DRC-2013-003210 - 0901a068803c2d90

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah II DRC-2013-003210 DIVISION OF RADIATION CONTROL
GARY R HERBERT
Governor
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
MEMORANDUM
TO: File
THROUGH: Phil Goble, Compliance Section Manager
FROM: Tom Rushing, P.G. ^/g f 2f -/J
DATE: September 25, 2013
SUBJECT: Review of the 2nd Quarter, 2013 (dated August 26,2013) Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004 - Energy Fuels Resources (USA)
Inc., White Mesa Uranium Mill, Blanding, Utah
This is a summary of Utah Division of Radiation Control ("DRC") staff review of the Energy Fuels
Resources (USA) Inc. ("EFR") groundwater monitoring report for the 2nd Quarter 2013 (April-June),
dated August 26, 2013 (received by DRC on August 28, 2013). The review included all sampling events
and accelerated monitoring during the quarter. The review was conducted to ensure compliance with all
applicable parts of Utah Groundwater Discharge Permit No. UGW370004 ("Permit") issued for the White
Mesa Uranium Mill located in Blanding, Utah.
DRC staff additionally reviewed the 2nd Quarter 2013 EFR groundwater compliance limit ("GWCL")
exceedance notice as follows:
1. Energy Fuels Resources (USA) Inc., August 23, 2013, Notice Pursuant to Part I.G.l(a) Q2,
2013
2. Energy Fuels Resources (USA) Inc., September 20, 2013, Transmittal of Plan and Time
Schedule under Utah Ground Water Discharge Permit UGW370004 Part I.G4(d) White
Mesa Mill
1. Checklist of Significant Findings and Associated Actions at the White Mesa Uranium Mill
1. The subject Monitoring Report was received by the due date per the Permit Part LF. 1
(due date September 1, 2013).
2. A May 25, 2012 EFR Permit modification request was made in order to document
accelerated reporting and monitoring agreements made during a teleconference with the
Utah Division of Radiation Control (DRC). DRC review of the 1st Quarter 2013 Report
recognized the telephone agreements regarding timelines for EFR to submit compliance
notices. The modification request is currently being addressed in a Permit modification.
3. An EFR October 10, 2012 Source Assessment Report, EFR April 13, 2012 pH Report,
and EFR December 12, 2012 Pyrite Investigation Report for previously documented out-
of-compliance parameters (multiple parameters), required per Stipulated Consent
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 2 of 11
Agreement, Docket No. UGW12-03. Per DRC review findings as documented in a DRC
review memo dated April 23, 2013 and transmitted via letter to EFR dated April 25,
2013, it is recommended that specific GWCL parameters for monitoring wells be
modified (12 instances), GWCL's for pH be modified for all monitoring wells, and that
GWCL's be removed from the permit for three up-gradient monitoring wells. These
requests are currently being addressed through the permit modification process.
4. Laboratory QA/QC flags were documented on the review period analytical data reports
from the contract laboratories. Per DRC review it appears that all discrepancies were
self-reported by EFR and that none of the discrepancies are violations of the Permit or the
QAP.
5. Three new monitoring wells went into accelerated monitoring frequency during the
monitoring period. MW-11 was accelerated from quarterly to monthly based on a single
exceedance of pH (April 16, 2013 sample). Monitoring well MW-31 went into
accelerated monitoring for pH based on an April 16, 2013 exceedance. Monitoring well
MW-27 went into accelerated monitoring for sulfate based on a May 21, 2013
exceedance. Accelerated monthly monitoring will commence in September 2013 for
these wells. Based on the Report and review of the period monitoring data no new wells
went into out of compliance status.
2. Accelerated Monitoring and POC Wells Exceeding GWCL's
When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL) set
forth in Table 2 of the Permit^ it is in Probable Out-of-Compliance (POOC) status. According to the
Permit, EFR is then required to immediately initiate accelerated sampling of that pollutant (see the
Permit, Part I.G.1). When monitoring,wells have parameters that have exceeded the Ground Water
Compliance Limit (GWCL) two or more consecutive times they are in Out of Compliance (OOC) status
(see the Permit, Part I.G.2).
In the event a constituent is in OOC status, EFR is required to prepare and submit within 30 calendar days
to the Director a plan and 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 monitoring point and that DMT
or BAT will be reestablished, in accordance with Part I.G.4(c) of the Permit.
Accelerated Monitoring Requirement Exception:
Based on review of 1st Qtr., 2nd Qtr., and 3rd Qtr. 2011 Groundwater Monitoring Reports, 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-3 5.
EFR stated in a March 26, 2012 response to the NOED that based on an agreement made between DRC
and EFR during a telephone conference call on April 5, 2010, EFR is not required to implement
accelerated monitoring until "the month following the submission of the Exceedance Notice for a specified
quarter." Based on DRC review of notes taken during the April 5, 2010 telephone conference (Loren
Morton 4/5/10), EFR verbally requested to wait until the end of the quarter to send in the notice of out-of
compliance status - but within 30 days of the last lab report that EFR receives for the quarterly
monitoring event.
EFR 2nd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 3 of 11
DRC notified EFR by letter (dated April 16, 2012) that in order to formalize the April 5, 2010 discussion
items related to out-of-compliance reporting and sampling, a written request for a groundwater permit
modification (groundwater permit, out-of-compliance notification and accelerated monitoring
requirements) is required for Director review and approval.
EFR submitted a May 25, 2012 written request for a Permit modification, including redline copies of
pertinent pages of the Permit to reflect the agreements made during the April 5, 2010 conference call.
The modification request is currently being addressed in a Permit modification. In the interim, DRC is
honoring 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.
Current Accelerated Monitoring Status:
The table below (Table 1) lists monitoring wells with parameters currently in OOC or POOC status and
are therefore required to be sampled under the accelerated monitoring requirements.
Table 1 - Wells Monitored Quarterly Accelerated to Monthly Monitoring
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-11 Class II water D-3 Manganese
Field pH
February 2010
April 2013
May 2010
September 2013
MW-14 Class III water D-4A Field pH
Manganese
February 2010
2nd Quarter 2012
May 2010
August 2012
MW-25 Class III water C-3 Field pH
Uranium
Cadmium
Chloride
41HQuarter 2010
September 2010
4th Quarter 2012
1st Quarter 2013
January 2011
January 2011
March 2013
June 2013
MW-26(a) Class III water C-2
Field pH ~
Nitrate + Nitrite (as N)
Chloroform
Uranium
Chloride
Dichloromethane
February 2010
February 2010
February 2010
February 2010
February 2010
April 2010
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
MW-30 Class II water D-2
Nitrate + Nitrite (as N)
Chloride
Selenium
Uranium
February 2010
1st Quarter 2011
April 2010
4th Quarter 2011
May 2010
May 2011
July 2010
March 2012
MW-31 Class III water D-2
Nitrate + Nitrite (as N)
Chloride
Sulfate
TDS
Selenium
Field pH
February 2010
1st Quarter 2011
4th Quarter 2010
September 2010
3rd Quarter 2012
April 2013
May 2010
May 2011
March 2011
January 2011
December 2012
September 2013
MW-3 5 Class II C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
3rd Quarter 2011
July 2011
July 2011
July 2011
October 2011
EFR 2nd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 4 of 11
Selenium
Molybdenum
3rd Quarter 2012
4th Quarter 2012
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
Date Accelerated
Monitoring First
Required
MW-1 Class II water U-l
Tetrahydrofuran
Sulfate
Manganese
4th Quarter 2012
4th Quarter 2012
4th Quarter 2012
1st Quarter 2013
1st Quarter 2013
1st Quarter 2013
MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
T3 Quarter 2010 313~Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
f* Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2010
4th Quarter 2012
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
1st Quarter 2013
MW-5 Class II water D-3 Uranium 4m Quarter 2010 1st Quarter 2011
MW-12 Class III water D-3 Field pH
Selenium
4m Quarter 2010
2nd Quarter 2010
1st Quarter 2011
3rd Quarter 2010
MW-15 Class III water D-4A Iron
Selenium
4" Quarter 2011
2nd Quarter 2012
1st Quarter 2012
3rd Quarter 2012
MW-18 Class III water U-l
Thallium
Field pH
Sulfate
TDS
f5 Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
MW-19 Class III water U-l
Field pH
Nitrate + Nitrite as N
Adjusted Gross Alpha
2"^ Quarter 2010
4th Quarter 2011
4th Quarter 2012
S^Quarter 2010
1st Quarter 2012
1st Quarter 2013
MW-23 Class III water D-3 Field pH
Manganese
2nd Quarter 2010
4th Quarter 2011
S^Quarter 2010
1st Quarter 2012
MW-24 Class III water D-1
Cadmium
Thallium
Field pH
Fluoride
f3 Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2013
MW-27 Class III water U-l
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Field pH
T3 Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
3rd Quarter 2011
3ra Quarter 2010
1st Quarter 2011
3rd Quarter 2010
2nd Quarter 2010
4th Quarter 2011
S^Quarter 2010
3rd Quarter 2010
3rd Quarter 2012
MW-28 Class III water D-1
Field pH
Chloride
Manganese
2_Hd~Quarter 2010
2nd Quarter 2010
°nd Quarter 2012
T* Quarter 2011
4th Quarter 2011 MW-29 Class III water D-2 Field pH
Iron
"^Quarter 2010
3rd Quarter 2011
i
EFR 2nd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 5 of 11
Manganese
TDS
2T Quarter 2012
2nd Quarter 2012
3rd Quarter 2012
3rd Quarter 2012
MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
2T Quarter 2010
2nd Quarter 2010
3™ Quarter 2010
3rd 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 Monitoring Wells in Accelerated Status. EFR is
required to notify the DRC on a quarterly basis regarding wells and parameters which went into
accelerated monitoring during the period [Part I.G.1 (a), Accelerated Monitoring Status Reports (AMSR)].
For the 2nd quarter 2013 monitoring, the AMSR and follow up Plan and Time Schedule [Required by the
Permit Part I.G.4(d)] was received, dated August 23, 2013 (received by DRC on August 26, 2013).
Three wells/parameters with new (single) exceedances were noted per review of the AMSR; MW-11 was
accelerated from quarterly to monthly based on an April 16, 2013 exceedance of the pH GWPL.
Monitoring well MW-31 went into accelerated monitoring for pH based on an April 16, 2013 exceedance
of the pH GWPL. Monitoring well MW-27 went into accelerated monitoring for sulfate based on a May
21, 2013 exceedance of the GWPL. Accelerated monthly monitoring will commence in September 2013
for these wells as agreed to during the April 5, 2010 DRC/EFR Conference Call.
Based on the Report and review of the period monitoring data, one new monitoring well/parameter went
into out-of-compliance (OOC) status during the 2nd Quarter 2013. Gross Alpha results for monitoring
well MW-32 was in excess of the GWCL (3.33 pCi/L) during the 1st quarter 2013 (5.02 pCi/L) and 2nd
quarter (3.72 pCi/L). A Plan and Time Schedule was submitted for the out of compliance parameter,
dated September 30, 2013. PRC staff review findings of the Plan and Time Schedule are discussed
below.
DRC Findings Regarding the EFR September 20, 2013 Plan and Time Schedule for Adjusted Gross
Alpha Out-of-Compliance Status at Monitoring Well MW-32
EFR proposes to submit a Source Assessment Report ("SAR") for Adjusted Gross Alpha at monitoring
well MW-32 within 90 days of Director approval of the September 20, 2013 Plan and Time Schedule.
Per EFR the SAR will include a geochemical analysis of gross alpha and indicator parameters (chloride,
fluoride, sulfate and uranium) in monitoring well MW-32. The intention will be to determine if "the
behavior of the water in MW-32 has changed since the time of the New Wells Background Report
(Intera, 2007).
EFR notes that if the OOC status is determined to be caused by background influences then no additional
evaluations to determine the extent and potential dispersion of the contamination will be necessary. In the
event that a background determination is made then EFR will submit to the Director as part of the SAR a
proposed revised GWCL for adjusted gross alpha in monitoring well MW-32.
EFR proposes to calculate the potential proposed revised GWCL using statistical analysis as described in
the existing wells Background Report (Intera, 2007) and as according to the Director approved flowsheet
for statistical analysis of GWCL revisions. EFR additionally notes that background at the White Mesa
Mill has recently been studied in the background report (Intera 2007), the October 12, 2012 Source
Assessment Report for several parameters in OOC status, and in a University of Utah Study at the White
Mesa Mill (Hurst and Solomon 2008). EFR notes that in some cases, such as at monitoring well MW-32,
limited indicator parameter data was available at the time of the past background studies.
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 6 of 11
DRC notes that the proposed plan and time schedule for investigation of adjusted gross alpha at
monitoring well MW-32 is consistent with recent investigations for OOC parameters at other wells.
Based on the proposal, DRC staff recommends that the September 20, 2013 plan and time schedule be
conditionally approved and that the SAR be reviewed by the Director when submitted to insure that any
findings of background influences and proposed GWCL modifications are supported with adequate
evidence to make the determinations.
The September 20, 2013 Plan and Time Schedule is recommended to be approved with the following
conditions:
1. The SAR for Adjusted Gross Alpha at groundwater monitoring well MW-32 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 UGW12-03), including
graphs, plots and charts, and;
2. The SAR will be submitted on or before 90 calendar days from EFR receipt of this
conditional approval letter.
3. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection
As stated in Section 6.2.7 of the EFR Quality Assurance Plan (QAP), Rev. 7.2, EFR has a choice
regarding purge volumes as follows:
"7. Purging three well casing volumes with a single measurement offield parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list offield parameters after recovery"
Per DRC review of the Report, the following methods were used for each Quarter (including accelerated
samples):
I Quarter I # Purged 2 Casing Volumes | # Purged to Dryness 1 # Purged 3 Casing Volumes
2^Qtr. 2013 | 38 5 1 0
When purging two casing volumes EFR QAP Rev. 7.2 directs EFR to first calculate the amount of time to
evacuate two casing volumes and then pump for that length of time. Per 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 monitoring
wells prior to sample collection during the 2nd Quarter 2013 monitoring period. Per past DRC onsite
sampling inspections it was noted that EFR sample collectors additionally use a graduated carboy and
cross check purged values to insure that the required amount of groundwater was evacuated.
In cases where wells are evacuated to dryness the QAP Rev. 7.2, applicable requires that:
"(vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worksheet.
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 7 of 11
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 described above.
Repeat this process if necessary for three complete purging events. If after the third purging the event, the
parameters of pH, specific conductance and temperature do not stabilize to within 10% RPD, the well is
considered sufficiently purged and collected samples can be submittedfor analysis"
DRC staff verified that in cases where the monitoring well was evacuated to dryness, the number of
gallons evacuated was recorded in compliance with the QAP. Also, DRC staff verified that depth to
groundwater was measured and recorded (comments field) on the field sheet.
4. Relative Percentage Difference Calculations for Blind Duplicate Analysis
DRC conducted a review of the blind duplicate samples collected during the 2nd Quarter 2013. 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 during the quarterly event - One with the baseline
samples and one with the accelerated samples).
The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the measured
concentrations are less than 5 times the required detection limit (Standard Methods, 1998)"
Per updated language in the QAP Rev. 7.2 Part 9.1.4, if any of the samples do not meet the comparison
criteria (and are not qualified according to the 5 times method detection limit criteria) then EFR is
required to conform to the procedures for corrective action listed as follows:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation errors, and,
3. If the samples are still within holding time, the QA Manager may request the laboratory re-
analyze the affected samples.
Per DRC cross check of the two blind duplicate samples collected and analyzed during the 2nd Qtr. 2013,
all sample results appear to conform to the Permit requirements (within 20% RPD).
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 8 of 11
5. Analytical Laboratories Used bv EFR Certified bv State of Utah to Perform Analysis for all
Analytes
The analytical laboratories (GEL Laboratories LLC, Charleston, SC and American West Analytical
Laboratories, Salt Lake City, UT) were contracted by EFR to perform analysis on the samples collected
during the 2nd Quarter, 2013. 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 laboratories were certified to perform analysis for the specified parameters during
the review period as follows.
GEL Laboratories Utah Certification is currently active per the Utah Bureau of Laboratory Website
(Directed to National LAMS Certifications). Per the website information:
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TNI00188
EPA Code SC00012
State ID E87156
Website
Extended Details
Primary AB responsible ^lorida DePft™nt of Health
for lab demographics Environmental Laboratory
^ r Certification Program
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
American West Analytical Utah Certification is currently active.
Basic Details
Name American West Analytical Laboratories
Type of Lab Commercial
TNI Lab Code TNI01955
EPA Code UT00031
State ID 8012638686
Website
Extended Details
Primary AB responsible T, » . t -„ u,
for lab demographics Utah DePartment of Health
GIS Location
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 9 of 11
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
6. Laboratory Report Turn Around Times
Per DRC review of EFR Table 1 included in the 2nd Qtr. 2013 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 or less (with some exceptions). 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 in the past and the Director may require a turn-around date be included in
the facility QAP if any future concerns regarding analysis turn around times are noted. Based on DRC
review the turn-around times for the 2nd Quarter 2013 data appear to be reasonable/appropriate.
7. Sample Holding Times
Per Table 2A and Table 2B of the Report, all holding times were met for each analyte submitted for
laboratory analysis. DRC staff cross checked all holding time requirements and verified that all
samples/analytes appeared to have been submitted within holding times during the 2nd Qtr. 2013 reporting
period.
8. Laboratory OA/OC Flags - 2nd Quarter 2013
QA/QC issues and DRC findings for the 2nd Quarter 2013 are summarized below:
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DRC Findings
MW-02, MW-18, MW-19,
MW-23, MW-24, MW-25,
MW-27, MW-31,MW-37,
Gross Alpha Counting Error
was not < 20% of the sample
analysis result (sample
activity)
The sample result + the
counting errors were less
than the GWCL in all
cases and are therefore
acceptable.
Per the QAP Part 9.1.4(b) "An
error term may be greater
than 20% of the reported
activity concentration when
the sum of the activity
concentration and error term
is less than or equal to the
GWCL"
Matrix Spike % recovery
outside of range MW-31
Nitrate +Nitrite and Chloride
None Per the QAP Part 8.1.2(a)
matrix spikes are required but
no requirements which would
disqualify the laboratory data
Per the QAPPart 8.1.2(a)
matrix spikes are required but
no requirements which would
disqualify the laboratory data
Matrix Spike % recovery
outside of range for MW-26
Nitrate + Nitrite and Sulfate
None
Laboratory Duplicate %
Recovery Comparisons
None The QAP requires check
samples but does not
EFR 2" Quarter Groundwater Monitoring Report
DRC Review Memo
Page 10 of 11
outside of range for MW-31
TDS
disqualify data based on
results out of laboratory
specified range
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
9. Review of Time-Concentration Plots
The Permit Part I.F.I.g requires EFR to submit Time-Concentration Plots for each monitoring well for
primary indicators of cell leakage (based on tailings cell concentrations and ground water partitioning and
retardation coefficients); chloride, fluoride, sulfate and uranium. DRC notes that per the discussions with
EFR it was agreed to that EFR need not plot trend lines on the Time Concentration Plots and that all data
is included on the plots (no data culled from the set). Per DRC review of the 2nd Qtr. 2013 Report, the
plots no longer include trend lines. The reviewed plots appear to be in conformance with the agreed upon
changes, no issues were identified.
10. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DRC cross checks of groundwater elevation measurement calculations used for the 2nd Quarter 2013,
approximately 5% of wells cross checked, comparing current depth to water measurements with plotted
elevations, no errors were noted. DRC noted that groundwater elevations appeared, stable and in
conformance with historical levels during the 2nd Qtr. 2013 period.
The upper wildlife pond at the White Mesa Mill was taken offline (pond recharge from Recapture
Reservoir discontinued) during the 4th Quarter 2011. Static water level measurement, for several ground
water monitoring wells in the vicinity of the upper wildlife pond are included on the table below. It was
noted that the static water levels in several monitoring wells close to the upper wildlife ponds showed
significant decrease in water levels during the 2nd Quarter 2013. Specifically, the following
wells/piezometers showed a significant decrease; 1. Piezometer 2-10.4 ft., 2. TWN-02 - 11.37 ft.,
3. TWN-04 - 6.7 ft., 4. TW4-25 - 9.8 ft.
Static Water Level in Wells in the vicinity of the White Mesa Mill Upper Wildlife Pond
Well No. Static Level
Piez 1
Piez2
Piez 3
MW-19
MW-27
TWN-02
TWN-03
TWN-04
TWN-06
TWN-07
TWN-08
TWN-09
1st Quarter
2012
61.59
21.20
40.25
52.14
51.04
21.00
32.80
41.05
74.60
88.34
61.63
62.89
2na Quarter
2012
61.52
21.28
40.29
52.08
51.00
21.02
32.83
41.03
74.62
88.39
61.64
62.90
3rd Quarter
2012
62.08
27.04
41.47
54.19
51.46
23.66
34.00
43.40
75.17
87.86
62.20
62.60
4th Quarter
2012
61.55
20.20
40.31
55.01
51.46
20.93
32.76
41.01
75.27
87.76
62.30
62.21
1st Quarter
2013
62.33
30.12
43.80
55.88
51.80
28.41
35.90
46.30
75.49
87.25
62.53
62.10
2nd Quarter
2013
62.87
31.60
44.30
56.84
52.39
32.37
37.32
47.75
75.93
87.05
63.01
62.05
EFR 2nd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 11 of 11
Well No. Static Level
2nd Quarter
2013
58.50
56.65
57.30
TWN-18
TW4-18
TW4-25
1st Quarter
2012
58.40
56.65
47.50
2nd Quarter
2012
58.40
56.61
47.50
3rd Quarter
2012
57.95
57.30
49.31
4m Quarter
2012
57.95
56.63
47.50
1st Quarter
2013
58.13
58.13
47.48
11. Conclusions and Recommendations
Based on DRC staff review of the above listed documents it is recommended that a correspondence letter
be sent to EFR with the following items:
1. Approval of the EFR September 20, 2013 Plan and Time Schedule for assessment of Adjusted
Gross Alpha OOC status at Monitoring Well MW-32, and,
2. Review findings regarding the 2nd Quarter 2013 Groundwater Monitoring Report for the White
Mesa Uranium Mill and close out of the review.
3. Review concerning out of compliance parameters sampling and accelerated monitoring
requirements.
12. References
1 Energy Fuels Resources (USA) Inc., May 28, 2013,1st Quarter2013 Groundwater Monitoring Report
Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill
2 Energy Fuels Resources (USA) Inc., May 10, 2013, Notice Pursuant to Part I.G.4(d) Ql, 2013
3 Energy Fuels Resources (USA) Inc., May 7, 2013, Source Assessment Report for TDS in MW-29 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 7.2.
5 INTERA Incorporated, 2007. Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County,
Utah.
6 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the. July 2007 Sampling Event at the Denison
Mines, USA, White Mesa Uranium Mill located near Blanding Utah Prepared by University of Utah
Department of Geology and Geophysics.
7 Utah Department of Environmental Quality, August 24, 2012, Utah Ground Water Discharge Permit,
Permit No. UGW37Q004 issuedfor the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill