DRC-2013-002255 - 0901a0688037d7ea

M DRC-2013-002255 II
Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
MEMORANDUM
TO File
THROUGH Phil Goble, Compliance Section Manager
FROM Tom Rushing, PG ffl S
DATE May 15,2013
SUBJECT Review of the 4th Quarter, 2012 (dated February 26,2013) Groundwater Momtonng
Report, Groundwater Discharge Permit UGW370004 - Energy Fuels Resources (USA)
Inc , White Mesa Uranium Mill, Blanding, Utah
This is a summary of DRC staff review ofthe Energy Fuels Resources (USA) Inc (EFR) groundwater
monitonng report for the 4th Quarter 2012 (Oct -Dec ), dated February 26, 2013 (received by DRC on
February 27, 2013) The review included all sampling events and accelerated monitonng dunng the
quarter, as well as EFR Exceedance Notices and Plan and Time Schedule documents (wntten notification
for momtonng exceedances) for the period, as follows
1 Energy Fuels Resources (USA) Inc , February 15, 2013, Notice Pursuant to Part IG 4(d) Q4,
2012
2 Energy Fuels Resources (USA) Inc , March 14, 2013, Transmittal of Plan and Time Schedule
under Utah Ground Water Discharge Permit UGW370004 Part IG 4(d) White Mesa Uranium
Mill
1. Checklist of Significant Findings and Associated Actions at the White Mesa Uranium Mill
1 The subject Monitonng Report was received by the due date, March 1,2013
2 A May 25, 2012 EFR Permit modification request was made m order to document
accelerated reporting and monitonng agreements made dunng a teleconference with the
Utah Division of Radiation Control (DRC) Per DRC staff discussions The May 25,
2012 request will be included with the White Mesa Mill Ground Water Permit Renewal
(Currently in the application review process) DRC review ofthe 4th Quarter 2012
Report recognized the telephone agreements regarding timelines for EFR to submit
compliance notices
3 The EFR source assessment report for previously documented out-of-compliance
parameters (multiple parameters), required per Stipulated Consent Agreement, Docket
No UGW12-03 was submitted to DRC, dated October 10, 2012 Per DRC review
findings as documented in a DRC review memo dated April 23, 2013 and transmitted via
letter to EFR dated Apnl 25, 2013, it is recommended that specific GWCL parameters for
EFR White Mesa U-Mill 4tn Qtr Groundwater Monitonng Report
DRC Review Memo
Page 2 of12
monitoring wells be modified (12 instances) and that GWCL's be removed from the
permit for 3 up-gradient monitoring wells, additionally 2 monitonng well parameters are
recommended to have modified GWCL's pending additional discussion between DRC
and EFR regarding a potential modified approach for statistical evaluation
4 The EFR pH report, which evaluates monitonng wells out-of-compliance for pH,
required per Stipulated Consent Agreement, Docket No UGW12-03 was submitted to
DRC, dated November 9, 2012 The EFR pynte investigation report, required per
Stipulated Consent Agreement, Docket No UGW 12-03 was submitted to DRC, dated
December 7,2012 Per DRC review findings as documented in a DRC review memo
dated Apnl 23, 2013 and transmitted via letter to EFR dated Apnl 25, 2013 it is
recommended that GWCL's for pH at all MW senes monitonng wells be reset based on
the revised statistical evaluation (calculated using field measured pH instead of
laboratory measured values) In regards to the pyrite investigation DRC notes that "the
Pyrite Report does not propose changes in Permit GWCL's but does provide support for
the determination that current out-of-compliance parameters are due to background
chemical concentrations within the aquifer matrix and are not caused by the release of
tailings solution to the environment"
5 DRC noted that several groundwater samples were collected with field turbidity
measurements 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 Specifically, dunng the 4th quarter 2012 the
following monitonng wells had readings greater than 5 NTU, MW-01, MW-12, MW-19,
MW-20, MW-23, MW-29, MW-32 and MW-37
6 Several laboratory QA/QC flags were documented on the review penod analytical data
reports from 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
7 One new monitonng well parameter was subject to out-of-comphance status, accelerated
monitonng requirements (Selenium at monitonng well MW-31) dunng the 4th quarter
reporting penod EFR failed to initiate accelerated monitonng dunng the required
month, December 2012 EFR additionally failed to collect an accelerated monthly
sample dunng January 2013 The violation was self-identified in the EFR Report and also
provides for corrective actions DRC staff recommends that a notice of violation be
issued to EFR regarding the violation
8 EFR request approval of a source assessment investigation for selenium at monitonng
well MW-31 per the March 14,2013 Plan and Time Schedule document DRC staff
recommends conditional approval of the SAR as discussed m the memo below
2. Accelerated Monitoring and POC Wells Exceeding GWCL's
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 m Probable Out-of-Comphance (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 m Out of Compliance (OOC) status
(see the Permit, Part IG 2)
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 3 of 12
In the event a constituent is in OOC status, EFR is required to prepare and submit within 30 calendar days
to the Director a plan and 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 insure that Permit limits will not be exceeded at the compliance monitonng point and that DMT
or BAT will be reestablished, in accordance with Part IG 4(c) ofthe 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 monitoring at well MW-35
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 monitoring until "the month following the submission of the Exceedance Notice for a specified
quarter " Based on DRC review of notes taken during the April 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 within 30 days of the last lab report that EFR receives for the quarterly
monitonng event
DRC notified EFR by letter (dated April 16, 2012) that m 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-comphance notification and accelerated monitonng
requirements) is required for Director review and approval
EFR submitted a May 25, 2012 wntten request for a Permit modification, including redhne 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 m the
renewal permit In the intenm, DRC is hononng the teleconference agreements and is not pursuing
Permit enforcement based on EFR failure to meet the current time and schedule submission requirements
as stated in the Permit
The table below (Table 1) lists monitoring wells with parameters currently in OOC or POOC status and
are currently under accelerated momtonng requirements
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 LI water D-3 Manganese February 2010 May 2010
MW-14 Class LU water D-4A Field pH
Manganese
February 2010
2nd Quarter 2012
May 2010
August 2012
MW-25 Class HI water C-3 Field pH
Uranium
Cadmium
4W Quarter 2010
September 2010
4th Quarter 2012
January 2011
January 2011
March 2013
MW-26(a) Class HI water C-2
Field pH
Nitrate + Nitnte (as N)
Chloroform
Uranium
Chlonde
Dichloromethane
February 2010
February 2010
February 2010
February 2010
February 2010
Apnl 2010
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
EFR White Mesa U-Mill 4th Qtr Groundwater Momtonng Report
DRC Review Memo
Page 4 of12
MW-30 Class II water D-2
Nitrate + Nitnte (as N)
Chlonde
Selenium
Uranium
February 2010
1st Quarter 2011
Apnl 2010
4th Quarter 2011
May 2010
May 2011
July 2010
March 2012
MW-31 Class III water D-2
Nitrate + Nitnte (as N)
Chlonde
Sulfate
TDS
Selenium
February 2010
1st Quarter 2011
4th Quarter 2010
September 2010
3rd Quarter 2012
May 2010
Apnl 2011
January 2011
January 2011
December 2012
MW-35 Class E C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
Molybdenum
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
3rd Quarter 2011
3rd Quarter 2012
4th Quarter 2012
July 2011
July 2011
October 2011
October 2011
December 2012
March 2013
D = Down-gradient, U = Up-gradient, C = Cross-gradient, 1,2,3,4A = Cell #
a = Monitoring well MW-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annually Accelerated to Quarterly Monitoring
Well Class *Position Parameter Date of First
Exceedance of
GWCL
4~arQuarter2012
4th Quarter 2012
4th Quarter 2012
Date Accelerated
Monitoring First
Required
MW-1 Class LI water U-l
Tetrahydrofuran
Sulfate
Manganese
41FQuarter2010
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
1st Quarter 2013
1st Quarter 2013
1st Quarter 2013
MW-2 Class IE water C-3 Adjusted Gross Alpha 1st Quarter 2011
MW-3 Class III water D-4A
Selenium
Field pH
Fluonde
Quarter 2010
3™ Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
3^ Quarter 2010
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
2nd Quarter 2010 3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
1st Quarter 2013
2nd Quarter 2010
4th Quarter 2010
4th Quarter 2012
MW-5 Class LI water D-3 Uranium 4th Quarter 2010
4th Quarter 2010
2nd Quarter 2010
1st Quarter 2011
MW-12 Class LU water D-3 Field pH
Selenium
1st Quarter 2011
3rd Quarter 2010
MW-15 Class HI water D-4A Iron
Selenium
4irQuarter2011
2nd Quarter 2012
1st Quarter 2012
3rd Quarter 2012
2"H_Quarter2010
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
MW-18 Class III water U-l
Thallium
Field pH
Sulfate
TDS
1st Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
3ia~Quarter2010
1st Quarter 2012
1st Quarter 2013
MW-19
Class HI water
U-l
Field pH
Nitrate + Nitnte as N
Adjusted Gross Alpha
i^Quarter 2010
4th Quarter 2011
4th Quarter 2012
EFR White Mesa U-Mill 4th Qtr Groundwater Monitonng Report
DRC Review Memo
Page 5 of 12
2nd Quarter 2010
4th Quarter 2011 MW-23 Class III water D-3 Field pH
Manganese
2~5a~Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
3* Quarter 2010
1st Quarter 2012
MW-24 Class III water D-1
Cadmium
Thallium
Field pH
Fluonde
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2013
"^Quarter 2010
1st Quarter 2011
3rd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2011
MW-27 Class III water U-l
Nitrate + Nitnte (as N)
Adjusted Gross Alpha
Sulfate
TDS
Chlonde
Field pH
2"^ Quarter 2010
4th Quarter 2010
2nd Quarter 2010
1st Quarter 2010
1st Quarter 2010
3rd Quarter 2011
T* Quarter 2010 Vs Quarter 2010
MW-28 Class III water D-1
Field pH
Chlonde
Manganese
2nd Quarter 2010 3rd Quarter 2010
2nd Quarter 2012 3rd Quarter 2012
MW-29 Class III water D-2
Field pH
Iron
Manganese
TDS
4m Quarter 2010
2nd Quarter 2011
2nd Quarter 2012
2nd Quartr 2012
1st Quarter 2011
3rd Quarter 2011
3rd Quarter 2012
3rd Quarter 2012
3irQuarter2010
3rd Quarter 2010 MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
T5 Quarter 2010
2nd 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 m Accelerated Status EFR is
required to notify the DRC on a quarterly basis regarding wells and parameters which went into
accelerated monitonng dunng the penod [Part IG 1(a), Accelerated Momtonng Status Reports (AMSR)]
For the 4th quarter 2012 monitonng, the AMSR and follow up Plan and Time Schedule [Required by the
Permit Part IG 4(d)] were received as follows
1 AMSR received for the 4th Quarter 2012 penod, dated February 15,2013 and received by DRC
on February 19,2013
2 Plan and Time Schedule for the 4th Quarter 2012 Report, dated March 14,2013 and received by
DRConMarchl5,2013
One new OOC well/parameter is noted for the reviewed reports, Well MW-31 Selenium The
March 14,2013 EFR Plan and Time Schedule document for 2 consecutive (OOC) exceedances of
Selenium at monitonng well MW-31, proposes the following follow up action for approval by the
Director
"The primary focus of the source assessment for selenium in MW-3lwill be two-fold First EFRI will
determine whether or not there is any new information that would suggest that the previous analyses
conducted in the Existing Wells Background Report, the SAR, or the pH Report has changed since the
date of that Report This analysis will include the following
1 A geochemical analysis of Selenium in MW-31 that will evaluate the behavior of the
constituents in MW-31 to determine if there are any changes in the behavior of indicator
constituents, such as Chloride, Sulfate, Fluoride and Uranium since the date ofthe Existing
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 6 of 12
Wells Background Report, the Source Assessment Report, and the pH Report, that may
suggest a change in the behavior of that well since the date of that Report,
2 If necessary, a mass balance analysis that will evaluate the observed concentrations in light
of the concentrations in Mill tailings and the presence or absence of any mounding at the
location of the well in question, and
Second, a pH analysis will be performed for selenium that will
3 Review the behavior ofpH in the well to determine if there has been a significant decrease in
pH in the well, and
4 Analyze the expected impact from any such decrease in pH on the concentration of selenium,
based on currently available information "
EFR additionally agrees m the March 14,2013 Plan and Time Schedule to prepare a Source Assessment
Report (SAR) with the same format that was used for an October 10,2012 SAR to address OOC
parameter studies, including utilization of the Director approved statistical flow chart for evaluation of
potentially proposed modified GWCL's The SAR format for Selenium at monitoring well MW-31 is
planned to follow the format below
A geochemical analysis of selenium in MW-31
Companson of calculated and measured TDS for samples with complete major ions
Charge balance calculations *
Descnptive statistics
Box plots to identify extreme outliers "
Histograms and Shapiro Wilk test for normality
Regression or Mann Kendall trend analysis
Proposed Revised GWCL for selenium in MW-31
A geochemical analysis of Indicator Parameters m MW-31
Descnptive statistics
Box plots to identify extreme outliers
Histograms and Shapiro Wilk test for normality
Regression and/or Mann Kendall trend analysis
A pH analysis in MW-31
Descnptive statistics
Box plots to identify extreme ouhers
Histograms and Shapiro Wilk test for normality
Regression and/or Mann Kendall trend analysis
Per the Plan and Time Schedule, EFR agrees to provide the "Source Assessment Report" (SAR)
according to activities listed in the March 14, 2013 Plan and Time Schedule within 90 days after approval
by the Director
DRC staff recommends that DRC approve the EFR March 14,2013 SAR with the following conditions
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 7 of12
1 The SAR for Selenium at groundwater monitonng well MW-31 will include all study
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 from EFR receipt of the conditional
approval letter
3. Failure to Collect Required Accelerated Ground Water Samples at Well MW-31 during
December, 2012
The following failure to collect compliance groundwater sample (accelerated sample) was noted by DRC
staff dunng review of the 4th Quarter 2012 Report as follows
1 EFR failed to collect a monthly accelerated sample for selenium at well MW-31 during
December, 2012
This issue was also identified by EFR and an explanation and corrective action was included m the 4th
Qtr 2012 Report narrative DRC staff notes that EFR also states that the accelerated sample for Selenium
at monitonng well MW-31 was not collected dunng January, 2013 although DRC has not yet received the
1st Qtr 2013 Report The cause of the violation per EFR was as follows
"EFR intended to commence the monthly sampling for the third quarter exceedances (selenium in MW-
31) in December 2012, which was the first monthly sampling event after the receipt of the third quarter
2012 data However, although the data were reviewed, the information was not communicated to the Mill
Staff in sufficient time to allow for the collection of the samples before the end of the fourth quarter 2012
or in the January 2013 monthly sampling events "
Corrective actions per EFR regarding the violation is as follows as descnbed m Section 4 of the 4th
Quarter 2012 Groundwater Monitonng Report
"The omission of the analytes from the December 2012 and January 2013 monthly events has prompted
the QA Manager to revise the exceedance tracking procedures and procedures for review of the
analytical data receivedfrom the laboratory Additional review using database reports will be
implemented immediately upon receipt of the data at the time the analytical data are uploaded to the
database by the QA Manger Specifically, the QA Manager reviews all analytical data prior to loading
into the electronic database After loading each analytical data set the QA Manager will query the
database for exceedances Any exceedances identified in that analytical data set will be forwarded to the
Mill Field Personnel with the new accelerated frequency Mill Personnel will not schedule accelerated
monthly sampling until the review of exceedances has been completed "
DRC notes that failure to accelerate monitonng for OOC parameters has been cited in four previous
notice of violations (UGW07-04, UGW08-01, UGW08-02 and UGW11-04) DRC staff recommends that
a notice of violation and order be issued regarding the current violation DRC notes that although the
failure to accelerate monitonng for selenium in monitonng well MW-31 during January, 2013 did not
occur dunng the reviewed reporting period, the violation should be included m the current notice of
violation since it is a continuation of the December, 2012 violation (results in additional and continuous
days of violation)
EFR White Mesa U-Mill 4th Qtr Groundwater Monitonng Report
DRC Review Memo
Page 8 of 12
4. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection
As stated in Section 6 2 7 ofthe EFR Quality Assurance Plan (QAP), Rev 7 2 which was in effect dunng
the 4th Quarter 2012 monitoring penod, EFR has a choice regarding purge volumes as follows
"7 Purging three well casing volumes with a single measurement of field parameters
2 Purging two casing volumes with stable field parameters (within 10% RPD)
3 Purging a well to dryness and stability of a limited list offield parameters after recovery"
Per DRC review of the 4th quarter report the following methods were used for each Quarter (including
accelerated samples)
I Quarter I # Purged 2 Casing Volumes I # Purged to Dryness I # Purged 3 Casing Volumes I
4m2012 36 5 0
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 prior to sample collection dunng the 4th Quarter 2012 and 3rd Quarter 2012 momtonng
period
In cases where wells are evacuated to dryness the QAP Rev 7 2, applicable to 3rd 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 ahquots, and purge the well again as described above
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 9 of 12 •*
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 staff venfied that in cases where the monitonng well was evacuated to dryness, the number of
gallons evacuated was recorded for the 4th Quarter 2012 in compliance with the QAP Rev 6 which
applied to the quarter sampling Also, DRC staff venfied that depth to groundwater was measured and
recorded (comments field) on the field sheet
DRC staff venfied that in cases where the monitonng well was evacuated to dryness dunng the 4th
Quarter 2012 that the field parameter stabilization requirements per the QAP Rev 7 2 (listed above) were
followed DRC noted that EFR additionally recorded field readings directly after the purge although this
reading is not required
5. Groundwater Samples Collected with Turbidity Measurement >5 NTU
As stated in Section 6 2 7(d)(v) ofthe 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 from the QAP under Rev 7 2
During the 4th Quarters 2012 monitonng event, there were 10 compliance well samples with readings
above 5 NTU's as follows
Table 2 - Groundwater Samples Collected with Turbidity Measurement ^5 NTU
Groundwater
Monitoring Event
7th" 4l" Qtr, 2012
4^ Qtr, 2012"
4"* Qtr, 2012"
4^ Qtr, 2012"
4* Qtr, 2012"
4th Qtr, 2012"
4'" Qtr, 2012
4th Qtr, 2012"
4" Qtr, 2012
4th Qtr 2012"
Well
MW-01 (l)
MW-12(,)
MW-19 (l)
MW-20 (1)
MW-23 TO"
MW-29 W
MW-32 (1)
MW-37(1)
MW-25 Accl"^"
MW-25 Accl (2)
Turbidity, NTU
96
99
93 5
144
75
21 32
32
170
21
80
Footnotes
'Data for this well was obtained from Tab B ofthe 4th Quarter 2012 Groundwater Monitoring Report
2Data for this well was obtained from Tab C of the 4* Quarter 2012 Groundwater Monitonng Report
EFR undertook a redevelopment project for groundwater monitonng wells dunng calendar years
2010/2011, in 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 regarding DRC interaction
with independent laboratones regarding the effect of turbidity measurements above 5 NTU on laboratory
methods included in the QAP Per the review, DRC 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
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 10 of 12
Based on the updated QAP language (Rev 7 2) and DRC Redevelopment Report findings, the turbidity
readings are not in violation ofthe Permit or current approved QAP
6. Relative Percentage Difference Calculations for Blind Duplicate Analvsis
DRC conducted a review of the blind duplicate samples collected dunng the 4th Quarter 2012 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 (2 total - baseline and accelerated events)
The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the measured
concentrations are less than 5 times the required detection limit (Standard Methods, 1998) "
Per updated language in the QAP Rev 7 2 Part 9 1 4, if any ofthe 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 ofthe 4th Quarter of 2012 blind duplicate for Selenium did not meet the 20% cntena (30 48
%) and Thallium did not meet the 20% cntena m the accelerated sample duplicate (27 23%) DRC notes
that the both nonconformance's were identified by EFR in Section 3 4 7 of the 4th Quarter Monitonng
Report, as well as on Table G7-A in appendix G ofthe report Per the EFR Report "The sample results
reported for both parameters were not five times greater than the reporting limit and as such the
deviation from the 20% RPD requirement is acceptable "
Per DRC staff review, the EFR blind duplicate compansons and explanations seem appropnate
7. Analytical Laboratories Used bv EFR Certified bv State of Utah to Perform Analvsis for all
Analytes
The analytical laboratones (GEL Laboratones LLC, Charleston, SC and Amencan West Analytical
Laboratones, Salt Lake City, UT) were contracted by EFR to perform analysis on the samples collected
dunng the 4th 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 contract laboratones were certified to perform analysis for the specified parameters dunng
the review penod as follows
GEL Laboratones Utah Certification is currently active
Amencan West Analytical Utah Certification is currently active
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 11 of 12
8. Laboratory Report Turn Around Times
Per DRC review of EFR Table 1 included m the 4th Qtr 2012 Report, it was noted that laboratory report
turnaround times (from date of EFR sample submission to the contract laboratory) was generally in the
range of 1 month, with longest turnaround times of approximately 2 14 months There is not a turnaround
requirement in the current QAP, therefore, current turnaround times are judgment based DRC has raised
concern over excessive laboratory turn-around times m the past and the Director may require a turn-
around date be included in the facility QAP if additional concerns are noted The turn-around times for
the 4th Quarter data appear to be reasonable
9. Laboratory QA/QC Flags - 4th Quarter 2012
QA/QC issues and DRC findings for the 4th Quarter 2012 are summarized below
Non-Conformance Summary
Identified?
EFRCorrefftiv»ti6n
|Surnmary# •
DRC Fmdings
Routine Reporting Limit
Check found discrepancy
regarding some parameters
which were raised due to
dilution of the sample
(sample matnx interference)
Discrepancies were reported
and it was venfied that m all
cases the reported value for
the analyte was higher than
the increased detection limit
Raising RL's due to
sample matnx is
common It may be
appropnate to raise the
RL's in the facility QAP
Matnx Spike outside of
laboratory recovery limits
for several monitonng wells,
Napthalene, Ammonia,
Nitrate + Nitnte as N, Cl,
S04, Mn, K
Recorded Discrepancies in
Appendix G
Recoveries vaned but
were qualified by the
laboratory, no range
required by current QAP
Note DRC reviewed the holding time summary chart, no exceedances of holding times were noted
DRC reviewed the temperature check charts, all sample batches were received by the laboratory
<6°C
10. Review of Time-Concentration Plots
The Permit Part IF 1 g requires EFR to submit Time-Concentration Plots for each monitonng well for
chlonde, fluonde, sulfate and uranium
Per DRC review of the Time-Concentration Plots for the 4th Qtr 2012 it appears that all issues which
were reported and discussed dunng previous DRC review (1st, 2nd, and 3rd Qtr's 2011 Reports) have been
resolved Specifically, EFR is no longer culling data from the plots based on the EFR findings that
certain concentrations are outliers DRC requested that EFR plot all ground water data histoncally and it
appears that the plots are representative ofthe data
DRC notes that per the discussions with EFR it was agreed to that EFR need not plot trend lines on the
Time Concentration Plots Therefore, the plots no longer include trend lines The reviewed plots appear
to be in conformance with the agreed upon changes
EFR White Mesa U-Mill 4 Qtr Groundwater Monitonng Report
DRC Review Memo
Page 12 of 12
11. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DRC cross checks of groundwater elevation measurement calculations used for the 4th Quarter 2012,
approximately 5% of wells cross checked, companng current depth to water measurements with plotted
elevations, no errors were found DRC noted that groundwater elevations appeared stable and in
conformance with histoncal levels dunng the review penods
12. Violations Where a Notice of Violation and Order is Recommended per Report Reviews
1 EFR failed to collect a monthly accelerated sample for selenium at well MW-31 dunng
December, 2012 and January, 2013 (Violation of Ground Water Discharge Permit No
UGW370004 PartlGl)
13. Conditional Approval Recommended per Report Review
It is recommended that the Director conditionally approve the "Source Assessment Report" (SAR) for
OOC status (Selenium at monitonng well MW-31) according to activities outlined in the March 14,2013
Plan and Time Schedule, with the following conditions
1 The SAR for Selenium at groundwater monitonng well MW-31 will include all study
elements and report structure ofthe October 10,2012 EFR Source Assessment Report,
including graphs, plots and charts
2 The SAR will be submitted on or before 90 days from EFR receipt ofthe conditional
approval letter
14. References
1 Energy Fuels Resources (USA) Inc , February 26, 2013, 4th Quarter2012 Groundwater Monitoring
Report Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill
2 Energy Fuels Resources (USA) Inc , February 15,2013, Notice Pursuant to Part IG 4(d) Q4, 2012
3 Energy Fuels Resources (USA) Inc , March 14, 2013, Transmittal of Plan and Time Schedule under
Utah Ground Water Discharge Permit UGW3 70004 Part IG 4(d) White Mesa Uranium Mill
4 Energy Fuels Resources (USA) Inc , June 6, 2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 72
5 Utah Department of Environmental Quality, August 24, 2012, Utah Division of Radiation Control,
Ground Water Discharge Permit, Permit No UGW370004, Energy Fuels Resources (USA) Inc