DRC-2016-005892 - 0901a0688061fd43

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Department of
Environmental Quality
Alan Matheson
Executive Director
State of Utah
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor DR>C- ZOUo'OO
MEMORANDUM
TO:File
FROM: Tom Rushir _
THROUGH: Phil Goble.
DATE:March 29, 2016
SUBJECT: Review of the Energy Fuels Resources (USA) Inc. 4th Quarter 2015 Ground Water
Monitoring Report for the White Mesa Uranium Mill
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, Februaiy 22, 2016 - Transmittal of 4th Quarter 2015 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, February 11,2016- State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.l(a).
3. EFR, February 11,2016 - 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, March 3,2016 - 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.
II. EFR February 22.2016 4th Quarter 2015 Groundwater Monitoring Report
1. Checklist of Significant Findings of the 4*** Otr. 2015 Report and Related Actions at
the White Mesa Uranium Mill:
a. The 4th Quarter 2015 Report was received on February 24,2016, which was before the
due date (Permit Part I.F. 1 - due date of March 1,2016).
b. 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
I. Review Summary:
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 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 2
the currently approved Quality Assurance Plan for the White Mesa Uranium Mill were
noted.
c. 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. DWMRC review of the 4th 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.
d. DWMRC Stipulated Consent Agreement, Docket No. UGW12-03 required EFR to
submit an October 10,2012 Source Assessment Report, an April 13, 2012 pH Report,
and a December 12, 2012 Pyrite Investigation Report for previously documented out-
of-compliance parameters (multiple parameters). Per DWMRC review findings as
documented in a DWMRC review memo dated April 23, 2013, and transmitted via
letter to EFR dated April 25,2013, it was recommended that specific GWCL
parameters for monitoring wells be modified (12 instances), GWCL’s for pH be
modified for all monitoring wells, and that GWCL’s be removed from the permit for
three up-gradient monitoring wells. These requests are currently being addressed
through the Permit Renewal process. Review of the 4th Quarter 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.
e. 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 4th Quarter 2015 Report data results were compared with the
interim limits or groundwater quality standards as listed in the currently active Permit.
f. 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.
g. One compliance parameter 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.1). 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 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.
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
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 Februaiy 2010 May 2010
MW-14 Class III water D-4A Field pH February 2010 May 2010
MW-25 Class III water C-3 Field pH
Uranium
Chloride
4 Quarter 2010
3rd Quarter 2010
3rd Quarter 2015
February 2013
March 2014
December 2015
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
February 2010
1st Quarter 2011
April 2010
May 2010
May 2011
July 2010
EFR 4th 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
Uranium
Field pH
Ammonia
Fluoride
4th Quarter 2011
4th Quarter 2014
4th Quarter 2014
4th Quarter 2015
March 2014
March 2015
March 2015
March 2016
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Sulfate
TDS
Selenium
______Field pH______
February 2010
1st Quarter 2011
4th Quarter 2010
September 2010
3rd Quarter 2012
February 2014
May 2010
May 2011
March 2011
January 2011
December 2012
June 2014
MW-35 Class II C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
______Field pH______
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
3rd Quarter 2011
3rd Quarter 2012
July 2011
July 2011
July 2011
July 2011
October 2011
December 2012
August 2011
D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1,2,3,4A = Cell #
a = Monitoring well MW-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annually Accelerated to Quarterly Monitoring
Well Class ♦Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-1 Class II water U-l
Field pH
Sulfate
Chloride
3rd Quarter 2014
4th Quarter 2012
2nd Quarter 2015
T3 Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
4th Quarter 2013
2nd Quarter 2015
2nd Quarter 2015
2nd Quarter 2015
4th Quarter 2015
1st Quarter 2015
1st Quarter 2013
1st Quarter 2016
MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
Beryllium
Cadmium
Zinc
Thallium
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
1st Quarter 2016
1st Quarter 2016
1st Quarter 2016
3rd Quarter 2016
^Quarter 2010 ^Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
1st Quarter 2013
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2010
4th Quarter 2012
MW-5 Class II water D-3 Uranium 4m Quarter 20 IQ r Quarter 2011
^Quarter 2014
MW-12 Class III water D-3 Field pH
Selenium
1st Quarter 2014
4th Quarter 2014 2nd Quarter 2015
3^ Quarter 2012
MW-15 Class III water D-4A Selenium
Field pH
2“ Quarter 2012
4th Quarter 2013 2nd Quarter 2014
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
Well Class *Position Parameter Date of First
Exceedance of
GWCL
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
1st Quarter 2014
Date Accelerated
Monitoring First
Required
MW-18 Class HI water U-l
Thallium
Sulfate
TDS
Field pH
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
MW-19 Class III water U-l Field pH
Nitrate + Nitrite as N
2“ Quarter 2010
4th Quarter 2011
3rd Quarter 2010
1st Quarter 2012
MW-24 Class III water D-l
Cadmium
Thallium
Field pH
Fluoride
Sulfate
2“ Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
4th Quarter 2014
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2013
2nd Quarter 2015
^Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
4th Quarter 2015
^Quarter 2010
4th Quarter 2014
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2014
3rd Quarter 2016
MW-27 Class III water U-l
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
Field pH
^Quarter 2014
3rd Quarter 2010
MW-28 Class in water D-l
Field pH
Chloride
Cadmium
Uranium
Vanadium
1 Quarter 2014
2nd Quarter 2010
2nd Quarter 2014 2nd Quarter 2014
2nd Quarter 2014 2nd Quarter 2014
2nd Quarter 2014 2nd Quarter 2014
2sa_Quarter 2011
3”1 Quarter 2012
1st Quarter 2016
MW-29 Class III water D-2
Field pH
TDS
Sulfate
4“ Quarter 2010
2nd Quarter 2012
2nd Quarter 2015
^Quarter 2010
2nd Quarter 2010
1st Quarter 2015
MW-32 Class IU water C-2
Adjusted Gross Alpha
Field pH
Chloride
3rd Quarter 2010
3 rd 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
fourth 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.l(a), Accelerated
Monitoring Status Reports (AMSR)]. For the 4*11 quarter 2015 monitoring, the AMSR was received by the
DWMRC dated February 11, 2016 (received by the DWMRC on February 12, 2016) and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received dated March 3,2016 (received by
the DWMRC on March 7,2016). The follow up Plan and Time Schedule addresses exceedances of sulfate
in monitoring well MW-18, Fluoride in monitoring well MW-24 and Field pH in monitoring well MW-24.
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:
“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 offield parameters after recovery. ”
Per DWMRC review of the Report, the following purge methods were used during the 4th Quarter 2015
(including accelerated samples). Purge methods and volumes are summarized on Table G-lAand Table G-
1B of the 4th Quarter 2015 Monitoring Report:
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
Quarter # Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes or
Continuous Pumping Wells
4th Qtr. 2015 33
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 4th 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 4th 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 Data Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is available to fill sample
containers.
Upon arrival at the well after recovery or when sufficient water is available for sampling measure depth to
water and record on the Field Data Worksheet.
Take one set of measurements offield parameters for pH, specific conductance and temperature only.
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 of pH, 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.”
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.
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind
Duplicate Analysis;
DWMRC conducted a review of the blind duplicate samples collected during the 4th 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 11-3-15 and MW-22/MW-70 on 11-17-15) and two with the accelerated
samples (MW-30/MW-65 on 10-7-15 and MW-35/MW-65 on 12/14/15).
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 4th Qtr. 2015
sampling event all sample results conform to the Permit requirements (within 20% RPD) with the
exception of Ammonia (as N) in duplicate MW-35/MW-65 for the November 3,2015 monitoring event
and adjusted gross alpha in duplicate pair MW-35/MW65 for the December 14, 2015 accelerated
monitoring event.
Per the 4th Qtr. 2015 Report:
“The duplicate results were within a 20% RPD in the quarterly samples except for ammonia in duplicate
pair MW-35/MW-65. The ammonia results reportedfor MW-35/MW-65 were not five times greater than
the reporting limits of 0.05 mg/L and as such the deviation from the 20% RPD requirement is acceptable.”
'‘Duplicate error for duplicate pair MW-35/MW-65 in the December 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 separate duplicate analyses of MW-35 (the
laboratory and field), it appears that the duplication issues are related to a matrix interference.
Reanalysis was not completed because of the suspected matrix interference issues.”
Per DRC review of the MW-35/MW-65 blind duplicate sample it was noted that the analysis results did not
overlap when considering the uncertainty of the results, as summarized on the table below:
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
Data Overlap Comparison:
MW-35 pCi/L MW-65 pCi/L
Result Uncertainty LB UB Result Uncertainty LB UB
4.69 0.549 4.14 5.24 6.58 0.676 5.90 7.26
Comparability Formula (Per EFR QAP 9.1.4):
6.58-4.69/(.6762 + ,5492)5 = 2.17
DWMRC notes that although the samples did not meet the comparability criteria, the QAP Section 9.1.4
only requires that EFR request that the lab check for transcription errors and request re-analysis if the
sample is within holding time. Per the EFR description of follow up actions it appears that the actions are
in conformance with the QAP requirements.
5. Analytical Laboratories Used by EFR Certified by State of Utah to Perform Analysis
for all Analytes;
The analytical laboratories (GEL Laboratories LLC, Charleston, SC and American West Analytical
Laboratories, Salt Lake City, UT) were contracted by EFR to perform analysis on the samples collected
during the 4* 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]
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 TNI01955
EPACode 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 (Summary of Well Sampling for Q4 2015) included in the 4th 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
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
the Director may require a tum-around date be included in the facility QAP if any future concerns
regarding review of turnaround times are noted. Based on DWMRC review the tum-around times for the
4th Quarter 2015, data tum-around times and EFR data review timelines appear to be
reasonable/appropriate.
7. Sample Holding Times:
Per Table G-2A and Table G-2B of the Report, all method holding times were met for each analyte
submitted for laboratory analysis. DWMRC staff cross checked all holding time requirements and verified
that all samples/analytes appeared to be analyzed within holding times during the 4th Qtr. 2015 reporting
period.
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
8. Sample Preservation:
Per review of the 4th 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. Laboratory OA/OC Flags - 4th Quarter 2015:
QA/QC issues and DWMRC findings for the 4th Quarter 2015 are summarized below:
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary___________
DWMRC Findings
Laboratory reporting limits
were raised for various
samples for parameters as
listed on the laboratory data
sheets.
EFR states that the raised
RL’s are due to sample
dilution and qualifies the data
in Table G-5A and G-5B
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-18 and MW-36 - Gross
Alpha Counting Error was
not < 20% of the sample
analysis result (sample
activity).
The sample result + the
counting error was less than
the GWCL and is therefore
acceptable. EFR provides
review of the counting errors
in Table G-8A and G-8B.
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-03
Magnesium, Silver,
Ammonia, MW-36 Nitrate,
MW-18 Sodium, Calcium,
Magnesium, Ammonia,
MW-02 Sodium, Calcium,
Magnesium, Ammonia,
None Per the QAP Part 8.1.2(a)
matrix spikes are required but
there are no requirements
which would disqualify the
laboratory data
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary____________
DWMRC Findings
MW-37 Sodium, Calcium,
Magnesium, Ammonia
Method blank detection
above QAP Required RL -
All below established
acceptance limits for the 4tf
Quarter 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.
Per AWAL Data Sheet: High
RPD due to suspected sample
non-homogeneity or matrix
interference. Samples
validated by the laboratory.
Data was reported with a
qualifier.
Note: DWMRC reviewed the holding time summary chart; no exceedances of holding times were noted
DWMRC reviewed the temperature check charts, all sample batches were received by the laboratory <6° C.
10.Review of Time-Concentration Plots
The Permit Part I.F.l .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 4th 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 4th 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 4* 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).
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 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, 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 4th 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.
in. EFR February 11.2016 Notice Pursuant to the Permit Part I.G.l(a)
The EFR February 11, 2016 Notice Pursuant to the Permit Part I.G.l(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 4th 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). Two
new wells/parameters with two consecutive exceedances were listed in the Notice: Monitoring Well MW-
11/manganese and Monitoring Well MW-26/ Nitrate + Nitrite and Chloroform. The Notice includes an
explanation of the exceedances and for all cases describes conditions that don’t warrant the future
submission of a 30-day plan and schedule to assess the source of the dual exceedances. Per DWMRC
review, the EFR explanations appear appropriate. The Notice also lists three new monitoring wells with
single parameter exceedance of GWCL’s during the 4th Quarter 2015 which are subject to requirements of
the Permit Part I.G.1 requiring commencement of accelerated monitoring. These wells/parameters are:
1. Monitoring Well MW-3 0/Fluoride
2. Monitoring Well MW-3/Thallium
3. Monitoring Well MW-27/Field pH
Per the Notice these wells parameters will be sampled on an accelerated monthly or 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 February 11.2016 Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status
Per the EFR February 11,2016 Request for Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status (“EFR Request”), EFR requests that two monitoring well parameters be
returned to baseline monitoring. Specifically, the EFR Request addresses the following wells/parameters
be returned to baseline monitoring: •
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
• MW-25/Uranium
• MW-03A/Nitrate + Nitrite and TDS
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 have been acceptable to reduce the
monitoring frequency.
The EFR request includes a table summary which lists the applicable monitoring results for each
well/parameter. The EFR request additionally includes analytical reports and field monitoring sheets for
sample results which had not been provided to DRC at the time of the request. Per DRC cross check of the
results it appears that eight or more 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:
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 14
Monitoring Well Parameter Baseline Monitoring Frequency
MW-25 Uranium Quarterly
MW-3A Nitrate + Nitrite (as N)
TDS
Semi-Annually
Semi-Annually
The return to baseline monitoring for these wells/parameters will be included in a transmittal letter for
Director Review and approval.
V. EFR March 3.2016 Transmittal of Plan and Time Schedule under UGW370004 Part
LG.4Cd)
The EFR March 3,2016 Plan and Time Schedule (“EFR Plan”) addresses exceedances of the GWCLs for
the following wells and parameters:
Monitoring Well
MW-18
MW-24
Parameter
Sulfate
Field pH
Fluoride
EFR Noted Findings
• Statistically significant rising trend
was identified in the Intera 2007
Existing Wells Background Report.
• Indicator Parameters - Chloride and
Uranium are exhibiting significantly
rising trends, Fluoride is exhibiting a
significantly decreasing trend.
• MW-18 is a far upgradient well.
A decreasing trend in field pH in
MW-24 was identified in the Intera
2008 New Wells Background Report.
Indicator Parameters - Chloride and
Sulfate are not trending and uranium
is exhibiting a decreasing trend.
These wells/parameters are in out of compliance status per the Permit Part I.G.2 and are required to
undergo corrective action per the Permit Part I.G.4. Per the EFR Plan and based on the EFR preliminary
investigation of the parameters, noting that rising concentration trends were indicated in past background
reports, EFR proposes to conduct statistical analysis of the groundwater data to determine if adjustment of
the affected GWCLs is appropriate. Per the EFR Plan, a Source Assessment Report (SAR), which will
include more specific source investigation and statistical analysis, will be submitted to the Director within
90 days after approval of the EFR Plan. Per DWMRC review of the EFR Plan, the outlined follow up
actions appear to be appropriate.
VI. Conclusions and Recommendations
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 15
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 4th 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 February 22, 2016,4th Quarter 2015 White Mesa Uranium
Mill Groundwater Monitoring Report based on findings as summarized above.
2. Close-out regarding review of the EFR February 11, 2016 Notice.
3. Removal of Parameters from accelerated monitoring status per the EFR February 11,2016 request.
4. Approval of the EFR March 3,2016 Plan and Time Schedule.
VII. References
1 Energy Fuels Resources (USA) Inc., February 22, 2016, 4th Quarter2015 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., February 11, 2016, State of Utah Ground Water Discharge Permit
No. UGW370004 White Mesa Uranium Mill-Notice Pursuant to Part J.G. 1(a).
3 Energy Fuels Resources (USA) Inc., February 11,2016, State of Utah Ground Water Discharge Permit
No. UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Staus.
4 EnergyFuels Resources (USA) Inc., March 3,2016 Transmittal of Plan and Time Schedule under Utah
Ground Water Discharge Permit UGW370004 Part I.G.4(d) White Mesa Mill
5 Energy Fuels Resources (USA) Inc., June 6,2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 7.2.
6INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp. ’s White Mesa Uranium Mill Site, San Juan County, Utah.
7 INTERA Incorporated, 2008, Background Groundwater Quality Report: New Wells for Denison Mines
(USA) Corp. ’s White Mesa Uranium Mill Site, San Juan County, Utah.
8 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the July 2007 Sampling Event at the Denison
Mines, USA, White Mesa Uranium Mill located near Blanding Utah. Prepared by University of Utah
Department of Geology and Geophysics.
9 Utah Department of Environmental Quality, August 24, 2012, Utah Ground Water Discharge Permit,
Permit No. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill.
EFR 4th Quarter 2015 Groundwater Monitoring Report
DWMRC Review Memo
Page 16