Loading...
HomeMy WebLinkAboutDRC-2019-003620 - 0901a06880a264eeY FUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.corn Div of Waste Management April 17, 2019 and Radiation Control APR 2 2 2019 --PiZ —Xic?-603620 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 first quarter ("Q 1") groundwater monitoring during the period from January 1, to March 31, 2019 under the January 19, 2018 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 March 22, 2019. 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 January 19, 2018, which sets revised GWCLs, requirements to perform accelerated monitoring under Part I.G.1 of the previous GWDP ceased effective on January 19, 2018, and the effect of the issuance of the revised GWDP was to create a "clean slate" for all constituents in all wells 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 Q1 2019 exceedances includes, for each exceedance, a brief discussion of whether 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 Letter to Mr. Ty L. Howard April 17, 2019 Page 2 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: 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"). 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. Letter to Mr. Ty L. Howard April 17, 2019 Page 3 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 Q1 2019. A 30-day plan and schedule contemplated in Part I.G. 1 c) of the GWDP will be required for the consecutive exceedances of cadmium in MW-25 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 the SARs submitted August 20, 2017, June 25, 2018, and January 16, 2019 and the Plan and Time Schedules submitted December 5, 2019 (approved March 5, 2019) and February 21, 2019. MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in all of the Q1 sampling events. A Plan and Time Schedule was submitted to DWMRC on February 21, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. MW-25 • Cadmium concentrations exceeded the GWCL in MW-25 in the February and March 2019 monthly sampling events. This is the first consecutive exceedance for cadmium in MW-25 under the January 19, 2018 GWDP. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. MW-26 • Nitrate + nitrite has exceeded its GWCL in all of the Q4 2018 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 2018 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 chloride concentration exceeded its GWCL in in the December 2018 monthly and the Q1 2019 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; Letter to Mr. Ty L. Howard April 17, 2019 Page 4 therefore, a plan to address this consecutive exceedance is not necessary and is not being submitted. 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. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the Q1 2019 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 all of the Q1 2019 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 MW-30 in all of the Q1 2019 sampling events. These exceedances are addressed in the SAR dated January 16, 2019. A plan or schedule to address the Q1 exceedances is not necessary and is not being submitted because exceedances have been addressed in the SAR which was submitted to DWMRC on January 16, 2019. The exceedances will continue to be noted and reported. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Q1 2019 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 monitoring periods for Q1 2019. 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. Letter to Mr. Ty L. Howard April 17, 2019 Page 5 • The sulfate concentration exceeded the GWCL in the January 19, 2018 GWDP in all of the Q1 2019 sampling events. These exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs became effective upon their publication in the March 19, 2019 GWDP. Sulfate was reported herein because the samples were collected prior to the publication of the March 19, 2019 GWDP. Sulfate will be removed from future exceedance notices. • The Total Dissolved Solids ("TDS") concentration exceeded the GWCL in the January 19, 2018 GWDP in all of the Q1 2019 sampling events. These exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs became effective upon their publication in the March 19, 2019 GWDP. TDS was reported herein because the samples were collected prior to the publication of the March 19, 2019 GWDP. TDS will be removed from future exceedance notices. • The uranium concentration exceeded the GWCL in the January 19, 2018 GWDP in all of the Q1 2019 sampling events. These exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs became effective upon their publication in the March 19, 2019 GWDP. Uranium was reported herein because the samples were collected prior to the publication of the March 19, 2019 GWDP. Uranium will be removed from future exceedance notices. • The selenium concentration exceeded the GWCL in the January 19, 2018 GWDP in all of the Q1 2019 sampling events. These exceedances are addressed in the SAR dated August 20, 2017 and approved by DWMRC on March 20, 2018. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs became effective upon their publication in the March 19, 2019 GWDP. Selenium was reported herein because the samples were collected prior to the publication of the March 19, 2019 GWDP. Selenium will be removed from future exceedance notices. 1.2 Quarterly Wells with New Exceedances Reported in Q1 Four new exceedances for the Q1 2019 quarterly well sampling program are listed below. These exceedances will result in an accelerated sampling frequency from quarterly to monthly. The wells listed below will only be sampled during the monthly events for those constituents that exceeded the GWCLs. The wells listed below will be sampled for all constituents listed in the GWDP during the quarterly events as that is the regularly scheduled sampling for the quarterly wells. It is important to note EFRI requested removal of field pH in MW-30 from accelerated monitoring by letter dated January 24, 2019. The February monthly sample results reported a concentration of field pH below the GWCL. Accelerated monthly monitoring of this constituent will continue uninterrupted pursuant to the requirements described below. • Field pH in MW-30 was slightly below the GWCL in the February monthly sampling event. Letter to Mr. Ty L. Howard April 17, 2019 Page 6 • Ammonia in MW-26 was slightly above the GWCL in the Q1 sampling event. • Field pH in MW-36 was slightly below the GWCL in the February monthly sampling event. • Selenium in MW-30 was slightly above the GWCL in the Q1 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. 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 (Q4 2018 and Q1 2019). MW-24 • Thallium concentrations exceeded the GWCL in MW-24 in the Q4 2018 and Q1 2019 sampling events. Thallium exceedances are addressed in the Plan and Time Schedule dated December 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. • Beryllium concentrations exceeded the GWCL in MW-24 in the Q4 2018 and Q1 2019 sampling events. Beryllium exceedances are addressed in the Plan and Time Schedule dated December 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. • Cadmium concentrations exceeded the GWCL in MW-24 in the Q4 2018 and Q1 2019 sampling events. Cadmium exceedances are addressed in the Plan and Time Schedule dated December 5, 2018, which DWMRC approved by letter dated March 5, 2019. A plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. MW-27 • The nitrate+nitrite concentration exceeded its GWCL for both the Q4 2018 sampling event and the Q1 2019 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. Letter to Mr. Ty L. Howard April 17, 2019 Page 7 MW-28 • Chloride has exceeded the GWCL for both the Q4 2018 sampling event and the Q1 2019 sampling event 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 Q4 2018 sampling event and the Q1 2019 sampling event. This consecutive exceedance is addressed in the Plan and Time Schedule, dated December 4, 2014. As a result of the Plan and Time Schedule, additional data will be collected and an assessed. As a result of DWMRC's acceptance of the Plan and Time Schedule, no additional actions for this consecutive exceedance are necessary at this time. 2.2 Semi-annual Wells with New Exceedances Reported in Q1 There were no new exceedances for the semi-annual well sampling program. Yours truly ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund Terry Slade Logan Shumway Scott Bakken Paul Goranson Table 1 - GW/CL Exceedances for First Quarter 2019 under the Jarman 19, 2018 GWDP Q1 2018 Results 0.2 2018 Results Q4 2018 Results mitoring Well Water Class) Constituent Exceeding GWCL GWCL in January 19, 2018 GWDP January 2018 Monthly Sample Date January 2018 Monthly Result Q1 2018 Sample Date Q1 2018 Result March 2018 Monthly Sample Date March 2018 Monthly Result Q2 2018 Sample Date Q2 2018 Result May 2018 Monthly Sample Date May 2018 Monthly Result June 2018 Monthly Sarnple Date June 2018 Monthly Result July 2018 Monthly Sample Date July 2018 Monthly Result August 2018 Monthly Sample Date August 2018 Monthly Result Q3 2018 Sample Date ` ' Q3 2018 Result Q4 2018 '! . .. . te Q4 2018 Result November 2018 Monthly Sample Date November 2018 Monthly Result December 2018 Monthly Sample Date December 2018 Monthb Result , A Requi 5/15/2018 10/25/2018 161 11/14/2018 11 (Class II) Manganese (ug/L) 164 67 1/24/2018 lija 2/20/2018 117 3/6/20 8 4/18/2018 /74 NA 6/19/2018 NA 7/24/2018 NA 8/9/2018 154 9/11/2018 171 195 12/11/2018 230 14. (Class III) Fluoride (mg/L) 0.2 1/23/2018 0.153 2/19/2018 0.100 3/6/2018 0.110 4/12/2018 <0.100 5/14/2018 0.135 6/18/2018 0.146 7/24/2018 0.183 8/9/2018 <0 100 9/11/2018 <0.100 10/25/2018 0.126 11/13/2018 0.142 12/11/2018 0.146 25 (Class III) Cadmium (ug/L) 1.5 1/23/2018 1.38 2/19/2018 28 3/7/2018 1.45 4/17/2018 1.38 5/14/2018 1.34 6/18/2018 1.38 7/23/2018 1.30 8/9/2018 1.36 9/10/2018 1.35 10/24/2018 1.30 11/13/2018 1.51 12/10/2018 1.49 Fluoride (mg/L) 0.42 NA 0.281 0.318 0.360 0.346 0.210 0.128 0.243 0.243 0.313 0.309 0.298 26 (Class III) Nitrate + Nitrite (as N) (mei-) 0.62 1/25/2018 0.862 2/22/2018 0.742 3/8/2018 0.691 4/19/2018 0.816 5/15/2018 0.920 6/19/2018 0.8 15 7/24/2018 0.704 8/10/2018 1.40 9/13/2018 0.825 10/25/2018 1.25 11/14/2018 1.08 12/10/2018 1.11 Chloroform (ug/L) 70 2280 1730 2350 2500 1740 3920 1160 1030 728 1130 2960 1460 Chloride (mg/L) 58.31 57.5 64.3 75.2 62.5 62.4 66.9 66.0 68.8 74.5 57.0 57.6 80.3 Methylene Chloride (ug/L) 5 5.79 9.80 11.6 17.4 8.55 10.3 3.07 2.47 1.58 2.13 4.99 2.55 Nitrogen, Ammonia as N 0.92 NA 0.506 NA 0.396 NA NA NA NA 0.480 0.415 NA NA Field pH (S.U.) 5.61 - 8.5 6.11 6.35 6.73 5.50 6.81 7.00 7.18 6.64 6.57 6.38 6.57 6.87 30 (Class II) Nitrate + Nitrite (as N) (mg/L) 2.5 1/23/2018 15.2 2/22/2018 17.6 3/8/2018 17.0 4/12/2018 17.3 5/15/2018 17.7 6/19/2018 16.9 7/24/2018 17.4 8/10/2018 18.7 9/11/2018 18.0 10/22/2018 17.3 11/14/2018 16.9 12/11/2018 17.2 Chloride (mg/L) 128 152 158 167 145 174 169 177 170 183 140 166 154 Selenium (ug/L) 47.2 43.5 45.5 NA 46 4 NA NA NA NA 42.5 45.6 NA NA Uranium (ug1L) 8.32 8.53 8.23 8.66 7.98 8.44 8.80 8.69 7.69 8.34 8.08 8.81 8.20 Field pH (S.U.) 6 47 - 8.5 6.18 6.54 6.87 6.33 6.74 6.84 7.39 6.91 6.94 6.56 6.94 7.11 31 (Class III) Nitrate + Nitrite (as N) (mg/L) 5 1/24/2018 17.0 2/20/2018 18.8 3/5/2018 19.0 4/17/2018 19.0 5/14/2018 18.8 6/18/2018 18.0 7/23/2018 18.0 8/10/2018 18.3 9/10/2018 20.1 10/24/2018 18.3 11/13/2018 17.9 12/10/2018 18.3 TDS (mg/L) 1700 1800 1930 NA 1980 NA 2010 2000 1980 2100 2000 1960 2090 Chloride (mg/L) 143 32.1 292 311 308 326 359 35 1 336 333 286 281 302 Selenium (ug/L) 86.81 89.3 88.7 N 90.2 NA 87.5 93.8 86.3 83.0 83.5 90.7 85.6 Uranium (ug/L) 9.1 1 1.4 11.2 11.4 11.5 11.5 12.9 12.3 11.7 11.0 11.6 13.2 12.7 Sulfate (mg/L) 697.60 835 NA 857 NA 976 857 841 893 950 841 905 . 36 (Class III) Field H (S.U.) 6.49 2 NS NA 3/7/2018 6.60 NS NA 4/11/2018 6.99 NS NA NS NA NS NA NS NA Re ' 10/3/2018 6.72 12/6/2018 7.08 NS NA NS NA )5 (Class II) Uranium (ug/L) 7.5 NS NA 2/16/2018 0.910 NS NA 4/10/2018 0.875 NS NA NS NA NS NA NS NA 9/11/2018 0.631 10/30/2018 0.618 NS NA NS NA 12 (Class III) Uranium (ug/L) 23.5 NS NA 3/2/2018 23.3 NS NA 4/10/2018 21.1 NS NA NS NA NS NA NS NA 9/12/2018 21.1 10/31/2018 20.9 NS NA NS NA 14 (Class III) Beryllium (ug/L) s _ NS NA 3/2/2018 1.69 NS NA 4/19/2018 2.78 NS NA NS NA NS NA NS NA 9/19/2018 1.68 10/24/2018 2.75 NS NA NS NA Cadmium (ug/L) 6.43 NA NA NA 6.97 NA NA NA NA 5.59 7.05 NA NA Fluoride (mg/L) 0.47 NA NA NA 0.324 NA NA NA NA NA 0.797 NA NA Nickel (mg/L) NA NA NA 49.5 NA NA NA NA NA 57.7 NA NA Thallium (ug/L) 2.01 NA NA NA 2.44 NA NA NA NA 2.18 2.63 NA NA Field pH (S.D.) 5.03 - 8.5 NA 5.89 NA 4.45 NA NA NA NA 5.30 5.09 NA NA 17 (Class 111) Nitrate + Nitrite (as N) (mg/L) 5.6 NS NA 2/21/2018 6.19 NS NA 4/18/2018 6.09 NS NA NS NA NS NA NS NA 9/12/2018 6.35 10/29/2018 8.69 NS NA NS NA Chloride (mg/L) 38 NA 32.4 NA 34.7 NA NA NA NA 35.6 28.9 NA NA 18 (Class III) Chloride (mg/L) 105 NS NA 2/21/2018 121 NS NA 4/19/2018 138 NS NA NS NA NS NA NS NA 9/12/2018 148 10/30/2018 119 NS NA NS NA Cadmium (ug/L) 5.2 NA 4.57 NA 4.99 NA NA NA NA 4.84 4.61 NA NA Gross Alpha (pCi/L) 2.42 NA NA NA 1.38 NA NA NA NA NA 2.55 NA NA Uranium (ug/L) 4.9 NA 3.94 NA 5.06 NA NA NA NA 7.04 6.18 NA NA 12 (Class III) Chloride (mg/L) 35.39 NS NA 2/16/2018 37.4 NS NA 4/10/2018 37.2 NS NA NS NA NS NA NS NA 9/5/2018 41.1 10/29/2018 33.7 NS NA NS NA Sulfate (mg/L) 2556.70 NA 2160 NA 2000 NA NA NA NA 2060 1800 NA NA 15 (Class II) Nitrogen. Ammonia as N 0.14 NS NA NS NA 4/10/2018 0.254 NS NA NS NA NS NA NS NA 9/10/2018 <0.0500 10/18/2018 0.117 NS NA NS NA ot Required and Not Sampled lot Applicable dances are shown in yellow ursuant to the January 19, 2018 GWDP these parameters were no longer in exceedance after January 19, 2018 and accelerated sampling was no longer required. The reset of the GWas allowed for the cessation of monthly sampling of these parameters after the issuance of the GWDP ing during the March monthly event. The exceedances noted during the first quarter event will begin accelerated monitoring with the June monthly event, as required by the revised GWDP. GWas were reset with the issuance of the January 19, 2018 GWDP. These parameters were no longer in exceedance and these accelerated samples were not required under the January 19, 2018 GWDP. These data were collected and are reported as required by Part 11.F of the GW 'Fable 1 - GWC1, Exceedances for Eir:t Quarter 2019 under the January 19, 2018 GWDP 01 2019 Results itoring Well Liter Classi Constituent Exceeding GWCL CWCL in January 19, 2018 GWDP Q I 2019 Sample Date Q1 2019 Result February 2019 Monthly Sample Date February 2019 Monthly Result March 2019 Monthly Sample Date March 2019 Monthly Result Required Quarterly Sampling Wells 1 (Class II) Manganese (ug/L) 164 67 1/15/2019 181 2/13/2019 211 .V6/2019 170 4 (Class III) Fluoride (mg/L) 0 2 1/17/2019 0.1 0 NS NA NS NA 5 (Class III) Cadmium (ug/L) 1.5 1/16/2019 1.32 2/12/2019 1.52 3/5/2019 1.54 Fluoride (mg/L) 0.42 0.302 NA NA Nitrate + Nitrite (as N) (mg/L) 0.62 2.21 0.967 3/6/2019 3.22 Chloroform (ug/L) 70 1200 1300 1290 Chloride (mg/L) 58,31 70.7 57.2 60.4 Methylene Chloride (ug/L) 5 3.24 1.91 1.45 Nitrogen, Ammonia as N 0.92 0.938 NA NA Field pH (S.U.) 5.61 - 8.5 6.43 6.25 6.77 0 (Class II) Nitrate + Nitrite (as N) (mg/L) 2.5 1/16/2019 17.9 2/13/2019 18.2 3/6/2019 16.2 Chloride (mg/L) 128 157 167 160 Selenium (ug/L) 47.2 48.6 NA NA Uranium (ug/L) 8.32 9.07 9.09 8.39 Field pH (S.U.) 6.47 - 8.5 6.60 6.46 6.97 I (Class III) Nitrate + Nitrite (as N) (mWL) 5 1/15/2019 19.0 2/12/2019 18.6 3/5/2019 18.5 TDS (m6/L) 1700 2030 2090 2160 Chloride (mg/L) 143 283 296 322 Selenium (ug/L) 86.81 89.7 88.5 91.1 Uranium (ug/L) 9.1 13.2 13.6 12.5 Sulfate (mg/L) 697.60 851 893 953 36 (Class III) Field pH (S.U.) 6.49 - 8.5 1/23/2019 6..15 NS NA NS NA Required Semi-Annual Sampling Wells 5 (Class II) Uranium (ug/L) 7.5 1/17/2019 0.557 NS NA NS NA 2 (Class III) Uranium (ug/L) 33 5 1/21/2019 23.6 NS NA NS NA 4 (Class III) Beryllium (ug/L) 2 1/23/2019 3.37 NS NA NS NA Cadmium (ug/L) 6.43 8.34 NA NA Fluoride (mg/L) 0.47 NA NA NA Nickel (mg/L) 50 NA NA NA Thallium (ug/L) 2.01 2.72 NA NA Field pH (S.U.) 5.03 - 8.5 4.63 NA NA 7 (Class III) Nitrate + Nitrite (as N) (me/L) 5.6 1/21/2019 6.40 NS NA NS NA Chloride (mg/L) 38 31.0 NA NA Chloride (mg/L) 105 127 NS NA NS NA Cadmium (ug/L) 5.2 4.76 NA NA Gross Alpha (pCi/L) 2.42 NA NA NA Uranium (ug/L) 4.9 7.12 NA NA 2 (Class III) Chloride (mg/L) 35.39 1/22/2019 35.6 NS NA NS NA Sulfate (mg/L) 2556.70 1950 NA NA -35 (Class 11) Nitrogen. Ammonia as N 0.14 1/16/2019 0.100 NS NA NS NA A Required and Not Sampled at Applicable lances are shown in yellow nt to the DWMRC letters of February 1, and March 5, 2019, these constituents will no longer be rnonitored on an accelerated schedule. These constituents dropped from this report after this quarter. 3Was were reset with the issuance of the March 19, 2019 GWDP. These parameters are no longer in exceedance as of March 19, 2019. These constituents dropped after this quarter.