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HomeMy WebLinkAboutDRC-2015-005419 - 0901a0688055a84cr, ENERGY FUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www energyfuels.com August 14, 2015 VIA PDF AND OVERNIGHT DELIVERY Scott Anderson, Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Div of Waste Management and Radiation Control AU6 11 2015 DRC-20l5-OO54-n Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a) Dear Mr. Anderson: The White Mesa Mill (the "Mill") performed second quarter ("Q2") groundwater monitoring during the period from April I, to June 30, 2015 under the August 24, 2012 version of the Mill's Groundwater Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were received during the period ending July 16, 2015. Pursuant to Part I.G.I.a) of the GWDP, (August 24, 2012) please take notice that the concentrations of specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this quarter in the attached Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been formatted to simplify the tracking of any continued exceedances from one monitoring period to the next by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics). Part I.G.I c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to the Executive Secretary a plan and a time schedule for assessment of the sources, extent and potential dispersion of the contamination, and an evaluation of potential remedial action to restore and maintain groundwater quality to ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT will be reestablished." The summary below relating to Q2 2015 exceedances includes, for each exceedance, a brief discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of other actions currently being undertaken by Energy Fuels Resources (USA) Inc. ("EFRI") or in light of other reports submitted by EFRI, and as determined by Division of Waste Management and Radiation Control ("DWMRC") (formerly Division of Radiation Control ["DRC"]) Staff. A description of the other actions and reports which have affected the requirement to submit a plan and time schedule are as follows: 1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing investigations at the Mill. Based on the results of the previous investigations, EFRI and the Director acknowledged that it has not been possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate + nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the activities associated with the CAP are on-going. Based on information provided by DWMRC in Letter to Mr. Scott Anderson August 14,2015 Page 2 teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30- day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at this time. 2. As discussed in previous quarterly groundwater sampling reports, the background levels and GWCLs for pH were established based on eight or more quarters of laboratory data, which are historically higher than field data. EFRl's letter to the Director dated January 31, 2011 proposed the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by EFRFs geochemical consultant, INTERA, Inc., EFRI compared the Mill's groundwater pH data from Q2 2011 and noted that all of the June 2011 groundwater results, and many of the other results from Q2 2011, were already outside the revised GWCLs that were to be proposed in the June 30, 2011 letter. Pursuant to teleconferences with DWMRC on December 5, and December 19, 2011, EFRI submitted a Work Plan and Schedule on January 20, 2012 and a revised plan based on DWMRC comments on April 13, 2012. Based on the approved Work Plan and Time Schedule, EFRI and DWMRC entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. The SCA required the completion of the pH Report and the Pyrite Investigation and associated report. The pH Report and Pyrite Investigation Report were submitted November 9, 2012 and December 7, 2012 respectively. By letter dated April 25, 2013, DWMRC accepted the conclusions that the out-of-compliance results for pH are due to background effects within the aquifer matrix and are not caused by Mill activities. DWMRC also approved the recalculation of the GWCLs. As a result, the 30-day plan and schedule for assessment is not required for field pH exceedances. 3. A Plan and Time Schedule will not be prepared for monitoring wells with two successive exceedances if successive exceedances were reported in a previous quarter and were included in the Source Assessment Reports ("SARs"), submitted October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13, 2014, and March 19, 2014 and the Plan and Time Schedule submitted January 8, 2015. A Plan and Time Schedule will not be submitted for those constituents covered by the previously mentioned SARs, because the conclusions and actions delineated in those reports were either accepted by DWMRC as documented in DWMRC correspondence dated April 25, 2013, July 23, 2013, September 17, 2013 January 7, 2014, March 10, 2014, and June 5, 2014 respectively. 4. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and methylene chloride exceedances is not required. It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to reflect background groundwater quality, as defined by the mean plus second standard deviation concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that, because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un- impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a given analyte will increase the number of exceedances due to statistical variation and not due to Mill activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a monthly frequency can result in resampling of essentially the same water and can lead to repeat Letter to Mr. Scott Anderson August 14, 2015 Page 3 exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same water. 1.0 Exceedances in Required Quarterly Sampling Wells 1.1 Quarterly Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods in Q2 2015. A 30-day plan and schedule contemplated in Part I.G.I c) of the GWDP will not be required for the consecutive exceedances below for the reasons stated below. One-time exceedances and non-successive exceedances are noted on Table 1, but not listed below. Consecutive exceedances which occurred in previous reporting periods are discussed in the SARs submitted to DWMRC October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13, 2014, and March 19, 2014 and the Plan and Time Schedule submitted January 8, 2015. MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in the March monthly and Q2 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-26 • Nitrate + nitrite has exceeded its GWCL in the March monthly and Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • Chloroform has exceeded its GWCL for all of the Q2 2015 sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of chloroform. Because this well is used in the chloroform capture program which is the subject of separate investigations and actions, a plan and time schedule to address the consecutive exceedances is not necessary and is not being submitted. MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January 20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform removal, concentrations of all constituents in that well are subject to potential variation over time as a result of the pumping activity. This will be taken into account by the Executive Secretary in determining compliance for this well." Based on information provided by DWMRC in teleconferences on April 27, and May 2, 2011, due to the current pumping status as part of the chloroform investigation program, the 30-day plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene chloride in MW-26. • The uranium concentration exceeded its GWCL in all of the Q2 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will Letter to Mr. Scott Anderson August 14, 2015 Page 4 become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL in all of the Q2 2015 sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The chloride concentration exceeded its GWCL in all of the Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL all of the Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The selenium concentration exceeded its GWCL in all of the Q2 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL in all of the monitoring periods for Q2 2015. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite Letter to Mr. Scott Anderson August 14, 2015 Page 5 contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The sulfate concentration exceeded its GWCL in all of the monitoring periods for Q2 2015. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The selenium concentration exceeded its GWCL in all of the monitoring periods for Q2 2015. This consecutive exceedance is addressed in the SAR, dated August 30, 2013. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The Total Dissolved Solids ("TDS") concentration exceeded its GWCL in all of the Q2 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-35 • The manganese concentration exceeded the GWCL in in all of the Q2 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • The uranium concentration exceeded the GWCL in MW-35 in all of the Q2 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next Letter to Mr. Scott Anderson August 14, 2015 Page 6 revision of the GWDP. As a result of DWMRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • The gross alpha minus Rn and U ("gross alpha") concentration exceeded the GWCL in MW-35 in all of the Q2 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • Field pH has been slightly outside (slightly lower than) the GWCL in the May 2015 and June 2015 monthly sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DWMRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DWMRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. 1.2 Quarterly Wells with New Exceedances Reported in Q2 No new exceedances for the quarterly wells were noted during Q2 2015. 2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly 2.1 Semi-annual Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods (Ql 2015 and Q2 2015). MW-3 was sampled twice during Q2 2015. Successive exceedances are defined in the GWDP as "concentration of a pollutant in two consecutive samples from a compliance monitoring point exceeds a GWCL". As noted below, cadmium and zinc exceeded the GWCL in 2 consecutive samples, but not two consecutive sampling events. MW-3 Letter to Mr. Scott Anderson August 14, 2015 Page 7 • Fluoride has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Selenium has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Cadmium has exceeded the GWCL for both of the samples collected in Q2 2015. This is the first consecutive exceedance for cadmium in MW-3. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. • Zinc has exceeded the GWCL for both of the samples collected in Q2 2015. This is the first consecutive exceedance for zinc in MW-3. Therefore, a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. MW-3A • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Selenium has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to Letter to Mr. Scott Anderson August 14, 2015 Page 8 address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-12 • Selenium has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-18 • Thallium has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells (MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In correspondence dated April 25, 2013, DWMRC noted "DWMRC agrees with the justification provided by EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan and schedule is not necessary because the exceedance is not caused by Mill activities and was previously discussed in the October 10, 2012 SAR. Until such time as the GWCLs are removed, the exceedances will continue to be noted and reported. • TDS has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells (MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In correspondence dated April 25, 2013, DWMRC noted "DWMRC agrees with the justification provided by EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan and schedule is not necessary because the exceedance is not caused by Mill activities and was previously discussed in the October 10, 2012 SAR. Until such time as the GWCLs are removed, the exceedances will continue to be noted and reported. MW-19 • Nitrate + nitrite has exceeded its GWCL in both the Ql 2015 sampling event and the Q2 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-24 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to Letter to Mr. Scott Anderson August 14, 2015 Page 9 address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-27 • The chloride concentration exceeded its GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-28 • Chloride has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-29 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-32 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DWMRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DWMRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. Letter to Mr. Scott Anderson August 14, 2015 Page 10 • Chloride has exceeded the GWCL for both the Ql 2015 sampling event and the Q2 2015 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. 2.1 Semi-annual Wells with New Exceedances Reported in Q2 New single exceedances for the Q2 2015 semi-annual well sampling program are listed below. These exceedances will result in an accelerated sampling frequency from semi-annually to quarterly. It is important to note that the wells listed below will only be sampled during the first and third quarterly events for the constituents which exceeded their GWCL. The wells listed below will be sampled for all constituents listed in the GWDP during the second and fourth quarterly events as that is the regularly scheduled sampling for the semi-annual wells. • Chloride in MW-1 was above the GWCL in the Q2 sampling event. • Beryllium in MW-3 was above the GWCL in the Q2 sampling event. • Sulfate in MW-29 was above the GWCL in the Q2 sampling event. Relative to accelerated reporting requirements, based on phone conversations with DWMRC on April 5, 2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the month following the submission of the Exceedance Notice for a specified quarter for wells that are being accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice for wells that are being accelerated from semiannually to quarterly. Per teleconferences with DWMRC, EFRI proposed modified language for the GWDP, Part 1.G.1 on May 25, 2012, to document DWMRC concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 teleconference. Harold Roberts David Turk Dan Hillsten Logan Shumway Scott Bakken Yours trul ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund Table 1 - GWCL Exceedances for Second Quarter 2015 under the August 24, 2012 GWDP Ql 2010 Results 02 2010 Results Q3 2010 Results Q4 2010 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24,2012 GWDP Ql 2010 Sample Date Ql 2010 Result Q2 2010 Sample Date Q2 2010 Result May 2010 Monthly Sample Date May 2010 Monthly Result June 2010 Monthly Sample Date June 2010 Monthly Result July 2010 Monthly Sample Date July 2010 Monthly Result August 2010 Monthly Sample Date August 2010 Monthly Result Q3 2010 Sample Date Q3 2010 Result October 2010 Monthly Sample Date October 2010 Monthly Result Q4 2010 Sample Date Q4 2010 Result December 2010 Monthly Sample Date December 2010 Monthly Result MW-11 (Class 11) Manganese (ug/L) Required Quarterly Sampling Wells 7/20/2010 123 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 2/2/2010 4/2.1/2010 6.45 7/20/2010 7.19 10/20/2010 6.6(1 Field pH (S.U.) 6.36 MW-25 (Class III) Cadmium (ug/L) NS 1.26 Uranium (ug/L) 6.5 Nitrate + Nitrite (as N) (mg/l.) 0.62 0.7 Uranium (ug/L) 58.7 37.5 Chloroform (ug/L) 800 MW-26 (Class III) Chloride (mg/L) 58.31 80 6/16/2010 9/26/2010 64 Field pH (S.U.) 6.36 6.9S 6.60 Dichloromethane (Methylene Chloride) (ug/L) 45 Nitrate + Nitrite (as N) (mg/L) 2.5 15.3 8/24/2010 /5 Chloride (mg/L) Uranium (ug/L) 8.32 6.82 NS MW-30 (Class II) Field pH (S.U.) 7/21/2010 7/27/2010 6.80 (6.82) 8/24/2010 6.73 9/14/2010 9/21/201(1 6.80 (6.84) Ammonia (mg/L) Selenium (ug/L) Nitrate + Nitrite (as N) (mg/L) 21.7 5/21/201(1 21.1 20 20 20 TDS (mg/L) NS MW-31 (Class III) Chloride (mg/L) NA Selenium (ug/L) NS NS 9/13/2010 (9/21/10) NS Field pH (S.U.I 6/15/2010 7.66 (7.13) 10/19/2010 Sulfate (mg/L) NS 539 Manganese (ug/L) 698 Thallium (ug/l) MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) NS Field pH (S.U.) Selenium (ua/L) Uranium (ue/L! NS Required Semi-Annual Sampling Wells MW-01 (Class II) etrahydrofuran (ug/I^ Chloride (mg/L) Field pH (S.U.) Sulfate (mg/L) 22.1 6.77 - 8.5 838 7.86 (6.87) NS NA NS Selenium (ug/L) 37.2 38.8 Field pH (S.U.) 6.14 (6.25) 6.35 MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/l.) 5/3/2010 NS Zine (ug/L) 173.19 Sulfate (mg/L) Nitrate + Nitrite (as N) (mg/l.) 0.73 Fluoride (Mg/L) 0.71 0.77 NS Field pH (S.U.) 6.23 (6.24) MW-3 A (Class 1 Sulfate (mg/L) 3680 Nitrate + Nilrile (as N) (mg/L) NS NS TDS (mg/L) Selenium (ug/L) MW-05 (Class II) Uranium (ug/L) 4/26/2010 NS Selenium (ug/l,) 25.7 27.6 MW-12 (Class III) Field pH (S.U.) 4/27/2010 NS 6.47 NS MW-15 (Class III) Selenium (ug/L) 128.7 Field pH (S.U.) Ql 2010 Results Q2 2010 Results Q3 2010 Results Q4 2010 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP Ql Sample Date Ql Result Q2 Sample Date MW-18 (Class III) Thallium (ug/l) Sulfate (mg/l.) Field pH (S.U.) TDS (mg/L) 6.25-8.5 3198.77 Q2 Result May Monthly Sample Date May Monthly Result June Monthly Sample Date NA NS June Monthly Result July Monthly Sample Date July Monthly Result August Monthly Sample Date August Monthly Result Q3 Sample Date Q3 Result October Monthly Sample Date October Monthly Q4 Sample Date Q4 Result December Monthly Sample Date Required Semi-Annual Sampling Wells, continued NS 3.64 11/18/2010 3.57 December Monthly Result MW-19 (Class III) Field pH (S.U.) 6.78-8.5 6.61 (6.66) 6.93 Nitrate + Nitrite (as N) (mg/L) NS 2.83 NS MW-23 (Class III) Field pH (S.U.) 6.18 NS Cadmium (ug/L) 4.28 NA Fluoride (mg/L) 0.36 MW-24 (Class III) Thallium (ug/L) NS NS 1.3 9/21/2010 1.09 Field pH (S.U.) 6.5 - 8.5 5.91(5.78) Nitrate + Nitrite (as N) (mg/l.) 5.6 5.9 MW-27 (Class III) Chloride (mg/L) 42 45 Sulfate (mg/L) 462 5/3/2010 NS 11/12/2010 TDS (mg/L) 1160 1110 Gross Alpha minus Rn & U (pCi/I.) 2.4 Chloride (mg/L) 105 106 Cadmium (ug/L) MW-28 (Class III) Uranium (ug/L) 4.9 NS 4/19/2010 NS 11/12/2010 Vanadium (ug/L) Field pH (S.U.) 5.67 5.91 5.72 TDS (mg/L) MW-29 (Class HI) Sulfate (mg/l.: NS 2770 NS NS NS 2690 Field pH (S.U.) 6.17 NS Gross Alpha minus Rn & U(pCi/L) 3.33 MW-32 (Class III) Chloride (mg/L) 35.39 NS NS Field pH (S.U.) 6.4 - 8.5 6.03 6.33 6.05 Notes: GWCL values are taken from August 24. 2012 version of GWDP. NS = Not Required and Nol Sampled — tveuuiiCU ana Fxecedanees are shown in yellow Values in (} parentheses are the field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for Second Quarter 2015 under the August 24. 2012 GWDP Ql 2011 Results Q2 2011 Results Q3 2011 Results Q4 2011 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2011 Monthly Sample Date January 2011 Monthly Sample Result Q12011 Sample Date Ql 2011 Result March 2011 Monthly Sample Date March 2011 Monthly Result Q2 2011 Sample Date Q2 2011 Result May 2011 Monthly Sample Date May 2011 Monthly Result June 2011 Monthly Sample Date June 2011 Monthly Result July 2011 Monthly Sample Date July 2011 Monthly- Result Q3 2011 Sample Date Q3 2011 Result September 2011 Monthly Sample Date September 2011 Monthly Result Q4 2011 Sample Date Q4 2011 Result November 2011 Monthly Sample Date November 2011 Monthly Result December 2011 Monthly Sample Date Required Quarterly Sampling Wells MW-11 (Class 11) Manganese (ug/L) 148 5/10/2011 170 6/15/2011 121 106 10/4/2011 MW-14 (Class 111) Held pH (S.U.) 6.5 - 8.5 l/l 1/201 1 6.37 6.23 10/4/2011 6.71 (6.82) MW-25 (Class III) Field pH (S.U.) 6.5 - 8.5 6.44 6.79 6.29 Cadmium (ug/L) 1.5 5/11/2011 6/20/2011 8/3/2011 8/30/11 6.42 (6.54) 6.51 8/30/2012 10/4/2011 Uranium (ug/L) 7.02 6.8 6.74 6.56 Nitrate + Nitrite (as N) (mg/L) 0.62 0.8 0.3 2.4 Uranium (ug/L) 41.8 57.4 58.9 Chloroform (ug/L) 1200 390 1900 1000 1300 1200 MW-26 (Class HI) Chloride (mg/l.) 3/15/2011 64 4/1/2011 8/3/201 8/30/11 60 9/7/2011 12/14/2011 Field pH (S.U.) 6.22 6.43 6.07 (6.58) Dichloromethane (Methylene Chloride) (ug/L) 20 7.9 Nilrate + Nitrite (as N) (mg/L) 2.5 16 16 17 16 Chloride (mg/L) 134 MW-30 (Class II) Uranium (ug/L) 8.32 4/11/2011 9/7/2011 Field pH (S.U.) 6.50 5.66 10/4/2011 11/29/2011 12/12/2011 6.96 (6.73) Ammonia (mg/L) Selenium (ug/L) 36.2 38.3 38.7 36.6 Nitrate + Nitrite (as N) (mg/L) 20 22 21 21 1370 MW-31 (Class III) Chloride (mg/L) Selenium (ug/L) 65.2 5/10/201 145 148 148 145 11/8/2011 (11/29/12) Field pH (S.U. 7.43 7.01 (7.34) Sulfate (mg/L) 532 541 539 Manganese (ug/l.) 248 369 348 267 283 Thallium (ug/l) NA 0.52 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 3.75 2/15/2011 NS 4.4 Field pll (S.U.) 6.49 6.40 Selenium (ug/L) Uranium (ug/L) 12.7 NA NA 24.2 18.3 Required Semi-Annual Sampling Wells MW-01 (Class II) Tetrahydrofuran (ug/L) Chloride (mg/L) Field pH (S.U.) Sulfate (mg/l.) 11.5 22.1 NS 4/19/201 4/11/201 1 rrm NA NA NA NS NA NS 7.08 (7.51) NS Selenium (ug/L) 37 45.4 46.7 Field pH (S.U.) 6.5 - 8.5 6.46 6.53 (6.83) MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/L) 4.67 2/15/2011 NS 8/10/2011 NS Zine (ug/L) 173.19 NA Sulfate (mg/L) 3663 NA Nilrate + Nitrite (as N) (mg/L) 0.3 Fluoride (Mg/L) 0.68 0.69 Field pH (S.U.) 6.19 6.5 (6.92) MW-03A (Class III) Sulfate (mg/L) 3730 3350 Nitrate + Nitrite (as N) (mg/l.) 1.3 4/13/2011 8/11/2011 NS TDS (mg/L) 5805 Selenium (ug/L) 89 95 MW-05 (Class 11) Uranium (ug/L: NS 29.5 NS NS MW-12 (Class III Selenium (ug/L) 25 39.0 35.4 Field pH (S.U.) 6.5 - 8.5 6.7 (6.97) MW- (Class Selenium (ug/L) Field pHlS.U.) 6.62 - 8.5 Ql 2011 Results Q2 2011 Results Q3 2011 Results Q4 2011 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2011 Monthly Sample Date January 2011 Monthly Sample Result Ql 2011 Sample Date Ql 2011 Result March 2011 Monthly Sample Date March 2011 Monthly Result Q2 2011 Sample Date Q2 2011 Result May 2011 Monthly Sample Date May 2011 Monthly Result June 2011 Monthly Sample Date June 2011 Monthly Result July 2011 Monthly Sample Date July 2011 Monthly Result Q3 20U Sample Date Q3 20U Result September 2011 Monthly Sample Date September 2011 Monthly Result Q4 2011 Sample Date Q4 20U Result November 2011 Monthly Sample Date November 2011 Monthly Result December 2011 Monthly Sample Date December 2011 Monthly Result Required Semi- Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/L) Field pH (S.U.) TDS (mg/L) 1770 3.74 3250 NA NS NA 8/10/2011 9/21/11 4.0 3.39 5.95 (6-30) 3190 10/11/2011 3.83 2020 6.55 (6.63) 3220 NA NA NA NA MW-19 (Class III) Field pH (S.U.) 6.78-8.5 Nitrate + Nitrite (as N) (mg/L) NS 6.88 (7.02) 4/5/2011 2.83 2.6 4.0 MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 6.13 4/5/2011 6.38 10/6/2011 6.56 (6.77) Cadmium (ug/I.) 2.5 2.78 MW-24 (Class III) Fluoride (mg/L; Sulfate (mg/L) 2903 NA Thallium (ug/I.) 4/5/2011 1.07 NS 10/11/2011 Field pH (S.U.) 5.73 6.45 Nitrate + Nitrite (as N) (mg/L) 6.4 MW-27 (Class III) Chloride (mg/L) 43 10/5/2011 TDS (mg/L) 1190 1110 Gross Alpha minus Rn &U(pCi/l.) Chloride (mg/L) 114 MW-28 (Class III) Cadmium (ug/I.) Uranium (ug/I.) 10/5/2011 Vanadium (ug/I.) Field pH (S.U.) 6.1 -8.5 6.01 «.97(6.1I) NA TDS (mg/L) MW-29 (Class III) Sulfate (mg/L) 2946 NS 2850 Field pH (S.U.) 6.46 - 8.5 NA NA NS MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 4.6 Chloride (mg/L) 35.39 8/2/201 8/30/1 1 NS 10/3/2011 Field pH (S.U.) 6.14 6.10 (6.20) NA NS GWCL values are taken from August 24. version of GWDP. NS = Not Required and Not Sampled Fxeeedanees are shown in yellow Values in () parentheses are Ihe field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for Second Quarter 21)15 under Ihe August 24. 2012 GWDP Ql 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2012 Monthly Sample Date January 2012 Monthly Result Ql 2012 Sample Date Ql 2012 Result March 2012 Monthly Sample Date March 2012 Monthly Result April 2012 Monthly Sample Date April 2012 Monthly Result Q2 2012 Sample Date Q2 2012 Result June 2012 Monthly Sample Date June 2012 Monthly Result Q3 2012 Sample Date Q3 2012 Result August 2012 Monthly Sample Date August 2012 Monthly Result September 2012 Monthly Sample Date September 2012 Monthly Result October 2012 Monthly Sample Date October 2012 Monthly Result Q4 2012 Sample Date Q4 2012 Result December 2012 Monthly Sample Date Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/l.) 131.29 1/26/2012 102 2/13/2012 3/13/2012 5/S/201 127 135 9/19/2012 138 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 1/24/201 6.36 2/21/2012 6.57 3/14/2012 4/12/2012 6.58 9/18/201: 7.08 Field pH (S.U.) 6.5-8.5 6.73 6.99 6.88 6.47 MW-25 (Class III) Cadmium (ug/L) 1.5 1/25/2012 2/14/2012 1.33 8/6/2012 9/18/201: 12/24/2012 Uranium (ug/I.) 6.93 6.52 7.6 6.61 Nitrate + Nitrite (as N)(mg/L) 0.62 1.9 2/15/2012 2.3 7/11/2012 1.9 3.5 Uranium (ug/L; 64.6 59.4 64.9 Chloroform (ue/L) MW-26 (Class III) Chloride (mg/L) 58.31 2/15/2012 1700 2400 970 2200 4020 82 Field pFHS.U.) 6.74 - 8.5 3T572TTTT 2/21/2012 3»i»()17 6.72 (6.91) (6.71) 5/7/2012 6/26/2012 6/19/2012 85 78 78 11/15/2012 12/24/2012 6.39 7.00(7.01) 7/11/2012 8/16/2012 7.10 (6.80) 6.60 Dichloromethane (Methylene Chloride) (ug/L) 2/15/2012 24 9.8 Nitrate + Nitrite (as N) (mg/L) 2.5 15 18 18.5 Chloride (mg/L) 130 135 Uranium (ug/l.) 8.32 NS 7.42 MW-30 (Class II) 6/18/2012 12/26/2012 Field pH (S.U.) 7.05 Ammonia (mg/I.) Selenium (ug/L) 34 35 39.5 38.5 38.4 41.9 Nitrate + Nitrite (as N) (mg/L) 21 21 21.6 21 21 TDS (mg/I.) 1380 1410 1460 MW-31 (Class III) Chloride (mg/L; 155 150 152 Selenium (ug/L) 6/18/2012 6/29/2012 7/9/201 161 175 172 76.9 12/18/2012 Field pH (S.U.) 7.28 (7.63) Sullale (mg/I.) 532 571 Manganese (ug/L) 269 277 258 253 241 Thallium (ug/l) 0.65 0.71 0.59 0.54 0.517 0.554 MW-35 (Class II) Gross Alpha minus Rn&U(pCi/I.) 3.75 6.5 6.2 1/24/2012 2/14/2012 3/13/2012 4/10/2012 4.9 4.2 5.4 10/23/201 Field pH (S.U.) 6.35 6.48 6.84 6.43 Selenium (ug/I.) 12.5 19.7 19.0 Uranium (ug/I.) 16.1 24.9 22.4 22.2 22.9 22.4 21.8 Required Semi-Annual Sampling Wells retrahydrofuran (ug/I MW-01 (Class II) Chloride (mg/I.) Field pH (S.U.) Sullale (mg/l.) 22.1 NS NS 5/1/201 NS 11/27/201 846 Selenium (ug/I.) 37 51.1 Field pH (S.U.) 6.5 - 8.5 MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/L) 4.67 NS 2/29/2012 NS NS 11/28/2012 /ine (ug/L) Sulfate (mg/I.) 3663 2340 Nitrale + Nitrite (as N) (mg/L) Fluoride (Me/I.) 0.86 0.96 1.26 Field pH (S.U.) 6.35 MW-03A (Class Sulfate (mg/L) Nitrate + Nitrite (as N) (mg/I.) NS 5/15/2012 1.31 NS Selenium (ug/L) 99.3 MW-05 (Class II) Uranium (ug/I.) 7/16/201 Selenium (ug/L) 25 NA 23.0 MW-12 (Class III) Field pH (S.U.) 6.5 - 8.5 7/17/2012 MW-15 (Class III) Selenium (ua/L) Field pHtS.U.) 6.62 - 8.5 5/9/2012 152 Ql 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2012 Monthly Sample Date January 2012 Monthly Result Ql 2012 Sample Date Ql 2012 Result March 2012 Monthly Sample Date March 2012 Monthly Result April 2012 Monthly Sample Date April 2012 Monthly Result Q2 2012 Sample Date Q2 2012 Result June 2012 Monthly Sample Date June 2012 Monthly Result Q3 2012 Sample Date Q3 2012 Result August 2012 Monthly Sample Date August 2012 Monthly Result September 2012 Monthly Sample Date September 2012 Monthly Result October 2012 Monthly Sample Date October 2012 Monthly- Result Q4 2012 Sample Date Q4 2012 Result December 2012 Monthly Sample Date December 2012 Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class 111) Thallium (ue/l) Sullale (mg/l.) Field pHIS.U.) TDS (mg/l.) 3198.77 2/27/2012 3230 N A 3.5/ 3280 N A 3.73 3220 11/26/2012 NS MW-19 (Class III) Field pH (S.U.) 6.78-8.3 NA 6.71 Nilrale + Nilrile (as N)(mg/I.) NS NS 5/16/2012 NS NS 2.83 3.9 3.7 3.96 MW-23 (Class III) Field pH (S.U.) Cadmium (ug/l.) Fluoride (mg/I.) MW-24 (Class III) Sullale ime/l ) 2903 NS 2/23/2012 NS NS Thallium (ug/I.) Field pH (S.U.) 6.03 6.21 Nilrale + Nilrile (a N) (mg/L) 6.4 6.2 6.7 NA MW-27 (Class III) Chloride (mg/I.) 44.2 Sullale (mg/l.) 11/13/2012 TDS (mg/I.) 1140 Gross Alpha minus Rn & V IpG/l.) 2.3 Chloride (ma/I.) 7/16/201. 8/1/2012 Cadmium (ua/I. MW-28 (Class III) Uranium (ua/I.) 11/14/2012 Vanadium (ue/I. Field pH (S.U.) 6.1 -8.5 6.22 7/16/2012 8/1/2012 6.38 5.98 TDS (mg/I.) 4600 8/1/2012 4420 MW-29 (Class III) Sullale (me/1.) 5/8/2012 Field pH (S.U.) 7.12 7/16/2012 8/1/2012 6.68 (6.45) NS Gross Alpha minus Rn & U (pCi/I.) 3.33 MW-32 (Class III) Chloride (mg/l.) 35.39 NS NS Field pH (S.U.) 6.4 - 8.5 Notes: GWCL values are laken from August 24. 2012 version of GWDP. NS = Nol Required and Not Sampled Fxeeedanees are shown in yellow Values in () parenlheses are Ihe Held pH measurements (or Ihe resampled analysi Table I - GWCL Exceedances for Second Quarter 21115 under Ihe Augusi 24 2012 CVVDP Ql 2013 Results Q2 2013 Results Q3 2013 Results Q4 2013 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24. 2012 GWDP January 2013 Monthly Sample Date January 2013 Monthly Result Ql 2013 Sample Date Ql 2013 Result March 2013 Monthly Sample Date March 2013 Monthly Result April 2013 Monthly- Sample Date April 2013 Monthly Result Q2 2013 Sample Date Q2 2013 Result June 2013 Monthly Sample Date June 2013 Monthly- Result Q3 2013 Sample Date Q3 2013 Result August 2013 Monthly Sample Date August 2013 Monthly Result September 2013 Monthly Sample Date September 2013 Monthly Result October 2013 Monthly Sample Date October 2013 Monthly Result Q4 2013 Sample Date Q4 2013 Result December 2013 Monthly Sample Date December 2013 Monthly Result Required Quarterly Sampling Wells MW-11 (Class 11) Manganese (ug/L) 2/20/2013 164 181 5/14/2013 144 6/25/2013 135 7/10/2013 158 134 10/22/2013 129 11/19/2013 MW-14 (Class 111) Field pH (S.U.) 6.48 6.52 3/20/2013 7/11/2013 6.48 6.77 11/20/2013 MW-25 (Class Field pH (S.U.) 6.32 6.74 6.62 Cadmium (ug/L) 1/22/2013 1.35 5/14/2013 1.52 10/22/2013 1.35 Uranium (ug/L) 6.5 7.13 Nitrate + Nilrile (as N) (mg/L) 0.62 1.66 1.73 2.01 3.042.11* 3.60 Uranium (ug/L) 65.7 57.8 64.3 71.3 70 58.8 Chloroform (ug/I.) 70 1340 1680 2110 4170 MW-26 (Class III) Chloride (mg/L) 58.31 1/24/2013 73.6 70.4 5/23/2013 63.1 6/5/2013 6/25/2013 87.8 77.9* 70.8 77.3 10/23/2013 Field pH (S.U.) 6.74 - 8.5 6.70 Diehloromethane (Methylene Chloride) (ug/L) 6.49 10.2 52.4* [12.11 42.4 29.8 Nilrate + Nitrite (as N) (mg/l.) 21.4 18.8 16.1 16.9 19.7 Chloride (mg/I.) 128 130 MW-30 (Class II) Uranium (ug/I.; 8.36 4/17/2013 5/15/2013 9/18/2013 Field pH (S.U.) 6.87 Ammonia (mg/L) Selenium (ug/L) 37.2 42.3 39 36.5 39.5 36.6 Nilrale + Nitrite (as N) (mg/I.) 22.8 19.3 23.8 20.0 21.7 21.2 23.9 TDS (mg/L) 1320 1270 1420 1510 1440 MW-31 (Class III) Chloride (mg/L) Selenium (ug/L) 1/22/2013 176 NS 81.8 72.9 5/1.3/2013 75.9 6/24/2013 179 188 174 73.7 73.2 72.6 74.5 Field pH (S.U.) 6.5 - 8.5 6.37 7.36 Sulfate (mg/l.) 611 644 630 659 666 637 Manganese (ug/L) 200 246 243 250 262 251 Thallium (ug/l) 0.505 MW-35 (Class II) Gross Alpha minus Rn & U(pCi/l.) 6.62 5.09 9.51 4/17/2013 5.70 3.92 8/19/2013 5.39 12/17/2013 Field pH (S.U.) 6.5 - 8.5 6.43 7.02 Selenium (ug/I.) 12.5 22.6 13.6 Uranium (ug/l.) 21.3 22.1 20.0 22.0 19.3 23.0 Required Semi-Annual Sampling Wells MW-01 (Class II) Telrahydrofuran (ug/L) Chloride (mg/I.) Field pH (S.U.) Sullale (mg/I.) 6.77 - 8.5 12.6 5/21/2013 3.26 839 NS NS Selenium (ue/L) 51.8 52.0 Field pH (S.U.; 6.20 6.46 MW-03 (Class Beryllium (ug/L) Cadmium (ug/L) NS <0.5 NS /ine ug/l ) 173.19 20.3 Sulfate (mg/I.) 3760 Nilrate + Nilrile (as N) (mg/I ] 0.73 Fluoride (Mg/I.) 0.902 1.18 1.28 Field pH (S.U.) 6.5 - 8.5 MW-03A (Class III) Sulfate (mg/L) 3640 3670 Nitrate + Nilrile (as N) (mg/I.) NS 1.22 5/23/2013 NS TDS (mg/l.) 6020 Selenium (ug/I.) Uranium (ug/I.) 7.5 36 7/18/2013 MW-12 (Class III) Selenium (ug/I.) 20.5 Field pH (S.U.) NS 7/17/2013 6.60 MW-15 (Class III) Selenium (ug/L) Field pH(S.U.) 5/15/2013 6.61 Ql 2013 Results Q2 2013 Results Q3 2013 Results Q4 2013 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2013 Monthly Sample Date January 2013 Monthly Result Ql 2013 Sample Date Ql 2013 Result March 2013 Monthly Sample Date March 2013 Monthly April 2013 Monthly Sample Date April 2013 Monthly Result Q2 2013 Sample Date Q2 2013 Result June 2013 Monthly Sample Date June 2013 Monthly Result Q3 2013 Sample Date Q3 2013 Result August 2013 Monthly Sample Date August 2013 Monthly Result September 2013 Monthly Sample Date September 2013 Monthly Result October 2013 Monthly Sample Date October 2013 Monthly Result Q4 2013 Sample Date Q4 2013 Result December 2013 Monthly Sample Date December 2013 Monthly Result Required Semi-Annual Sampling Weils, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/I.) Field pH (S.U.) TDS (mg/I.) 3198.77 3.26 NS NS NA 2.81 6.45 NS NS 2000 6.38 NS MW-19 (Class III) Field pH (S.U.) Nitrate + Nitrite (as N) (mg/L) 5/20/2013 2.83 4.21 3.70 MW-23 (Class III) Field pH (S.U.) 6.37 NS NS 6.6 I NS 12/18/2013 7.21 Cadmium (ug/I.) 6.72 MW-24 (Class III) Fluoride (mg/I.) 0.36 Sulfate (mg/I.) NS Thallium (ug/I.) 5/22/2013 0.618 Field pH (S.U.) 6.5-8.5 6.29 NS Nilrate + Nitrite (as N) (mg/l.) 7.94 7.09 MW-27 (Class III) Chloride (mg/I.) 38 44.2 45.0 Sulfate (mg/I.) 497 TDS (mg/L) 1140 1110 1100 Gross Alpha minus Rn & U (pCi/L) Chloride (mg/I.) 110 107 MW-28 (Class III) Cadmium (ug/I.) 5.2 Uranium (ug/I.) NS 7/17/2013 NS 12/4/2013 3.34 Vanadium (ug/L: 30 Field pH (S.U.) 6.63 TDS (mg/L) MW-29 (Class Sulfate (mg/L) 3/6/2013 NS 2750 Field pH (S.U.) 6.46 - 8.5 6.37 6.35 MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 3.33 3.72 Chloride (mg/I.) 35.39 2/19/2013 7/9/2013 Field pH (S.U.) 6.4 - 8.5 GWCL values are taken from Augusi 24. 2012 version of GWDP. NS = Not Required and Nol Sampled ills — ivcquiieu Kxceedanecs are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Tablr I - GYVCL Kxceedances for Second Quarter 2015 under the August 24. 2012 GWDP Ql 2014 Results Q2 2014 Results Q3 2014 Results 04 2014 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2014 Monthly Sample Date January 2014 Monthly Result February 2014 Monthly Sample Date February 2014 Monthly Result Ql 2014 Sample Date Q12014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly Sample Date May 2014 Monthly Result Q2 2014 Sample Date Q2 2014 Result July 2014 Monthly Sample Date July 2014 Monthly Result August 2014 Monthly Sample Date August 2014 Monthly Result Q3 2014 Sample Date Q3 2014 Result October 2014 Monthly Sample Date October 2014 Monthly Result Q4 2014 Sample Date Q4 2014 Result December 2014 Monthly Sample Date December 2014 Monthly Result Required Quarterly Sampling Wells MW-11 (Class Manganese (ug/I.; 141 136 128 6/3/2014 139 139 MW-14 (Class HI) Field pH(S.U.) 6.16 3/11/2014 5/13/2014 6/3/2014 6.25 MW-25 (Class III) Field pH (S.U.) 6.5 - 8.5 6.10 6.27 6.49 Cadmium (ug/I.) 1/7/2014 2/13/2014 1.29 1.51 1.30 9/3/2014 Uranium (ug/l.) Nitrate + Nitrite (as N) (mg/I.) 2.42 2.12 1.20 2.0 1.00 1.09 Uranium (ug/I.) 81.7 72.2 96.0 90.6 74.4 48.4 Chloroform (ug/L) 2800 2330 2200 1520 MW-26 (Class HI) Chloride (mg/I.) 1/8/2014 69.7 61.0 4/30/2014 62.1 8/20/2014 59.0 Field pH (S.U.) 12/10/14 12/15/14 6.74 - 8.5 6.80 6.50 7.19 6.60 7.28 6.09 Dichloromethane (Methylene Chloride) (ug/I.) 6.52 25.8 5.54 10.2 43.3 7.34 Nitrate + Nitrite (as N) (mg/L) 20.3 18.4 18.3 17.9 19.4 13.8 16.8 Chloride (mg/I.) 128 144 140 136 MW-30 (Class H) Uranium (ug/l. 9.82 7.70 4/23/2014 8/20/2014 11/10/2014 12/10/2014 Field pH (S.U.) 6.56 Ammonia (mg/I.) NA Selenium (ug/I.) 35.6 35.8 37.0 35.4 48.5 53.6 38.9 Nitrate + Nitrite (as N) (mg/L) 24.0 20.6 23.3 23.1 15.2 18.9 TDS (mg/I.) 1320 1490 1520 1400 1420 1520 MW-31 (Class III) Chloride (mg/L) Selenium (ug/L; 1/7/2014 194 197 77.2 85.4 5/13/2014 200 77.9 82.8 9/3/2014 210 78.9 73.0 12/9/2014 Field pH (S.U.) 6.5 - 8.5 7.13 6.45 7.45 6.69 Sulfate (mg/I.) 558 639 620 560 Manganese (ug/I.) 200 204 202 228 Thallium (ua/1) MW-35 (Class II) Ciross Alpha minus Rn t U (pCi/L) 3.75 4.12 3.98 4.33 3/11/14 7/29/2014 3.93 Field pH (S.U.) 6.5 - 8.5 6.07 6.32 Selenium (ug/l.) 12.5 14.1 13.9 13.2 31.4 Uranium (ug/I.; 20.6 26.9 23.9 Required Semi-Annual Sampling Wells MW-01 (Class II) Tetrahvdroluran (ug/l.) Chloride (mg/I.) Field pH (S.U.) Sulfate (mg/I.) 838 NS NA NS 11/17/2014 920 Selenium (ug/I.) 69.5 94.0 Field pH (S.U.) 6.23 6.13 MW-03 (Class III) Beryllium (ug/I.) NA Cadmium (ug/l.) 2/26/2014 NS Zine (ug/L) 173.19 Sulfate (mg/I.) 3663 Nitrate + Nitrite (as N) (mg/I.) 0.73 Fluoride (Mg/I.) 0.771 1.02 1.0 Field pH (S.U.) 6.5 - 8.5 6.40 6.41 MW-03A (Class Sulfalc (mg/L) 3640 377* Nitrate + Nitrite (as N) (mg/I.) NS NA NS TDS (mg/L) Selenium (ug/L) 129 MW-05 (Clasi II) Uranium (ug/L) 7.5 NS 2/12/2014 6/4/2014 2.42 MW-12 (Class Selenium (ug/L) Field pH (S.U.) NS 2/12/2014 6.13 7.10 6.47 MW-15 (Class 111) Selenium (ug/l.) Field pH (S.U.) NS 6.38 Ql 2014 Results Q2 2014 Results 03 2014 Results Q4 2014 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2014 Monthly Sample Date January 2014 Monthly Result February 2014 Monthly Sample Date February 2014 Monthly Result Ql2014 Sample Date Ql 2014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly Sample Date May 2014 Monthly Result Q2 2014 Sample Date Q2 2014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly Sample Date May 2014 Monthly- Result Q3 2014 Sample Date Q3 2014 Result October 2014 Monthly Sample Date October 2014 Monthly Result Q4 2014 Sample Date Q4 2014 Result December 2014 Monthly Sample Date Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/L) Held pH (S.U.) TDS (mg/L) 3198.77 2/19/2014 2.77 6.16 NA 2020 3260 NS NS 2.7 NS MW-19 (Class III) Held pH (S.U.) 6.78-8.5 6.29 6.46 Nilrate + Nitrite (as N) (mg/I.) NS NS 9/11/2014 2.83 3.82 NA MW-23 (Class Held pH (S.U.) 3/5/2014 NS Cadmium (ug/L) 5.92 2.91 MW-24 (Class III) Huoride (mg/L) 0.36 NA 0.4 Sulfate (mg/L) Thallium (ug/I.) 1.85 1.23 NS 9/17/2014 3120 Held pH (S.U.) 6.5 - 8.5 6.07 5.09 Nilrale + Nitrite (as N) (mg/I.) 7.35 6.30 MW-27 (Class III) Chloride (mg/I.) 47.0 42.6 Sulfate (mg/I.: 2/25/2014 484 TDS (mg/I.) 1090 Gross Alpha minus Rn & U (pCi/1.) NS Chloride (mg/L) 114 MW-28 (Class Cadmium (ug/L) 5.2 Uranium (ug/L) 2/26/2014 61.3 NS 10.6 21.2 Vanadium (ug/l.) 30 Held pH (S.U.) 6.1-8.5 6.01 5.79 TDS (mg/l.) MW-29 (Class III) Sullale (mg/L) NS 6/3/2014 NS Held pH (S.U.) 6.46 - 8.5 NA 6.11 MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 3.33 Chloride (mg/L) 35.39 NS 2/11/2014 NS Held pH (S.U.) 6.4 - 8.5 3.69 6.17 11/5/2014 6.08 NS GWCL values are taken from Augusi 24, 2012 version of GWDP. NS = Nol Required and Not Sampled NR = Required and Nol Reported NA = Nol Applicable Exceedances are shown in yellow Values in () parcnlhescs are the field pH measurements for the resampled analyses. Table I - GWCL Exceedances for Second Quarter 2015 under the August 24. 2012 GWDP Ql 2015 Results Monitoring WeU (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 201S Monthly Sample Date January 2015 Monthly Result Ql 2015 Sample Date Ql 2015 Result March 2015 Monthly Sample Date March 2015 Monthly Result Q2 2015 Sample Date Q2 2015 Result May 2015 Monthly Sample Date May 2015 Monthly Result June 2015 Monthly Sample Date June 2015 Monthly Result Sample Frequency MW-11 (Class II) Manganese (ug/L) Required Quarterly Sampling Wells 2/3/2015 138 3/3/201 149 Quarterly MW-14 (Class III) Field pH (S.U.) 6.49 6.44 4/8/2015 Quarterly Field pH (S.U.) <U2 6.52 MW-25 (Class III) Cadmium (ug/L) 1/20/2015 2/4/2015 6/1/2015 6/23/2015 6.59, 6.53 Quarterly 1.27 1.38 Uranium (ug/I.) 6.5 6.54 6.81 6/23/2015 Quarterly Quarterly Nitrale + Nitrite (as N) (mg/L) 2.68 Quarterly Uranium (ug/L) 78.1 72.6 Quarterly Chloroform (ug/l.) 70 3570 1160 2610 Quarterly MW-26 (Class III) Chloride (mg/I.) 58.31 1/21/2015 59.9 2/11/2015 77.2 5/12/2015 61.4 60.8 Quarterly Field pH (S.U.) 6.74 - 8.5 6.25 6.20 6.60 6.46 6/3/2015 6/24/2015 6.58, 6.20 Quarterly Diehloromc thane (Methylene Chloride) (ug/l.) 6.42 5.89 9.38 Quarterly Nilrate + Nitrite (as N) (mg/I.) 19.5 14.9 17.3 Quarterly Chloride (mg/L) 128 142 145 Quarterly Uranium (ug/I.) 8.32 MW-30 (Class I 5/12/2015 Quarterly Field pH (S.U.) 6.41 6.32 6.67 6/2/2015 6/24/2015 Quarterly Ammonia (mg/l.) 0.0824 Selenium (ug/l.) 37.2 40.9 38.0 37.3 6/24/2015 Quarterly Quarterly Nitrate + Nilrite (as N) (mg/l.) 20.9 18.7 19.8 Quarterly TDS (mg/L) 1320 1680 1700 1630 Quarterly MW-31 (Class III) Chloride (mg/L) 226 209 Quarterly Selenium (ug/l.) 75.7 71.6 74.4 Quarterly Field pH (S.U.) 6.5 - 8.5 6/1/2015 6/23/2015 Quarterly Sulfate (mg/L) 669 623 691 Quarterly Manganese (ug/L) 237 207.0 Quarterly Thallium (ug/l) Quarlerly MW-35 (Class II) Gross Alpha minus Rn & U (pCi/I.) 6.86 5.61 3.81 4.25 4/9/2015 5/12/2015 Quarlerly Field pH (S.U.) 6.26 6.46 6/2/2015 6/23/2015 6.50, 6.41 Quarterly Selenium (ug/l.) 14.2 26.6 Jraniutn (ug/L) 21.8 20.6 24.4 6/23/2015 Quarterly Quarterl) Required Semi-Annual Sampling Wells MW-01 (Class II) Telrahydrofuran (ug/l.) Chloride (mg/l.) Field pH (S.U.) Sulfate (mg/L) 22.1 838 1.63 NS Semi-Annually Scmi-Annually Semi-Annually Semi-Annually Selenium (ug/l.) 61.1 4/23/2015 5/20/2015 81, 61.7 Semi-Annually Field pHIS.U.) 6.5 - 8.5 6.12 4/23/2015 4/29/2015 5/20/2015 6.18, 6.51, 6.23 Semi-Annually MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/I.) 4.67 2/11/2015 Zine (ug/I.) 4/23/2015 5/20/2015 1.44, 2.08 Semi-Annually 5.03,14.2 Semi-Annually 238, 373 Semi-Annually Sulfate (mg/L.) 3700 Semi-Annually Nitrale + Nitrite (as N) (mg/l.) Semi-Annually Fluoride (mg/L) 1.08 1.00 Semi-Annually Field pH (S.U.) 4/23/2015 4/29/2015 Semi-Annually MW-03A (Class III) Sulfalc (mg/I.) 3720 Semi-Annually Nitrale + Nitrite (as N) (mg/L) NS Semi-Annually TDS (mg/L) 5805 Semi-Annually Selenium (ug/L) 94.1 Semi-Annually MW-05 (Class II) Uranium (ug/I.) 2/10/2015 NS 4/21/2015 Semi-Annually Selenium (ug/L) 30.0 29.4 Semi-Annually MW-12 (Class III) Field pH (S.U.) 6.5 - 8.5 2/9/2015 6.33 4/21/201 4/28/201 NS Semi-Annually MW-15(ClassI Selenium (ug/L) 128.7 Field pH (S.U.) 6.62 - 8.5 2/4/2015 Semi-Annually 6.50 Semi-Annually Ql 2015 Results Q2 2015 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2015 Monthly Sample Date January 2015 Monthly Result Ql 2015 Sample Date Ql2015 Result March 2015 Monthly- Sample Date March 2015 Monthly Result Q2 2015 Sample Date Q2 2015 Result May 2015 Monthly- Sample Date May 2015 Monthly Result June 2015 Monthly Sample Date June 2015 Monthly Result Sample Frequency Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ue/l) Sulfate (mg/L) Field pH (S.U.) TDS (mg/L) 3198.77 6.27 3240 NS NA NS Semi-Annually Semi-Annually Semi-Annually Semi-Annually MW-19 (Class in) Field pH (S.U.) 6.78-8.5 6.45 Nitrate + Nitrite (as N) (mg/L) NS 2.83 NS Semi-Annually Semi-Annually MW-23 (Class III) Field pH (S.U.) NS Semi-Annually Cadmium (ug/L) 3.31 Fluoride (mg/L) 0.36 MW-24 (Class III) Sulfate (mg/I.) Thallium (ug/I.) NS Field pH (S.U.) 6.5 - 8.5 5/28/2015 6/24/2015 5.39, 5.98 NS Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually Nitrate + Nitrite (as N) (mg/I.) 15.27 MW-27 (Class III) Chloride (mg/L) 44.2 47.6 Sulfate (mg/L) 2/9/2015 NS TDS (mg/L) Gross Alpha minus Rn & U (pCi/L) NA Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually Chloride (mg/L) 130 125 Cadmium (ug/I.) 5.2 4/21/2015 MW-28 (Class III) Uranium (ug/L) 2/9/2015 6.13 NS Vanadium (ug/L) 30 Field pH (S.U.) 5.86 4/21/2015 4/27/2015 6.08, 6.17 Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually TDS (mg/L) 4400 MW-29 (Class III) Sulfate (mg/L) 4/30/2015 2960 Field pH (S.U.) 6.42 6.36 Semi-Annually Semi-Annually Semi-Annually Gross Alpha minus Rn & U (pCi/L) 3.33 MW-32 (Class III) Chloride (mg/I.) 35.39 NS NS Field pH (S.U.) 6.4 - 8.5 2/9/2015 Semi-Annually Semi-Annually Semi-Annually Notes: GWCL values are taken from August 24, 2012 version of GWDP. NS = Nol Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Kxceedanccs are shown in yellow Values in () parenlheses are Ihe field pH measuremenls for ihe resampled analyses.