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HomeMy WebLinkAboutDRC-2014-001301 - 0901a068803fa879ENERGYFUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.enerpvfuels.com Mr. Rusty Lundberg Division of Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4820. January 23, 2014 Sent VIA OVERNIGHT DELIVERY DRC-2014-001301 Re: Transmittal of the Contamination Investigation Report ("CIR") for Nitrate in Monitoring Wells TW4-12 and TW4-27 White Mesa Uranium Mill Dear Mr. Lundberg: Enclosed are two copies of the Contamination Investigation Report ("CIR") as well as two CDs each containing a word searchable electronic copy of the report. Installation of four new perched groundwater monitoring wells, TW4-28, TW4-29, TW4-30, and TW4-31 was completed as required by the February 14, 2013 DRC Confirmatory Action Letter. TW4-28, TW4-29, TW4-30, and TW4-31 were installed to provide additional information regarding the nitrate concentrations in TW4-12 and TW4-27. Based on the second quarter 2013 results for TW4-28, TW4-29, TW4-30, and TW4-31, and as discussed with UDEQ via telephone on July 25, 2013 and approved by UDEQ via letter dated August 2, 2013, EFRI added one additional monitoring well in the vicinity of TW4-28 and two additional monitoring wells in the vicinity of TW4-29. Installation of these three new perched groundwater monitoring wells, TW4-32, TW4-33, and TW4-34 was completed as discussed with UDEQ via telephone on July 25, 2013 and approved by UDEQ via letter dated August 2, 2013. The DRC letter of February 14, 2013 required that a separate CIR for the new wells be prepared and submitted within 60 days of receipt of the analytical data for TW4-28, TW4-29, TW4-30, and TW4- 31. Based on the second quarter 2013 data for TW4-28, TW4-29, TW4-30, and TW4-31 , as agreed to by UDEQ in the July 25, 2013 telephone call, it was considered premature to prepare a CIR based on the these four wells only. EFRI collected hydraulic and contaminant concentration data from TW4-32, TW4-33, and TW4-34. Pursuant to the August 2, 2013 DRC letter, EFRI sampled TW4-32, TW4-33, HYDRO GEO CHEM, INC. Environmental Science & Technology CONTAMINATION INVESTIGATION REPORT TW4-12 AND TW4-27 AREAS WHITE MESA URANIUM MILL NEAR BLANDING, UTAH January 23, 2014 Prepared for: ENERGY FUELS RESOURCES (USA) INC 225 Union Blvd., Suite 600 Lakewood, Colorado 80228 Prepared by: HYDRO GEO CHEM, INC. 51 West Wetmore Road, Suite 101 Tucson, Arizona 85705 (520) 293-1500 Project Number 7180000.00-01.0 Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 i TABLE OF CONTENTS 1. INTRODUCTION.............................................................................................................. 1 2. BACKGROUND................................................................................................................ 3 2.1 Nitrate and Chloride Near Well TW4-12................................................................5 2.2 Nitrate and Chloride Near Well TW4-27................................................................5 2.3 Water Level Behavior Near TW4-12 and TW4-27 ................................................6 3. WELL INSTALLATION, TESTING, AND SAMPLING................................................. 7 3.1 TW4-28 through TW4-31.......................................................................................7 3.2 TW4-32 through TW4-34.......................................................................................7 4. RESULTS........................................................................................................................... 9 4.1 Perched Groundwater Elevations............................................................................9 4.2 Analytical Results.................................................................................................11 4.2.1 TW4-28 through TW4-31......................................................................... 11 4.2.2 TW4-32 through TW4-34......................................................................... 12 5. DISCUSSION AND CONCLUSIONS............................................................................ 13 6. RECOMMENDATIONS.................................................................................................. 15 7. REFERENCES ................................................................................................................. 17 8. LIMITATIONS................................................................................................................. 19 TABLES 1 Summary of Slug Test Results 2 Summary of Analytical Results for New Wells Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 ii TABLE OF CONTENTS (Continued) FIGURES 1 Site Plan Showing Perched Well and Piezometer Locations and TW4-12/TW4-27 CIR Focus Area 2 Kriged 4th Quarter, 2013 Water Levels Showing TW4-12/TW4-27 CIR Focus Area, White Mesa Site 3 Nitrate and Chloride at TW4-12 and TW4-13 4 Nitrate in the Vicinity of TW4-27 5 Chloride in the Vicinity of TW4-27 6 Water Levels in Wells near TW4-12 and TW4-27 7 Kriged 4th Quarter, 2013 Perched Water Elevations Showing Inferred Pathlines 8 Kriged 4th Quarter, 2013 Nitrate (mg/L) (Nitrate + Nitrite as N) in the CIR Focus Area 9a Kriged 4th Quarter, 2013 Chloroform (µg/L) in the CIR Focus Area 9b Kriged 4th Quarter, 2013 Chloroform (µg/L) in the CIR Focus Area with 70 µg/L Isocon Adjusted by Hand 10 Chloroform Concentrations at TW4-6, TW4-26, TW4-29, and TW4-33 APPENDICES A EFRI Field Records B Laboratory Analytical Reports and Associated QA/QC Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 1 1. INTRODUCTION This Contamination Investigation Report (CIR) describes the investigation into perched groundwater nitrate concentrations exceeding 10 milligrams per liter (mg/L) at wells TW4-12 and TW4-27, both located in the eastern portion of the White Mesa Uranium Mill property near Blanding, Utah. The investigation is in response to the February 14, 2013 letter from the State of Utah Division of Radiation Control (DRC) to Energy Fuels Resources (USA) Inc (EFRI) [hereafter the “DRC letter”]. The purpose of the investigation was to bound the nitrate exceeding the State of Utah Groundwater Quality Standard (GWQS) of 10 mg/L in the vicinities of TW4- 12 and TW4-27 and to evaluate potential sources of the nitrate. The initial phase of the investigation included the installation and testing of four new perched monitoring wells TW4-28, TW4-29, TW4-30, and TW4-31 (shown in Figure 1). All wells were installed, tested, and sampled in accordance with conditions set forth in the DRC letter. TW4-28 was located downgradient of TW4-12. TW4-29, TW4-30, and TW4-31 were installed south, southeast, and east of TW4-27, at locations presumed to be down and cross-gradient of TW4-27. The results of sampling these wells as part of routine second quarter, 2013 monitoring indicated that nitrate exceeding 10 mg/L near TW4-27 was bounded but that nitrate near TW4-12 was not bounded. Chloroform exceeding the State of Utah GWQS of 70 micrograms per liter (µg/L) was also unexpectedly detected at TW4-29, at a location that appeared to be primarily cross-gradient to the chloroform plume located to the north-northwest. As a result of these findings, DRC, in conference with EFRI, agreed to extend the timeframe for submission of the CIR set forth in the DRC letter, until such time as additional well installation and sampling had delineated both nitrate exceeding 10 mg/L and chloroform exceeding 70 µg/L. A second round of well installation, testing, and sampling was performed. Wells TW4-32, TW4- 33, and TW4-34 were installed (at the locations shown on Figure 1), tested, and sampled as part of routine fourth quarter, 2013 monitoring in accordance with DRC-specified conditions. Data from these wells indicate that nitrate is bounded downgradient of TW4-12 and that both chloroform and nitrate are bounded near TW4-27. Elements of the CIR set forth in the DRC letter include the following: 1. Interpretation of analytical data, groundwater levels, gradients, flow directions, and well hydraulic properties; 2. Copies of EFRI field records, laboratory reports, and chain of custody forms; Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 2 3. Identification of all Quality Assurance Samples, e.g. trip blanks, equipment blanks, duplicate samples; 4. Groundwater contour and nitrate isoconcentration map with one of the isoconcentration lines showing the 10 mg/L boundary; 5. A discussion of the potential source(s) of the nitrate observed in well TW4-27 and any nitrate above 10 mg/L in the newly installed wells; and 6. Conclusions and recommended path forward. Specific elements of the CIR listed above are presented in the following Sections, Figures, and Appendices: • Item (1) is addressed in Sections 3 and 4, Tables 1 and 2, and Figures 2 through 9b. • Items (2) and (3) are addressed in Appendices A and B. • Item (4) is addressed by Figures 2, 7, and 8. • Item (5) is addressed in Sections 5 and 6. • Item (6) is addressed in Sections 5 and 6. Additionally, chloroform isoconcentration maps (Figures 9a and 9b) showing the 70 µg/L boundary are included, as are discussions of the potential source of the TW4-29 chloroform and recommended path forward (Sections 5 and 6).. Furthermore, DRC expressed concern regarding the relationship between nitrate in TW4-12 and TW4-27, and nitrate located to the west-northwest that is the focus of the Nitrate Corrective Action Plan (CAP) (HGC, 2012a). Language relevant to this concern is provided in Sections 2, 5, and 6. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 3 2. BACKGROUND Existing and new wells (TW4-28 through TW4-34) installed as part of this investigation are completed in perched water hosted by the Burro Canyon Formation, and, where saturated thicknesses are greater, the overlying Dakota Sandstone. The Burro Canyon Formation is separated from the underlying regional Navajo/Entrada aquifer by approximately 1,000 to 1,100 feet of Morrison Formation and Summerville Formation materials having a low average vertical permeability. The Brushy Basin Member of the Morrison Formation is a bentonitic shale that lies immediately beneath the Burro Canyon Formation and forms the base of the perched water zone at the site. Perched water flow is generally from northeast to southwest across the site (Figure 2). Beneath and south of the tailings cells, in the west central portion of the site, perched water flow is south-southwest to southwest. Flow on the western margin of the mesa is also south, approximately parallel to the rim (where the Burro Canyon Formation is terminated by erosion). On the eastern side of the site perched water flow is also generally southerly. Because of mounding near existing and former wildlife ponds, flow direction ranges locally from westerly (west of the ponds) to easterly (east of the ponds). Water delivery to the northern ponds (north of TW4-12 as shown in Figure 1) ceased in March 2012, but the associated mound, while smaller, is still evident. Perched water generally has a low quality, with total dissolved solids ranging from approximately 1,100 to 7,900 mg/L, and is used primarily for stock watering and irrigation north (upgradient) of the site. As of the fourth quarter of 2013, depths to perched water range from approximately 32 feet near the wildlife ponds in the northeastern portion of the site to approximately 120 feet at the southwestern margin of tailings Cell #3. Saturated thicknesses range from approximately 87 feet near the northern wildlife ponds to less than 5 feet in the southwest portion of the site, downgradient of the tailings cells. A saturated thickness of approximately 2 feet occurs in well MW-34 along the south dike of tailings Cell 4B, and the perched zone is apparently dry at MW- 33 located at the southwest corner of Cell 4B. Between TW4-12 and new well TW4-31, the saturated thickness declines from approximately 61 ft to 22 ft. The permeability of the perched zone is generally low. Although sustainable yields of as much as 4 gallons per minute (gpm) have been achieved in wells penetrating higher transmissivity zones, well yields are typically low (<1/2 gpm) due to the generally low permeability of the perched zone. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 4 Hydraulic testing of perched zone wells yields a hydraulic conductivity range of approximately 2 x 10-8 to 0.01 cm/s (HGC, 2012b). Hydraulic conductivities of wells tested as part of this investigation lie within this range. In general, the highest permeabilities and well yields are in the area of the site immediately northeast and east (upgradient to cross gradient) of the tailings cells. A relatively continuous, higher permeability zone associated with a perched groundwater chloroform plume has been inferred to exist in this portion of the site (HGC, 2007). Analysis of drawdown data collected from this zone during long-term pumping of MW-4, TW4-19, and MW-26 (TW4-15) yielded estimates of hydraulic conductivity ranging from 4 x 10-5 to 1 x 10-3 cm/s. The perched groundwater chloroform plume was detected in 1999 in the vicinity of MW-4. Extraction of chloroform-laden perched water began in 2003 with the initiation of pumping at MW-4 and TW4-19. Subsequently, MW-26, TW4-20, and lastly, TW4-4 were added to the pumping network. TW4-4 pumping began in the first quarter of 2010. Based on well installation and monitoring between 1999 and 2010, the maximum downgradient extent of the chloroform plume was between TW4-6 and TW4-26. Upon initiation of pumping at TW4-4, the boundary of the plume appeared to recede to the area between TW4-4 and TW4-6. Elevated nitrate concentrations of several mg/L have historically been associated with the chloroform plume which is presumed to originate from former sanitary leach fields that received laboratory wastes (HGC, 2007). This nitrate is distinct from the nitrate that is the focus of the Nitrate CAP (HGC, 2012a). Nitrate that is the focus of the CAP extends from the area northeast of the millsite to a portion of the area beneath the tailings cells, and is associated with the ‘historical pond’. The historical pond is a former stock watering pond located in the vicinities of TWN-2 and TWN-3 that was removed prior to Mill construction. Nitrate in this area exceeding 10 mg/L is deemed the “nitrate plume”. The nitrate plume is associated with chloride concentrations exceeding 100 mg/L as discussed in the nitrate CAP. Nitrate within the nitrate plume is addressed by the nitrate pumping system which consists of wells TW4-22, TW4-24, TW4-25, and TWN-2 (Figure 1). Nitrate exceeding 10 mg/L detected at TW4-12 and TW4-27, which is the focus of this investigation, is distinct from the nitrate plume that is addressed in the nitrate CAP. Nitrate exceeding 10 mg/L detected at TW4-12 and TW4-27 was of concern because it was not bounded by wells having concentrations less than 10 mg/L. Furthermore, nitrate at TW4-26 that has recently risen and remained above 10 mg/L did not appear to be adequately bounded by wells having concentrations less than 10 mg/L. Nitrate concentrations at other wells located outside and east-southeast of the nitrate plume, generally in the area between the nitrate plume and TW4-12 and TW4-27, have periodically exceeded 10 mg/L (for example TW4-10). These Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 5 other wells are typically associated with the chloroform plume. However, because nitrate at these other wells is bounded by wells having nitrate concentrations less than 10 mg/L, and because they are within the influence of the chloroform pumping system (consisting of wells MW-4, MW-26, TW4-4, TW4-19, and TW4-20 [Figure 1]), these other wells are not the subject of this report. 2.1 Nitrate and Chloride Near Well TW4-12 Well TW4-12, along with TW4-13 and TW4-14, were installed in July, 2002 to bound the chloroform plume to the east. All three wells have been non-detect for chloroform. Nitrate was detected at TW4-12 at concentrations of a few mg/L during the first sampling. Concentrations remained relatively low until about 2008 when they began to increase (Figure 3). Concentrations have met or exceeded 10 mg/L since the second quarter of 2012. Chloride concentrations at TW4-12 are low (<45 mg/L) compared to chloride concentrations associated with the nitrate plume (typically > 100 mg/L), but are on an upward trend as shown in Figure 3. Nitrate concentrations at TW4-13, located directly downgradient of TW4-12 at the time of installation, have remained below 10 mg/L. Chloride concentrations at TW4-13 (typically between 50 and 60 mg/L) are higher than at TW4-12 or TW4-14, have been relatively stable, and are lower than concentrations associated with the nitrate plume. 2.2 Nitrate and Chloride Near Well TW4-27 Well TW4-27 was installed in October, 2011 at a location expected to bound the chloroform plume to the southeast. Although detected in the initial sampling, chloroform has not been detected at TW4-27 since the initial sampling. However, nitrate at TW4-27 has been consistently detected at concentrations exceeding 10 mg/L. Nitrate concentrations at TW4-27 have ranged between approximately 24 and 41 mg/L and appear to be relatively stable (Figure 4). Chloride concentrations at TW4-27 (Figure 5) are low (<25 mg/L) compared to chloride concentrations at either TW4-12 or wells associated with the nitrate plume (typically having concentrations > 100 mg/L). Chloride concentrations appear to be increasing at TW4-27. As shown in Figure 4, nitrate concentrations at TW4-27 are also higher than at nearby wells TW4-6, TW4-14, and TW4-26, although nitrate at TW4-26 has recently risen and remained above 10 mg/L. Chloride concentrations at TW4-27 are similar to concentrations at TW4-26, and are lower than concentrations at TW4-6 and TW4-14 (Figure 5). Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 6 2.3 Water Level Behavior Near TW4-12 and TW4-27 Well TW4-14, located adjacent to TW4-27, was dry at the time of installation. As shown in Figure 6, water levels in TW4-14 have risen approximately 8 feet since the third quarter of 2002. Water levels at TW4-6, TW4-12, TW4-13, and TW4-14 have all risen since the time of installation presumably under the influence of seepage from the wildlife ponds. The change in water level at TW4-14 has been smaller than at adjacent wells TW4-6 or TW4-13, and the water level behavior at TW4-27 has been similar to that of TW4-14. The similarity in magnitudes and in rates of water level increase suggest that both TW4-14 and TW4-27 are completed in materials having similar hydraulic properties. Water levels at TW4-26 are similar in magnitude and in rate of change to those at TW4-6, suggesting that TW4-6 and TW4-26 are likewise completed in materials having similar hydraulic properties. The small change in water level at TW4-14 compared to TW4-6 suggests that the permeability of the perched zone is lower at TW4-14 (and TW4-27) than at TW4-6 (and TW4-26). Similarly, the relatively small change in water level at TW4-14 compared to TW4-13 suggests that the permeability at TW4-14 (and TW4-27) is lower than at TW4-13. Hydraulic test results provided in Table 1 indicate that the hydraulic conductivity at TW4-27 is an order of magnitude lower than at TW4-6 or TW4-26. These results, in conjunction with the water level behavior discussed above, indicate that the permeability of the perched zone is relatively low at TW4-14 and TW4-27 compared to areas to the west and north. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 7 3. WELL INSTALLATION, TESTING, AND SAMPLING The results of the installation, hydraulic testing, and sampling of wells installed during the investigation are summarized in Sections 3.1 and 3.2. Details of the installation and testing are provided in HGC (2013a) and HGC (2013b.) 3.1 TW4-28 through TW4-31 Wells TW4-28 though TW4-31 were installed in March 2013 at the locations shown in Figure1. Wells were developed by surging and bailing followed by overpumping, and surveyed by a State of Utah licensed surveyor. Hydraulic tests were performed during April 2013. Details of well installation and testing are provided in HGC (2013a). Hydraulic test results are provided in HGC (2013a) and Table 1. Hydraulic tests consisted of slug tests analyzed using AQTESOLVTM (HydroSOLVE, 2000), a computer program developed and marketed by HydroSOLVE, Inc. Data were analyzed using two solution methods: the KGS unconfined method (Hyder et al., 1994) and the Bouwer-Rice unconfined method (Bouwer and Rice, 1976). Data were collected automatically using downhole pressure transducers/data loggers and by hand using an electric water level meter. Both automatically logged and hand-collected data were analyzed. As indicated in Table 1, estimates of hydraulic conductivity range from 1.1 x 10-5 centimeters per second (cm/s) to 3.9 x 10-4 cm/s using automatically logged data, and from 1.4 x 10-5 cm/s to 4.1 x 10-4 cm/s using hand-collected data. Estimates are within the range previously measured at the site (approximately 2 x 10-8 cm/s to 0.01 cm/s). Wells TW4-28 through TW4-31 were sampled as part of the routine quarterly monitoring events. To date, these wells have been sampled during the second, third, and fourth quarters of 2013. 3.2 TW4-32 through TW4-34 Wells TW4-32 though TW4-34 were installed in September 2013 at the locations shown in Figure 1. Wells were developed by surging and bailing followed by overpumping, and surveyed by a State of Utah licensed surveyor. Hydraulic tests were performed during October 2013. Details of well installation and testing are provided in HGC (2013b). Hydraulic testing procedures were the same as for wells TW4-28 through TW4-31. Test results are provided in HGC (2013b) and Table 1. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 8 As indicated in Table 1, estimates of hydraulic conductivity range from approximately 2.5 x 10-5 cm/s to 1.5 x 10-4 cm/s using automatically logged data, and from approximately 1.2 x 10-5 cm/s to 1.3 x 10-4 cm/s using hand-collected data. Estimates are within the range previously measured at the site (approximately 2 x 10-8 cm/s to 0.01 cm/s). Wells TW4-32 through TW4-34 were sampled as part of the routine fourth quarter monitoring event. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 9 4. RESULTS Results of water level measurements and sample analyses are presented in Sections 4.1 and 4.2. Copies of EFRI field records, laboratory analytical results, and associated Quality Assurance/Quality Control (QA/QC) are provided in Appendices A and B. Sampling and analysis were performed under the Mill’s chloroform monitoring program. The EFRI Quality Assurance (QA) Manager performed a QA/QC review of data collected as part of this investigation to confirm compliance of the monitoring program with requirements of the Mill’s Quality Assurance Plan (QAP). As required in the QAP, data QA includes preparation and analysis of QC samples in the field, review of field procedures, an analyte completeness review, and QC review of laboratory methods and data. Identification of field QC samples collected and analyzed is provided in the Quarterly Chloroform Monitoring Reports submitted to the DRC under separate cover. Discussion of adherence to Mill sampling Standard Operating Procedures (SOPs), analytical completeness review results, and the steps and tests applied to check laboratory data QA/QC are also discussed in the Quarterly Chloroform Monitoring Reports. The second and third quarter, 2013 Quarterly Chloroform Monitoring Reports were submitted to DRC on August 26, 2013 and November 29, 2013, respectively. The Quarterly Chloroform Monitoring Report for the fourth quarter will be submitted to DRC on or before March 1, 2014. Appendix A contains EFRI’s field records, and Appendix B contains laboratory reports, chain- of-custody forms, analytical data and the associated QA samples for the wells discussed in this CIR. The Quarterly Chloroform Monitoring Reports include all of the data collected for the chloroform program for each quarter. A QC review summary is included with the data presented herein. The full QC sample review and the associated QC checks and tables are included with the Quarterly Chloroform Monitoring Reports. Because the Quarterly Chloroform Monitoring Report for the fourth quarter will be submitted to DRC at a later data (on or before March 1, 2014), only a portion of the quarterly chloroform monitoring data are included in Appendix B; however, the fourth quarter, 2013 QC summary is included here for completeness. 4.1 Perched Groundwater Elevations Figure 7 is a perched water elevation contour map for the fourth quarter, 2013, showing inferred perched flow pathlines from TW4-26, TW4-27, and TW4-28. Figure 7 covers the area of focus of this investigation and incorporates data from all wells installed as part of the investigation. As Figure 7 shows, TW4-32 is located immediately downgradient of TW4-12 and TW4-28 and is properly situated to bound nitrate detected above 10 mg/L at TW4-12 and TW4-28. Figure 7 Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 10 also shows that TW4-31 is downgradient of TW4-27 and that TW4-29 and TW4-30 are approximately cross-gradient of TW4-27. Furthermore, TW4-30 and TW4-31 are downgradient of TW4-29; TW4-34 is down and cross-gradient of TW4-26, and cross-gradient of TW4-29; and TW4-29 is downgradient of TW4-26. The wells installed near TW4-27 are therefore properly located to bound nitrate detected above 10 mg/L at TW4-26 and TW4-27, and to bound chloroform detected above 70 µg/L at TW4-29. Hydraulic gradients are relatively steep in the areas north of TW4-14 and west of TW4-27. The magnitude of the southerly hydraulic gradient between TW4-13 and TW4-14 is approximately 0.07 ft/ft, and the magnitude of the easterly hydraulic gradient between TW4-29 and TW4-31 is approximately 0.044 ft/ft. By contrast, the gradient between TW4-12 and TW4-13 is approximately 0.019 ft/ft. The steep gradients near TW4-14 and TW4-27 are interpreted to result primarily from the relatively low hydraulic conductivity of the perched zone in the vicinities of these wells, and the transient nature of portions of the perched groundwater system. The perched groundwater system is transient primarily because of recharge from the wildlife ponds (Figure 1). Residual perched groundwater mounds are associated with the northern ponds to which water is no longer delivered. A mound is also associated with the southern pond which is still active. The excess water resulting from past and current wildlife pond recharge has caused perched water levels to increase over portions of the site, including the focus area of the CIR. Where permeabilities are higher, the excess water is more readily conducted away from the recharge areas, less of the excess goes into storage, and increases in water levels and saturated thicknesses are smaller. In areas where permeabilities are lower, excess recharge water is less readily conducted away from the recharge areas, more of the excess goes into storage, thereby causing larger increases in water levels and saturated thicknesses. Increases in saturated thicknesses also occur in higher permeability areas receiving recharge that are upgradient of lower permeability areas because the lower permeability areas act as partial hydraulic barriers and cause water to ‘back up’ within the higher permeability areas. Increases in water levels are moderated to some extent by the larger transmissivities that result from the increased saturated thicknesses. The hydraulic conductivity of the perched zone drops by nearly two orders of magnitude between TW4-4 and TW4-26, and by nearly three orders of magnitude between TW4-4 and TW4-27. The permeability contrasts between the low permeability area in which TW4-14 and TW4-27 are completed and surrounding areas, combined with the increased recharge and generally increasing water levels associated with the wildlife ponds, creates the steep hydraulic gradients along the margins of the low permeability area. The area near TW4-14 and TW4-27 Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 11 can be considered to be partially hydraulically isolated from surrounding areas due to low permeability. This behavior is consistent with the absence of chloroform at TW4-14 and TW4- 27, which are more directly down gradient of the chloroform at TW4-4 than is TW4-29. Chloroform has presumably impacted TW4-29 sooner than either TW4-14 or TW4-27 because TW4-29 is located in higher permeability materials. A relatively steep southeasterly hydraulic gradient of approximately 0.065 ft/ft is also present between TW4-28 and TW4-32 in contrast to the relatively shallow gradient of approximately 0.01 ft/ft between TW4-12 and TW4-28. This suggests that the permeability of the perched zone is higher at TW4-12 than at TW4-28 or TW4-32. 4.2 Analytical Results Analytical results for new wells are summarized in Table 2. Figure 8 displays nitrate analytical results and Figures 9a and 9b chloroform analytical results for the fourth quarter, 2013. These Figures cover the area of focus of this investigation and incorporate data from all wells installed as part of the investigation. Figure 9 displays unadjusted kriged chloroform isocons, and Figure 9b displays kriged chloroform isocons adjusted by hand. The unadjusted isocons imply that chloroform at TW4-29 and TW4-33 may not be continuous with the chloroform plume to the north-northwest. Figure 9b shows what is considered a more reasonable interpretation, with the chloroform plume extending continuously from TW4-4 to TW4-29, where it is bounded. Overall, Figures 8, 9a, and 9b indicate that nitrate exceeding 10 mg/L at TW4-12, TW4-26, and TW4-27, and chloroform exceeding 70 µg/L at TW4-29 and TW4-33 are bounded by wells installed as part of the investigation. 4.2.1 TW4-28 through TW4-31 The initial sampling of wells TW4-28 though TW4-31 during the second quarter 2013 monitoring event indicated that nitrate exceeding 10 mg/L was bounded downgradient and cross- gradient of TW4-27, but that nitrate was not bounded downgradient of TW4-12. Nitrate concentrations at TW4-28 (located immediately downgradient of TW4-12) were approximately 14.9 mg/L, 17.3 mg/L, and 16.2 mg/L during the second, third and fourth quarters of 2013, respectively. Because the second quarter sample result exceeded 10 mg/L, an additional well (TW4-32) was installed downgradient of TW4-28. Nitrate concentrations at TW4-29, TW4-30, and TW4-31 (located cross-gradient.and downgradient of TW4-27) were approximately 4.6 mg/L, 0.95 mg/L, and 1.3 mg/L, respectively Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 12 during the second quarter, 2013 sampling; 4.2 mg/L, 0.96 mg/L, and 1.1 mg/L, respectively during the third quarter, 2013 sampling; and 4.1 mg/L, 1.2 mg/L, and 1.3 mg/L, respectively during the fourth quarter, 2013 sampling. Based on these results, nitrate exceeding 10 mg/L at TW4-27 is bounded. Although the analytical data from TW4-29, TW4-30, and TW4-31 indicated that the TW4-27 nitrate was bounded, chloroform was unexpectedly detected at TW4-29 at a concentration of 242 µg/L during the second quarter, exceeding the GWQS of 70 µg/L. As a result, wells TW4-33 and TW4-34 were installed. TW4-33 was installed between TW4-4 and TW4-29 to determine if the TW4-29 chloroform was contiguous with the chloroform plume located to the north-northwest, and TW4-34 was installed to determine if chloroform was bounded to the south. As indicated in Figure 7, TW4-34 is cross-gradient of TW4-29, and TW4-30 and TW4-31 are downgradient of TW4-29. 4.2.2 TW4-32 through TW4-34 Nitrate was detected at concentrations of approximately 4.3 mg/L, 1.8 mg/L, and 1.6 mg/L at TW4-32, TW4-33, and TW4-34, respectively, during their initial sampling during the fourth quarter 2013 monitoring event. Chloroform was not detected at TW4-32 or TW4-34, and was detected at a concentration of 126 µg/L at TW4-33. These results in conjunction with those from TW4-28 through TW4-31 indicate that nitrate is bounded downgradient (to the southeast) of TW4-28, that nitrate is bounded downgradient (to the east) and cross-gradient (to the southeast) of TW4-26, that chloroform at TW4-29 is bounded downgradient (to the east) and cross-gradient (to the south), and that chloroform at TW4-29 is likely continuous with the chloroform plume located to the north-northwest (Figure 9b). Chloroform likely migrated from the vicinity of TW4-4 in a nearly cross-gradient direction around the low permeability area defined by TW4-14 and TW4-27. Because both nitrate exceeding 10 mg/L and chloroform exceeding 70 µg/L were bounded, no additional wells were required to complete this investigation. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 13 5. DISCUSSION AND CONCLUSIONS Nitrate detected above 10 mg/L at TW4-12, TW4-26, and TW4-27 (the ‘eastern’ nitrate) is cross- gradient of the nitrate plume addressed in the CAP, and separated from the nitrate plume by perched wells having nitrate concentrations that are non-detect or, if detected, less than 10 mg/L. Much of the nitrate east of the nitrate plume (generally in the area between the nitrate plume and TW4-12 and TW4-27) is associated with the chloroform plume and is within the influence of the chloroform pumping system. In addition, chloride concentrations in the eastern nitrate area typically have chloride concentrations that are below 60 mg/L whereas wells within the nitrate plume typically have chloride exceeding 100 mg/L. Furthermore, as shown in Figure 4, nitrate exceeding 10 mg/L in the eastern area occurs in relatively isolated pockets. Concentrations within these pockets are generally lower than concentrations detected over most of the nitrate plume. Only concentrations at TW4-27 are comparable to concentrations detected within the major portion of the nitrate plume. The fundamentally different areal distribution and generally lower nitrate and chloride concentrations suggest that at least some of the eastern area nitrate exceeding 10 mg/L originates from relatively small, localized sources. Specific results of the investigation include: 1. Nitrate exceeding 10 mg/L at TW4-12 (and TW4-28) is bounded by concentrations below 10 mg/L at wells TW4-3, TW4-13, and TW4-32. TW4-32 is downgradient of TW4-12 and TW4-28, and TW4-3 is cross-gradient of TW4-12. TW4-13 appears to be located in a direction generally downgradient to cross-gradient of TW4-12. 2. Nitrate exceeding 10 mg/L at TW4-26 is bounded by concentrations below 10 mg/L at wells TW4-6, TW4-23, TW4-29, TW4-33, and TW4-34. TW4-29 is downgradient of TW4-26; TW4-23 is upgradient of TW4-26; and TW4-6, TW4-33 and TW4-34 are cross- gradient of TW4-26. 3. Nitrate exceeding 10 mg/L at TW4-27 is bounded by concentrations below 10 mg/L at wells TW4-14, TW4-29, TW4-30, TW4-31, and TW4-33. TW4-31 is downgradient of TW4-27; TW4-33 is upgradient of TW4-27; and TW4-14, TW4-29, and TW4-30 are cross-gradient of TW4-27. Possible sources for nitrate at TW4-12 include potentially elevated soil concentrations resulting from former cattle ranching operations. Continued increases in concentrations in the vicinity of TW4-12 are expected to result from reduced dilution related to cessation of water delivery to the northern wildlife ponds. Projecting current conditions forward, TW4-12 nitrate may continue to migrate downgradient toward TW4-32 but is expected to remain inside the eastern property boundary (Figure 7) and to Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 14 be mitigated by natural attenuation enhanced by pyrite oxidation as discussed in HGC (2012c). Based on current perched groundwater contours, perched water at TW4-32 is expected to migrate along a curved path towards TW4-31. The likely source for nitrate detected at TW4-27 is a localized source related to former cattle ranching operations. Natural attenuation enhanced by pyrite oxidation (discussed in HGC, 2012c) will likely mitigate any nitrate migrating from the vicinity of TW4-27. Rates of migration are expected to be low due to the low permeability of the perched zone at TW4-27. Furthermore, the absence of chloroform at TW4-14 and TW4-27 is consistent with low permeability conditions at these wells and indicates that nitrate at TW4-27 is migrating very slowly (consistent with not having reached TW4-31). The likely source for nitrate detected at TW4-26 is also a localized source related to former cattle ranching operations. Natural attenuation enhanced by pyrite oxidation (discussed in HGC, 2012c) will likely mitigate the nitrate. An unexpected result of the investigation into eastern area nitrate was the discovery of chloroform exceeding 70 µg/L at TW4-29. Data from new wells TW4-33 and TW4-34 installed to establish the extent of the TW4-29 chloroform indicate that: 1. Chloroform exceeding 70 µg/L at TW4-29 is bounded by concentrations below 70 µg/L at wells TW4-26, TW4-27, TW4-30 and TW4-34. TW4-30 is downgradient of TW4-29; TW4-26 is upgradient of TW4-29; and TW4-27 and TW4-34 are cross-gradient of TW4- 29. 2. Chloroform concentrations at TW4-33 that are lower than concentrations at TW4-29, and the likelihood that a pathway exists from TW4-4 to TW4-33 to TW4-29, suggests that concentrations in the vicinity of TW4-33 were likely higher prior to initiation of TW4-4 pumping, and that lower concentrations currently detected at TW4-33 are due to its closer proximity to TW4-4. Furthermore, TW4-4 pumping is likely to reduce chloroform at both TW4-33 and TW4-29 by cutting off the source. The decrease at TW4-33 is expected to be faster than at TW4-29 because TW4-33 is in closer proximity to TW4-4 pumping. Such behavior is expected by analogy with the decreases in chloroform concentrations at TW4-6 and TW4-26 once TW4-4 pumping began as shown in Figure 10. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 15 6. RECOMMENDATIONS The results of the investigation indicate that nitrate exceeding 10 mg/L in the ‘eastern’ area is bounded and occurs in relatively isolated pockets. Nitrate and chloride concentrations within these pockets are generally lower than concentrations detected over most of the nitrate plume that is addressed by the nitrate CAP. The fundamentally different areal distribution and generally lower nitrate and chloride concentrations suggest that the eastern nitrate is distinct from the nitrate addressed by the CAP and that at least some of the eastern nitrate originates from relatively small, localized sources. Nitrate exceeding 10 mg/L at TW4-12 (and TW4-28), at TW4-26, and at TW4-27 is bounded by wells installed as part of the investigation. Chloroform exceeding 70 µg/L at TW4-29 is also bounded and is likely to be continuous with the chloroform plume located to the north-northwest. Based on the investigation results the following interpretations and recommendations are made: 1. Because nitrate in the vicinities of TW4-12 and TW4-27 is distinct from the nitrate addressed in the nitrate CAP, it does not seem appropriate at this time to link the TW4- 12/TW4-27 nitrate to the nitrate CAP. 2. Nitrate at TW4-12 and TW4-28 is interpreted to originate potentially from sources likely related to former cattle ranching operations. Increasing concentrations in this area are expected to result from reduced dilution caused by cessation of water delivery to the northern wildlife ponds. Because of the expected containment within the eastern property boundary (Figure 7), and the expected mitigating impact of natural attenuation, no action at the present time other than continued monitoring is considered reasonable and is recommended. Should nitrate concentrations exceed 10 mg/L at TW4-32 (located immediately downgradient of TW4-28), alternate action will be taken that will likely include installation of additional wells to bound the nitrate. Although natural attenuation is expected to have a mitigating impact on this nitrate, cessation of water delivery to the northern wildlife ponds and the consequent reduction in dilution is expected to compete with this process, potentially increasing nitrate concentrations. 3. Because nitrate at TW4-26 is interpreted to originate from a localized source likely the result of former cattle ranching operations, and is expected to be mitigated by natural attenuation, no action at the present time other than continued monitoring is considered reasonable and is recommended. Should nitrate concentrations exceed 10 mg/L at downgradient wells (first TW4-29 and then TW4-30), or cross-gradient well TW4-34, alternate action will be taken that will likely include the installation of additional wells to bound the nitrate. 4. Because nitrate at TW4-27 is migrating slowly due to low permeability conditions, is interpreted to originate from a localized source likely the result of former cattle ranching operations, and is expected to be mitigated by natural attenuation, no action at the present time other than continued monitoring is considered reasonable and is recommended. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 16 Should nitrate concentrations exceed 10 mg/L at TW4-31 (located immediately downgradient of TW4-27), or cross-gradient wells TW4-29 or TW4-30, alternate action will be taken that will likely include installation of additional wells to bound the nitrate. 5. At present, no action for TW4-29 chloroform other than continued pumping of TW4-4 and continued monitoring is considered reasonable and is recommended. Concentrations at TW4-29 and TW4-33 are expected to diminish under the influence of TW4-4 pumping by analogy with the concentration behavior at TW4-6 and TW4-26 (Figure 10). Should chloroform concentrations greater than 70 µg/L impact downgradient wells (TW4-30 and TW4-31), or cross-gradient well TW4-34, alternate action will be taken that will likely include installation of additional wells to bound the chloroform. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 17 7. REFERENCES Bouwer, H. and R.C. Rice. 1976. A Slug-Test method for Determining Hydraulic Conductivity of Unconfined Aquifers with Completely or Partially Penetrating Wells. Water Resources Research, Vol. 12, No. 3, Pp. 423-428. Hyder, Z, J.J. Butler, Jr. C.D. McElwee, and W. Liu. 1994. Slug Tests in Partially Penetrating Wells. Water Resources Research, Vol. 30, No. 11, Pp. 2945-2957. HydroSOLVE, Inc. 2000. AQTESOLV for Windows. User=s Guide Hydro Geo Chem, Inc. (HGC). 2007. Preliminary Corrective Action Plan, White Mesa Uranium Mill Near Blanding, Utah. Submitted to Denison Mines (USA) Corp. August 20, 2007. HGC. 2012a. Corrective Action Plan for Nitrate, White Mesa Uranium Mill Near Blanding, Utah. Submitted to Denison Mines (USA) Corp. May 7, 2012. HGC. 2012b. Second Revision. Hydrogeology of the Perched Groundwater Zone in the Area Southwest of the Tailings Cells, White Mesa Uranium Mill Site, Blanding, Utah. Submitted to Energy Fuels Resources (USA) Inc. November 7, 2012. HGC. 2012c. Investigation of Pyrite in the Perched Zone, White Mesa Uranium Mill, Blanding, Utah. Submitted to Energy Fuels Resources (USA) Inc. December 12, 2012. HGC. 2013a. Installation and Hydraulic Testing of Perched Monitoring Wells TW4-28 through TW4-31, White Mesa Uranium Mill Near Blanding, Utah. Submitted to Energy Fuels Resources (USA) Inc. April 13, 2013. HGC. 2013b. Installation and Hydraulic Testing of Perched Monitoring Wells TW4-32 through TW4-34, White Mesa Uranium Mill Near Blanding, Utah (As-Built Report). Submitted to Energy Fuels Resources (USA) Inc. October 30, 2013. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 18 Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 19 8. LIMITATIONS The information and conclusions presented in this report are based upon the scope of services and information obtained through the performance of the services, as agreed upon by HGC and the party for whom this report was originally prepared. Results of any investigations, tests, or findings presented in this report apply solely to conditions existing at the time HGC’s investigative work was performed and are inherently based on and limited to the available data and the extent of the investigation activities. No representation, warranty, or guarantee, express or implied, is intended or given. HGC makes no representation as to the accuracy or completeness of any information provided by other parties not under contract to HGC to the extent that HGC relied upon that information. This report is expressly for the sole and exclusive use of the party for whom this report was originally prepared and for the particular purpose that it was intended. Reuse of this report, or any portion thereof, for other than its intended purpose, or if modified, or if used by third parties, shall be at the sole risk of the user. Contamination Investigation Report TW4-12 and TW4-27 Areas, White Mesa Uranium Mill, Near Blanding, Utah H:\718000\nitrateast\CIR\report\Fnl_TW27_CIR_rev2.doc January 23, 2014 20 TABLES TABLE 1 Summary of Slug Test Results Bouwer-Rice Bouwer-Rice Test Correction Saturated Thickness K (cm/s) Ss (1/ft) K (cm/s) K (cm/s) Ss (1/ft) K (cm/s) TW4-4 (lt) uncorrected 22 1.66E-03 6.21E-05 2.89E-04 1.63E-03 3.01E-04 7.91E-04 TW4-4 (et) uncorrected 22 NA NA 1.26E-03 NA NA NA TW4-6 uncorrected 24 1.15E-05 3.67E-05 1.00E-05 1.19E-05 1.49E-04 1.32E-05 TW4-26 uncorrected 18 2.40E-05 3.23E-04 2.16E-05 2.28E-05 3.13E-04 2.55E-05 TW4-27 uncorrected 9 NA NA NA 2.13E-06 1.51E-03 1.59E-06 TW4-27 100% correction 9 7.01E-07 2.22E-03 1.99E-06 NA NA NA TW4-27 60% correction 9 1.35E-06 1.27E-03 1.15E-06 NA NA NA TW4-28 uncorrected 67.9 3.52E-04 1.22E-06 3.92E-04 3.29E-04 7.49E-06 4.07E-04 TW4-29 uncorrected 17.7 4.24E-05 1.19E-03 5.24E-05 4.52E-05 9.62E-04 5.66E-05 TW4-29 (lt) uncorrected 17.7 NA NA 2.00E-05 NA NA 3.80E-05 TW4-30 uncorrected 9.6 1.44E-04 1.00E-02 6.22E-05 1.34E-04 1.00E-02 1.38E-04 TW4-30 (et) uncorrected 9.6 NA NA 1.63E-04 NA NA 2.91E-04 TW4-30 (lt) uncorrected 9.6 NA NA 1.12E-05 NA NA 1.41E-05 TW4-31 uncorrected 18.1 4.18E-05 2.54E-05 3.87E-05 3.24E-05 9.65E-05 4.01E-05 TW4-32 uncorrected 64.8 9.53E-05 1.15E-04 NA 5.34E-05 7.97E-04 5.86E-05 TW4-32(et) uncorrected 64.8 NA NA 1.09E-04 NA NA 1.34E-04 TW4-32(lt) uncorrected 64.8 NA NA 2.51E-05 NA NA 1.17E-05 TW4-33 uncorrected 13.1 5.51E-05 3.73E-04 5.78E-05 5.25E-05 5.32E-04 5.76E-05 TW4-34 uncorrected 25.2 9.98E-05 1.13E-03 1.54E-04 9.39E-05 1.54E-03 1.25E-04 TW4-34 (lt) uncorrected 25.2 NA NA 1.17E-04 NA NA NA Notes: Bouwer-Rice = Unconfined Bouwer-Rice solution method in Aqtesolve™ cm/s = centimeters per second et = early time data lt = late time data ft = feet K = hydraulic conductivity KGS = Unconfined KGS solution method in Aqtesolve™ Ss= specific storage NA= Not Applicable Automatically Logged Data Hand Collected Data KGS KGS H:\718000\nitrateast\CIR\CIR_Tables_1213.xls: Table 1 1/23/2014 TABLE 2 Summary of Analytical Results for New Wells Well Quarter Chloroform Nitrate Chloride (of 2013) (ug/L) (mg/L) (mg/L) TW4-28 Q2 ND 14.9 44.6 TW4-28 Q3 ND 17.3 45.3 TW4-28 Q4 ND 16.2 45.2 TW4-29 Q2 242 4.63 44.8 TW4-29 Q3a 262 3.52 37.7 TW4-29 Q3b 246 4.18 41.4 TW4-29 Q4 260 4.11 42.5 TW4-30 Q2 ND 0.948 36 TW4-30 Q3 ND 0.952 36.3 TW4-30 Q4 ND 1.24 35.9 TW4-31 Q2 ND 1.26 28.4 TW4-31 Q3 ND 1.1 29.4 TW4-31 Q4 ND 1.33 28 TW4-32 Q4 ND 4.26 52.1 TW4-33 Q4 126 1.82 47.2 TW4-34 Q4 ND 1.64 19.2 Notes: ND = not detected a = first sampling b = second sampling H:\718000\nitrateast\CIR\CIR_Tables_1213.xls: Table 2 1/23/2014 FIGURES HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE northern wildlife ponds southern wildlife pond 1 mile Mill Site CORRAL CANYON CORRAL SPRINGS COTTONWOOD ENTRANCE SPRING RUIN SPRING WESTWATER Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B MW-01 MW-02 MW-03 MW-05 MW-11 MW-12 MW-14MW-15 MW-17 MW-18 MW-19 MW-20 MW-21 MW-22 MW-23 MW-24 MW-25 MW-26 MW-27 MW-28 MW-29 MW-30 MW-31 MW-32 MW-33 MW-34 MW-35 MW-36 MW-37 TW4-01 TW4-10 TW4-20TW4-22 TWN-01 TWN-02 TWN-03 TWN-04 TWN-05 TWN-06 TWN-07 TWN-08 TWN-09 TWN-10 TWN-11 TWN-12 TWN-13 TWN-14 TWN-15 TWN-16 TWN-17 TWN-18 TWN-19 PIEZ-01 PIEZ-02 PIEZ-03 PIEZ-04 PIEZ-05 TW4-03 TW4-05 TW4-09 TW4-11 TW4-12 TW4-13 TW4-14 TW4-16 TW4-18 TW4-31 TW4-32 TW4-34 TW4-19 TW4-04 TW4-07 TW4-21 TW4-24 TW4-25 TW4-26 TW4-02 TW4-08 MW-04 TW4-27 TW4-06 TW4-23 TW4-28 TW4-29 TW4-30TW4-33DR-05 DR-06 DR-07 DR-08 DR-09 DR-10 DR-11 DR-12 DR-13 DR-14 DR-15 DR-17 DR-19 DR-20 DR-21 DR-22 DR-23 DR-24 abandoned abandoned abandoned abandoned abandoned abandoned abandoned abandoned abandoned EXPLANATION perched monitoring well perched piezometer seep or spring SITE PLAN SHOWING PERCHED WELL AND PIEZOMETER LOCATIONS AND TW4-12/TW4-27 CIR FOCUS AREA H:/718000/nitrateast/CIR/CIR_area.srf MW-5 PIEZ-1 RUIN SPRING temporary perched monitoring well installed September, 2013 TW4-32 temporary perched monitoring well temporary perched nitrate monitoring well TW4-12 TWN-7 TW4-19 perched chloroform or nitrate pumping well focus area for CIR 1 HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE 1 mile CORRAL CANYON CORRAL SPRINGS COTTONWOOD ENTRANCE SPRING RUIN SPRING WESTWATER Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B MW-01 MW-02 MW-03 MW-05 MW-11 MW-12 MW-14MW-15 MW-17 MW-18 MW-19 MW-20 MW-21 MW-22 MW-23 MW-24 MW-25 MW-26 MW-27 MW-28 MW-29 MW-30 MW-31 MW-32 MW-33 MW-34 MW-35 MW-36 MW-37 TW4-01 TW4-10 TW4-20TW4-22 TWN-01 TWN-02 TWN-03 TWN-04 TWN-05 TWN-06 TWN-07 TWN-08 TWN-09 TWN-10 TWN-11 TWN-12 TWN-13 TWN-14 TWN-15 TWN-16 TWN-17 TWN-18 TWN-19 PIEZ-01 PIEZ-02 PIEZ-03 PIEZ-04 PIEZ-05 TW4-03 TW4-05 TW4-09 TW4-11 TW4-12 TW4-13 TW4-14 TW4-16 TW4-18 TW4-31 TW4-32 TW4-34 TW4-19 TW4-04 TW4-07 TW4-21 TW4-24 TW4-25 TW4-26 TW4-02 TW4-08 MW-04 TW4-27TW4-06 TW4-23 TW4-28 TW4-29 TW4-30 TW4-33DR-05 DR-06 DR-07 DR-08 DR-09 DR-10 DR-11 DR-12 DR-13 DR-14 DR-15 DR-17 DR-19 DR-20 DR-21 DR-22 DR-23 DR-24 5583 5504 5467 5503 5524 5501 54955494 5502 5586 5597 5452 dry 5450 5491 5507 5540 5574 5544 5514 5540 5549 dry 5492 5494 5493 5485 55765559 5551 55705564 5561 5592 5595 5593 5541 5537 5590 5595 5598 5592 abandoned 5588 5562 abandoned abandoned abandoned abandoned abandoned abandoned 5587 abandoned 5605 abandoned 5586 5608 5580 5543 5557 5582 5573 5528 5559 5578 5564 5534 5554 5559 5581 5580 55665562 55805565 5543 5539 5540 5580 5526 5522 5534 5527 5523 5483 5485 5492 5474 5480 5482 5487 5490 5487 5466 5465 5454 5455 5443 5420 dry 5425 5418 5624 5383 5234 5560 5380 5468 (not included) EXPLANATION perched monitoring well showing elevation in feet amsl perched piezometer showing elevation in feet amsl seep or spring showing elevation in feet amsl KRIGED 4th QUARTER, 2013 WATER LEVELS SHOWING TW4-12/TW4-27 CIR FOCUS AREA WHITE MESA SITE MW-5 PIEZ-1 RUIN SPRING temporary perched monitoring well installed September, 2013 showing approximate elevation in feet amsl TW4-32 temporary perched monitoring well showing elevation in feet amsl temporary perched nitrate monitoring well showing elevation in feet amsl TW4-12 TWN-7 5503 5582 5562 5592 5564 5380 estimated dry area NOTE: MW-4, MW-26, TW4-4, TW4-19, and TW4-20 are chloroform pumping wells; TW4-22, TW4-24, TW4-25, and TWN-2 are nitrate pumping wells focus area for CIR H:/718000/nitrateast/CIR/Sitewl1213.srf 2 H:\718000\nitrateast\CIR\TW6_TW12_13_14_new_ntcl.xls: plot 3 F3 0 10 20 30 40 50 60 70 80 1/1/2002 1/1/2003 1/1/2004 12/31/2004 12/31/2005 12/31/2006 12/31/2007 12/30/2008 12/30/2009 12/30/2010 12/30/2011 12/29/2012 12/29/2013 date co n c e n t r a t i o n ( m g / L ) TW4-12 nitrate TW4-12 chloride TW4-13 nitrate TW4-13 chloride NITRATE AND CHLORIDE AT TW4-12 AND TW4-13HYDRO GEO CHEM, INC.Approved FigureDateAuthorDateFile Name SJS 01/08/14 3PLOT 3 F301/08/14SJS H:\718000\nitrateast\CIR\TW6_TW12_13_14_new_ntcl.xls: plot 4 F4 0 10 20 30 40 50 60 70 80 1/1/2002 1/1/2003 1/1/2004 12/31/2004 12/31/2005 12/31/2006 12/31/2007 12/30/2008 12/30/2009 12/30/2010 12/30/2011 12/29/2012 12/29/2013 date co n c e n t r a t i o n ( m g / L ) TW4-27 TW4-6 TW4-14 TW4-26 NITRATE IN THE VICINITY OF TW4-27HYDRO GEO CHEM, INC.Approved FigureDateAuthorDateFile Name SJS 01/08/14 4plot 4 F401/08/14SJS H:\718000\nitrateast\CIR\TW6_TW12_13_14_new_ntcl.xls: plot 4 F5 0 10 20 30 40 50 60 70 80 1/1/2002 1/1/2003 1/1/2004 12/31/2004 12/31/2005 12/31/2006 12/31/2007 12/30/2008 12/30/2009 12/30/2010 12/30/2011 12/29/2012 12/29/2013 date co n c e n t r a t i o n ( m g / L ) TW4-27 TW4-6 TW4-14 TW4-26 CHLORIDE IN THE VICINITY OF TW4-27HYDRO GEO CHEM, INC.Approved FigureDateAuthorDateFile Name SJS 01/08/14 5plot 4 F501/08/14SJS H:\718000\nitrateast\CIR\TW27area_wl.xls: plot F6 5510 5520 5530 5540 5550 5560 5570 5580 5590 5600 12/31/1999 12/30/2001 12/30/2003 12/29/2005 12/29/2007 12/28/2009 12/28/2011 date el e v a t i o n ( f t a m s l ) TW4-6 TW4-12 TW4-13 TW4-14 TW4-26 TW4-27 WATER LEVELS IN WELLS NEAR TW4-12 AND TW4-27HYDRO GEO CHEM, INC.Approved FigureDateAuthorDateFile Name SJS 01/08/14 6plot F601/08/14SJS HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE HYDRO GEO CHEM, INC. APPROVED DATE REFERENCE FIGURE H:\718000\nitrateast\CIR\tw6_26_27_new_ntchl.xls: plot F10 0 200 400 600 800 1000 1200 1/1/2002 1/1/2003 1/1/2004 12/31/2004 12/31/2005 12/31/2006 12/31/2007 12/30/2008 12/30/2009 12/30/2010 12/30/2011 12/29/2012 12/29/2013 date co n c e n t r a t i o n ( u g / L ) TW4-6 TW4-26 TW4-29 TW4-33 TW4-4 pumping start CHLOROFORM CONCENTRATIONS AT TW4-6, TW4-26, TW4-29, AND TW4-33 HYDRO GEO CHEM, INC.Approved FigureDateAuthorDateFile Name SJS 01/08/14 10plot F1001/08/14SJS APPENDIX A EFRI FIELD RECORDS APPENDIX A.1 EFRI FIELD RECORDS SECOND QUARTER 2013 APPENDIX A.2 EFRI FIELD RECORDS THIRD QUARTER 2013 APPENDIX A.3 EFRI FIELD RECORDS FOURTH QUARTER 2013 APPENDIX B LABORATORY ANALYTICAL REPORTS AND ASSOCIATED QA/QC APPENDIX B.1 LABORATORY ANALYTICAL REPORTS AND ASSOCIATED QA/QC SECOND QUARTER 2013 APPENDIX B.2 LABORATORY ANALYTICAL REPORTS AND ASSOCIATED QA/QC THIRD QUARTER 2013 APPENDIX B.3 LABORATORY ANALYTICAL REPORTS AND ASSOCIATED QA/QC FOURTH QUARTER 2013