DRC-2018-001331 - 0901a068807b2991

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 Anderson
Director
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File
Phil Goble, Manager
Tom Rushing, P.G.
January 31, 2018
Review of the Energy Fuels Resources (USA) Inc. 3rd Quarter 2017 Ground Water
Monitoring Report for the White Mesa Uranium Mill
PM
z M /(*
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 13, 2017, Transmittal of 3rd Quarter 2017 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, November 15, 2017, State of Utah Ground Water Discharge Permit No. UGW3 70004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.l(a).
3. EFR, November 15, 2017, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status
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 of the 3rd Otr. 2017 Report and Related Actions at the White
Mesa Uranium Mill:
1. The 3rd Quarter 2017 Report was received on November 17, 2017, which was before the
due date (Permit Part I.F.l - due date of December 1).
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, Charleston, South Carolina. DWMRC verified that the laboratories
have current Utah certification for all parameters/methods used. No deyiations/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
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 tieq Utah gov
Printed on 100% recycled paper
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 3rd Quarter 2017 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 3rd Quarter 2017 Report is based on current Permit
GWCL’s, 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 those wells. The approved
GWCL’s will not be enforceable until final inclusion in the renewal permit; therefore, the
3rd Quarter 2017 Report data results were compared with the interim limits or groundwater
quality standards as listed in the currently active Permit.
6. Laboratoty 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. Two compliance parameters went into accelerated monitoring frequency during the
monitoring period (Fluoride in monitoring well MW-14 and Uranium in monitoring well
MW-12).
8. It was noted that the measured uranium concentration in monitoring well MW-5 was 145
pg/L for the 1st Quarter 2017 sample which is the highest recorded concentration for
uranium to date at the monitoring well. The second highest uranium concentration was the
4th Quarter 2014 sample which was 36.2 pg/L. Uranium concentrations appear to spike
during the winter months with concentrations during other times being much lower.
Monitoring well MW-5 has been in quarterly accelerated monitoring since 2011 based on
dual exceedances of uranium for the 4th Quarter 2010 and 1st Quarter 2011 samples. Per a
June 26, 2017 telephone discussion between DWMRC and EFR concerning the high 1st
Quarter 2017 uranium concentration: EFR had noted that the uranium concentrations were
elevated and appeared to spike during the 4th or Is1 quarter monitoring events of each year.
Monitoring well MW-5 was noted to have the top of the casing standpipe at ground level
due to a rise in ground level from soil placement for tailings cell 3. Based on these
findings, EFR extended the casing to rise above ground level during early May, re­
surveyed the well on May 11, 2017, re-graded the soil around the well to ensure that water
drained away from the well casing and, over-pumped the well on 5/19/2017 (extracted
42.7 gallons of water from the well). Per the June 26, 2017 phone call, DWMRC and EFR
agreed that a new section should be included in future Groundwater Reports to provide a
summary of findings and actions undertaken by EFR to address the uranium exceedances
at monitoring well MW-5. The 3rd Quarter 2017 Groundwater Report includes a section
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 2
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 3
discussing actions at monitoring well MW-5 (Section 2.4.3.2 of the Report). It was noted
that the 3rd Quarter 2017 laboratory result for uranium in MW-05 was 2.46 mg/L which is
well below the groundwater compliance limit for uranium in the well (7.5 mg/L).
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.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
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
renewed permit dated January 9, 2018 includes these changes.
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:
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 4
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
Sulfate
February 2010
3rd Qtr. 2017
May 2010
December 2017
MW-14 Class III water D-4A Field pH
Fluoride
February 2010
May 2017
May 2010
November 2017
MW-25 Class III water C-3 Field pH
Uranium
Chloride
Cadmium
d* Quarter 2010
1st Quarter 2016
1st Quarter 2013
1st Quarter 2016
February 2013
April 2016
June 2013
April 2016
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
Fluoride
February 2010
1st Quarter 2011
April 2010
4th Quarter 2011
4th Quarter 2014
4th Quarter 2015
May 2010
May 2011
July 2010
March 2014
March 2015
March 2016
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Sulfate
TDS
Selenium
Uranium
Field pH
February 2010
1st Quarter 2011
4th Quarter 2010
September 2010
3rd Quarter 2012
3rd Quarter 2016
February 2014
May 2010
May 2011
March 2011
January 2011
December 2012
December 2016
June 2014
MW-35 Class 11 C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
Field pH
2nd Quarter 2011
2nd Quarter 2011
3 rd Quarter 2011
3rd Quarter 2011
3 rd 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
1st Quarter 2015
1st Quarter 2013
1st Quarter 2016
MW-3 Class HI water D-4A Selenium 2nd Quarter 2010 3rd Quarter 2010
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 5
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
Zinc
Thallium
Cadmium
Beryllium
Tetrahydrofuran
Manganese
Nickel
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
4th Quarter 2013
2nd Quarter 2015
4th Quarter 2015
2nd Quarter 2015
2nd Quarter 2015
2nd Quarter 2016
2nd Quarter 2016
3rd Quarter 2016
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
1st Quarter 2016
3rd Quarter 2016
1st Quarter 2016
1st Quarter 2016
3rd Quarter 2016
3rd Quarter 2016
N/A
MW-3A Class III water D-4A
Field pH
Sulfate
Selenium
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
MW-5 Class II water D-3 Uranium
Field pH
4th Quarter 2010
1st Quarter 2017
ls‘ Quarter 2011
3rd Quarter 2017
MW-12 Class III water D-3
Field pH
Selenium
Uranium
1st Quarter 2014
4d' Quarter 2014
2nd Quarter 2017
2nd Quarter 2014
2nd Quarter 2015
3rd Quarter 2017
MW-15 Class III water D-4A Selenium
Field pH
2nd Quarter 2012
4th Quarter 2013
3rd Quarter 2012
2nd Quarter 2014
MW-18 Class III water U-l
Thallium
Sulfate
TDS
Field pH
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
1st Quarter 2014
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
2nd Quarter 2010
4th Quarter 2011
3rd Quarter 2010
Is1 Quarter 2012
MW-23 Class II water D-3 Field pH 4th Quarter 2016 1st Quarter 2017
MW-24 Class III water D-l
Cadmium
Thallium
Field pH
Fluoride
Sulfate
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
4th Quarter 2014
3 rd 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
Field pH
2nd Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
4th Quarter 2015
3rd Quarter 2010
4th Quarter 2014
3 rd Quarter 2010
3rd Quarter 2010
1st Quarter 2014
3rd Quarter 2016
MW-28 Class III water D-l
Field pH
Chloride
Cadmium
Uranium
Vanadium
1st Quarter 2014
2nd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
MW-29 Class HI water D-2 Field pH
TDS
4th Quarter 2010
2nd Quarter 2012
2nd Quarter 2011
3 rd Quarter 2012
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 6
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Sulfate 2nd Quarter 2015 1st Quarter 2016
Field pH 2nd Quarter 2010 3rd Quarter 2010
MW-32 Class III water C-2 Chloride 1st Quarter 2015 2nd Quarter 2014
Sulfate 4th Quarter 2016 1st Quarter 2017
* 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
3rd Quarter of 2017. 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 3rd Quarter 2017 monitoring, the AMSR was dated
November 15, 2017 (received by DWMRC on November 17, 2017).
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:
“7. Purging three well casing volwnes 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 3rd Quarter 2017
(including accelerated samples). Purge methods and volumes are summarized on Table G-1A and G-1B of
the 3rd Quarter 2017 Monitoring Report:
| Quarter # Purged 2 Casing Volumes | # Purged to Dryness # Purged 3 Casing Volumes |
3rd Qtr. 2017 32 1 3 (continuous pumping)
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 2017 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 2017 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 shippedfor 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.”
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 3rd Quarter 2017. 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-14/MW-65 on 8-15-17 and MW-37/MW-70 on 9-25-17) and two with the accelerated
samples (MW-35/MW-65 on 7-12-17 and MW-30/MW-65 on 9-12-17).
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 3rd Qtr. 2017
sampling event all sample results conform to the Permit requirements (within 20% RPD) with the
exception of Cadmium in the 9/25/17 duplicate (29% RPD).
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 7
Part 9.1.4.a of the facility Quality Assurance Plan (QAP) states “RPDs will be calculated in comparisons of
duplicate and original field sample results. Non-conformance will exist when the RPD > 20%, unless the
measured concentrations are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, February 1994,
9240, 1-05-01, p. 25).
Per the 3rd Quarter 2017 Report regarding the 9/25/17 cadmium blind duplicate, “both of the cadmium
sample results reported for MW-37/MW-70 were not five times greater than the reporting limits of 0.5
pg/L and as such the deviation from the 20% RPD requirement is acceptable.”
Per review it appears that the sample results for cadmium were not equal to or greater than 5 times the
approved reporting limit. Therefore, the RPD for fluoride is in conformance with requirements of the QAP
and no further action is warranted.
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 3rd Quarter, 2017. 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:
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
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 8
EFR 3 rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 9
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
American West Analytical Laboratories Current Utah Certification
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 included in the 3rd Qtr. 2017 Report, it was noted that laboratory
report turnaround times (from date of EFR sample submission to the contract laboratory) for normal
frequency monitoring was approximately 30 days for all samples (not including re-submission/corrected
reports). Per DWMRC review it was noted that EFR acted quickly to identify any deficiencies in the
reports and request corrected versions.
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 3rd
Quarter 2017, 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 3rd Qtr. 2017 reporting
period.
8. Sample Preservation:
Per review of the 3rd Quarter 2017 Report (Tables 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 - 3rd Quarter 2017:
QA/QC issues and DWMRC findings for the 3rd Quarter 2017 are summarized below:
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 10
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DWMRC Findings
Laboratory reporting limits
were raised for various
samples/parameters.
Y EFR states that the raised
RL’s are due to sample
dilution and qualifies the data
in Table G 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.
Sample gross alpha counting
error greater than 20% for
the MW-26 and MW-31
sample.
Y 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.
Sample results were lower
than the GWCL (1.19 and
1.01 pCi/L).
Matrix Spike % recovery
outside of range: MW-30
Nitrate, MW-70 Nitrate and
Gross Alpha
Y Per AWAL Data Sheet:
Matrix spike recovery
indicates matrix interference.
The method is in control as
indicated by the LCS.
Per the QAP Part 8.1.2(a)
matrix spikes are required but
there are no requirements
which would disqualify the
laboratory data. Data was
reported with a qualifier.
Laboratory Duplicate %
Recovery Comparison
Outside of Range: MW-31
Gross Alpha.
Y Same AWAL comments as
per the matrix spike %
recovery item above.
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
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 11
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 3rd Qtr. 2017 Report,
the reviewed plots appear to be in conformance with the agreed upon changes.
11. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DWMRC cross checks of groundwater elevation measurement calculations used for the 3rd Quarter
2017, 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
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 12
IUC White Mesa Mill Hydrographs: Piezometers Q South Wildlife Ponds
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, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-20,
TW4-21, TW4-22, TW4-24, TW4-25, TW4-37, TW4-39.
The nitrate pumping project was initiated during January 2013 (TW4-22, TW4-24, TW4-25 and TWN-2).
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.
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.
12. EFR November 15,2017 Notice Pursuant to the Permit Part I.G.lfa)
The EFR November 15, 2017 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 3rd Quarter 2017. 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 reports that no wells/parameters went into OOC status during the 3rd Quarter 2017.
Based on DWMRC review of the Notice it appears that all requirements of the Permit were met.
13. EFR November 15,2017 Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status
Per the EFR November 15, 2017 Request for Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status (“EFR Request”), EFR requests that three monitoring well parameters
be returned to baseline monitoring. Specifically, the EFR Request addresses the following
wells/parameters be returned to baseline monitoring:
• MW-15 Selenium
• MW-19 Nitrate
• MW-29 Sulfate
EFR requests that these monitoring wells be returned to baseline monitoring based on eight or more
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 return the monitoring frequency.
The EFR request includes a table summary which lists the applicable monitoring results for each
well/parameter. 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 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 13
Monitoring Well Parameter Number of Consecutive
Sample Results Below the
GWCL
Baseline Monitoring
Frequency
MW-15 Selenium 9 Semi-Annually
MW-19 Nitrate 9 Semi-Annually
MW-29 Sulfate 8 Semi-Annually
The return to baseline monitoring for these wells/parameters will be included in a transmittal letter for
Director Review and approval.
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 3rd Quarter of 2017 appears to be
reliable. It is recommended that a correspondence letter be sent to EFR with the following items:
1. Close-out regarding DWMRC review of the EFR November 13, 2017 3rd Quarter 2017 White
Mesa Uranium Mill Groundwater Monitoring Report based on findings as summarized above.
2. Close-out regarding DWMRC review of the EFR November 15,2017 Notice.
3. Removal of Parameters from accelerated monitoring status per the EFR November 15, 2017
request.
15. References
1 Energy Fuels Resources (USA) Inc., November 13, 2017, 3rd Quarter2017 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., November 15, 2017, 2017, State of Utah Ground Water Discharge
Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part LG. 1 (a).
3Energy Fuels Resources (USA) Inc., November 15, 2017, White Mesa Uranium Mill - Removal of
Certain Groundwater Monitoring Parameters from Accelerated Monitoring Status
4 Energy Fuels Resources (USA) Inc., August 15, 2017, 2017, White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP), Revision 7.3.
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. 3 White Mesa Uranium Mill Site, San Juan County, Utah.
1 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.
78 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.
EFR 3rd Quarter 2017 Groundwater Monitoring Report
DWMRC Review Memo
Page 14