DRC-2015-001086 - 0901a068804d8afc

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIA TION CON TROL
Rusty Lundberg
Director DRC-2015-001086
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File
'A/ir Phil Goble, Compliance Section Manager
Tom Rushing, P.G. >Ji^—
January 7, 2015
Review of the November 5, 2014 Energy Fuels Resources (USA) Inc. 3r 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, November 5,2014, Transmittal of 3rd Quarter 2014 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, November 14,2014, State of Utah Ground Water Discharge Permit No. UGW3 70004
White Mesa Uranium Mill — Notice Pursuant to Part I.G.I (a).
3. EFR, December 4, 2014, Transmittal of Plan and Time Schedule under Utah ground Water
Discharge Permit UGW370004 Part I.G.4(d) White Mesa Mill
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 of the 3rd Qtr 2014 Report and Related Actions at the White
Mesa Uranium Mill:
1. The 3r Quarter 2014 Report was received on November 10, 2014, which was before the
due date (Permit Part I.F.I the due date of December 1, 2014).
2. DRC notes that samples were analyzed by a different laboratory (Chemtec-Ford
Laboratories) than previous reports which utilized American West Analytical Laboratories
("AWAL"). This was due to a fire at the AWAL facility. EFR notified DRC ofthe
needed change prior to submitting the samples for analysis. Per discussion below, DRC
notes that Chemtec-Ford has current certification for all parameters/methods used. No
deviations/violations of the currently approved Quality Assurance Plan for the White Mesa
Uranium Mill.
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 2
3. 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 of the 3rd 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.
4. DRC Stipulated Consent Agreement, Docket No. UGW 12-03 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
3rd 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.
5. Permit compliance limits for monitoring wells around the White Mesa Mill Cell 4B
(Monitoring Wells MW-35, MW-36 and MW-37) were approved by the Director via letter
dated July 15, 2014. The approval was based on DRC staff review of a May 1, 2014 EFR
Background Groundwater Quality Report for the wells. The approved GWCL's will not
be enforceable until final inclusion in the renewal permit; therefore, the 3rd Quarter Report
data results were compared with the interim limits or groundwater quality standards as
listed in the currently active Permit.
6. 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").
7. One compliance parameter went into accelerated monitoring frequency during the
monitoring period; Field pH was accelerated form semi-annual to quarterly sampling based
on second exceedances during the 3rd quarter 2014 ground water sampling event.
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
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.
EFR 3 Quarter 2014 Groundwater Monitoring Report
Page 3
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.
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 Monito ring
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
Uranium
Chloride
4m Quarter 2010
3rd Quarter 2010
Is' Quarter 2013
February 2013
March 2014
June 2013
MW-26 (a) Class III water C-2
Field pH
Nitrate + Nitrite (asN)
Chloroform
Uranium
Chloride
Dichloromethane
Carbon Tetrachloride
February 2010
February 2010
February 2010
February 2010
February 2010
April 2010
Is' 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
February 2010
1st Quarter 2011
April 2010
May 2010
May 2011
July 2010
EFR 3r Quarter 2014 Groundwater Monitoring Report
Page 4
Well Class *Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Uranium 4"' Quarter 2011 March 2014
MW-31 Class III water D-2
Nitrate + Nitrite (asN)
Chloride
Sulfate
TDS
Selenium
Field pH
February 2010
Is' Quarter 2011
4,h 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 201 1
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
4,h Quarter 2012
3rd Quarter 2014
4th Quarter 2012
4'h Quarter 2012
Date Accelerated
Monitoring First
Required
MW-1 Class II water U-l
Tetrahydrofuran
Field pH
Sulfate
Manganese
f5 Quarter 2010
Is'Quarter 2013
1st Quarter 2015
Is' Quarter 2013
Is' Quarter 2013
MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (as N)
Sulfate
2nd Quarter 2010
2nd Quarter 2010
4,h Quarter 2013
4th Quarter 2013
3™ Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
^Quarter 2010
MW-3 A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (asN)
2nd Quarter 2010
2nd Quarter 2010
4,h Quarter 2010
4lh Quarter 2012
3rd Quarter 2010
3rd Quarter 2010
3 rd Quarter 2010
1st Quarter 2011
Is' Quarter 2013
MW-5 Class II water D-3 Uranium 4"1 Quarter 2010
^Quarter 2010
Is'Quarter 2014
Is'Quarter 2011
MW-12 Class III water D-3 Selenium
Field pH
3rd Quarter 2010
2nd Quarter 2014
2^ Quarter 2012
4lh Quarter 2013 MW-15 Class III water D-4A Selenium
Field pH
3rd Quarter 2012
2nd Quarter 2014
T5 Quarter 2010
MW-18 Class III water U-
Thallium
Sulfate
TDS
Field pH
2nd Quarter 2010
2nd Quarter 2010
Is' Quarter 2014
2"^ Quarter 2010
4,h Quarter 2011
4lh Quarter 2012
3rd 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
T5 Quarter 2010
3™ Quarter 2010
Is' Quarter 2012
Is'Quarter 2013
MW-23 Class III water D-3 Field pH 3rg Quarter 2010
EFR 3 Quarter 2014 Groundwater Monitoring Report
Page 5
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-24 Class III water D-l
Cadmium
Thallium
Field pH
Fluoride
TT Quarter 2010
2"d Quarter 2010
2nd Quarter 2010
4lh Quarter 2012
2~i!TQuarter 2010
4lh Quarter 2010
1st Quarter 2010
1st Quarter 2010
2nd Quarter 2013
3rd Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
Is' Quarter 2013
MW-27 Class 111 water U-l
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
3™ Quarter 2010
4,h Quarter 2014
3rd Quarter 2010
3rd Quarter 2010
lsl Quarter 2014
2^ Quarter 2014
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
MW-28 Class III water D-l
Field pH
Chloride
Cadmium
Uranium
Vanadium
Is' Quarter 2014
2nd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
2nd Quarter 2014
4th Quarter 2010 f5 Quarter 2011
3rd Quarter 2012 MW-29 Class III water D-2 Field pH
TDS 2nd Quarter 2012
Quarter 2010 MW-3 2 Class III water C-2 Adjusted Gross Alpha
Field pH 2nd Quarter 2010
3ra Quarter 2010
3rd Quarter 2010
* D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A = Cell U
Table 1 above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status as of the
third 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 3rd quarter 2014 monitoring, the AMSR and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received, dated November 14, 2014
(received by DRC on November 18, 2014).
One parameter with a new exceedance was noted per review of the AMSR; MW-28 was accelerated from
semi-annual to quarterly based on a 3rd Quarter 2014 exceedances of the Cadmium, Uranium, and
Vanadium GWCLs; MW-27 was accelerated from semi-annual to quarterly based on a 3rd Quarter 2014
exceedance of the field pH GWCL.
DRC notes that monitoring well MW-28 was damaged prior to groundwater sampling during the 2nd
Quarter 2014 and per discussions with EFR at that time, it was agreed that the results of the 3rd Quarter
2014 would be reviewed and compared with those previous data to determine if exceedances of cadmium,
uranium and vanadium were continuous. 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. See sections below for comparisons of the 2nd Quarter and 3rd Quarter 2014 data results.
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:
"/. Purging three well casing volumes with a single measurement offield parameters
2. Purging rwo casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after recovery"
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 6
Per DRC review of the Report, the following purge methods were used during the 3rd Quarter 2014
(including accelerated samples):
Quarter | # Purged 2 Casing Volumes # Purged to Dryness I # Purged 3 Casing Volumes
3rd Qtr. 2014 30 4 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 3rd Quarter 2014 monitoring period. Volumes are calculated according to
measured pump rates and can be verified by calibration marks on the collection carboys.
During the 3rd Quarter monitoring four wells were pumped or bailed to dryness (It was noted that MW-23
was pumped to dryness on 9/4/2014, however the required analysis was for pH only and no field samples
were collected). 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.
The well should be sampled as soon as a sufficient volume of groundwater is available lo 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 shippedfor analysis.
If the field parameters ofpH, specif c 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 and samples were
collected, 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.
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 7
4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind
Duplicate Analysis:
DRC conducted a review of the blind duplicate samples collected during the 3rd 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 ofthe blind duplicate samples collected and analyzed during the 3rd Qtr. 2014 (See
Appendix 1 for comparisons), all sample results conform to the Permit requirements (within 20% RPD)
with the exception of Nitrate + Nitrite and Zinc for the M W-37/MW-65. Duplicates for Gross Alpha were
analyzed using the formula in the current QAP Section 9.1.4. DRC also noted a large discrepancy between
the blind duplicate sample results for MW-37/MW-70.
Nitrate +Nitrate and Zinc Nonconformance Blind Duplicate MW-37/MW-70
EFR noted that "both of the sample results reported for MW-37/MW-70 were not five times greater than
the reporting limits of 0.1 and 10 respectively and as such the deviation from the 20% RPD requirement is
acceptable." Per review DRC agrees that this is the case and no further action is required regarding the
blind duplicate results.
Gross Alpha Nonconformance Blind Duplicate MW-37/MW-70
The laboratory results for Adjusted Gross Alpha are summarized on the table below:
Date
9/17/2014
9/17/2014
Well No.
MW-3 7
MW-70
Adjusted Gross Alpha Result (pCi/L)
1.17 +/-0.265 (GEL Laboratories)
<1.00+/-.230
DRC notes that the result for MW-70 was reported as not detected and therefore EFR did not provide
results for comparisons of this blind duplicate. DRC performed a comparison of the results as 1.17 pCi/L
and 1.0 pCi/L and notes that the formula for comparison of radiological samples includes an evaluation of
the error terms for each sample. Using a value of 1.0 pCi/L for MW-70 is therefore conservative.
The result of the comparison showed a value of 50.4 which is out of bounds per the current QAP which
requires a result of <2. DRC will include an advisory in the transmittal letter to EFR noting that the blind
duplicate indicates poor comparability and should be subject to follow up action as required by the QAP.
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 8
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 Chemtech Ford
Laboratories, Salt Lake City, UT) were contracted by EFR to perform analysis on the samples
collected during the 3rd Quarter, 2014. 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.
Chemtech Ford Laboratories current Utah certification per the Utah Bureau of Health Website -
National Environmental Laboratory Accreditation Management System:
Basic Details
Name Chemtech Ford Laboratory
Type of Lab Commercial
TNI Lab Code TNI0I969
EPA Code UT00027
State ID 8012627299
Website http://www.chemtechford.com/
Extended Details
Primary AB responsible
for lab demographics
GIS Location
Description
Comments
Effective Date
Commercial Samples
Active Yes
Address 1
Type Location
Company Chemtech Ford Laboratories
Contact David Gayer
Address I 9632 South 500 West
Address 2
City Sandy
State Utah
Zip 84070
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
GEL Laboratories LLC current Utah certification per the Utah Certification and attached list of
certified parameters and methods.
Basic Details
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TNI00188
Utah Department of Health
Yes
EFR 3r Quarter 2014 Groundwater Monitoring Report
Page 9
EPA Code SC00012
State ID E87I56
Website
Extended Details
Primary AB responsible
for lab demographics 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]
Email jbwffiuel com
DRC noted that the only analyte requested by EFR to be analyzed by GEL Laboratories was gross alpha
(Total Alpha Radium) and that GEL Laboratories holds current accreditation in Utah for that analyte
method EPA 900.1.
DRC additionally notes that EFR changed laboratories from American West Analytical ("AWAL") to
Chemtech Ford for the 3rd Quarter 2014 data period, which was due to a fire at AWAL rendering the
laboratory unable to process samples. DRC notes that EFR contacted/coordinated the laboratory change
with DRC via several telephone conference calls. DRC recognizes that some of the data reported for the
3rd Quarter 2014 does not appear to conform to past measurements. EFR does not specifically discuss
laboratory discrepancies in the Report; laboratory results are compared with Permit listed GWCL without
further justifications.
6. Laboratory Report Turn Around Times:
Per DRC review of EFR Table 1 included in the 3rd Qtr. 2014 Report, it was noted that laboratory report
turnaround times (from date of EFR sample submission to the contract laboratory) for normal frequency
monitoring was approximately 30 days on average (not including re-submission/corrected reports) with the
longest report turnaround time being 31 days. Accelerated samples for July 2014 had an average
turnaround time of approximately 50 days; and accelerated samples for August 2014 had an average
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 10
turnaround of 40 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 tum-around
times in the past and the Director may require a tum-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 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 be analyzed within holding times during the 3rd Qtr. 2014 reporting period.
8. Sample Preservation:
Per review of the 3rd Quarter 2014 Report (Table G-3 A 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 - 3rd Quarter 2014:
QA/QC issues and DRC findings for the 3rd Quarter 2014 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,
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-26, MW-27 - 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-37
Nitrate, MW-26
Nitrate/Nitrite, MW-31
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-3 5
Gross Alpha.
The results outside of the
laboratory established
acceptance limits do not
affect the quality or
usability of the data
because the recoveries
DRC notes that the laboratory
(GEL) reported the data
without a qualifier.
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 11
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DRC Findings
and RPD's above the
acceptance limits are
indicative of non-
homogeneity in the
sample matrix.
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. 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); 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 ofthe 3rd 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 3rd 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 ofthe
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 Q North Wildlife Ponds
UJ *M2 i
• !
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 12
IUC White Mesa Milt Hydrographs. Piezometers © South Wildlife Ponds
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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.
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. EFR November 14, 2014 Notice Pursuant to the Permit Part I.G.l(a)
The EFR November 14, 2014 Notice Pursuant to the Permit Part I.G.I (a) ("Notice") discusses the status
of monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-compliance
EFR 3rd Quarter 2014 Groundwater Monitoring Report
Page 13
("OOC") status, as updated through the 3rd Quarter 2014. DRC notes that the Notice was submitted timely
regarding currently agreed upon schedules.
The Notice summarizes wells/parameters with OOC status which have been resolved by either separate
corrective actions plans or approved modified GWCL's (pending inclusion in the renewal Permit). The
Notice also lists one new monitoring well/parameter (MW-28 Uranium) which went into OOC status
during the 3rd Quarter and is subject to requirements of the Permit Part I.G.4(c) requiring an assessment of
the sources of the contamination and potential remedial action to restore compliance. The assessment for
MW-28 was received by DRC, dated December 4, 2014, and is discussed in the section below.
Based on DRC review of the Notice it appears that all requirements of the Permit were met.
13. EFR December 4, 2014 Transmittal of Plan and Time Schedule for Wells in Out-of-
compliance ("OOC") Status
The EFR December 4, 2014 Transmittal of Plan and Time Schedule under Utah Ground Water Discharge
Permit ("Plan") documents planned actions regarding monitoring well parameters which went into out-of-
compliance ("OOC") status during the 3rd quarter of 2014 and were subject to the requirements of the
Permit Part I.G.4(c) which requires the Plan to be submitted to DRC within 30 calendar days. Uranium in
monitoring well MW-28 was the only constituent identified in the Plan.
The Plan notes that monitoring well MW-28 was struck by a vehicle during May 2014 which damaged the
monitoring well outer and inner casings. The Plan includes an attached Well Repair Notification for well
MW-28 which was dated July 2, 2014 and sent to the DRC Director. The Notification documents well
damage, pump retrieval and repair activities which occurred at the site. The Plan notes that monitoring
violations at the well may have been caused by debris entering the well due to the damage and the repair
activities. DRC notes that EFR provided overpumping at the well for redevelopment on June 5, 2014.
Per DRC comparison of 2nd Quarter 2014 and 3rd Quarter 2014 U ranium data, it appears that all
concentrations noted as in probable-out-of-compliance status (Cadmium, Uranium, Vanadium) or with
elevated concentrations when compared to background (Manganese) as reported for the 2nd Quarter
decreased during the 3rd Quarter. Based on these decreases, DRC agrees that the damage was a likely
cause of the exceedances and that some residual material may be present in the well. If this is the case then
the material will potentially be removed by continued purging activities during routine sampling.
DRC additionally notes that EFR accelerated monitoring (semi-annual to quarterly) for the parameters
exceeding GWCL's at MW-28 during the 2nd Quarter 2014 (Cadmium, Uranium, Vanadium) was initiated
by EFR in compliance with the Permit requirements.
Based on the likely cause of the MW-28 uranium OOC status, EFR proposes that the corrective action will
be to continue accelerated monitoring to determine if the uranium concentrations decrease to below
compliance limits. DRC agrees that this action is sufficient, at this time, to determine if compliance at the
monitoring well will be re-established by continued purging and sampling.
14. Conclusions and Recommendations
Based on DRC staff review of the above listed documents, it was noted that the requirements of the Permit
appear to have been met by EFR and the data collected during the 3rd Quarter of 2014 appear to be reliable.
It is recommended that a correspondence letter be sent to EFR with the following items:
EFR 3r Quarter 2014 Groundwater Monitoring Report
Page 14
1. Closeout regarding DRC review ofthe EFR 3rd Quarter 2014 White Mesa U ranium Mill
Groundwater Monitoring Report, based on findings above.
2. Findings regarding DRC review of November 14, 2014 Notice. Note that several of the parameters
currently in POOC/OOC have been resolved through previous approved actions (Chloroform and
Nitrate Plumes) or approved modified GWCL's (Pending inclusion in the renewal Permit).
3. Discussion ofthe EFR December 4, 2014 Plan and Time Schedule for 3rd Quarter 2014 GWCL
exceedances (Uranium in MW-28). Discussion regarding Monitoring Well MW-28 which was
damaged during the previous quarter and concurrence with the decision to maintain accelerated
monitoring to determine if continued purging and sampling shows a decrease of uranium
concentrations to below the GWCL.
14. References
1 Energy Fuels Resources (USA) Inc., November 5, 2014, 3rd Quarter2014 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., December 4, 2014, State of Utah Ground Water Discharge Permit
No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part I.G4(d).
3 Energy Fuels Resources (USA) Inc., June 6, 2012, White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP), Revision 7.2.
5 INTERA Incorporated, 2007, Revised Background Groundwater Quality Report: Existing Wells
for Dension Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
6 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison Mines
(USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
7 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 DUPLICATE ANALYSIS
Facility Name: Energy Fuels Resources
Well Number MW-30 (Blind Duplicate MW-65)
Parameter MW-30 Sample
(mg/L) Sample Date Result mg/L
Arsenic 9/9/2014 0 0059
Date of Data
Entry
Blind Duplicate
Analysis MW-65
0 0052
25-Nov-14
Relative Percent
Difference (RPD)
126
Bicarbonate 9/9/2014 189 188 05
Calcium 9/9/2014 242 239 1 2
Chloride 9/9/2014 136 137 -0 7
Fluoride 9/9/2014 04 04 00
Magnesium 9/9/2014 66 8 67 -0 3
Manganese 9/9/2014 0015 0015 00
Nitrate + Nitrite 9/9/2014 16 8 17 3 -2 9
Potassium 9/9/2014 63 6 3 00
Selenium 9/9/2014 0 0536 0 049 90
Sodium 9/9/2014 94 9 93 7 1 3
Sulfate 9/9/2014 720 722 -0 3
TDS 9/9/2014 1540 1560 -1 3
Uranium 9/9/2014 0 0077 0 007 95
ENERGY FUELS RESOURCES BLIND DUPLICATE ANALYSIS
Facility Name:
Well Number:
Parameter
(mg/L)
Energy Fuels
MW-37 (Blind
Sample Date
Resources
Duplicate MW-70)
MW-37 Sample
Result mg/L
Date of Data
Entry:
Blind Duplicate
Analysis MW-70
25-Nov-14
Relative Percent
Difference (RPD)
Bicarbonate 9/17/2014 243 240 1 2
Calcium 9/17/2014 403 425 -5 3
Chloride 9/17/2014 44 44 00
Fluoride 9/17/2014 03 0 3 00
Magnesium 9/17/2014 121 126 -4 0
Nickel 9/17/2014 0 0347 0 0344 09
Nitrate + Nitrite 9/17/2014 1 04 85 7
Potassium 9/17/2014 14 3 147 -2 8
Selenium 9/17/2014 0 0122 00115 59
Sodium 9/17/2014 475 493 -3 7
Sulfate 9/17/2014 2370 2380 -0 4
TDS 9/17/2014 3850 3840 03
Thallium 9/17/2014 0 0005 0 0005 00
Uranium 9/17/2014 0 0107 0 0103 38
Zinc 9/17/2014 0 01 0 02 -66 7
Adjusted Gross
Alpha (pCi/L)
9/17/2014 1 17 50.4
ENERGY FUELS RESOURCES BLIND DUPLICATE ANALYSIS
Facility Name: Energy Fuels Resources
Well Number: MW-35 (Blind Duplicate MW-65)
Date of Data
Entry: 25-Nov-14
Page 17
MW-25 Sample Blind Duplicate Relative Percent
Parameter Sample Date Result mg/L Analysis MW-65 Difference (RPD)
Manganese I 7/29/2014 I 0 212 I 0 221 I -4 2
Selenium 7/29/2014 0 0132 0 0127 39
Uranium 7/29/2014 0 0265 0.0225 16 3
Gross Alpha 7/29/2014 3 09 4 00 -1.2
(pCi/L) | | |
ENERGY FUELS RESOURCES BLIND DUPLICATE ANALYSIS
Facility Name: Energy Fuels Resources
Well Number: MW-30 (Blind Duplicate MW-65)
MW-35 Sample
Parameter Sample Date Result mg/L
Date of Data
Entry:
Blind Duplicate
Analysis MW-65
25-Nov-14
Relative Percent
Difference (RPD)
Chloride 8/20/2014 139 139 00
Nitrate + Nitrite 8/20/2014 138 14 9 -7 7
Selenium 8/20/2014 0 0485 0 0472 2 7
Uranium 8/20/2014 0 0076 0.0074 2 7