DRC-2014-002404 - 0901a06880418281

A7 Ml
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO File DRC-2014-002404
THROUGH: Phil Goble, Compliance Section Manager
FROM: Tom Rushing, P.G. ^ fC T/tf/l**
DATE: March 19, 2014
SUBJECT: Review of the 4th Quarter, 2013 (dated February 12, 2014) 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 monitoring report for the 4th Quarter 2013 (October-December), dated
February 12, 2014 (received by DRC on February 14, 2014). 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. UGW3 70004 ("Permit") issued for the White
Mesa Uranium Mill located in Blanding, Utah.
DRC staff additionally reviewed the EFR February 10, 2014 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 during the fourth quarter
White Mesa Mill sampling and analysis.
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 March 1,2014).
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). 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 through the Permit renewal process.
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 Agreement,
Docket No. UGW12-03. Per DRC review findings as documented in a DRC review memo
EFR 4 Quarter Groundwater Monitoring Report
Page 2
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 3 up-gradient monitoring wells. These requests are currently
being addressed through the Permit renewal process.
4. Laboratory QA/QC flags were documented on the review period analytical data reports
from the contract laboratories. 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 Quality Assurance Plan ("QAP").
5. Four new monitoring wells (five compliance parameters) went into accelerated monitoring
frequency during the monitoring period. Uranium in monitoring well MW-25 was
accelerated from quarterly to monthly based on an exceedance of the GWCL during March
2013; Uranium in monitoring well MW-30 went into monthly accelerated monitoring
based on a March 2013 exceedance; Nitrate + Nitrite and Sulfate in monitoring well MW-
3 went into accelerated quarterly monitoring based on 4th Quarter 2013 exceedances; Field
pH in monitoring well MW-15 went into quarterly accelerated monitoring based on an
exceedance during the 4th Quarter 2013.
6. One discrepancy was noted regarding EFR analysis of blind duplicate samples as
discussed in section 4 below.
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.I). 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
LG.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 ensure 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 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 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 4 Quarter Groundwater Monitoring Report
Page 3
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
Permit modification request is currently under DRC review and is pending inclusion in the Permit renewal.
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 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
Fluoride
Uranium
Cadmium
Chloride
4in 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 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-35 Class II C-4B
Uranium
Manganese
Thallium
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
July 2011
July 2011
July 2011
EFR 4 Quarter Groundwater Monitoring Report
Page 4
Adjusted Gross Alpha
Selenium
3rd Quarter 2011
3rd Quarter 2012
October 2011
December 2012
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
^ Quarter 2012
4th Quarter 2012
4th Quarter 2012
2~5!rQuarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
4th Quarter 2013
1st Quarter 2013
1st Quarter 2013
1st Quarter 2013
MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
3^Quarter2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
T* Quarter 2010
MW-3 A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
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 4tn Quarter 2010 1st Quarter 2011
f* Quarter 2014 MW-12 Class III water D-3 Selenium AT Quarter 2013
4irQuarter 2011
2nd Quarter 2012
4th Quarter 2013
MW-15 Class III water D-4A
Iron
Selenium
Field pH
T Quarter 2012
3rd Quarter 2012
2nd Quarter 2014
MW-18 Class III water U-l
Thallium
Sulfate
TDS
T5 Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
2^ Quarter 2010
4th Quarter 2011
4th Quarter 2012
3ra 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
3™ Quarter 2010
1st Quarter 2012
1st Quarter 2013
37a~Quarter2010
1st Quarter 2012 MW-23 Class III water D-3 Field pH
Manganese
T5 Quarter 2010
MW-24 Class III water D-l
Cadmium
Thallium
Field pH
Fluoride
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2012
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2013
^"Quarter 2010
1st Quarter 2011
3rd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
MW-27 Class III water U-l
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
2^Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
T* Quarter 2010 3ia"Quarter2010
3rd Quarter 2010
3rd Quarter 2012
MW-28 Class III water D-l
Field pH
Chloride
Manganese
2nd Quarter 2010
2nd Quarter 2012
T3 Quarter 2011 MW-29 Class III water D-2 Field pH 4m Quarter 2010
EFR 4 Quarter Groundwater Monitoring Report
Page 5
Manganese
TDS
251 Quarter 2012
2nd Quarter 2012
i^Quarter 2010
2nd Quarter 2010
3ra Quarter 2012
3rd Quarter 2012
MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
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 Monitoring Wells in Accelerated Status as of the
fourth quarter 2013. 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.l(a), Accelerated
Monitoring Status Reports (AMSR)]. For the 4th quarter 2013 monitoring, the AMSR and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received, dated February 10, 2014 (received
by DRC on February 12, 2014).
Two wells/parameters with a new exceedance were noted per review of the AMSR; MW-25 was
accelerated from quarterly to monthly based on a 4th Quarter 2013 exceedance of the Uranium GWCL;
MW-30 was accelerated from quarterly to monthly based on a 4th Quarter 2013 exceedance of the Uranium
GWCL.
Two monitoring wells (three parameters) with a new exceedances were noted per review of the AMSR;
MW-3 was accelerated from semi-annual to quarterly based on a 4th Quarter 2013 exceedance of the
Nitrate + Nitrite and the Sulfate GWCL's; MW-15 was accelerated from semi-annual to quarterly
monitoring based on a 4th Quarter 2013 exceedance of the field pH GWCL.
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
4tnQtr. 2013 37 1-continuous 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 monitoring wells
prior to sample collection during the 4th Quarter 2013 monitoring period. Volumes are calculated
according to measured pump rates and can be verified by calibration marks on the collection carboys.
In cases where wells are evacuated to dryness the QAP Rev. 7.2, applicable requires that:
"(vii) If the well is purged to dryness:
EFR 4 Quarter Groundwater Monitoring Report
Page 6
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 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 and Radiological Comparisons for Blind
Duplicate Analysis
DRC conducted a review of the blind duplicate samples collected during the 4th 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 (4 total during the quarterly event - two with the baseline samples
and two 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.
EFR 4 Quarter Groundwater Monitoring Report
Page 7
Per DRC cross check of the blind duplicate samples collected and analyzed during the 4 Qtr. 2013 (See
Appendix 1 for comparisons), all sample results conform to the Permit requirements (within 20% RPD)
with the exception of Gross Alpha in the November 20, 2013 duplicate sample and Tetrahydrofuran
("THF") in the December 11, 2013 duplicate sample.
The Gross Alpha duplicate sample is not required to conform to the RPD <20% criteria of the Quality
Assurance Plan but is required to conform to the equation listed in 9.1.4.C Per DRC calculation, the
November 20, 2013 duplicate is in compliance with the Quality Assurance Plan, with a result of 1.349
(Required to be <2).
DRC noted that the THF RPD was not calculated in the EFR 4th Quarter Monitoring Report. The RPD
calculation result was 27.9 %. Per Part 9.1.4.a. of the QAP "RPDs will be calculated in comparisons of
duplicate and original field sample results. Non-conformance will exist when the RPD >20%, unless the
measured activities are less than 5 times the required detection limit (Standard Methods, 1998) "
For purposes of compliance with the EFR QAP, DRC has historically considered the term "detection limit"
to be synonymous with "reporting limit." The sample result for THF in MW-3 was 4.86 ug/L, and the
sample result for duplicate MW-70 was 3.67 ug/L. The reporting limit, per the American West Laboratory
Data Sheet was 1.0 ug/L. Therefore the blind duplicate meets conformance by the result being less than 5
times the reporting limit.
5. Analytical Laboratories Used by EFR Certified by 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 4th 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.
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
Primary AB responsible Deparrment of Health
for lab demographics r
GIS Location
Description
Comments
EFR 4 Quarter Groundwater Monitoring Report
Page 8
Effective Date
Commercial Samples Yes
Active Yes
Address 1
Type Location
Company
Contact Kyle Gross
Address 1 463 West 3600 South
Address 2
City Salt Lake City
State Utah
Zip 84115-
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
DRC noted that AWAL was accredited for all applicable analytes (analytes requested by EFR)
and that the specific analytes were updated on September 13, 2013.
GEL Laboratories LLC current Utah certification per the Utah Bureau of Health Website -
National Environmental Laboratory Accreditation Management System
Basic Details
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TNI00188
EPA Code SC00012
State ID E87156
Website
Extended Details
Primary AB responsible p|orj(ja 0^^^ of Health Environmental Laboratory Certification Program for lab demographics r
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
Address 1
Type Location
EFR 4 Quarter Groundwater Monitoring Report
Page 9
Company
Contact JAMES B. WESTMORELAND
Address 1 2040 Savage Rd
Address 2
City
State
Zip
Country
Phone
Fax
Email
Charleston
South Carolina
29407
US
8435568171
8437661178
ibw(q)gel.com
DRC noted that the only analyte requested by EFR to be analyzed by GEL Laboratories is gross alpha
(Total Alpha Radium) and that GEL Laboratories holds current accreditation in Utah for that analyte
(Effective update September 13, 2013)
6. Laboratory Report Turn Around Times
Per DRC review of EFR Table 1 included in the 4th 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 (21 to 37 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 4th 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 4th Qtr. 2013 reporting
period.
8. Laboratory QA/QC Flags - 4th Quarter 2013
QA/QC issues and DRC findings for the 4th Quarter 2013 are summarized below:
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DRC Findings
Laboratory reporting limits
were raised for various
samples for analysis of Ca,
Cl, K, Na, S04, Mg, Mn,
Nitrate/Nitrite (N),
Chloroform, TDS
Y 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-03A, MW-05, MW-17,
MW-23, MW-24, MW-27,
Y The sample result + the
counting errors were less
Per the QAP Part 9.1.4(b) "An
error term may be greater
EFR 4 Quarter Groundwater Monitoring Report
Page 10
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DRCFindings
MW-28, MW-30, MW-31,
MW-32, MW-36 Gross
Alpha Counting Error was
not <20% of the sample
analysis result (sample
activity)
than the GWCL in all
cases and are therefore
acceptable.
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-36
Selenium Arsenic,
Chromium, Cobalt, Copper,
Iron, Manganese, Nickel,
Zinc, MW-03 Manganese,
None Per the QAP Part 8.1.2(a)
matrix spikes are required but
no requirements which would
disqualify the laboratory data
Laboratory Duplicate %
Recovery Comparison
Outside of Range MW-31
TDS
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 in 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 criteria. 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 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 4th Qtr. 2013 Report, 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 4th Quarter 2013,
approximately 5% of wells cross checked, comparing water level measured elevations minus measured
static levels with plotted elevations, no errors were noted.
EFR 4 Quarter Groundwater Monitoring Report
Page 11
The upper wildlife ponds at the White Mesa Mill were 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. Per the 3rd Quarter 2013 the water
elevations showed additional significant decline in several wells (Piez-3, TWN-04, TW4-18, TW4-25).
These declines can be attributed to natural dissipation of the area ground water mound and/or ground water
pumping activities related to corrective action of nitrate and chloroform contamination plumes
(development of cone of depressions around pumping wells).
Static Water Level in Wells in the vicinity of the White Mesa Mill Upper Wildlife Pond
Well No. Static Level
2nd Quarter
2012
3*3
Quarter
2012
4m Quarter
2012
1st Quarter
2013
2,,aQuarter
2013
3ra Quarter
2013
4"' Quarter
2013
Piez 1 61.52 62.08 61.55 62.33 62.87 62.61 62.41
Piez 2 21.28 27.04 20.20 30.12 31.60 32.43 32.85
Piez 3 40.29 41.47 40.31 43.80 44.30 46.90 42.06
MW-19 52.08 54.19 55.01 55.1 56.84 57.25 57.96
MW-27 51.00 51.46 51.46 51.80 52.39 52.38 53.56
TWN-02
Pumping
Well 2013
21.02 23.66 20.93 28.41 32.37 32.31 31.28
TWN-03 32.83 34.00 32.76 35.90 37.32 37.14 36.50
TWN-04 41.03 43.40 41.01 46.30 47.75 48.54 49.87
TWN-06 74.62 75.17 75.27 75.49 75.93 75.95 76.94
TWN-07 i.39 87.86 87.76 87.25 87.05 86.85 87.26
TWN-08 61.64 62.20 62.30 62.53 63.01 Abandoned Abandoned
TWN-09
TWN-18
TW4-05
TW4-18
TW4-25
Pumping
Well 2013
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
Abandoned
59.45
60.7
61.28
83.72
Nitrate and Chloroform Corrective Action Plan Pumping Wells:
Ground water elevations are being impacted by effects from ground water pumping for the nitrate and
chloroform contamination plume remediation. The following monitoring wells have been converted to
active pumping wells:
Nitrate Pumping Wells TW4-22, TW4-24, TW4-25, TWN-2
Chloroform Pumping Wells - MW-4, MW-26, TW4-19, TW4-20, TW4-4
The nitrate pumping project was initiated during January 2013 (TW4-22, TW4-24, TW4-25 and TWN-2).
The chloroform pumping project was initiated during April 2003 utilizing two wells (Wells MW-4 and
EFR 4 Quarter Groundwater Monitoring Report
Page 12
TW4-19). Monitoring well MW-26 was then converted to a pumping well during August 2003.
Monitoring well TW4-20 was initiated as a pumping well during August 2005, and monitoring well TW4-4
was initiated as a pumping well in January 2010.
The pumping wells for both the nitrate and chloroform projects are set up with a delay device wherein the
wells purge for a set amount of time then shut off in order to let the well recharge. All pumping wells
include a flow meter which records the volume of water pumped from the well in gallons. Quarterly nitrate
and chloroform reports are prepared by EFR and include pump volumes and delineation of pump capture
zones based on kriged water contours. The kriged water level maps included with the 4th Quarter Report
include these areas which are directly southwest from the upper wildlife ponds.
DRC notes that the 4th Quarter 2013 Nitrate Report kriged water contour maps show developing cones of
depression around pumping wells TW4-25 and pumping wells TW4-20/MW-26. The depression around
well TW4-25 is particularly pronounced (early in pump period) probably due to the artificial recharge and
groundwater mounding in that area. Also, as discussed in the EFR Nitrate Corrective Action Report,
nitrate concentrations in pumping wells is expected to increase over time due to the large amount of
dilution from the groundwater mounding in the area which should decrease over time. DRC expects that
ground water elevation contours will continue to adjust in response to the pumping activities and
discontinuance of recharge to the upper wildlife ponds.
11. Conclusions and Recommendations
Based on DRC staff review of the above listed documents, it was noted that overall the requirements of the
Permit were met by EFR and the data collected during the 4th Quarter of 2013 appears to be reliable. It is
recommended that a correspondence letter be sent to EFR with the following items:
1. Notice of Enforcement Discretion regarding the failure of EFR to identify non-conformance of the
THF blind duplicate sample and failure to complete procedural requirements of the QAP.
2. Request for information consisting of follow up regarding the non-conformance in the THF blind
duplicate. The request will consist of follow up procedures required by the QAP.
3. Close out regarding DRC review of the 4th Qtr. 2013 White Mesa Uranium Mill Groundwater
Monitoring Report based on findings above.
12. References
1 Energy Fuels Resources (USA) Inc., February 12, 2014, 4th Quarter201S Groundwater Monitoring Report
Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill
2 Energy Fuels Resources (USA) Inc., February 10, 2014, Notice Pursuant to Part I. G.4(d) Q4, 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.I (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
for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County,
Utah.
EFR 4 Quarter Groundwater Monitoring Report
Page 13
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
Appendix 1 - EFR Blind Duplicates, DRC RPD Calculations
URANIUM ONE BLIND DUPLICATE ANALYSIS
Facility Name: Energy Fuels Resources
Well Number: MW-36 (Blind Duplicate MW-65)
MW-36 Sample
Parameter Sample Date Result mg/L
Date of Data Entry: 17-Mar-14
Blind Duplicate
Analysis MW-65
Relative Percent Difference
(RPD)
Calcium 11/20/2013 423 422 0.2
Magnesium 11/20/2013 130 131 -0.8
Potassium 11/20/2013 10.1 9.45 6.6
Selenium 11/20/2013 235 233 0.9
Sodium 11/20/2013 669 665 0.6
Thallium 11/20/2013 0.575 0.583 -1.4
Uranium 11/20/2013 24.3 26.7 -9.4
Bicarbonate 11/20/2013 301 286 5.1
Chloride 11/20/2013 54.7 59 -7.6
Fluoride 11/20/2013 0.35 0.297 16.4
Nitrate/Nitrite 11/20/2013 0.208 0.209 -0.5
Sulfate 11/20/2013 2480 2550 -2.8
Gross Alpha 11/20/2013 1 42 1.94 -31.0
Total Dissolved
Solids 11/20/2013 4520 4860 -7.2
DRC BLIND DUPLICATE ANALYSIS
Facility Name:
Well Number:
Parameter
Energy Fuels Resources
MW-03 (Blind Duplicate MW-70)
MW-29 Result
Sample Date mg/L
Date of Data Entry: 17-Mar-14
Blind Duplicate
Analysis MW-70
Relative Percent Difference
(RPD)
Calcium 12/11/2013 425 396 7.1
Magnesium 12/11/2013 239 223 6.9
Manganese 12/11/2013 975 876 10.7
Potassium 12/11/2013 23.3 21.7 7.1
Selenium 12/11/2013 32.8 29.9 7.1
Sodium 12/11/2013 785 722 8.4
Thallium 12/11/2013 1.1 0.991 10.4
Uranium 12/11/2013 37 34.2 7.9
Zinc 12/11/2013 20.3 18.2 10.9
Bicarbonate 12/11/2013 312 319 -2.2
Chloride 12/11/2013 63.8 61.8 3.2
Fluoride 12/11/2013 1.28 1.13 12.4
Nitrate/Nitrite 12/11/2013 1.21 1.24 -2.4
Sulfate 12/11/2013 3760 3430 9.2
Tetrahydrofuran 12/11/2013 4.86 3.67 27.9
Gross Alpha 12/11/2013 0.0
Total Dissolved
Solids 12/11/2013 5860 6140 -4.7
N.D. = Non Detected Concentration