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HomeMy WebLinkAboutDRC-2018-006602 - 0901a0688086cbaaSPENCER J. COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director C --o o 6oz_. MEMORANDUM TO: File THROUGH: Phil Goble, Manager PA 6 S7 r FROM: Tom Rushing, P.G. R 61Z-7 DATE: June 25, 2018 SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 1st Quarter 2018 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 9, 2018, Transmittal of ft Quarter 2018 Groundwater Monitoring Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill. 2. EFR, May 1, 2018, 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. 2018 Report and Related Actions at the White Mesa Uranium Mill: 1. The 1' Quarter 2018 Report was received on May 11, 2018, 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 Radium Alpha which was analyzed by GEL Laboratories LLC, Charleston, South Carolina. DWMRC verified that the laboratories have current Utah certification. One deviation from the Mill Groundwater Monitoring Quality Assurance Plan (QAP) was noted regarding the currently used method for gross alpha by GEL laboratories. It appears that GEL does not have current accreditation for the currently used method (900.1). This issue is discussed below. 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 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801)-536-0222 • T.D.D. (801) 536-4414 www.deq utah gov Printed on 100% recycled paper EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 2 discrepancies were self-reported by EFR. 4. One compliance parameter went into accelerated monitoring frequency during the monitoring period (Field pH in monitoring well MW-30). 5. The renewed GWDP was issued and effective on January 19, 2018. Several changes were made to the permit regarding ground water compliance limits which shortened the list of monitoring wells/parameters in out-of-compliance status. Note that some monitoring wells which were required to be sampled on an accelerated monthly monitoring schedule were returned to baseline quarterly sampling and in some cases a January sample was collected and reported prior to the GWDP renewal. 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. One well/parameter is currently undergoing 00C review, fluoride in monitoring well MW-14. A plan and time schedule was submitted to DWMRC by EFR on March 2, 2018. The plan and time schedule was reviewed and approved by DWMRC on March 30 and requires the submission of a source assessment study on or before June 30, 2018. One well went into POOC accelerated monitoring status based on data during the review period (Field pH in monitoring well MW-30). Accelerated Monitoring Requirement Exception: Per past DWMRC review; 1st Qtr., 2nd Q tr and 4th Qtr. 2011 Groundwater Monitoring Reports, DWMRC issued a February 7, 2012 Notice of Enforcement Discretion ("NOED") for failure on the part of EFR to comply with these timelines for acceleration of groundwater monitoring at well MW-35. EFR stated in a March 26, 2012 response to the NOED that based on an agreement made between DWMRC and EFR during a telephone conference call on April 5, 2010, EFR is not required to implement accelerated monitoring until "the month following the submission of the Exceedance Notice for a specified quarter." Based on DWMRC review of notes taken during the April 5, 2010 telephone conference (Loren Morton 4/5/10), EFR verbally requested to wait until the end of the quarter to submit the notice of out-of - compliance status — but within 30 days of the last lab report that EFR receives for the quarterly monitoring event. DWMRC notified EFR by letter (dated April 16, 2012) that in order to formalize the April 5, 2010 discussion items related to out-of-compliance reporting and sampling, a written request for a groundwater EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 3 permit modification (groundwater permit, out-of-compliance notification and accelerated monitoring requirements) was required for Director review and approval. EFR submitted a May 25, 2012 written request for a Permit modification, including redline copies of pertinent pages of the Permit to reflect the agreements made during the April 5, 2010 conference call. The renewed permit dated January 9, 2018 includes these changes and this DWMRC review memo will be the last to include discussion related to this item. 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 II water D-3 Sulfate 3rd Qtr. 2017 December 2017 ' MW-14 Class III water D-4A Fluoride May 2017 November 2017 MW-25 Class III water C-3 Cadmium Fluoride 1 st Quarter 2016 4th Quarter 2017 April 2016 March 2018 MW-26(a) Class III water C-2 Nitrate + Nitrite (as N) Chloroform Chloride Dichloromethane February 2010 February 2010 February 2010 April 2010 May 2010 May 2010 May 2010 June 2010 MW-30 Class II water D-2 Nitrate + Nitrite (as N) Chloride Field pH February 2010 1 st Quarter 2011 1st Quarter 2018 May 2010 May 2011 2"d Quarter 2018 MW-31 Class III water D-2 Nitrate + Nitrite (as N) Chloride Uranium 1st Quarter 2010 1 st Quarter 2011 3rd Quarter 2016 May 2010 May 2011 December 2016 D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1,2,3,4A = Cell a = Monitoring well MW-26 is a pumping well for the Chloroform investigation Wells Monitored Semi-annually Accelerated to Quarterly Monitorin # Well Class *Position Parameter Date of First Exceedance of GWCL Date Accelerated Monitoring First Required MW-5 Class II water D-3 Uranium 4th Quarter 2010 1st Quarter 2011 MW-12 Class III water D-3 Uranium 2nd Quarter 2017 3rd Quarter 2017 MW-24 Class III water D-1 Beryllium 4th Quarter 2017 1 st Quarter 2018 MW-27 Class III water U-1 Nitrate + Nitrite (as N) Chloride 2nd Quarter 2010 1st Quarter 2010 3rd Quarter 2010 3rd Quarter 2010 MW-28 Class III water D-1 Chloride Cadmium Uranium 2nd Quarter 2010 2nd Quarter 2014 2nd Quarter 2014 3rd Quarter 2010 2' Quarter 2014 2nd Quarter 2014 MW-32 Class III water C-2 Chloride Sulfate 1st Quarter 2015 4th Quarter 2016 2nd Quarter 2014 1st Quarter 2017 EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 4 * D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A = Cell # Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status as of the 1st Quarter of 2018. 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 1 St Quarter 2018 monitoring, the AMSR was dated May 1, 2018 (received by DWMRC on May 3, 2018). 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. 7.3, EFR has a choice regarding purge volumes as follows: 41. 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 afier recovery" Per DWMRC review of the Report, the following purge methods were used during the 15t Quarter 2018 (including accelerated samples). Purge methods and volumes are summarized on Table G-1A and G-1B of the Report: Quarter # Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes rt Qtr. 2018 22 1 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 1 St Quarter 2018 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 2018 monitoring one well was pumped or bailed to dryness. In cases where wells are evacuated to dryness the QAP Rev. 7.3 (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 afier recovery or when sufficient water is available for sampling measure depth to water and record on the Field Data Worksheet. Take one set of measurements of field parameters for pH, spec0c conductance and temperature only. Collect the samples into the appropriate sample containers. EFR 1 st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 5 Take an additional set of measurements of field parameters for pH, specific conductance and temperature qfter 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 i f 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. For this Report this only applied to monitoring well MW-24, it was noted that 2 casing volumes were purged from the well prior to the well dryness. The sample was collected the following day, and field measurements were collected as required by the QAP. However, depth to water before sample collection was not recorded on the field data worksheet. Per a telephone call between DWMRC (Tom Rushing) and EFR (Kathy Weinel) regarding this issue (6/21/18) it was discussed that the measurement was not included on the worksheet. EFR discussed that the measurement was taken but that it was not included on the form. EFR stated that future worksheets will include the DTW before sample collection. 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 2018. Per the QAP, one blind duplicate must be collected with each sample batch. DWMRC confffmed 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 2/19/18) and two with the accelerated samples (MW-35/MW-65 on 1/23/18 and MW- 30/MW-65 on 3/8/18). 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, 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 15t Qtr. 2018 sampling event all sample results conform to the Permit requirements (within 20% RPD). EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 6 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 1st Quarter, 2018. 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 during the review period except as follows: A discrepancy was noted regarding the gross alpha (total alpha radium) laboratory results and currently accredited methods for GEL (NELAC Certification). Specifically, the QAP lists methods 900.0 and 900.1 for gross alpha analysis. The GEL laboratory results lists that method 900.1 was used for the analysis of "Total Alpha Radium, Liquid." Current GEL accreditation is for method 903.0 for this test. It appears that GEL does not have current accreditation for method 900.1. Per DWMRC review of method 903.0, the method is used to determine radium-226 (radium-223, radium- 224 and radium-226) by co-precipitation and alpha counting system. Method 900.1 determines radium-226 by radon-222 emanation. A discussion regarding the discrepancy between the laboratory accreditation, laboratory data sheets and facility QAP will occur prior to Report close-out. GEL Laboratories LLC current Utah Certification: Name GEL Laboratories, LLC Type of Lab Commercial TNI Lab Code TNI00188 EPA Code SC00012 State ID E87156 Website Extended Details Primary AB responsible for lab demogiaphics Utah Department of Health GIS Location Description Comments Effective Date Commercial Samples Yes Active Yes Address 1 Type Location Company Contact JAMES B. WESTMORELAND Address 1 2040 Savage Rd Address 2 City Charleston State South Carolina Zip 29407 Country US Phone 8435568171 Fax 8437661178 EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 7 Email jbw@gel.com American West Analytical Laboratories Current Utah Certification Name American West Analytical Laboratories Type of Lab Commercial 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 Commercial Samples Yes Active Yes Address 1 Type Location Company Contact Kyle Gross Address 1 3440 South 700 West Address 2 City Salt Lake City State Utah Zip 84119 Country US Phone 8012638686 Fax 8012638687 Email kyle@awal-labs.com 6. Laboratory Report Turn Around Times: Per DWMRC review of EFR Table 1 included in the 1st Qtr. 2018 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 days or less for all samples (not 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 1st Quarter 2018, data turn-around times and EFR data review timelines appear to be reasonable/appropriate. EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 8 7. Sample Holding Times: Per Tables G-2A, G-2B, G-5A and G-5B of the Report, all method holding times were met for each analyte submitted for laboratory analysis. DWMRC staff cross checked all holding time requirements and verified that all samples/analytes appeared to be analyzed within holding times during the 1st Qtr. 2018 reporting period. 8. Sample Preservation: Per review of the st Quarter 2018 Report (Tables G-3A and G-3B, 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. 9. Laboratory OA/QC Flags — 4th Quarter 2017: QA/QC issues and DWMRC findings for the et Quarter 2018 are summarized below: Noil-ronlerinance Stumm! \ Sell- It:lentil*? Ill'R ( rrecti\ e \ction c,Lithary l)1\ \IR( 1-indiw • p Laboratory reporting limits were raised for various samples/parameters. Y EFR states that the raised RL's are due to sample dilution and qualifies the data in Table G based on all sample results being above the raised RL. The EFR QAP allows for raised RL's if due to the need for dilution. DWMRC verified that in all cases when the RL was raised above the QAP required RL the sample result was higher in concentration. Matrix Spike % recovery outside of range: MW-14 Ammonia, MW-25 Y Per AWAL Data Sheet: Matrix spike recovery indicates matrix interference. The method is in control as indicated by the LCS. 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. Ammonia, MW-31 Ammonium, MW-36 Ammonia. Laboratory Duplicate % Recovery Comparison Outside of Range: MW-14 TDS, MW-36 TDS, MW-31 TDS. Y Same AWAL comments as per the matrix spike % recovery item above. 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. 10. 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. DWMIRC 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 1 st Qtr. 2018 Report, the reviewed plots appear to be in conformance with the agreed upon changes. EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 9 11. Review of Depth to Groundwater Measurements and Water Table Contour Maps Per DWMRC cross checks of groundwater elevation measurement calculations used for the 1st Quarter 2018, approximately 5% of wells cross checked, comparing surface 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. 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 during recent quarterly monitoring. 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). Whim /Nu= Rodrogriplass PluomeNre florek Ponds MOWN Now MI flobsgmplis: Mammy EFR 1st Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 10 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. 12. EFR May 1, 2018 Notice Pursuant to the Permit Part I.G.1(a) The EFR May 1, 2018 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 1st Quarter 2018. DWMRC notes that the Notice was submitted timely regarding currently agreed upon schedules and has been updated based on issuance of the renewed GWDP (Issued effective January 19, 2018). The Notice summarizes wells/parameters with 00C status which have been resolved by either separate corrective actions plans or approved modified GWCL's (pending inclusion in the renewal Permit). No new wells went into 00C status during the l' Quarter 2018. Field pH in monitoring well MW-30 exceeded the GWCL during the January 2018 sampling period and will continue accelerated POOC monthly monitoring based on the new exceedance. 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 was noted: 1. The field data worksheet for monitoring well MW-24 does not include depth to water immediately prior to collecting samples as required by the QAP when purging a well to dryness. DWMRC contacted EFR by phone regarding this issue on June 21, 2018 and it was reported by EFR that all future field worksheets would include the depth to water measurement in the comments field of the electronic worksheet. Based on this being a first time violation of the QAP for this issue and that only one well was purged to dryness during the quarter (single violation), the DWMRC will not pursue enforcement. If future Reports fail to report the depth to water information then additional action may be warranted. EFR 1St Quarter 2018 Groundwater Monitoring Report DWMRC Review Memo Page 11 2. It was noted that GEL Laboratories LLC is performing analysis for Gross Alpha (Total Alpha Radium) using method 900.1. However, per DWMRC review of the NELAC accreditation for GEL it does not appear that method 900.1 is accredited. The accreditation that GEL has is for method 903.0. This item was discussed during a conference call on June 26, 2018 and it was agreed that EFR would contact GEL to correct the discrepancy. Based on follow up communication with EFR, it appears that the identified deficiencies in the report will be corrected by informal communication and action. If the deficiencies are not corrected then further action may be warranted. Overall, the requirements of the Permit appear to have been met by EFR, and the data collected during the 1st Quarter of 2018 appears to be reliable. It is recommended that a correspondence letter be sent to EFR with the following items: 1. Close-out regarding DWMRC review of the EFR May 9, 2018, 1st Quarter 2018 White Mesa Uranium Mill Groundwater Monitoring Report based on findings as summarized above. 2. Close-out regarding DWMRC review of the EFR May 1, 2018 Notice Pursuant to Part I.G.1(a). 15. References 1 Energy Fuels Resources (USA) Inc., May 9, 2018, 1st Quarter2018 Groundwater Monitoring Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill. 2 Energy Fuels Resources (USA) Inc., May 1, 2018, 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., August 15, 2017, 2017, White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan (QAP), Revision 7.3. 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 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, August 24, 2012, Utah Ground Water Discharge Permit, Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill. 8 Utah Department of Environmental Quality, January 19, 2018, Utah Ground Water Discharge Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill.