Loading...
HomeMy WebLinkAboutDRC-2015-005130 - 0901a0688055762aState of Utah GARY R HERBERT Governor SPENCER J COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T Anderson Director MEMORANDUM TO: THROUGH: FROM: DATE: SUBJECT: File Phil Goble, Manager Tom Rushing, P.G. ^/5? August 11, 2015 Review of the May 12, 2015 Energy Fuels Resources (USA) Inc. 1st Quarter 2015 Ground Water Monitoring Report for the White Mesa Uranium Mill Review Summary; The Utah Division of Waste Management and Radiation Control ("DWMRC") has reviewed the following documents submitted by Energy Fuels Resources (USA) Inc. ("EFR"): 1. EFR, May 12, 2015, Transmittal of Is' Quarter 2015 Groundwater Monitoring Report Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill. 2. EFR, May 6, 2015, State of Utah Ground Water Discharge Permit No. UGW3 70004 White Mesa Uranium Mill - Notice Pursuant to Part I. G.l(a). 3. EFR, May 7, 2015, Removal of Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status 4. EFR, May 19, 2015, Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004 Part I.G.4(c) The review was conducted to ensure compliance with all applicable parts of Utah Groundwater Discharge Permit No. UGW370004 ("Permit") issued for the White Mesa Uranium Mill located in Blanding, Utah. 1. Checklist of Significant Findings of the l" Otr. 2015 Report and Related Actions at the White Mesa Uranium Mill; 1. The 1st Quarter 2015 Report was received on May 14, 2015, which was before the due date (Permit Part I.F.I - due date of June 1, 2015). 2. DWMRC notes that samples were analyzed by American West Analytical Laboratories ("AWAL") with the exception of Gross Radium Alpha which was analyzed by GEL Laboratories LLC. DWMRC verified that the laboratories have current Utah certification for all parameters/methods used. No deviations/violations of the currently approved Quality Assurance Plan for the White Mesa Uranium Mill were noted. 3. Per a previous EFR request, a May 25, 2012 EFR Permit modification request was made in order to document accelerated reporting and monitoring agreements made during a 195 North 1950 West • Salt Lake City, UT Mailing Address P O Box 144880 • Salt Lake City, UT 84114-4880 Telephone(801) 536-0200• Fax (801)-536-0222-TDD (801) 536-4414 www deq Utah gov Printed on 100% recycled paper EFR 1 Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 2 teleconference with the DWMRC. Per DWMRC staff discussions: The May 25, 2012 request will be included with the White Mesa Mill Ground Water Permit Renewal. DWMRC review of the 3rd Quarter 2014 Report recognizes the telephone agreements regarding timelines for EFR to submit compliance notices. The modification request is currently being addressed through the Permit renewal process. 4. DWMRC Stipulated Consent Agreement, Docket No. UGW12-03 required EFR to submit an October 10, 2012 Source Assessment Report, an April 13, 2012 pH Report, and a December 12,2012 Pyrite Investigation Report for previously documented out-of- compliance parameters (multiple parameters). Per DWMRC review findings as documented in a DWMRC review memo dated April 23, 2013, and transmitted via letter to EFR dated April 25, 2013, it was recommended that specific GWCL parameters for monitoring wells be modified (12 instances), GWCL's for pH be modified for all monitoring wells, and that GWCL's be removed from the permit for three up-gradient monitoring wells. These requests are currently being addressed through the Permit Renewal process. Review of the 4th Quarter 2014 Report is based on current Permit GWCL's, modified GWCLs are required to undergo public notice requirements per the Utah Administrative Code and listed in an active Permit. 5. Permit compliance limits for monitoring wells around the White Mesa Mill Tailings Cell 4B (Monitoring Wells MW-35, MW-36 and MW-37) were approved by the Director via letter dated July 15, 2014. The approval was based on DWMRC staff review of a May 1, 2014 EFR Background Groundwater Quality Report for the wells. The approved GWCL's will not be enforceable until final inclusion in the renewal permit; therefore, the 1st Quarter 2015 Report data results were compared with the interim limits or groundwater quality standards as listed in the currently active Permit. 6. Laboratory QA/QC flags were documented in the review period analytical data reports from the contract laboratories. Per DWMRC review it appears that all discrepancies were self-reported by EFR. 7. Four compliance parameters went into accelerated monitoring frequency during the monitoring period, as discussed below. 2. Accelerated Monitoring and POC Wells Exceeding GWCL's: When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL) set forth in Table 2 of the Permit, it is in Probable Out-of-Compliance (POOC) status. According to the Permit, EFR is then required to immediately initiate accelerated sampling of that pollutant (see the Permit, Part I.G.I). When monitoring wells have parameters that have exceeded the Ground Water Compliance Limit (GWCL) two or more consecutive times they are in Out-of-Compliance (OOC) status (see the Permit, Part I.G.2). In the event a constituent is in OOC status, EFR is required to prepare and submit within 30 calendar days to the Director a plan and time schedule for assessment of the sources, extent and potential dispersion of the contamination, and an evaluation of potential remedial action to restore and maintain groundwater quality to ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT will be re-established, in accordance with Part I.G.4(c) of the Permit. EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 3 Accelerated Monitoring Requirement Exception: Per past DWMRC review; 1st Qtr., 2nd Qtr., and 3rd Qtr. 2011 Groundwater Monitoring Reports, DWMRC issued a February 7, 2012 Notice of Enforcement Discretion ("NOED") for failure on the part of EFR to comply with these timelines for acceleration of groundwater monitoring at well MW-35. EFR stated in a March 26, 2012 response to the NOED that based on an agreement made between DWMRC and EFR during a telephone conference call on April 5, 2010, EFR is not required to implement accelerated monitoring until "the month following the submission of the Exceedance Notice for a specified quarter." Based on DWMRC review of notes taken during the April 5, 2010 telephone conference (Loren Morton 4/5/10), EFR verbally requested to wait until the end of the quarter to submit the notice of out-of compliance status - but within 30 days of the last lab report that EFR receives for the quarterly monitoring event. DWMRC notified EFR by letter (dated April 16, 2012) that in order to formalize the April 5, 2010 discussion items related to out-of-compliance reporting and sampling, a written request for a groundwater permit modification (groundwater permit, out-of-compliance notification and accelerated monitoring requirements) was required for Director review and approval. EFR submitted a May 25, 2012 written request for a Permit modification, including redline copies of pertinent pages of the Permit to reflect the agreements made during the April 5, 2010 conference call. The Permit modification request is currently under DWMRC review and is pending inclusion in the Permit Renewal. In the interim, DWMRC is honoring the teleconference agreements and is not pursuing Permit enforcement based on EFR failure to meet the current time and schedule submission requirements as stated in the Permit. Current Accelerated Monitoring Status: The table below (Table 1) lists monitoring wells with parameters currently in OOC or POOC status and therefore required to be sampled under the accelerated monitoring requirements: Table 1 - Wells Monitored Quarterly Accelerated to Monthly Monitoring Well Class * Position Parameter Date of First Exceedance of GWCL Date Accelerated Monitoring First Required MW-11 Class II water D-3 Manganese February 2010 May 2010 MW-14 Class III water D-4A Field pH February 2010 May 2010 MW-25 Class III water C-3 Field pH Uranium Chloride 4m Quarter 2010 3rd Quarter 2010 1st Quarter 2013 February 2013 March 2014 June 2013 MW-26(a) Class III water C-2 Field pH Nitrate + Nitrite (as N) Chloroform Uranium Chloride Dichloromethane Carbon Tetrachloride February 2010 February 2010 February 2010 February 2010 February 2010 April 2010 1st Quarter 2014 May 2010 May 2010 May 2010 May 2010 May 2010 June 2010 June 2014 MW-30 Class II water D-2 Nitrate + Nitrite (as N) Chloride February 2010 Is'Quarter 2011 May 2010 May 2011 EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 4 Well Class *Position Parameter Date of First Exceedance of GWCL Date Accelerated Monitoring First Required Selenium Uranium Field pH Ammonia April 2010 4th Quarter 2011 4th Quarter 2014 4th Quarter 2014 July 2010 March 2014 March 2015 March 2015 MW-31 Class III water D-2 Nitrate + Nitrite (as N) Chloride Sulfate TDS Selenium Field pH February 2010 1st Quarter 2011 4th Quarter 2010 September 2010 3rd Quarter 2012 February 2014 May 2010 May 2011 March 2011 January 2011 December 2012 June 2014 MW-35 Class II C-4B Uranium Manganese Thallium Adjusted Gross Alpha Selenium Field pH 2nd Quarter 2011 2nd Quarter 2011 3rd Quarter 2011 3rd Quarter 2011 3rd Quarter 2012 July 2011 July 2011 July 2011 July 2011 October 2011 December 2012 August 2011 D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1,2,3,4A = Cell # a = Monitoring well MW-26 is a pumping well for the Chloroform investigation Wells Monitored Semi-annually Accelerated to Quarterly Monitoring Well Class *Position Parameter Date of First Exceedance of GWCL Date Accelerated Monitoring First Required MW-Class II water U-l Tetrahydrofuran Field pH Sulfate Manganese 4"1 Quarter 2012 3rd Quarter 2014 4th Quarter 2012 4th Quarter 2012 ^Quarter 2010 2nd Quarter 2010 2nd Quarter 2010 4th Quarter 2013 4th Quarter 2013 1st Quarter 2013 1st Quarter 2015 1st Quarter 2013 Is'Quarter 2013 S^Quarter 2010 3rd Quarter 2010 3rd Quarter 2010 2nd Quarter 2014 2nd Quarter 2014 MW-3 Class III water D-4A Selenium Field pH Fluoride Nitrate + Nitrite (as N) Sulfate MW-3A Class III water D-4A Field pH Sulfate TDS Selenium Nitrate + Nitrate (as N) 2"dQuarter 2010 2nd Quarter 2010 2nd Quarter 2010 4th Quarter 2010 4th Quarter 2012 3HQuarter 2010 3rd Quarter 2010 3rd Quarter 2010 1st Quarter 2011 Is'Quarter 2013 ^Quarter 2010 2nd Quarter 2010 1st Quarter 2014 4th Quarter 2014 MW-5 Class II water D-3 Uranium Is'Quarter 2011 MW-12 Class III water D-3 Selenium Field pH Selenium 3™ Quarter 2010 2nd Quarter 2014 2nd Quarter 2015 MW-15 Class III water D-4A Selenium Field pH ^Quarter 2012 4th Quarter 2013 3rd Quarter 2012 2nd Quarter 2014 2"* Quarter 2010 MW-18 Class III water U-l Thallium Sulfate 2nd Quarter 2010 3rd Quarter 2010 3rd Quarter 2010 EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 5 Well Class * Position Parameter Date of First Exceedance of GWCL 2nd Quarter 2010 Is' Quarter 2014 Date Accelerated Monitoring First Required TDS Field pH 3™ Quarter 2010 2nd Quarter 2014 MW-19 Class III water U-l Field pH Nitrate + Nitrite as N Adjusted Gross Alpha ^Quarter 2010 4th Quarter 2011 4th Quarter 2012 3rd Quarter 2010 1st Quarter 2012 1st Quarter 2013 MW-23 Class III water D-3 Field pH ^Quarter 2010 3rd Quarter 2oTo~ MW-24 Class III water D-l Cadmium Thallium Field pH Fluoride Sulfate ^Quarter 2010 2nd Quarter 2010 2nd Quarter 2010 4th Quarter 2012 4th Quarter 2014 3rd Quarter 2010 3rd Quarter 2010 3rd Quarter 2010 1st Quarter 2013 2nd Quarter 2015 MW-27 Class III water U-l Nitrate + Nitrite (as N) Adjusted Gross Alpha TDS Chloride Sulfate 2~"a~Quarter 2010 4th Quarter 2010 1st Quarter 2010 1st Quarter 2010 2nd Quarter 2013 3rd Quarter 2010 4th Quarter 2014 3rd Quarter 2010 3rd Quarter 2010 1st Quarter 2014 MW-28 Class HI water D-l Field pH Chloride Cadmium Uranium Vanadium 1st Quarter 2014 2nd Quarter 2010 2nd Quarter 2014 2nd Quarter 2014 2nd Quarter 2014 T5 Quarter 2014 3rd Quarter 2010 2nd Quarter 2014 2nd Quarter 2014 2nd Quarter 2014 2"HrQuarter 2011 3rd Quarter 2012 MW-29 Class III water D-2 Field pH TDS 4th Quarter 2010 2nd Quarter 2012 S^Quarter 2010 3rd Quarter 2010 MW-32 Class III water C-2 Adjusted Gross Alpha Field pH Chloride 2s1 Quarter 2010 2nd Quarter 2010 Is' Quarter 2015 2nd Quarter 2015 * D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A = Cell # Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status as of the first quarter of 2015. EFR is required to notify the DWMRC on a quarterly basis regarding wells and parameters which went into accelerated monitoring during the period [Part I.G.I (a), Accelerated Monitoring Status Reports (AMSR)]. For the 1st quarter 2015 monitoring, the AMSR and follow up Plan and Time Schedule [Required by the Permit Part I.G.4(d)] was received, dated May 6, 2015 (received by DWMRC on May 7, 2015). One parameter with a new exceedance was noted per review of the AMSR: MW-32 was accelerated from semi-annual to quarterly based on a 1st Quarter 2015 exceedance of the Chloride GWCL. DWMRC notes that monitoring well MW-28 was damaged prior to groundwater sampling during the 2nd Quarter 2014 and per discussions with EFR at that time, it was agreed that the results of the 3rd Quarter 2014 would be reviewed and compared with those previous data to determine if exceedances of cadmium, uranium and vanadium were continuous. It is possible/likely that repair of the well and redevelopment activities which occurred subsequent to the damage will correct the exceedances. Based on subsequent discussion between DWMRC and EFR, it was decided that additional accelerated monitoring results, beyond the 3rd Quarter 2014, would be needed to determine if the well damage was the cause of the parameter exceedances and whether additional corrective action, and the type of action (e.g. groundwater EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 6 pumping), would be required. DWMRC subsequently approved an EFR December 4, 2014 Plan and Time schedule to assess the uranium, vanadium and cadmium GWCL exceedences at monitoring well MW28, by letter dated January 8, 2015. Noting that EFR agreed to perform additional accelerated monitoring for those parameters and, if concentrations did not decrease by the 1st quarter 2015, to perform a video inspection of the interior of the monitoring well. Per the EFR Report, the uranium, vanadium and cadmium concentrations in MW-28 were all below the GWCL's for 1st quarter 2015. EFR will continue accelerated monitoring, but, per the approved Plan and Time Schedule no additional actions are required at this time. The EFR 1st Quarter 2015 Report additionally includes a "MW-28 Repair Report and Plan and Time Schedule" as Tab K. The tab includes a copy of EFR's original, December 4, 2014 Plan and Time Schedule and repair photos. 3. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection: As stated in Section 6.2.7 of the EFR Quality Assurance Plan (QAP), Rev. 7.2, EFR has a choice regarding purge volumes as follows: "7. Purging three well casing volumes with a single measurement offield parameters 2. Purging two casing volumes with stable field parameters (within 10% RPD) 3. Purging a well to dryness and stability of a limited list offield parameters after recovery Per DWMRC review of the Report, the following purge methods were used during the 1st Quarter 2015 (including accelerated samples). Purge methods and volumes are summarized on Table G-l A of the 1st Quarter 2015 Monitoring Report: Quarter Is'Qtr. 2015 # Purged 2 Casing Volumes | # Purged to Dryness | # Purged 3 Casing Volumes 30 4 4 When purging two casing volumes, EFR QAP Rev. 7.2 directs EFR to first calculate the amount of time to evacuate two casing volumes and then pump for that length of time. Per DWMRC cross-check of the field data sheets for each of the reports reviewed, it appears EFR correctly calculated the well casing volumes and evacuated the required two volumes (when 2 casing volume method selected) in monitoring wells prior to sample collection during the 1st Quarter 2015 monitoring period. Volumes are calculated according to measured pump rates and can be verified by calibration marks on the collection containers. During the 1st Quarter of 2015 monitoring four wells were pumped or bailed to dryness. In cases where wells are evacuated to dryness the QAP Rev. 7.2 requires that: "(vii) If the well is purged to dryness: Record the number of gallons purged on the Field Data Worksheet. The well should be sampled as soon as a sufficient volume of groundwater is available to fill sample containers. Upon arrival at the well after recovery or when sufficient water is available for sampling measure depth to water and record on the Field Data Worksheet. Take one set of measurements offield parameters for pH, specific conductance and temperature only. EFR 1 Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 7 Collect the samples into the appropriate sample containers. Take an additional set of measurements of field parameters for pH, specific conductance and temperature after the samples have been collected. If the field parameters ofpH, specific conductance and temperature are within 10% RPD the samples can be shipped for analysis. If the field parameters ofpH, specific conductance and temperature are not within 10% RPD, dispose of the sample aliquots, and purge the well again as described above. Repeat this process if necessary for three complete purging events. If after the third purging the event, the parameters of pH, specific conductance and temperature do not stabilize to within 10% RPD, the well is considered sufficiently purged and collected samples can be submitted for analysis." DWMRC staff verified that in cases where the monitoring well was evacuated to dryness and samples were collected, the number of gallons evacuated was recorded in compliance with the QAP. Also, DWMRC staff verified that depth to groundwater was measured and recorded (comments field) on the field sheet. 4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind Duplicate Analysis: DWMRC conducted a review of the blind duplicate samples collected during the 1st Quarter 2015. Per the facility QAP, one blind duplicate must be collected with each sample batch. DWMRC confirmed that one blind duplicate was collected for each batch - 4 total during the quarterly event - two with the baseline samples (MW-35/MW-65 on 2-15-15 and MW-36/MW-70 on 2-10-15) and two with the accelerated samples (MW-30/MW-65 on 1-21-15 and MW-35/MW-65 on 3-4-15). The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the measured concentrations are less than 5 times the required detection limit (Standard Methods, 1998)." Per updated language in the QAP Rev. 7.2 Part 9.1.4, if any of the samples do not meet the comparison criteria (and are not qualified according to the 5 times method detection limit criteria) then EFR is required to conform to the procedures for corrective action listed as follows: 1. Notify the laboratory, 2. Request the laboratory review all analytical results for transcription and calculation errors, and, 3. If the samples are still within holding time, the QA Manager may request the laboratory re-analyze the affected samples. Per DWMRC cross check of the blind duplicate samples collected and analyzed during the 1st Qtr. 2015 sampling event all sample results conform to the Permit requirements (within 20% RPD) with the exception of Nitrate + Nitrite as N duplicate MW-30/MW-65 for the January 2015 accelerated monitoring event (1/21/2015). Regarding the Nitrate + Nitrite as N duplicate MW-30/MW-65 for the January 21, 2015 accelerated monitoring event, EFR provides the following explanation in the 1st 2015 Report, "Both of the sample results reportedfor MW-30/MW-65 were not five times greater than the reporting limits of 5.0 and as such the deviation from the 20% RPD requirement is acceptable." The White Mesa Quality Assurance Plan, EFR Is Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 8 Section 9.1.4.a states, "RPD's will be calculated in comparison of duplicate and original field sample results. Non-conformance will exist when the RPD >20% unless the measured concentrations are less than 5 times the required detection limit (Standard Methods, 1998)." Per Standard Methods, 1998 the method detection limit for Nitrate/Nitrite as N by method E.353.2 is 0.0057 mg/L, and the required reporting limit in the QAP is 0.1 mg/L. DWMRC notes that the laboratory used a dilution factor of 50 for the samples and therefore raised the reporting limit to 5 mg/L. Based on DWMRC review of the QAP, it appears that when referring to the "required detection UmiF that the QAP is referring to the required reporting limit. In this case, DWMRC concurs that the reported concentration is not more than the raised reporting limit of 5mg/L and is probably acceptable by the terms of the QAP; however, it was noted per review of the method that "The applicable range is 0.05-10.0 mg/L nitrate-nitrite nitrogen. The range may be extended with sample dilution." The question is whether the currently used method is appropriate for reported concentrations which require a 50 times dilution of the sample. This issue will be discussed with EFR during a close out meeting, as well as other options (e.g. other methods which may be more appropriate). 5. Analytical Laboratories Used by EFR Certified by State of Utah to Perform Analysis for all Analytes: The analytical laboratories (GEL Laboratories LLC, Charleston, SC and American West Analytical Laboratories, Salt Lake City, UT) were contracted by EFR to perform analysis on the samples collected during the 1st Quarter, 2015. Per DWMRC review of the National Environmental Laboratory Accreditation Management System Website (cross check of laboratory certification for specific parameters) it appears that the EFR contract laboratories were certified to perform analysis for the specified parameters during the review period as follows. GEL Laboratories LLC current Utah Certification: Basic Details Name GEL Laboratories, LLC Type of Lab Commercial TNI Lab Code TNI00188 EPA Code SC00012 State ID E87156 Website Extended Details Primary AB responsible for lab demographics Utah Department of Health GIS Location Description Comments Effective Date Commercial Samples Yes Active Yes Address 1 Type Location Company Contact JAMES B. WESTMORELAND Address 1 2040 Savage Rd Address 2 City Charleston State South Carolina EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 9 Zip 29407 Country US Phone 8435568171 Fax 8437661178 Email ibw@gel.com American West Analytical Laboratories Current Utah Certification Basic Details Name American West Analytical Laboratories Type of Lab Commercial TNI Lab Code TNI01955 EPA Code UT00031 State ID 8012638686 Website Extended Details Primary AB responsible for lab demographics GIS Location Description Comments Effective Date Commercial Samples Active Yes Address 1 Type Location Company Contact Kyle Gross Address 1 463 West 3600 South Address 2 City Salt Lake City State Utah Zip 84115- Country US Phone 8012638686 Fax 8012638687 Email kyle@awal-labs.com DWMRC noted that the only analyte requested by EFR to be analyzed by GEL Laboratories was gross alpha (Gross Alpha Radium) and that GEL Laboratories holds current accreditation in Utah for that analyte method EPA 900.1 GFPC Modified. 6. Laboratory Report Turn Around Times: Per DWMRC review of EFR Table 1 included in the 1st Qtr. 2015 Report, it was noted that laboratory report turnaround times (from date of EFR sample submission to the contract laboratory) for normal frequency monitoring was approximately 30 days on average not including re-submission/corrected reports. Per DWMRC review it was noted that EFR acted quickly to identify any deficiencies in the reports and request corrected versions. Utah Department of Health Yes EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 10 There is not a turnaround time requirement in the current QAP; therefore, current turnaround times are judgment based. DWMRC has raised concern over excessive laboratory turn-around times in the past and the Director may require a turn-around date be included in the facility QAP if any future concerns regarding analysis turnaround times are noted. Based on DWMRC review the turn-around times for the 1st Quarter 2015, data turn-around times and EFR data review timelines appear to be reasonable/appropriate. 7. Sample Holding Times: Per Table G-2A and Table G-2B of the Report, all method holding times were met for each analyte submitted for laboratory analysis. DWMRC staff cross checked all holding time requirements and verified that all samples/analytes appeared to be analyzed within holding times during the 1st Qtr. 2015 reporting period. 8. Sample Preservation: Per review of the 1st Quarter 2015 Report (Table G-3A and Laboratory Check-in Sheets) it appears that all samples required to be chilled (<6° C) met the temperature preservation requirements. Per review of the laboratory check in sheets and laboratory QA/QC, no issues related to sample preservation were noted. 9. Laboratory OA/OC Flags - Is' Quarter 2015: QA/QC issues and DWMRC findings for the 1st Quarter 2015 are summarized below: Non-Conformance Summary Self- Identified? EFR Corrective Action Summary DWMRC Findings Laboratory reporting limits were raised for various samples for analysis of Ca, CI, K, Na, S04, Mg, TDS, Nitrate/Nitrite (as N), Ammonia EFR states that the raised RL's are due to sample dilution and qualifies the data in Table G based on all sample results being above the raised RL. The EFR QAP allows for raised RL's if due to the need for dilution. DWMRC verified that in all cases when the RL was raised above the QAP required RL the sample result was higher in concentration. MW-26, MW-32 - Gross Alpha Counting Error was not < 20% of the sample analysis result (sample activity). The sample result + the counting errors were less than the GWCL in all cases and are therefore acceptable. Per the QAP Part 9.1.4(b) "An error term may be greater than 20% of the reported activity concentration when the sum of the activity concentration and error term is less than or equal to the GWCL" Matrix Spike % recovery outside of range: MW- 11 Ammonia, MW-26 Ammonia, MW-19 Nitrate, MW-11 Nitrate, MW-26 Ammonia, MW-03 Nitrate, MW-31 Nitrate, MW-26 Nitrate None Per the QAP Part 8.1.2(a) matrix spikes are required but there are no requirements which would disqualify the laboratory data EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 11 Non-Conformance Summary Self- Identified? EFR Corrective Action Summary— DWMRC Findings Laboratory Duplicate % Recovery Comparison Outside of Range MW-03A TDS Per AWAL Data Sheet: High RPD due to suspected sample non-homogeneity or matrix interference Data was reported with a qualifier Note: DWMRC reviewed the holding time summary chart; no exceedances of holding times were noted DWMRC reviewed the temperature check charts, all sample batches were received by the laboratory <6° C. 10. Review of Time-Concentration Plots The Permit Part I.F.I .g requires EFR to submit Time-Concentration Plots for each monitoring well for primary indicators of cell leakage (based on tailings cell concentrations and ground water partitioning and retardation coefficients); chloride, fluoride, sulfate and uranium. DWMRC notes that per the discussions with EFR, it was agreed to that EFR need not plot trend lines on the Time Concentration Plots and that all data is included on the plots (no data culled from the set). Per DWMRC review of the 1st Qtr. 2015 Report, the reviewed plots appear to be in conformance with the agreed upon changes, no issues were identified. 11. Review of Depth to Groundwater Measurements and Water Table Contour Maps Per DWMRC cross checks of groundwater elevation measurement calculations used for the 4lh Quarter 2014, approximately 5% of wells cross checked, comparing surface measured elevations minus measured static levels with plotted elevations, no errors were noted. The upper wildlife ponds at the White Mesa Mill were taken offline (pond recharge from Recapture Reservoir discontinued) during the 4th Quarter 2011 in order to re-establish groundwater contours. Hydrographs of the upper wildlife pond ground water piezometers (Water Level Elevation vs. Time) are included below. It was also noted that the static water levels in several monitoring wells close to the upper wildlife ponds showed significant decrease in water levels during recent quarterly monitoring. These declines can be attributed to natural dissipation of the area ground water mound and/or ground water pumping activities related to corrective action of nitrate and chloroform contamination plumes (development of cone of depressions around pumping wells). 9«22 U18 ? 5 AM E I. S.«10 | woe 5 2 SMt | MM ? • MM IUC Whftt Mtu Hid Hydrographr Ptozomttn Q North WHUf* Ponds EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 12 5.5*5 — 5.544 — 5 £43 - i 5J40 — * 6,530 — ! ssn - • ! 5.537 I i SJ536 -- | 5555 -- i 5J34 — : ifiii - - SAW - W31 • 5*30 -- &sza - IUC WhRt M«M MIH Hytfrograplw: Pt*XMMt*ra 6 South WIMHf* Pond* * » - < </W v. -jr.. -44- -V- Nitrate and Chloroform Corrective Action Plan Pumping Wells: Ground water elevations are being impacted by effects from ground water pumping for the nitrate and chloroform contamination plume remediation. The following monitoring wells have been converted to active pumping wells: Nitrate Pumping Wells TW4-22, TW4-24, TW4-25, TWN-2 Chloroform Pumping Wells - MW-4, MW-26, TW4-19, TW4-20, TW4-4 The nitrate pumping project was initiated during January 2013 (TW4-22, TW4-24, TW4-25 and TWN-2). The chloroform pumping project was initiated during April 2003 utilizing two wells (Wells MW-4 and TW4-19). Monitoring well MW-26 was then converted to a pumping well during August 2003. Monitoring well TW4-20 was initiated as a pumping well during August 2005, and monitoring well TW4-4 was initiated as a pumping well during January 2010. The pumping wells for both the nitrate and chloroform projects are set up with a delay device wherein the wells purge for a set amount of time then shut off in order to let the well recharge. All pumping wells include a flow meter which records the volume of water pumped from the well in gallons. Quarterly nitrate and chloroform reports are prepared by EFR and include pump volumes and delineation of pump capture zones based on kriged water contours. The kriged water level maps included with the 1st Quarter 2015 Report include these areas which are directly southwest from the upper wildlife ponds. DWMRC expects that ground water elevation contours will continue to adjust in response to the pumping activities and discontinuance of recharge to the upper wildlife ponds. 12. EFR May 6.2015 Notice Pursuant to the Permit Part I.G.l(a) The EFR May 6, 2015 Notice Pursuant to the Permit Part I. G. 1 (a) ("Notice") discusses the status of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-compliance EFR 1st Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 13 ("OOC") status, as updated through the 1st Quarter 2015. DWMRC notes that the Notice was submitted timely regarding currently agreed upon schedules. The Notice summarizes wells/parameters with OOC status which have been resolved by either separate corrective actions plans or approved modified GWCL's (pending inclusion in the renewal Permit). The Notice also lists one new monitoring well/parameter (MW-32 Chloride) which went into OOC status during the 1st Quarter and is subject to requirements of the Permit Part I.G.4(c) requiring an assessment of the sources of the contamination and potential remedial action to restore compliance. The Notice Page 11 includes a justification to not submit the assessment report which states "MW-32... The recalculated GWCL's will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCL's, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCL's become effective, the exceedances will continue to be noted and reported." Based on DWMRC review of the Notice it appears that all requirements of the Permit were met. 13. EFR May 7,2015 Removal of Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status Per the EFR May 7, 2015 Request for Removal of Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status ("EFR Request"), EFR requests that two monitoring well parameters be returned to baseline monitoring. Specifically, the EFR Request addresses the following wells/parameters be returned to baseline monitoring: • MW-1, Tetrahydrofuran • MW-23, Field pH The EFR requests that these monitoring wells be returned to baseline monitoring based on eight consecutive sample results below the GWCL. Per past protocols regarding the return of monitoring well parameters to baseline monitoring, eight consecutive sample results below the GWCL has been acceptable to reduce the monitoring frequency. The EFR Request includes a table summary which lists the applicable monitoring results for each well/parameter. The EFR Request additionally includes analytical reports and field monitoring sheets for sample results which had not been provided to DWMRC at the time of the request. Per DWMRC cross check of the results it appears that eight consecutive results have been obtained for each of the wells/parameters. Therefore it is recommended that the wells/parameters be returned to baseline monitoring as summarized on the table below: Monitoring Well Parameter Baseline Monitoring Frequency MW-Tetrahydrofuran Semi-Annual MW-23 Field pH Semi-Annual The return to baseline monitoring for these wells/parameters will be included in a transmittal letter for Director review and approval. EFR Is Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 14 14. EFR May 19.2015 Transmittal of Plan and Time Schedule under the Permit Part I.G.4(c) The EFR May 19, 2015 Plan and Time Schedule ("EFR Plan") addresses exceedances of the approved recalculated GWCL's for selenium, sulfate, total dissolved solids and field pH at monitoring well MW-31. EFR notes that these constituents show significant upward concentration trends and that these trends were identified in the 2007 Facility revised background groundwater quality report and subsequent reports submitted to DWMRC by EFR. The EFR Plan agrees to submit a Source Assessment Report ("SAR") for the above listed constituents in monitoring well MW-31 within 90 days after the approval of the EFR Plan. EFR notes that "The location of MW-31 is important when determining potential sources of contamination. MW-31 was included in the October 2012 SAR for exceedances in sulfate and TDS. The October 2012 SAR concluded that the increasing TDS, chloride, and sulfate concentrations were due to the proximity of that well to the nitrate/chloride plume." DWMRC notes that monitoring well MW-31 is located at the southeast corner of the White Mesa Mill Tailings Cell 2, and may be impacted by the nitrate/chloride site plume. EFR has argued that the increases do not appear to be due to impacts from tailings solution as evidences by other indicator parameter relative stabilization (uranium and fluoride) and that the trends were noted according to previous background studies. EFR proposes to include studies to determine if the MW-31 exceedances are due to fluctuating background concentrations, including: geochemical analysis, mass balance analysis (using tailings solution concentrations), and a pH analysis. If the concentrations are determined to be due to background influences then EFR will propose changes to the modified GWCL's. If the concentrations cannot be attributed to background fluctuations then EFR will propose further analysis to determine the source and extent of the potential contamination. EFR agrees to prepare an SAR report which will follow the format of previously submitted SARs and will include information related to all studies performed. EFR agrees to submit the SAR to the Director within 90 days after approval of the EFR Plan. Based on DWMRC review of the EFR Plan it is recommended that the plan be approved in order to address the GWCL exceedances at monitoring well MW-31. It appears that the EFR Plan is consistent with past approved actions to address GWCL exceedances. 15. Conclusions and Recommendations Based on DWMRC staff review of the above listed documents, it was noted that the requirements of the Permit appear to have been met by EFR and the data collected during the 1st Quarter of 2015 appear to be reliable. It is recommended that a correspondence letter be sent to EFR with the following items: 1. Close-out regarding DWMRC review of the EFR May 12,2015, 1st Quarter 2015 White Mesa Uranium Mill Groundwater Monitoring Report based on findings as summarized above. 2. Close-out regarding DWMRC review of the EFR May 6, 2015 Notice. 3. Approval of the EFR May 7, 2015 request to return two wells/parameters to baseline monitoring frequency. 4. Approval of the EFR May 19, 2015 EFR plan to submit an SAR for parameters exceeding GWCL's at monitoring well MW-31 (selenium, sulfate, TDS, field pH) to the Director within 90 days of approval of the plan. EFR Is Quarter 2015 Groundwater Monitoring Report DWMRC Review Memo Page 15 16. References 1 Energy Fuels Resources (USA) Inc., May 12, 2015, Is' Quarter2015 Groundwater Monitoring Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill. 2 Energy Fuels Resources (USA) Inc., May 6, 2015, State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a). 3 Energy Fuels Resources (USA) Inc., May 7,2015, State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status 4EnergyFuels Resources (USA) Inc., May 19, 2015, Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004 Part I.G.4(c) White Mesa Mill 5 Energy Fuels Resources (USA) Inc., June 6, 2012, White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan (QAP), Revision 7.2. 6INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah. 7 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah. 8 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results, Interpretations and Recommendations for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa Uranium Mill located near Blanding Utah. Prepared by University of Utah Department of Geology and Geophysics. 9 Utah Department of Environmental Quality, August 24, 2012, Utah Ground Water Discharge Permit, Permit No. UGW370004 issuedfor the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill.