DRC-2022-020926 - 0901a068810e39fc

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
September 8, 2022
VIA E-MAIL AND EXPRESS DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Dear Mr. Hansen:
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 (“EFRI’s”) perched
groundwater monitoring well MW-41.
MW-41 was installed the week of July 18, 2022. MW-41 was installed with the approval of the State of Utah
Division of Waste Management and Radiation Control (DWMRC). The primary purpose for installing MW-41
is to investigate groundwater quality between upgradient well MW-24 and downgradient well MW-2.
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 MW-41.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance
cc: David Frydenlund
Garrin Palmer
Scott Bakken
Logan Shumway
Stewart Smith (HGC)
DRC-2022-020926

HYDRO GEO CHEM, INC.
Environmental Science & Technology

INSTALLATION AND HYDRAULIC TESTING OF
PERCHED WELL MW-41
WHITE MESA URANIUM MILL
NEAR BLANDING, UTAH
(AS-BUILT REPORT)

September 8, 2022

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 MW-41
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 MW-41 and Kriged 2nd Quarter 2022 Water Levels, White Mesa Site
2 MW-41 As-Built Well Construction Schematic
3 MW-41 Corrected and Uncorrected Automatically-Logged Water Level Displacements

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 MW-41
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 MW-41
at the White Mesa Uranium Mill (the “Mill” or the “site”) near Blanding, Utah. MW-41 was
installed during the week of July 18, 2022 with the approval of the State of Utah Division of
Waste Management and Radiation Control (DWMRC) and is located between existing
groundwater monitoring wells MW-2 and MW-24 as shown on Figure 1.
MW-41 is located generally upgradient of MW-2 and downgradient of MW-24. The primary
purpose for installing MW-41 is to investigate groundwater quality between upgradient well
MW-24 and downgradient well MW-2. In addition, the well was to be constructed with a
completely submerged well screen (no open screen above the water table).
The primary purpose of eliminating open screen above the water table is to minimize transport of
air into the vadose zone in the vicinity of the well to in turn minimize oxygen transport to
groundwater. Enhanced oxygen transport to groundwater near monitoring wells increases
oxidation of naturally-occurring pyrite in the formation hosting perched groundwater near the
wells, lowers pH, and mobilizes trace metals contained in pyrite, as well as other pH sensitive
metals that occur naturally in the formation near the wells.
However, as will be discussed below, although saturated conditions were encountered at
approximately 92 feet below land surface (ft. bls) during drilling, and the well was constructed
with the top of screen at approximately 100 ft. bls, subsequent depth to water measurements
established the static water level to be approximately 111 ft. below top of casing (ft. btoc),
yielding approximately 8 feet of screen above the water table (based on nearly 3 feet of casing
stickup). A plan will be submitted to remove the existing casing, ream the borehole to a larger
diameter, and re-install the casing with a completely submerged screen.
Development of MW-41 consisted of surging and bailing on August 3, 4 and 5, followed by
overpumping on August 12, 15 and 16, 2022. Hydraulic testing consisted of a slug test conducted
on August 23 and 24, 2022. Performing the slug test using the existing casing is considered
appropriate because the test primarily measures formation properties (rather than properties of
the well itself).

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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 Recapture Drilling, and the boring logged by Mr. D. Kapostasy and Mr. T.
Boam, employees of Energy Fuels (USA) Corporation (EFRI). An as-built diagram for the well
construction, based primarily on information provided by Mr. D. Kapostasy, is shown in Figure
2. The depth to water shown in the as-built diagram was based on water level measurement just
prior to surging and bailing. MW-41 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 12-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 10 feet below land surface. Once the surface casing
was in place, the borehole was cored by air rotary using a 2-inch inner diameter core bit. The
following day the borehole was reamed using a 6 ¼ - inch diameter polycrystalline diamond
compact (PDC) drag bit. The borehole penetrated the Dakota Sandstone and the Burro Canyon
Formation and terminated in the Brushy Basin Member of the Morrison Formation.
Drill core samples were logged and placed in labeled, core storage boxes, each accommodating
approximately 10 feet of core. Within intervals having little or no core recovery, drill cuttings
were logged, and samples stored in labelled zip-sealed plastic bags. A copy of the lithologic log
submitted by Mr. Kapostasy and Mr. Boam is provided in Appendix A.
2.2 Construction
MW-41 was constructed using 4-inch diameter, Schedule 40, flush-threaded PVC casing and
0.02-slot, factory-slotted PVC screen. Filter pack gravel was installed to a depth of
approximately 19 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
MW-41 was developed by surging and bailing followed by overpumping. Development records
are provided in Appendix B. Due to low productivity, surging and bailing and overpumping

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activities were conducted over periods of several days in order to remove the required volumes
of water.

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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 1-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 30 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
Background (pre-test) automatically logged water level data displayed a noticeable upward trend
during the 30 minutes prior to the test that appeared unrelated to barometric pressure changes.
The nature of the linear trend is unknown, as it was not reflected in the hand-collected data,
indicating that it was not the result of a water level increase.
In addition, due primarily to the slow recovery of water levels, and the need to continue the test
until the following day, barometric pressure changes also impacted the automatically-logged

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data. Therefore, the automatically-logged data were corrected for a linear trend as well as
barometric pressure changes. A comparison of corrected and uncorrected automatically-logged
water level displacements is provided in Figure 3. As shown, even though the specific cause of
the linear trend is unknown, correcting for the linear trend and for barometric pressure changes
yielded approximately 600 minutes (10 hours) of interpretable data.
Test data were analyzed using AQTESOLVTM (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 3rd, then 5th, then 7th, then 9th, etc., record was retained for analysis. For
example, if the first 30 records were retained (30 seconds of data at 1-second intervals), the next
records to be retained would be the 33rd, the 38th, the 45th, the 54th, etc.
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). Because only the first
10 hours of automatically-logged data were considered interpretable, analyses of the
automatically-logged data were confined to the first 10 hours of those data.
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.
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.

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Table 2 summarizes test parameters and Table 3 and Appendix C provide the results of the
analyses. Appendix C contains plots generated by AQTESOLVJ 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 2.27 x 10-6 centimeters per second (cm/s) to 3.1 x 10-6 cm/s using
automatically logged data, and from approximately 2.99 x 10-6 cm/s to 3.82 x 10-6 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).
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.

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4. CONCLUSIONS
Procedures for the installation, hydraulic testing, and development at new perched well MW-41
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 MW-41 were analyzed using the
KGS and Bouwer-Rice analytical solutions. Estimates of hydraulic conductivity range from
approximately 2.27 x 10-6 centimeters per second (cm/s) to 3.1 x 10-6 cm/s using automatically
logged data, and from approximately 2.99 x 10-6 cm/s to 3.82 x 10-6 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).
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.
As discussed in Section 1 a plan will be developed to replace the existing casing in MW-41 after
removal and reaming the borehole to a larger diameter. The new casing will have a shorter
screened interval that is completely submerged to prevent excessive oxygen transport to
groundwater near the well. Slug tests conducted using the existing casing are considered
adequate for estimation of formation hydraulic properties near MW-41 and will not need to be
repeated once the casing has been replaced.

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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.
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)
MW-41 10164390.77 2215969.15 5620.02 5617.08
Notes:
amsl = above mean sea level
* = state plane coordinates
Well
H:\718000\MW41\Report\MW41_T1_T2_T3.xlsx: T 1
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)
MW-41 128.0 108.0 100.0 130.0 20.0
Note: All depths are in feet below land surface
H:\718000\MW41\Report\MW41_T1_T2_T3.xlsx: T 2
TABLE 3
Slug Test Results
Bouwer-Rice Bouwer-Rice
Test Saturated
Thickness (ft)
K
(cm/s)
Ss
(1/ft)
K
(cm/s)
K
(cm/s)
Ss
(1/ft)
K
(cm/s)
MW-41 20.0 2.27E-06 8.29E-05 3.10E-06 2.99E-06 1.70E-04 3.82E-06
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\MW41\Report\MW41_T1_T2_T3.xlsx: T 3

FIGURES
HYDRO
GEO
CHEM, INC.
EXPLANATION
perched monitoring well showing
elevation in feet amsl
perched piezometer showing
elevation in feet amsl
seep or spring showing
elevation in feet amsl
LOCATION OF MW-41 AND
KRIGED 2nd QUARTER, 2022 WATER LEVELS
WHITE MESA SITE
H:/718000/MW41/report/MW41location.srf
MW-5
PIEZ-1
RUIN SPRING
temporary perched monitoring well
showing elevation in feet amsl
temporary perched nitrate monitoring
well showing elevation in feet amsl
TW4-12
TWN-7
5504
5568
5569
5588
5380
5463
MW-38
TW4-42
temporary perched nitrate monitoring
well installed April, 2021showing
elevation in feet amsl
5523
temporary perched monitoring
well installed September, 2021
showing elevation in feet amsl
TW4-43
TWN-20
new perched monitoring well MW-41
MW-41
1
CHEM, INC.
GEO
HYDRO
Approved DateDate File Name FigureAuthor
MW-41
AS-BUILT WELL CONSTRUCTION SCHEMATIC
SJS 08/05/22 7180292AJAA08/05/22 2
0
0.2
0.4
0.6
0.8
1
1.2
1.4
1.6
0 200 400 600 800 1000 1200 1400
di
s
p
l
a
c
e
m
e
n
t

(
f
e
e
t
)
elapsed time (minutes)
uncorrected
corrected
MW-41 CORRECTED AND UNCORRECTED
AUTOMATICALLY-LOGGED WATER LEVEL
DISPLACEMENTS
HYDRO
GEO
CHEM, INC.Approved FigureDateAuthorDateFile Name
SJS 09/01/22 3F3 MW-41 Plot09/01/22SJS

APPENDIX A

LITHOLOGIC LOG

APPENDIX B

WELL DEVELOPMENT FIELD SHEETS

APPENIDX C

SLUG TEST PLOTS
0.01 0.1 1. 10. 100. 1000.
0.
0.2
0.4
0.6
0.8
1.
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\MW41\SlugTest\aqtesolv\final\mw41.aqt
Date: 09/06/22 Time: 12:35:15
PROJECT INFORMATION
Company: HGC
Client: EFRI
Test Well: MW-41
AQUIFER DATA
Saturated Thickness: 20. ft
WELL DATA (MW-41)
Initial Displacement: 0.72 ft Static Water Column Height: 20. ft
Total Well Penetration Depth: 20. ft Screen Length: 20. ft
Casing Radius: 0.167 ft Well Radius: 0.26 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: KGS Model
Kr = 2.267E-6 cm/sec Ss = 8.291E-5 ft-1
Kz/Kr = 0.1
0. 200. 400. 600. 800. 1000.
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\MW41\SlugTest\aqtesolv\final\mw41br.aqt
Date: 09/06/22 Time: 12:36:13
PROJECT INFORMATION
Company: HGC
Client: EFRI
Test Well: MW-41
AQUIFER DATA
Saturated Thickness: 20. ft Anisotropy Ratio (Kz/Kr): 0.1
WELL DATA (MW-41)
Initial Displacement: 0.72 ft Static Water Column Height: 20. ft
Total Well Penetration Depth: 20. ft Screen Length: 20. ft
Casing Radius: 0.167 ft Well Radius: 0.26 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: Bouwer-Rice
K = 3.1E-6 cm/sec y0 = 0.625 ft
0.1 1. 10. 100. 1000. 1.0E+4
0.
0.2
0.4
0.6
0.8
1.
Time (min)
Di
s
p
l
a
c
e
m
e
n
t

(
f
t
)
WELL TEST ANALYSIS
Data Set: H:\718000\MW41\SlugTest\aqtesolv\final\mw41h.aqt
Date: 09/07/22 Time: 10:23:18
PROJECT INFORMATION
Company: HGC
Client: EFRI
Test Well: MW-41
AQUIFER DATA
Saturated Thickness: 20. ft
WELL DATA (MW-41)
Initial Displacement: 0.71 ft Static Water Column Height: 20. ft
Total Well Penetration Depth: 20. ft Screen Length: 20. ft
Casing Radius: 0.167 ft Well Radius: 0.26 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: KGS Model
Kr = 2.991E-6 cm/sec Ss = 0.00017 ft-1
Kz/Kr = 0.1
0. 300. 600. 900. 1.2E+3 1.5E+3
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\MW41\SlugTest\aqtesolv\final\mw41hbr.aqt
Date: 09/07/22 Time: 10:24:05
PROJECT INFORMATION
Company: HGC
Client: EFRI
Test Well: MW-41
AQUIFER DATA
Saturated Thickness: 20. ft Anisotropy Ratio (Kz/Kr): 0.1
WELL DATA (MW-41)
Initial Displacement: 0.71 ft Static Water Column Height: 20. ft
Total Well Penetration Depth: 20. ft Screen Length: 20. ft
Casing Radius: 0.167 ft Well Radius: 0.26 ft
Gravel Pack Porosity: 0.3
SOLUTION
Aquifer Model: Unconfined Solution Method: Bouwer-Rice
K = 3.818E-6 cm/sec y0 = 0.57 ft

APPENDIX D

SLUG TEST DATA