DRC-2021-001166 - 0901a06880de9541

Div c".Alate iViz-Iraent and Radlation Control
JAN 2 6 2021
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com ENERGY FUELS
January 25, 2021
VIA PDF AND OVERNIGHT DELIVERY
Ty L. Howard
Director
Division of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4880
DRC-ZoZI-ooliGc,
Re: State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill — Notice Pursuant to Part I.G.1 (a)
Dear Mr. Howard:
The White Mesa Mill (the "Mill") performed fourth quarter ("Q4") groundwater monitoring during the
period from October 1, to December 31, 2020 under the March 19, 2019 version of the Mill' s Groundwater
Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were received
during the period ending December 28, 2020.
Pursuant to Part I.G.1.a) of the GWDP, please take notice that the concentrations of specific constituents in
the monitoring wells highlighted in yellow and bold italics in the columns for this quarter in the attached
Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been formatted to simplify the
tracking of any continued exceedances from one monitoring period to the next by charting ongoing
monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics).
As a result of the issuance of a revised GWDP on March 19, 2019, which sets revised GWCLs, requirements
to perform accelerated monitoring for certain constituents under Part I.G.1 of the previous GWDP ceased
effective on March 19, 2019, and the effect of the issuance of the revised GWDP was to create a "clean
slate" for certain constituents going forward.
Part I.G.1 c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to
the Director a plan and a time schedule for assessment of the sources, extent and potential dispersion of the
contamination, and an evaluation of potential remedial action to restore and maintain groundwater quality
to ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT
will be reestablished." The summary below relating to exceedances includes, for each exceedance, a brief
discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of
other actions currently being undertaken by Energy Fuels Resources (USA) Inc. ("EFRI") or in light of
other reports submitted by EFRI, and as determined by Division of Waste Management and Radiation
Control ("DWMRC") Staff. A description of the other actions and reports which have affected the
requirement to submit a plan and time schedule are as follows:
Letter to Mr. Ty L. Howard
January 25, 2021
Page 2
1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing
investigations at the Mill. Based on the results of the previous investigations, EFRI and the
Director acknowledged that it has not been possible to date to determine the source(s), cause(s),
attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride
in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate +
nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the
activities associated with the CAP are on-going. Based on information provided by DWMRC in
teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30-day
plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at
this time.
2. A Plan and Time Schedule will not be prepared for monitoring wells with two successive
exceedances if those successive exceedances were reported in a previous quarter and/or were
included in a previous Source Assessment Report ("SAR") during the current permit period
beginning March 19, 2019. Inclusion in a previous SAR means that the GWCLs were modified
based on conclusions and actions delineated in the previous SAR which were accepted by
DWMRC.
3. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program
and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action
Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket No. UGW-
20-01. As a result, the 30-day plan and schedule for assessment of chloroform and methylene
chloride exceedances is not required.
It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to
reflect background groundwater quality, as defined by the mean plus second standard deviation
concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each
monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that,
because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un-
impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the time.
Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a given analyte
will increase the number of exceedances due to statistical variation and not due to Mill activity.
Additionally, given the slow velocity of groundwater movement, accelerated sampling at a monthly
frequency can result in resampling of essentially the same water and can lead to repeat exceedances for
accelerated constituents not due to Mill activities, but due to repeat sampling of the same water.
1.0 Exceedances in Required Quarterly Sampling Wells
1.1 Quarterly Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods in Q4 2020. A 30-day plan and schedule contemplated in Part I.G.1 c) of
the GWDP will be required as noted below. One-time exceedances and non-successive exceedances are
noted on Table 1, but not listed below. Consecutive exceedances which occurred in previous reporting
periods are discussed in previously submitted SARs.
Letter to Mr. Ty L. Howard
January 25, 2021
Page 3
MW-11
• Manganese concentrations exceeded the GWCL in MW-11 in all of the Q4 sampling events. This
consecutive exceedance is addressed in the SAR, dated June 27, 2019. As a result of the SAR, the
GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become
effective upon their publication in the next revision of the GWDP. As a result of DWIVIRC's
acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance
is not necessary and will not be submitted. Until such time as the new GWCLs become effective,
the exceedances will continue to be noted and reported.
• The chloride concentration exceeded its GWCL in September monthly event and the Q4 2020
sampling event. As mentioned above, a CAP has been submitted and approved to address
nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions
specified in the CAP are currently being implemented; therefore, a plan to address this consecutive
exceedance is not necessary and is not being submitted.
MW-26
MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January 20,
2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform
removal, concentrations of all constituents in that well are subject to potential variation over time as a result
of the pumping activity. This will be taken into account by the Executive Secretary in determining
compliance for this well." Based on information provided by DWMRC in teleconferences on April 27, and
May 2, 2011, due to the current pumping status as part of the chloroform investigation program, the 30-day
plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene
chloride in MW-26.
• Nitrate + nitrite has exceeded its GWCL in the September and Q4 2020 sampling events. As
mentioned above, a CAP has been submitted and approved and the specified actions are currently
being implemented; therefore, a plan to address this consecutive exceedance is not necessary and
is not being submitted.
• Chloroform has exceeded its GWCL in all of the Q4 2020 sampling events. MW-26 is used as a
pumping well for the ongoing chloroform capture program and is expected to yield increased
concentrations of chloroform. Because this well is used in the chloroform capture program which
is the subject of separate investigations and actions, a plan and time schedule to address the
consecutive exceedances is not necessary and is not being submitted.
• The Total Dissolved Solids ("TDS") concentration exceeded its GWCL in Q3 and Q4 2020
sampling events. This is the first consecutive exceedance for TDS in MW-26 under the March 19,
2019 GWDP. Therefore, a plan and schedule for assessment will be submitted under separate cover
within 30 days of this Exceedance Notice.
MW-30
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2020 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore, a plan to address this consecutive exceedance is not necessary and is not
being submitted.
Letter to Mr. Ty L. Howard
January 25, 2021
Page 4
• The chloride concentration exceeded its GWCL in all of the Q4 2020 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination
which is expected to address chloride in groundwater. The actions specified in the CAP are
currently being implemented; therefore, a plan to address this consecutive exceedance is not
necessary and is not being submitted.
• Uranium concentrations exceeded the GWCL in all of the Q4 2020 sampling events. This
consecutive exceedance is addressed in the SAR, dated January 15, 2019. As a result of the SAR,
the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of
DWMRC' s acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become
effective, the exceedances will continue to be noted and reported.
• Selenium concentrations exceeded the GWCL in all of the Q4 2020 sampling events. This
consecutive exceedance is addressed in the SAR, dated January 15, 2019. As a result of the SAR,
the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will
become effective upon their publication in the next revision of the GWDP. As a result of
DWMRC' s acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become
effective, the exceedances will continue to be noted and reported.
MW-31
• Nitrate + nitrite has exceeded its GWCL in all of the Q4 2020 sampling events. As mentioned
above, a CAP has been submitted and approved and the specified actions are currently being
implemented; therefore, a plan to address this consecutive exceedance is not necessary and is not
being submitted.
• The chloride concentration exceeded its GWCL in all of the Q4 2020 sampling events. As
mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination
which is expected to address chloride in groundwater. The actions specified in the CAP are
currently being implemented; therefore, a plan to address this consecutive exceedance is not
necessary and is not being submitted.
• The TDS concentration exceeded its GWCL in all of the Q4 2020 sampling events. A SAR was
submitted to DWMRC on June 24, 2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC' s acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported.
• The sulfate concentration exceeded its GWCL in the September and Q4 2020 sampling events. A
SAR was submitted to DWMRC on June 24, 2020. As a result of the SAR, the GWCLs have been
recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their
publication in the next revision of the GWDP. As a result of DWMRC' s acceptance of the
recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary
and will not be submitted. Until such time as the new GWCLs become effective, the exceedances
will continue to be noted and reported.
Letter to Mr. Ty L. Howard
January 25, 2021
Page 5
• Uranium concentrations exceeded the GWCL in all of the Q4 2020 sampling events. A Plan and
Time Schedule that addresses exceedances of uranium in MW-31 was submitted to DWMRC on
November 18, 2020; therefore, an additional plan to address this consecutive exceedance is not
necessary and is not being submitted.
1.2 Quarterly Wells with New Exceedances Reported in Q4
There are no new exceedances for the Q4 2020 quarterly well sampling program.
2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly
2.1 Semi-annual Wells with Two Successive Exceedances
As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for
two successive sampling periods (Q3 2020 and Q4 2020).
MW-12
• Uranium concentrations exceeded the GWCL in the Q3 and Q4 2020 sampling events. A Plan and
Time Schedule that addresses exceedarices of uranium in MW-12 was submitted to DWMRC on
November 18, 2020; therefore, an additional plan to address this consecutive exceedance is not
necessary and is not being submitted.
• Selenium concentrations exceeded the GWCL in the Q3 and Q4 2020 sampling events. A Plan and
Time Schedule that addresses exceedances of selenium in MW-12 was submitted to DWMRC on
November 18, 2020; therefore, an additional plan to address this consecutive exceedance is not
necessary and is not being submitted.
MW-24
• Beryllium concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. Beryllium exceedances are addressed in the SAR dated June 27, 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
• Cadmium concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. Cadmium exceedances are addressed in the SAR dated June 27, 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
• Fluoride concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. Fluoride exceedances are addressed in the SAR dated June 27, 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC's acceptance of the study strategy, a plan and schedule to address this consecutive
Letter to Mr. Ty L. Howard
January 25, 2021
Page 6
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
• Nickel concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. Nickel exceedances are addressed in the SAR dated June 27, 2019. As a result of the SAR,
EFRI installed a collocated well to study potential installation issues associated with MW-24.
DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result of
DWMRC' s acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
• Thallium concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. Thallium exceedances are addressed in the SAR dated June 27, 2019. As a result of the
SAR, EFRI installed a collocated well to study potential installation issues associated with MW-
24. DWMRC approved the collocated well strategy by letter dated September 5, 2019. As a result
of DWMRC' s acceptance of the study strategy, a plan and schedule to address this consecutive
exceedance is not necessary and will not be submitted. Until such time as the study is complete,
the exceedances will continue to be noted and reported.
• Sulfate concentrations exceeded the GWCL in MW-24 in the Q3 2020 and Q4 2020 sampling
events. A SAR was submitted to DWMRC on June 27, 2019. As a result of the SAR, EFRI installed
a collocated well to study potential installation issues associated with MW-24. DWMRC approved
the collocated well strategy by letter dated September 5, 2019. As a result of DWMRC' s
acceptance of the study strategy, a plan and schedule to address this consecutive exceedance is not
necessary and will not be submitted. Until such time as the study is complete, the exceedances will
continue to be noted and reported.
MW-27
• The nitrate+nitrite concentration exceeded its GWCL for both the Q3 2020 and Q4 2020 sampling
events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite
contamination which is expected to address chloride in groundwater. The actions specified in the
CAP are currently being implemented; therefore, a plan to address this consecutive exceedance is
not necessary and is not being submitted.
MW-28
• Chloride has exceeded the GWCL for both the Q3 2020 and the Q4 2020 sampling events and
during previous quarters. As mentioned above, a CAP has been submitted and approved and the
specified actions are currently being implemented; therefore, a plan to address this consecutive
exceedance is not necessary and is not being submitted.
• Uranium has exceeded the GWCL for both the Q3 2020 and the Q4 2020 sampling events. A SAR
that addresses exceedances of uranium in MW-28 was submitted to DWMRC on October 19, 2020;
therefore, an additional plan to address this consecutive exceedance is not necessary and is not
being submitted.
Letter to Mr. Ty L. Howard
January 25, 2021
Page 7
MW-32
• Chloride has exceeded the GWCL for both the Q3 2020 and the Q4 2020 sampling events. As
mentioned above, a CAP has been submitted and approved and the specified actions are currently
being implemented; therefore, a plan to address this consecutive exceedance is not necessary and
is not being submitted.
2.2 Semi-annual Wells with New Exceedances Reported in Q4
Two new single exceedances for the Q4 2020 semi-annual well sampling program are listed below.
• Gross alpha in MW-24 was slightly above the GWCL in the Q4 sampling event; and
• Uranium in MW-29 was slightly above the GWCL in the Q4 sampling event.
Relative to accelerated reporting requirements, reporting of exceedances is required to be completed within
30 days of receipt of the last data package for a quarterly monitoring event. Similarly, accelerated
monitoring is required to commence the month following the submission of the Exceedance Notice for a
specified quarter for wells that are being accelerated from quarterly to monthly and the quarter following
the submission of the Exceedance Notice for wells that are being accelerated from semiannually to
quarterly.
Yours truly,
arty ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Scott Bakken, David Frydenlund, Logan Shumway, Terry Slade
Table 1 - GWCL F,xceedances for Fourth Quarter 2020 under the March 19, 2019 GWDP
Q2 2019 Results Q3 2019 Results Q4 2019 Results
Monitoring Well
(Water Class) Constituent Exceeding GWCL GWCL in March
19, 2019 GWDP
Q2 2019
Sample Date
Q2 2019
Result
May 2019
Monthly
Sample Date
May 2019
Monthly
Result
June 2019
Monthly
Sample Date
June 2019
Monthly
Result
,
Q3 2019
Sample Date
Q3 2019
Rult
August 2019
Monthly
Sample Date
August 2019
Monthly
Result
Sept. 2019
Monthly
Sample Date
Sept. 2019
Monthly
Result
Q4 2019
Sample Date
Q4 2019
Result
November
2019 Monthly
Sample Date .
November
2019 Monthly
Result
December
2019 Monthly
t Sample Dae
December
2019
Monthly
Result
MW-11 (Class II)
Chloride (mdL) 39.16
4/24/2019
34
5/7/2019
NA
6/3/2019
NA
• ii:r.,,,_ ,.11 _;,_.t, ... Sampling
7/16/2019
48.4
8/5/2019
Wells
11/12/2019
39.1
12/3/2019
35.4 N A
9/24/2019
NA
10/15/2019
30.8
Sulfate (mg/L) 1309 1160 NA NA 1410 NA NA 1290 1140 1100
TDS (mg/L) 2528 1890 NA NA 1890 NA NA 2100 NA NA
Manganese (ug/L) 164.67 181 210 2 10 199 202 174 185 206 167
MW-25 (Class III) Cadmium (ug/L) 1.5 4/10/2019 1.30 5/8/2019 1.41 6/4/2019 1.47 7/15/2019 1./3 8/6/2019 1.37 9/23/2019 1.38 10/9/2019 1.45 11/13/2019 1.36 12/4/2019 1.45
MW-26 (Class III)
Nitrate + Nitrite (as N) (mg/L) 0.62
4/24/2019
3.00
5/7/2019
0.986
6/4/2019
3.16
7/16/2019
2.06
8/6/2019
3.10
9/24/2019
1.59
10/9/2019
2.35
11/13/2019
2.90
12/4/2019
2.32
Chloroform (ug/L) 70 4140 1140 778 3110 1090 1540 1710 1280 1110
Chloride (mg/L) 58.31 82.0 73.0 72.6 75.2 83.5 62.1 73.8 62.3 57.7
TDS (mg/L) 3284.19 2820 NA NA 3100 NA NA 2920 NA NA
Methylene Chloride (ug/L) 5 4.16 1.69 <1.00 10.7 1.12 3.35 2.95 1.73 2.64
MW-30 (Class II)
Nitrate + Nitrite (as N) (mg/L) 2.5
4/9/2019
18.5
5/7/2019
17.9
6/3/2019
15.8
7/16/2019
19.3
8/6/2019
15.8
9/24/2019
17.9
10/8/2019
18.2
11/13/2019
17.2
12/4/2019
17.8
Chloride (mg/L) 128 /38 175 165 181 190 176 170 180 185
Selenium (ug/L) 47.2 53.6 49.9 48.4 50.9 49.1 56.8 56.4
Uranium (ug/L) 8.32 8.62 8.15 8.88 9.03 9.39 8.12 8.69 9.29 8.99
MW-31 (Class III)
Nitrate + Nitrite (as N) (mg/L) 5
4/10/2019
19.7
5/7/2019
18.9
6/3/2019
19.7
7/15/2019
19.8
8/5/2019
17.0
9/23/2019
19.5
10/9/2019
19.8
11/12/2019
18.8
12/3/2019
18.3
Sulfate (mg/L) 993 917 NA NA 1150 NA NA 1010 990 1020
TDS (mg/L) 2132 2080 NA NA 2580 NA NA 2280 2650 2030
Uranium (ug/L) 15 14 NA NA 14.3 NA NA 14.4 NA NA
Chloride (m L) 143 294 346 325 374 372 365 318 338 343
Required Semi-Annua Sampling We ls ""111185F'
MW-12 (Class III) Uranium (ug/L) 23.5 4/25/2019 23.2 NS NA NS NA 7/11/2019 23.1 NS NA NS NA 10/23/2019 21.6 NS NA NS NA Selenium (ug/L) 39 33.9 NA 30.3
MW-24 (Class III)
Be Ilium ul ) 2
5/2/2019
2.83
NS
NA
NS
NA
7/18/2019
2.94
NS
NA
NS
NA
11/6/2019
3.25
NS
NA
NS
NA
Cadmium (11.1 ) 6.43 8.24 NA NA 8.37 NA NA 9.31 NA NA
Fluoride (mt ) 0.47 a839 NA NA 0.996 NA NA 0.667 NA NA
gi 50 63.9 NA NA 70.6 NA NA 75.4 NA NA
7507 7020 NA NA NA NA NA 7700 NA NA
Thallium (u... L) 2.01 2.73 NA NA 2.61 NA NA 2.88 NA NA
Gross Al I ha (sCi/L) 7.5 3.32 NA NA NA NA NA 2.86 NA NA
Sulfate (mg/L) 2903 2790 NA NA NA NA NA 2630 NA NA
Field pH (S.U.) 5.03 - 8.5 4.53 NA NA 5.03 NA NA 5.19 NA NA
MW-27 (Class III) Nitrate + Nitrite (as N) (mg/L) 5.6 4/23/2019 6.33 NS NA NS NA 7/12/2019
8/15/2019 6.50 NS NA NS NA 10/22/2019 6.27 NS NA NS NA
MW-28 (Class III)
Chloride (mg/L) 105
4/24/2019
165
NS
NA
NS
NA
7/12/2019
8/16/2019
133
NS
NA
NS
NA
10/22/2019
149
NS
NA
NS
NA
Selenium (u! L) 11.1 12.4 NA NA 10.6 NA NA 16.5 NA NA
Nitrate + Nitrite (as N) (nal ) 5 3.7 NA NA NA NA NA 5.14 NA NA
Gross Alpha (pCi/L) 2.42 1.94 NA NA 1.20 NA NA <1.00 NA NA
Uranium (ug/L) 4.9 9.60 NA NA 7.83 NA NA 12.4 NA NA
MW-29 (Class III) Uran um (ug/L) 15 4/24/2019 15.00 NS NA NS NA NS NA NS NA NS NA 10/22/2019 14.20 NS NA NS NA
MW-32 (Class III) Chloride (mg/L) 35.39 4/9/2019 34.5 NS NA NS NA 8/15/2019 35.7 NS NA NS NA 10/8/2019 35.3 NS NA NS NA
Notes:
NS= Not Required and Not Sampled
NA= Not Applicable
Exceedances are shown in yellow
Table 1 - GWCL Exceedances for Fourth Quarter 2020 under the March 19, 2019 GWDP
Q1 2020 Results Q2 2020 Results Q3 2020 Results Q4 2020 Results
Monitoring
Well (Water
Class)
Constituent Exceeding GWCL
GWCL in
March 19,
2019
GWDP
QI 2020 c 1
''alighe Date
Q l 2020
Result
February
2020
Monthly
Sample Date
February
2020
Monthly
Result
March 2020
Monthly
S ple
Date
March
2020
Monthly Result
Q2 2020
Sample
Date
Q2 2020
Result
May 2020
Monthly
S ple
Date
May 2020 " .hi
''.4)1I'my Result
June 2020
Monthly
S ple
Date
June 2020
Monthly
Result
Q3 2020
Sample
Date
Q3 2020 Result
August
2020
Monthly
Sample
Date
August
2020
Monthly
Result
September
2020
Monthly
Sample Date
September
2020
Monthly
Result
Q4 2020
Sample Date
Q4 2020
Result
November
2020
Monthly
Sample Date
November
2020
Monthly
Result
December
2020
Monthly
Sample Date
December
2020
Monthly
Result
Required Quarterly Sampling Wells
MW-11
(Class II)
Chloride (mg/L) 39.16
1/15/2020
1/28/2020
38.9
2/4/2020
42.1
3/10/2020
41.0
4/8/2020
38.3
5/5/2020
39.0
6/2/2020
40.1
7/7/2020
42.1
8/11/2020
43.9
9/2/2020
40.6
10/12/2020
44.8
11/16/2020
33.7
12/7/2020
37.4
Sulfate (mg/L) 1309 1180 1260 1120 1180 1180 1310 1260 1220 1170 1300 858 1330
TDS (mg/L) 2528 1920 NA NA 1920 NA NA 2590 NA NA 992 2040 1990
Manganese (ug/L) 164.67 169 227 183 189 206 211 178 276 230 211 174 212
MW-25
(Class III) Cadmium (ug/L) 1.5 1/15/2020 1.35 2/5/2020 1.52 3/11/2020 1.41 4/7/2020 1.46 5/6/2020 1.52 6/3/2020 1.46 7/7/2020 1.39 8/10/2020 1.54 9/2/2020 1.61 10/13/2020 1.43 11/17/2020 1.23 12/8/2020 1.59
MW-26
(Class III)
Nitrate + Nitrite (as N) (mg/L) 0.62
1/15/2020
0.873
2/4/2020
0.978
3/10/2020
1.60
4/8/2020
0.747
5/6/2020
1.16
6/3/2020
3.44
7/9/2020
1.360
8/11/2020
0 407
9/2/2020
0.623
10/15/2020
0.936
11/17/2020
0.379
12/8/2020
0.611
Chloroform (ug/L) 70 1260 1640 1720 1420 1200 1530 4030 1940 1070 872 2800 1200
Chloride (mg/L) 58.31 78.8 66.9 76.9 62.8 73.8 63.7 67.6 57.5 59.8 57.2 36.4 42.1
TDS (mg/L) 3284.19 3010 NA NA 2600 NA NA 3880 NA NA 4860 2980 3040
Methylene Chloride (ug/L) 5 2.79 2.76 4.44 1.94 1.48 2.35 6.59 2.67 <1.00 <1.00 14.60 1.52
MW-30
(Class II)
Nitrate + Nitrite (as N) (mg/L) /.5
1/15/2020
16.4
2/5/2020
17.8
3/11/2020
19.0
4/6/2020
18.1
5/6/2020
18.6
6/3/2020
18.3
7/6/2020
18.4
8/11/2020
21.1
9/1/2020
18.3
10/13/2020
16.8
11/17/2020
13.4
12/8/2020
12.0
Chloride (mg/L) 128 182 187 182 195 177 180 185 183 166 183 150 166
Selenium (ug/L) 47.2 49.7 49.9 48.1 54.4 51.5 50.5 51.8 56.0 55.3 53.5 54.9 51.8
Uranium (ug/L) 8.32 8.88 9.06 9.50 9.24 8.94 9.28 9.76 10.6 9.90 9.92 9.95 9.56
MW-31
(Class III)
Nitrate + Nitrite (as N) (mg/L) 5
1/14/2020
17.5
2/4/2020
18.0
3/10/2020
19.2
4/6/2020
18.8
5/5/2020
20.1
6/2/2020
18.7
7/7/2020
19.2
8/10/2020
21.6
9/1/2020
18.4
10/19/2020
18.6
11/16/2020
16.5
12/7/2020
18.8
Sulfate (mg/L) 993 1120 1150 1080 1130 1080 1130 1150 1100 1110 1100 676 922
TDS (mg/L) 2132 2220 2240 2380 2400 2330 2440 2400 2580 2650 2370 2490 2560
Uranium (ug/L) 15 14.8 NA NA 15.5 NA NA 18.1 19.7 18.5 19.3 17.8 19.5
Chloride (nig/L) 143 381 370 368 376 361 377 370 368 367 345 251 311
Required Semi-Annual Sampling Wells
MW-12
(Class III)
Uranium (ug/L) 23.5 1/16/2020 21 9 NS NA NS NA 4/9/2020 23.7 NS NA NS NA 7/8/2020 25.6 NS NA NS NA 10/20/2020 26.2 NS NA NS
,
NA Selenium (ug/L) 39 NA 41.2 40.1 52.7
MW-24
(Class III)
Beryllium (ug/L) 2
1/22/2020
2.07
NS
NA
NS
NA
4/22/2020
2.95
NS
NA
NS
NA
7/10/2020
2.59
NS
NA
NS
NA
10/28/2020
2.47
NS
NA
NS
NA
Cadm um (ug/L) 6.43 7.30 NA NA 8.46 NA NA 8.43 NA NA 8.12 NA NA
Fluoride (mg/L) 0.47 0.805 NA NA 0.732 NA NA 1.08 NA NA 0.976 NA NA
Nickel (mg/L) 50 68.1 NA NA 72.6 NA NA 76.7 NA NA 77.3 NA NA
Manganese (ug/L) 7507 7010 NA NA 7750 NA NA 8010 NA NA 7480 NA NA
Thallium (ug/L) 2.01 1.92 NA NA 2.81 NA NA 3.07 NA NA 2.92 NA NA
Gross Alpha (pCi/L) 7.5 4.95 NA NA 5.69 NA NA 3 7/ NA NA 9.03 NA NA
Sulfate (meL) 2903 2960 NA NA 2870 NA NA 2920 NA NA 3220 NA NA
Field pH (S.U.) 5.03 - 8.5 6.01 NA NA 5.60 NA NA 5.70 NA NA 5 19 NA NA
MW-27
(Class III) Nitrate + Nitrite (as N) (mg/L) 5.6 1/16/2020 6.18 NS NA NS NA 4/8/2020 6.43 NS NA NS NA 7/8/2020 6.62 NS NA NS NA 10/21/2020 6.52 NS NA NS NA
MW-28
(Class 111)
Chloride (mg/L) 105
1/16/2020
151
NS
NA
NS
NA
4/15/2020
129
NS
NA
NS
NA
7/8/2020
140
NS
NA
NS
NA
10/23/2020
127
NS
NA
NS
NA
Selenium (ug/L) 11.1 13.4 NA NA 10.2 NA NA 15.5 NA NA 9.90 NA NA
Nitrate + Nitrite (as N) (mg/L) 5 NA NA NA 2.6 NA NA 4 58 NA NA 2.39 NA NA
Gross Alpha (pCi/L) 2.42 1.79 NA NA 1.69 NA NA 1.60 NA NA 1.68 NA NA
Uranium (ug/L) 4.9 7.56 NA NA 5.91 NA NA 11.80 NA NA 5.88 NA NA
MW-29
(Class III) Uranium (ug/L) 15 NS
-
NA NS NA NS NA 4/8/2020 14.8 NS NA NS NA NS NA NS NA NS NA 10/13/2020 15.3 NS NA NS NA
MW-32
(Class III) Chloride (mg/L) 35.39 1/14/2020 38.0 NS NA NS NA 4/7/2020 36.4 NS NA NS NA 7/6/2020 33.0 NS NA NS NA 10/12/2020 36.3 NS NA NS NA
Notes:
NS= Not Required and Not Sampled
NA= Not Applicable
Exceedances are shown in yellow