DRC-2014-005327 - 0901a0688049136a

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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
DRC-2014-005327
MEMORANDUM
TO: File
THROUGH: Phil Goble, Compliance Section Manager
FROM: Tom Rushing, P.G. 0^ el/l^/2c?/9
September 15, 2014 DATE:
SUBJECT: Review ofthe August 15, 2014 Energy Fuels Resources (USA) Inc. 2nd Quarter 2014
Ground Water Monitoring Report for the White Mesa Uranium Mill
Review Summary:
The Utah Division of Radiation Control ("DRC") has reviewed the following documents submitted by
Energy Fuels Resources (USA) Inc. ("EFR"):
1. EFR, August 15,2014, Transmittal of 2nd Quarter 2014 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, August 11,2014, State oj Utah Ground Water Discharge Permit No. UGW370004 White
Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a).
3. EFR, August 11,2014, State of Utah Ground Water Discharge Permit No. UGW3 70004,
White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status.
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.
1. Checklist of Significant Findings ofthe 2nd Qtr 2014 Report and Related Actions at the White
Mesa Uranium Mill:
1. The 2" Quarter 2014 Report was received on August 19, 2014, which was before the due
date (Permit Part I.F.I the due date was September 1, 2014).
2. Per a previous EFR request, 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 ofthe 2nd Quarter 2014 Report recognizes the
telephone agreements regarding timelines for EFR to submit compliance notices. The
modification request is currently being addressed through the Permit renewal process.
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 2
3. DRC Stipulated Consent Agreement, Docket No. UGW12-03 required EFR to submit an
October 10, 2012 Source Assessment Report, an April 13, 2012 pH Report, and a
December 12, 2012 Pyrite Investigation Report for previously documented out-of-
compliance parameters (multiple parameters). 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 was 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 renewal process. Review of the
2nd Quarter 2014 Report is based on current Permit GWCL's, modified GWCLs are
required to undergo public notice requirements per the Utah Administrative Code and
listed in an active Permit.
4. Laboratory QA/QC flags were documented in 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 were violations
of the Permit or the Quality Assurance Plan ("QAP").
5. Four compliance parameters went into accelerated monitoring frequency during the
monitoring period. Gross Alpha in monitoring well MW-27 was accelerated from semi-
annual to quarterly based on an exceedance of the GWCL during the 2nd Quarter 2014;
Cadmium, Uranium and Vanadium in monitoring well MW-28 were accelerated from
semi-annual to quarterly based on exceedances of the GWCL during the 2nd Quarter 2014.
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 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:
Per past DRC review; lsl 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 submit 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 2014 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) was 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 February 2010 May 2010
MW-14 Class III water D-4A Field pH February 2010 May 2010
MW-25 Class III water C-3 Field pH
Fluoride
Uranium
Chloride
4m Quarter 2010
3rd Quarter 2013
3rd Quarter 2010
Is' Quarter 2013
February 2013
December 2013
March 2014
June 2013
MW-26(a) Class III water C-2
Field pH
Nitrate + Nitrite (as N)
Chloroform
Uranium
Chloride
Dichloromethane
Carbon Tetrachloride
February 2010
February 2010
February 2010
February 2010
February 2010
April 2010
1st Qtr 2014
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
June 2014
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 2014
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
February 2014
May 2010
May 2011
March 2011
January 2011
December 2012
June 2014
MW-35 Class II C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
3rd Quarter 2011
3rd Quarter 2012
July 2011
July 2011
July 2011
October 2011
December 2012
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 4
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
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
4m Quarter 2012
4,h Quarter 2012
4th Quarter 2012
1st Quarter 2013
1st Quarter 2013
Is' Quarter 2013
3~"rQuarter 2010
3rd Quarter 2010
3rd Quarter 2010 MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
2^Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2013
4th Quarter 2013
2nd Quarter 2014
2nd Quarter 2014
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
^Quarter 2010
2nd Quarter 2010
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
Is' Quarter 2013
2nd Quarter 2010
4th Quarter 2010
4lh Quarter 2012
MW-5 Class II water D-3 Uranium 4'" Quarter 2010 Is'Quarter 2011
MW-12 Class III water D-3 Selenium
Field pH
i^Quarter 2010
Is'Quarter 2014
3™ Quarter 2010
2nd Quarter 2014
^Quarter 2012
4th Quarter 2013 MW-15 Class III water D-4A Selenium
Field pH
3ra Quarter 2012
2nd Quarter 2014
MW-18 Class III water U-
Thallium
Sulfate
TDS
Field pH
2^ Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
Is'Quarter 2014
3™ Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
MW-19 Class III water U-l
Field pH
Nitrate + Nitrite as N
Adjusted Gross Alpha
^Quarter 2010
4,h Quarter 2011
4th Quarter 2012
3™ Quarter 2010
1st Quarter 2012
Quarter 2013
3"^ Quarter 2010 MW-23 Class III water D-3 Field pH 2^ Quarter 2010
3ia~Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
,st Quarter 2013
MW-24 Class III water D-1
Cadmium
Thallium
Field pH
Fluoride
f5 Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4Ul Quarter 2012
^Quarter 2010
4th Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
S^Quarter 2010
4th Quarter 2014
3 rd Quarter 2010
3rd Quarter 2010
Is' Quarter 2014
MW-27 Class III water U-
Nitrate +Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
^Quarter 2014
3 rd Quarter 2010
3rd Quarter 2012
2nd Quarter 2014
MW-28 Class III water D-1
Field pH
Chloride
Manganese
Cadmium
1st Quarter 2014
2nd Quarter 2010
2nd Quarter 2012
2nd Quarter 2014
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 5
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Uranium
Vanadium
2nd Quarter 2014
2nd Quarter 2014
2^ Quarter 2014
2nd Quarter 2014
2~™rQuarter2011
3rd Quarter 2012
3rd Quarter 2012
MW-29 Class III water D-2
Field pH
Manganese
TDS
4,n Quarter 2010
2nd Quarter 2012
2nd Quarter 2012
MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
2^ Quarter 2010
2nd Quarter 2010
3rd 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
second quarter of 2014. 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 2014 monitoring, the AMSR and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received, dated August 11, 2014 (received
by DRC on August 13,2014).
Four parameters with new exceedances were noted per review of the AMSR; MW-28 was accelerated from
semi-annual to quarterly based on 2nd Quarter 2014 exceedances of the Cadmium, Uranium, and Vanadium
GWCLs; MW-27 was accelerated from semi-annual to quarterly based on a 2nd Quarter 2014 exceedance
ofthe field pH GWCL.
DRC notes that monitoring well MW-28 was damaged prior to groundwater sampling, and that
exceedances of cadmium, uranium and vanadium may be the result of contamination after the damage. It
was noted that concentrations of arsenic, cadmium and manganese in the well were also higher than
historical concentrations, although not in exceedance of GWCL's. EFR is required to submit a plan and
time schedule report within 30 days of the accelerated monitoring report ("AMSR") if a parameter exceeds
the GWCL in two consecutive monitoring events. DRC will review issues regarding MW-28
contamination, monitoring well damage and repair when reviewing reports related to those issues.
EFR Request to Return Monitoring Well MW-28 Manganese, MW-29 Manganese, and MW-25
Fluoride, to Baseline Monitoring Frequency:
Per the EFR August 11, 2014 Request, EFR provides information regarding compliance monitoring at
wells MW-28 for manganese, MW-29 for manganese and well MW-25 for fluoride. These
wells/parameters are currently required to be sampled on an accelerated basis due to OOC status (see table
above).
MW-28 Manganese
The August 11, 2014 request for monitoring frequency reduction for manganese in MW-28 states that
monitoring results "have been below the Groundwater Compliance Limit ('GWCL "J specified in the
GWDP for eight consecutive sampling events since Q2 2012'." Per DRC review of the request and past
sampling result it appears that the last eight consecutive accelerated samples for manganese in monitoring
well MW-28 have been below the GWCL. Based on past approvals of return to baseline monitoring, this
request is consistent and return to baseline monitoring is appropriate.
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 6
MW-29 Manganese
The EFR August 11, 2014 request for monitoring frequency reduction for manganese in MW-29 is
likewise based on the eight most recent consecutive monitoring results showing concentrations below the
GWCL. Per DRC review of the monitoring results it appears that return to baseline monitoring frequency
is appropriate.
MW-25 Fluoride
The EFR August 11, 2014 request for monitoring frequency reduction for fluoride in MW-25 is likewise
based on the eight most recent consecutive monitoring results showing concentrations below the GWCL.
Per DRC review of the monitoring results it appears that return to baseline monitoring frequency is
appropriate.
Therefore, the wells/parameters and monitoring frequencies listed on the table below are recommended to
be approved.
Well:No3§|#«tgff^;. Parameter Baseline MohT^rinjg Fr^uericyl;^^
MW-28 Manganese Semi-Annual
MW-29 Manganese Semi-Annual
MW-25 Fluoride Quarterly
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 during the 2nd Quarter 2014
(including accelerated samples):
Quarter # Purged 2 Casing Volumes # Purged to Dryness # Purged 3 Casing Volumes
2"* Qtr. 2014 33 5 3-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 volumes (when 2 casing volume method selected) in monitoring wells prior to
sample collection during the 2nd Quarter 2014 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 requires that:
"(vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worksheet.
EFR 2 Quarter 2014 Groundwater Monitoring Report
Page 7
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 of pH, 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 and Radiological Comparisons for Blind
Duplicate Analysis:
DRC conducted a review of the blind duplicate samples collected during the 2nd Quarter 2014. 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.
Per DRC cross check of the blind duplicate samples collected and analyzed during the 2nd Qtr. 2014 (See
Appendix 1 for comparisons), all sample results conform to the Permit requirements (within 20% RPD)
with the exception of Uranium in the MW-25/MW-65 April monthly sample and Thallium in the MW-
35/MW-65 May monthly sample.
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 8
Thallium Nonconformance Blind Duplicate MW-35/MW-65
EFR noted that in the case of Thallium in MW-35/M W-65, no additional action was taken since the
duplicate results are not greater than 5 times the required detection limits. Per DRC review of the results
this was confirmed. 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)." The sample result
for thallium in MW-35 was 0.000521 ug/L, and the sample result for duplicate MW-65 was 0.000672
ug/L. The reporting limit, per the American West Laboratory Data Sheet was 0.0005 ug/L (5 X RL =
0.0025 pg/L). Therefore the blind duplicate meets conformance by the result being less than 5 times the
reporting limit.
Uranium Nonconformance Blind Duplicate MW-25/MW-65
The uranium blind duplicate results were outside of acceptance limits and EFR therefore implemented
corrective actions in conformance with the requirements of the QAP. Per the 2nd Quarter 2014 Report:
"The corrective actions that were taken in accordance with the QAP procedure are as follows: the QA
Manager contacted the Analytical Laboratory and requested a review of the raw data to assure that there
were no transcription errors and the data were accurately reported...reanalysis was not completed as the
laboratory is temporarily unavailable due to a catastrophic fire suffered in early July." DRC notes that the
reported concentrations for uranium in blind duplicate MW-25/MW-65 were 0.0106 mg/L and 0.00791
mg/L respectively. It is noted that the reported concentrations were above the Permit compliance limit
(0.0015 mg/L), but below the Utah Ground Water Quality Standard (0.03 mg/L). Based on DRC review of
the corrective actions it appears that the actions taken were appropriate (given the circumstances of the
laboratory fire).
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:
American West Analytical
Laboratories
Type of Lab Commercial
TNI Lab Code TNI01955
EPA Code UT00031
State ID 8012638686
Website
Extended Details
EFR 2n Quarter 2014 Groundwater Monitoring Report
Page 9
Prirnary AB responsible ^ D ent of Hea,th
for lab demographics
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
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 TN100188
EPA Code SC00012
State ID E87156
Website
Extended Details
Primary AB responsible pjorj(ja rj)epanTnent of Health Environmental Laboratory Certification Proaram for lab demographics r J °
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 10
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]
Email [e-mail]
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
method EPA 900.1.
6. Laboratory Report Turn Around Times:
Per DRC review of EFR Table 1 included in the 2nd Qtr. 2014 Report, it was noted that laboratory report
turnaround times (from date of EFR sample submission to the contract laboratory) was 30 days on average
(not including re-submission/corrected reports) with the longest report turnaround time being 36 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 2nd Quarter 2014,
data appear to be reasonable/appropriate.
7. Sample Holding Times:
Per Table G-2A and Table G-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. 2014 reporting
period.
8. Sample Preservation:
Per review of the 2nd Quarter 2014 Report (Table G-3A and Laboratory Check-in Sheets) it appears that all
samples required to be chilled (<6° C) met the temperature preservation requirements. Per review of the
laboratory check in sheets, no issues related to sample preservation were noted.
9. Laboratory QA/QC Flags - 2nd Quarter 2014:
QA/QC issues and DRC findings for the 2nd Quarter 2014 are summarized below:
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page
Non-Conformance Summary Self-^fe I
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,
Fluoride, TDS. Silver,
Nitrate/Nitrite (as N), Iron,
Fluoride.
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. DRC verified that in
all cases when the RL was
raised above the QAP required
RL the sample result was
higher in concentration
MW-1, MW-18-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-32
Nitrate/Nitrite, MW-05,
Magnesium, MW-12,
Chloride, Fluoride, Sulfate,
MW-22, Ammonia, MW-23,
Nitrate/Nitrite.
None Per the QAP Part 8.1.2(a)
matrix spikes are required but
there are no requirements
which would disqualify the
laboratory data
Laboratory Duplicate %
Recovery Comparison
Outside of Range MW-20
TDS.
Y 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 <6° C.
10. 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
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 12
included on the plots (no data culled from the set). Per DRC review ofthe 2nd Qtr. 2014 Report, the
reviewed plots appear to be in conformance with the agreed upon changes, no issues were identified.
11. 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 2014,
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 ponds at the White Mesa Mill were taken offline (pond recharge from Recapture
Reservoir discontinued) during the 4th Quarter 2011. Hydrographs of the upper wildlife pond ground water
piezometers (Water Level Elevation vs. Time) are included below. It was also noted that the static water
levels in several monitoring wells close to the upper wildlife ponds showed significant decrease in water
levels during recent quarterly monitoring. 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).
IUC White Mesa Mill Hydrographs: Piezometers @ North Wildlife Ponds
5.622
5.818
5.614 IF
*•* :•»
5.610
<>••* 5.606
*• Sti 5.602
5.598
5.594
J3~ a+-oa
5.590
5.586 72
Location Rtiattve toVWdWa Ponds
North Ponds P-l (north side)
P 2 (between)
P-3 (soum side)
5.582
5,578
5,574
I
EFR 2nd Quarter 2014 Groundwater Monitoring Report
Page 13
IUC White Mesa Mill Hydrographs: Piezometers (3> South Wildlife Ponds
"T"
Location Relative to Wildlife Ponda
SoufttPonds P-4 (norm side)
P-5 (soutti side)
3^
-o-P-5
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
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 during 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 2nd Quarter 2014
Report include these areas which are directly southwest from the upper wildlife ponds.
EFR 2n Quarter 2014 Groundwater Monitoring Report
Page 14
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.
12. Conclusions and Recommendations
Based on DRC staff review ofthe above listed documents, it was noted that overall the requirements of the
Permit were met by EFR and the data collected during the 1st Quarter of 2014 appears to be reliable. It is
recommended that a correspondence letter be sent to EFR with the following items:
1. Advisory regarding elevated concentrations of vanadium, arsenic and uranium) in Monitoring Well
MW-28 (damaged monitoring well).
2. Approval of return to baseline monitoring form manganese in MW-28, manganese in MW-29, and
fluoride in MW-25.
3. Close out regarding DRC review of the 2nd Quarter 2014 White Mesa Uranium Mill Groundwater
Monitoring Report, based on findings above.
13. References
1 Energy Fuels Resources (USA) Inc., August 15, 2014, 2nd Quarter2014 Groundwater Monitoring Report,
Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., August 11, 2014, State of Utah Ground Water Discharge Permit No.
UGW3 70004 White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a).
3 Energy Fuels Resources (USA) Inc., August 11, 2014, State of Utah Ground Water Discharge Permit No.
UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater
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.
6 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison Mines
(USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
1 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.
8 Utah Department of Environmental Quality, August 24, 2012, Utah Ground Water Discharge Permit,
Permit No. UGW370004 issuedfor the Energy Fuels Resources (USA) Inc. White Mesa Uranium Mill.
Appendix 1 - EFR Blind Duplicates, DRC RPD Calculations
• ENERGY.FUELS RESOURCES BLIND DUPLICATE1 ANALYSiS^, ;.,o>#
-I Date.;6f Da^§^
Facility Name:?};':
i-Well Number "
jgarameterlj
Energy Fuels Resources - Entry;;.^• 25-Aug-14
MW:35 (Blind Duplicate MW-65) ^f^^^^l^^i^^^i
^mple.Date^;
MW-35 Sample; :j, Bnrtd;Dupli&ate|
Result,rng/L -
Relative Perqen^
Calcium 6/4/2014 518 533 -2.9
Iron 6/4/2014 81.3 87.4 -7 2
Magnesium 6/4/2014 173 173 0.0
Manganese 6/4/2014 202 205 -1 5
Potassium 6/4/2014 11.6 11 9 -2.6
Selenium 6/4/2014 139 142 -2 1
Sodium 6/4/2014 386 396 -2.6
Uranium 6/4/2014 21 9 22 4 -2.3
Ammonia 6/4/2014 0 0778 0 0831 -6.6
Bicarbonate 6/4/2014 340 360 -5.7
Chloride 6/4/2014 62.6 59 4 52
Fluoride 6/4/2014 0 35 0.347 09
Sulfate 6/4/2014 2040 1960 40
Gross Alpha 6/4/2014 3 36 4 17 -21 5
Total Dissolved
Solids 6/4/2014 3720 3,880 -4 2
Facility Name:
Well Number
Parameter
•ENERGY,FUELS RESOURCES BLIND DUPLICATE ANALYSIS.^k*';' *;
:Mi 25-Aug-14
5 Date of Data
Energy Fuels Resources :' Entry: -;
MW-22 (Blind Duplicate MW-70) '•1 ' " ':"" V ; "'7
[MW-22 Sample*., Blind Duplicate ; Relative percent
Sampled Date Result mg/L • Analysis MW-70 • , Difference (RPD)
Calcium 6/11/2014 400 416 -3 9
Beryllium 6/11/2014 152 158 -3.9
Cadmium 6/11/2014 169 170 -0.6
Cobalt 6/11/2014 513 525 -2 3
Copper 6/11/2014 120 121 -0 8
Iron 6/11/2014 69 4 78 3 -12.1
Lead 6/11/2014 6 29 6.54 -3 9
Magnesium 6/11/2014 1120 1180 -5.2
Manganese 6/11/2014 46500 50400 -8.0
Molybdenum 6/11/2014 183 187 -2 2
Nickel 6/11/2014 316 321 -1.6
Potassium 6/11/2014 20.9 21.5 -2.8
Selenium 6/11/2014 16.9 18 -6 3
Sodium 6/11/2014 267 274 -2.6
Thallium 6/11/2014 1.44 1.46 -1 4
Uranium 6/11/2014 31 9 31.9 00
Zinc 6/11/2014 1470 1530 -4 0
Ammonia 6/11/2014 0 534 0.652 -19.9
Bicarbonate 6/11/2014 12.5 143 -134
Chloride 6/11/2014 54 9 54 8 02
Page 17
Fluoride 6/11/2014 14.5 14.4 07
Nitrate/Nitrite 6/11/2014 2 97 2 96 0.3
Sulfate 6/11/2014 6950 6830 1 7
Gross Alpha 6/11/2014 3.57 3.39 5.2
Total Dissolved
Solids 6/11/2014 8560 8,480 0.9
. ENERGY FUEL^^^gl^g
Facility Name: Energy Fuels Resources
•Well Number : MW-25 (Blind Duplicate MW-65)
* \ - "" " MW-25 Sample
Parameter . ; * *. Sample Date ;; Result mg/L
JND DUPLICATE ANALYSIS;
Date of Data .
Entry: <
Blind: Duplicate : Relative Percent
Analysis MW-65 '; Difference (RPD)
mm
25-Aug-14
Cadmium 4/28/2014 1 51 1.8 -17.5
Chloride 4/28/2014 31 31.6 -1.9
Fluoride 4/28/2014 0 409 0.446 -8.7
Uranium 4/28/2014 106 7.91 29 1
ENERGY FUELS RESOURCES BLIND DUPLICATE ANALYSIS
Facility Name:
Well Number:
Parameter
Energy Fuels Resources
MW-35 (Blind Duplicate MW-65)
.;:;!V.MW:35 Sample
Sample Date^f* Result mg/L .' j
. bate of Data
Entry:
Blind Duplicate
Analysis MW-65
25-Aug-14
' Relative Rercenf;|
Difference.(RPpj^#.
Ill mi
Manganese 5/14/2014 249 226 9.7
Selenium 5/14/2014 17 155 92
Thallium 5/14/2014 0 521 0 672 -25.3
Uranium 26 9 27.8 -3.3
Gross Alpha 5/14/2014 3 67 5.38 -37.8