DRC-2016-003562 - 0901a06880607332

^^gf^NERGYFUELS Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
February 11, 2016 Div of Waste Management
and R'iHl;itmn Control
VIA PDF AND OVERNIGHT DELIVERY
Scott Anderson,
Director of Waste Management and Radiation Control DRC-ZO\(a
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.1 (a)
Dear Mr. Anderson:
The White Mesa Mill (the “Mill”) performed fourth quarter (“Q4”) groundwater monitoring during the
period from October 1, to December 31, 2015 under the August 24, 2012 version of the Mill’s
Groundwater Discharge Permit (the “GWDP”). All analytical data needed for comparison to the GWCLs
were received during the period ending January 13, 2016.
Pursuant to Part I.G.l.a) of the GWDP, (August 24, 2012) please take notice that the concentrations of
specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this
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 I.G. 1 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 ensure 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 Q4 2015 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 other actions currently being undertaken by Energy Fuels Resources
(USA) Inc. (“EFRI”) or in light of other reports submitted by EFRI, and as determined by Division of
Waste Management and Radiation Control (“DWMRC”) Staff. A description of the other actions and
reports which have affected the requirement to submit a plan and time schedule are as follows:
1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing
investigations at the Mill. Based on the results of the previous investigations, EFRI and the
Director acknowledged that it has not been possible to date to determine the source(s), cause(s),
attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride
in groundwater. EFRI submitted a Corrective Action Plan (“CAP”) in February 2012 for nitrate
+ nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the
activities associated with the CAP are on-going. Based on information provided by DWMRC in
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teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, 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. EFRI’s letter to the Director dated January 31,2011 proposed
the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by
EFRFs geochemical consultant, INTERA, Inc., EFRI compared the Mill’s groundwater pH data
from Q2 2011 and noted that all of the June 2011 groundwater results, and many of the other
results from Q2 2011, were already outside the revised GWCLs that were to be proposed in the
June 30, 2011 letter. Pursuant to teleconferences with DWMRC on December 5, and December
19, 2011, EFRI submitted a Work Plan and Schedule on January 20, 2012 and a revised plan
based on DWMRC comments on April 13, 2012. Based on the approved Work Plan and Time
Schedule, EFRI and DWMRC entered into a Stipulated Consent Agreement (“SCA”) dated July
12, 2012. The SCA required the completion of the pH Report and the Pyrite Investigation and
associated report. The pH Report and Pyrite Investigation Report were submitted November 9,
2012 and December 7, 2012 respectively. By letter dated April 25, 2013, DWMRC accepted the
conclusions that the out-of-compliance results for pH are due to background effects within the
aquifer matrix and are not caused by Mill activities. DWMRC also approved the recalculation of
the GWCLs. As a result, the 30-day plan and schedule for assessment is not required for field pH
exceedances.
3. A Plan and Time Schedule will not be prepared for monitoring wells with two successive
exceedances if successive exceedances were reported in a previous quarter and were included in
the Source Assessment Reports (“SARs”), submitted October 10, 2012, May 8, 2013, August 30,
2013, December 17, 2013, January 13, 2014, and March 19, 2014 and the Plan and Time
Schedules submitted May 19, and September 10, 2015. A Plan and Time Schedule will not be
submitted for those constituents covered by the previously mentioned SARs, because the
conclusions and actions delineated in those reports were either accepted by DWMRC as
documented in DWMRC correspondence dated April 25, 2013, July 23, 2013, September 17,
2013 January 7, 2014, March 10, 2014, and June 5, 2014 respectively.
4. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program
and are covered by State of Utah Notice of Violation (“NOV”) and Groundwater Corrective
Action Order (“CAO”) State of Utah Department of Environmental Quality (“UDEQ”) Docket
No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and
methylene chloride exceedances is not required.
It is important to note that under 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. In fact, more frequent sampling of a
given analyte will increase the number of exceedances due to statistical variation and not due to Mill
activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a
Letter to Mr. Scott Anderson
February 11, 2016
Page 2
monthly frequency can result in resampling of essentially the same water and can lead to repeat
exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same
water.
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 in Q4 2015. A 30-day plan and schedule contemplated in Part I.G.l c)
of the GWDP will not be required for the consecutive exceedances below for the reasons stated below.
One-time exceedances and non-successive exceedances are noted on Table 1, but not listed below.
Consecutive exceedances which occurred in previous reporting periods are discussed in the SARs
submitted to DWMRC October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13,
2014, March 19, 2014 and the Plan and Time Schedules submitted May 19, September 10, and December
9, 2015.
MW-11
Letter to Mr. Scott Anderson
February 11, 2016
Page 3
• Manganese concentrations exceeded the GWCL in MW-11 in September 2015 and October 2015
monthly sampling events. This consecutive exceedance is addressed in the SAR, dated October
10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC.
The recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
MW-26
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2015 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• Chloroform has exceeded its GWCL for all of the Q4 2015 sampling events. MW-26 is used as a
pumping well for the ongoing chloroform capture program and is expected to yield increased
concentrations of chloroform. Because this well is used in the chloroform capture program
which is the subject of separate investigations and actions, a plan and time schedule to address the
consecutive exceedances is not necessary and is not being submitted.
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 DWMRC in teleconferences
on April 27, and May 2, 2011, due to the current pumping status as part of the chloroform investigation
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.
Letter to Mr. Scott Anderson
February 11, 2016
Page 4
• The uranium concentration exceeded its GWCL in all of the Q4 2015 sampling events. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR,
the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of
DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to address this
consecutive exceedance is not necessary and will not be submitted. Until such time as the new
GWCLs become effective, the exceedances will continue to be noted and reported.
• Field pH has been slightly outside (slightly lower than) the GWCL in the Q4 2015 (November)
and December monthly sampling events. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• The chloride concentration exceeded its GWCL in all of the Q4 2015 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
• Methylene chloride has exceeded its GWCL in the Q4 2015 (November) and December 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. Because this well is used in the
chloroform capture program which is the subject of separate investigations and actions, a plan
and time schedule to address the consecutive exceedances is not necessary and is not being
submitted.
MW-30
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2015 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL all of the Q4 2015 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
Letter to Mr. Scott Anderson
February 11,2016
Page 5
• The selenium concentration exceeded its GWCL in all of the Q4 2015 sampling events. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR,
the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of
DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to address this
consecutive exceedance is not necessary and will not be submitted. Until such time as the new
GWCLs become effective, the exceedances will continue to be noted and reported.
MW-31
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2015 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL in all of the monitoring periods for Q4 2015. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
• The sulfate concentration exceeded its GWCL in all of the monitoring periods for Q4 2015. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012 and the Plan and Time
Schedule which was submitted to DWMRC on May 19, 2015 and approved by DWMRC on
August 11, 2015. A SAR was submitted on December 9, 2015. Therefore, a plan and schedule for
assessment will not be submitted under separate cover within 30 days of this Exceedance Notice.
• The selenium concentration exceeded its GWCL in all of the monitoring periods for Q4 2015.
This consecutive exceedance is addressed in the SAR, dated August 13, 2013 and the Plan and
Time Schedule which was submitted to DWMRC on May 19, 2015 and approved by DWMRC
on August 11, 2015. A SAR was submitted on December 9, 2015. Therefore, a plan and schedule
for assessment will not be submitted under separate cover within 30 days of this Exceedance
Notice.
• The Total Dissolved Solids (“TDS”) exceeded its GWCL in all of the monitoring periods for Q4
2015. This consecutive exceedance is addressed in the SAR, dated October 10, 2012 and the Plan
and Time Schedule which was submitted to DWMRC on May 19, 2015 and approved by
DWMRC on August 11, 2015. A SAR was submitted on December 9, 2015. Therefore, a plan
and schedule for assessment will not be submitted under separate cover within 30 days of this
Exceedance Notice.
• Field pH has been slightly outside (slightly lower than) the GWCL in the October monthly and
Q4 2015 (November) sampling events. This consecutive exceedance is addressed in the pH
Report, dated November 9, 2012 and the Plan and Time Schedule which was submitted to
DWMRC on May 19, 2015 and approved by DWMRC on August 11, 2015. A SAR was
submitted on December 9, 2015. Therefore, a plan and schedule for assessment will not be
submitted under separate cover within 30 days of this Exceedance Notice.
MW-35
Letter to Mr. Scott Anderson
February 11, 2016
Page 6
• The uranium concentration exceeded the GWCL in MW-35 in all of the Q4 2015 sampling
events. A plan and schedule to address this exceedance is not necessary and is not being
submitted because the exceedances are based on the interim GWCLs for MW-35, which have
been set at a fraction of the Groundwater Quality Standards. Background has been established
for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. Asa result of the
Background Report, the GWCLs have been calculated and accepted by DWMRC in a letter dated
July 15, 2014. The calculated GWCLs will become effective upon their publication in the next
revision of the GWDP. As a result of DWMRC’s acceptance of the calculated GWCLs, a plan
and schedule to address this consecutive exceedance is not necessary and will not be submitted.
Until such time as the new GWCLs become effective, the exceedances will continue to be noted
and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not
necessarily represent impacts to groundwater from Mill activities.
• The gross alpha minus Rn and U (“gross alpha”) concentration exceeded the GWCL in all of the
Q4 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is
not being submitted because the exceedances are based on the interim GWCLs for MW-35,
which have been set at a fraction of the Groundwater Quality Standards. Background has been
established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a
result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in
a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication
in the next revision of the GWDP. As a result of DWMRC’s acceptance of the calculated
GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not
be submitted. Until such time as the new GWCLs become effective, the exceedances will
continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs
noted herein, do not necessarily represent impacts to groundwater from Mill activities.
• Field pH has been slightly outside (slightly lower than) the GWCL in the September and October
2015 monthly sampling events. A plan and schedule to address this exceedance is not necessary
and is not being submitted because the exceedances are based on the interim GWCLs for MW-35,
which have been set at a fraction of the Groundwater Quality Standards. Background has been
established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a
result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in
a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication
in the next revision of the GWDP. As a result of DWMRC’s acceptance of the calculated
GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not
be submitted. Until such time as the new GWCLs become effective, the exceedances will
continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs
noted herein, do not necessarily represent impacts to groundwater from Mill activities.
• The selenium concentration exceeded the GWCL in MW-35 in in the September and October
2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not
being submitted because the exceedances are based on the interim GWCLs for MW-35, which
have been set at a fraction of the Groundwater Quality Standards. Background has been
established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result
of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter
dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the
next revision of the GWDP. As a result of DRC’s acceptance of the calculated GWCLs, a plan
and schedule to address this consecutive exceedance is not necessary and will not be submitted.
Until such time as the new GWCLs become effective, the exceedances will continue to be noted
and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not
necessarily represent impacts to groundwater from Mill activities.
1.2 Quarterly Wells with New Exceedances Reported in Q4
One new single exceedance for the Q4 2015 quarterly well sampling program is listed below. These
exceedances will result in an accelerated sampling frequency from quarterly to monthly. It is important to
note that the well listed below will only be sampled monthly for the constituents which exceeded their
GWCL. The well 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 well.
• Fluoride in MW-30 was above the GWCL in the Q4 sampling event.
Relative to accelerated reporting requirements, based on phone conversations with DWMRC on April 5,
2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data
package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the
month following the submission of the Exceedance Notice for a specified quarter for wells that are being
accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice
for wells that are being accelerated from semiannually to quarterly. Per teleconferences with DWMRC,
EFRI proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DWMRC
concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012
teleconference.
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 (Q3 2015 and Q4 2015).
MW-3
• Fluoride has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• Selenium has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
Letter to Mr. Scott Anderson
February 11,2016
Page 7
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2015 sampling
event and the Q4 2015 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 9, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• Cadmium has exceeded the GWCL for the Q2 2015 sampling event and the Q4 sampling event.
This consecutive exceedance is addressed in the Plan and Time Schedule which was submitted to
DWMRC on September 10, 2015 and approved by DWMRC on November 10, 2015. Therefore,
a plan and schedule for assessment will not be submitted under separate cover within 30 days of
this Exceedance Notice.
• Zinc has exceeded the GWCL for the Q2 2015 sampling event and the Q4 sampling event. This
consecutive exceedance is addressed in the Plan and Time Schedule which was submitted to
DWMRC on September 10, 2015 and approved by DWMRC on November 10, 2015. Therefore,
a plan and schedule for assessment will not be submitted under separate cover within 30 days of
this Exceedance Notice.
Letter to Mr. Scott Anderson
February 11, 2016
Page 8
MW-18
• Thallium has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells
(MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In
correspondence dated April 25, 2013, DWMRC noted “DWMRC agrees with the justification
provided by EFR, that far upgradient wells are not likely to be impacted by current Mill
activities...” and has recommended the removal of GWCLs for MW-18 from the next revision of
the GWDP. A plan and schedule is not necessary because the exceedance is not caused by Mill
activities and was previously discussed in the October 10, 2012 SAR. Until such time as the
GWCLs are removed, the exceedances will continue to be noted and reported.
• Sulfate has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015 sampling
event. This is the first consecutive exceedance for sulfate in MW-18. Therefore, a plan and
schedule for assessment will be submitted under separate cover within 30 days of this Exceedance
Notice.
MW-24
• Fluoride has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015
sampling event. This is the first consecutive exceedance for fluoride in MW-24. Therefore, a
plan and schedule for assessment will be submitted under separate cover within 30 days of this
Exceedance Notice.
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2015 sampling
event and the Q4 2015 sampling event. As mentioned above, site-wide pH issues and trends are
Letter to Mr. Scott Anderson
February 11, 2016
Page 9
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 9, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
MW-27
• The chloride concentration exceeded its GWCL for both the Q3 2015 sampling event and the Q4
2015 sampling event and during previous quarters. As mentioned above, a CAP has been
submitted and approved to address nitrate+nitrite contamination which is expected to address
chloride in groundwater. The actions specified in the CAP are currently being implemented;
therefore a plan to address this consecutive exceedance is not necessary and is not being
submitted.
MW-28
• Chloride has exceeded the GWCL for both the Q3 2015 sampling event and the Q4 2015
sampling event and during previous quarters. As mentioned above, a CAP has been submitted and
approved and the specified actions are currently being implemented; therefore a plan to address
this consecutive exceedance is not necessary and is not being submitted.
MW-29
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2015 sampling
event and the Q4 2015 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DWMRC’s acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
2.1 Semi-annual Wells with New Exceedances Reported in Q4
New single exceedances for the Q4 2015 semi-annual well sampling program are listed below. These
exceedances will result in an accelerated sampling frequency from semi-annually to quarterly. It is
important to note that the wells listed below will only be sampled during the first and third quarterly
events for the constituent which exceeded the GWCL. The wells listed below will be sampled for all
constituents listed in the GWDP during the second and fourth quarterly events as that is the regularly
scheduled sampling for the semi-annual wells.
• Thallium in MW-3 was above the GWCL in the Q4 sampling event.
• pH in MW-27 was outside (slightly below) the GWCL in the Q4 sampling event.
Relative to accelerated reporting requirements, based on phone conversations with DWMRC on April 5,
2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data
package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the
month following the submission of the Exceedance Notice for a specified quarter for wells that are being
accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice
for wells that are being accelerated from semiannually to quarterly. Per teleconferences with DWMRC,
EFRI proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DWMRC
concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012
teleconference.
Letter to Mr. Scott Anderson
February 11, 2016
Page 10
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc:David Frydenlund
Harold Roberts
David Turk
Logan Shumway
Scott Bakken
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2010 Results Q2 2010 Results Q3 2010 Results Q4 2010 Results
Monitoring Well
(Water Class)
Constituent Exceeding
GWCL
GWCL in
August 24,2012
GWDP
Q1 2010 Sample Q1 2010
Date Result
Q2 2010
Sample Date
Q2 2010
Result
May 2010
Monthly
Sample Date
May 2010
Monthly
Result
June 2010
Monthly
Sample Date
June 2010
Monthly
Result
July 2010
Monthly
Sample Date
July 2010
Monthly
Result
August 2010
Monthly
Sample Date
August 2010
Monthly Result
Q3 2010
Sample Date
Q3 2010
Result
October 2010
Monthly
Sample Date
October 2010
Monthly Q4 2010
Sample Date
Q4 2010
Result
December 2010
Monthly Sample
Date
December 2010
Monthly Result
Required Quarterly Sampling Wells
MW-11 (Class II)Manganese (ug/L)131.29 134 99 7/20/2010
MW-14 (Class III)Field pH (S.U.)
Field pH (S.U.)6.36
MW-25 (Class III)Chloride (mg/L)
Cadmium (ug/L)
Uranium (ug/L)
Nitrate + Nitrite (as N)
________(mg/L)________
Uranium (ug/L)
Chloroform (ug/L)
MW-26 (Class III)Chloride (mg/L)
Field pH (S.U.)6.45
Dichloromethane
(Methylene Chloride)
_______(ug/L)________
Nitrate + Nitrite (as N)
________(mg/L)________
Chloride (mg/L)
Uranium (ug/L)
MW-30 (Class II)Field pH (S.U.)6.55 7/21/2010
7/27/2010 6.80 (6.82)
9/14/2010
9/21/2010 6.80 (6.84)
Ammonia (mg/L)
Fluoride (mg/L)
Selenium (ug/L)35.3
Nitrate + Nitrite (as N)
________(mg/L)________22.5
TPS (mg/L)
MW-31 (Class III)Chloride (mg/L)
Selenium (ug/L)
9/13/2010
(9/21/10)
Field pH (S.U.)7.66 (7.13)
Sulfate (mg/L)
Manganese (ug/L)
Thallium (ug/1)
MW-35 (Class II)
Gross Alpha minus Rn & U
(pCi/L)
Field pH (S.U.)
Selenium (ug/L)
Uranium (ug/L)NA
Required Semi-Annual Sampling Wells
MW-01 (Class II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)
7.86 (6.87)
805
NA
Selenium (ug/L)
Field pH (S.U.)6.14 (6.25)
Beryllium (ug/L)
MW-03 (Class III)Cadmium (ug/L)
Zinc (ug/L)
Thallium (ug/1)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
(mg/L)
Fluoride (Mg/L)
Field pH (S.U.)6.5 - 8.5 6.23 (6.24)
MW-3A (Class III)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
(mg/L)
TPS (mg/L)
Selenium (ug/L)
MW-05 (Class II)Uranium (ug/L)
Selenium (ug/L)31.9
MW-12 (Class III)
Field pH (S.U.)
4/27/2010
MW-15 (Class III)Selenium (ug/L)
Field pH (S.U.)
Q12010 Results Q2 2010 Results Q3 2010 Results Q4 2010 Results
Monitoring Well
(Water Class)
Constituent Exceeding
GWCL
GWCL in
Current GWDP Q1 Sample Date Q1 Result Q2 Sample
Date Q2 Result May Monthly
Sample Date
May
Monthly
Result
June Monthly
Sample Date
June Monthly
Result
July Monthly
Sample Date
July Monthly
Result
August
Monthly
Sample Date
August Monthly
Result
Q3 Sample
Date Q3 Result
October
Monthly
Sample Date
October
Monthly
Result
Q4 Sample
Date Q4 Result
December
Monthly Sample
Date
December
Monthly Result
Required Semi-Annual Sampling Wells, continued
MW-18 (Class III)
Thallium (ug/I)
Sulfate (mg/I.)
Field pH (S.U.)
TDS (mg/L)
1.95
1938.9
6.25-8.5
3198.77
3.73
1950
NA NA
MW-19 (Class III)Field pH (S.U.) 6.78-8.5 6.61 (6.66)
Nitrate + Nitrite (as N)
________(mg/L)________
Cadmium (ug/L)
Fluoride (mg/L)
MW-24 (Class III)Sulfate (mg/L)
Thallium (ug/L)
Field pH (S.U.)5.91 (5.78)
Nitrate + Nitrite (as N)
________(mg/I.)________
Chloride (mg/L)
MW-27 (Class III)Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
Gross Alpha minus Rn & U
(pCi/L)_________
Chloride (mg/L)
Cadmium (ug/L)
MW-28 (Class III)Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)
TDS (mg/L)
MW-29 (Class III)Sulfate (mg/L)
Field pH (S.U.)
Gross Alpha minus Rn & U
(pCi/L)
MW-32 (Class III)Chloride (mg/L)
Field pH (S.U.)
GWCL values are taken from August 24. 2012 version of GWDP.
NS = Not Required and Not Sampled
i>i\. — rvcquiicu aiiu
— rsFUir*~J
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2011 Results Q2 2011 Results Q3 2011 Results Q4 2011 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in
August 24,
2012 GWDP
January 2011
Monthly
Sample Date
January 2011
Monthly Sample
Result
Q1 2011
Sample
Date
Q1 2011
Result
March 2011
Monthly
Sample Date
March
2011
Monthly
Result
Q2 2011
Sample
Date
Q2 2011
Result
May 2011
Monthly
Sample Date
May 2011
Monthly
Result
June 2011
Monthly
Sample Date
June 2011
Monthly
Result
July 2011
Monthly
Sample Date
July 2011
Monthly
Result
Q3 2011
Sample
Date
Q3 2011
Result
September
2011
Monthly
Sample Date
September
2011Monthly
Result
Q4 2011
Sample Date
Q4 2011
Result
November
2011 Monthly
Sample Date
November
2011 Monthly
Result
December
2011
Monthly
Sample Date
December
2011
Monthly
Result
Required Quarterly Sampling Wells
(Class II)Manganese (ug/L)131.29 6/15/2011 121
MW-14
(Class III)Field pH (S.U.)6.23
(6.41)6.71 (6.82)
MW-25
(Class III)
Field pH (S.U.)8/3/2011
8/30/11
6.42
(6.54)
Chloride (mg/L)
Cadmium (ug/L)
Uranium (ug/L)
MW-26
(Class III)
Nitrate + Nitrite (as N)
(mg/L)
Uranium (ug/L)
Chloroform (ug/L)
Chloride (mg/L)8/3/2011
8/30/11
Field pH (S.U.)6.52 6.07
(6.58)
Dichloromethane
(Methylene Chloride)
(ug/L)
MW-30
(Class II)
Nitrate + Nitrite (as N)
_______(mg/L)_______
Chloride (mg/L)
Uranium (ug/L)
Field pH (S.U.)
10/4/2011
11/29/2011 6.96 (6.73)
Ammonia (mg/L)
Fluoride (mg/L)
Selenium (ug/L)
MW-31
(Class III)
Nitrate + Nitrite (as N)
_______(mg/L)_______
TDS (mg/L)
Chloride (mg/L)
Selenium (ug/L)
11/8/2011(11/29/12)
Field pH (S.U.)7.01 (7.34)
Sulfate (mg/L)
MW-35
(Class II)
Manganese (ug/L)
Thallium (ug/1)
Gross Alpha minus Rn
& U (pCi/L)
Field pH (S.U.)
Selenium (ug/L)
Uranium (ug/L)
Required Semi-Annual Sampling Wells
MW-01
(Class II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)
NA
7.06
QML
NA
7.08 (7.51)
713
MW-03
(Class III)
Selenium (ug/L)
Field pH (S.U.)6.53 (6.83)
Beryllium (ug/L)
Cadmium (ug/L)
Zinc (ug/L)
Thallium (ug/1)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
(mg/L)
Fluoride (Mg/L)
MW-03 A
(Class III)
Field pH (S.U.)6.5 (6.92)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
(mg/L)
TDS (mg/L)
Selenium (ug/L)
MW-05
(Class II)Uranium (ug/L)
MW-12
(Class III)
Selenium (ug/L)35.4
Field pH (S.U.)6.7 (6.97)
MW-15
(Class III)
Selenium (ug/L)
Field pH (S.U.)
4/12/2011
112
Q1 2011 Results Q2 2011 Results Q3 2011 Results Q4 2011 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in
Current
GWDP
January 2011
Monthly
Sample Date
January 2011
Monthly Sample
Result
Q1 2011
Sample
Date
Q12011
Result
March 2011
Monthly
Sample Date
March
2011
Monthly
Result
Q2 2011
Sample
Date
Q2 2011
Result
May 2011
Monthly
Sample Date
May 2011
Monthly
Result
June 2011
Monthly
Sample Date
June 2011
Monthly
Result
July 2011
Monthly
Sample Date
July 2011
Monthly
Result
Q3 2011
Sample
Date
Q3 2011
Result
September
2011
Monthly
Sample Date
September
2011
Monthly
Result
Q4 2011
Sample Date
Q4 2011
Result
November
2011 Monthly
Sample Date
November
2011 Monthly
Result
December
2011
Monthly
Sample Date
December
2011
Monthly
Result
Required Semi-Annual Sampling Wells, continued
MW-18
(Class III)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
6.25-8.5
3198.77
3.49
8/10/20119/21/11 5.95
(6.30)6.55 (6.63)
MW-19
(Class III)
Field pH (S.U.)6.88 (7.02)
Nitrate + Nitrite (as N)
_______(mg/D_______
Cadmium (ug/L)
NS
2.78
2.6
2.61
MW-24
(Class III)
Fluoride (mg/L)
Sulfate (mg/L)
Thallium (ug/L)
Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/L)_______
MW-27
(Class III)
Chloride (mg/L)
Sulfate (mg/L)
Field pH (S.U.) 6.5 - 8.5
TDS (mg/L)
Gross Alpha minus Rn
& U (pCi/L)
Chloride (mg/L)
MW-28
(Class III)
Cadmium (ug/L)
Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)6.07 (6.11)
TDS (mg/L)
MW-29
(Class III)
Sulfate (mg/L)
Field pH (S.U.)
MW-32
(Class III)
Gross Alpha minus Rn
& U (pCi/L)
Chloride (mg/L) 35.39 8/2/20118/30/11
Field pH (S.U.)6.4 - 8.5 6.10
(6.20)
GWCL values are taken from August 24.:
of GWDP.
NS = Not Required and Not Sampled
n H"—“i> u i
Exceedances are shown in yellow
Values in () parentheses arc the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results
Monitoring Well
(Water Class)
Constituent
Exceeding GWCL
GWCL in
August 24,
2012 GWDP
January 2012
Monthly
Sample Date
January 2012
Monthly
Result
Q1 2012
Sample Date
Q1 2012
Result
March 2012
Monthly
Sample Date
March
2012
Monthly
Result
April 2012
Monthly
Sample Date
April 2012
Monthly
Result
Q2 2012
Sample
Date
Q2 2012
Result
June 2012
Monthly
Sample
Date
June 2012
Monthly
Result
Q3 2012
Sample
Date
Q3 2012
Result
August
2012
Monthly
Sample
Date
August
2012
Monthly
Result
September
2012
Monthly
Sample
Date
September
2012
Monthly
Result
October
2012
Monthly
Sample Date
October
2012
Monthly
Result
Q4 2012
Sample Date
Q4 2012
Result
December
2012
Monthly
Sample Date
December
2012
Monthly
Result
Required Quarterly Sampling Wells
MW-11 (Class II)Manganese (ug/L)131.29 1/26/2012 5/8/2012 127 9/19/2012
MW-14 (Class III)Field pH (S.U.) 3/14/2012 9/18/2012 10/23/2012 6.83
Field pH (S.U.)
MW-25 (Class III)Chloride (mg/L)
Cadmium (ug/L)
Uranium (ug/L)
Nitrate + Nitrite (as
N) (mg/L)
Uranium (ug/L)
Chloroform (ug/L)
MW-26 (Class III)Chloride (mg/L)2/15/2012
Field pH (S.U.)
2/15/2012
2/21/2012
3/8/201 ?.
6.72 (6.91)
(6.71)
5/7/2012
6/26/2012
7.00(7.01)7/11/2012
8/16/2012
7.10
(6.80)
Dichloromethane
(Methylene Chloride)
(ug/L)
2/15/2012
Nitrate + Nitrite (as
N) (mg/L)
Chloride (mg/L)
Uranium (ug/L)
MW-30 (Class II)Field pH (S.U.)
Ammonia (mg/L)
Fluoride (mg/L)
Selenium (ug/L)
Nitrate + Nitrite (as
N) (mg/L)
TPS (mg/L)
MW-31 (Class III)Chloride (mg/L)
Selenium (ug/L)1/24/2012 6/18/2012
6/29/2012
Field pH (S.U.)7.28 (7.63)
Sulfate (mg/L)
Manganese (ug/L)
Thallium (ug/1)0.5
MW-35 (Class II)
Gross Alpha minus
Rn & U (pCi/L)
Field pH (S.U.)
Selenium (ug/L)
Uranium (ug/L)22.4 22.2
Required Semi-Annual Sampling Wells
MW-01 (CLASS
II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)
Selenium (ug/L)
Field pH (S.U.)
Beryllium (ug/L)
MW-03 (Class III)Cadmium (ug/L)
Zinc (ug/L)
Thallium (ug/1)
Sulfate (mg/L)
Nitrate + Nitrite (as
N) (mg/L)
Fluoride (Mg/L)
Field pH (S.U.)
MW-03A (Class
HI)
Sulfate (mg/L)
Nitrate + Nitrite (as
N) (mg/L)
TPS (mg/L)5805
Selenium (ug/L)
MW-05 (Class II)Uranium (ug/L)7.5
Selenium (ug/L)
MW-12 (Class III)Field pH (S.U.)6.5 - 8.5
MW-15 (Class III)Selenium (ug/L)
Field pH (S.U.)6.62 - 8.5 5/9/2012
Q1 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results
Monitoring Well
(Water Class)
Constituent
Exceeding GWCL
GWCL in
Current
GWDP
January 2012
Monthly
Sample Date
January 2012
Monthly
Result
Q1 2012
Sample Date
Q1 2012
Result
March 2012
Monthly
Sample Date
March
2012
Monthly
Result
April 2012
Monthly
Sample Date
April 2012
Monthly
Result
Q2 2012
Sample
Date
Q2 2012
Result
June 2012
Monthly
Sample
June 2012
Monthly
Result
Q3 2012
Sample
Date
Q3 2012
Result
August
2012
Monthly
Sample
Date
August
2012
Monthly
Result
September
2012
Monthly
Sample
Date
September
2012
Monthly
Result
October
2012
Monthly
Sample Date
October
2012
Monthly
Result
Q4 2012
Sample Date
Q4 2012
Result
December
2012
Monthly
Sample Date
December
2012
Monthly
Result
Required Semi-Annual Sampling Wells, continued
MW-18 (Class III)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
3.63 3.51 3.2
MW-19 (Class III)Field pH (S.U.)
Nitrate + Nitrite (as
N) (mg/L)
Cadmium (ug/L)
Fluoride (mg/L)
MW-24 (Class III)Sulfate (mg/L)
Thallium (ug/L)
Field pH (S.U.)
Nitrate + Nitrite (as
N) (mg/L)
Chloride (mg/L)
MW-27 (Class III)Sulfate (mg/L)
Field pH (S.U.)6.5 - 8.5
TDS (mg/L)
Gross Alpha minus
Rn & U (pCi/L)
Chloride (mg/L)7/16/2012
8/1/2012
Cadmium (ug/L)
MW-28 (Class III)Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)7/16/2012
8/1/2012
6.38
<5.81)
TDS (mg/L)
MW-29 (Class III)Sulfate (mg/L)
Field pH (S.U.)7/16/2012
8/1/2012
6.68
(6.45)
NA
NA
Gross Alpha minus
Rn & U (pCi/L)
MW-32 (Class III)Chloride (mg/L)35.39
Field pH (S.U.) 6.57
GWCL values are taken from August 24, 2012 version of
GWDP.
NS = Not Required and Not Sampled
i>i\ — ivequiieu aiiu
NA = NuiT*" '
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2013 Results Q2 2013 Results Q32013 Results Q4 2013 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in August
24, 2012 GWDP
January 2013
Monthly
Sample Date
January
2013
Monthly
Result
Q1 2013
Sample
Date
Q1 2013
Result
March
2013
Monthly
Sample
Date
March 2013
Monthly
Result
April 2013
Monthly
Sample Date
April 2013
Monthly
Result
Q2 2013
Sample
Date
Q2 2013
Result
June 2013
Monthly
Sample
Date
June 2013
Monthly
Result
Q3 2013
Sample
Date
Q3 2013
Result
August
2013
Monthly
Sample
Date
August
2013
Monthly
Result
September
2013
Monthly
Sample
September
2013
Monthly
Result
October
2013
Monthly
Sample Date
October
2013
Monthly
Result
Q4 2013
Sample Date
Q4 2013
Result
December
2013 Monthly
Sample Date
December
2013 Monthly
Result
Required Quarterly Sampling Wells
MW-11 (Class
ID Manganese (ug/L)4/16/2013 5/14/2013 6/25/2013 135
MW-14 (Class
111)
Field pH (S.U.)8/20/2013
Field pH (S.U.)6.5 - 8.5
MW-25 (Class
HI)Chloride (mg/L)
Cadmium (ug/L)
Uranium (ug/L)
Nitrate + Nitrite (as N)
_______(mg/L)
Uranium (ug/L)
Chloroform (ug/L)
MW-26 (Class
III)
Chloride (mg/L)6/5/2013
6/25/2013 8/20/2013
Field pH (S.U.)
Dichloromethane
(Methylene Chloride)
(ug/L)
52.4*
[12.1]
Nitrate + Nitrite (as N)
_______(mg/L)_______
Chloride (mg/L)
Uranium (ug/L)
MW-30 (Class
II)Field pH (S.U.)8/20/2013
Ammonia (mg/L)
Fluoride (mg/L)
Selenium (ug/L)
Nitrate + Nitrite (as N)
_______(mg/L)_______
TDS (mg/L)
MW-31 (Class
III)
Chloride (mg/L)
Selenium (ug/L)12/17/2013
Field pH (S.U.) 7.28
Sulfate (mg/L)
Manganese (ug/L)
Thallium (ug/1)0.505
MW-35 (Class
II)
Gross Alpha minus Rn &
_______U (pCi/L)_______
Field pH (S.U.)
Selenium (ug/L)22.6
Uranium (ug/L)22.0
Required Semi-Annual Sampling Wells
MW-01 (Class
II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)
17.8
Selenium (ug/L)
Field pH (S.U.)
MW-03 (Class
HI)
Beryllium (ug/L)
Cadmium (ug/L)
Zinc (ug/L)7/18/2013
Thallium (ug/1)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
_______(mg/L)_______
Fluoride (Mg/L)
Field pH (S.U.)
MW-03A (Class
HI)
Sulfate (mg/L)3120 3670
Nitrate + Nitrite (as N)
(mg/L)
TDS (mg/L)
Selenium (ug/L)
MW-05 (Class
ID Uranium (ug/L)0.574
MW-12 (Class
III)
Selenium (ug/L)
Field pH (S.U.)
MW-15 (Class
III)
Selenium (ug/L)
Field pH (S.U.)
Q1 2013 Results Q2 2013 Results Q3 2013 Results Q4 2013 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in Current
GWDP
January 2013
Monthly
Sample Date
January
2013
Monthly
Result
Q1 2013
Sample
Date
Q1 2013
Result
March
2013
Monthly
Sample
Date
March 2013
Monthly
Result
April 2013
Monthly
Sample Date
April 2013
Monthly
Result
Q2 2013
Sample
Date
Q2 2013
Result
June 2013
Monthly
Sample
Date
June 2013
Monthly
Result
Q3 2013
Sample
Date
Q3 2013
Result
August
2013
Monthly
Sample
Date
August
2013
Monthly
Result
September
2013
Monthly
Sample
Date
September
2013
Monthly
Result
October
2013
Monthly
Sample Date
October
2013
Monthly
Result
Q4 2013
Sample Date
Q4 2013
Result
December
2013 Monthly
Sample Date
December
2013 Monthly
Result
Required Semi-Annual Sampling Wells, continued
MW-18 (Class
HI)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
3.26 NA 2.81 3.06
MW-19 (Class
III)
Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/L)_______
Cadmium (ug/L)
MW-24 (Class
III)
Fluoride (mg/L)
Sulfate (mg/L)2903
Thallium (ug/L)
Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/L)_______
MW-27 (Class
III)
Chloride (mg/L)
Sulfate (mg/L)
Field pH (S.U.)2/25/2013
TDS (mg/L)
Gross Alpha minus Rn &
U (pCi/L)
Chloride (mg/L)
MW-28 (Class
HI)
Cadmium (ug/L)
Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)
TDS (mg/L)
MW-29 (Class
HI)
Sulfate (mg/L)
Field pH (S.U.)
MW-32 (Class
III)
Gross Alpha minus Rn &
U (pCi/L)3.33
Chloride (mg/L)
Field pH (S.U.)
GWCL values are taken from August 24, 2012 version of GWDF.
NS = Not Required and Not Sampled
i>i\ — rvcquucu
I'nVa = T> u i
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2014 Results Q2 2014 Results Q3 2014 Results Q4 2014 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in August
24, 2012 GWDP
January 2014
Monthly
Sample Date
January
2014
Monthly
Result
February
2014
Monthly
Sample Date
February
2014
Monthly
Result
Q1 2014
Sample
Date
Q1 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q2 2014
Sample
Date
Q2 2014
Result
July 2014
Monthly
Sample
Date
July 2014
Monthly
Result
August
2014
Monthly
Sample
Date
August
2014
Monthly
Result
Q3 2014
Sample
Date
Q3 2014
Result
October
2014
Monthly
Sample
Date
October
2014
Monthly
Result
Q4 2014
Sample Date
Q4 2014
Result
December
2014 Monthly
Sample Date
December
2014 Monthly
Result
Required Quarterly Sampling Wells
ju,
MW-11 (Class Manganese (ug/L)3/11/2014 5/14/2014 128 6/3/2014 7/29/2014
MW-14 (Class
___HU___Field pH (S.U.) 4/23/2014
Field pH (S.U.)
MW-25 (Class
HI)Chloride (mg/L)7/28/2014
Cadmium (ug/L)
Uranium (ug/L)
Nitrate + Nitrite (as N)
(mg/L)
Uranium (ug/L)
Chloroform (ug/L)
MW-26 (Class
III)
Chloride (mg/L)58.31 12/10/14
12/15/14
Field pH (S.U.)
Dichloromethane
(Methylene Chloride)
(ug/L)
43.3 7.34
6.25 (6.44)
Nitrate + Nitrite (as N)
_______(nlg/I.)_______
Chloride (mg/L)
Uranium (ug/L)
MW-30 (Class
II)Field pH (S.U.)
Ammonia (mg/L)
Fluoride (mg/L)0.332
Selenium (ug/L)35.8
138
Nitrate + Nitrite (as N)
_______(mg/L)_______
TDS (mg/L)
MW-31 (Class
III)
Chloride (mg/L)
Selenium (ug/L)
Field pH (S.U.)
Sulfate (mg/L)
6.73
Manganese (ug/L)
Thallium (ug/1)
MW-35 (Class
II)
Gross Alpha minus Rn &
U (pCi/L)3.93
Field pH (S.U.)
Selenium (ug/L)
Uranium (ug/L)26.9
Required Semi-Annual Sampling Wells
MW-01 (Class
II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)
Selenium (ug/L)
Field pH (S.U.)
MW-03 (Class
HI)
Beryllium (ug/L)
Cadmium (ug/L)
Zinc (ug/L)
Thallium (ug/1)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
_______(mg/1,)_______
Fluoride (Mg/L)
Field pH (S.U.)
MW-03A (Class
III)
Sulfate (mg/L)
Nitrate + Nitrite (as N)
(mg/L)
TDS (mg/L)
Selenium (ug/L)
___a___
MW-05 (Class Uranium (ug/L)
MW-12 (Class
HI)
Selenium (ug/L)
Field pH (S.U.)6.5 - 8.5
MW-15 (Class
III)
Selenium (ug/L)
Field pH (S.U.)6.62 - 8.5
Q1 2014 Results 02 2014 Results Q3 2014 Results Q4 2014 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in Current
GWDP
January 2014
Monthly
Sample Date
January
2014
Monthly
Result
February
2014
Monthly
Sample Date
February
2014
Monthly
Result
Q1 2014
Sample
Date
Q1 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q2 2014
Sample
Date
Q2 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q3 2014
Sample
Date
Q3 2014
Result
October
2014
Monthly
Sample
Date
October
2014
Monthly
Result
Q4 2014
Sample Date
Q4 2014
Result
December
2014 Monthly
Sample Date
December
2014 Monthly
Result
Required Semi-Annual Sampling Wells, continued
MW-18 (Class
III)
Thallium (ug/1)
Sulfate (mg/I.)
Field pH (S.U.)
TDS (mg/L)
NA
MW-19 (Class
III)
Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/I-)_______
Cadmium (ug/L)
MW-24 (Class
III)
Fluoride (mg/L)0.36
Sulfate (mg/L)
Thallium (ug/L)
Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/L)_______
MW-27 (Class
HI)
Chloride (mg/L)45.9
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
Gross Alpha minus Rn &
U (pCi/I.)
Chloride (mg/L)
MW-28 (Class
HD
Cadmium (ug/L)
Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)
TDS (mg/L)
MW-29 (Class
III)
Sulfate (mg/L)
Field pH (S.U.)6.46 - 8.5
MW-32 (Class
HI)
Gross Alpha minus Rn &
U (pCi/L)
Chloride (mg/L)
Field pH (S.U.)
GWCL values are taken from August 24. 2012 \
GWDP.
NS = Not Required and Not Sampled
NR = Required and Not Reported
NA = Not Applicable
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2015 under the August 24, 2012 GWDP
Q1 2015 Results Q2 2015 Results Q32015 Results Q4 2015 Results
Monitoring Well
(Water Class)
Constituent Exceeding
GWCL
GWCL in
August 24,
2012 GWDP
January 2015
Monthly
Sample Date
January 2015
Monthly
Result
Q1 2015
Sample Date
Q1 2015
Result
March 2015
Monthly
Sample Date
March 2015
Monthly
Result
Q2 2015
Sample Date
Q2 2015
Result
May 2015
Monthly
Sample Date
May 2015
Monthly
Result
June 2015
Monthly
Sample
Date
June 2015
Monthly
Result
July 2015
Monthly
Sample
Date
July 2015
Monthly
Result
Q3 2015
Sample
Date
Q3 2015
Result
September
2015
Monthly
Sample
Date
September
2015
Monthly
Result
October
2015
Monthly
Sample
Date
October
2015
Monthly
Result
Q4 2015
Sample
Date
Q4 2015
Result
December
2015
Monthly
Sample
Date
December
2015
Monthly
Result
Sample
Frequency
Required Quarterly Sampling Wells
MW-11 (Class II)Manganese (ug/L)2/3/2015 8/10/2015 Quarterly
MW-14 (Class III)Field pH (S.U.)8/11/2015 Quarterly
Field pH (S.U.)6/1/2015
6/23/2015 6.59, 6.53
MW-25 (Class III)Chloride (mg/L)8/10/2015
Cadmium (ug/L)
Uranium (ug/L)
Quarterly
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
_______(mg/L)_______
Uranium (ug/L)
Chloroform (ug/L)
MW-26 (Class III)Chloride (mg/L)
Field pH (S.U.)6/3/2015
6/24/2015
8/10/2015
8/17/2015
6.58, 6.20
Dichloromethane
(Methylene Chloride)
(ug/L)
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
_______(mg/L)_______
Chloride (mg/L)128
Uranium (ug/L)
MW-30 (Class II)Field pH (S.U.)6/2/2015
6/24/2015 6.94, 6.32
Ammonia (mg/L)
Fluoride (mg/L)
Selenium (ug/L)38.0 37.2 39.2
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
_______(mg/L)_______18.8
TPS (mg/L)
MW-31 (Class III)Chloride (mg/L)
Selenium (ug/L)1/20/2015
Field pH (S.U.)6/1/2015
6/23/2015 7.14, 7.08 7.22
Sulfate (mg/L)638
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Manganese (ug/L)201, 176
Thallium (ug/1)<0.5, <0.5
MW-35 (Class II)
Gross Alpha minus Rn &
U (pCi/L)3.75
Field pH (S.U.)6/2/2015
6/23/2015 6.50, 6.41
9/15/15
9/22/15
9/28/15 6.52, 6.41,
6.49
Selenium (ug/L)16.7, 28.5
Uranium (ug/L)22.5 21.3, 22.3
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Required Semi-Annual Sampling Wells
MW-01 (Class II)
Chloride (mg/L)
Field pH (S.U.)
Sulfate (mg/L)838
NA Semi-Annually
Semi-Annually
Semi-Annually
Selenium (ug/L)4/23/2015
5/20/2015 81, 61.7
Field pH (S.U.)
4/23/2015
4/29/2015
5/20/2015
6.18, 6.51,
6.23
Beryllium (ug/L)
MW-03 (Class III)Cadmium (ug/L)
Zinc (ug/L)173.19
4/23/2015
5/20/2015
1.44, 2.08
5.03,14.2
238, 373
Thallium (ug/1)4/23/2015
5/20/2015
Sulfate (mg/L)3663
Nitrate + Nitrite (as N)
_______(mg/L)_______0.73
Fluoride (mg/L)0.68
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Field pH (S.U.)6.5 - 8.5 4/23/2015
4/29/2015
MW-03A (Class
III)
Sulfate (mg/L)3640
Nitrate + Nitrite (as N)
(mg/L)
TPS (mg/L)
Selenium (ug/L)
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
MW-05 (Class II)Uranium (ug/L)Semi-Annually
Selenium (ug/L)24.6
MW-12 (Class III)
Field pH (S.U.)6.5 - 8.5 4/21/2015
4/28/2015
Semi-Annually
Semi-Annually
MW-15 (Class III)Selenium (ug/L)
Field pH (S.U.)6.62 - 8.5
Semi-Annually
Semi-Annually
Q1 2015 Results Q2 2015 Results Q3 2015 Results Q4 2015 Results
Monitoring Well
(Water Class)
Constituent Exceeding
GWCL
GWCL in
August 24,
2012 GWDP
January 2015
Monthly
Sample Date
January 2015
Monthly
Result
Q1 2015
Sample Date
Q1 2015
Result
March 2015
Monthly
Sample Date
March 2015
Monthly
Result
Q2 2015
Sample Date
Q2 2015
Result
May 2015
Monthly
Sample Date
May 2015
Monthly
Result
June 2015
Monthly
Sample
Date
June 2015
Monthly
Result
July 2015
Monthly
Sample
Date
July 2015
Monthly
Result
Q3 2015
Sample
Date
Q3 2015
Result
September
2015
Monthly
Sample
Date
September
2015
Monthly
Result
October
2015
Monthly
Sample
Date
October
2015
Monthly
Result
Q4 2015
Sample
Date
Q4 2015
Result
December
2015
Monthly
Sample
Date
December
2015
Monthly
Result
Sample
Frequency
Required Semi-Annual Sampling Wells, continued
MW-18 (Class III)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
1938.9
NA Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
MW-19 (Class III)Field pH (S.U.)
Nitrate + Nitrite (as N)
_______(mg/L)_______
Semi-Annually
Semi-Annually
Cadmium (ug/L)3.75
Fluoride (mg/L)0.36
MW-24 (Class III)Sulfate (mg/L)
Thallium (ug/L)
Field pH (S.U.)5/28/2015
6/24/2015 5.39, 5.98
Semi-Annually
Semi- Annually
Semi-Annually
Semi-Annually
Semi-Annually
Nitrate + Nitrite (as N)
_______(mg/L)________
Chloride (mg/L)
MW-27 (Class III)Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
Gross Alpha minus Rn &
U (pCi/L)
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Chloride (mg/L)130
Cadmium (ug/L)5.2
MW-28 (Class III)Uranium (ug/L)
Vanadium (ug/L)
Field pH (S.U.)6.1 -8.5 4/21/2015
4/27/2015 6.08, 6.17
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
TDS (mg/L)
MW-29 (Class III)Sulfate (mg/L)
Field pH (S.U.)
Semi-Annually
Semi-Annually
Semi-Annually
Gross Alpha minus Rn &
U (pCi/L)
MW-32 (Class III)Chloride (mg/L)36.3 37.3
Field pH (S.U.)
Semi-Annually
Semi-Annually
Semi-Annually
GWCL values are taken from August 24. 2012 \
GWDP.
NS = Not Required and Not Sampled
NR = Required and Not Reported
NA = Not Applicable
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Reported from the quarterly chloroform sample