DRC-2013-001149 - 0901a0688034558a

State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADL\TI0N CONTROL
Rusty Lundberg
Director
DRC-2OI3-001I49
MEMORANDUM
TO
THROUGH
FROM
DATE
SUBJECT
File
Phil Goble, Compliance Section Manager
Tom Rushing, PG I'B^^P
January 28, 2013
Review of the 2"'^ Quarter, 2012 (dated August 29,2012), and 3''* Quarter, 2012 (dated
November 26,2012) Groundwater Monitonng Reports, Groundwater Discharge Permit
UGW370004 - Energy Fuels Resources (USA) Inc , White Mesa Uranium Mill,
Blandmg, Utah
This is a summary of DRC staff review of the Energy Fuels Resources (USA) Lie (EFR) groundwater
monitonng reports for the 2"'* Quarter 2012 (Apnl - June) dated August 29,2012 (received by DRC on
August 30, 2012) and the 3''* Quarter 2012 (July - September) dated November 26, 2012 (received by
DRC on November 27,2012) The review included all sampling events and accelerated monitonng
dunng those quarters, as well as EFR Exceedence Nobces and Plan and Time Schedule documents
(wntten notificabon for momtonng exceedences) for the penods, as follows
1 July 27,2012, EFR Notice Pursuant to Part IG 1(a) second quarter ("Q2") groundwater monitonng,
2 November 15, 2012, EFR Notice Pursuant to Part IG 1(a) third quarter ("Q3") groundwater
monitonng, and,
3 December 13, 2012 Transmittal of Plan and Time Schedule under Utah Ground Water Discharge
Permit UGW370004 Part IG 4(d) White Mesa Mill, Relevant to Q3 violabons of Part IG 2 of the
Permit
1. Checklist of Significant Findings and Associated Actions at the White Mesa Uranium Mill
1 The subject Monitonng Reports were received by their respective due dates, September
1, 2012, and December 1, 2012, respectively
2 EFR proposes to prepare a Source Assessment Report (SAR) for Du-ector Review withm
90 days of Director approval of the 12/13/13 Plan and Time Schedule to address out-of-
compliance for TDS at momtonng well MW-29 Conditional approval by the Director is
recommended as discussed in the memo below
3 A May 25,2012 EFR Permit modification request was made in order to document
accelerated reporting and monitonng agreements made dunng a teleconference with the
Utah Division of Radiation Conti-ol (DRC) Per DRC staff discussions The May 25,
EFR White Mesa U-Mill 2"*^ and 3'** Qti^ Groundwater Momtonng Reports
DRC Review Memo
Page 2 of 16
2012 request will be included with the White Mesa Mill Ground Water Permit Renewal
(Currently in the application review process)
4 The EFR source assessment report for previously documented out-of-compliance
parameters (multiple parameters), required per Stipulated Consent Agreement, Docket
No UGW 12-03 was submitted to DRC, dated October 10,2012, and is currently under
DRC review
5 The EFR pH report, which evaluates monitonng wells out-of-compliance for pH,
required per Stipulated Consent Agreement, Docket No UGW 12-03 was submitted to
DRC, dated November 9,2012 and is currently under DRC review
6 The EFR pynte investigation report, required per Stipulated Consent Agreement, Docket
No UGW12-03 was submitted to DRC, dated December 7, 2012 and is currently under
DRC review
7 Two issues for advisory were noted by DRC dunng review of the field sheets for
groundwater monitonng dunng the review penod 1 Averages of field readings were not
recorded on the field sheet for momtonng well MW-14 dunng the 4/12/12 sampling, and,
2 "Final depth" recorded on the field sheet for monitonng well MW-24 dunng the
7/17/12 sampling was greater than the total design well depth
8 DRC noted that several groundwater samples were collected with a field turbidity
measurement greater than 5 NTU Per the current approved White Mesa Mill Quality
Assurance Plan Rev 7 2 (QAP) it is not required that the readings be below 5 NTU
Also, per DRC review of an EFR Well Development Report (dated September 30, 2011)
DRC staff found that turbidity greater than 5 NTU would not affect laboratory analysis of
the samples or quality of the sample results
9 Samples for the volatile organic compounds (VOCs) exceeded the QAP required sample
holding time for monitonng well MW-26 for the September 2012 accelerated momtonng
penod Monthly accelerated samples for chloroform and dichloromethane were invalid
for September 2012
10 EFR failed to collect a monthly accelerated sample for chloroform and dichloromethane
at well MW-26 durmg July, 2012 EFR states that the parameter had to be resampled due
to "poor agreement" between the MW-26 sample and the blind duplicate MW-65 sample
but the resample was not conducted until the following month
11 Several laboratory QA/QC flags were documented on the review penod analytical data
reports fi-om the contract laboratones Per DRC review it appears that all discrepancies
were self-reported by EFR and that none of the discrepancies are violations of Permit or
QAP
2. Accelerated Monitoring and POC Wells Exceeding GWCL
When a monitonng well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL) set
forth m 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 IG 1) When monitonng 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 IG 2)
In the event a constituent is m OOC status, EFR is required to 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
EFR White Mesa U-Mill 2"*^ and 3^'^ Qtr Groundwater Momtonng Reports
DRC Review Memo
Page 3 of 16
quality to insure that Permit limits will not be exceeded at the compliance monitonng pomt and that DMT
or BAT will l?e reestablished, in accordance with Part IG 4(c) of the Permit
The DRC 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 monitonng at well MW-3 5
EFR stated in a March 26,2012 response to the NOED that based on an agreement made between DRC
and EFR dunng a telephone conference call on Apnl 5, 2010, EFR is not required to implement
accelerated monitonng until ^'the month following the submission of the Exceedence Notice for a specified
quarter " Based on DRC review of notes taken durmg the Apnl 5, 2010 telephone conference (Loren
Morton 4/5/10,0900), EFR verbally requested to wait until the end of the quarter to send in the notice of
out-of compliance status - but withm 30 days of the last lab report that EFR receives for the quarterly
monitonng event
DRC notified EFR by letter (dated Apnl 16, 2012) that in order to formalize the Apnl 5,2010 discussion
items related to out-of-compliance reporting and sampling, a wntten request for a groundwater permit
modification (groundwater permit, out-of-compliance notification and accelerated monitonng
requirements) is required for Director review and approval
EFR submitted a May 25,2012 wntten request for a Permit modification, includmg redline copies of
pertinent pages of the Permit to reflect the agreements made dunng the Apnl 5,2010 conference call
The Permit modification request is currently under DRC review and is pending modification In the
intenm, DRC is hononng the teleconference agreements and is not pursumg Permit enforcement based on
EFR failure to meet the current time and schedule submission requirements
In the tables listed below are monitonng wells with parameters currently in accelerated OOC or POOC
status
Table 1 - Wells Monitored Quarterly Accelerated to Monthly Monitoring
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitonng First
Required
MW-11 Class n water D-3 Manganese February 2010 May 2010
MW-14 Class III water D-4A Field pH
Manganese
February 2010
2"** Quarter 2012
May 2010
August 2012
MW-25 Class III water C-3 Field pH
Uranium
4"" Quarter 2010
September 2010
January 2011
January 2011
MW-26^'^ Class in water C-2
Field pH
Niti-ate -1- Nitiite (as N)
Chloroform
Uranium
Chlonde
Dichloromethane
TDS
February 2010
February 2010
February 2010
February 2010
February 2010
Apnl 2010
September 2010
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
January 2011
MW-30 Class n water D-2
Niti-ate + Nitiite (as N)
Chlonde
Selenium
Uranium
February 2010
Quarter 2011
Apnl 2010
4* Quarter 2011
May 2010
May 2011
July 2010
March 2012
EFR White Mesa U-Mill 2"** and 3'^ Qtr Groundwater Momtonng Reports
DRC Review Memo
Page 4 of 16
Well Class •Position Parameter Date of Fnst
Exceedance of
GWCL
Date Accelerated
Monitonng First
Required
Field pH 2"''Qti 2011 July 2011
MW-31 Class in water D-2
Nitiate + Nitiite (as N)
Chlonde
Sulfate
TDS
Field pH
Selenium
February 2010
Quarter 2011
4* Quarter 2010
September 2010
2nd Quarter 2011
3'^ Quarter 2012
May 2010
Apnl 2011
January 2011
January 2011
July 2011
December 2012
MW-35 Class n C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
2nd Quarter 2011
2nd Quarter 2011
3'^ Quarter 2011
3'^ Quarter 2011
3'** Quarter 2012
July 2011
July 2011
October 2011
October 2011
December 2012
D = Down-gradient, U = Up-gradient, C = Cross-gradient, 1,2,3,4A = Cell #
a = Monitonng 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
Monitonng First
Required
MW-2 Class ni water C-3 Adjusted Gross Alpha 4"^ Quarter 2010 Quarter 2011
MW-3 Class in water D-4A
Selenium
Field pH
Fluonde
2"''Quarter 2010
2°'* Quarter 2010
2"'* Quarter 2010
3'" Quarter 2010
3''* Quarter 2010
3'** Quarter 2010
MW-3A Class in water D-4A
Field pH
Sulfate
TDS
Selenium
2"" Quarter 2010
2"** Quarter 2010
2*"* Quarter 2010
4* Quarter 2010
3'''Quarter 2010
3"* Quarter 2010
3'*^ Quarter 2010
Quarter 2011
MW-5 Class n water D-3 Uranium 4"^ Quarter 2010 Quarter 2011
MW-12 Class in water D-3 Field pH
Selenium
4"" Quarter 2010
2°^ Quarter 2010
Quarter 2011
3"* Quarter 2010
MW-15 Class in water D-4A Iron
Selenium
4"" Quarter 2011
2"^* Quarter 2012
V Quarter 2012
3'^ Quarter 2012
MW-18 Class in water U-1
Thallium
Field pH
Sulfate
TDS
Quarter 2010
2"^^ Quarter 2010
2"^^ Quarter 2010
2"''Quarter 2010
2"''Quarter 2010
3'*^ Quarter 2010
3"^ Quarter 2010
3"^ Quarter 2010
MW-19 Class ni water U-1 Field pH
Nitiate + Nitnte as N
2"'* Quarter 2010
4* Quarter 2011
3'" Quarter 2010
1''Quarter 2012
MW-23 Class in water D-3 Field pH
Manganese
2"''Quarter 2010
4* Quarter 2011
3"* Quarter 2010
Quarter 2012
MW-24 Class in water D-1
Cadmium
Thallium
Field pH
2"''Quarter 2010
2°'* Quarter 2010
2°^* Quarter 2010
3'^ Quarter 2010
3"" Quarter 2010
3'^^ Quarter 2010
MW-27 Class in water U-1 Nitiate + Nitiite (as N) 2°'* Quarter 2010 3"* Quarter 2010
EFR White Mesa U-Mill 2"*^ and 3''^ Qti" Groundwater Momtonng Reports
DRC Review Memo
Page 5 of16
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitonng First
Required
Adjusted Gross Alpha
Sulfate
TDS
Chlonde
Field pH
4"^ Quarter 2010
2"^* Quarter 2010
Quarter 2010
Quarter 2010
3'^ Quarter 2011
V Quarter 2011
3'^* Quarter 2010
2"'' Quarter 2010
2"''Quarter 2010
4* Quarter 2011
MW-28 Class in water D-1
Field pH
Chlonde
Manganese
2"'* Quarter 2010
2"^* Quarter 2010
2'^''Quarter 2012 OJ O
J O
J
a a
a

SS
S
q q
q

to t
o t
o
oo
o
to o
o

MW-29 Class ni water D-2
Field pH
Iron
Manganese
TDS
4"^ Quarter 2010
2"^* Quarter 2011
2"^* Quarter 2012
2"'*Quartr2012
Quarter 2011
3"* Quarter 2011
3'^* Quarter 2012
3"* Quarter 2012
MW-32 Class in water C-2 Adjusted Gross Alpha
Field pH
2°'Quarter 2010
2""* Quarter 2010
3'''Quarter 2010
3"* Quarter 2010
* D = Down-gradient, U = Up-gradient, C = Cross-gradient, 1, 2, 3, 4A = Cell #
Table 1 above is a comprehensive list of all Groundwater Monitonng Wells in Accelerated Status EFR is
required to notify the DRC on a quarterly basis regarding wells and parameters which went into
accelerated monitonng durmg the penod [Part IG 1(a), [Accelerated Monitoring Status Reports
(AMSR)] For the two quarters of monitonng reviewed, the reports have been received as follows
1 AMSR received for the 2"^* Quarter Report, dated July 27,2012 and received by DRC on July 30,
2012
2 AMSR received for the 3rd Quarter Report, dated November 15,2012 and received by DRC on
November 16, 2012
Note that DRC review of the report completeness and agreed upon investigations and actions between
DRC and EFR regarding parameters/wells currently in OOC status, including dates of agreements and
documents are detailed m section 6 below EFR and the Director entered into a Stipulated Consent
Agreement, specifying corrective actions for the OOC parameters, based upon agreed upon study
objectives and activities Based upon language in the subject AMSR's as agreements between DRC and
EFR, current parameters which are under re-evaluation according to the agreed upon actions are included
in the Stipulated Consent Agreement and do not require specific corrective actions to be listed in the
AMSR with the exception of TDS in Well MW-29
One new OOC well/parameter is noted for the reviewed reports. Well MW-29 TDS EFR has requested
that the Director approve m the Plan and Time Schedule study submitted by EFR on December 13,2012
(Plan and Time Schedule to investigate the OOC status), and received by DRC on December 14, 2012
This Item is discussed m section 5 of this memo below
3. FaUure to Collect Required Ground Water Samples at Well MW-26 during the 3"* Quarter
2012
The following failures to collect compliance groundwater samples were noted by DRC dunng review of
the 3"* Quarter 2012 Report as follows
EFR White Mesa U-Mill 2"*^ and 3''' Qtr Groundwater Momtonng Reports
DRC Review Memo
Page 6 of 16
1 Samples for the volatile organic compounds (VOCs) exceeded the QAP required sample
holding time for momtonng well MW-26 for the September 2012 accelerated momtonng
penod Therefore, monthly accelerated samples for chloroform and dichloromethane
were invalid for September 2012 Violation of Ground Water Discharge Permit No
UGW370004 Part IG 1 b and Part IG 4 b
2 EFR failed to collect a monthly accelerated sample for chloroform and dichloromethane
at well MW-26 dunng July, 2012 EFR states that the parameter had to be resampled due
to "poor agreement" between the MW-26 sample and the blind duplicate MW-65 sample,
however, the resample was not collected dunng the required month Violation of Ground
Water Discharge Permit No UGW370004 Part IG 1 b and Part IG 4 b
These issues were also identified by EFR and included in the 3"* Qti Report narrative Causes of the
violations, as per EFR, for each of the violations was as follows
Violation 1 - This violation is discussed in section 4 0 of the 3"* Qti Report, per the Report the "deviation
was due to laboratory error EFR was not informed by the laboratory of the holding time issue until
October 12, 2012 which prevented resampling of the September monthly compliance sample " EFR notes
that laboratory had "more than sufficient time" to analyze the sample within the required holding time and
determines that the corrective action will be to change contiact laboratones
• DRC notes that EFR has included results for VOCs at well MW-26 for the September, 2012
event on the monitonng data tables, even though they were analyzed outside of required holding
time DRC will request that the data be removed from the tables since it is invalid
Violations 2 and 3 - These violations are discussed in section 2 1 1 of the 3'^ Qti Report EFR states
''''MW-26 and MW-65 (duplicate of MW-26) were resampledfor volatile organic compounds ("VOCs ")
due to a laboratory issue which resulted in poor agreement between the sample (MW-26) and the
duplicate (MW-26)
• DRC notes that EFR does not identify violations 2 and 3 (as violations) and does not mclude
corrective action with the 3"* Qti 2012 Report
4. Summarv of July 27,2012,2°" Quarter 2012 Data Results AMSR:
New Accelerated Well or Start OOC Status and Parameter:
Semi-Annual Baseline to Quarterly Accelerated:
MW-15 - Selenium
MW-28 - Manganese
MW-29 - Manganese
MW-29-TDS
Semi-Annual Wells with Two Successive Exceedances beginning Q2 (Out of Compliance)
None
EFR White Mesa U-Mill 2"*^ and 3''^ Qti* Groundwater Momtonng Reports
DRC Review Memo
Page 7 of 16
Quarterly Baseline to Monthly Accelerated:
MW-14 - Manganese
Quarterly Wells with Two Successive Exceedances beginning Q2 (Out of Compliance)
None
5. Summarv of November 15, 2012,3'^'' Quarter 2012 Data Results AMSR:
New Accelerated Well or Start OOC Status and Parameter:
Semi-Annual Baseline to Quarterly Accelerated:
None
Semi-Annual Wells with Two Successive Exceedances beginning QI (Out of Compliance)
MW-29 - TDS
Quarterly Baseline to Monthly Accelerated:
MW-31 - Selenium
Quarterly Wells with Two Successive Exceedances beginning QI (Out of Compliance)
None
Based on DRC review of the monitonng accelerations and OOC status, and with consideration of the May
25,2012 EFR Permit modification request, it appears that EFR has appropnately identified momtonng
exceedances as well as required follow up actions /
The December 13,2012 EFR Plan and Time Schedule document for 2 consecutive (OOC) exceedances of
TDS at monitonng well no MW-29, proposes the following follow up action for approval by the
Director
1 A geochemical analysis of TDS in MW-29
Comparison of calculated and measured TDSfor samples with complete major ions
Charge balance calculations
Descriptive statistics
Box plots to identify extreme outliers
Histograms and Shapiro Wilk test for normality
Regression or Mann Kendall trend analysis
Proposed Revised GWCL for TDS in MW-29
2 A geochemical analysis of Indicator Parameters in MW-29
Descriptive Statistics
Box plots to identify extreme outliers
EFR White Mesa U-Mill 2""^ and 3'"^ Qti" Groundwater Momtonng Reports
DRC Review Memo
Page 8 of 16
Histograms and Shapiro Wilk test for normality
Regression and/or Mann Kendall trend analysis
The EFR December 13,2012 Plan and Time Schedule argues that the increasing tiend m TDS is likely
due to background fluctuation and is not due to tailings cell leakage based on associated decreasing tiends
in chlonde, fluonde and sulfate ground water concentiations at well MW-29 EFR proposes as a first step
in the analysis of the TDS mcreasmg tiend will be to conduct a geochemical analysis of indicator
parameters of the MW-29 groundwater to determine if the "behavior" of chemical constituents has
changed since the time of the New Wells Background Report If, based on this analysis, the TDS is
concluded to be the result of background fluctuations then EFR will provide a statistical analysis of TDS
data from MW-29 using the methods descnbed in the Existing Wells Background Report (INTERA,
2007a) and the Director approved flow sheet for statistical analysis of groundwater data at the White
Mesa Uranium Mill
EFR agrees to provide the "Source Assessment Report" (SAR) according to activities listed m the
December 13,2012 Plan and Time Schedule within 90 days after approval by the Director
It IS recommended that DRC approve the EFR December 13,2012 SAR with the following conditions
1 The SAR for TDS at groundwater monitonng well MW-29 will include all stiidy
elements and report structure of the October 10,2012 EFR Source Assessment Report
(approved by the Director through Stipulated Consent Agreement UGW 12-03), including
graphs, plots and charts
2 The SAR will be submitted on or before 90 days fi-om EFR receipt of the conditional
approval letter
6. Stipulated Consent Agreement Docket No. UGW12-03 Regarding Studies for Groundwater
Monitoring OOC Parameters and Decreasing pH Trends
Stipulated Consent Agreement Docket Number UGW 12-03 (SCA) was duly executed by the DRC
Director and the EFR Vice President and Counsel on July 12,2012 The SCA was executed in order to
provide formal approval of three Plan and Time Schedule Documents, including follow-up actions and
timelines, m order to investigate and resolve multiple parameters m out-of-compliance status for several
ground monitonng wells at the White Mesa Uranium Mill Facility (See Table 1 Above)
Specifically the SCA provides approval for EFR Plan and Time Schedule documents dated June 13,2011,
September 7,2011 and Apnl 13,2012 The Apnl 13,2012 Plan and Time Schedule addresses stiidies,
actions, and timelmes in order to investigate decreasing pH tiends which have been identified at several
monitonng wells across the site
Three types of study will be mcluded
1- Geochemical Analysis
2- Mass Balance
3- Hyrogeologic analysis for wells distant fi-om the Mill's tailings cells
Geochemical Analysis Study to evaluate "indicator constituents" to determine changes in behavior for
each well since the date of the Existing Wells Background Report
EFR White Mesa U-Mill 2"'' and 3'*^ Qti" Groundwater Monitonng Reports
DRC Review Memo
Page 9 of 16
Mass Balance Analysis Evaluation of concentiation m the groimdwater in companson with the Mill
tailings and an evaluation of any mounding at the location of the well m question
Hydrogeologic Analysis Evaluation to determine the plausibility of impact fi-om Mill tailings
The purpose of these studies is to "evaluate the behavior of all the constituents m the well in question to
determine if there are any changes in the behavior" of applicable constituents as compared with past
studies as cited in the EFR Plan and Time Schedules
If significant changes are identified then EFR will propose to the Executive Secretary further analysis to
identify the source and the extent of the contamination
If no significant changes are identified then EFR will propose changes to the GWCL's for the wells and
constituents of concem The SCA requires that any proposed revised GWCL is calculated in accordance
with the logic flow diagram included in the background study reports (INTERA 2007)
For ground water monitonng wells that are showing decreasing pH tiends, EFR will additionally conduct
sampling of existing well core to determine if the hypothesized cause being dissolution of iron pynte in
the mineral matnx of the Burro Canyon Aquifer is potentially the cause of such decreasing tiends
Agreed upon well core samples will be visually examined by XRF screening and will also be submitted
for bench analysis of iron pynte concentiation (% of mineral matnx)
DRC received the study documents as required by the Stipulated Consent Agreement UGW 12-03 as
follows
1 EFR submitted the '''Source Assessment Report for the White Mesa Uranium MilF dated October
10, 2012 and received by DRC on October 12,2012
2 EFR submitted the pH Report for the White Mesa Mill on November 9,2012 and received by
DRC on November 13, 2012
3 EFR submitted the Pynte Investigation Report for the White Mesa Mill on December 7,2012 and
received by DRC on December 10,2012
DRC review of these documents is pending No additional action is recommended regardmg the
compliance parameters, included in the SCA, until review of the submitted documents has been
completed Additional actions will be conducted under separate review of those documents and may
include Director Approval of modified GWCL's based on source assessments and statistical tests
7. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection
As stated in Section 6 2 7(d)(v) of the DUSA Quality Assurance Plan (QAP), Rev 6 which was m effect
dunng the 2"'' Quarter monitonng penod, two casing volumes must be evacuated fi-om the well before the
sample is collected (unless purged to dryness) The DUSA QAP directs DUSA to first calculate the
amount of time to evacuate two casing volumes and then pump for that length of time
As stated in Section 6 2 7 of the EFR Quality Assurance Plan (QAP), Rev 7 2 which was in effect dunng
the 3"* Quarter monitonng penod, EFR has a choice regarding purge volumes as follows
"7 Purging three well casing volumes with a single measurement offield parameters
EFR White Mesa U-Mill 2"'' and 3'*^ Qtr Groundwater Monitonng Reports
DRC Review Memo
Page 10 of 16
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 DRC review of the reports the followmg methods were used for each Quarter (includmg accelerated
samples)
Quarter # Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes
2"''2012 39 8
3"* 2012 25 5 4 (continuous pumping)
When purging two casing volumes EFR QAP versions 6 and 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 DRC 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 casing volumes (when 2 casing volume method selected) in
monitonng wells pnor to sample collection dunng the 2"'* Quarter 2012 and 3"^ Quarter 2012 monitonng
penods
In cases where wells are evacuated to dryness the QAP Rev 7 2, applicable to 3"* Quarter 2012 sample
collection 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 ofpH, specific conductance and temperature are not within 10% RPD, dispose of
the sample aliquots, and purge the well again as descnbed 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 submitted for analysis "
DRC venfied that in cases where the momtonng well was evacuated to dryness, the number of gallons
evacuated was recorded for the 1^^ Quarter 2012 in compliance with the QAP Rev 6 which applied to the
EFR White Mesa U-MiU 2"^^ and 3'^^ Qtr Groundwater Momtonng Reports
DRC Review Memo
Page 11 of 16
quarter sampling Also, DRC venfied that depth to groundwater was measured and recorded (comments
field) on the field sheet
DRC venfied that in cases where the momtonng well was evacuated to dryness dunng the 3^'* Quarter
2012 that the requirements per the QAP Rev 7 2 (listed above) were followed DRC noted that EFR
additionally recorded field readings directly after the purge
DRC identified the followmg issues regarding well sampling sheets dunng the 2^^ Quarter 2012
Well No Purge Date Issue 1
MW-14 4/12/12 Averages of field readings were not recorded on the field sheet
DRC identified the followmg issues regarding well sampling sheets dunng the 3^'' Quarter 2012
Well No Purge Date Issue- 1
MW-24 7/17/12 Final depth recorded on field sheet is greater than the design well depth
8. Groundwater Samples Collected with Turbidity Measurement >:S NTU
As stated in Section 6 2 7(d)(v) of the EFR QAP Rev 6 " turbidity measurement in the water should
be <5 NTU prior to sampling unless the well is characterized by water that has a higher turbidity " This
language was removed fi-om the QAP under Rev 7 2
Dunng the 2"** and 3"* Quarters 2012 monitonng events, there were 20 compliance well samples with
readings above 5 NTU's as follows
Table 2 - Groundwater Samples Collected with Turbidity Measurement ^ NTU
Groundwater
Momtonng Event Well Turbidity, NTU
2"** Qtr, 2012 MW-01 ^'^ 55
T"^ Qtr, 2012 MW-12^'^ 16 0
2'^ Qtr, 2012 MW-17^'^ 11 5
2"" Qtr, 2012 MW-20 ^'^ 488
2"" Qtr, 2012 MW-22 ^'^ 15 1
2"" Qtr, 2012 MW-23 ^'^ 108
2"" Qtr, 2012 MW-26 ^'^ 15 1
2"" Qtr. 2012 MW-29 ^'^ 125
2"'* Qtr, 2012 MW-32 ^'^ 44
2"" Qtr, 2012 MW-25 Accl ^'^ 445
2"'* Qtr, 2012 MW-31 Accl 283
2"** Qtr, 2012 MW-31 Accl ^'^ 26
3"^ Qtr, 2012 MW-12 11 6
3''* Qtr, 2012 MW-23 160
3'" Qtr, 2012 MW-25 11 5
3'** Qtr, 2012 MW-29 21 3
3'** Qtr, 2012 MW-29 14 0
3'" Qtr, 2012 MW-32 66
3''* Qtr, 2012 MW-37 23 2
3'" Qtr, 2012 MW-31 Accl 87
Footnotes
'Data for this well was obtained from Tab B of the 2"^ Quarter 2012 Groundwater Momtonng Report
^Data for this well was obtained from Tab B of the 4* Quarter 2012 Groundwater Momtonng Report
EFR White Mesa U-Mill 2"'' and 3'*' Qti- Groundwater Momtonng Reports
DRC Review Memo
Page 12 of 16
EFR undertook a redevelopment project for groundwater monitonng wells dunng calendar years
2010/2011, m response to a DRC letter dated June 1,2010 A redevelopment report was prepared and
submitted to DRC on September 30,2011 (Received by DRC on October 3,2011) which was reviewed
by DRC
Per the DRC review memo dated November 6,2012 a summary was provided regardmg DRC interaction
with independent laboratones regarding the effect of turbidity measurements above 5 NTU on laboratory
methods included m the QAP Per the review, PRC found based on the above information turbid
samples > 5 NTU should not affect analysis for the monitoring parameters required in the QAP " It is
noted that the high NTU would affect only the nutnent and background parameters since other samples
are field filtered
Based on the updated QAP language (Rev. 7 2) and DRC Redevelopment Report findings, the turbidity
readings are not m violation of the Permit or current approved QAP
9. Relative Percentage Difference Calculations for Blind Duplicate Analvsis
DRC conducted a review of the blmd duplicate samples collected dunng each of the monitonng quarters
Per the facility QAP, one blind duplicate must be collected with each sample batch DRC confirmed that
one blind duplicate was collected for each batch
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 m the QAP Rev 7 2 Part 9 1 4, if any of the samples do not meet the companson
cntena (and are not qualified according to the 5 times method detection limit cntena) 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 transcnption 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
The results of the 2"** Quarter of 2012 (MW-26/MW-65 5/7/2012) blind duplicates for Fluonde did not
meet the 20% cntena (RPD value was 20 69%) DRC notes that the nonconformance was identified by
EFR m Section 3 4 7 of the 2"** Quarter Monitonng Report, as well as on Table G7-A in appendix G of the
report Per the EFR Report "The sample results reported for MW-18/MW70 were not five times greater
than the reporting limit of 30 and as such the deviation from the 20% RPD requirement is acceptable "
Per DRC review of the results for the 3"* quarter of 2012 blind duplicates, all results appear to be within
the 20% RPD requirement
Per DRC review, the EFR blind duplicate compansons and explanations seem appropnate m the 2"^^ and
3"* Quarter Momtonng Reports
EFR White Mesa U-Mill 2"^^ and 3'*^ Qtr Groundwater Momtonng Reports
DRC Review Memo
Page 13 of 16
10. Analytical Laboratories Used by EFR Certified bv State of Utah to Perform Analvsis for all
Analytes
The analytical laboratones (Energy Laboratones, Casper, WY and Amencan West Analytical
Laboratones, Salt Lake City, UT) were contiacted by EFR to perform analysis on the samples collected
dunng the 4* Quarter, 2011 and 1'^ Quarter 2012 Per DRC review of the National Environmental
Laboratory Accreditation Management System Website (cross check of laboratory certification for
specific parameters) it appears that the EFR contiact laboratones were certified to perform analysis for
the specified parameters dunng the review penod as follows
The Bureau of Laboratory Improvement - Energy Laboratones Utah Certification current valid through
1/15/2013 for affected parameters and including the time penod of analyses for the reviewed reports
The Bureau of Laboratory Improvement ~ Amencan West Analytical Utah Certification current valid
through 1/4/2013 for affected parameters and including the time penod of analyses for the reviewed
reports
11. Laboratory Report Turn Around Times
Per DRC review of EFR Table 1 included m the 2"^* and 3"* Qti 2012 Reports, it was noted that laboratory
report tumaround times (fi-om date of EFR sample submission to the contiact laboratory) was generally in
the range of 1 month, with longest turnaround times of 2 months There is not a tumaround requirement
in the current QAP, therefore, current tumaround times are judgment based DRC has raised concem
over excessive laboratory tum-around times and the Director may require a tum-aroimd date be included
m the facility QAP if additional concems are noted The tum-around times in the 2"** and 3"* Quarter
reports appear to be reasonable
12. Laboratory QA/QC Flags - 2"" Quarter 2012
QA/QC issues and DRC findings for the 2"^ Quarter 2012 are summanzed below
Non-C6ipi|toance'
jden#fied'?
I^FI^prectiveAc^
^Summary .
^DRCFfflmgs y-V
Routine Reporting Limit
Check found discrepancy
regarding some parameters
which were raised due to
dilution of the sample
(sample matnx interference)
Y Discrepancies were reported Raising RL's due to
sample matnx is
common It may be
appropnate to raise the
RL's m the facility QAP
Multiple Momtonng Wells
with Counting Errors > 20%,
Gross Alpha
Y EFR Venfied that data
results were below the
GWCL
Sum of the activity
concentiation and error
term result was <GWCL
Matnx Spike outside of
laboratory recovery limits
for several monitonng wells,
THF, Ca, Mg, Na, Mn, Ag,
Se, Acetone, MEK and U
Y Recorded Discrepancies m
Appendix G
Recovenes vaned but
were qualified by the
laboratory, no range
required by current QAP
Surrogate Recovenes outside Y Recorded Discrepancies in MS Recovenes vaned.
EFR White Mesa U-Mill 2"'' and 3'^^ Qti- Groundwater Momtonng Reports
DRC Review Memo
Page 14 of 16
of laboratory limits for p-
Bromofluorobenzene at
several monitonng wells
Appendix G qualified by the
laboratory, no range
required by current QAP
Method Blank detections
above QAP required RL for
Bicarbonate
Y Recorded Discrepancies in
Appendix G and discussion
in section 3 4 9 of the Report
"QAP Revision 7 2 states
that non-conformance
conditions will exist when
contaminant levels in the
samples are not order of
magnitude greater than the
blank result"
DRC notes that blank
compansons are mcluded
in part 9 1 3 of the current
QAP Rev 7 2 Data
appears to be qualified, >
than an order of
magnitude for affected
samples
LCS Recovery outside of
laboratory acceptance range
for Methyl Ethyl Keytone
and Acetone
Y Recorded Discrepancies in
Appendix G
No QAP required range,
data was qualified by the
laboratory
Note
13.
DRC reviewed the holdmg time summary chart, no exceedances of holding times were noted
DRC reviewed the temperature check charts, all sample batches were received by the laboratory
^°C
Laboratory QA/QC Flags - 3"* Quarter of 2012
QA/QC issues and DRC findings for the 3*^^ Quarter 2012, as summanzed by EFR, below
Non-Confoonance ^
sSmW^' *'
Self-
Identif^*?
0^ Co|i^e Action ^ p
^Summary
fD^lpidmgf .=^.1,.
Routine Reporting Limit
Check found discrepancy
regardmg some parameters
which were raised due to
dilution of the sample
(sample matnx
interference)
Y In all cases the reported
value for the analyte was
higher than the increased
detection limit Data
qualified by a "D" flag
Raising RL's due to
sample matnx
interference appeared
to be appropnate and
acceptable based on
data results
Low Matnx Spike
Recovenes for several
sample parameters
Y Recorded the
Discrepancy in the
laboratory reports and
section G of the report
No requirements in
current approved QAP
Low Surrogate Recovery
for p-Bromofluorobenzene
Y Recorded the
Discrepancy
No requirements m
current approved QAP
Method Blank Bicarbonate
concentiations reported
above the QAP required
RL
Y Recorded Discrepancies
in Appendix G and
discussion in section
3 49of the Report "g^P
Revision 7 2 states that
non-conformance
conditions will exist when
contaminant levels in the
DRC notes that blank
compansons are
included m part 9 1 3 of
the current QAP Rev
7 2 Data appears to be
qualified, > than an
order of magnitude for
affected samples
EFR White Mesa U-Mill 2"^* and 3'*^ Qtr Groundwater Monitonng Reports
DRC Review Memo
Page 15 of 16
^»C(IBbriri»ce
.iSummars^t
Self- ft,..
IdentSj^
El^Jorrecti ve #c]^on
Sunanai^ • , -. -tl; -..
PgRCFl^^gS'^lJ:^^
samples are not order of
magnitude greater than
the blank result"
High Recovery for Gross
Alpha LCS
Y Recorded the
Discrepancy
No requirements in
current approved QAP
High Matiix Spike %
Recovery for Nitiate
Nitnte as N
Y Recorded Discrepancies
m Appendix G
No QAP required
range, data was
qualified by the
laboratory
Note DRC reviewed the holding time summary chart, no exceedences of holding times were noted
DRC reviewed the temperature check charts, all sample batches were received by the laboratory
^°C
14. Review of Time-Concentration Plots
The Permit Part IF 1 g requires EFR to subrmt Time-Concentiation Plots for each monitonng well for
chlonde, fluonde, sulfate and uranium
Per DRC review of the Time-Concentiation Plots for the 2"** Qti 2012 and 3"* Qti 2012 it appears that all
issues which were reported and discussed dunng previous DRC review (r*, 2"**, and 3"^^ Qti's 2011
Reports) have been resolved Specifically, EFR is no longer culling data fi-om the plots based on the EFR
findings that certain concentiations are outliers DRC requested that EFR plot all ground water data
histoncally and it appears that the plots are representative of the data
DRC notes that per the discussions with EFR it was agreed to that EFR need not plot tiend lines on the
Time Concentiation Plots. Therefore, the plots no longer mclude tiend lines The reviewed plots appear
to be in conformance with the agreed upon changes
15. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DRC cross checks of groundwater elevation measurement calculations used for the 2"*^ Quarter 2012
and 3'** Quarter 2012, approximately 5% of wells cross checked, companng well as built groundwater
elevation data with current depth to water measurements, no errors were found DRC noted that
groundwater elevations appeared stable and in conformance with histoncal levels dunng the review
penods No effects regardmg dewatenng of the upper wildlife ponds were noted on local groundwater
mounding
16. Violations Where a Notice of Violation and Order is Recommended per Report Reviews
1 Samples for the volatile organic compounds (VOCs) exceeded the QAP required sample
holding time for monitonng well MW-26 for the September 2012 accelerated monitonng
penod Monthly accelerated samples for chloroform and dichloromethane were mvalid
for September 2012 Violations of Ground Water Discharge Permit No UGW370004
Part IG 1 b and Part IG 4 b
EFR White Mesa U-Mill 2"*^ and 3''' Qti- Groundwater Monitonng Reports
DRC Review Memo
Page 16 of 16
2 EFR failed to collect a monthly accelerated sample for chloroform and dichloromethane
at well MW-26 durmg July, 2012 EFR states that the parameter had to be resampled due
to "poor agreement" between the MW-26 sample and the blind duplicate MW-65 sample,
however, the resample was not collected dunng the required month Violations of Ground
Water Discharge Permit No UGW370004 Part IG 1 b and Part IG 4 b
17. Conditional Approval Recommended per Report Review
It IS recommended that the Director conditionally approve the "Source Assessment Report" (SAR)
according to activities outlined in the December 13,2012 Plan and Time Schedule, with the following
conditions
1 The SAR for TDS at groundwater monitonng well MW-29 will include all study
elements and report stmcture of the October 10,2012 EFR Source Assessment Report,
including graphs, plots and charts
2 The SAR will be submitted on or before 90 days fi-om EFR receipt of the conditional
approval letter
18. Advisories Recommended per Report Reviews
Two issues for advisory were noted by DRC dunng review of the field sheets for groimdwater monitonng
dunng the review penod 1 Averages of field readings were not recorded on the field sheet for
monitonng well MW-14 during the 4/12/12 sampling, 2 "Final depth" recorded on the field sheet for
monitoring well MW-24 dunng the 7/17/12 sampling was greater than the total well depth
19. References
* Energy Fuels Resources (USA) Inc , July 27, 2012, Notice Pursuant to Part IG l(aj Q2, 2012
^Energy Fuels Resources (USA) Inc , August 29, 2012, T'^ Quarter 2012 Groundwater Monitoring
Report Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill
^ Energy Fuels Resources (USA) Inc , December 13,2012, Notice Pursuant to Part IG 4(d) Q3, 2012
Energy Fuels Resources (USA) Inc , November 26, 2012,5'^^ Quarter 2012 Groundwater Monitonng
Report Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill
^ Energy Fuels Resources (USA) Inc , March 22,2010, White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP), Revision 6
^Energy Fuels Resources (USA) Inc , June 6,2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 7 2
^Utah Department of Environmental Quality, Division of Radiation Control, Ground Water Discharge
Permit, Permit No UGW370004, Denison Mines (USA) Corp