DRC-2013-003620 - 0901a068803e0313

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.(8 9*
State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2013-003620
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File
Phil Goble, Compliance Section Manager
Tom Rushing, P.G.
December 9,2013
Review of the 3rd Quarter, 2013 (dated November 20, 2013) Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004 - Energy Fuels Resources (USA)
Inc., White Mesa Uranium Mill, Blanding, Utah
This is a summary of Division of Radiation Control ("DRC") staff review of the Energy Fuels Resources
(USA) Inc. ("EFR") groundwater momtonng report for the 3rd Quarter 2013 (July-September), dated
November 20, 2013 (received by DRC on November 21, 2013). The review included all sampling events
and accelerated momtonng dunng 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 m Blanding, Utah.
DRC staff additionally reviewed the EFR November 15, 2013 document titled "State of Utah Ground
Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part
I.G. 1(a)." This document provides a detailed explanation of ground water compliance issues dunng the
third quarter White Mesa Mill sampling and analysis.
c
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 I.F. 1
(due date December 1,2013).
2. A May 25, 2012 EFR Permit modification request was made in order to document
accelerated reporting and momtonng 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.
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-comphance parameters (multiple parameters), required per Stipulated Consent
Agreement, Docket No. UGW 12-03. Per DRC review findings as documented m a DRC
review memo dated Apnl 23, 2013 and transmitted via letter to EFR dated Apnl 25,
EFR 3r Quarter Groundwater Monitoring Report
DRC Review Memo
Page 2 of 14
2013, it is recommended that specific GWCL parameters for momtonng wells be
modified (12 instances), GWCL's for pH be modified for all momtonng wells, and that
GWCL's be removed from the permit for 3 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 laboratones. Per DRC review (Section 8 Below) 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 monitonng wells went into accelerated monitoring frequency dunng the
momtonng period. MW-11 was accelerated from quarterly to monthly based on a single
exceedance of GWCL's (Apnl 16, 2013 sample). Monitoring well MW-31 went into
accelerated monitonng for pH based on an Apnl 16,2013 exceedance. Monitoring well
MW-27 went into accelerated monitonng 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 monitonng 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 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 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 re-established, 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 monitonng 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 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 Apnl 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.
DRC notified EFR by letter (dated Apnl 16,2012) that m order to formalize the Apnl 5,2010 discussion
items related to out-of-compliance reporting and sampling, a written request for a groundwater permit
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 3 of 14
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 dunng the April 5, 2010 conference call.
The Permit modification request is currently under DRC review and is pending 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
therefore required to be sampled under the accelerated monitonng 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
Apnl 2013
May 2010
September 2013
MW-14 Class HI water D-4A Field pH
Manganese
February 2010
2nd Quarter 2012
May 2010
August 2012
MW-25 Class III water C-3 Field pH
Fluonde
Uranium
Cadmium
Chloride
4W Quarter 2010
3rd Quarter 2013
3rd Quarter 2010
4th Quarter 2012
1st Quarter 2013
January 2011
December 2013
January 2011
March 2013
June 2013
MW-26(a) Class m water C-2
Field pH
Nitrate + Nitrite (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
MW-30 Class II water D-2
Nitrate + Nitrite (as N)
Chlonde
Selenium
Uranium
February 2010
1st Quarter 2011
April 2010
4th Quarter 2011
May 2010
May 2011
July 2010
March 2012
MW-31 Class IQ water D-2
Nitrate + Nitrite (as N)
Chlonde
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-35 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 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 4 of 14
Selenium
Molybdenum
y3 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
Monitonng 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 ELT water D-4A
Selenium
Field pH
Fluonde
T* Quarter 2010 3"7a_Quarter2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
MW-3A Class ITJ water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
2"^Quarter2010
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 4s Quarter 2010 1st Quarter 2011
MW-12 Class in water D-3 Field pH
Selenium
4th Quarter 2010
2nd Quarter 2010
1st Quarter 2011
3rd Quarter 2010
MW-15 Class ITJ water D-4A Iron
Selenium
4"arQuarter 2011
2nd Quarter 2012
1st Quarter 2012
3rd Quarter 2012
MW-18 Class IH water U-l
Thallium
Field pH
Sulfate
TDS
"^Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
313" Quarter 2010
1st Quarter 2012
1st Quarter 2013
MW-19 Class m water U-l
Field pH
Nitrate + Nitnte as N
Adjusted Gross Alpha
f* Quarter 2010
4th Quarter 2011
4th Quarter 2012
^Quarter 2010
1st Quarter 2012 MW-23 Class IH water D-3 Field pH
Manganese
2"^ Quarter 2010
4th Quarter 2011
3ld_Quarter2010
3rd Quarter 2010 MW-24 Class m water D-l
Cadmium
Thallium
Field pH
Fluonde
2lidQuarter2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
3rd Quarter 2010
1st Quarter 2013
3"H"Quarter2010
1st Quarter 2011
3rd Quarter 2010
2nd Quarter 2010
4th Quarter 2011
MW-27 Class IU water U-l
Nitrate + Nitnte (as N)
Adjusted Gross Alpha
TDS
Chlonde
Field pH
"^Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
3rd Quarter 2011
MW-28 Class UI water D-l
Field pH
Chloride
Manganese
T5 Quarter 2010
2nd Quarter 2010
2nd Quarter 2012
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2012
MW-29 Class III water D-2 Field pH
Iron
4m Quarter 2010
3rd Quarter 2011
i^Quarter 2011
4th Quarter 2011
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 5 of 14
3^ Quarter 2012 Manganese
TDS
2T Quarter 2012
2nd Quarter 2012 3rd Quarter 2012
MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
T* Quarter 2010
2nd Quarter 2010
3ra 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 Monitonng Wells in Accelerated Status. EFR is
required to notify the DRC on a quarterly basis regarding wells and parameters which went into
accelerated monitoring dunng the period [Part I.G. 1(a), Accelerated Monitoring Status Reports (AMSR)].
For the 3rd quarter 2013 monitoring, the AMSR and follow up Plan and Time Schedule [Required by the
Permit Part I.G.4(d)] was received, dated November 15, 2013 (received by DRC on November 18, 2013).
One well/parameter with a new (single) exceedance was noted per review of the AMSR; MW-25 was
accelerated from quarterly to monthly based on a 3rd Quarter 2013 exceedance of the Fluoride GWCL.
Based on review of the AMSR there were no new exceedances for the semi-annual well sampling
program.
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 purge methods were used for each Quarter (including
accelerated samples):
Quarter # Purged 2 Casing Volumes | # Purged to Dryness | # Purged 3 Casing Volumes
3rd Qtr. 2013 37 1 1-contmuous pumping well
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 monitonng
wells prior to sample collection dunng the 3rd Quarter 2013 monitoring penod. During 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 3r Quarter Groundwater Monitoring Report
DRC Review Memo
Page 6 of 14
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 submitted for 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 3rd 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 blind duplicate samples collected and analyzed dunng the 3rd Qtr. 2013 (4
samples, 8 parameters), all sample results conform to the Permit requirements (within 20% RPD).
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 7 of 14
rs
It was noted that the blind duplicate samples which were collected were for a limited number of
parameters. As such, only 8 total parameters were split in the 4 blind duplicate samples. Although the
facility QAP does not specifically require that split samples include well locations where a full suite of
samples will be analyzed, this is the intention of the split sample collection and comparison. DRC will
include an advisory to EFR that future split samples should be collected at wells where a complete suite
of analyses will be performed.
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
dunng the 3rd 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 laboratones were certified to perform analysis for the specified parameters during
the review period as follows.
American West Analytical Laboratories - Salt Lake City, UT Certification Active Per the website
information:
Basic Details
Name American West Analytical Laboratories
Type of Lab Commercial
TNI Lab Code TNI01955
EPA Code UT00031
State ID 8012638686
Website
Extended Details
PnmaryAB responsible TT. . , uu r T , , , Utah Department of Health ior lab demographics K
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
Address 1
Type Location
Company
Contact Kyle Gross
Address 1 463 West 3600 South
Address 2
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 8 of 14
City Salt Lake City
State Utah
Zip 84115-
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
GEL South Carolina ~ Utah Certification is currently active.
Basic Details
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TNI00188
EPA Code - SC00012
State ID E87156
Website
Extended Details
f^lab^enwg^^^ Florida Department of Health Environmental Laboratory Certification Program
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
Address 1
Type Location
Company
Contact JAMES B. WESTMORELAND
Address 1 2040 Savage Rd
Address 2
City Charleston
State South Carolina
Zip 29407
Country US
Phone [phone]
Fax [phone]
EFR 3r Quarter Groundwater Monitoring Report
DRC Review Memo
Page 9 of 14
Email [e-mail]
6. Laboratory Report Turn Around Times
Per DRC review of EFR Table 1 included in the 3rd Qtr. 2013 Report, it was noted that laboratory report
turnaround times (from date of EFR sample submission to the contract laboratory) was generally m the
range of lmonth (12 to 48 days). There is not a turnaround time 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 turnaround times are noted. Based on DRC
review the turn-around times for the 3rd Quarter 2013 data appear to be reasonable/appropriate.
7. Sample Holding Times
Per Table 2 A 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 venfied that all
samples/analytes appeared to have been submitted within holding times dunng the 3rd Qtr. 2013 reporting
penod.
8. Laboratory QA/QC Flags - 3rd Quarter 2013
QA/QC issues and DRC findings for the 3rd Quarter 2013 are summarized below:
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary^: '
DRC Bindings
Laboratory reporting limits
were raised for vanous
samples for analysis of S04,
TDS, Cl, Ca, K, Na, Mg,
Nitrate/Nitnte (N),
Chloroform, TDS and Fe
EFR states that the raised
RL's are due to sample
dilution and qualifies the
data in Table G based on
all sample results being
above the raised RL
The EFR QAP allows for
raised RL's if due to need for
dilution
MW-11, MW-14, MW-19,
MW-25, MW-26, MW-27,
MW-30, MW-31, MW-32,
MW-35, MW-36, 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-14
Sodium, Calcium, MW-26
Nitrate/Nitrite (N), MW-19
Nitrate/Nitnte (N), MW-12
Nitrate/Nitnte (N), MW-01
Sodium, Calcium, MW-37
Ammonia
None Per the QAP Part 8.1.2(a)
matnx spikes are required but
no requirements which would
disqualify the laboratory data
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 10 of 14
Method blank detection
outside of limits for Toluene
lab report no. 1307232
Y The Toluene sample
Results were not affected
by the method blank
detection because there
were no positive
detections for toluene in
any of the samples m the
analytical batch.
Facility QAP requires that the
Method blank (check samples)
be used to assess the quality of
the data. DRC staff noted that
none of the laboratory results
for toluene were above the 1.0
mg/L required RL. DRC
accepts the EFR corrective
action since a detection in the
method blank should
correspond to greater detection
in the samples due to
contamination during the run.
Matrix spike recovery
outside of required range for
chloroform and
Nitrate/Nitrite (N) in
monitoring well MW-26
The recoveries and
RPD's above the
acceptance limits do not
affect the quality or
usability of the data
because the recoveries
and RPD's above the
acceptance limits are
indicative of matrix
interference most likely
caused by other
constituents m the
samples.
Per the facility QAP, the
duplicate spike (matrix spike)
sample serves as a check
evaluating the effect of the
sample matrix on the accuracy
of analysis. The QAP requires
that the matrix spike samples
be run according to state
certified laboratory procedures
but does not specify
enforcement requirements for
samples outside of the
acceptance cnteria. DRC
notes that the laboratory
reported the data with a listed
qualifier.
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. 1 .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); chlonde, fluonde, 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 3rd 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. DRC additionally notes that any depicted increasing data trends m the
indicator parameters were investigated in preparation of the October 10, 2012 EFR Source Assessment
Report.
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 11 of 14
10. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DRC cross checks of groundwater elevation measurement calculations used for the 3rd Quarter 2013,
approximately 5% of wells cross checked, comparing water level measured elevations minus measured
static levels with plotted elevations, no errors were noted.
The upper wildlife pond at the White Mesa Mill was taken offline (pond recharge from Recapture
Reservoir discontinued) dunng the 4th Quarter 2011. Static water level measurement, for several ground
water monitonng 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. Per the 3rd Quarter 2013 the water
elevations showed additional significant decline in several wells (Piez-3, TWN-04, TW4-18, TW4-25),
indicating that the water levels are continuing to re-establish to pre-pond levels.
Static Water Level in Wells in the vicinity of the White Mesa Mill Upper Wildlife Pond
Well Nof>* :. >a.-?-v:;>-.. .Y* - 'Static Level
1st Quarter
2012 Quarter
2012a
3^T~
Quarter
2012
4"l"Quarter^
»^012 ,
ffl|iliQuarteri
2013
^Quarter
2013
3rd Quarter *
Piez 1 61.59 61.52 62.08 61.55 62.33 62.87 62.61
Piez2 21.20 21.28 27.04 20.20 30.12 31.60 32.43
Piez 3 40.25 40.29 41.47 40.31 43.80 44.30 46.90
MW-19 52.14 52.08 54.19 55.01 55. 56.84 57.25
MW-27 51.04 51.00 51.46 51.46 51.80 52.39 52.38
TWN-02 21.00 21.02 23.66 20.93 28.41 32.37 32.31
TWN-03 32.80 32.83 34.00 32.76 35.90 37.32 37.14
TWN-04 41.05 41.03 43.40 41.01 46.30 47.75 48.54
TWN-06 74.60 74.62 75.17 75.27 75.49 75.93 75.95
TWN-07 88.34 88.39 87.86 87.76 87.25 87.05 86.85
TWN-08 61.63 61.64 62.20 62.30 62.53 63.01 Abandoned
TWN-09
TWN-18
TW4-05
TW4-18
TW4-25
62.89
58.40
56.65
47.50
62.90
58.40
56.61
47.50
62.60
57.95
57.30
49.31
62.21
57.95
56.63
47.50
62.10
58.13
58.13
47.48
62.05
58.50
58.65
56.65
57.30
Abandoned
58.43
59.35
58.43
59.00
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. DRC will include an advisory to EFR that future split samples should be collected at wells where
a complete suite of analyses will be performed.
2. Close out regarding DRC review of the 3rd Qtr. 2013 White Mesa Uranium Mill Groundwater
Monitoring Report
EFR 3rd Quarter Groundwater Monitoring Report
DRC Review Memo
Page 12 of 14
12. References
1 Energy Fuels Resources (USA) Inc., November 20,2013, 3rd 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 LG.4(d) Ql, 2013
3 Energy Fuels Resources (USA) Inc., November 15, 2013, State of Utah Ground Water Discharge
Permit No. UGW3 70004 White Mesa Uranium Mill - Notice Pursuant to Part I. G. 1(a)
4 Energy Fuels Resources (USA) Inc., June 6, 2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 7.2.
5INTERA Incorporated, 2007. Revised Background Groundwater Quality Report: Existing Wells
forDension 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. UGW370004 issued for the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill
Attachment - Energy Fuels
ReSOWCeSB,'ndD"P'-teComparisons
laife:^'-^-'! White Mesa Uranium Mill feate o^afel&^''iliW^-i'3-Dec-13 ;;:iFacil_it7:.Na||e:;
Well Nurnber:'-. . MW-29 (Blind Duplicate MW-65
.Parameter' • Sample. Date
l|MW^i|r;SarT§e' Rpufli^ Per^t^f.v'"
jm&jL- -,; • MW-65 '
Iron 7/17/2013 1.4 1.43 -2.1
Manganese 7/17/2013 5.14 5.04 2.0
Total Dissolved
Solids 7/17/2013 4270 4420 -3.5
7/18/2013 <0.05 ron <0.0300
7/18/2013 Selenium 0.108 7.7 0.1
p;bat£ofbS 3-Jun-13
••;.:i^$g:;^\\''W^^o?E?Hf^- •• —• ?-
Facility Name: • : •" -• White Mesa Uranium Mill
1^41 "\ Blind Duplicate Analysis Relative Percent gf$$£
llgResu|ii|/L^ -r: Difference (RPD)
8/26/2013 0.164 -3.7 Manganese 0.158
aSSaSlwi
Cadmium 9/20/2013 -3.0 0.00135 0.00131
9/20/2013 0.00607 -1.3 Uranium 0.00599