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.