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HomeMy WebLinkAboutDRC-2023-003902 - 0901a068811e6a1fApril 25 , 2023 VIA PDF AND OVERNIGHT DELIVERY Doug Hansen Director Division of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West Salt Lake City, UT 84116 Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www .energyfuels.com :Jiv f W ~ . d ~ I ' . ' "'~ lt ..., t ol APR 2 8 20?3 Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill -Notice Pursuant to Part I.G.1 (a) Dear Mr. Hansen: The White Mesa Mill (the "Mill") performed first quarter ("QI ") groundwater monitoring during the period from January 1, to March 31 , 2023 under the March 8, 2021 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 March 27, 2023 . Pursuant to Part LG. I .a) of the GWDP, 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). As a result of the issuance of a revised GWDP on March 8, 2021 , which sets revised GWCLs, requirements to perform accelerated monitoring for certain constituents under Part I.G.1 of the previous GWDP ceased effective on March 8, 2021, and the effect of the issuance of the revised GWDP was to create a "clean slate" for certain constituents going forward. Part I.G.1 c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to the Director 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 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 : DRC-2023-003902 Letter to Mr. Doug Hansen April 25, 2023 Page2 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, EFRJ 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. EFRJ 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 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. A Plan and Time Schedule will not be prepared for monitoring wells with two successive exceedances if those successive exceedances were reported in a previous quarter and/or were included in a previous Source Assessment Report ("SAR") during the current permit period beginning March 8, 2021. Inclusion in a previous SAR means that the GWCLs were modified based on conclusions and actions delineated in the previous SAR which were accepted by DWMRC. 3. 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 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 Ql 2023. A 30-day plan and schedule contemplated in Part I.G.1 c) of the GWDP will be required as noted 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 previously submitted SARs. Letter to Mr. Doug Hansen April 25, 2023 Page 3 MW-11 • The chloride concentration exceeded its GWCL in all of the QI 2023 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. • The nitrate concentration exceeded its GWCL in in all of the QI 2023 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. • The selenium concentration exceeded its GWCL in all of the QI 2023 sampling events. This is the first consecutive exceedance for selenium in MW-11. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. MW-26 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. • Chloroform has exceeded its GWCL in all of the QI 2023 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. • The nitrate concentration exceeded its GWCL in all of the QI 2023 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. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the QI 2023 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 QI 2023 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination Letter to Mr. Doug Hansen April 25, 2023 Page4 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. • Selenium has exceeded the GWCL for all of the Ql 2023 sampling events. A SAR was submitted on January 28, 2022. 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. • Uranium has exceeded the GWCL in the December 2022 and Ql 2023 sampling events. A SAR was submitted on January 28, 2022. 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 Ql 2023 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 sulfate concentration exceeded its GWCL in the Ql and February 2023 sampling events. A SAR was submitted to DWMRC on June 24, 2020. 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. • The TDS concentration exceeded its GWCL in all of the Ql 2023 sampling events. A SAR was submitted to DWMRC on June 24, 2020. 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. • The chloride concentration exceeded its GWCL in all of the Ql 2023 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. Doug Hansen April 25, 2023 Page 5 • Uranium concentrations exceeded the GWCL in all of the Ql 2023 sampling events. A SAR was submitted to DWMRC on April 29, 2021. 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. 1.2 Quarterly Wells with New Exceedances Reported in Ql There are no new exceedances for the Q 1 2023 quarterly well sampling program. 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 (Q4 2022 and Ql 2023). MW-24 Beryllium, cadmium, fluoride, nickel, thallium, and field pH exceeded their GWCLs in MW-24 in the Q4 2022 and Ql 2023 sampling events. The exceedances noted above are addressed in the SAR dated June 27, 2019. As a result of the SAR, EFRI installed a collocated well to study potential installation issues associated with MW-24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. In response to the previously identified exceedances and increasing trends, in 2020 EFRI voluntarily completed a study of MW-24A ( collocated with MW-24) to determine what geochemical and hydrogeological influences are present which may be impacting monitoring data collected at these two wells and potentially other wells across the Mill site. The MW-24A study and report included several additional field data collection and analytical activities based on the conclusions of other Mill reports. The results of the analytical and test data collected during the MW-24A study demonstrated that natural processes unrelated to disposal of materials in the Tailings Management System can account for the behavior of all trace metals of concern, as well as fluoride, in groundwater at MW-24 and MW-24A. Bottle- roll test results indicated that naturally-occurring trace metals can be mobilized at concentrations similar to or greater than in groundwater even without a large pH decrease, suggesting that agitation alone, such as would occur during routine purging and sampling oflow permeability wells such as MW-24A, could result in metals mobilization. Based on the results of the MW-24A study EFRI has voluntarily agreed to implement a MW-24A Phase 2 study to determine what geochemical and hydrogeological influences are present that may be affecting monitoring data collected at other wells across the Mill site. EFRl coordinated the Phase 2 study efforts with DWMRC. DWMRC approved the Phase 2 study plan by letter dated June 16, 2022. The Phase 2 study will build on the results of the previous study and will supplement the data using eight other Mill site locations. As a result ofDWMRC's acceptance of the study strategy, a plan and schedule to address these consecutive exceedances is not necessary and will not be submitted. Until such time as the study is complete, the exceedances will continue to be noted and reported. Letter to Mr. Doug Hansen April 25, 2023 Page 6 MW-28 • Chloride has exceeded the GWCL for both the Q4 2022 and Ql 2023 sampling events 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. • Uranium has exceeded the GWCL for both the Q4 2022 and Ql 2023 sampling events. A SAR was submitted to DWMRC on October 19, 2020. 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-37 • The field pH measurement was slightly below its GWCL for both the Q4 2022 and Ql 2023 sampling events. This is the first consecutive exceedance for field pH in MW-37. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. 2.2 Semi-annual Wells with New Exceedances Reported in Ql There are no new exceedances for the Ql 2023 semi-annual well sampling program. Yours truly, i( a1-t/jf µ,,,..J ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Director, Regulatory Compliance cc: Scott Bakken, David Frydenlund, Logan Shumway, Garrin Palmer, Jordan App Monitoring Well (Water Constituent Exceeding GWCL Class) Nitrate + Nitrite (as N) (mg/L) Chloride (mg/L) MW-11 Manganese ( ug/L) (Class II) Sulfate (mg/L) TDS (mg/L) Selenium (ug/L) MW-25 (Class TDS (mg/L) III ) Chloride (mg/L) MW-26 Nitrate + Nitrite (as N) (mg/L) Chloroform ( ug/L) (Class III) Chloride (mg/L) Nitrate + Nitrite (as N) (mg/L) MW-30 Chloride (mg/L) Selenium (ug/L) (Class II) Field pH (S U ) Uranium (ug/L) Nitrate + Nitrite (as N) (mg/L) MW-31 Sulfate (mg/L) (Class Ill) TDS (mg/L) Uranium (ug/L) Chloride (mg/L) MW-12 Uranium (ug/L) (Class III) Selenium (ug/L) MW-17 Chloride (mg/L) /Class Ill) Beryllium (ug/L) Cadmium (ug/L) Fluoride (mg/L) Nickel (mg/L) MW-24 Manganese (ug/L) (Class III) Thallium (ug/L) Gross Aloha /oCi/L) Sulfate (mg/L) TDS (mg/L) Field pH (S U.) MW-27 Nitrate + Nitrite (as N) (mg/L) (Class Ill) Fluoride (mg/L) Chloride (mg/L) MW-28 Selenium (ug/L) (Class 111) Nitrate + Nitrite (as N) (mg/L) Uranium (ug/L) MW-29 Uranium (ug/L) /Class III) MW-32 Chloride (mg/L) /Class Ill) MW-37 Field pH (S.U.) (Class III) Notes: NS= Not Required and Not Sampled NA= Not Applicable Exceedances are shown in yellow GWCLin QI 2021 March 8, Sample 2021 GWDP Date 2.5 39. 16 237 1/12/21 1309 2528 12.5 2976 1/11 /21 35 0.62 70 1/14/21 58.31 2.5 128 53.6 1/11 /21 6.47 -8.5 9.82 5 993 2132 1/12/21 15 143 23.5 39 1/14/21 46.8 NS 2 6.43 0.47 50 7507 2 01 1/14/21 7.5 2903 4450 5.03 -8.5 5.6 1/14/21 0.85 105 II I 1/15/21 5 4.9 15 1/15/21 35.39 1/14/21 6.6 1 -8.5 NS Ql 2021 Results February February March March 2021 2021 QI 2021 Monthly 2021 Monthly 2021 Result Monthly Monthly Sample Result Sample Result Date Date Required Quarterly Sampling Wells 1.21 NA NA 46.4 46.4 46.9 185 2/9/21 254 3/8/21 221 1140 1260 1270 2010 2160 1950 <5 NA NA 2660 NS NA NS NA 34 NA NA 0.6 19 0.764 0.617 2200 2/10/21 1930 3/9/21 2190 57.4 71.3 63.9 17.7 /4.3 17.0 184 /89 /92 55.6 2/10/21 55.3 3/9/21 56.3 7.49 7.25 7.14 9.86 11.6 /0.2 17. I 14.3 17.4 1070 1130 1210 2460 2/9/21 2960 3/8/21 2400 19. 7 22.2 20.2 354 380 388 Required Semiannual Sampling Wells 25.0 35.1 NS NA NS NA NA NS NA NS NA 2.75 NA NA 8.79 NA NA 0.916 NA NA 70.4 NA NA 7460 NA NA 2.74 NS NA NS NA 2.94 NA NA 2980 NA NA 4260 NA NA 5.08 NA NA 5.16 NS NA NS NA NA /28 NA NA 14.0 NS NA NS NA 3.44 NA NA 10.3 NA NA /6.9 NS NA NS NA 36.9 NS NA NS NA NA NS NA NS NA These GWCLs were reset with the issuance of the March 8, 2021 GWDP. The new GWCLs became effective on March 8, 2021 and the first exceedance under the revised GWDP was noted in the March monthly data. Q2 2021 Sample Date 04/20/21 04/14/21 04/21/21 04/14/21 04/13/21 4/20/21 4/26/21 4/29/21 4/15/21 4/15/21 4/14/21 4/13/21 5/12/21 Table 1 -GWCL Exceedances under the March 8, 2021 GWDP Q2 2021 Results QJ 202.l Results Q4 2021 Results May 2021 June 2021 August August September September November November December December May 2021 June 2021 QJ 2021 2021 Q4 2021 Q2 2021 Monthly Monthly Monthly Monthly Sample QJ 2021 Monthly 2021 2021 2021 Sample Q4 2021 2021 2021 2021 2021 Result Sample Sample Result Monthly Monthly Monthly Result Monthly Monthly Monthly Monthly Date Result Date Result Date Sample Result Sample Date Result Date Sample Date Result Sample Date Result Date Required Quarterly Sampling Wells Required Quarterly Sampling Wells Required Quarterly Sampling Wells 0.948 NA NA 0.924 NA NA 1.5 NA NA 47. 7 46.4 52.1 48.3 57.0 49.6 52.8 53.6 53.9 237 5/10/21 NA 6/8/21 NA 7/27/21 376 8/10/21 NA 9/7/21 NA 10/20/21 286 11/16/21 261 12/13/21 300 1290 1280 1270 1470 1370 1240 1360 1300 1350 2110 2190 1960 2680 NA NA 2200 2230 2140 <5 NA NA <5 NA NA 6.75 NA NA 2720 NS NA NS NA 7/28/2 I 3100 NS NA NS NA I 0/20/21 2680 11/16/2 I 2920 12/14/2 1 2590 34.8 NA NA 34.2 NA NA 33.1 NA NA 1.42 1.06 0.368 0.352 1.42 0.710 0.928 1.18 1.76 777 5/11 /21 733 6/8/21 1590 7/28/2 1 723 8/10/21 996 9/9/21 516 10/21 /21 540 11/16/21 568 12/15/21 1160 57.5 69.6 54.9 54.0 61.4 59.3 55.2 56.9 75.9 17. 7 18.6 17.0 20.6 /6.5 15.4 /4.3 /8.0 /8.6 /62 188 170 /88 /6/ /83 /82 /82 /84 55.7 5/1 1/21 58.3 6/8/21 54./ 7/29/21 56.3 8/9/21 56./ 9/8/21 60.4 I 0/19/21 54.6 11/17/21 53.6 12/14/2 1 58.8 720 720 7.36 6.98 6.84 6.70 6.77 7.18 7 04 /0.3 JO. 7 9.84 9.60 9.38 9.74 9.76 9.67 JO. I 18.6 18.9 20.6 18.7 /5. 7 16.0 18./ /9.3 17.9 1170 1200 1170 1210 1130 1130 1220 1180 1220 2300 5/10/21 2610 6/7/21 2400 7/27/21 3100 8/9/21 2600 9/7/21 2870 I 0/19/21 2600 11/15/21 26/0 12/13/2 1 2420 20./ 2/. 7 20.8 20.0 /9.3 20.2 20.9 21.5 21.8 377 384 374 39/ 365 356 371 366 376 Required Semiannual Sampling Wells Required Semiannual Sampling Wells Required Semiannual Sampling Wells 22.9 28.8 NS NA NS NA 7/21/21 22.2 32.4 NS NA NS NA 11/9/21 23.1 26.4 NS NA NS NA 32.6 NS NA NS NA NS NA NS NA NS NA 11/8/21 33.4 NS NA NS NA 2.78 NA NA 2. 71 NA NA 2.66 NA NA 8.08 NA NA 9.26 NA NA 9.30 NA NA 0.925 NA NA 1.4 NA NA 0.988 NA NA 72.4 NA NA 76. 7 NA NA 76. 7 NA NA 7540 NA NA 7890 NA NA 7430 NA NA 3.02 NS NA NS NA 7/29/21 2.91 NS NA NS NA 11/10/21 3.14 NS NA NS NA 3.18 NA NA 1.92 NA NA 1.56 NA NA 2960 NA NA 3050 NA NA 3220 NA NA 4460 NA NA 4940 NA NA 4730 NA NA 5.00 NA NA 5.85 NA NA 5.23 NA NA 6.57 6.32 3.88 NS NA NS NA 7/22/21 NS NA NS NA 10/26/21 NS NA NS NA 0.69 NA 0.65 144 NA NA 152 NA NA 147 NA NA 13.4 NS NA NS NA 7/23/21 18.5 NS NA NS NA 10/26/21 11.2 NS NA NS NA 4 09 NA NA 6.09 NA NA 1.89 NA NA 8.52 NA NA 13.80 NA NA 6.03 NA NA 16.2 NS NA NS NA 7/22/21 15.8 NS NA NS NA 10/27/2 I 14.9 NS NA NS NA 31.8 NS NA NS NA 7/28/21 36.5 NS NA NS NA 11/2/21 36.I NS NA NS NA 7.00 NS NA NS NA NS NA NS NA NS NA 11/17/21 706 NS NA NS NA Monitoring Well (Water Class) MW-II (Class 11) MW-25 (Class 111) MW-26 (Class Ill) MW-30 (Class II) MW-31 (Class Ill) MW-12 (Class Ill) MW-17 (Class 111) MW-24 (Class Ill) MW-27 (Class 111) MW-28 (Class 111) MW-29 (Class Ill) MW-32 (Class Ill) MW-37 /Class Ill) QI 2022 Results February February March 2022 March GWCL in QI 2022 2022 Constituent Exceeding GWCL March 8, 2021 Sample QI 2022 Monthly 2022 Monthly 2022 GWDP Date Result Sample Monthly Sample Monthly Date Result Date Result Required Quarterly Sampling Wells Nitrate+ Nitrite (as N) (mg/L) 2.5 2.55 NA NA Chloride (mg/L) 39.16 5/. I 57.2 67. 7 Manganese (ug/L) 237 1/18/22 156 2/8/22 233 3/8/22 224 Sulfate (mg/L) 1309 1020 1240 1170 TDS (mg/L) 2528 2050 1900 2080 Selenium (ug/L) 12.5 9.29 NA NA TDS (mg/L) 2976 1/17/22 2720 2/9/22 2690 3/7/22 2610 Chloride (mg/L) 35 34.1 NA NA Nitrate + Nitrite (as N) (mg/L) 0.62 0.601 0.367 0.600 Chloroform (ug/L) 70 1/20/22 8/8 2/9/22 /580 3/8/22 /460 Chloride (mg/L) 5831 77.I 58.6 64.I Nitrate + Nitrite (as N) (mg/L) 2.5 14.5 13.6 /6.6 Chloride (mg/L) 128 181 184 196 Selenium (ug/L) 53.6 1/17/22 56.7 2/9/22 57. 7 3/7/22 62.0 Field pH (S U ) 6.47 -8.5 7.62 720 7.12 Uranium (ug/L) 9.82 JO. I 10.3 9.9 Nitrate + Nitrite (as N) (mg/L) 5 /8.0 /3.5 17.0 Sulfate (mg/L) 993 1210 1250 731 TDS (mg/L) 2132 1/19/22 2620 2/8/22 2680 3/7/22 2530 Uranium (ug/L) 15 21.7 22./ 22.5 Chloride (mg/L) 143 370 379 416 Required Semiannual Sampling Wells Uranium (ug/L) 23.5 1/20/22 Selenium (ug/L) 39 22.1 25.6 NS NA NS NA Chloride (mg/L) 46.8 NS NA NS NA NS NA Beryllium (ug/L) 2 2. 71 NA NA Cadmium (ug/L) 6.43 8.46 NA NA Fluoride (mg/L) 0.47 I NA NA Nickel (mg/L) 50 80.9 NA NA Manganese (ug/L) 7507 7630 NA NA Thallium (ug/L) 201 1/27/22 2.66 NS NA NS NA Gross Alpha (pCi/L) 7.5 2.26 NA NA Sulfate (mg/L) 2903 3060 NA NA TDS (mg/L) 4450 4140 NA NA Field pH (S U ) 5.03 -8.5 5.31 NA NA Nitrate + Nitrite (as N) (mg/L) 5.6 6.25 1/18/22 NS NA NS NA Fluoride (mg/L) 0.85 NA Chloride (mg/L) 105 /40 NA NA Selenium (ug/L) 11.1 1/20/22 /3.3 NS NA NS NA Nitrate+ Nitrite (as N) (mg/L) 5 4 03 NA NA Uranium (ug/L) 4.9 8.50 NA NA Uranium (ug/L) 15 1/18/22 15./ NS NA NS NA Chloride (mg/L) 35.39 1/19/22 35.0 NS NA NS NA Field pH (S.U.) 6.61 -8.5 NS NA NS NA NS NA Pursuant to ttie DWMRC letter of August 8, 2022, these constituents will no longer be monitored on an accelerated schedule. Th ese constituents will be dropped from this report after this quarter. Q2 2022 Sample Date 4/18/22 4/12/22 4/20/22 4/20/22 4/11/22 4/19/22 4/18/22 4/27/22 4/12/22 4/19/22 4/14/22 4/11/22 5/17/22 Table I -GWCL Exceedances under the March 8, 2021 GWDP Q2 2022 Results QJ 2022 Results Q4 2022 Results May 2022 June 2022 August August September September November November December December May 2022 June 2022 QJ 2022 2022 Q4 2022 Q2 2022 Monthly Monthly Monthly Monthly Sample QJ 2022 Monthly 2022 2022 2022 Sample Q4 2022 2022 2022 2022 2022 Result Sample Result Sample Result Date Result Sample Monthly Monthly Monthly Date Result Monthly Monthly Monthly Monthly Date Date Date Result Sample Date Result Sample Date Result Sample Date Result Required Quarterly Sampling Wells Required Quarterly Sampling Wells Required Quarterly Sampling Wells 2.2 1.6 1.9 2.12 2.45 2.65 2.90 2.74 1.30 54.9 59.5 46.4 54.0 67.4 68. I 72./ 71.9 52.3 180 5/4/22 254 6/6/22 228 7/12/22 297 8/8/22 201 9/21/22 212 10/10/22 214 11/8/22 220 12/14/22 273 1240 1270 866 /390 1260 1300 1140 1140 1330 2060 2290 2360 2520 3230 2280 2570 2270 2370 10.8 NA NA 9.3 NA NA 15.5 NA NA 3600 5/3/22 2660 6/7/22 2730 7/13/22 2830 8/9/22 2780 9/20/22 2750 10/10/22 2660 11/9/22 2690 12/14/22 2780 33.4 NA NA 22.4 NA NA 35.8 NA NA 0.8 I. I 0.60 1.63 1.56 0.491 0.632 0.408 2.66 447 5/4/22 616 6/7/22 1250 7/14/22 <1.0 8/9/22 1120 9/20/22 810 10/13/22 749 11/10/22 512 12/15/22 460 56.8 63.2 47.4 6/.0 65.0 62. J 65.5 59.2 60.6 17 15 11.0 17.6 13.5 /6.5 17.9 15.9 /6. I 173 /95 126 108 185 /82 /96 156 /95 64.9 5/4/22 69.4 6/7/22 65.7 7/13/22 61. I 8/9/22 64.3 9/20/22 70.0 10/13/22 65./ 11/9/22 75.6 12/13/22 70.8 6.92 7.24 7.32 7.33 7.33 6.81 6.84 6.37 6.59 9.6 /0. J 9.6 10.0 10. I 8.3 9.8 10. I /3.0 /8.0 /3.0 13.0 16.9 16.8 17. I 17.0 16.0 /2.6 1180 1220 1110 1260 /230 1200 972 /380 1280 4300 5/3/22 2660 6/6/22 2690 7/12/22 2700 8/8/22 2700 9/20/22 2830 10/11/22 2720 11/8/22 2670 12/13/22 2700 22.0 22.9 21.5 22.6 22.7 18.8 23.3 24.5 26.2 372 38/ 35/ 42/ 396 390 397 243 335 Required Semiannual Sampling Wells Required Semiannual Sampling Wells Required Semiannual Sampling Wells 20.5 31.3 NS NA NS NA 7/14/22 21.6 NS 29.2 NA NS NA 10/13/22 21.2 32.1 NS NA NS NA 31.5 NS NA NS NA NS NA NS NA NS NA 10/17/22 54.0 NS NA NS NA 2.5 NA NA 2.7 NA NA 3.3 NA NA 9.20 NA NA 8.6 NA NA 10.9 NA NA 0.8 NA NA 0.760 NA NA 1.53 NA NA 74.3 NA NA 69.9 NA NA 86.9 NA NA 7070 NA NA 7/20/22 7540 NA NA 8130 NA NA 3./ NS NA NS NA 7/28/22 3.0 NS NA NS NA 11/2/22 3.5 NS NA NS NA 2.28 NA NA 2.55 NA NA 2.70 NA NA 3/20 NA NA 2800 NA NA 2680 NA NA 3350 NA NA 4200 NA NA 4440 NA NA 4.81 NA NA 4.89 NA NA 4.39 NA NA 4.80 6.30 5.18 5.26 NS NA NS NA 7/15/22 NS NA NS NA 10/19/22 NS NA NS NA 0.90 0.530 0.722 130 NA NA 159 NA NA /6/ NA NA /9.8 NS NA NS NA 7/15/22 20.8 NS NA NS NA 10/12/22 23.7 NS NA NS NA 5./ NA NA 5./6 NA NA 5.69 NA NA 10./0 NA NA /2.4 NA NA /2.5 NA NA 15. 7 NS NA NS NA 7/14/22 /5. I NS NA NS NA 10/12/22 /5.2 NS NA NS NA 28.6 NS NA NS NA 7/15/22 28.2 NS NA NS NA 10/11/22 37.I NS NA NS NA 704 NS NA NS NA NS NA NS NA NS NA 11/1 /22 6.60 NS NA NS NA .\. Table I -GWCL Exceedances under the March 8, 2021 GWDP Ql 2023 Results February February March 2023 March Monitoring GWCLin Qt 2023 2023 Well (Water Constituent Exceeding GWCL March 8, 2021 Sample QI 2023 Monthly 2023 Monthly 2023 Class) GWDP Date Result Sample Monthly Sample Monthly Date Result Date Result Required Quarterly Sampling Wells Nitrate + Nitrite (as N) (mg/L) 2.5 3.49 2.89 2.53 Chloride (mg/L) 39.16 70. 7 71.4 66.3 MW-II Manganese ( ug/L) 237 193 161 211 (Class 11) 1/25/23 2/8/23 3/14/23 Sul fate (mg/L) 1309 1240 1100 1430 TDS (mg/L) 2528 2390 2120 2300 Selenium (ug/L) 12.5 17.5 17.7 14.9 MW-25 (Class TDS (mg/L) 2976 2750 2610 2600 111) 1/23/23 2/7/23 3/15/23 Chloride (mg/L) 35 32.4 32.2 32.6 MW-26 Nitrate + Nitrite (as N) (mg/L) 0.62 1.82 1.94 0.875 (Class 111) Chloroform (ug/L) 70 1/26/23 709 2/8/23 664 3/14/23 1060 Chloride (mg/L) 58.3 1 51.5 52.2 47.7 Nitrate + Nitrite (as N) (mg/L) 2.5 18. I 15.9 17.3 MW-30 Chloride (mg/L) 128 166 173 199 (Class 11) Selenium (ug/L) 53.6 1/25/23 68.8 2/8/23 70.6 3/15/23 72./ Field pH (S.U.) 6.47 -8.5 7 0 1 6.77 7.15 Uranium (ug/L) 9.82 10.8 9.6 9.6 Nitrate + Nitrite (as N) (mg/L) 5 18. 7 16.5 17.9 MW-31 Sulfate (mg/L) 993 1230 1/90 951 (Class 111) TDS (mg/L) 2132 1/24/23 2740 2/7/23 2730 3/14/23 2520 Uranium (ug/L) 15 25.4 23.3 23.7 Chloride (mg/L) 143 333 388 302 Required Semiannual Sampling Wells MW-12 Uranium (ug/L) 23.5 21.3 1/26/23 NS NA NS NA (Class 111) Selenium (ug/L) 39 270 MW-17 Chloride (mg/L) 46.8 1/30/23 (Class III) 26.5 NS NA NS NA Beryllium (ug/L) 2 2.4 NA NA Cadmium (ug/L) 6.43 9.2 NA NA Fluoride (mg/L) 0.47 0.699 NA NA Nickel (mg/L) 50 72.5 NA NA MW-24 Manganese (ug/L) 7507 7000 NA NA (Class 111) Thallium (ug/L) 201 1/31 /23 2.9 NS NA NS NA Gross Aloha (oCi/L) 7.5 2.27 NA NA Sulfate (mg/L) 2903 2720 NA NA TDS (mg/L) 4450 4220 NA NA Field pH (S.U) 5.03 -8.5 4.76 NA NA MW-27 Nitrate + Nitrite (as N) (mg/L) 5.6 5.25 (Class III) 1/27/23 NS NA NS NA Fluoride (mg/L) 0.85 0.685 Chloride (mg/L) 105 140 NA NA MW-28 Selenium ( ug/L) 11.1 1/27/23 <5.0 NS NA NS NA (Class 111) Nitrate + Nitrite (as N) (mg/L) 5 4.57 NA NA Uranium (ug/L) 4.9 15.5 NA NA MW-29 Uranium (ug/L) 15 1/27/23 9.7 NS NA NS NA (Class 111) MW-32 Chloride ( mg/L) 35.39 1/30/23 27.9 NS NS (Class Ill) NA NA MW-37 Field pH (S U ) 6.6 1 -8.5 2/9/23 (Class 111) 6.55 NS NA NS NA