DRC-2022-015041 - 0901a0688109e5e7

.,‘
Vs‘
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Douglas J. Hansen
Director
D RC-2022- o15 34-
TO: File
THROUGH: Phil Goble, Manager
FROM: Tom Rushing, P.G.
DATE: June 16, 2022
MEMORANDUM
P, 6 4,146b 06/16/2022
Thomas , 2022 09 55 MDT) 06/16/2022
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. lst Quarter 2022 Ground Water
Monitoring Report for the White Mesa Uranium Mill
Review Summary:
The Utah Division of Waste Management and Radiation Control ("Division") has reviewed the
following documents submitted by Energy Fuels Resources (USA) Inc. ("EFR"):
1. EFR, May 5, 2022, Transmittal of .1sl Quarter 2022 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill
(Received by the Division on May 11, 2022).
2. EFR, May 2, 2022, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill — Notice Pursuant to Part I.G.1(a) (Received by the
Division cm May 4, 2022.
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 Otr. 2022 Report and Related Actions at the
White Mesa Uranium Mill:
1. The 1st Quarter 2022 Report was received on May 5, 2022, 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"), Chemtech-Ford Laboratories ("Chemtech") and for Gross
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 deg utah gov
Printed on 100% recycled paper
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 2
Alpha analyzed by GEL Laboratories LLC, Charleston, South Carolina. DWMRC
verified that the laboratories have current Utah certification for the parameters
analyzed. 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. Per review of the 1st Qtr. 2022 groundwater head measurements, it was noted that
Piez-3A shows an approximate 3 ft. rise in water elevation. Per follow up
communication with EFR it was noted that the same rise is noted in the 1st Qtr.
And 2nd Qtr. 2022 water elevations taken during sampling. EFR is investigating
potential causes of the Piez-3A water elevation rise.
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 new compliance parameter went into accelerated monitoring frequency (POOC) based on
sampling during the St Quarter 2022 (Nitrate + Nitrite in Monitoring Well MW-11).
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 Monitoring
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-1 1 Class 11 water D-3 Chloride 3rd Quarter 2019 November 2019
EFR 1 st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Sulfate
Total Dissolved Solids
Manganese
Nitrate + Nitrite (as N)
3" Quarter 2019
3rd Quarter 2021
i -.rd .-", yuarter 2021
1" Quarter 2022
November 2019
November 2021
November 2021
June 2022
MW-25 Total Dissolved Solids 3rd Quarter 2021 November 2021
MW-26(a) Class III water C- 2
Nitrate + Nitrite (as N)
Chloroform
Chloride
Carbon Tetrachloride
Methylene Chloride
Total Dissolved Solids
February 2010
February 2010
February 2010
1' Quarter 2021
3" Quarter 2020
3rd Quarter 2021
May 2010
May 2010
May 2010
2nd Quarter 2021
August 2020
November 2021
MW-30 Class II water D-2
Nitrate + Nitrite (as N)
Chloride
Uranium
Selenium
Total Dissolved Solids
February 2010
1" Quarter 2011
1" Quarter 2021
1" Quarter 2021
3rd Quarter 2021
May 2010
May 2011
2nd Quarter 2021
2nd Quarter 2021
November 2021
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Total Dissolved Solids
Sulfate
Uranium
1" Quarter 2010
1' Quarter 2011
3" Quarter 2019
i -.rd ..-sti y after 2019
2nd Quarter 2020
May 2010
May 2011
November 2019
November 2019
August 2020
D = Down-gradient; U = Up-gradient; C = Cross-gradient;
a = Monitoring well MW-26 is a pumping well for the
Wells Monitored Semi-annually Accelerated to Quarterly
1,2,3,4A, 4B =
Chloroform investigation
Monitoring
Date of First
Exceedance of
GWCL
Cell #
Date Accelerated
Monitoring First
Required
Well Class *Position Parameter
MW-12 Class III water D-3 Uranium
Selenium
2' Quarter 2017
2nd Quarter 2020
3' Quarter 2017
3rd Quarter 2020
MW-24 Class III water D-1 Beryllium
Cadmium
Thallium
Field pH
Fluoride
Nickel
Manganese
Sulfate
Gross Alpha
Total Dissolved Solids
4' Quarter 2017
2nd Quarter 2018
2nd Quarter 2018
2" Quarter 2018
4th Quarter 2018
4th Quarter 2018
4" Quarter 2019
1" Quarter 2020
4th Quarter 2020
2" Quarter 2021
1" Quarter 2018
3' Quarter 2018
3' Quarter 2018
3" Quarter 2018
3rd Quarter 2019
3rd Quarter 2019
1" Quarter 2020
3rd Quarter 2020
3rd Quarter 2021
3rd Quarter 2021
MW-27 Class III water U-1 Nitrate + Nitrite (as N) 2nd Quarter 2010 3rd Quarter 2010
MW-28 Class III water D-1
Chloride
Cadmium
Uranium
Selenium
2" Quarter 2010
2' Quarter 2014
2" Quarter 2014
2nd Quarter 2019
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
3rd Quarter 2019
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 4
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Nitrate + Nitrite (as N) 4th Quarter 2019 3rd Quarter 2020
MW-29 Class III water D-2 Uranium 4th Quarter 2020 3' 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 #
Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status
as of the 1st Quarter of 2022. 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 1st Quarter 2022 monitoring,
the AMSR was dated May 2, 2022. 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 offield 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 offield parameters afier 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
1 st Qtr. 2022 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 2022 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 2022 monitoring period three monitoring 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:
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
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.
Take one set of measurements offield parameters for pH, specific conductance, and temperature
only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements offield 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, 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. 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 2022.
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-31/MW-65 on 1/19/2022); and two with the accelerated samples,
(MW-30/MW-65 on 2/9/2022) and (MW-11/MW-65 on 3/8/2022).
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)."
EFR 1 St Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
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,
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 lst
Quarter 2022 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 1st Quarter 2022. No additional action is required. It was noted that a few
of the reported sample results did not meet the radiological counting error requirements of less
than 20% of the result, however, in those cases no further action is required based on the QAP
condition that the 20% criteria do not have to be met if the sum of the result and error is less than
the GWCL. The sum was less than the GWCL in all samples which had a Permit GWCL for
comparison.
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; Chemtech Ford Laboratory,
Sandy, UT; and American West Analytical Laboratories, Salt Lake City, UT) were contracted by
EFR to perform analysis on the samples collected during the 1 st 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
EFR 1St Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
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
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
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
Address 2
City Salt Lake City
State Utah
Zip 84119-
Country USA
Phone [phone]
Fax [phone]
Email [e-mail]
Chemtech Ford Laboratory Current Utah Certification
Basic Details
Name Chemtech Ford Laboratory
Type of Lab Not Specified
TNI Lab Code TNI01969
EPA Code UT00027
State ID 8012627299
Website http://www.chemtechford.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 Chemtech Ford Laboratories
Contact David Gayer
Address 1 9632 South 500 West
Address 2
City Sandy
State Utah
Zip 84070-
Country United States
Phone [phone]
Fax [phone]
Email [e-mail]
6. Laboratory Report Turn Around Times:
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
Per DWMRC review of EFR Table 1 included in the 1" Qtr. 2022 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 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 ist Quarter 2022, 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 Table G-2A 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 1st Qtr. 2022
reporting period.
8. Sample Preservation:
Per review of the 1t Quarter 2022 Report (Part 3.4.3, 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 1st Quarter 2022 Report all trip blank
results associated with the quarterly, semi-annual, and accelerated samples were nondetect for
volatile organic compounds except for the March monthly trip blank which had a reported
concentration of 1.9 µg/L. Per EFR findings regarding the trip blank detection it was noted that
since the trip blank results were less than an order of magnitude of the of the sample results, the
trip blanks were within the acceptance limits of the QAP. No additional action is warranted.
10. Laboratory QA/QC Flags — 1st Quarter 2022:
QA/QC issues and DWMRC findings for the 1" Quarter 2022 are summarized below:
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
Non-Conformance-,, ,
: Summary
Self- '
Identified?
EFR Corrective Action :.
Summary
DWMRC Findings r
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 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.
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. 2022 Report, the reviewed plots appear to be in conformance
with the agreed upon changes.
P•1
MOD Pa. 1.1,, Pords: P 1 P 2 (bahoem) P (v.,. abonsmsa 20,22 P (*sib Pnsta. 20161
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
12. 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 2022, 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 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).
Per review of the 1st Qtr. 2022 groundwater elevations, it was noted that Piez-3A shows an
approximate 3 ft. rise in water elevation. Per follow up communication with EFR it was noted
that the same rise is noted in the 1st Qtr. And 2nd Qtr. 2022 water elevations taken during
sampling. EFR is investigating potential causes of the Piez-3A water elevation rise.
It/C While MesaMU Flydrographs: Plesansters Cs North W Write Ponds
553 5.532
5531
5530 5525
5,526
5,527 5,526
5525 5.524
5 523
5 522
5521 5
5,515 5515
5514
i
EFR 1 st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 12
IUC Wham Mesa Min hlythographs. Pleeofneters kl2, South Wildlife 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 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.
13. EFR May 2, 2022, Notice Pursuant to the Permit Part I.G.1(a)
The EFR May 2, 2022, Notice Pursuant to the Permit Part I.G. I (a) ("Notice") discusses the status
of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
compliance ("00C") status, as updated through the 1" Quarter 2022. 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 current modified GWDP (Issued effective March 8, 2021) in effect during the monitoring
period.
Per the Notice, one new parameter went into POOC or 00C status during the 15` Quarter 2021
(Nitrate + Nitrite as N in MW-11). 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 letter:
1. Close-out regarding DWMRC review of the EFR May 5, 2022, 1t Quarter 2022
Groundwater Monitoring Report.
2. Close-out regarding DWMRC review of the EFR May 2, 2022, Notice Pursuant to Part
I.G. 1 (a).
15. References
'Energy Fuels Resources (USA) Inc., May 5, 2022, lst Quarter2022 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., May 2, 2022, 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 7.6.
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. Suinmary 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.
EFR 1st Quarter 2022 Groundwater Monitoring Report
DWMRC Review Memo
Page 14
7 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.