DRC-2015-008094 - 0901a0688059b1b4

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Lette
State 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. Andetson
Director
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
Phil Goble, Manager f^j^O ^/
Tom Rushing, P.G.
October 29, 2015
Review ofthe August 19,2015 Energy Fuels Resources (USA) Inc. 2nd 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, August 19, 2015 - Transmittal of 2nd Quarter 2015 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, August 14, 2015-State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G. 1(a).
3. EFR, September 10,2015 - Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part I.G.4(d) White Mesa Mill.
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 ofthe 2nd Otr. 2015 Report and Related Actions at the White
Mesa Uranium Mill:
1. The 2nd Quarter 2015 Report was received on August 24, 2015, which was before the due
date (Permit Part I.F.I - due date of September 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
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.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 2
DWMRC review of the 2nd Quarter 2015 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 2nd Quarter 2015 Report is based on current Permit
GWCLs, 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 2nd
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.
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 2nd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
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 IU water C-3 Field pH
Uranium
Chloride
4th 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
February 2010
February 2010
February 2010
February 2010
February 2010
April 2010
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
MW-30 Class II water D-2
Nitrate + Nitrite (as N)
Chloride
Selenium
Uranium
Field pH
Ammonia
February 2010
1st Quarter 2011
April 2010
4th Quarter 2011
4th Quarter 2014
4th Quarter 2014
May 2010
May 2011
July 2010
March 2014
March 2015
March 2015
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Sulfate
February 2010
1st Quarter 2011
4th Quarter 2010
May 2010
May 2011
March 2011
EFR 2" 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
TDS
Selenium
Field pH
September 2010
3rd Quarter 2012
February 2014
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
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
July 2011
July 2011
July 2011
October 2011
December 2012
August 2011
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-1 Class II water U-l
Tetrahydrofuran
Field pH
Sulfate
Chloride
4th Quarter 2012
3rd Quarter 2014
4th Quarter 2012
2nd Quarter 2015
1st Quarter 2013
1st Quarter 2015
1st Quarter 2013
1st Quarter 2016
^Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
1st Quarter 2016
1st Quarter 2016
1st Quarter 2016
MW-3 Class HI water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
Beryllium
Cadmium
Zinc
T* Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
4th Quarter 2013
2nd Quarter 2015
2nd Quarter 2015
2nd Quarter 2015
^Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2010
4th Quarter 2012
"^Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
Is* Quarter 2013
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
MW-5 Class II water D-3 Uranium 4m Quarter 2010 l51 Quarter 2011
^Quarter 2014 MW-12 Class III water D-3 Field pH
Selenium
1st Quarter 2014
4th Quarter 2014 2nd Quarter 2015
^Quarter 2012
4th Quarter 2013
3~^ Quarter 2012 MW-15 Class III water D-4A Selenium
Field pH 2nd Quarter 2014
2nd Quarter 2010
MW-18 Class HI water U-l
Thallium
Sulfate
TDS
Field pH
2nd Quarter 2010
2nd Quarter 2010
1st Quarter 2014
3™ Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2010
4th Quarter 2011
2nd Quarter 2010~
3"7aQuarter2010
1st Quarter 2012 MW-19 Class HJ water U-l Field pH
Nitrate + Nitrite as N
3^ Quarter 2010 MW-23 Class III water D-3 Field pH
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-24 Class III water D-l
Cadmium
Thallium
Field pH
Fluoride
Sulfate
2"* Quarter 2010
2M Quarter 2010
2nd Quarter 2010
4th Quarter 2012
4th Quarter 2014
^Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
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
3ra Quarter 2010
4th Quarter 2014
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2014
2^ Quarter 2014
MW-28 Class III water D-l
Field pH
Chloride
Cadmium
Uranium
Vanadium
1st Quarter 2014
2nd Quarter 2010 3rd Quarter 2010
2nd Quarter 2014 2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
MW-29 Class HI water D-2
Field pH
TDS
Sulfate
4th Quarter 2010
2nd Quarter 2012
2nd Quarter 2015
^Quarter 2010
^Quarter 2011
3rd Quarter 2012
1st Quarter 2016
MW-32 Class III water C-2
Adjusted Gross Alpha
Field pH
Chloride
2nd Quarter 2010
1st Quarter 2015
3rd Quarter 2010
3* Quarter 2010
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
second 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. 1(a), Accelerated
Monitoring Status Reports (AMSR)]. For the 2nd quarter 2015 monitoring, the AMSR was received by the
DWMRC dated August 14,2015 (received by the DWMRC on August 17,2015) and follow up Plan and
Time Schedule [Required by the Permit Part I.G.4(d)] was received dated September 10,2015 (received by
the DWMRC on September 11, 2015). The follow up Plan and Time Schedule addresses exceedances of
cadmium, zinc, beryllium and nickel in monitoring well MW-3. DRC notes that cadmium and zinc went
into OOC during the second quarter 2015, and that beryllium and nickel were included by EFR since they
are in POOC or have shown higher than normal concentrations during the quarter. Per the AMSR "As
noted above, this Plan covers the constituents (cadmium and zinc) that were identified as being in violation
of Part I.G.2 of the Permit, in the Q2 2015 Exceedance Notice, dated August 14, 2015. In addition, two
other constituents (beryllium and nickel), which have not been identified as being in violation, are being
addressed voluntarily."
Five parameters with new exceedances were noted per review of the AMSR as follows: Chloride in
monitoring well MW-1; Beryllium, Cadmium, and Zinc in monitoring well MW-3; and Sulfate in
monitoring well MW-29.
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:
EFR 2nd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
"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 2nd Quarter 2015
(including accelerated samples). Purge methods and volumes are summarized on Table G-l A of the 2nd
Quarter 2015 Monitoring Report:
Quarter
2nd Qtr. 2015"
# Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes or
Continuous Pumping Wells
48 8
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 2nd 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 2nd 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 grounawater 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.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements offield 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 submittedfor analysis."
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
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 2nd 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 4-9-15 and MW-20/MW-70 on 4-30-15) and two with the accelerated
samples (MW-35/MW-65 on 5-12-15 and MW-30/MW-65 on 6-24-15).
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 2nd Qtr. 2015
sampling event all sample results conform to the Permit requirements (within 20% RPD) with the
exception of Iron and Zinc in duplicate MW-30/MW-70 for the April 30,2015 monitoring event, Adjusted
Gross Alpha for the May 2015 accelerated monitoring event and Ammonia for the June 2015 accelerated
monitoring event.
Per the 2nd Qtr. 2015 Report:
"The duplicate results were within a 20% RPD in the quarterly samples except for iron and zinc in
duplicate pair MW-29/MW-65. The zinc results reportedfor MW-29/MW-65 were not five times greater
than the reporting limit of 10.0 and as such the deviation from the 20% RPD requirement is acceptable...
The revised procedure for duplicate results outside of acceptance limits was implementedfor the iron
results during the quarter for duplicate pair MW-29/MW-65. The corrective actions that were taken in
accordance with the QAP procedure are as follows: the QA Manager contacted the analytical laboratory
and requested a review of the raw data to assure that there were no transcription errors and the data were
accurately reported. The laboratory noted that the data were accurate and reported correctly. Reanalysis
was not completed as the samples were disposed of by the laboratory. Results of the RPD test are provided
under Tab G."
"The duplicate results were within a 20% RPD in the monthly accelerated samples except for ammonia in
duplicate pair MW-30/MW-65 in the June monthly sampling event. Both of the sample results reportedfor
MW-30/MW-65 were not five times greater than the reporting limits of 0.05 and as such the deviation from
the 20% RPD requirement is acceptable. "
EFR 2n Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
"Radiologics Counting Error and Duplicate Evaluation — Duplicate error for duplicate pair
MW-35/MW-65 in the May monthly event was above the acceptance limit specified in the QAP... The
corrective actions that were taken in accordance with the QAP procedure are as follows: the QA Manager
contacted the Analytical Laboratory and requested a review of the raw data to assure that there were no
transcription errors and the data were accurately reported. The laboratory noted that the data were
accurate and reported correctly. It was noted during data review that the laboratory used sample MW-35
for the laboratory duplicate. The laboratory duplicate RPD was also outside of the laboratory established
RPD limits. Based on 2 sparate duplicate analyses of MW-35 (the laboratory andfield), it appears that the
duplication issues are related to a matrix interference. Reanalysis was not completed because of the
suspected matrix interference issues."
5. Analytical Laboratories Used bv EFR Certified bv 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 2nd 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
Zip 29407
Country US
Phone [phone]
EFR 2nd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
Fax [phone]
Email [e-mail]
American West Analytical Laboratories Current Utah Certification
Basic Details
Name American West Analytical Laboratories
Type of Lab Commercial
TNI Lab Code TNIO1955
EPA Code UT00031
State ID 8012638686
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 Kyle Gross
Address 1 463 West 3600 South
Address 2
City Salt Lake City
State Utah
Zip 84115-
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
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 2nd Qtr. 2015 Report, it was noted that laboratory
report turnaround times (from date of EFR sample submission to the contract laboratory) for all monitoring
was approximately 30 days on average.
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 2nd
Quarter 2015, data turn-around times and EFR data review timelines appear to be reasonable/appropriate.
EFR 2n Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
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 2nd Qtr. 2015 reporting
period.
8. Sample Preservation:
Per review of the 2nd Quarter 2015 Report (Table G-3 A 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 - 2nd Quarter 2015:
QA/QC issues and DWMRC findings for the 2nd Quarter 2015 are summarized below:
Non-Conformance Summary Sell-
Identified?
EFR Corrective Action
Sumnii vs
DWMRC Findings
Laboratory reporting limits
were raised for various
samples for analysis of Ca,
Cl, 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-5A 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-25, MW-26, MW-28,
and 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-01
Potassium, MW-23
Ammonia, MW-24
Nitrate/Nitrite (as N), 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
Method blank detection
above QAP Required RL for
Zinc
None - All recoveries were
within laboratory established
acceptance limits
Nonconformity reported by
EFR and validated by the
laboratory.
Laboratory Duplicate %
Recovery Comparison
Outside of Range MW-26
Per AWAL Data Sheet: High
RPD due to suspected sample
non-homogeneity or matrix
Data was reported with a
qualifier
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
Non-Conformance Summary Self-
Identilied?
•A R orrecth Aci • •
Summary
DWM
Gross Radium Alpha interference
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 ofthe 2nd 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 2nd Quarter
2015, 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).
IUC White Mesa Mill Hydrographs: Piezometers @ North Wildlife Ponds
5.622
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 12
IUC Mite M«a Mill Hydrographs: Pt*zom*t»ra g South Vflktllfs Ponds
rW
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 2nd 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.
EFR 2n Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
12. EFR August 14.2015 Notice Pursuant to the Permit Part LG.l(a)
The EFR August 14,2015 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
("OOC") status, as updated through the 2nd 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 three new monitoring wells with single parameter exceedances of GWCL's during the 2nd
Quarter 2015 and are subject to requirements of the Permit Part I.G.I requiring commencement of
accelerated monitoring. These wells/parameters are:
1. Monitoring Well MW-l/Chloride
2. Monitoring Well MW-3/Beryllium
3. Monitoring Well MW-29/Sulfate
Per the Notice these wells parameters will be sampled on an accelerated quarterly monitoring frequency
according to DWMRC/EFR agreed upon schedules. Based on DWMRC review of the Notice it appears
that all requirements of the Permit were met.
13. EFR September 10.2015 Transmittal of Plan and Time Schedule under the Permit Part
I.G.4(c)
The EFR September 10,2015 Plan and Time Schedule ("EFR Plan") addresses exceedances of the
approved recalculated GWCL's for cadmium and zinc at monitoring well MW-3 which are in out of
compliance status per the Permit Part I.G.2 and required to undergo corrective action per the Permit Part
I.G.4. EFR additionally included an evaluation of beryllium and nickel for monitoring well MW-3 in the
EFR Plan since "these two additional constituents have either exceeded the GWCL once, as in the case of
beryllium, or have reported results approaching the GWCL, as in the case of nickel."
Per the ERF Plan part 3.1 "while the mobility in groundwater of cadmium, zinc, beryllium and nickel is
sensitive to decreases in pH, additional variability of these constituents may be due to the effects of the well
construction. Specifically, an unusual well sump and stagnant groundwater which accumulates in the
sump may be affecting the analytical results reportedfor MW-3."
"MW-3 was constructed with 9-10 feet of blank casing below the screened interval. This "sump " water
becomes stagnant between sampling events. Purging prior to sampling eliminates most of the stagnant
water present in the sump, but it is not possible to remove all water within the sump during purging.
During sampling, groundwater enters the well through the screen and mixes with the remaining stagnant
water in the sump. The mixing of fresh and stagnant water, and/or stirring up any sediment accumulating
in the sump, may be affecting the analytical results."
This was discussed with representatives of DWMRC and EFR during two conference calls. It was agreed
that it would be appropriate to verify whether the well design/construction was the potential cause of the
exceedances prior to conducting additional source investigation activities and submitting a full source
assessment plan to DWMRC for review. If the well design/construction is not found to be the cause of the
exceedances then additional investigation and/or justification of the exceedances will be prepared. EFR
additionally notes that the exceeded parameters are sensitive to pH changes in the water and will be
EFR 2n Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 14
investigated as part of the initial plan, as stated by EFR "with respect to MW-3, preliminary analysis
suggests that cadmium, zinc, beryllium and nickel increases represent impacts attributable to statistically
significant decreasing pH."
The EFR Plan states that an inert inflatable well packer will be installed below the well screen in order to
isolate the blank screen and prevent mixing of stagnant water and sediment in the sump with the
groundwater sample. EFR will use the normal purging methods listed in the facility quality assurance plan
after installation of the packer, and will collect 4 quarters of groundwater samples. The data will be
submitted to DWMRC via the scheduled quarterly groundwater monitoring reports. After receipt of the
analytical data for these samples, EFR will coordinate with DWMRC regarding a path forward.
EFR states that "the field installation of the packer will be completed within 90 days after approval of this
Plan. The quarterly sampling described above will commence the first quarter following the installation of
the packer."
Based on DWMRC review of the EFR Plan, it appears that the planned activities are as agreed upon during
the DWMRC/EFR teleconferences held during September 2015. EFR notes in the Plan conclusion that
monitoring well MW-3 is located approximately 2,000 feet downgradient from the Mill's tailings cells and,
based on measured hydraulic parameters of the Burro Canyon Aquifer and calculated groundwater velocity
(0.9 ft/yr) it is unlikely that tailings cell leakage could reach MW-3 during the 30 years that the Mill has
been in operation. It is recommended that the EFR Plan be approved with the understanding that a full
source investigation report detailing findings of the initial investigation will be required, and that additional
activities regarding the GWCL exceedances at monitoring well MW-3 may be warranted. With regards to
the EFR study whether pH is causing the increased concentrations in groundwater, DWMRC will clarify
that if this is the case, then the EFR findings need to justify the observed concentrations using solid lines of
evidence (e.g. rock/groundwater geochemical reactions). It may be appropriate for EFR to demonstrate the
potential of pH to cause the increasing dissolved metals concentrations using available data of the Burro
Canyon Fm. Mineralogy and appropriate geochemical modeling software.
14. 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 2nd 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 ofthe EFR August 19, 2015,2nd Quarter 2015 White Mesa
Uranium Mill Groundwater Monitoring Report based on findings as summarized above.
2. Close-out regarding DWMRC review of the EFR August 14, 2015 Notice.
3. Approval of the EFR September 10,2015 Plan and Time Schedule.
15. References
1 Energy Fuels Resources (USA) Inc., August 19, 2015,2nd Quarter2015 Groundwater Monitoring Report,
Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., August 14,2015, State of Utah Ground Water Discharge Permit No.
UGW370004 White Mesa Uranium Mill -Notice Pursuant to Part I.G. 1(a).
EFR 2" Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 15
3 EnergyFuels Resources (USA) Inc., September 10,2015, Transmittal of Plan and Time Schedule under
Utah Ground Water Discharge Permit UGW370004 Part I.G.4(c) White Mesa Mill
4 Energy Fuels Resources (USA) Inc., June 6, 2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 7.2.
5INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
6 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison Mines
(USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
7 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.
8 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.