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HomeMy WebLinkAboutDRC-2011-007141 - 0901a0688025a866DENISO MINES Denison Mines (USA) Corp. 1050 17th Street, Suite 950 Denver, CO 80265 USA Tel : 303 628-7798 Fax : 303 389-4125 www.denisonmines.com 14 August 8, 2011 VIA PDF AND FEDEX Rusty Lundberg, Co-Executive Secretary Utah Water Quality Board Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4850 Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part l.G.l (a) Dear Mr. Lundberg: The White Mesa Mill (the "Mill") performed second quarter ("Q2") groundwater monitoring during the period from April 1, to June 20, 2011 under the February 15, 2011 version of the Mill's Groundwater Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs was received during the period ending July 8, 2011. Pursuant to Part I.G.l.a) of the GWDP, (February 15, 2011) please take notice that the concentrations of specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for the second quarter in the attached Table 1, exceeded their respective GWCLs. For ease of review, Table 1 has been formatted to simplify the tracking of any continued exceedances from one monitoring period to the next by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics). Part l.G.l c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to the Executive Secretary a plan and a 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 insure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT will be reestablished." The summary below relating to the second quarter 2011 exceedances includes, for each exceedance, a brief discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of Page 1 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201Ldocx other actions currently being undertaken by Denison, as determined by Utah Department of Environmental Quality (UDEQ) Staff as stated in teleconferences with Denison on April 27 and May 2, 2011. Where applicable, the plan and time schedule for assessment will be submitted to the Executive Secretary within 30 days of this exceedance notice. Under the February 15, 2011 revision of the GWDP, GWCLs have been determined on a well- by-well basis to reflect background groundwater quality, as defined by the mean plus second standard deviation concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that, because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to groundwater from Mill operations. The following are items of note relevant to all exceedance data presented herein: 1. Nitrate + nitrite and chloride in monitoring wells at the site are the subject of an ongoing investigation. In the December 30, 2009 Nitrate Contamination Investigation Report, prepared by Intera, Inc., Intera has concluded that the elevated nitrate + nitrite and chloride concentrations observed at the Mill resulted from sources unrelated to the Mill's operations. UDEQ subsequently determined that the CIR is incomplete, and Denison has agreed to perform an expanded investigation into potential Mill-related and non-Mill related sources. Additional investigations and negotiations with UDEQ are currently in progress. Based on information provided by UDEQ in teleconferences on April 27, and May 2, 2011, due to the ongoing investigations, the 30-day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at this time. 2. As discussed in previous quarterly groundwater sampling reports, the background levels and GWCLs for pH were established based on eight or more quarters of laboratory data, which are historically higher than field data due to effects from the evolution of carbon dioxide, and subsequent increase in pH from field to lab. Denison's letter to the Co- Executive Secretary of the Utah Water Quality Board dated January 31, 2011 proposed the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by Denison's geochemical consultant, INTERA, Inc., Denison compared the Mill's most recent groundwater pH data from the second quarter of 2011, including accelerated sampling results as recent as June 2011, and noted that all of the June 2011 groundwater results, and many of the other results fi:-om the second quarter, were already outside the revised GWCLs to be proposed in the June 30, 2011 letter. By the letter dated June 30, 2011, Denison proposed to submit to DRC by August 31, 2011 a Work Plan and Schedule to complete investigations to address the site-wide pH issue. Denison also requested the opportunity for a meeting with DRC in July or August 2011, to discuss Denison's findings to date and to agree upon the steps and milestone dates to be incorporated in the Work Plan and Schedule. Based on information provided by UDEQ in Page 2 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 20n.docx teleconferences on April 27, and May 2, 2011, due to the current commitment to provide a Work Plan and Schedule for field pH, the 30-day plan and schedule for assessment is not required for field pH exceedances. 1.0 Exceedances in Required Quarterly Sampling Wells 1.1 Quarterly Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods as of the second quarter 2011. Where applicable, the 30-day plan and schedule for assessment described above will be submitted under separate cover for consecutive exceedances which first occurred in the second quarter of 2011. One time exceedances are noted on Table 1, and listed below. Consecutive exceedances which occurred in previous reporting periods are discussed in the respective Exceedance Notice for that quarter. MW-11 Manganese concentrations exceeded the GWCL in MW-11 in the April (Q2) and May sampling events. Manganese has periodically exceeded the GWCL in MW-11 since the issuance of the January 20, 2010 GWDP, which established intra-well GWCLs. The consecutive manganese exceedances noted in MW-11 were previously discussed in the Plan and Time Schedule Under Part LGA (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. MW-14 • Field pH has been slighfly outside (slighfly lower than) the GWCL in MW-14 in the April (Q2), May and June sampling events. As mentioned above, site-wide pH issues and trends are currently under re-evaluation. MW-25 • Field pH has been slighfly outside (slighfly lower than) the GWCL in MW-25 in the May and June sampling events. As mentioned above, site-wide pH issues and trends are currently under re-evaluation. • Uranium concentrations exceeded the GWCL in MW-25 in the May and June sampling events. This is the first consecutive exceedance for uranium in MW-25. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days ofthis Exceedance Notice. MW-26 • Chloroform in MW-26 has exceeded its GWCL for all of the monitoring periods for 2011. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of chloroform. Page 3 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx • Methylene chloride exceeded its GWCL in the May and June monthly sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of methylene chloride. MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January 20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform removal, concentrations of all constituents in that well are subject to potential variation over time as a result of the pumping activity. This will be taken into account by the Executive Secretary in determining compliance for this well." Based on information provided by UDEQ in teleconferences on April 27, and May 2, 2011, due to the current pumping status as part of the chloroform program, the 30-day plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene chloride in MW-26. Field pH has been slightly outside (slightly lower than) the GWCL in MW-26 in the April (Q2), May and June sampling events. As mentioned above, site-wide pH issues and trends are currently under re-evaluation. Uranium concentrations exceeded the GWCL in MW-26 in the April (Q2) and May sampling events. Uranium has periodically exceeded the GWCL in MW-26 since the issuance of the January 20, 2010 GWDP, which established intra-well GWCLs. The consecutive uranium exceedances noted in MW-26 were previously discussed in the Plan and Time Schedule Under Part LGA (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. Chloride concentrations exceeded its GWCL in both the Ql and Q2 2011 sampling events. This is the first consecutive exceedance of chloride in MW-26. However, as mentioned above, chloride concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-30 • Nitrate + nitrite concentrations exceeded its GWCL in all sampling events during the second quarter 2011 and during previous quarters. As mentioned above, nitrate + nitrite concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. • Chloride concentrations exceeded its GWCL in the consecutive samples collected in Ql and Q2 2011. As mentioned above, chloride concentrations are currently under re- evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. Page 4 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx Selenium concentrations exceeded its GWCL in all sampling events during the second quarter 2011. Selenium has exceeded the GWCL in MW-30 since the issuance of the January 20, 2010 GWDP, which established intra-well GWCLs. The consecutive selenium exceedances noted in MW-30 were previously discussed in the Plan and Time Schedule Under Part IG. 4 (d), submitted to UDEQ on June 13,2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. MW-31 Nitrate + nitrite concentrations exceeded its GWCL in all sampling events during the second quarter 2011 and during previous quarters. As mentioned above, nitrate + nitrite concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-35 Manganese concentrations exceeded the GWCL in MW-35 in the Ql and Q2 sampling events. This is the first consecutive exceedance of manganese in MW-35. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. It should be noted that background has not yet been established for MW-35 and that the interim GWCLs for MW-35 have been set at a fraction of the Groundwater Quality Standards pending the determination of background. Therefore, exceedance of these interim GWCLs do not necessarily represent impacts to groundwater from Mill activities. Uranium concentrations exceeded the GWCL in MW-35 in the Ql and Q2 sampling events. This is the first consecutive exceedance of uranium in MW-35. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days ofthis Exceedance Notice. It should be noted that background has not yet been established for MW-35 and that the interim GWCLs for MW-35 have been set at a fraction of the Groundwater Quality Standards pending the determination of background. Therefore, exceedance of these interim GWCLs do not necessarily represent impacts to groundwater from Mill activities. 1.2 Quarterly Wells with New Exceedances Reported in Q2 New exceedances for the quarterly well sampling program are listed below. The exceedances listed will result in an accelerated sampling frequency from quarterly to monthly. It is important to note that the wells listed below will only be sampled for those constituents which exceeded the GWCLs during the monthly events. The wells listed below will be sampled for all constituents listed in the GWDP during the quarterly events as that is the regularly scheduled sampling for the quarterly wells. Page 5 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx • Field pH in MW-30 was slighfly outside (lower than) the GWCL in the June sampling event • Field pH in MW-31 was slightly outside (lower than) the GWCL in the June sampling event. 2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly 2.1 Semi-annual Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods (Ql [2011] and Q2 [2011]). MW-3 Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql sampling event and the Q2 sampling event. As mentioned above, site-wide pH issues and trends are currently under re-evaluation, and a plan and schedule to address this consecutive exceedance is not necessary and is not being submitted. Selenium has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. The consecutive selenium exceedances noted in MW-3 were previously discussed in the Plan and Time Schedule Under Part LGA (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. MW-18 Thallium has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. The consecutive thallium exceedances noted in MW-18 were previously discussed in the Plan and Time Schedule Under Part L.G A (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessaryand is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. TDS has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. This is the first consecutive exceedance of TDS in MW-18. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice for the TDS exceedance. MW-24 Field pH has been slighfly outside (slighfly lower than) the GWCL for both the Ql sampling event and the Q2 sampling event. As mentioned above, site-wide pH issues and trends are currently under re-evaluation, and a plan and schedule to address this consecutive exceedance is not necessary and is not being submitted. Thallium has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. Page 6 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx • Cadmium has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. The consecutive thallium and cadmium exceedances noted in MW-24 were previously discussed in the Plan and Time Schedule Under Part L.G A (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. MW-27 Nitrate + Nitrite have exceeded the GWCL for both the Ql sampling event and the Q2 sampling event and during previous quarters. As mentioned above, nitrate + nitrite concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. Chloride has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event and during previous quarters. As mentioned above, chloride concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. TDS has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event. The consecutive TDS exceedances noted in MW-27 were previously discussed in the Plan and Time Schedule Under Part L.G.4 (d), submitted to UDEQ on June 13, 2011. An additional plan or schedule to address the Q2 exceedances is not necessary and is not being submitted because the assessment processes and schedule have not changed since the June 13, 2011 submission. MW-28 Field pH has been slightly outside (slighfly lower than) the GWCL for both the Ql sampling event and the Q2 sampling event and during previous quarters. As mentioned above, site-wide pH issues and trends are currently under re-evaluation, and a plan and schedule to address this consecutive exceedance is not necessary and is not being submitted. Chloride has exceeded the GWCL for both the Ql sampling event and the Q2 sampling event and during previous quarters. As mentioned above, chloride concentrations are currently under re-evaluation and a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-29 Field pH has been slighfly outside (slightly lower than) the GWCL for both the Q4 sampling event and the Q2 sampling event (Q4 and Q2 are the last two consecutive sampling events). As mentioned above, site-wide pH issues and trends are currently under re-evaluation, and a plan and schedule to address this consecutive exceedance is not necessary and is not being submitted. Page 7 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx MW-32 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 sampling event and the Ql sampling event and during previous quarters. As mentioned above, site-wide pH issues and trends are currently under re-evaluation, and a plan and schedule to address this consecutive exceedance is not necessary and is not being submitted. 2.1 Semi-annual Wells with New Exceedances Reported in Q2 New exceedances for the semi-annual well sampling program are listed below. The exceedances listed will result in an accelerated sampling frequency from semi-annually to quarterly. It is important to note that during the first and third quarterly events the wells listed below will only be sampled for those constituents which exceeded the GWCLs because the first and third quarterly events do not include the semi-annual well sampling program. The wells listed below will be sampled for all constituents listed in the GWDP during the second and fourth quarter events as that is the regularly scheduled sampling for the semi-annual wells. • Iron in MW-29 exceeded the GWCL in the Q2 sampling event in April 2011. If you have any questions or require any ftirther information, please contact the undersigned. Yours truly. Jo Ann Tischler Director, Compliance and Permitting cc: David Frydenlund Ron Hochstein Ryan Palmer Harold Roberts David Turk Kathy Weinel Page 8 N:\Notices\GW Exceedence notices\08.08.11 Notice\Notice_of_Exceedance_GW_Q2_8 201 l.docx Tabic 1 - GWCL Exceedances for Second Quarter 2011 under the February 15, 2011 GWDP Ql Results^ Q2 Results Q3 Results Q4 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Jun 17, 2010 GWDP Q" Sample Date Ql Result Q2 Sample Date Q2 Result May Monthly Sample Date May Monthly Result June Monthly Sample Date June Month l> Result July Monthly Sample Date July Monthly Result August Monthly Sample Date August Monthly Result Q3 Sample Date Q3 Resuil October Monthly Sample Date October Monthly Result Q4 Sample Date Q4 Result December Monlhly Sample Date December Monthly Result Required Quarterly Sam )ling \N ells MW-11 (Class 11) Manganese (ug/L) 131.29 2/10/10 134 4/28/10 137 5/24/10 122 6/16/10 99 7/20/10 123 8/25/10 138 9/8/10 128 10/20/10 141 11/11/10 133 12/15/10 158 MW-11 (Class 11) Tetrahydrofuran (ug/L) II.5 2/10/10 12 4/28/10 5.2 5/24/10 <I.O 6/I6/I0 <1.0 7/27/10 2.17 8/25 10 - 1.0 9/8/10 • I.O 10/20/10 < 1.0 11/11/10 <1.0 12/15/10 <I.O MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 2/2/10 6.45 4/21/10 6.29 5/2I/I0 6.36 6/16/10 6.45 7/20/10 7.19 8/25/10 6.48 9/8/10 6.51 10/20/10 6.60 11/10/10 6.37 12/15/10 6.47 MW-25 (Class III) I ield pll (S.U.) 6.5 - 8.5 2/26/2010 6.53 4/28/2010 7.2 \S NA \s NA NS NA NS NA 9/8/2010 6.58 NS NA 11/10/10 6.36 NS NA MW-25 (Class III) Uranium 6.5 2/26/2010 5.93 4/28/2010 6.43 NS NA NS NA NS NA NS NA 9/8/2010 6.57 NS NA 11/10/10 5.89 NS NA MW-26 (Class 111) Nitrate + Nitrite (as N) (mg/L) 0.62 2/2/10 1.3 4/22/10 2 5/21/10 0.3 6/16/10 0.4 7/21/10 0.6 8/16/10 0.6 9/26/10 0.7 10/20/10 0.4 11/15/10 0.2 12/15/10 0.4 MW-26 (Class 111) Uranium (ug/L) 41.8 2/2/10 58.7 4/22/10 66.7 5/21/10 37.4 6/16/10 36.6 7/21/10 34.4 8/16/10 71.8 9/26/10 72.7 10/20/10 37.5 11/15/10 30.4 12/15/10 29.6 MW-26 (Class 111) Chloroform (ug/L) 70 2/2/10 700 4/22/10 1700 5/21/10 800 6/16/10 940 7/21/10 900 8/16/10 2800 9/26/10 2100 10/20/10 1000 11/15/10 1900 12/15/10 1400 MW-26 (Class 111) Chloride (mg/L) 58.31 2/2/10 72 4/22/10 57 5/21/10 80 6/16/10 47 7/21/10 52 8/16/10 49 9/26/10 64 10/20/10 52 11/15/10 48 12/15/10 52 MW-26 (Class 111) Held pll (S.U.) 6.74 - 8.5 2/2/10 6.59 4/22/10 7.18 5/21/10 6.36 6/16/10 6.98 7/21/10 6.45 8/16/10 6.39 9/26/10 6.60 10/20/10 6.61 11/15/10 6.49 12/15/10 6.45 MW-26 (Class 111) Dichloromethane (Methylene Chloride) (ug/L) 5 2/2/10 1 4/22/10 9.9 5/21/10 NR 6/16/10 2.2 7/21/10 12 8/16/10 24 9/26/10 45 10/20/10 5.5 11/15/10 16 12/15/10 1.2 MW-26 (Class 111) TDS (mg/L) .3284.19 2/2/10 3100 4/22/10 3280 5/21/10 NS 6/16/10 NS 7/21/10 NS 8/16/10 NS 9/26/10 3440 10/20/10 NS 11/15/10 3140 12/15/10 NS MW-26 (Class 111) Gross Alpha minus Rn & U (pCi/L) 4.69 2/2/10 2.4 4/22/10 0.6 5/21/10 NS 6/16/10 NS 7/21/10 NS 8/16/10 NS 9/26/10 2.5 10/20/10 NS 11/15/10 6.4 12/15/10 NS MW-30 (Class 11) Nitrate + Nitrite (as N) (mg/L) 2.5 2/9/10 16.1 4/27/10 15.8 5/21/10 17 6/15/10 15.3 7/21/10 16 8/24/10 16 9/14/10 15 10/19/10 15 11/9/10 15 12/14/10 16 MW-30 (Class 11) Chloride (mg/L) 128 2/9/10 127 4/27/10 97 5/21/10 NS 6/15/10 NS NS NS NS NS 9/14/10 \ 11 10/19/10 NS 11/9/10 126 12/14/10 NS MW-30 (Class 11) Fidd pH (S.U.) 6.5 - 8.5 2/9/10 6.81 4/27/10 6.55 5/21/10 6.62 6/15/10 7.47 7/21/2010 6.82 8/24/10 6.73 9/14/10 6.80 10/19/10 6.77 11/9/10 6.75 12/14/10 6.65 MW-30 (Class 11) Selenium (ug/L) 34 2/9/10 32 4/27/10 5/21/10 NS 6/15/10 NS 7/27/10 33.5 8/24/10 .?5.6 9/14/10 32.6 10/19/10 32.4 11/9/10 32.2 12/14/10 .30.5 MW-31 (Class 111) Nitrate + Nitrite (as N) (niR/L) 5 2/9/10 21.7 4/20/10 22.5 5/21/10 23 6/15/10 21.1 7/21/10 20 8/24/10 22 9/13/10 21 10/19/10 20 11/9/10 20 12/14/10 20 MW-31 (Class 111) TDS(mg1) 1320 2/9/10 1150 4/20/10 1220 NS NA NS NA NS NA NS NA 9/13/10 1330 NS NA 11/9/10 1320 12/14/10 NS MW-31 (Class 111) Chloride (mg/L) 143 2/9/10 128 4/20/10 128 NS NA NS NA NS NA NS NA 9/13/10 139 NS NA 11/9/10 138 12/14/10 NS MW-31 (Class 111) Field pH (S.U.) 6.5 - 8.5 2/9/10 6.96 4/20/10 7.38 5/21/10 6.95 6/15/10 7.01 7/2I/I0 7.8 8/24/10 7.1 9/13/10 7.66 10/19/10 6.92 11/9/10 6.98 12/14/10 6.95 MW-31 (Class 111) Sulfate (mg/L) 532 2/9/10 507 4/20/10 522 NS NA NS NA NS NA NS NA 9/13/10 527 NS NA 11/9/10 539 12/14/10 NS MW-35 (Class 11)^ Manganese (ug/L) 200 NS N.A NS NA NS NA NS NA NS NA NS NA NS NA NS NA 11/30/10 698 ' NS NA MW-35 (Class 11)^ Uranium (ug/L) 7.5 NS NA NS NA NS NA NS NA NS NA NS NA NS NA NS NA 11/30/10 27.2' NS NA Required Semi-Annual Sampling Wells MW-2 (Class 111) Gross Alpha minus Rn & U (pCi/L) 3.2 NS NA 1.2 NS NA NS NA NS NA NS NA NS NA NS NA 3.5 NS NA MW-3 (Class 111) Selenium (ug L) 37 NS NA 5/3/10 37.2 NS NA NS NA NS NA NS NA 9/20/10 35.5 NS NA 11/19/10 38.8 NS NA MW-3 (Class 111) Field pH (S.U.) 6.5 - 8.5 NS NA 5/3/10 6.14 (6.25) NS NA NS NA NS NA NS NA 9/20/10 6.39 NS NA 11/19/10 6.35 NS NA MW-3 (Class 111) Fluoride (.VIg/L) 0.68 NS NA 5/3/10 0.71 NS NA NS NA NS NA NS NA 9/20/10 0.63 NS NA 11/19/10 0.77 NS NA MW-3A (Class 111) Field pM (S.U.) 6.5 - 8.5 NS NA 5/4/10 6.23 (6.24) NS NA NS NA NS NA NS NA 9/21/10 6.42 NS NA 11/22/10 6.21 NS NA MW-3A (Class 111) Sulfate (mg/L) 3640 NS NA 5/4/10 3680 NS NA NS NA NS NA NS NA 9/21/10 3630 NS NA 11/22/10 3850 NS NA MW-3A (Class 111) TDS (mg/L) 5805 NS NA 5/4/10 5860 NS NA NS NA NS NA NS NA 9/21/10 5470 NS NA 11/22/10 5330 NS NA MW-3A (Class 111) Selenium (ug/L) 89 NS NA 5/4/10 81.4 NS NA NS NA NS NA NS NA 9/21/10 NS NS NA 11/22/10 94.8 NS NA MW-5 (Class 11) Uranium (ug/L) 7.5 NS NA 4/26/10 0.39 NS NA NS NA NS NA NS NA NS NA NS NA U/Il/lO 11.6 NS NA MW-12 (Cla.ss 111) Field pll (S.U.) 6.5 - 8.5 NS NA 4/27/10 7.16 NS NA NS NA NS NA NS NA 9/20/10 6.62 NS NA 11/19/10 6.47 NS NA MW-12 (Cla.ss 111) Selenium (ug/L) 25 NS NA 4/27/10 25.7 NS NA NS NA NS NA NS NA 9/20/10 31.9 NS NA 11/19/10 27.6 NS NA MW-18 (Class III) rhalliuin (ug/l) 1.95 NS NA 5/4/10 3.73 NS NA NS NA NS NA NS NA 9/15/10 3.64 NS NA 11/18/10 3.57 NS NA MW-18 (Class III) Sulfate (mg/L) 1938.9 NS NA 5/4/10 1950 NS NA NS NA NS NA NS NA 9/15/10 1930 NS NA 11/18/10 1910 NS NA MW-18 (Class III) Field pll (S.U.) 6.25-8.5 NS NA 5/4/10 6.2 NS NA NS NA NS NA NS NA 9/15/10 7.23 \s NA 11/18/10 6.37 NS NA MW-18 (Class III) TDS (mg/L) 3198.77 NS NA 5/4/10 3280 NS NA NS NA NS NA NS \A 9/15/10 3190 NS NA 11/18/10 3030 NS NA Table 1 - GWCL Exceedances for Second Quarter 2011 under the February 15, 2011 GWDP Ql Results Q2 Results Q3 Results Q4 Results .Monitoring Well (Water Class) Consliluent Exceeding GWCL GWCL in Curreni GWDP Ql Sample Date Ql Result Q2 Sample Dale Q2 Result May Month l> Sample Date May Monthly Result June Month l> Sample Datc June Monthly Result July Monthly Sample Date Juiy Monthly Result August Monlhl> Sample Dale August Monlhly Result Q3 Sample Date Q3 Result October Monthly Sample Date October MonihI> Result Q4 Sample Dale Q4 Result December Monthly Sample Date December Monthly Result Required Semi-Annual Sampling Wells, continued MW-19 (Class 111) Field pH (S.U.) 6.78-8.5 NS NA 5/4/10 6.61 (6.66) NS NA NS NA NS NA NS NA 9/15/10 6.93 NS NA 11/18/10 6.8 NS NA MW-23 (Class 111) Field pH (S.U.) 6.5 - 8.5 NS NA 4/22/10 6.18 NS NA NS NA NS NA NS NA 9/14/10 7.05 NS NA 11/22/10 6.44 NS NA MW-24 (Class 111) Cadmium (ug/L) 2.5 NS NA 5/6/10 4.28 NS NA NS NA NS NA NS NA 9/21/10 5.06 NS NA 11/17/10 3.22 NS NA MW-24 (Class 111) Thallium (ug/L) 1 NS NA 5/6/10 1.3 NS NA NS NA NS NA NS NA 9/21/10 1.57 NS NA 11/17/10 1.09 NS NA MW-24 (Class 111) Field pH (S.U.) 6.5 - 8.5 NS NA 5/6/10 5.91 (5.78) NS NA NS NA NS NA NS NA 9/21/10 6.64 NS NA 11/17/10 6.1 NS NA MW-27 (Class 111) Nitrate t Nitrite (as N) (mg/L) 5.6 NS NA 5/3/10 5.8 NS NA NS NA NS NA NS NA 9/I4/I0 5.9 NS NA 11/12/10 5.7 NS NA MW-27 (Class 111) Chloride (mg/L) 38 NS NA 5/3/10 42 NS NA NS NA NS NA NS NA 9/I4/I0 42 NS NA 11/12/10 45 NS NA MW-27 (Class 111) Sulfate (mg/L) 462 NS NA 5/3/10 469 NS NA NS NA NS NA NS NA 9/I4/I0 461 NS NA 11/12/10 452 NS NA MW-27 (Class 111) 1 DS (mg/L) 1075 NS NA 5/3/10 1160 NS NA NS NA NS NA NS NA 9/I4/I0 1060 NS NA 11/12/10 1110 NS NA MW-27 (Class 111) Gross Alpha minus Rn & U (pCi/L) 2 NS NA 5/3/10 1.6 NS NA NS NA NS NA NS NA 9/I4/I0 NA NS NA 11/12/10 2.4 NS NA MW-28 (Class 111) Chloride (mg/L) 105 NS NA 4/19/10 108 NS NA NS NA NS NA NS NA 9/14/10 106 NS NA 11/12/10 107 NS NA MW-28 (Class 111) Field pH (S.U.) 6.1 - 8.5 NS NA 4/19/10 5.67 NS NA NS NA NS NA NS NA 9/14/10 5.91 NS NA 11/12/10 5.72 NS NA MW-29 (Class 111) Iron (ug/L) 1869 NS NA 4/27/10 1630 NS NA NS NA NS NA NS NA NS NA NS NA 11/9/10 1490 NS NA MW-29 (Class 111) Field pll (S.U.) 6.46 - 8.5 NS NA 4/27/10 6.82 NS NA NS NA NS NA NS NA NS NA NS NA 11/9/10 6.17 NS NA MW-32 (Class 111) Gross Alpha minus Rn & U (pCi/L) 3.33 NS NA 4/20/10 5.4 NS NA NS NA NS NA NS NA 9/13/10 2.9 NS NA 11/IO/IO 8.8 NS NA MW-32 (Class 111) Field pll (S.U.) 6.4 - 8.5 NS NA 4/20/10 6.03 NS NA NS NA NS NA NS NA 9/13/10 6.33 NS NA 11/IO/IO 6.05 NS NA Notes: GWCL values are taken from February 15, 2011 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Exceedances are shown in yellow ' The revised pennit dated February 15, 2011 was received after the exceedance notice for 04 was submitted on February ~ The Ql 2011 exceedances noted here were inadvertantly omitted from the Ql Exceedance Notice submitted May 13, 201 4, 2011. It is reported here as an exceedance in this this notice, but was not reported in Q4 2010. . No accelarated monitoring was missed as a result of the omission. Table 1 - GWCL Exceedances for Second Quarter 2011 under the February 15, 2011 GWDP Ql 2011 Results Q2 2011 Results Monitoring Well (Water (lass) Constitueni Exceeding GWCL GWCL in Jun 17, 2010 GWDP Januarv 2011 Monthly Sample Date January 2011 Monthly Sample Result QI 2011 Sample Dale Ql 2011 Result March 2011 Monthly Sample Date March 2011 Monlhly Result Q2 2011 Sample Dale Q2 2011 Result May 2011 Monthly Sample Date May 2011 Monthly Result June 2011 Monthly Sample Dale June 2011 Monlhly Result Sample Frequency MW-I 1 (Class II) Manganese (ug/L) 131.29 l/Il/ll 121 2/2/11 145 3/15/11 68 4/4/2011 148 5/10/2011 170 6/15/2011 121 Quarterly MW-I 1 (Class II) Tetrahydrofuran (ug/L) 11.5 l/Il/ll • 1.0 2/2/11 • 1.0 3/15/11 ! n 4/4/2011 • 1.0 5/10/2011 • 1.0 6 20 201 1 • 1.0 Quarterly MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 l/ll/ll 6.37 2/7/11 6.22 .3/14/11 6.76 4/4/2011 6.63 5/10/2011 6.37 6/15/2011 5.83 Quarterly MW-25 (Class III) Field pll (S.U.) 6.5 - 8.5 1/11/11 6.44 2/2/11 6.66 3/15/11 6.79 4/4/2011 6.7 5/11/20II 6.1 6/20/2011 5.77 Quarterly MW-25 (Class III) Uranium 6.5 1/11/11 7.02 2/2/11 4.77 3/15/11 6.8 4/4/2011 5.56 5/11/20II 6.72 6/20/2011 7.06 Quarterly MW-26 (Cla.ss Hi) Nitrate + Nitrile (as N) (mKl.) 0.62 I/I2/11 0.2 2/16/11 0.25 3/15/11 0.6 4/1/2011 0.8 5/10/2011 0.4 6/20/2011 0.3 Quarterly MW-26 (Cla.ss Hi) Uranium (ug/I.) 41.8 I/I2/11 32 2/16/11 69..? 3/15/11 31.8 4/1/2011 60.2 5/10/2011 57.4 6/20/2011 18.5 Quarterly MW-26 (Cla.ss Hi) Chlorofonn (ug 1.) 70 I/I2/11 800 2/16/11 730 3/15/11 1200 4/1/2011 390 5/10/2011 1900 6/20/2011 730 Quarterly MW-26 (Cla.ss Hi) Chloride (mg L) 58.31 I/I2/11 52 2/16/11 59 3/15/11 64 4/1/2011 64 5/10/2011 54 6/20/2011 39 Quarterly MW-26 (Cla.ss Hi) Field pll (S.U.) 6.74 - 8.5 I/I2/11 6.83 2/16/11 6.06 3/15/11 6.89 4/1/2011 6.22 5/10/2011 6.43 6/20/2011 6.52 Quarterly MW-26 (Cla.ss Hi) Dichloromethane (Methylene Chloride) (uu/L) 5 I/I2/11 <1.0 2/16/11 10 3/15/11 14 4/1/2011 3.1 5/10/2011 20 6/20/2011 7 Quarterly MW-26 (Cla.ss Hi) TDS (mg/L) 3284.19 I/I2/11 3100 2/16/11 3270 3/15/11 3140 4/1/2011 3310 5/10/2011 3140 3020 Quarterly MW-26 (Cla.ss Hi) Gross Alpha minus Rn & U \pCi/L) 4.69 I/I2/11 NS 2/16/11 3 3/15/11 2.7 4/1/2011 3.3 5/10/2011 .3.9 4.3 Quarterly MW-30 (Class II) Nitrate Nitrite (as N) (mn/L) 2.5 1/10/11 15 2/1/11 16 3/14/11 17 4/11/2011 16 5/10/2011 16 6/20/2011 17 Quarterly MW-30 (Class II) Chloride (mg 1.) 128 1/10/11 NS 2/1/11 134 3/14/11 NS 4/11/2011 134 5/10/2011 128 6/20/2011 127 Quarterly Quarterly MW-30 (Class II) Field pll (S,U.) 6.5 - 8.5 1/10/11 6.65 2/1/11 6.96 3/14/11 7.10 4/11/2011 6.83 5/10/2011 6.7 6/20/2011 5.66 Quarterly Quarterly MW-30 (Class II) Selenium (ug/L) 34 1/10/11 36.2 2/1/11 34.^ 3/14/11 34 4/11/2011 44.4 5/10/2011 38.3 6/20/2011 38.7 Quarterly MW-31 (Class III) Nitrate + Nitrite (as N) (mn/l.) 5 I/IO/II 19 2/1/11 21 3/14/11 22 4/1/2011 21 5/10/2011 20 6/20/2011 22 Quarterly MW-31 (Class III) TDS (mg/L) 1320 I/IO/II 1240 2/1/11 1220 3/14/11 1250 4/1/2011 1370 5/10/2011 1290 6/20/2011 1330 Quarterly MW-31 (Class III) Chloride (mg/L) 143 I/IO/II NS 2/1/11 145 3/14/11 NS 4/1/2011 143 5/10/2011 143 6/20/2011 145 Quarterly MW-31 (Class III) Field pll (S.U.) 6.5 - 8.5 I/IO/II 6.65 2/1/11 7.21 3/14/11 7.43 4/1/2011 7.01 5/10/2011 6.73 6/20/2011 6.16 Quarterly MW-31 (Class III) Sulfate (mg/L) 532 I/IO/II NS 2/1/11 538 3/14/11 531 4/1/2011 503 5/10/2011 512 6/20/2011 540 (,)uailcrly MW-35 (Class 11)^ Manganese (ug/L) 200 NS NA 2/15/11 248 NS NA 6/7/2011 369 NS NA NS NA Quarterly MW-35 (Class 11)^ Uranium (ug/L) 7.5 NS NA 2/15/11 12.7 NS NA 6/7/2011 21.7 NS NA NS NA Quarterly Re(|uired Semi-.-\nnual Sampling Wells MW-2 (Class 111) Gross Alpha minus Rn & U (pCi/L) 3.2 NS NA l.l NS NA 4/12/2011 1.2 NS NA NS NA Semi-Annually MW-3 (Class III) Selenium (ug/L) 37 NS NA 2/15/11 40.5 NS NA 4/13/2011 45.4 NS NA NS NA Sani-Annuallv MW-3 (Class III) Field pH (S.U.) 6.5 - 8.5 NS NA 2/15/11 6.09 NS NA 4/13/2011 6.46 NS NA NS NA Semi-Annually MW-3 (Class III) Fluoride (MgL) 0.68 NS NA 2/15/11 0.69 NS NA 4/13/2011 0.68 NS NA NS NA Semi-Annually MW-3A (Class III) Field pH (S.U.) 6.5 - 8.5 NS NA 2/16/11 6.05 NS NA 4/13/2011 6.58 NS NA NS NA Semi-Annually MW-3A (Class III) Sulfate (mg/L) 3640 NS NA 2/16/11 3730 NS NA 4/13/2011 3350 NS NA NS NA Semi-Annually MW-3A (Class III) TDS (mg/L) 5805 NS NA 2/16/11 5770 NS NA 4/13/2011 5720 NS NA NS NA Semi-Annually MW-3A (Class III) Selenium (ug/L) 89 NS NA 2/16/11 99 NS NA 4/13/2011 85.8 NS NA NS NA Semi-Annually MW-5 (Class 11) Uranium (ug/L) 7.5 NS NA 2/14/11 29.5 NS NA 4/12/2011 7.16 NS NA NS NA Semi-Annually MW-12 (Class 111) Field pH (S.U.) 6.5 - 8.5 NS NA 2/15/11 6.43 NS NA 4/5/2011 6.67 NS NA NS NA Semi-Annually MW-12 (Class 111) Selenium (ug/L) 25 NS NA 2/15/11 39 NS NA 4/5/2011 21.7 NS NA NS NA Semi-Annually MW-18 (Class III) 1 h.illium (ug/l) 1.95 NS NA 2/15/11 3.49 NS NA 4/6/2011 3.74 NS NA NS NA Semi-Annually MW-18 (Class III) Sulfate (mg L) 1938.9 NS NA 2/15/11 1770 NS NA 4/6/2011 1780 NS NA NS NA Semi-Annually MW-18 (Class III) Field pH(S.U.) 6.25-8.5 NS NA 2/15/11 6.27 NS NA 4/6/2011 6.71 NS NA NS NA Semi-Annually MW-18 (Class III) 1DS(mgI) 3198.77 NS NA 2/15/11 3250 NS NA 4/6/2011 3250 NS N \ \^ NA Semi-Annually Table 1 - GWCL Exceedances for Second Quarter 2011 under the February 15, 2011 GWDP Ql 2011 Results Q2 2011 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Curreni GWDP January 2011 Monthly Sample Date January 2011 Monthly Sample Result Ql 2011 Sample Date Ql 2011 Result March 2011 Monlhly Sample Datc March 2011 Monthly Result 02 2011 Sample Date Q2 2011 Result May 2011 Monthly Sample Dale May 2011 Monthly Resuil June 2011 Monthly Sample Date June 2011 Monthly Result Sample Erequency Required Semi-Annual Sampling Wells, continued MW-19 (Class III) Field pH (S.U.) 6.78-8.5 NS NA 2/21/2011 6.78 NS NA 4/5/2011 7.03 NS NA NS NA Semi-Annually MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 NS NA 2/9/2011 6./.? NS NA 4/5/2011 7.14 NS NA NS NA Semi-Annually MW-24 (Class III) Cadmium (ug/L) 2.5 NS NA 2/10/2011 2.78 NS NA 4/5/2011 2.61 NS NA NS NA Semi-Annually MW-24 (Class III) Thallium (ug/L) 1 NS NA 2/10/2011 1.42 NS NA 4/5/2011 1.07 NS NA NS NA Semi-Annually MW-24 (Class III) Field pH (S.U.) 6.5 - 8.5 NS NA 2/10/2011 5.73 NS NA 4/5/2011 6.12 NS NA NS NA Semi-Annually MW-27 (Class III) Nitrate i Nitrite (as N) (mg/L) 5.6 NS NA 2/9/2011 6 NS NA 4/5/2011 6.4 NS NA NS NA Semi-Annually MW-27 (Class III) Chloride (mg/L) 38 NS NA 2/9/2011 46 NS NA 4/5/2011 43 NS NA NS NA Semi-Annually MW-27 (Class III) Sulfate (mg/L) 462 NS NA 2/9/2011 455 NS NA 4/5/2011 442 NS NA NS NA Semi-Annual lv MW-27 (Class III) 1 DS (mg/L) 1075 NS NA 2/9/2011 1090 NS NA 4/5/2011 1190 NS NA NS NA Semi-Annually Gross Alpha minus Rn & U (pCi/L) 2 NS NA 0.7 NS NA 1.1 NS NA NS NA Semi-Annually MW-28 (Class III) Chloride (mg/L) 105 NS N \ 2/14/2011 114 NS NA 4/11/2011 109 NS NA NS NA Semi-Annually MW-28 (Class III) Field pH (S.U.) 6.1 - 8.5 NS NA 2/14/2011 5.69 ^NS NA 4/11/2011 6.01 NS NA NS NA Semi-Annually MW-29 (Class III) Iron (ug/L) 1 S69 NS NA NS NA NS NA 4/18/2011 3010 NS NA NS N A Semi-Annually MW-29 (Class III) Field pll (S.U.) 6.46-8.5 NS NA NS NA NS NA 4/18/2011 6.45 NS NA NS NA Semi-Annually MW-32 (Class 111) Gross Alpha ininus Rn & U (pCi/L) 3.33 NS NA 2/9/2011 1.5 NS NA 4/1/2011 4.6 NS NA NS NA Semi-Annually MW-32 (Class 111) 1 ielil pll (S.U.) 6.4 - 8.5 NS NA 2/9/2011 5.99 NS NA 4/1/2011 6.14 NS NA NS NA Semi-Annually Notes: GWCL values are taken from February 15, 2011 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applieable Exceedances are shown in yellow • l he Ql 2011 exceedances noted here were inadvertantly omitted Irom the Ql Exceedance Notice submitted May 13, 2011. No accelarated monitoring was missed as a result of the omission.