology of the White Mesa Uranium Mill, Blanding, Utah. Submitted to
Energy Fuels Resources (USA) Inc, June 6, 2014.
HydroSOLVE, Inc. 2000. AQTESOLV for Windows. User=s Guide.

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6. LIMITATIONS
The information and conclusions presented in this report are based upon the scope of services
and information obtained through the performance of the services, as agreed upon by HGC and
the party for whom this report was originally prepared. Results of any investigations, tests, or
findings presented in this report apply solely to conditions existing at the time HGC’s
investigative work was performed and are inherently based on and limited to the available data
and the extent of the investigation activities. No representation, warranty, or guarantee, express
or implied, is intended or given. HGC makes no representation as to the accuracy or
completeness of any information provided by other parties not under contract to HGC to the
extent that HGC relied upon that information. This report is expressly for the sole and exclusive
use of the party for whom this report was originally prepared and for the particular purpose that
it was intended. Reuse of this report, or any portion thereof, for other than its intended purpose,
or if modified, or if used by third parties, shall be at the sole risk of the user.

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TABLES
TABLE 1
Well Survey Data
Northing *Easting *Top of Casing Ground
(feet) (feet) (feet amsl) (feet amsl)
TW4-37 10164486.36 2219415.73 5631.85 5630.13
Notes:
amsl = above mean sea level
* = state plane coordinates
Well
H:\718000\tw37\TW37_tables.xls: T1
TABLE 2
Slug Test Parameters
Depth to Depth to Depth to Top Depth to Base Saturated Thickness
Well Brushy Basin Water of Screen of Screen Above Brushy Basin
(feet) (feet) (feet) (feet) (feet)
TW4-37 109.0 57.4 52.0 112.0 51.6
Note: All depths are in feet below land surface
H:\718000\tw37\TW37_tables.xls: T2
TABLE 3
Slug Test Results
Bouwer-Rice Bouwer-Rice
Test Saturated
Thickness
K
(cm/s)
Ss
(1/ft)
K
(cm/s)
K
(cm/s)
Ss
(1/ft)
K
(cm/s)
TW4-37 51.6 1.43E-04 2.14E-04 2.17E-04 1.93E-04 8.60E-05 2.33E-04
Notes:
Bouwer-Rice = Unconfined Bouwer-Rice solution method in Aqtesolve™
cm/s = centimeters per second
ft = feet
K = hydraulic conductivity
KGS = Unconfined KGS solution method in Aqtesolve™
Ss= specific storage
Automatically Logged Data Hand Collected Data
KGS KGS
H:\718000\tw37\TW37_tables.xls: T3

FIGURES
HYDRO
GEO
CHEM, INC.APPROVED DATE REFERENCE FIGURE
1000 feet
MW-25
MW-27
MW-31
TW4-01
TW4-02
TW4-03
TW4-04
TW4-05
TW4-06
TW4-09
TW4-10
TW4-11
TW4-12
TW4-13
TW4-14
MW-26
TW4-16
MW-32
TW4-18TW4-19
TW4-20
TW4-21
TW4-22
TW4-23
TW4-24
TW4-25
TW4-26
PIEZ-02
PIEZ-03
PIEZ-04
TWN-01
TWN-02
TWN-03
TWN-04
TW4-07 TW4-08
MW-04
TW4-27
TW4-29
TW4-32
TW4-33
TW4-34
TW4-28
TW4-30
TW4-31
5537
5574
5548
5547
5550
5577
5541
5577
5538
5576
5573
5533
5579
5569
5531
5558
5559
5548
55775568
5566
5578
5557
5539
5560
5587
5536
5592
5590
5535
5587
5597
5596
5589
5549 5547
5551
5528
5533
5561
5535
5532
5578
5526
5523
5572
TW4-35
TW4-36
5526
5560
TW4-37
EXPLANATION
perched monitoring well showing
elevation in feet amsl
temporary perched monitoring well
showing elevation in feet amsl
perched piezometer showing
elevation in feet amsl
temporary perched monitoring well
installed May, 2014 showing
elevation in feet amsl
MW-4
TW4-7
PIEZ-2
TW4-35
LOCATION OF TW4-37 AND
KRIGED 1st QUARTER, 2015 WATER LEVELS
WHITE MESA SITE
5551
5549
5592
5526
NOTE: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, and TW4-20 are chloroform pumping wells;
TW4-22, TW4-24, TW4-25, and TWN-2 are nitrate pumping wells
TW4-37 temporary perched monitoring well
installed March, 2015 showing
elevation in feet amsl
1H:/718000/tw37/Utw37loc.srfSJS5/12/2015
5572

APPENDIX A

LITHOLOGIC LOGS

APPENDIX B

WELL DEVELOPMENT FIELD SHEETS

APPENIDX C

SLUG TEST PLOTS
0.01 0.1 1. 10. 100.
0.
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\tw37\aqtesolve\tw37.aqt
Date: 04/30/15 Time: 12:24:30
PROJECT INFORMATION
Client: EFRI
Test Well: tw4-37
AQUIFER DATA
Saturated Thickness: 51.57 ft
WELL DATA (tw4-37)
Initial Displacement: 0.61 ft Static Water Column Height: 51.57 ft
Total Well Penetration Depth: 51.57 ft Screen Length: 51.57 ft
Casing Radius: 0.167 ft Well Radius: 0.281 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: KGS Model
Kr = 0.0001427 cm/sec Ss = 0.0002139 ft-1
Kz/Kr = 0.1
0. 4. 8. 12. 16. 20.
0.01
0.1
1.
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\tw37\aqtesolve\tw37br.aqt
Date: 04/30/15 Time: 12:26:53
PROJECT INFORMATION
Client: EFRI
Test Well: tw4-37
AQUIFER DATA
Saturated Thickness: 51.57 ft Anisotropy Ratio (Kz/Kr): 0.1
WELL DATA (tw4-37)
Initial Displacement: 0.61 ft Static Water Column Height: 51.57 ft
Total Well Penetration Depth: 51.57 ft Screen Length: 51.57 ft
Casing Radius: 0.167 ft Well Radius: 0.281 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: Bouwer-Rice
K = 0.0002171 cm/sec y0 = 0.3288 ft
0.01 0.1 1. 10. 100.
0.
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\tw37\aqtesolve\tw37h.aqt
Date: 04/30/15 Time: 12:27:16
PROJECT INFORMATION
Client: EFRI
Test Well: tw4-37
AQUIFER DATA
Saturated Thickness: 51.57 ft
WELL DATA (tw4-37)
Initial Displacement: 0.61 ft Static Water Column Height: 51.57 ft
Total Well Penetration Depth: 51.57 ft Screen Length: 51.57 ft
Casing Radius: 0.167 ft Well Radius: 0.281 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: KGS Model
Kr = 0.0001931 cm/sec Ss = 8.597E-5 ft-1
Kz/Kr = 0.1
0. 4. 8. 12. 16. 20.
0.01
0.1
1.
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\tw37\aqtesolve\tw37hbr.aqt
Date: 04/30/15 Time: 12:27:38
PROJECT INFORMATION
Client: EFRI
Test Well: tw4-37
AQUIFER DATA
Saturated Thickness: 51.57 ft Anisotropy Ratio (Kz/Kr): 0.1
WELL DATA (tw4-37)
Initial Displacement: 0.61 ft Static Water Column Height: 51.57 ft
Total Well Penetration Depth: 51.57 ft Screen Length: 51.57 ft
Casing Radius: 0.167 ft Well Radius: 0.281 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: Bouwer-Rice
K = 0.0002331 cm/sec y0 = 0.3442 ft

APPENDIX D

SLUG TEST DATA
TW37DSP.TXT
TW4-37
elapsed time displacement
(min) (ft)
1.67E-05 0.606537
0.050017 0.496881
0.100017 0.517872
0.150017 0.510867
0.200017 0.496863
0.250017 0.487525
0.300017 0.471188
0.350017 0.466516
0.400017 0.452512
0.450017 0.445507
0.550017 0.417499
0.700017 0.389485
0.900017 0.3568
1.150017 0.321775
1.450017 0.282079
1.800017 0.235377
2.200017 0.209667
2.650017 0.172285
3.150017 0.151229
3.700017 0.134833
4.300017 0.109099
4.950017 0.097357
5.650017 0.080943
6.400017 0.071522
7.200017 0.07376
8.050017 0.064327
8.950017 0.057221
9.900017 0.047777
10.90002 0.045325
11.95002 0.042868
13.05002 0.040404
14.20002 0.042601
15.40002 0.037793
16.65002 0.039977
17.95002 0.053821
19.30002 0.048995

Page 1
TW37HDSP.TXT
TW4-37
elapsed time displacement
(min) (ft, hand collected)
0.17 0.6
0.333 0.45
0.55 0.39
0.75 0.35
1 0.31
1.33 0.3
1.75 0.23
2 0.2
2.53 0.17
3.58 0.13
4.5 0.1
5.83 0.09
8.08 0.06
10.92 0.05
12.66 0.04
21.8 0.04
30.25 0.03
37.25 0.03

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