DRC-2015-002343 - 0901a068805277c7

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2015-002343
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File
fit Phil Goble, Compliance Section Manager
Tom Rushing, P.G. "j (H if 2-3/1 $
March 23,2015
Review of the February 19, 2015 Energy Fuels Resources (USA) Inc. 4th 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, February 19, 2015, Transmittal of 4th Quarter 2014 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill.
2. EFR, February 5, 2015, State of Utah Ground Water Discharge Permit No. UGW370004
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a).
3. EFR, February 9, 2015, Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status
The review was conducted to ensure compliance with all applicable parts of Utah Groundwater Discharg
Permit No. UGW370004 ("Permit") issued for the White Mesa Uranium Mill located in Blanding, Utah.
1. Checklist of Significant Findings of the 4lh Qtr. 2014 Report and Related Actions at the White
Mesa Uranium Mill:
1. The 4th Quarter 2014 Report was received on February 27, 2015, which was before the d
date (Permit Part I.F. 1 the due date of March 1, 2015).
2. DRC notes that samples were analyzed by American West Analytical Laboratories
("AWAL") with the exception of ammonia which was analyzed by Chemtech-Ford
Laboratories, and Gross Radium Alpha which was analyzed by GEL Laboratories LLC.
DRC verified that all laboratories have current certification for all parameters/methods
used. No deviations/violations of the currently approved Quality Assurance Plan for the
White Mesa Uranium Mill were noted.
3. Per a previous EFR request, a May 25, 2012 EFR Permit modification request was made
order to document accelerated reporting and monitoring agreements made during a
teleconference with the Utah Division of Radiation Control (DRC). Per DRC staff
195 North 1950 West • Salt Lake City, I I
Mailing Address: P.O. Box 144850 • Salt Lake City, I T 84114-4850
Telephone [phone] • Fax [phone] • T.D.D [phone]
www.tieq.uiah.fiov
Prinled on 100% recycled paper
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 2
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
4th 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 Tailings 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 4lh Quarter
2014 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 it appears that all discrepancies were self-
reported by EFR. One of the discrepancies was determined to be a violation of the Facility
Quality Assurance Plan ("QAP") and recommended that EFR be cited for the violation in a
Notice of Enforcement Discretion, as discussed below.
7. Four compliance parameters went into accelerated monitoring frequency during the
monitoring period, as discussed below.
2. Accelerated Monitoring and POC Wells Exceeding GWCL's:
When a monitoring well has a pollutant that exceeds a Ground Water Compliance Limit (GWCL) set forth
in Table 2 of the Permit, it is in Probable Out-of-Compliance (POOC) status. According to the Permit,
EFR is then required to immediately initiate accelerated sampling of that pollutant (see the Permit, Part
I.G.I). When monitoring wells have parameters that have exceeded the Ground Water Compliance Limit
(GWCL) two or more consecutive times they are in Out-of-Compliance (OOC) status (see the Permit, Part
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 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 4X Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 3
Accelerated Momtoring Requirement Exception:
Per past DRC review; 1st Qtr., 2nd Qtr., and 3rd Qtr. 2011 Groundwater Monitoring Reports, DRC issued a
February 7, 2012 Notice of Enforcement Discretion ("NOED") for failure on the part of EFR to comply
with these timelines for acceleration of groundwater monitoring at well MW-35.
EFR stated in a March 26, 2012 response to the NOED that based on an agreement made between DRC
and EFR during a telephone conference call on April 5, 2010, EFR is not required to implement accelerated
monitoring until "the month following the submission of the Exceedance Notice for a specified quarter.''''
Based on DRC review of notes taken during the April 5, 2010 telephone conference (Loren Morton
4/5/10), EFR verbally requested to wait until the end of the quarter to 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 Monitoring
Well Class * Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-11 Class II water D-3 Manganese February 2010 May 2010
MW-14 Class III water D-4A Field pH February 2010 May 2010
MW-25 Class III water C-3 Field pH
Uranium
Chloride
4,n Quarter 2010
3rd Quarter 2010
Is'Quarter 2013
February 2013
March 2014
June 2013
MW-26 (a)
MW-30
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' Quarter 2014
Class II water D-2 Nitrate + Nitrite (as N)
Chloride
February 2010
Is' Quarter 2011
May 2010
May 2010
May 2010
May 2010
May 2010
June 2010
June 2014
May 2010
May 201 1
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 4
Well Class * Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Selenium
Uranium
Field pH
Ammonia
April 2010
4th Quarter 2011
4th Quarter 2014
4"' Quarter 2014
July 2010
March 2014
March 2015
March 2015
MW-31 Class IU water D-2
Nitrate + "Nitrite (as N)
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 201 I
December 2012
June 2014
MW-35 Class II C-4B
Uranium
Manganese
Thallium
Adjusted Gross Alpha
Selenium
2nd Quarter 2011
2nd Quarter 2011
3rd Quarter 2011
3rd Quarter 2011
3rd Quarter 2012
July 2011
July 2011
July 2011
October 2011
December 2012
D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1,2,3,4A = Cell #
a = Monitoring well MW-26 is a pumping well for the Chloroform investigation
Wells Monitored Semi-annually Accelerated to Quarterly Monitoring
Well Class * Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
MW-1 Class II water U-l
Tetrahydrofuran
Field pH
Sulfate
Manganese
4m Quarter 2012
3rd Quarter 2014
4th Quarter 2012
4th Quarter 2012
1st Quarter 2013
1st Quarter 2015
1st Quarter 2013
Is' Quarter 2013
MW-3 Class III water D-4A
Selenium
Field pH
Fluoride
Nitrate + Nitrite (asN)
Sulfate
2^ Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4lh Quarter 2013
4th Quarter 2013
3ra Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
2nd Quarter 2014
2nd Quarter 2014
2^ Quarter 2010
MW-3A Class III water D-4A
Field pH
Sulfate
TDS
Selenium
Nitrate + Nitrate (as N)
2nd Quarter 2010
2nd Quarter 2010
4th Quarter 2010
4lh Quarter 2012
^Quarter 2010
2nd Quarter 2010
lsl Quarter 2014
4th Quarter 2014
3ra Quarter 2010
3 rd Quarter 2010
3rd Quarter 2010
1st Quarter 2011
Is' Quarter 2013
MW-5 Class II water D-3 Uranium
T5 Quarter 2010
Quarter 2011
MW-12 Class III water D-3
Selenium
Field pH
Selenium
2nd Quarter 2014
2nd Quarter 2015
Quarter 2012
4th Quarter 2013 MW-15
MW-18
Class III water D-4A Selenium
Field pH
3ra Quarter 2012
2nd Quarter 2014
Class III water U-l
Thallium
Sulfate
TDS
^Quarter 2010
2nd Quarter 2010
3ra Quarter 2010
3rd Quarter 2010
2nd Quarter 2010 [ 3rd Quarter 2010
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 5
Well Class •Position Parameter Date of First
Exceedance of
GWCL
Date Accelerated
Monitoring First
Required
Field pH Is' Quarter 2014 2"* Quarter 2014
3~frQuarter 2010
1st Quarter 2012
Is' Quarter 2013
MW-19 Class III water U-l
Field pH
Nitrate + Nitrite as N
Adjusted Gross Alpha
2na Quarter 2010
4,h Quarter 2011
4lh Quarter 2012
^Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
2nd Quarter 2010
4lh Quarter 2012
4lh Quarter 2014
3^ Quarter 2010 MW-23 Class III water D-3 Field pH
^Quarter 2010
3rd Quarter 2010
3rd Quarter 2010
1st Quarter 2013
2,,d Quarter 2015
MW-24 Class III water D-1
Cadmium
Thallium
Field pH
Fluoride
Sulfate
2^ Quarter 2010
4th Quarter 2010
1st Quarter 2010
lsl Quarter 2010
2nd Quarter 2013
Vs Quarter 2010
4,h Quarter 2014
3rd Quarter 2010
3rd Quarter 2010
Is' Quarter 2014
MW-27 Class III water U-l
Nitrate + Nitrite (as N)
Adjusted Gross Alpha
TDS
Chloride
Sulfate
MW-28 Class III water D-1
Field pH
Chloride
Cadmium
Uranium
Vanadium
1st Quarter 2014 ^Quarter 2014
3rd Quarter 2010 2nd Quarter 2010
2nd Quarter 2014 2nd Quarter 2014
2nd Quarter 2014 2nd Quarter 2014
2nd Quarter 2014 2nd Quarter 2014
^Quarter 2011
3rd Quarter 2012 MW-29 Class III water D-2 Field pH
TDS
4tn Quarter 2010
2nd Quarter 2012
MW-32 Class III water C-2 Adjusted Gross Alpha
Field pH
2^ Quarter 2010
2"d Quarter 2010
3™ Quarter 2010
3rd Quarter 2010
* D = Down-gradient; U = Up-gradient; C = Cross-gradient; 1, 2, 3, 4A = Cell #
Table I above is a comprehensive list of all Groundwater Monitoring Wells in Accelerated Status as of the
fourth 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.I (a), Accelerated
Monitoring Status Reports (AMSR)]. For the 4lh quarter 2014 monitoring, the AMSR and follow up Plan
and Time Schedule [Required by the Permit Part I.G.4(d)] was received, dated February 5, 2015 (received
by DRC on February 6, 2015).
Four parameters with a new exceedances were noted per review of the AMSR: MW-30 was accelerated
from quarterly to monthly based on a 4th Quarter 2014 exceedances of the field pH and Ammonia
GWCL's, MW-12 was accelerated from semi-annual to quarterly based on a 4lh Quarter 2014 exceedance
of the field Selenium GWCL, and MW-24 was accelerated from semi-annual to quarterly based on a 4lh
Quarter 2014 exceedance of the Sulfate GWCL.
DRC noted that monitoring well MW-35 field pH results were outside of the ground water quality standard
range per the November and December 2014 field results. This parameter was not included on the OOC
accelerated monitoring list based on the GWQS not being listed in the Permit Table 2. DRC does note that
field pH is measured on the current accelerated monitoring frequency due to other parameters at the well
needing this frequency.
EFR 4th Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 6
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 is possible/likely that repair of the well and redevelopment
activities which occurred subsequent to the damage will correct the exceedances. Based on subsequent
discussion between DRC and EFR, it was decided that additional accelerated monitoring results, beyond
the 3rd Quarter 2014, would be needed to determine if the well damage was the cause of the parameter
exceedances and whether additional corrective action, and the type of action (e.g. groundwater pumping),
will be required.
3. Monitoring Wells Purged for Two Casing Volumes Before Sample Collection:
As stated in Section 6.2.7 of the EFR Quality Assurance Plan (QAP), Rev. 7.2, EFR has a choice regarding
purge volumes as follows:
"7. Purging three well casing volumes with a single measurement offield parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list offield parameters after recovery
Per DRC review of the Report, the following purge methods were used during the 4th Quarter 2014
(including accelerated samples). Purge methods and volumes are summarized on Table G-l A of the 4th
Quarter 2014 Monitoring Report:
Quarter # Purged 2 Casing Volumes 1 # Purged to Dryness I # Purged 3 Casing Volumes
4lh Qtr. 2014 33 [ 5 1
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 4th Quarter 2014 monitoring period. Volumes are calculated according to
measured pump rates and can be verified by calibration marks on the collection containers.
During the 4"1 Quarter of 2014 monitoring five wells were pumped or bailed to dryness. In cases where
wells are evacuated to dryness the QAP Rev. 7.2 requires that:
"(vii) Ifthe 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 to fill sample
containers.
Upon arrival at the well after recovery or when sufficient water is available for sampling measure depth to
water and record on the Field Data Worksheet.
Take one set of measurements offield parameters for pH, specific conductance and temperature only.
Collect the samples into the appropriate sample containers.
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 7
Take an additional set of measurements offield parameters for pH, specific conductance and temperature
after the samples have been collected.
Ifthe field parameters ofpH, specific conductance and temperature are within 10% RPD the samples can
be shippedfor analysis.
Ifthe field parameters ofpH, specific conductance and temperature are not within 10% RPD, dispose of
the sample aliquots, and purge the well again as described above.
Repeat this process if necessary for three complete purging events. If after the third purging the event, the
parameters of pH, specific conductance and temperature do not stabilize to within 10% RPD, the well is
considered sufficiently purged and collected samples can be submittedfor analysis."
DRC staff verified that in cases where the monitoring well was evacuated to dryness 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.
4. Relative Percentage Difference Calculations and Radiological Comparisons for Blind
Duplicate Analysis:
DRC conducted a review of the blind duplicate samples collected during the 4th Quarter 2014. Per the
facility QAP, one blind duplicate must be collected with each sample batch. DRC confirmed that one blind
duplicate was collected for each batch (4 total during the quarterly event - two with the baseline samples
and two with the accelerated samples).
The duplicates are required to be within 20% Relative Percent Difference (RPD), unless "the measured
concentrations are less than 5 times the required detection limit (Standard Methods, 1998)."
Per updated language in the QAP Rev. 7.2 Part 9.1.4, if any of the samples do not meet the comparison
criteria (and are not qualified according to the 5 times method detection limit criteria) then EFR is required
to conform to the procedures for corrective action listed as follows:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation errors, and,
3. If the samples are still within holding time, the QA Manager may request the laboratory re-analyze
the affected samples.
Per DRC cross check of the blind duplicate samples collected and analyzed during the 4lh Qtr. 2014
sampling event all sample results conform to the Permit requirements (within 20% RPD) with the
exception of Bicarbonate for the MW-22/MW-70 duplicate and Chloroform and Methylene Chloride for
the M W-26/M W-65 accelerated duplicate. A discussion of these nonconforming duplicates is below.
Per the White Mesa Uranium Mill Quality Assurance Plan Section 9.1.4 "Corrective actions for duplicate
deviations shall first determine ifthe deviation is indicative of a systematic issue which requires the
procedures described in Section 10. Ifthe non-conformance is limited in scope and nature, the QA Manger
will: 1. Notify the laboratory, 2. Request the laboratory review all analytical results for transcription and
calculation errors, and, 3. Ifthe samples are still within holding time the QA Manager may request the
laboratory re-analyze the affected samples." Per summaries of blind duplicate RPD's outside of
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 8
acceptance criteria, included below; it appears that EFR implemented the required corrective actions as
discussed below.
Bicarbonate Nonconformance Blind Duplicate MW-37/MW-70
"The RPD's outside of the acceptance criteria are likely due to matrix interferences in MW-22. Results of
the RPD test are provided under Tab G." Per the White Mesa Quality Assurance Plan, EFR is required to
follow actions per Part 9.1.4 (listed above). Per the Report "The corrective actions that were taken in
accordance with the QAP procedure are as follows: the QA Manager contacted the Analytical Laboratory
and requested a review of the raw data to assure that there were no transcription errors and the data were
accurately reported. The laboratory noted that the data were accurate and reported correctly. Reanalysis
was not completed as the samples were beyond the method specified holding times."
Chloroform and Carbon Tetrachloride Nonconformance Blind Duplicate MW-26/MW-65
Per the Report, Section 3.4.7 (p. 12), "The RPD's outside of the acceptance criteria are likely due to the
elevated concentrations in MW-26. Results of the RPD test are provided under Tab G." DRC notes that
MW-26 is currently being used as a pumping well to remediate chloroform contamination and that the
concentrations of organic solvents may be variable, over short durations, due to the pumping activity. EFR
performed the required corrective actions as per the White Mesa Mill Quality Assurance Plan, Part 9.1.4.
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; Chemtech Ford Laboratories, Sandy,
UT, and American West Analytical Laboratories, Salt Lake City, UT) were contracted by EFR to perform
analysis on the samples collected during the 4th 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:
Basic Details
Name Chemtech Ford Laboratory
Type of Lab Commercial
TNI Lab Code TN 101969
EPA Code UT00027
State ID 8012627299
Website http://www.chemtechford.com/
Extended Details
Primary AB responsible
for lab demographics Utah Department of Health
GIS Location
Description
Comments
Effective Date
Commercial Samples Yes
Active Yes
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 9
Address 1
Type Location
Company Chemtech Ford Laboratories
Contact David Gayer
Address 1 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:
Basic Details
Name GEL Laboratories, LLC
Type of Lab Commercial
TNI Lab Code TN 100188
EPA Code SC00012
State ID E87156
Website
Extended Details
Primary AB responsible
for lab demographics
GIS Location
Description
Comments
Effective Date
Commercial Samples
Active Yes
Address 1
Type Location
Company
Contact JAMES B. WESTMORELAND
Address 1 2040 Savage Rd
Address 2
City Charleston
State South Carolina
Zip 29407
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
American West Analytical Laboratories Current Utah Certification
Basic Details
Name American West Analytical Laboratories
Type of Lab Commercial
TNI Lab Code TNI01955
Utah Department of Health
Yes
EFR 4l Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 10
EPA Code UT00031
State ID 8012638686
Website
Extended Details
Primary AB responsible
for lab demographics
GIS Location
Description
Comments
Effective Date
Commercial Samples
Active Yes
Address 1
Type Location
Company
Contact Kyle Gross
Address 1 463 West 3600 South
Address 2
City Salt Lake City
State Utah
Zip 84115-
Country US
Phone [phone]
Fax [phone]
Email [e-mail]
DRC noted that 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.
6. Laboratory Report Turn Around Times:
Per DRC review of EFR Table 1 included in the 4lh 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. Per DRC
review it was noted that EFR acted quickly to identify any deficiencies in the reports and request corrected
versions.
There is not a turnaround time requirement in the current QAP; therefore, current turnaround times are
judgment based. DRC has raised concern over excessive laboratory turn-around times in the past and the
Director may require a turn-around date be included in the facility QAP if any future concerns regarding
analysis turnaround times are noted. Based on DRC review the turn-around times for the 4th Quarter 2014,
data turn-around times and EFR data review timelines 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 4th Qtr 2014 reporting period.
Utah Department of Health
Yes
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 11
8. Sample Preservation:
Per review of the 4th 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 and laboratory QA/QC, no issues related to sample preservation were noted.
9. Laboratory QA/QC Flags - 4th Quarter 2014:
QA/QC issues and DRC findings for the 4th 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, TDS,
Nitrate/Nitrite (as N),
Ammonia
Y EFR states that the raised
RL's are due to sample
dilution and qualifies the data
in Table G based on all
sample results being above
the raised RL.
The EFR QAP allows for
raised RL's if due to need for
dilution. DRC verified that in
all cases when the RL was
raised above the QAP
required RL the sample result
was higher in concentration.
MW-23, MW-28-Gross
Alpha Counting Error was
not < 20% of the sample
analysis result (sample
activity).
Y 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-25,
TDS
None Per the QAP Part 8.1.2(a)
matrix spikes are required but
there are no requirements
which would disqualify the
laboratory data
Method Blank Detections
Reported above the QAP
Required RL for all
Ammonia Samples, analyzed
by Chemtec-Ford
From EFR Report Part 3.4.9,
p. 15, "Ammonia was
reported in the method blanks
in several analytical groups.
The samples associated with
these method blanks were not
an order of magnitude
greater than the blank results
as required by the QAP.
Blank detections are
indicative of a false positive
or high bias to the sample
results as the laboratory
contribution increases the
concentration of the sample
results A comparison of the
fourth quarter results to
Per the QAP Part 9.1.3 "Trip
blanks, method blanks, and
equipment rinsate samples
will be compared with the
original sample results. Non-
conformance conditions will
exist when contaminant levels
in the sample(s) are not an
order of magnitude greater
than the blank result." As per
the EFR response, the data
results are not an order of
magnitude higher than the
blank detections and are
therefore in non-conformance
with the QAP. Ammonia
results exceeded the GWCL
EFR 4th Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 12
Non-Conformance Summary Self-
Identified?
EFR Corrective Action
Summary
DRC Findings
historic results indicates that
the ammonia results reported
by Chemtec-Ford are in fact
caused by blank
contamination. The QAP
requirement to analyze a
method blank with each batch
and evaluate the results has
been completed as required.
As previously stated, this
issue is a result of EFRI using
Chemtec-Fordfor the
ammonia analyses due to a
catastrophic fire at A WAL in
July. This issue will be
resolved in the first quarter
2015, when the Mill samples
are analyzed by AWAL."
in one monitoring well,
MW-30, during the
monitoring period. This issue
will be included as a notice of
enforcement discretion.
Matrix Spike Recoveries for
Accelerated Samples outside
of REC Range for MW-1 1
(October Accelerated), Cd,
Mn, Se, Th, U; MW-26
(October and December
Accelerated) Chloride and
M itrate
Y 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-31,
TDS, MW-65 Gross Radium
Alpha
Y The results outside of the
laboratory established
acceptance limits do not
affect the quality or usability
of the data because the
recoveries and RPD's above
the acceptance limits are
indicative of non-
homogeneity in the sample
matrix.
DRC notes that the laboratory
(GEL) reported the Gross
Alpha data without a
qualifier.
Note: DRC reviewed the holding time summary chart; no exceedances of holding times were noted
DRC reviewed the temperature check charts, all sample batches were received by the laboratory <6° C.
10. Review of Time-Concentration Plots
The Permit Part I.F. 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 of the 4lh Qtr. 2014 Report, the
reviewed plots appear to be in conformance with the agreed upon changes, no issues were identified.
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 13
11. Review of Depth to Groundwater Measurements and Water Table Contour Maps
Per DRC cross checks of groundwater elevation measurement calculations used for the 4lh Quarter 2014,
approximately 5% of wells cross checked, comparing surface 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 in order to re-establish groundwater contours.
Hydrographs of the upper wildlife pond ground water piezometers (Water Level Elevation vs. Time) are
included below. It was also noted that the static water levels in several monitoring wells close to the upper
wildlife ponds showed significant decrease in water levels during recent quarterly monitoring. These
declines can be attributed to natural dissipation of the area ground water mound and/or ground water
pumping activities related to corrective action of nitrate and chloroform contamination plumes
(development of cone of depressions around pumping wells).
IUC White Mesa Mill Hydrographs Piezometers @ North Wildlife Ponds
E
r 6610
C
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2 sco:
S
5 574
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 14
IUC White M*sa Mill Hydrographs PlszomtUr* @ South Wildlife Ponds
LOCMKHI Hrtont la Wddklt Poiite
[ P-4 -*-P&|
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 4,h 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.
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 15
12. EFR February 5,2015 Notice Pursuant to the Permit Part I.G.l(a)
The EFR February 5, 2015 Notice Pursuant to the Permit Part LG. 1(a) ('"Notice") discusses the status of
monitoring wells and parameters in probable out-of-compliance ("POOC") and out-of-compliance
("OOC") status, as updated through the 4lh 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 4th Quarter and is subject to requirements of the Permit Part l.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.
Monitoring Well MW-35 exceeded the GWQS for pH; The 4,h Qtr. 2014 (November 2014) measurement
was 6.35 S.U.; The December 2014 measurement was 6.25 S.U. However, it was noted that a compliance
range for pH was not included on Table 2 in the current permit. Additionally, DRC notes that a GWCL for
field pH in this well was approved by the Director on July 15, 2014, based on EFR submitted groundwater
background reports, but that it has not yet been included in the Permit (pending permit renewal). The
approved field pH for well MW-35 is 6.15 S.U to 8.5 S.U. EFR currently collects monthly accelerated
measurements of field pH at monitoring well MW-35 since the well is subject to accelerated monitoring for
other parameters (Field pH is part of the sample collection process to insure stable parameters prior to
sample collection).
Based on DRC review of the Notice it appears that all requirements of the Permit were met. DRC will
provide an advisory and request corrections for the issues noted above.
13. EFR February 9, 2015 Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status
Per the EFR February 9, 2015 Request for Removal of Certain Groundwater Monitoring Parameters from
Accelerated Monitoring Status ("EFR Request"), EFR requests that four monitoring well parameters be
returned to baseline monitoring. Specifically, the EFR Request addresses the following wells/parameters
be returned to baseline monitoring:
• MW-26/Carbon Tetrachloride
• MW-31/Field pH
• MW-1 /Manganese
• MW-19/Gross Alpha
The EFR requests that these monitoring wells be returned to baseline monitoring based on eight
consecutive sample results below the GWCL. Per past protocols regarding the return of monitoring well
parameters to baseline monitoring, eight consecutive sample results below the GWCL has been acceptable
to reduce the monitoring frequency
The EFR Request includes a table summary which lists the applicable monitoring results for each
well/parameter. The EFR Request additionally includes analytical reports and field monitoring sheets for
sample results which had not been provided to DRC at the time of the request. Per DRC cross check ol the
results it appears that eight consecutive results have been obtained for each of the wells/parameters
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 16
Therefore it is recommended that the wells/parameters be returned to baseline monitoring as summarized
on the table below:
Monitoring Well Parameter Baseline Monitoring Frequency
MW-26 Carbon Tetrachloride Quarterly
MW-31 Field pH Quarterly
MW-1 Manganese Semi-Annual
MW-19 Gross Alpha Semi-Annual
The return to baseline monitoring for these wells/parameters will be included in a transmittal letter for
Director review and approval.
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 4th Quarter of 2014 appear to be reliable.
It is recommended that a correspondence letter be sent to EFR with the following items:
1. Closeout regarding DRC review of the EFR 4th Quarter 2014 White Mesa Uranium Mill
Groundwater Monitoring Report based on findings as summarized above.
2. A "Notice of Enforcement Discretion" regarding contamination in the method blanks for ammonia
samples during the monitoring period. Per the Report, the contamination was due to a temporary
change of contract laboratories and will return to the original contract laboratory, AWAL, for the
next quarterly analysis.
3. Approval of parameters included in the February 9, 2015 request to return to baseline monitoring
frequency. The approval will affect four monitoring well parameters as discussed above.
15. References
1 Energy Fuels Resources (USA) Inc., February 19, 2015, 4th Quarter2014 Groundwater Monitoring
Report, Groundwater Discharge Permit UGW370004, White Mesa Uranium Mill.
2 Energy Fuels Resources (USA) Inc., February 5, 2015, State of Utah Ground Water Discharge Permit
No. UGW370004 White Mesa Uranium Mill-Notice Pursuant to Part I.G.J (a).
3 Energy Fuels Resources (USA) Inc., February 9, 2015, State of Utah Ground Water Discharge Permit
No. UGW370004 White Mesa Uranium Mill - Removal of Certain Groundwater Monitoring Parameters
from Accelerated Monitoring Status
4 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.
EFR 4 Quarter 2014 Groundwater Monitoring Report
DRC Review Memo
Page 17
6 INTERA Incorporated, 2007, Background Groundwater Quality Report: New Wells for Denison Mines
(USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah.
1 Hurst, T.G., and Solomon, D.K., 2008. Summary of Work Completed, Data Results,
Interpretations and Recommendations for the July 2007 Sampling Event at the Denison
Mines, USA, White Mesa Uranium Mill located near Blanding Ulah. 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.