DRC-2014-008181 - 0901a068805459a6

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State of Utah
GARY R. HERBERT
Governor
Spencer J. Cox
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
Phil Goble
Dean Henderson ^/tj //f~
May 12, 2014
Review of the 2nd Quarter, 3rd Quarter and 4th Quarter 2014 Nitrate Monitoring Report for
the Nitrate Contamination Investigation, Energy Fuels Resources (USA) Inc. ("EFR")
White Mesa Uranium Mill, near Blanding, Utah
The Utah Division of Radiation Control ("DRC") has reviewed the August 18, 2014, White Mesa
Uranium Mill 2nd Quarter 2014 Nitrate Monitoring Report ("2nd QTR 14"), November 11, 2014 White Mesa
Uranium Mill 3rd Quarter 2014 Nitrate Monitoring Report ("3rd QTR 14") and February 25, 2014 White
Mesa Uranium Mill 4th Quarter 2014 Nitrate Monitoring Report ("4lh QTR 14") for the Nitrate
Contamination Investigation.
For the review of this Report the following regulatory enforcement documents were used:
Corrective Action Plan for Nitrate White Mesa Uranium Mill near Blanding, Utah, May 7, 2012,
("CAP")
• The EFR Quality Assurance Plan, June 7, 2012, Revision. 7.2 ("QAP")
REVIEW
Monitor Well Sampling for the 2nd Quarter, 3rd Quarter and 4th Quarter 2014
In each quarter the following monitor wells were sampled and analyzed for inorganic chloride and nitrate +
nitrite (as N) as required in the CAP:
Monitor wells TWN-1, TWN-2, TWN-3, TWN-4, TWN-7, TWN-18, TW4-22, TWN-24, and TWN-25,
and Piezometer 1, Piezometer 2, and Piezometer 3.
In each quarter the monitoring wells were purged using the three approved QAP well purging strategies
and meet QAP requirements for each strategy:
1. Purging two casing volumes with stable field parameters for specific conductivity,
turbidity, pH, redox potential, and water temperature (within 10% RPD):
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www. deq. Utah, gov
Printed on 100% recycled paper
Page 2
Wells: TWN-1, TWN-4, and TWN-18.
2. Purging a well to dryness and stability of field parameters for pH, specific conductivity, and
water temperature only after recovery:
Wells: TWN-3 and TWN-7
3. Continuously Pumped Wells that are considered sufficiently evacuated to immediately collect
a sample:
Wells: TW4-22, TW4-24, and TW4-25
Chloride and nitrate + nitrite (as N) were analyzed for methods consistent with the requirements of the
QAP.
QAQC
Holding Times
The method holding times for each quarter and parameter for samples collected at each monitor well were
received and analyzed within the required holding times in the QAP.
Receipt Temperature
In each quarter all samples were received within the required QAP temperature limit of 6° C.
Detection Limits
In each quarter all sample sets for each were measured and reported to the required QAP reporting limits.
Sample Duplicates
One duplicate sample was collected for each quarter. All duplicate samples analytical results for the
sample/duplicate pairs were within the 20% acceptance limits as required in the QAP (see Table 2 below).
Groundwater Head Monitoring for 2nd Quarter, 3rd Quarter and 4th Quarter 2014
Depth to groundwater was measured in the following wells and/or piezometers as required in Part I.E.3 of
the Pennit:
• The quarterly groundwater compliance monitoring wells.
• Existing monitoring well MW-4 and all of the temporary chloroform investigation
wells.
• Piezometers P-l, P-2, P-3, P-4 and P-5.
• MW-20, MW-22 and MW-34
• Nitrate monitoring wells.
• The DR piezometers which were installed during the Southwest Hydrologic
Investigation.
• In addition to the above, depth to water measurements are routinely observed in conjunction with
sampling events for all wells sampled during quarterly and accelerated efforts, regardless of the
sampling purpose.
All well levels used for groundwater contour mapping were measured and recorded within 5 calendar days
of each other.
Page 3
Estimation of Pumped Nitrate Mass Removal
The 2nd QTR 14 reported an estimate of 102 lbs. of nitrate was removed from the chloroform pumping wells
(MW-4, MW-26, TW4-4, TW4-19, and TW4-20) and the nitrate pumping wells (TWN-2, TW4-22, TW4-
24, and TW4-25). Of the 102 lbs. removed approximately 92 lbs. or 90%, was removed by the nitrate
pumping wells. In the attached Table 3, the DRC shows calculations that verify these reported estimates.
The 3rd QTR 14 reported an estimate of 93 lbs. of nitrate was removed from the chloroform pumping wells
(MW-4, MW-26, TW4-4, TW4-19, and TW4-20) and the nitrate pumping wells (TWN-2, TW4-22, TW4-
24, and TW4-25). Of the 93 lbs. removed approximately 82 lbs. or 88%, was removed by the nitrate
pumping wells. In the Attached Table 3, the DRC shows calculations that verify these reported estimates.
The 4lh QTR 14 reported an estimate of approximately 109 lbs. of nitrate was removed from the chloroform
pumping wells (MW-4, MW-26, TW4-4, TW4-19, and TW4-20) and the nitrate pumping wells (TWN-2,
TW4-22, TW4-24, and TW4-25). Ofthe 109 lbs. removed approximately 93 lbs. or 85%, was removed by
the nitrate pumping wells. In the attached Table 3, the DRC shows calculations that verify these reported
estimates.
Reporting
Each Report included the following information as required in the CAP:
a) Introduction
b) Sampling and Monitoring Plan:
i. Description of monitor wells sampled;
ii. Description of sampling methodology, equipment and decontamination
procedures;
iii. Identification of all quality assurance samples, e.g. equipment blanks
duplicate samples, etc.
c) Data Interpretation:
i. Interpretation of groundwater levels, gradients, and flow directions. The interpretation will
include a discussion on: 1) current site groundwater contour map, 2) hydrographs to show
groundwater elevation in each monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in data table that includes historic
groundwater level data for each well, 4) calculations documenting quarterly nitrate mass
removed by pumping;
ii. Interpretation of all analytical results for each well including a discussion on: 1) a current
nitrate isoconcentration map, 2) graphs showing nitrate concentration trends in each well
through time and, analytical results for each well summarized in data table that includes
historic analytical results for each well; and
iii. An electronic copy of all laboratory results for groundwater quality monitoring conducted
during the quarter will be provided to the Executive Secretary.
d) Conclusions and Recommendations
e) Copies of EFR field reports, laboratory reports, and chain of custody forms. The nitrate plume is
defined to include any monitoring well that has concentration of nitrate in excess of 10 mg/L.
Page 4
Field pH Measurements
The 2nd QTR 14, 3rd QTR 14, and 4th QTR 14 reports had field pH measurements recorded on the field data
worksheets for piezometer P1EZ-3 of 11.70, 12.30, and 11.56 respectively witch exceeds the Utah pH
GWQS (6.5-8.5) [see table 4]. On Further review of the previous nitrate monitoring reports, from lsl
quarter 2010 to 1st quarter 2014 also had field pH measurements recorded that exceeded the Utah GWQS
that ranged from 11.12 to 12.49.
On May 18, 2015 in a conference call with both the DRC and EFR to discuss the concern for the field pH
measurements at PIEZ-3 exceeding Utah GWQS. To help identify possible cause for these pH
measurements it was agreed that EFR would sample PIEZ-3 for contaminants listed in Table 2 (with the
exception of gross alpha) of EFRs ground water discharge pennit (UGW370004) in June 2015 during the
2nd Quarter 2015 nitrate monitoring event. In addition, it was agreed that as soon as EFR gets the
analytical results for PIEZ-3 they will send them to DRC for evaluation. Thereafter, a conference call will
be held between DRC and EFR to discuss a plan to resolve the pH measurements at PIEZ-3 exceeding
GWQS.
Conclusions on Compliance with the CAP, QAP
Per the DRC review it appears that the 2"d QTR 14, 3rd QTR 14, and 4,h QTR 14 reports complies with the
CAP and QAP. Therefore, a letter will be drafted for the Director Signature, notifying EFR of the review
and closing-out of these reports.
Page 5
References
Energy Fuels Resources (USA) Inc., June 7, 2012, White Mesa Uranium Mill, Ground Water Monitoring
Quality Assurance Plan (Revision 7.2).
HYDRO GEO CHEM, INC, May 7, 2012, Corrective Action Plan for Nitrate White Mesa Uranium
Mill near Blanding, Utah
Table 1 of 1
Historic Nitrate, Nitrate + Nitrite and Cloride Concentrations
Nitrate Contamination Investigation
White Mesa Uranium Mill Denision Mines Corp.
Monitoring Event Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l) Monitoring Event
TWN-2 (Pumping well starting in
January 2013)
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/17/2010
2nd Qtr 5/26/2010
3rd Qtr 9/27/2010
4th Qtr 12/7/2010
1st Qtr 1/26/2011
2nd Qtr 4/20/2011
3rd Qtr 7/26/2011
4th Qtr 10/17/2011
1st Qtr 1/9/2012
2nd Qtr 4/18/2012
3rd Qtr 7/24/2012
4th Qtr 10/17/2012
1st Qtr 2/18/2013
2nd Qtr 4/23/2013
3rd Qtr 8/27/2013
4th Qtr 10/16/2013
1st Qtr 1/14/2014
2nd Qtr 5/6/2014
3rd Qtr 8/5/2014
4th Qtr 10/8/2014
05
06
06
0 6
0 5'
05
0 5
0 5
0 6
06
0 6
0 43
Nitrate
0 68
0 84
1 24
161
147
1 63
1 7
1 46
17
20
19
14
17
19
14
10
15
17
17
17 5
1st Qtr 3/24/2010
2nd Qtr 6/2/2010
3rd Qtr 9/29/2010
4th Qtr 12/9/2010
1st Qtr 2/1/2011
2nd Qtr 4/28/2011
3rd Qtr 7/28/2011
4th Qtr 10/20/2011
1st Qtr 1/12/2012
2nd Qtr 4/20/2012
3rd Qtr 7/31/2012
4th Qtr 7/17/2012
.62.1
69
69
48
31
48
54
22.10
Pumping System Started in January 2013
17 6
174
24 1
26 8
29 2
31 1
28
27 6
1st Qtr 2/19/2013
2nd Qtr 4/24/2013
3rd Qtr 8/27/2013
4th Qtr 7/16/2013
1st Qtr 1/13/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
4th Qtr 10/8/2014
57.3
57.7
80.0
111
42 6
44.7
42.0
71
85
97
104
93
93
85
74
76
86
103
93
79
80 5
82 1
75 9
70 4
72 4
84 9
80
81
Monitoring Event Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l) Monitoring Event Nitrate, Nitrate ^
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/25/2010
2nd Qtr 6/3/2010
3rd Qtr 7/16/2010
4th Qtr 12/10/2010
1st Qtr 2/1/2011
2nd Qtr 4/28/2011
3rd Qtr 7/29/2011
4th Qtr 10/20/2011
1st Qtr 1/12/2012
2nd Qtr 4/20/2012
3rd Qtr 7/31/2012
4th Qtr 10/17/2012
1st Qtr 2/19/2013
2nd Qtr 4/24/2013
3rd Qtr 8/28/2013
4th Qtr 10/17/2013
1st Qtr 1/15/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
4th Qtr 10/9/2014
253
26
27
24
24
26
25
25
25
24
27
12.1
Nitrate
22.2
27.2
20.9
23.5
19.6
23.6
19.5
19.1
111
118
106
117
138
128
134
129
143
152
158
149
1st Qtr 3/16/2010
2nd Qtr 5/27/2010
3rd Qtr 9/27/2010
4th Qtr 12/8/2010
1st Qtr 1/25/2011
2nd Qtr 4/20/2011
3rd Qtr 7/26/2011
4th Qtr 10/18/2011
1st Qtr 1/9/2012
2nd Qtr 4/18/2012
3rd Qtr 7/25/2012
4th Qtr 7/15/2012
Pumping System Started in January 2013
157
158
171
163
160
168
174
153
1st Qtr 2/18/2013
2nd Qtr 4/23/2013
3rd Qtr 8/27/2013
4th Qtr 7/16/2013
1st Qtr 1/14/2014
2nd Qtr 5/6/2014
3rd Qtr 8/5/2014
4th Qtr 10/8/2014
09
1 0
09
1 0
09
09
1 1
09
0 9
1 1
1 4
1 45
1 5
1 63
1 6
1 69
1 4
16
2 0
1 44
22
22
19
21
21
21
35
20
20
24
25
26 4
25 3
24 4
27 2
29 4
28 4,
29 6
28
30 7
Monitoring Event Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l) Monitoring Event Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/16/2010
2nd Qtr 5/26/2010
3rd Qtr 7/12/2010
4th Qtr 12/7/2010
1st Qtr 1/25/2011
2nd Qtr 4/20/2011
3rd Qtr 7/26/2011
4th Qtr 10/17/2011
1st Qtr 1/9/2012
2nd Qtr 4/18/2012
3rd Qtr 7/24/2012
4th Qtr 10/15/2012
1st Qtr 2013
2nd Qtr 2013
0 3
0 3
0 3
0 3
"04
0 3
03
0 3
0 2
0 3
0 3
<0 1
NA
NA
43
44
43
45
47
44
44
45^
45
39
48
43 5
TWN-5 abandoned on July 31, 2013
1st Qtr 3/23/2010
2nd Qtr 6/1/2010
3rd Qtr 7/13/2010
4th Qtr 12/7/2010
1st Qtr 1/26/2011
2nd Qtr 4/20/2011
3rd Qtr 7/27/2011
4th Qtr 10/18/2011
1st Qtr 1/10/2012
2nd Qtr 4/18/2012
3rd Qtr 7/25/2012
4th Qtr 7/15/2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2013
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2014
1 5
1 4
1 4
1 2
1 1
1 5
1 1
1 4
1 2
1 1
1 4
0 78
19
22
73
21
18
22
17
21
20
22
22
20 4
NA
NA
NA
NA
NA
NA
NA
NA
Shaded = Nitrate, Nitrate + Nitrite concentrations greater than the Ground Water Quality Standard of 10 mg/l
NA = Per the CAP and SCO, these wells not sampled 2013
Table 1 of 2
Historic Nitrate, Nitrate + Nitrite and Clorlde Concentrations
Nitrate Contamination Investigation
White Mesa Uranium Mill Denision Mines Corp
Monitoring Event
TWN-7
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l) Monitoring Event Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/17/2010
2nd Qtr 5/28/2010
3rd Qtr 7/14/2010
4th Qtr 12/10/2010
1st Qtr 1/27/2011
2nd Qtr 4/21/2011
3rd Qtr 7/29/2011
4th Qtr 10/19/2011
1st Qtr 1/11/2012
2nd Qtr 4/20/2012
3rd Qtr 7/26/2012
4th Qtr 10/16/2012
1st Qtr 2/19/2013
2nd Qtr 4/24/2013
3rd Qtr 8/28/2013
4th Qtr 10/16/2013
1st Qtr 1/15/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
4th Qtr 10/9/2014
08
1 2
1 8
1
1 3
1 7
0 7
2 2
2 3
1 2
09
0 64
Nitrate
0 59
1 16
0 835
0986
0 882
0 564
09
0 968
6
6
7
4
6
6
5
6
5
6
6
5 67
1st Qtr 3/16/2010
2nd Qtr 5/26/2010
3rd Qtr 7/12/2010
4th Qtr 12/7/2010
1st Qtr 1/25/2011
2nd Qtr 4/19/2011
3rd Qtr 7/26/2011
4th Qtr 10/17/2011
1st Qtr 1/9/2012
2nd Qtr 4/18/2012
3rd Qtr 7/24/2012
4th Qtr 7/15/2012
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
<0 1
11
11
11
9
13
10
18
10
11
15
11
11 4
Pumping System Started in January 2013
5 68
5
6 96
5 7
5 75
5 26
6
5 93
1st Qtr 2013
2nd Qtr 2013
NA
NA
TWN-8 abandoned on July 31, 2013
Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/23/2010
2nd Qtr 6/1/2010
3rd Qtr 7/15/2010
4th Qtr 12/9/2010
1st Qtr 2/1/2011
2nd Qtr 4/28/2011
3rd Qtr 7/29/2011
4th Qtr 10/20/2011
1st Qtr 1/12/2012
2nd Qtr 4/20/2012
3rd Qtr 7/31/2012
4th Qtr 10/17/2012
1st Qtr 2013
2nd Qtr 2013
76
77
10.7
8 0
9 5
10.0
.11.0
10.9
12.2
10.6
123
12.5
183
175
210
172
217
192
208
134
202
209
215
194
1st Qtr 3/23/2010
2nd Qtr 6/2/2010
3rd Qtr 7/14/2010
4th Qtr 12/8/2010
1st Qtr 1/26/2011
2nd Qtr 4/21/2011
3rd Qtr 7/27/2011
4th Qtr 10/18/2011
1st Qtr 1/10/2012
2nd Qtr 4/19/2012
3rd Qtr 7/25/2012
4th Qtr 7/16/2012
1st Qtr 2013
2nd Qtr 2013
1 5
1 0
02
1 3
0 3
1 2
0 1
0 2
08
09
06
0 12
54
30
21
28
40
28
28
33
44
28
33
30 8
TWN-9 abandoned on July 31, 2013 TWN-10 abandoned on July 31, 2013
Monitoring Event Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l) Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/17/2010
2nd Qtr 6/1/2010
3rd Qtr9/27/2010
4th Qtr 12/8/2010
1st Qtr 1/27/2011
2nd Qtr 4/26/2011
3rd Qtr 7/27/2011
4th Qtr 10/17/2011
1st Qtr 1/10/2011
2nd Qtr 4/19/2012
3rd Qtr 7/25/2012
4th Qtr 10/16/2012
1st Qtr 2013
2nd Qtr 2013
1 4
1 3
1 4
14
1 4
1 4
0 1
16
1 6
1 6
18
1 84
73
72
76
72
84
76
76
76
69
71
77
76 4
1st Qtr 3/17/2010
2nd Qtr5/26/2010
3rd Qtr 7/12/2010
4th Qtr 12/7/2010
1st Qtr 1/26/2011
2nd Qtr 4/26/2011
3rd Qtr 7/26/2011
4th Qtr 10/17/2011
1st Qtr 1/10/2012
2nd Qtr 4/18/2012
3rd Qtr 7/25/2012
4th Qtr 7/16/2012
1st Qtr 2013
2nd Qtr 2013
0 7
08
07
0 7
4 2
1 0
0 6
1 2
09
1 2
14
1 41
113
106
112
103
87
109
102
87
104
106
102
101
TWN-11 abandoned on July 31, 2013 TWN-12 abandoned on July 31, 2013
Shaded = Nitrate, Nitrate + Nitrite concentrations greater than the Ground Water Qualitv Standard of 10 mg/l
NA = Per the CAP and SCO, these wells not sampled 2013
Table 1 of 3
Historic Nitrate, Nitrate + Nitrite and Cloride Concentrations
Nitrate Contamination Investigation
White Mesa Uranium Mill Dentslon Mines Corp.
Monitoring Event TWN-13
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/17/2010
2nd Qtr 5/26/2010
3rd Qtr 9/27/2010
4th Qtr 12/7/2010
1st Qtr 1/25/2011
2nd Qtr 4/26/2011
3rd Qtr 7/26/2011
4th Qtr 10/17/2011
1st Qtr 1/9/2012
2nd Qtr 4/18/2012
3rd Qtr 7/24/2012
4th Qtr 10/15/2012
1st Qtr 2013
2nd Qtr 2013
0 1
0 2
04
1 6
<0 1
<0 1
<0 1
<0 1
NA
NA
47
49
53
57
103
49
49
48
46
53
48
47 3
TWN-13 abandoned on July 31, 2013
1st Qtr 3/24/2010
2nd Qtr 6/2/2010
3rd Qtr 7/15/2010
4th Qtr12/10/2010
1st Qtr 1/28/2011
2nd Qtr 4/27/2011
3rd Qtr 7/29/2011
4th Qtr10/19/2011
1st Qtr 1/11/2012
2nd Qtr 4/20/2012
3rd Qtr 7/27/2012
4th Qtr 7/17/2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2013
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2014
29
2 9
35
4 2
3 7
3 5
35
3 9
3 5
34
3 7
4 03
24
30
26
28
24
30
25
27
26
27
27
27 4
NA
NA
NA
NA
NA
NA
NA
NA
Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event
Nitrate, Nitrate H
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/18/2010
2nd Qtr 5/28/2010
3rd Qtr 7/13/2010
4th Qtr 12/9/2010
1st Qtr 1/27/2011
2nd Qtr 4/27/2011
3rd Qtr 7/28/2011
4th Qtr 10/19/2011
1st Qtr 1/11/2012
2nd Qtr 4/20/2012
3rd Qtr 7/26/2012
4th Qtr 10/17/2012
1st Qtr 2013
2nd Qtr 2013
0 7
1 0
1 0
1 2
1 4
16
1 6
1 3
1 5
1 6
2 1
1 79
TWN-15 abandoned on July 31, 2013
1st Qtr 3/17/2010
2nd Qtr 5/27/2010
3rd Qtr 9/27/2010
4th Qtr 12/9/2010
1st Qtr 1/27/2011
2nd Qtr 4/27/2011
3rd Qtr 7/27/2011
4th Qtr10/18/2011
1st Qtr 1/10/2012
2nd Qtr 4/19/2012
3rd Qtr 7/25/2012
4th Qtr 7/16/2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2013
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2013
1 2
1 3
2 6
2
4 6
1 6
2 4
2 6
2 8
2 0
2 4
2 50
35
35
35
30
34
39
31
34
33
50
33
32 1
NA
NA
NA
NA
NA
NA
NA
NA
Monitoring Event
Nitrate, Nitrate + Chloride (mg/l)
Monitoring Event
Nitrate, Nitrate + Chloride (mg/l)
1st Qtr 3/24/2010
2nd Qtr 6/3/2010
3rd Qtr 7/15/2010
4th Qtr 12/10/2010
1st Qtr 2/1/2011
2nd Qtr 4/28/2011
3rd Qtr 7/29/2011
4th Qtr 10/20/2011
1st Qtr 1/12/2012
2nd Qtr 4/20/2012
3rd Qtr 7/27/2012
4th Qtr 10/17/2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
10.4
11
89
8
8 6
9
8 5
8 1
8 7
9 1
95
9 65
Nitrate Pumping
TWN-17 abandoned on July 31, 2013
78 1st Qtr 3/17/2010 1 6
87 2nd Qtr 6/1/2010 18
66 3rd Qtr 9/27/2010 1 8
65 4th Qtr 12/9/2010 1 6
90 1st Qtr 1/27/2011 1 4
81 2nd Qtr 4/26/2011 1 8
74 3rd Qtr 7/28/2011 1 8
71 4th Qtr 10/18/2011 1 9
79 1st Qtr 1/10/2012 1 9
80 2nd Qtr 4/19/2012 2 1
85 3rd Qtr 7/26/2012 2 3
84 8 4th Qtr 7/16/2012 [ 195
System Started in JanuaryJ013
1st Qtr 2/18/2013 2 27
2nd Qtr 4/23/2013 2 32
3rd Qtr 8/27/2013 2 04
4th Qtr 10/16/2013 2 15
lstQtr/14/2014 2 33
2nd Qtr 5/6/2014 2 18
3rd Qtr 8/5/2014 1 8
4th Qtr 10/8/2014 147
42
63
64
59
61
67
65
60
64
64
67
67 5
68 7
64 3
70 4
67 3
684
76 5
70
74 8
Shaded = Nitrate, Nitrate + Nitrite concentrations greater than the Ground Water Quality Standard of 10 mg/l
NA = Per the CAP and SCO. these wells not sampled 2013
Table 1 of 4
Historic Nitrate, Nitrate + Nitrite and Clonde Concentrations
Nitrate Contamination Investigation
White Mesa Uranium Mill Oenlsion Mines Corp.
Monitoring Event TWN-19
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event Upper Wildlife Pond (UMIP)
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/23/2010
2nd Qtr 6/1/2010
3rd Qtr 9/27/2010
4th Qtr 12/9/2010
1st Qtr 2/1/2011
2nd Qtr 4/28/2011
3rd Qtr 7/28/2011
4th Qtr 10/18/2011
1st Qtr 1/10/2012
2nd Qtr 4/1.9/2012
3rd Qtr 7/26/2012
4th Qtr 10/16/2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2012
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2014
NA
NA
NA
NA
NA
NA
NA
NA
72
6 2
7 2
70
70
69
7 1
6 5
70
68
75
77
118
113
113
107
114'
120
113
108
114
117
117
118
1st Qtr 3/18/2010
2nd Qtr 6/2/2010
3rd Qtr 7/19/2010
4th Qtr 12/10/2010
1st Qtr 1/31/2011
2nd Qtr 4/25/2011
3rd Qtr 7/25/2011
4th Qtr 10/19/2011
1st Qtr 1/31/2012
2nd Qtr 2012
3rd Qtr 2012
4th Qtr 2012
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2012
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2014
<0 1
CO 1
cO 1
<0 1
<0 1
<0 1
<0 1
NS
NS
NS
NA
NA
NA
NA
NA
NA
NA
NA
clO
<10
<10
<10
clO
clO
Monitoring Event Piezometer 1
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event Piezometer 2
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 2010
2nd Qtr 6/2/2010
3rd Qtr 7/19/2010
4th Qtr 12/10/2010
1st Qtr 1/31/2011
2nd Qtr 4/25/2011
3rd Qtr 7/25/2011
4th Qtr 10/19/2011
1st Qtr 1/11/2012
1st Qtr 1/10/2012
2nd Qtr 4/20/2012
3rd Qtr 7/27/2012
4th Qtr 10/17/2012
1st Qtr 2/19/2013
2nd Qtr 4/24/2013
3rd Qtr 8/28/2013
4th Qtr 10/16/2013
1st Qtr 1/13/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
|4th Qtr 10/8/2014
72
68
6 5
7
68
/
6 6
7 1
70
66
7 2
7 66
52
52
60
60
58
53
55
78
114
58
56
55
1st Qtr 2010
2nd Qtr 6/2/2010
3rd Qtr 7/19/2010
4th Qtr12/10/10
1st Qtr 1/31/2011
2nd Qtr 4/25/2011
3rd Qtr //25/2011
4th Qtr10/19/2011
1st Qtr 1/11/2012
1st Qtr 1/31/2012
2nd Qtr 4/20/2012
3rd Qtr 7/27/2012
4th Qtr 7/17/2012
Nitrate Pumping System Started in January 2013
8 11
8 88
7 83
6 68
6 79
7 57
5 1
5 75
56 7
53 3
55 1
54 1
56 2
52 1
55
57 6
1st Qtr 2/19/2013
2nd Qtr 4/24/2013
3rd Qtr 8/28/2013
4th Qtr10/16/2013
1st Qtr 1/13/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
4th Qtr 10/8/2014
06
06
02
03
03
0 1
0 1
0 1
0 1
0 2
0 2
0 19
0 22
0 172
0 198
0 36
0 169
0 736
08
0 755
9
1
8
9
9 5
9 67
10 3
9 66
9 22
11 4
11 4
12
12 2
Monitoring Event
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event
Nitrate, Nitrate **
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 3/24/2010
2nd Qtr 6/2/2010
3rd Qtr 7/19/2010
4th Qtr 12/9/2010
1st Qtr 1/31/2011
2nd Qtr 4/25/2011
3rd Qtr 7/25/2011
4th Qtr 10/19/2011
1st Qtr 1/11/2012
2nd Qtr 4/20/2012
3rd Qtr 7/27/2012
4th Qtr 10/17/2012
1st Qtr 2/24/2013
2nd Qtr 4/24/2013
3rd Qtr 8/28/2013
4th Qtr 10/16/2013
1st Qtr 1/13/2014
2nd Qtr 5/7/2014
3rd Qtr 8/6/2014
4th Qtr 10/8/2014
1 7
1 6
1 8
1 8
1 8
1 7
18
1 7
1 8
1 7
18
2 75
Nitrate
185
183
1 81
18
1 7
1 79
1 7
1 74
116
36
35
25
40
35
61
12
20
53
21
20 1
1st Qtr 2010
2nd Qtr 2010
3rd Qtr 2010
4th Qtr 2010
1st Qtr 1/31/2011
2nd Qtr 2011
3rd Qtr 2011
4th Qtr 2011
1st Qtr 2012
2nd Qtr 2012
3rd Qtr 2012
4th Qtr 2012
Pumping System Started in January 2013
21
21 2
22 4
23 5
26
23 9
26
28 3
1st Qtr 2013
2nd Qtr 2013
3rd Qtr 2013
4th Qtr 2013
1st Qtr 2014
2nd Qtr 2014
3rd Qtr 2014
4th Qtr 2014
NA
NA
NA
NA
NA
NA
NA
NA
NS = Not sampled
NA = Per the CAP and SCO, these wells not sampled 2013
Table 1 of 5
Historic Nitrate, Nitrate + Nitrite and Cloride Concentrations
Nitrate Contamination Investigation
White Mesa Uranium Mill Denision Mines Corp
Monitoring Event TW4-22 (Pumping well starting in
Nitrate, Nitrate +
Nitrite (mg/l)
Chloride (mg/l)
Monitoring Event TW4-24 (Pumpin ; well stating in
Nitrate, Nitrate H
Nitrite (mg/l)
Chloride (mg/l)
1st Qtr 2/11/2013
2nd Qtr 6/5/2013
3rd Qtr 9/3/2013
4th Qtr 10/29/2013
1st Qtr 1/27/2014
2nd Qtr 5/19/2014
3rd Qtr 8/11/2014
4th Qtr 10/21/2014
54.6
635
586
487
501
598
614
540
596
1st Qtr 2/11/2013
2nd Qtr 6/5/2013
3rd Qtr 9/3/2013
4th Qtr 10/3/2013
1st Qtr 1/27/2014
2nd Qtr 5/19/2014
3rd Qtr 8/11/2014
4th Qtr10/21/2014
, 35.9
23.7
32.6
34,6
Win-. > sis
33
31.5
3S.7
596
916
998
1,030
809
1,020
1,150
1,050
Monitoring Event TW4-25 (Pumpin
Nitrate, Nitrate +
Nitrite (mg/l)
1st Qtr 2/11/2013
2nd Qtr 6/5/2013
3rd Qtr 9/3/2013
4th Qtr 10/29/2013
1st Qtr 1/27/2014
2nd Qtr 5/19/2014
3rd Qtr 8/11/2014
4th Qtr 10/21/2014
9
5 24
5 69
6 1
2 16
1 21
1 6
1 03
well starting in
Chloride (mg/l)
190
136
119
88 6
85 7
51 1
67
58 1
Shaded = Nitrate. Nitrate + Nitrite concentrations greater than the Ground Water Quality Standard of 10 mg/l
Table 2
Summary of QA/QC Duplicate Sample
2nd Quarter 2014
Parameter GWQS Duplicate of TWN-4
TWN-4 TWN-65 RPD
Nitrate + Nitrite (as N)
Chloride
10 mg/L
none
1.55
29.6
1.54
26.6
0.6
10.7
3rd Quarter 2014
Parameter GWQS Duplicate of TWN-1
TWN-4 TWN-65 RPD
Nitrate + Njtrite (as N)
Chloride
lOmg/L
none
1.7
28
1.4
28
19.4
0.0
4th Quarter 2014
Parameter GWQS Duplicate of TWN-18
TWN-4 TWN-65 RPD
Nitrate + Nitrite (as N)
Chloride
10 mg/L
none
1.47
74.8
L47
72.3
0.0
3.4
Tabel 3
DRC Nitrate Mass Removal Calculations
Energy Fuels Resorses Inc. White Mesa Mill, Bland, Utah
2nd Quarter 2014
Data Discretions Chloroform Pumping Wells
MW4 MW-26 TW4-4 TW4-19 TW4-20
Nitrate Pumping Wells
TWN-2 TW4-22 TW4-24 TW4-25
Nitrate (mg/L)
Nitrate (g/L)
Nitrate (Ibs/L)
Nitrate (lbs/gal)
Total gallons pumped
lbs of nitrate removed
Gallons of nitrate removed
4 1
4 10E-03
9 06E-06
3 43E-05
71,935
2 5
0 20
0 9
9 00E-04
1 99E-06
7 53E-06
23,758
02
0 01
5 9
5 90E-03
1 30E-05
4 93E-05
60,235
30
0 24
1 3
1 30E-03
2 87E-06
1 09E-05
297,660
32
0 26
6 0
5 95E-03
1 31E-05
4 98E-05
18,462
09
0 07
44 7
4 47E-02
9 88E-05
3 74E-04
47,612
178
1 45
47 2
4 72E-02
1 04E-04
3 95E-04
24,194
9 5
0 78
35 0
3 50E-02
7 73E-05
2 93E-04
216,984
63 5
5 17
1 2
1 21E-03
2 67E-06
1 01E-05
145,829
1 5
0 12
Total lbs of nitrate removed from chloroform pumping wells
Total gallons of nitrate removed chloroform pumping wells
98
08
Total lbs of nitrate removed from nitrate pumping wells
Total gallons of nitrate removed nitrate pumping wells
92 3
7 5
(Total lbs nitrate removed from all pumping wells
(Total gallons of nitrate removed from all pumping wells
|% lbs of nitrate removed by nitrate pumping wells
102.1
83
90 4
3rd Quarter 2014
Data Discriptions Chloroform Pumping Wells
MW4 MW-26 TW4-4 TW4-19 TW4-20
Nitrate Pumping Wells
TWN-2 TW4-22 TW4-24 TW4-25
Nitrate (mg/L)
Nitrate (g/L)
Nitrate (Ibs/L)
Nitrate (lbs/gal)
Total gallons pumped
lbs of nitrate removed
Gallons of nitrate removed
3 7
3 70E-03
8 17E-06
3 09E-05
74,788
2 3
0 19
07
7 00E-04
1 55E-06
5 85E-06
24,062
0 1
0 01
53
5 30E-03
1 17E-05
4 43E-05
69,229
3 1
0 25
1 6
1 60E-03
3 54E-06
1 34E-05
309,742
4 1
0 34
4 30
4 30E-03
9 50E-06
3 60E-05
17,238
06
0 05
42 0
4 20E-02
9 28E-05
3 51E-04
46,927
16 5
1 34
41 5
4 15E-02
9 17E-05
3 47E-04
24,611
8 5
0 69
31 5
3 15E-02
6 96E-05
2 63E-04
213,653
56 3
4 58
1 6
1 60E-03
3 54E-06
1 34E-05
119,664
1 6
0 13
Total lbs of nitrate removed from chloroform pumping wells
Total gallons of nitrate removed chloroform pumping wells
10 3
0 8
Total lbs of nitrate removed from nitrate pumping wells
Total gallons of nitrate removed nitrate pumping wells
82 9
6 7
Total lbs nitrate removed from all pumping wells
Total gallons of nitrate removed from all pumping wells
% lbs of nitrate removed by nitrate pumping wells
93.2
76
89 0
4th Quarter 2014
Data Discriptions
MW4
Chloroform Pumping Wells
MW-26 TW4-4 TW4-19 TW4-20
Nitrate Pumping Wells
TWN-2 TW4-22 TW4-24 TW4-25
Nitrate (mg/L)
Nitrate (g/L)
Nitrate (Ibs/L)
Nitrate (lbs/gal)
Total gallons pumped
lbs of nitrate removed
Gallons of nitrate removed
5 1
5 07E-03
1 12E-05
4 24E-05
63,093
27
0 22
09
9 34E-04
2 06E-06
7 81E-06
21,876
02
0 01
70
7 02E-03
1 55E-05
5 87E-05
64,423
38
0 31
4 7
4 72E-03
1 04E-05
3 95E-05
198,331
7 8
0 64
7 7
7 67E-03
1 69E-05
6 41E-05
16,342
1 0
0 09
70 6
7 06E-02
1 56E-04
5 90E-04
47,586
28 1
2 29
54 9
5 49E-02
1 21E-04
4 59E-04
23,957
11 0
0 89
35 7
3 57E-02
7 89E-05
2 99E-04
178,469
53 3
4 34
1 0
1 03E-03
2 28E-06
8 61E-06
107,416
09
0 08
Total lbs of nitrate removed from chloroform pumping wells
Total gallons of nitrate removed chloroform pumping wells
15 5
1 3
Total lbs of nitrate removed from nitrate pumping wells
Total gallons of nitrate removed nitrate pumping wells
93 3
76
Total lbs nitrate removed from all pumping wells
Total gallons of nitrate removed from all pumping wells
% lbs of nitrate removed by nitrate pumping wells
108.8
89
85 8
Tabel 4
Field pH at Nitrate Investigation Piezometers, Monitoring Wells, and Pumping Wells
Energy Fuels Resorses Inc. White Mesa Mill, Bland, Utah
Well Location
1st 2014
Stable Field pH Measurements
2nd 2014 3rd 2014 4th 2014
PIEZ-1
PIEZ-2
PIEZ-3
TWN-1"
TWN-2
TWN-3
TWN-4
TWN-7
TWN-18
TW4-22
TW4-24
TW4-25
9.18
7.05
11.42
7.31
6.40
6.95
7.06
6.59
6.76
6.60
6.37
6.71
9.47
7.37
11.70
7.25
6.84
7.03
7.17
7.01
7.00
6.70
6.59
6.83
9.02
8.02
12.30
7.47
7.00
7.45
7.24
7.52
7.02
6.82
6.80
6.83
8.40
6.94
11.56
6.94
6.30
6.83
6.73
7.35
6.47
6.40
6.35
6.35
Shaded pH measurements out of compliance with Utah GWQS (6.5-8.5)
Red highlighted pH measurement are above 9.00