DRC-2015-001367 - 0901a068804f3533

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ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
February 5, 2015
VIA PDF AND OVERNIGHT DELIVERY
Rusty Lundberg,
Director, Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
DRC-2015-001367
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a)
Dear Mr. Lundberg:
The White Mesa Mill (the "Mill") performed fourth quarter ("Q4") groundwater monitoring during the
period from October l, to December 31, 2014 under the August 24, 2012 version of the Mill's
Groundwater Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs
were received during the period ending December 31, 2014.
Pursuant to Part I.G.I.a) of the GWDP, (August 24, 2012) please take notice that the concentrations of
specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this
quarter in the attached Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been
formatted to simplify the tracking of any continued exceedances from one monitoring period to the next
by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in
color and bold italics).
Part I.G. 1 c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to
the Executive Secretary a plan and a time schedule for assessment of the sources, extent and potential
dispersion of the contamination, and an evaluation of potential remedial action to restore and maintain
groundwater quality to ensure that Permit limits will not be exceeded at the compliance monitoring point
and that DMT or BAT will be reestablished." The summary below relating to Q4 2014 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
Radiation Control ("DRC") Staff. A description of the other actions and reports which have affected the
requirement to submit a plan and time schedule are as follows:
1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing
investigations at the Mill. Based on the results of the previous investigations, EFRI and the
Director acknowledge that it has not been possible to date to determine the source(s), cause(s),
attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride
in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate
+ nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the
activities associated with the CAP are on-going. Based on information provided by DRC in
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 2
teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30-
day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances
at this time.
2. As discussed in previous quarterly groundwater sampling reports, the background levels and
GWCLs for pH were established based on eight or more quarters of laboratory data, which are
historically higher than field data. EFRI's letter to the Director dated January 31, 2011 proposed
the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by
EFRI's geochemical consultant, INTERA, Inc., EFRI compared the Mill's groundwater pH data
from Q2 2011 and noted that all of the June 2011 groundwater results, and many of the other
results from Q2 2011, were already outside the revised GWCLs that were to be proposed in the
June 30, 2011 letter. Pursuant to teleconferences with DRC on December 5, and December 19,
2011, EFRI submitted a Work Plan and Schedule on January 20, 2012 and a revised plan based
on DRC comments on April 13, 2012. Based on the approved Work Plan and Time Schedule,
EFRI and DRC entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. The
SCA required the completion of the pH Report and the Pyrite Investigation and associated report.
The pH Report and Pyrite Investigation Report were submitted November 9, 2012 and December
7, 2012 respectively. By letter dated April 25, 2013, DRC accepted the conclusions that the out-
of-compliance results for pH are due to background effects within the aquifer matrix and are not
caused by Mill activities. DRC also approved the recalculation of the GWCLs. As a result, the
30-day plan and schedule for assessment is not required for field pH exceedances.
3. A Plan and Time Schedule will not be prepared for monitoring wells with two successive
exceedances in Q3 2014 if successive exceedances were reported in a previous quarter and were
included in the Source Assessment Reports ("SARs"), submitted October 10, 2012, May 8, 2013,
August 30, 2013, December 17, 2013, January 13, 2014, and March 19, 2014. A Plan and Time
Schedule will not be submitted for those constituents covered by the previously mentioned SARs,
because the conclusions and actions delineated in those reports were either accepted by DRC as
documented in DRC correspondence dated April 25, 2013, July 23, 2013, September 17, 2013
January 7, 2014, March 10, 2014, and June 5, 2014 respectively.
4. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program
and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective
Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket
No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and
methylene chloride exceedances is not required.
It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to
reflect background groundwater quality, as defined by the mean plus second standard deviation
concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each
monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that,
because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-
impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the
time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not
necessarily represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a
given analyte will increase the number of exceedances due to statistical variation and not due to Mill
activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a
monthly frequency can result in resampling of essentially the same water and can lead to repeat
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 3
exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same
water.
1.0 Exceedances in Required Quarterly Sampling Wells
1.1 Quarterly Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods in Q4 2014. A 30-day plan and schedule contemplated in Part I.G.I c)
of the GWDP will not be required for the consecutive exceedances below for the reasons stated below.
One-time exceedances and non-successive exceedances are noted on Table 1, but not listed below.
Consecutive exceedances which occurred in previous reporting periods are discussed in the SARs
submitted to DRC October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13,
2014, and March 19, 2014 and the Plan and Time Schedule submitted December 4, 2014.
MW-14
• Field pH has been slightly outside (slightly lower than) the GWCL for all of the Q4 2014
sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports
submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012
report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC'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-25
• Field pH has been slightly outside (slightly lower than) the GWCL for all of the Q4 2014
sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports
submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012
report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC'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 ti me as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
MW-26
• Nitrate + nitrite has exceeded its GWCL in the October monthly and the Q4 2014 sampling
events. As mentioned above, a CAP has been submitted and approved and the specified actions
are currently being implemented; therefore a plan to address this consecutive exceedance is not
necessary and is not being submitted.
• Chloroform has exceeded its GWCL for all of the Q4 2014 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.
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 4
• Methylene chloride has exceeded its GWCL for the Q4 2014 and December monthly sampling
events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is
expected to yield increased concentrations of methylene chloride. Because this well is used in the
chloroform capture program which is the subject of separate investigations and actions, a plan
and time schedule to address the consecutive exceedances is not necessary and is not being
submitted.
MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January
20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for
chloroform removal, concentrations of all constituents in that well are subject to potential variation over
time as a result of the pumping activity. This will be taken into account by the Executive Secretary in
determining compliance for this well." Based on information provided by DRC 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.
• The uranium concentration exceeded its GWCL in all of the monitoring periods for Q4 2014.
This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the
SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
• Field pH has been slightly outside (slightly lower than) the GWCL for the Q4 2014 and
December monthly sampling events. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-30
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2014 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL all of the Q4 2014 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 Q4 2014 sampling events. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 5
become effective upon their publication in the next revision of the GWDP. As a result of DRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs
become effective, the exceedances will continue to be noted and reported.
MW-31
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2014 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL in all of the monitoring periods for Q4 2014. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore a plan to address this consecutive exceedance is
not necessary and is not being submitted.
• The sulfate concentration exceeded its GWCL in all of the monitoring periods for Q4 2014. This
consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR,
the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC'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 selenium concentration exceeded its GWCL in all of the monitoring periods for Q4 2014.
This consecutive exceedance is addressed in the SAR, dated August 30 2013. As a result of the
SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of DRC'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 Total Dissolved Solids ("TDS") concentration exceeded its GWCL in all of the Q4 2014
sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-35
• The manganese concentration exceeded the GWCL in all of the Q4 2014 sampling events. A plan
and schedule to address this exceedance is not necessary and is not being submitted because the
exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of
the Groundwater Quality Standards. Background has been established for MW-35 in the
Background Report submitted to DRC on May 1, 2014. As a result of the Background Report,
the GWCLs have been calculated and accepted by DRC in a letter dated July 15, 2014. The
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 6
calculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported. It
should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily
represent impacts to groundwater from Mill activities.
• The uranium concentration exceeded the GWCL in MW-35 in all of the Q4 2014 sampling
events. A plan and schedule to address this exceedance is not necessary and is not being
submitted because the exceedances are based on the interim GWCLs for MW-35, which have
been set at a fraction of the Groundwater Quality Standards. Background has been established
for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the
Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July
15, 2014. The calculated GWCLs will become effective upon their publication in the next
revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and
schedule to address this consecutive exceedance is not necessary and will not be submitted. Until
such time as the new GWCLs become effective, the exceedances will continue to be noted and
reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not
necessarily represent impacts to groundwater from Mill activities.
• The selenium concentration exceeded the GWCL in MW-35 in the Q3 2014 and October monthly
sampling events. A plan and schedule to address this exceedance is not necessary and is not being
submitted because the exceedances are based on the interim GWCLs for MW-35, which have
been set at a fraction of the Groundwater Quality Standards. Background has been established
for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the
Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July
15, 2014. The calculated GWCLs will become effective upon their publication in the next
revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and
schedule to address this consecutive exceedance is not necessary and will not be submitted. Until
such time as the new GWCLs become effective, the exceedances will continue to be noted and
reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not
necessarily represent impacts to groundwater from Mill activities.
• The gross alpha minus Rn and U ("gross alpha") concentration exceeded the GWCL in MW-35 in
all of the Q4 2014 sampling events. A plan and schedule to address this exceedance is not
necessary and is not being submitted because the exceedances are based on the interim GWCLs
for MW-35, which have been set at a fraction of the Groundwater Quality Standards.
Background has been established for MW-35 in the Background Report submitted to DRC on
May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and
accepted by DRC in a letter dated July 15, 2014. The calculated GWCLs will become effective
upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the
calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported. It should be noted that the exceedances of the interim
GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities.
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 7
1.2 Quarterly Wells with New Exceedances Reported in Q4
Two new exceedances for the Q4 2014 quarterly well sampling program are listed below. These
exceedances will result in an accelerated sampling frequency from quarterly to monthly. The wells listed
below will only be sampled during the monthly events for those constituents that exceeded their GWCLs.
The wells listed below will be sampled for all constituents listed in the GWDP during the quarterly events
as that is the regularly scheduled sampling for the quarterly wells. Accelerated monthly monitoring of the
constituents will begin on or before the March 2015 monthly sampling event pursuant to the requirements
described below.
• Ammonia in MW-30 was slightly above the GWCL in the Q4 (November) sampling event.
• Field pH in MW-30 was slightly below the GWCL in the Q4 2014 (November) sampling event.
Relative to accelerated reporting requirements, based on phone conversations with DRC on April 5, 2010,
reporting of exceedances is required to be completed within 30 days of receipt of the last data package for
a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the month
following the submission of the Exceedance Notice for a specified quarter for wells that are being
accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice
for wells that are being accelerated from semiannually to quarterly. Per teleconferences with DRC, EFRI
proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DRC concurrence
with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 teleconference.
2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly
2.1 Semi-annual Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods (Q3 2014 and Q4 2014).
MW-3
• Fluoride has exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• Selenium has exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 8
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-3A
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-12
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-15
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-18
• Thallium has exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012.
In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells
(MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In
correspondence dated April 25, 2013, DRC noted "DRC agrees with the justification provided by
EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has
recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan
and schedule is not necessary because the exceedance is not caused by Mill activities and was
previously discussed in the October 10, 2012 SAR. Until such time as the GWCLs are removed,
the exceedances will continue to be noted and reported.
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 9
MW-19
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. Consecutive
exceedances are also addressed in the SAR, dated October 10, 2012. In the October 10, 2012
SAR, EFRI requested the removal of GWCLs for the far upgradient wells (MW-1, MW-18, and
MW-19) at the Mill which cannot be impacted by Mill activities. In correspondence dated April
25, 2013, DRC noted "DRC agrees with the justification provided by EFR, that far upgradient
wells are not likely to be impacted by current Mill activities..." and has recommended the
removal of GWCLs for MW-18 from the next revision of the GWDP. A plan and schedule is not
necessary because the exceedance is not caused by Mill activities and was previously discussed in
the October 10, 2012 SAR. Until such time as the GWCLs are removed, the exceedances will
continue to be noted and reported.
MW-24
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
MW-27
• Nitrate + Nitrite have exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event and during previous quarters. As mentioned above, a CAP has been submitted and
approved and the specified actions are currently being implemented; therefore a plan to address
this consecutive exceedance is not necessary and is not being submitted.
• The chloride concentration exceeded its GWCL for both the Q3 2014 sampling event and the Q4
2014 sampling event and during previous quarters. As mentioned above, a CAP has been
submitted and approved to address nitrate+nitrite contamination which is expected to address
chloride in groundwater. The actions specified in the CAP are currently being implemented;
therefore a plan to address this consecutive exceedance is not necessary and is not being
submitted.
MW-28
• Chloride has exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event and during previous quarters. As mentioned above, a CAP has been submitted and
approved and the specified actions are currently being implemented; therefore a plan to address
this consecutive exceedance is not necessary and is not being submitted.
• Uranium has exceeded the GWCL for both the Q3 2014 sampling event and the Q4 2014
sampling event. This consecutive exceedance is addressed in the Plan and Time Schedule, dated
December 4, 2014. As a result of the Plan and Time Schedule, additional data will be collected
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 10
through Ql 2015 and an assessment of the necessity for further actions will be determined at that
time. As a result of DRC's acceptance of the Plan and Time Schedule, no additional actions for
this consecutive exceedance are necessary at this time. Until the completion of the additional
data, the exceedances will continue to be noted and reported.
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-29
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC'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-32
• Field pH has been slightly outside (slightly lower than) the GWCL for both the Q3 2014 sampling
event and the Q4 2014 sampling event. As mentioned above, site-wide pH issues and trends are
addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the
November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The
recalculated GWCLs will become effective upon their publication in the next revision of the
GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to
address this consecutive exceedance is not necessary and will not be submitted. Until such time as
the new GWCLs become effective, the exceedances will continue to be noted and reported.
2.1 Semi-annual Wells with New Exceedances Reported in Q4
Two new exceedances for the Q4 2014 semi-annual well sampling program are listed below. These
exceedances will result in an accelerated sampling frequency from semi-annually to quarterly. It is
important to note that the wells listed below will only be sampled during the first and third quarterly
events for the constituents which exceeded their GWCL. The wells listed below will be sampled for all
constituents listed in the GWDP during the second and fourth quarterly events as that is the regularly
scheduled sampling for the semi-annual wells.
• Sulfate in MW-24 was above the GWCL in the Q4 sampling event.
• Selenium in MW-12 was above the GWCL in the Q4 sampling event.
Relative to accelerated reporting requirements, based on phone conversations with UDEQ on April 5,
2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data
package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the
Letter to Mr. Rusty Lundberg
February 5, 2015
Page 11
month following the submission of the Exceedance Notice for a specified quarter for wells that are being
accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice
for wells that are being accelerated from semiannually to quarterly. Per teleconferences with UDEQ,
EFRI proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DRC
concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012
teleconference.
Yours truly
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David Frydenlund
Harold Roberts
David Turk
Dan Hillsten
Scott Bakken
I
— Ql 2010 Results Q2 2010 Results
TjdJe^GWCLExceedfMicesft^
Q3 2010 Results Q4 2010 Results
Monitoring Well
(Water Class)
Constituent Exceeding
GWCL
GWCL in
August 24, 2012
GWDP
Ql 2010 Sample
Date
Ql 2010
Result
Q2 2010
Sample Date
Q2 2010
Result
May 2010
Monthly
Sample Date
May 2010
Monthly
Result
June 2010
Monthly
Sample Date
June 2010
Monthly
Result
July 2010
Monthly
Sample Date
July 2010
Monthly
Result
August 2010
Monthly
Sample Date
August 2010
Monthly Result
Q3 2010
Sample Date
Q3 2010
Result
October 2010
Monthly
Sample Date
October 2010
Monthly
Result
Q4 2010
Sample Date
Q4 2010
Result
December 2010
Monthly Sample
Date
December 2010
Monthly Result
MW-11 (Class II) Manganese (ug/L) 131.29 134
Required Quarterly Sampling Wells
138 141 133 12/15/10
MW-14 (Class III) Field pH (S.U.) 6.45 4/21/2010 6.29 5/21/2010 6.36 6/16/2010 6.45 7/20/2010 7.19 8/25/2010 6.48 9/8/2010 6.51 6.60 6.37 12/15/2010
Field pH (S.U.) 6.5 - 8.5 6.53 7.2 NA NA NA NA 6.58 6.36
MW-25 (Class III) Cadmium (ug/L) 1.5 2/3/2010 4/28/2010 NS NS NS 9/8/2010 1.4 11/10/2010 NS
Uranium (ug/L) 6.5 5.93 6.43 NA NA 5.89
NA
Nitrate + Nitrite (as N)
(mg/L) 0.62 1.3 0.3 0.4 0.6 o.d 0.2
Uranium (ug/L) 37.4 36.6 34.4 71.8
Chloroform (ug/L) 70 700 1700 800 940 900 2800 2100 1000 1900
Chloride (mg/L) 58.31 72 80 47
MW-26 (Class III) Carbon Tetrachloride
(ug/L)
2/2/2010 4/22/2010 5/21/2010 6/16/2010 7/21/2010 8/16/2010 9/26/2010 10/20/2010 11/15/2010 12/15/2010
Field pH (S.U.) 6.74 - 8.5 6.59 6.36 6.45 6.39 6.60 6.61 6.49
Dichloromethane
(Methylene Chloride)
(ug/L)
45 5.5 16
0.4
29.6
1400
52
6.45
Nitrate + Nitrite (as N)
(mg/L) 15.8 15.3 7/21/2010 8/24/2010 16
Chloride (mg/L) NS NS
Uranium (ug/L) 8.32 6.82 6.82 NS NS
MW-30 (Class II) 2/9/2010 4/27/2010 5/21/2010 6/15/2010
Field pH (S.U.) 6.50 6.81 6.55 6.62 7,47 7/21/2010
7/27/2010 6.80 (6.82) 8/24/2010 6.73
9/14/2010
9/21/2010
7.10 NA 6.64
10/19/2010 11/9/2010 12/14/2010
6.80 (6.84) 6.77 6.75
Ammonia (mg/L)
Selenium (ug/L) 34 35.3 35.6
NA
6.65
30.5
Nitrate + Nitrite (as N)
(mg/L) 21.7 22.5 5/21/2010 23 6/15/2010 21.1 7/21/2010 20 8/24/2010 22 21 10/19/2010 20 20
TDS (mg/L) 1150 1220 NS NS NS NA NS NA 1330 NS NA 1320
MW-31 (Class III) Chloride (mg/L) 143 2/9/2010 128 4/20/2010 I2S NS NA NS NA NS NS
Selenium (ug/L) 60.8 59.6 NS NS
9/13/2010
(9/21/10)
139 NS 11/9/2010 138 12/14/2010
60
Field pH (S.U.) 6.5 - 8.5 6.96 7.66(7.13)
Sulfate (mg/L) 532 507 539
20
NS
NS
6.95
NS
Manganese (ug/L) 200
Thallium (ug/1) 0.5 NA NA NA 1.14
MW-35 (Class II) Gross Alpha minus Rn &
U (pCi/L) 3.75 NS NS NS NS NS
Selenium (ug/L) 12.5 NA
ranium (ue/l. 27.2
NA
NA
Required Semi-Annual Sampling Wells
MW-01 (Class 1
Manganese (ug/L)
Tetrahydrofuran (ug/L)
Field pH (S.U.)
Sulfate (mg/L)
289
1 1.5
6.77 - 8.5
838
NA
5/5/2010 ) (6.87) NS
NA
NS
NA
NS NS NS
275
11/18/2010 NS
NA
Selenium (ug/L) 37 NA 37.2 38.8
Field pH (S.U.) 6.5 - 8.5 NA 6.14 (6.25) NA 6.39 6.35
MW-03 (Class III) Sulfate (mg/L) 3663 NS 5/3/2010 3490 NS NA 3430
Nitrate + Nitrite (as N)
(mg/L) 0.73 NA 0.3
Fluoride (Mg/L) 0.71 0.63 9.77
NA
NA
Field pH (S.U.) 6.5 - 8.5 6.23 (6.24) NA NA 6.42 6.21
MW-3A (Class III)
Sulfate (mg/L) 3640 3680 NA NA 3850
Nitrate + Nitrite (as N)
(mg/L) 1.3 1.0 NA 9/21/2010 NS 11/22/2010 NS
TDS (mg/L) 5805 5860 NA NA NA 5330
Selenium (ug/L) 89 NS 94.8
NA
NA
NA
NA
MW-05 (Class II) Uranium lug/L) 7.5 11.6
MW-12 (Class III) Selenium (ug/L) 25 25.7 NA NA NS 9/20/2010
31.9
NS 1/19/2010
27.6
Field pH (S.U.: 6.5 - 8.5 NS 6.47
MW-15 (Class III) Selenium (ug/L) 128.7
Field pH (S.U.) 6.62-NS 4/21/2010 loo
6.98 NS NA NS NS 6.57 NA
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I Ql 2012 Results 1 Q2 2012 Results Q3 2012 Results Q4 2012 Results 1
Monitoring Well
(Water Class)
Constituent
Exceeding GWCL
GWCL in
Current
GWDP
January 2012
Monthly
Sample Date
January 2012
Monthly
Result
Ql 2012
Sample Date
Ql 2012
Result
March 2012
Monthly
Sample Date
March
2012
Monthly
Result
April 2012
Monthly
Sample Date
April 2012
Monthly
Result
Q2 2012
Sample
Date
Q2 2012
Result
June 2012
Monthly
Sample
Date
June 2012
Monthly
Result
Q3 2012
Sample
Date
Q3 2012
Result
August
2012
Monthly
Sample
Date
August
2012
Monthly
Result
September
2012
Monthly
Sample
Date
September
2012
Monthly
Result
October
2012
Monthly
Sample Date
October
2012
Monthly
Result
Q4 2012
Sample Date
Q4 2012
Result
December
2012
Monthly
Sample Date
December
2012
Monthly
Result
Required Semi-Annual Sampling Wells, continued
MW-18 (Class III)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
1.95
1938.9
6.25-8.5
3198.77
NA
2/27/2012
1920
3230
NA
NS
NA
NA
4/30/2012
3.5/
1790
6.59
3280
7/18/2012
3.73
1900
6.64
3220
NS
NA
NS NS 11/26/2012
3.2
1210
6.51
NS
NA
Field pH (S.U.) 6.78-8.5 NA 6.83 6.86 6.71
MW-19 (Class III) Gross Alpha minus
Rn & U (pCi/L) 2.36 NS NS 4.86
Nitrate + Nitrite (as
N) (mg/L) 3.9 3.7 3.96
MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 2/20/2012 6.61 NS NA NS NA 5/16/2012 NS 7/17/2012 7.10 NS NS NS NA 12/5/2012 6.61 NS NA
Cadmium (ug/L) 2.25 2.01 4.7
Fluoride (mg/L) 0.36 NA NA NA 0.14 NA NA NA NA NA 0.558
MW-24 (Class ni) Sulfate (mg/L) 2903 NA
Thallium (ug/L)
2/23/2012 NS NS NA 5/10/2012 2490 NS 7/18/2012
1.36
NS NS NS 11/29/2012
Field pH (S.U.I 6.03 6.21 6.45 6.01
NS
NA
NA
Nitrate + Nitrite (as
N) (mg/L) 5.6 6.4 NA 6.2 6.7 NA NA 6.9
MW-27 (Class III) Chloride (mg/L) 45 NA 46 NA 47 NA NA NA 44.2
Sulfate (mg/L) 462 NS NA 2/28/2012 446
TDS (mg/L) 1075 1140 1170 1150
Gross Alpha minus
Rn & U (pCi/L) 2.3 NA 0.8 NA 1.2 NA NA 1.33
Chloride (mg/L) 105 109 NA 114 NA 7/16/2012 105 115
Cadmium (ug/L) 5.2
MW-28 (Class III) Uranium (ug/L) NS NA 5/8/2012 3.44 NA NS NA NS NA NA 11/14/2012 3.45
Vanadium (ug/L) 30
Field pH (S.U.) 6.1-8.5 NA 7/16/2012
8/1/2012
6.38
am 5.98
NS
TDS (mg/L) 4400 NA 4600 8/1/2012 4420 4430
MW-29 (Class III) Field pH (S.U.) 6.46 - 8.5 NS 2/22/2012 7.12 NS NS 5/8/2012 6.47 NS 7/16/2012
8/1/2012
6.68
(6.45)
NS NS NS 11/14/2012
MW-32 (Class III)
Gross Alpha minus
Rn & U (pCi/L) 3.33 NA 1.8
NS 2/21/2012 NS
Field pH (S.U.) 6.4 - 8.5 6.23
Notes:
GWCL values are taken from August 24, 2012 version of
GWDP.
NS = Not Required and Not Sampled
NR = Required and
NA = Not
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
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Ql 2013 Results Q2 2013 Results Q3 2013 Results Q4 2013 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in Current
GWDP
January 2013
Monthly
Sample Date
January
2013
Monthly
Result
Ql 2013
Sample
Date
Ql 2013
Result
March
2013
Monthly
Sample
Date
March 2013
Monthly
Result
April 2013
Monthly
Sample Date
April 2013
Monthly
Result
Q2 2013
Sample
Date
Q2 2013
Result
June 2013
Monthly
Sample
Date
June 2013
Monthly
Result
Q3 2013
Sample
Date
Q3 2013
Result
August
2013
Monthly
Sample
Date
August
2013
Monthly
Result
September
2013
Monthly
Sample
Date
September
2013
Monthly
Result
October
2013
Monthly
Sample
Date
October
2013
Monthly
Result
Q4 2013
Sample Date
Q4 2013
Result
December
2013 Monthly
Sample Date
December
2013 Monthly
Result
Required Semi-Annual Sampling Wells, continued
Thallium (ug/1)
MW-18 (Class
ni) Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
1938.9
6.25-8.5
3198.77
NS 2/25/2013
3.26
6.35
3350
NS
NA
NS 5/20/2013
2.81
1860
3160
NA
7/15/2013
3.32
1860
6.45
3170
NS
NA
NA
NA
12/3/2013
3.06
2000
6.38
3240
NS
NA
Field pH (S.U.) 6.78-8.5 6.50 7.16 NA 6.9 1 NA 6.58
MW-19 (Class
III) Gross Alpha minus Rn &
U (pCi/L) 2.36 5/20/2013 NS 7/15/2013 NS NS 12/3/2013
Nitrate + Nitrite (as N)
(mg/L) 2.83 3.61 NA 4.21 3.66 NA 3.70
MW-23 (Class
III) Field pH (S.U.) 6.5 - 8.5 NS NA 3/11/2013 6.37 NS NS 5/23/2013 7/18/2013 6.61 NS NA NS 12/18/2013 7.21 NS NA
Cadmium (ug/L) 2.5 2.0 NA 6.72
MW-24 (Class
III)
Fluoride (mg/L) 0.36 0.355 0.211 NA 0.288 NA 0.310
Sulfate (mg/L) 2903 NA
Thallium (ug/L)
3/13/2013 5/22/2013 2070
0.618
NS 7/19/2013
1.64
NS NS NA
NA
NS NA 12/12/2013 2490
Field pH (S.U.) 6.5 - 8.5 6.29 6.11 5.80 6.08
NS
NA
NA
NA
NA
NA
Nitrate + Nitrite (as N)
(mg/L) 5.6 NA 7.94 7.09 NA 6.97 NA NA 7.89
MW-27 (Class
m)
Chloride (mg/L) 38 50.3 44.3 NA 44.2 NA 45.0
Sulfate (mg/L) 462 NS NA 5/21/2013 497 NS NS NA
TDS (mg/L) 1075 1140 1110 1110 NA 1100
Gross Alpha minus Rn I
U (pCi/L) <1.0 1.57 NA <1.00 1.2S
NA
NA
Chloride (mg/L) 105 NA 110 102 107 NA 109
Cadmium (ug/L)
MW-28 (Class
III)
Uranium (ug/L) 4.9 NA 3/5/2013 NA NS NS 3.58 7/17/2013 NA NS 3.34
Vanadium (ug/L) 30 <I5.0
Field pH (S.U.) 6.1-8.5 6.00 6.63 5.97 NA 6.10
NA
NA
MW-29 (Class
III)
TDS (mg/L) 4400 4599 4340 NA
Field pH (S.U.! 6.46 - 8.5 NS NA 3/6/2013 6.36 NS 5/23/2013 NS NA 7/17/2013 6.37 NS NA 11/20/2013 6.35 NS
MW-32 (Class
111)
Gross Alpha minus Rn &
U (pCi/L) 3.33 5.92 J.72 6.46 NA 1.86
NS 5/13/2013 NS NS
Field pH (S.U.) 6.4-8.5 NA 6.39 6.29
Notes:
GWCL values are taken from August 24, 2012 version of GWDP.
NS = Not Required and Not Sampled
NR = Required
NA = Not
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.
Table 1 - GWCL Exceedances for Fourth Quarter 2014 under the August 24, 2012 GWDP
Ql 2014 Results Q2 2014 Results Q3 2014 Results Q4 2014 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in August
24, 2012 GWDP
January 2014
Monthly
Sample Date
January
2014
Monthly
Result
February
2014
Monthly
Sample
Date
February
2014
Monthly
Result
Ql 2014
Sample
Date
Ql 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q2 2014
Sample
Date
Q2 2014
Result
July 2014
Monthly
Sample
Date
July 2014
Monthly
Result
August
2014
Monthly
Sample
Date
August
2014
Monthly
Result
Q3 2014
Sample
Date
Q3 2014
Result
October
2014
Monthly
Sample
Date
October
2014
Monthly
Result
Q4 2014
Sample Date
Q4 2014
Result
December
2014 Monthly
Sample Date
December
2014 Monthly
Result
Sample
Frequency
Required Quarterly Sampling Wells
MW-11 (Class
II) Manganese (ug/L) 2/24/2014 163 3/1 1/2014 134 4/25/2014 136 6/3/2014 166 139 139 157 186 Quarterly
MW-14 (Class
III) Field pH (S.U.) 6.5 - 8.5 1/8/2014 6.60 2/24/2014 6.16 3/11/2014 6.33 6.44 6.41 6.46 6.25 Quarterly
MW-25 (Class
III)
Field pH (S.U.) 6.5 - 8.5 6.37 6.27 6.74 6.36 6.49 6.31 6.36
Cadmium (ug/L) 1/7/2014 2/13/2014 3/10/2014 1.29 1.51 6/2/2014 1.24 1.30 8/18/2014 1.30 1.30 10/6/2014 11/4/2014 1.57 12/9/2014
Uranium (ug/L) 6.5 NA 5.83 6.26 10.6
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
(mg/L) 0.62 2.42 2.12 1.30 1.20 1.64 2.0 1.00 1.10
Uranium (ug/L) 41.8 81.7 72.2 51.8 96.0 90.6 75.0 86.5 74.4 48.4 42.5
Chloroform (ug/L) 70 1580 2810 2800 1580 2330 2200 1580 894 1520 2280
Chloride (mg/L) 58.31 69.7 70.4 61.0 62.1 61.0 63.2 80.0 59.0 68.0
MW-26 (Class
III)
Carbon Tetrachloride
(ug/L)
1/8/2014 6.86 4/30/2014 NA 5/14/2014 <1.0 6/5/2014 <1.0 7/29/2014 <1.0 8/20/2014 <1.0 9/4/2014 <1.0 10/7/2014 11/18/2014 <1.0
12/10/14
12/15/14 <1.0
Field pH (S.U.) 6.74 - 8.5 6.50 7 19 7.13 6.78 6.60 7.28 6.67 6.85 6.09 6.25 (6.44)
Dichloromethane
(Methylene Chloride)
(ug/L)
25.8 15.5 5.54 10.2 6.73 9.6 43.3 10.9 7.34 28.4
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
< mg/l.) 2.5 20.3 18.4 21.3 17.9 19.4 15.6 13.8 11.0 16.2
Chloride (mg/L) 128 131 135
MW-30 (Class
II)
Uranium (ug/L) 8.32 7.84 6 S4 9.82 7.35 7.40 7.60 7.70 7.76 7.65
1/8/2014 2/25/2014 3/11/2014 5/14/2014 8/20/2014 9/9/2014 10/7/2014 11/10/2014 12/10/2014
Field pH (S.U.) 6.50 6.74 6.56 7.06 6.89 6.76 6.82 6.92 6.22
Ammonia (mg/L) 0.30
Selenium (ug/L) 34 35.6 35.8 38.0 32.8 37.0 35.4 42.9 48.5 53.6 38.9 36.8
138
7.67
6.77
37.5
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Nitrate + Nitrite (as N)
(mg/L) 24.0 20.6 26.2 19.1 23.3 23.1 19.0 15.2 18.9 15.9 20.9
MW-31 (Class
III)
TDS (mg/L) 1320 1510 1460 1440 1400 1410 1420 1520
Chloride (mg/L) 143 1/7/2014 194 197 230 4/28/2014 230 5/13/2014 200 6/2/2014 773 7/28/2014 200 8/18/2014 210 9/3/2014 210 10/6/2014 205 11/14/2014 204 12/9/2014
Selenium (ug/L) 75.S 77.2 85.4 74.5 69.4 77.P 82.8 81.5 78.9 73.0
Field pH (S.U.) 6.5 - 8.5 6.45 6.53
Sulfate (mg/L) 532 558 681 639 555 600 620 560 606 639
215
71.1
687
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Manganese (ug/L) 247 204 249 202 212 228 222
Thallium (ug/1) 0.5 0.535 <0.5 0.582 0.521 <0.5 <0.5 <0.5 0.6 <0.5 <0.5
MW-35 (Class
II)
Gross Alpha minus Rn &
U (pCi/L) 1/8/2014 4.12 3.98 2/26/14 4.33 4/25/2014 6/4/2014 4.70 9/3/2014 3.93 10/6/2014 4.14 11/12/2014 3.92 12/9/2014
Selenium (ug/L) 12.5 8.95 18.6 17.0 13.9 13.2 28.9 31.4 15.5
Uranium (ug/L) 20.8 20.6 21.5 30.6 26.9 21.9 20.3 23.6 23.9 19.6
232
<0.5
4.54
20.3
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Required Semi-Annual Sampling Wells
MW-01 (Class
II)
Manganese (ug/L)
Tetrahydrofuran (ug/L)
Field pH (S.U.)
Sulfate (mg/L)
289
NS NS 2/20/2014
76.8
NS
NA
5/28/2014
82.3
909
9/10/2014
80.0
6.75
11/17/2014
920
NS
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Selenium (ug/L) 37 37.0 69.5 94.0 62.4
MW-03 (Class
III)
Field pH (S.U.) 6.5 - 8.5 6.23 6.56 6.13 6.37
Sulfate (mg/L) 3663 NA 2/26/2014 NA 5/30/2014 3460 NS NA NA 9/16/2014 3120 NS NA 3800
Nitrate + Nitrite (as N)
(mg/l.) 0.73 0.573 0.6 0.330
Fluoride (Mg/L) 0.68 NA 0.771 1.02 1.0 1.08
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Field pH (S.U.) 6.5 - 8.5 NA 6.58 6.60 NA 6.40 6.41
MW-03A (Class
111)
Sulfate (mg/L) 3640 3100 NA NA 3830 NA 3350 NA 3770
Nitrate + Nitrite (as N)
(mg/L) 1.3 NS 0.849 0.97
TDS (mg/L) 5805 NA 5600 NA NA 5790 NA 5460 NA 5370
Selenium (ug/L) 92.1 104 129
NA Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
MW-05 (Class Uranium (ug/L) 22.0 36.20 Semi-Annually
MW-12 (Class
III)
Selenium (ug/L) 25 NS NS 2/12/2014 23.7 6/4/2014 17.20 NA NA 9/16/2014 NA 33.30
Field pH (S.U.) 6.5 - 8.5 6.13 6.47 6.25
NA Semi-Annually
Semi-Annually
MW-15 (Class
III)
Selenium (ug/L) 128.7
Field pH (S.U.) 6.62 - 8.5 NA
2/25/2014 110 105
6.51
NS NA 273 106
6.38 6.41
NS Semi-Annually
Semi-Annually
Ql 2014 Results Q2 2014 Results Q3 2014 Results Q4 2014 Results
Monitoring
Well (Water
Class)
Constituent Exceeding
GWCL
GWCL in Current
GWDP
January 2014
Monthly
Sample Date
January
2014
Monthly
Result
February
2014
Monthly
Sample
Date
February
2014
Monthly
Result
Ql 2014
Sample
Date
Ql 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q2 2014
Sample
Date
Q2 2014
Result
April 2014
Monthly
Sample
Date
April 2014
Monthly
Result
May 2014
Monthly
Sample
Date
May 2014
Monthly
Result
Q3 2014
Sample
Date
Q3 2014
Result
October
2014
Monthly
Sample
Date
October
2014
Monthly
Result
Q4 2014
Sample Date
Q4 2014
Result
December
2014 Monthly
Sample Date
December
2014 Monthly
Result
Sample
Frequency
Required Semi-Annual Sampling Wells, continued
MW-18 (Class
DT)
Thallium (ug/1)
Sulfate (mg/L)
Field pH (S.U.)
TDS (mg/L)
1938.9
6.25-8.5
3198.77
NA NS
NA
2/19/2014
6.16
NS NA
NA
NA
NA
NA
5/27/2014 2020
3260
NA NS 9/9/2014 1760
6.40
NS
NA
11/10/2014 1810
6.10
2960
NA
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Field pH (S.U.) 6.78-8.5 6.29 NA NA 7.38 NA 6.46 6.33
MW-19 (Class
III) Gross Alpha minus Rn &
U (pCi/L) 2.36 NS <1.0 NS 5/27/2014 <1.0
Nitrate + Nitrite (as N)
(mg/L) 2.83 3.82 3.68 0.4 NA
Semi-Annually
Semi-Annually
Semi-Annually
MW-23 (Class
III) Field pH (S.U.) 6.5 - 8.5 NS NA 3/5/2014 6.52 NS 6/1 1/2014 6.67 NS NA NS NA 9/4/2014 6.56 NS 11/19/2014 6.69 NS NA Semi-Annually
Cadmium (ug/L) 5.92 2.91 NA
MW-24 (Class
III)
Fluoride (mg/L) 0.36 NA 0.234 0.337 NA NA 0.4 0.109
Sulfate (mg/L) 2903 NS NA
Thallium (ug/L) 1.85
NS NA 5/30/2014 2450
1.23
NS NS 11/19/2014 3120
0.821
NS
Field pH (S.U.; 5.89 6.07 5.09 5.69
NA
NA
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Nitrate + Nitrite (as N)
(mg/L) 5.6 NA NA 7.98 NA 7.35 NA NA 6.30 7.70
MW-27 (Class
III)
Chloride (mg/L) NA NA 47.9 45.9 NA NA 46.0 42.6
Sulfate (mg/L) 462 NS NA NA NS NA 5/28/2014 484 11/5/2014 419
'I DS (mg/Ll 1075 1090
Gross Alpha minus Rn &
U (pCi/L) NA I 08 2.33 1.16 <1.0
NA
NA
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Chloride (mg/L) 105 NA 113 NA NA 114 112 117
Cadmium (ug/L) 5.2
MW-2 8 (Class
III)
Uranium (ug/L) NA 2/26/2014 NS NA 6/18/2014 61.3 9/16/2014 10.6 NS 21.2
Vanadium (ug/L) 30 109
Field pH (S.U.) 6.1-8.5 6.01 5.79 5.72
NA
NA
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
Semi-Annually
MW-29 (Class TDS (mg/L) 4400 4500 4200 4210
Field pH (S.U.) 6.46 - 8.5
NS
NA
NS NS NS 6/3/2014 NS
6.10
1/10/2014
6.11
NS
Semi-Annually
Semi-Annually
MW-32 (Class
III)
Gross Alpha minus Rn £
U (pCi/L) 3.33 4.35 3.69 2.56
NS NS
Field pH (S.U.) 6.4 - 8.5 6.15 6.17 NA 6.08
Semi-Annually
Semi-Annually
Notes:
GWCL values are taken from August 24. 2012 version of
GWDP.
NS = Not Required and Not Sampled
NR = Required
NA = Not
Exceedances are shown in yellow
Values in () parentheses are the field pH measurements for the resampled analyses.