DRC-2016-002301 - 0901a068805f3bdc

Department of
Environmental Quality
Alan Matheson
Executive Director
State ofUtah DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL GARY R. HERBERT
Governor Scott T. Anderson
Director
SPENCER J. COX
Lieutenant Governor
MEMORANDUM
TO: File
THROUGH: Phil Goble, Manager /1(,C /z;-J ,('
FROM: TomRushing,P.G. Jf!. 1-zrr ... Ze>t6
DA TE: January 28, 2016
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 3rd Quarter 2015 Ground Water
Monitoring Report for the White Mesa Uranium Mill
I. 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, November 18, 2015-Transmittal of 3rc1 Quarter 2015 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, November 18, 2015-State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill-Notice Pursuant to Part LG.l(a).
3. EFR, November 18, 2015-State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill -Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status.
4. EFR, December 3, 2015-Transmittal of Plan and Time Schedule under Utah Ground Water
Discharge Permit UGW370004 Part LG.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.
II. EFR November 18, 2015 3n1 Quarter 2015 Groundwater Monitoring Report
1. Checklist of Significant Findings of the 3rd Otr. 2015 Report and Related Actions at
the White Mesa Uranium Mill:
a. The 3rd Quarter 2015 Report was received on November 20, 2015, which was before
the due date (Permit Part l.F.l -due date of December 1, 2015).
b. DWMRC notes that samples were analyzed by American West Analytical
Laboratories ("AW AL") 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
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 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Pase2
the currently approved Quality Assurance Plan for the White Mesa Uranium Mill were
noted.
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 staffdiscussions: The May
25,2012 request will be included with the White Mesa Mill Ground Water Permit
Renewal. DWMRC review of the 3'd 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.
DWMRC Stipulated Consent Agreement, DocketNo. UGWI2-03 required EFRto
submit an October 70,2012 Source Assessment Report an April 13,2012 pH Report,
and a December 72,2012Pyrite 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 3'Quarter 2015 Report is based
on current Permit GWCLs, modified GWCLs are required to undergo public notice
requirements per the Uoh Administrative Code and listed in an active Permit.
Permit compliance limits for monitoring wells around the White Mesa Mill Tailings
Cell 48 (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 3'd Quarter 2015 Report data results were compared with the
interim limits or groundwater quality standards as listed in the currently active Permit.
Laboratory QA/QC flags were documented in the review period analyical data reports
from the contract laboratories. Per DWMRC review it appears that all discrepancies
were self-reported by EFR.
One compliance parameter went into accelerated monitoring frequency during the
monitoring period, as discussed below.
2. Accelerated Monitorins and POC Wells Exceedins 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.l). 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
r.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.
d.
0D'
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
Accelerated Monitoring Requirement Exception:
Per past DWMRC review; 1" Qtr.,2nd qtr., and 3'd Qtr.20l I Groundwater Monitoring Reports, DWMRC
issued a February 7 , 2012 Notice of Enforcement Discretion ("NOED") for failure on the part of EFR to
comply with these timelines for acceleration of groundwater monitoring at well MW-35.
EFR stated in a March 26,2012 response to the NOED that based on an agreement made between
DWMRC and EFR during a telephone conference call on April 5, 2010, EFR is not required to implement
accelerated monitoring until "the month following the submission of the Exceedance Notice for a specified
quarter." Based on DWMRC review of notes taken during the April 5,2010 telephone conference (Loren
Morton 4l5ll0), 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 I 6, 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.
C urrent Accelerated Monitoring Status :
The table below (Table l) 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 Monitorer uarterlv Accelerated to Monthly Moni
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Reouired
MW-11 Class II water D-3 Mansanese Februarv 2010 Mav 2010
MW-14 Class III water D-4A Field pH Februarv 2010 Mav 2010
MW-25 Class III water c-3 Field pH
Uranium
Chloride
4"'Quarter 2010
3'o Quarter 2010
3'o Ouarter 2015
February 2013
March 2014
December 2015
MW-26(u,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
Aoril2010
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
February 2010
1't Quarter 2011
Aoril20l0
May 2010
May 201I
Julv 2010
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Pase 4
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Uranium
Field pH
Ammonia
4'Quarter 201I
4'Quarter 2014
4^ Quarter 2014
March 2014
March 2015
March 2015
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Sulfate
TDS
Selenium
Field oH
February 2010
l" Quarter 2011
4ft Quarter 2010
September 2010
3'd Quarter 2012
Februarv 2014
May 2010
May 2011
March 2011
January 201 1
December 2012
June 2014
MW-35 Class II c-48
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
Field oH
2nd Quarter 2011
2nd Quarter 2011
3'o Quarter 2011
3'o Quarter 2011
3'o Quarter 2012
Julv 2011
July 2011
July 2011
July 2011
October 201I
December 2012
Aueust 20l l
D: Down-gradient; U : Up-gradient; C : Cross-gradient; 1,2,3,4A : Cell #
a : Monitoring well MlIt-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annuallv Accelerated to Ouarterlv Monitorins
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-l Class II water u-1
Tetrahydrofuran
Field pH
Sulfate
Chloride
4" Quarter 2012
3'o Quarter 2014
4ft Quarter 2012
2no Quarter 2015
't Quarter 2013
't Quarter 2015
't Quarter 2013
't Ouarter 2016
MW-3 Class III water D-44,
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
Beryllium
Cadmium
Zinc
2"" Quarter 2010
2'o Quarter 2010
2* Quarter 2010
4* Quarter 2013
4ft Quarter 2013
2no Quarter 2015
2no Quarter 2015
2nd Ouarter 2015
3'" Quarter 2010
3d Quarter 2010
3'Quarter 2010
2no Quarter 2014
2no Quarter 2014
1't Quarter 2016
I't Quarter 2016
l't Ouarter 2016
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate * Nitrate (as N)
2'" Quarter 2010
2"d Quarter 2010
2"d Quarter 2010
4'n Quarter 2010
4th Quarter 2012
3'Quarter 2010
3'o Quarter 2010
3'd Quarter 2010
l't Quarter 201I
l't Ouarter 2013
MW-5 Class II water D-3 Uranium 4'' Ouarter 2010 l" Ouarter 201I
MW-12 Class III water D-3 Field pH
Selenium
l"'Quarter 2014
4* Ouarter 2014
2"o.Quarter 2014
2no Ouarter 2015
MW-15 Class III water D-4A Selenium
Field oH
2'- Quarter 2072
4'n Ouarter 2013
3'" Quarter 2012
2"o Quarter 2014
MW-I8 Class III water u-1 Thallium 2"" Quarter 2010 3'" Ouarter 2010
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Pase 5
* D : Down-gradient; U: Up-gradient; C : Cross-gradient; I, 2, 3, 4A : Cell #
Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status as of the
third quarter of 2015. EFR is required to notiff 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)1. For the 3'o quarter 2015 monitoring, the AMSR was received by the
DWMRC dated November 18, 2015 (received by the DWMRC on November 20,2015) and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received dated December 3, 2015 (received
by the DWMRC on December 4,2015). The follow up Plan and Time Schedule addresses exceedances of
sulfate in monitoring well MW-3. DRC notes that sulfate went into OOC during the third quarter 2015.
3. Monitorins Wells Purged for Two Casins Volumes Before Samnle 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:
" I. 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 of field parometers after recovery."
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Reouired
Sulfate
TDS
Field oH
2"" Quarter 2010
2no Quarter 2010
1't Ouarter 2014
3'" Quarter 2010
3'Quarter 2010
2"" Qtarter 2014
MW-19 Class III water u-l Field pH
Nitrate + Nitrite as N
2^ Quarter 2010
4* Ouarter 2011
3'" Quarter 2010
l't Ouarter 2012
MW-23 Class III water D-3 Field pH 2"'Ouarter 2010 3" Quarter 2010
MW-24 Class III water D-1
Cadmium
Thallium
Field pH
Fluoride
Sulfate
2"" Quarter 2010
2no Quarter 2010
2" Quarter 2010
4ft Quarter 2012
4* Ouarter 2014
3'" Quarter 2010
3'Quarter 2010
3'o Quarter 20i0
1't Quarter 2013
2no Ouarter 2015
MW-27 Class III water u-t
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
2'' Quarter 2010
4u Quarter 2010
l" Quarter 2010
l't Quarter 2010
2"d Ouarter 2013
3'" Quarter 2010
4ft Quarter 2014
3'd Quarter 2010
3'd Quarter 2010
1't Ouarter 2014
MW-28 Class III water D-l
Field pH
Chloride
Cadmium
Uranium
Vanadium
l" Quarter 2014
2no Quarter 2010
2no Quarter 2014
2"o Quarter 2014
2"" Ouarter 2014
2'o Quarter 2014
3'o Quarter 2010
2no Quarter 2014
2no Quarter 2014
2"" Ouarter 2014
MW-29 Class III water D-2
Field pH
TDS
Sulfate
4' Quarter 2010
2"d Quarter 2012
2no Ouarter 2015
2no Quarter 2011
3'o Quarter 2012
1't Ouarter 2016
MW-32 Class III water c-2
Adjusted Gross Alpha
Field pH
Chloride
2"" Quarter 2010
2"d Quarter 2010
1't Ouarter 2015
3'" Quarter 2010
3'Quarter 2010
2no Ouarter 2015
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
Per DWMRC review of the Report, the following purge methods were used during the 3'd Quarter 2015
(including accelerated samples). Purge methods and volumes are summarized on Table G-lAand Table G-
lB of the 3'o Quarter 2015 Monitoring Report:
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 3'o 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 3'd Quarter of 2015 monitoring three 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 Dota Worksheet.
The well should be sampled as soon as a sfficient volume of groundwater is svailcble tofill sample
containers.
Upon arrival at the well after recovery or when sfficient water is available for sampling meosure 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 hsve been collected.
If the field parameters of pH, specific conductance and temperature are within I 0% RPD the samples can
be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not within I0% 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 sfficiently purged and collected samples can be submittedfor analysis."
DWMRC staffverified 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 gtoundwater was measured and recorded (comments field) on the field sheet.
Quarter # Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes or
Continuous Pumoins Wells
3'" otr. 2015 JZ aJ
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
4. Relative Percentaee Difference Calculations and Radiolosical Comnarisons for Blind
Duplicate Analvsis:
DWMRC conducted a review of the blind duplicate samples collected during the 3'd 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-344W-65 on 7-28-15 and MW-35/]vIW-70 on 8-10-15) and two with the accelerated
samples (MW-l IA,IW-65 on7-7-75 and MW-3544W-70 on9/22115 and9l28ll5).
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 .l .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:
l. Notiff 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 3'd Qtr. 2015
sampling event all sample results conform to the Permit requirements (within 20% RPD) with the
exception of Nitrate + Nitrite (as N) in duplicate MW-344W-65 for the July 28,2015 monitoring event and
Adjusted Gross Alpha for the September 2015 accelerated monitoring event.
Per the 3'd Qtr. 2015 Report:
"The duplicate results were within a 20% WD in the quarterly samples exceptfor nitrate in duplicate pair
MW-3/MW-65. Both of the nitrate sample results reportedfor MW-3/MII/65 were notfive times greater
than the reporting limits of 0.1 and as such the deviationfrom the 20% RPD requirement is acceptable.
Results of the KPD test are provided under Tab G. "
Per DRC cross check nitrate sample results reported for MW-3iMW-65 were not five times greater than the
reporting limit and were not subject to the RPD <20yo requirement in the facility QAP.
DRC cross checked and verified that all radiological analyses meets the approved QAP requirements for
counting error limits (less than 20%o of the reported activity concentration) and for comparability (results of
formula calculations <2).
5. Analvtical Laboratories Used by EFR Certified bv State of Utah to Perform Analvsis
for all Analvtes:
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 3'd 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.
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
GEL Laboratories LLC current Utah Certification:
Basic Details
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TNI00l88
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 I
Tlpe Location
Company
Contact JAMES B. WESTMORELAND
Address 12040 SavageRd
Address 2
City Charleston
State South Carolina
Zip29407
Country US
Phone [phone]
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 TNI0I955
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
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
Active Yes
Address I
Type Location
Company
Contact Kyle Gross
Address I 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 analye requested by EFR tobe analyzed by GEL Laboratories was gross
alpha (Gross Alpha Radium) and that GEL Laboratories holds current accreditation in Utah for that analye
method EPA 900.1 GFPC Modified.
6. Laboratorv Renort Turn Around Times:
Per DWMRC review of EFR Table I included in the 3'd 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 tum-around times for the 3'd
Quarter 2015, dataturn-around times and EFR data review timelines appear to be reasonable/appropriate.
7. Sample Holdine 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 3'o Qtr. 2015 reporting
period.
8. SamDle Preservation:
Per review of the 3'd Quarter 2015 Report (Table G-3A and G-3B 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. Laboratorv OA/OC Flaes - 3'd Ouarter 2015:
QA/QC issues and DWMRC findings for the 3'd Quarter 2015 are summarized below:
Non-Confornrance Summary Self-
Identified?
EFR Corrective'Action
Summary
D1V\4RC Findings
Laboratory reporting limits
were raised for various
samples for parameters as
listed on the laboratory data
sheets.
Y 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- 3l- Gross Alpha
Counting Error was not (
20%o of the sample analysis
result (sample activity).
Y The sample result + the
counting errors was less than
the GWCL and is therefore
acceptable.
Per the QAP Part 9.1.4(b)
"An error term may be
greater than 20% ofthe
reported activity
concentration when the sum
of the activity concentration
and error term is less than or
eaual to the GWCL"
Matrix Spike % recovery
outside of range: MW-36
Ammonia, MW-36 Nitrate,
MW-03 Nitrate, MW-03
Fluoride, MW-l I Silver,
MW-70 Nitrate, MW-70
Gross Alpha, MW-30
Ammonia, MW-30 Nitrate,
MW-35 Gross Alpha.
Y None Per the QAP Part 8.1.2(a)
matrix spikes are required but
there are no requirements
which would disqualiff the
laboratory data
Method blank detection
above QAP Required RL -
All below established
acceptance limits for the 3'd
Ouarter 2015.
Y None - All recoveries were
within laboratory established
acceptance limits.
No issues this quarter,
typically any issues are
validated by the laboratory.
Laboratory Duplicate %
Recovery Comparison -
Various parameters out of
range as listed on the
laboratory QA/QC review
sheets.
Y Per AWAL DataSheet: High
RPD due to suspected sample
non-homogeneity or matrix
interference. Samples
validated by the laboratory.
Data was reported with a
qualifier.
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
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.1.g requires EFR to submit Time-Concentration Plots for each monitoring well for
primary indicators of cell leakage (based on tailings cell concentrations and ground water partitioning and
retardation coefficients); chloride, fluoride, sulfate and uranium. DWMRC notes that per the discussions
with EFR, it was agreed to that EFR need not plot trend lines on the Time Concentration Plots and that all
data is included on the plots (no data culled from the set). Per DWMRC review of the 3'd Qtr. 2015 Report,
the reviewed plots appear to be in conformance with the agreed upon changes, no issues were identified.
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
11. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DWMRC cross checks of groundwater elevation measurement calculations used for the 3'd Quarter
2015, approximately 5% of wells cross checked, comparing surface measured elevations minus measured
static levels with plotted elevations, no enors were noted.
The upper wildlife ponds at the White Mesa Mill were taken offline (pond recharge from Recapture
Reservoir discontinued) during the 4s Quarter 201 I 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).
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DWMRC Review Memo
Pase 12
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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, TW 4-24, TW 4-25, 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 2no 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.
III. EFR November 18.2015 Notice Pursuant to the Permit Part I.G.l(a)
The EFR November 1 8, 201 5 Notice Pursuant to the Permit Part LG. I (a) ("Notice") discusses the status
of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-compliance
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
("OOC') status, as updated through the 3'd Quarter 20 I 5 . DWMRC notes that the Notice was submitted
timely regarding currently agreed upon schedules.
The Notice summarizes wells/parameters with OOC status which have been resolved by either separate
corrective actions plans or approved modified GWCL's (pending inclusion in the renewal Permit). The
Notice also lists one new monitoring well with single parameter exceedance of GWCL's during the 3'o
Quarter 2015 which is subject to requirements of the Permit Part I.G.l requiring commencement of
accelerated monitorins. This well is:
1. Monitorins Well MW-25/Chloride
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.
IV. EFR November 18.2015 Removal of Certain Groundwater Monitorins Parameters from
Accelerated Monitorine Status
Per the EFR November 18, 2015 Requestfor Removol of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status ("EFR Request"), EFR requests that two monitoring well parameters
be returned to baseline monitoring. Specifically, the EFR Request addresses the following
wells/parameters be returned to baseline monitoring:
r MW-25/Cadmiumr MW-30/Ammonia
The EFR requests that these monitoring wells be returned to baseline monitoring based on eight
consecutive sample results below the GWCL. Per past protocols regarding the return of monitoring well
parameters to baseline monitoring, eight consecutive sample results below the GWCL has been acceptable
to reduce the monitoring frequency.
The EFR Request includes a table summary which lists the applicable monitoring results for each
welVparameter. The EFR Request additionally includes analytical reports and field monitoring sheets for
sample results which had not been provided to DRC at the time of the request. Per DRC cross check of the
results it appears that eight consecutive results have been obtained for each of the wells/parameters.
Therefore it is recommended that the wells/parameters be returned to baseline monitoring as summarized
on the table below:
The return to baseline monitoring for these wells/parameters will be included in a transmittal letter for
Director review and approval.
V. EFR December 3. 2015 Transmittal of Plan and Time Schedule under UGW370004 Part
r.c.4(d)
Monitorine Well Parameter Baseline Monitorins F reouencv
MW-25 Cadmium Ouarterlv
MW-30 Ammonia Ouarterlv
EFR 3'd Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 14
The EFR December 3,2015 Plan and Time Schedule ("EFR Plan") addresses exceedances of the current
GWCL for sulfate at monitoring well MW-3 which is in out of compliance status per the Permit PartLG.2
and required to undergo corrective action per the Permit Part I.G.4. The EFR Plan notes that a plan was
submitted on September I 0, 20 I 5 to address exceedances of cadmium and zinc in monitoring well MW-3,
the same monitoring well as addressed in the EFR Plan. As such EFR proposes to use the same strategy
and data collection procedures for sulfate in monitoring well as in the September 10, 2015 Plan.
Specifically to perform an analysis of sulfate in monitoring well MW-3 to determine if the exceedance is
due to a previously reported increasing trend in MW-3, is due to the construction design of MW-3 or a
combination of these factors.
EFR will utilize an inflatable packer to isolate and eliminate 9-10 feet of blank casing below the well
screen to determine if stagnant water in this interval may be causing mixing of fresh and stagnant water
and accumulated solids in the well groundwater samples. Per the EFR Plan, the packer installation will be
completed by February 8,2016, as required by the previously approved Plan dated September 10, 2015.
A full suite of samples will be collected for 4 quarters after the installation of the packer. Data will be
provided to the DWMRC as they are received by EFR. After completion of the 4 quarters of data, EFR
and DWMRC will discuss the results and reporting requirements concerning the data, as well as a path
forward concerning potential additional needs for source assessments in monitoring well MW-3. Based on
review of the EFR Plan it is recommended that the Director include the sulfate exceedances with the
previously approved plan for monitoring well MW-3. This issue will be included with the review letter for
the 3'o Quarter 2015 Ground Water Monitoring Report.
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 3'o 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 review of the EFR November 18, 2015, 3'd Quarter 2015 White Mesa Uranium
Mill Groundwater Monitoring Report based on findings as summarized above.
2. Close-out regarding review of the EFR November 18, 2015 Notice.
3 . Removal of Parameters from accelerated monitoring status per the EFR November 1 8, 20 I 5
request.
4. Approval of the EFR December 3,2015 Plan and Time Schedule.
VII. References
tEnergy Fuels Resources (USA) Inc., November 18, 2015,3'd Quarter20l5 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
' En"rgy Fuels Resources (USA) lnc., November 18, 2015, State of Utah Ground Woter Discharge Permit
No. UGW370004 lVhite Mesa Uranium Mill - Notice Pursuant to Part LG.l(a).
vI.
EFR 3'o Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 15
' Energy Fuels Resources (USA) Inc., November 18, 2015, State of Utah Ground Water Discharge Permit
No. UGlf/370004 White Mesa Uranium Mill - Removal of Certain Groundwoter Monitoring Parameters
from Acceleroted Monitoring Staus.
o EnergyFuels Resources (USA) Inc., December 3 , 2015, Transmittal of Plan and Time Schedule under
Uah Ground Water Discharge Permit UGW370004 Part 1.G.4(d) White Mesa Mill
t Energy Fuels Resources (USA) lnc., June 6,2012,llthite Mesa (Jranium Mill Ground llater Monitoring
Quality Assurance Plan (QAP), Revision 7.2.
u hITERA Incorporated ,2007, Revised Background Groundwater Quatity Report: Existing lY'ells
for Dension Mines (USA) Corp.'s lYhite Mesa Uranium Mill Site, San Juan County, Uah.
t hITERA Incorporated ,2007 , Background Groundwster Quatity Report: New Wells for Denison Mines
(USA) Corp.'s White Mesa Uranium Mill Site, San Juan County, Uah.
8Hurst, 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 Uah. Prepared by University of Utah
Department of Geology and Geophysics.
'Utuh Department of Environmental Quality, August 24,2012, (Jtah Ground lVater Discharge Permit,
Permit No. UGW370004 issuedfor the Energt Fuels Resources (USA) Inc. White Mesa Uranium Mill.