Loading...
HomeMy WebLinkAboutDRC-2015-008346 - 0901a068805b1fadENERGYFUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com November 18, 2015 Div of Waste Management and Radiation Control Scott Anderson, VIA PDF AND OVERNIGHT DELIVERY NOV 2 0 2015 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 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 third quarter ("Q3") groundwater monitoring during the period from July 1, to September 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 October 28, 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 Q3 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 November 18,2015 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. EFRI'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 EFRI's 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 arid 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 Schedules submitted May 19, and September 10, 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 November 18, 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 Q3 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, March 19, 2014 and the Plan and Time Schedules submitted May 19, and September 10, 2015. MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in all of the Q3 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 all of the Q3 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 Q3 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 Q3 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, Letter to Mr. Scott Anderson November 18,2015 Page 4 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 in the Q3 2015 (August) and September monthly 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 Q3 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. • Methylene chloride has exceeded its GWCL in the June monthly and July monthly sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of methylene chloride. 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-30 • Nitrate + nitrite has exceeded its GWCL in all of the Q3 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 Q3 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 Q3 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. Letter to Mr. Scott Anderson November 18,2015 Page 5 MW-3] • Nitrate + nitrite has exceeded its GWCL in all of the Q3 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 Q3 2015. 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 sulfate concentration exceeded its GWCL in all of the monitoring periods for Q3 2015. This consecutive exceedance is addressed in the SAR, dated October 10, 2012 and in the Plan and Time Schedule submitted May 19, 2015. As a result a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. • The selenium concentration exceeded its GWCL in all of the monitoring periods for Q3 2015. This consecutive exceedance is addressed in the SAR, dated August 20, 2013 in the Plan and Time Schedule submitted May 19, 2015. As a result a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. • The Total Dissolved Solids ("TDS") exceeded its GWCL in all of the monitoring periods for Q3 2015. This consecutive exceedance is addressed in the SAR, dated August 20, 2013 in the Plan and Time Schedule submitted May 19, 2015. As a result a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. MW-35 • The uranium concentration exceeded the GWCL in MW-35 in all of the Q3 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 gross alpha minus Rn and U ("gross alpha") concentration exceeded the GWCL in MW-35 in the June and July 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 Letter to Mr. Scott Anderson November 18, 2015 Page 6 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 Q3 2015 (August) and September 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. • The selenium concentration exceeded the GWCL in MW-35 in all of the Q3 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 DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC 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 DRC'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 Q3 One new single exceedance for the Q3 2015 quarterly well sampling program is listed below. These exceedances will result in an accelerated sampling frequency from quarterly to monthly. It is important to note that the well listed below will only be sampled monthly for the constituents which exceeded their GWCL. The well listed below will be sampled for all constituents listed in the GWDP during the quarterly events as that is the regularly scheduled sampling for the well. • Chloride in MW-25 was above the GWCL in the Q3 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, Letter to Mr. Scott Anderson November 18, 2015 Page 7 EFRI proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DWMRC concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 teleconference. 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 (Q2 2015 and Q3 2015). MW-1 • Sulfate has exceeded the GWCL for both the Q2 2015 sampling event and the Q3 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-3 • Fluoride has exceeded the GWCL for both the Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 November 18, 2015 Page 8 • Sulfate has exceeded the GWCL for both of the samples the Q2 2015 sampling event and the Q3 2015 sampling event. This is the first consecutive exceedance for sulfate 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 Q2 2015 sampling event and the Q3 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. • Sulfate has exceeded the GWCL for both the Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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-24 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q2 2015 sampling event and the Q3 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 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 November 18,2015 Page 9 MW-27 • The nitrate+nitrite concentration exceeded its GWCL for both the Q2 2015 sampling event and the Q3 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. • The chloride concentration exceeded its GWCL for both the Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 Q2 2015 sampling event and the Q3 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 Letter to Mr. Scott Anderson November 18,2015 Page 10 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. • Chloride has exceeded the GWCL for both the Q2 2015 sampling event and the Q3 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 Q3 No new exceedances for the semi-annual wells were noted during Q3 2015. Yours truly, » ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund Harold Roberts David Turk Logan Shumway Scott Bakken Table 1 - GWCL Exceedances for Third Quarter 2015 under the August 24. 2012 GWDP Ql 2010 Results Q2 2010 Results Q3 2010 Results Ql 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 Required Quarterly Sampling Wells MW-11 (Class I Manganese (ug/L) 4/28/2010 137 5/24/2010 99 7/20/2010 123 MW-14 (Class III) Field pH (S.U.) 2/2/2010 6.29 6.36 7/20/2010 7.19 9/8/2010 10/20/2010 12/15/2010 Field pH (S.U.) 6.5 - 8.5 6.36 MW-25 (Class HI) Chloride (mg/L) 2/3/2010 NS 9/8/2010 NS NS Cadmium (ug/L) 1.26 Uranium (ug/L) 6.5 6.43 6.57 Nilrale + Nitrite (as N) (mg/L) Uranium (ug/L) JS.7 34.4 72.7 30.4 Chloroform (ug/L) 1700 940 1000 MW-26 (Class III) Chloride (mg/L) 8/16/2010 Field pH (S.U.) Dichloromethane (Methylene Chloride) (ug/L) 9.9 Nitrate + Nitrite (as N) (mg/l.) 15.8 Chloride (mg/L) Uranium (ug/L) NS MW-30 (Class I 4/27/2010 6/15/2010 Field pH (S.U.) 6.5 - 8.5 7/21/2010 7/27/2010 6.80 (6.82) 8/24/2010 9/14/2010 9/21/2010 6.80 (6.84) Ammonia (mg/L) 0.14 NA NS Selenium (ug/L) 7/27/2010 8/24/2010 35.6 Nitrate + Nitrite (as N) (mg/L) 6/15/2010 21.1 20 20 20 TPS (mg/L) NS 1330 MW-31 (Class III) Chloride (mg/L) Selenium (ug/L) 2/9/2010 NS NS 9/13/2010 (9/21/10) 11/9/2010 Field pH (S.U.) 7.80 7.66 (7.13) Sulfate (mg/l.) NS NS Manganese (ug/L) 698 Thallium (ug/l) 1.14 MW-35 (Class II) Gross Alpha minus Rn & It (pCj/L) 3.75 NS Field pH (S.U.) 6.5 - 8.5 Selenium (ug/L) Uranium (ug/L) NA Required Semi-Annual Sampling Wells MW-01 (Class II) Tetrahydrofuran (ug/L) Chloride (mg/L) Field pHIS.U.) Sulfate (mg/L) NS 7.86 (6.87) NA NS Selenium (ug/L) 37.2 Field pH(S.U.) 6.5 - 8.5 6.14 (6.25) 6.39 6.35 MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/I.) NS NS Zinc (ug/L) Sulfate (mg/L) 3490 Nitrate + Nitrite (as N) (mg/L) Fluoride (Mg/L) Field pH (S.U.) 6.23 (6.24) 6.42 6.21 MW-3A (Class III) Sulfate (mg/L) Nitrate + Nitrite (as N) (mg/L) 1.3 5/4/2010 TDS (mg/L) 5860 Selenium (ug/L) 94.8 MW-05 (Class II) Uranium (ug/I.) 7.5 NS NS 11.6 Selenium (ug/L) MW-12 (Class III) Field pH (S.U.) 7.16 NS NS MW-15 (Class III) Selenium (ue/L) Field pH(S.U.) NS 11/11/2010 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 Q2 Result May Monthly Sample Date May Monthly Result June Monthly Sample Date 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 Result Q4 Sample Date Q4 Result December Monthly Sample Date December Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/I.) Field pH (S.U.) NS 1950 6.2 NS 3.64 6.37 3030 MW-19 (Class III) Field pH(S.U.) 6.61 (6.66) 6.8 Nitrate + Nitrite (as N) (mg/L) NS 9/15/2010 NS MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 NS NS Cadmium (ug/L) Fluoride (mg/L) MW-24 (Class III) Sulfate (mg/L) 5/6/2010 NS 11/17/2010 Thallium (ug/L) 1.3 1.09 Field pH (S.U.) 6.5 - 8.5 5.91 (5.7S) Nitrate + Nitrite (as N) (mg/I.) MW-27 (Class III) Chloride (mg/I-) NA 45 Sulfate img/I. 1 TPS (mg/I,) 1160 1110 Gross Alpha minus Rn &. U(pCi/L) Chloride (mg/L) 108 NA 106 107 Cadmium (ug/I.) MW-28 (Class III) Uranium (ug/I.) 4/19/2010 Vanadium (ug/L) 30 Field pH (S.U.) TPS (mg/I.) NA MW-29 (Class III) Sulfate (mg/I.) 2946 4/27/2010 NS Field pH (S.U.) 6.82 NA 6.17 Gross Alpha minus Rn & U (pCi/L) 3.33 MW-32 (Class III) Chloride (mg/L) NS Field pH(S.U.) 6.4 - 8.5 Notes: GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled ills — iscquiicu diiu F.xceedances are shown in yellow Values in () parentheses are (he field pH measurements for the resampled analyses. Table 1 - GWCL Kxceedances for Third Quarter 2015 under the August 24, 21112 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 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 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 December 2011 Monthly- Result Required Quarterly Sampling Wells MW-11 (Class ID Manganese (ug/L) 148 170 6/15/2011 9/7/2011 106 MW-14 (Class 111) Field pH (S.U.) 7/5/2011 6.23 (6.41) 9/8/2011 6.71 (6.82) Field pH (S.U.) 6.5 - 8.5 6.44 6.79 6.1 5.77 8/3/2011 8/30/11 6.42 (6.54) MW-25 (Class III) Chloride (mg/L) 2/2/2011 6/20/201 1 7/6/2011 8/3/2011 NA 10/4/2011 12/12/2011 Cadmium (ug/L) 8/30/2012 1.19 Uranium (ug/L) 6.5 7.02 6.72 7.06 6.74 Nitrate + Nitrite (as N) (mg/L) 2.4 Uranium (ug/L) 32 Chloroform (ug/I.) 70 800 730 1200 390 1900 1300 440 1200 MW-26 (Class III) Chloride (mg/l.) 58.31 1/12/201 64 8/3/2011 8/30/11 66 61 Field pH (S.U.) 6.06 6.22 6.43 6.07 (6.58) Dichloromethane (Methylene Chloride) (ug/I..) 2.4 Nitrate + Nitrite (as N) (mg/L) 16 Chloride (mg/L) MW-30 (Class II) Uranium (ug/L) 3/14/201 Field pH (S.U.) 5.66 10/4/2011 11/29/2011 6.96 (6.73 Ammonia (mg/L) Selenium (ug/L) 38.3 38.7 39.7 36.6 36.8 38 Nitrate + Nitrite (as N) (mg/L) 22 20 TDS (mg/I.) MW-31 (Class III) Chloride (mg/L) Selenium (ug/L) 2/1/2011 6/20/201 1 145 NS 7/5/201 NS 8/2/2011 148 10/3/2011 145 11/8/2011 (11/29/12) Field pH (S.U.) 7.01 (7.34) Sulfate (mg/L) 538 532 1330 NS Manganese (ue/L) 348 270 283 Thallium (ua/1) 0.57 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/I.) 4.5 Field pH (S.U.) 6.49 Selenium (ug/L) NA Uranium (ug/L) NA NA 24.2 18.3 24 0.63 4.2 Required Semi-Annual Sampling Wells MW-01 (Class II) Telrahydrofuran (ug/I.) Chloride (mg/I.) Field pH (S.U.) Sulfate (mg/l.) 4/11/2011 18 NA NA NS 7.08 (7.51) NS NS Selenium (ug/I.) 40.5 Field pH (S.U.) 6.32 6.53 (6.83) MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/L) NS 4/13/2011 1.26 NS Zinc (ug/L) Sulfate (mg/L! 3663 Nitrate + Nitrite (as N) (mg/I.) 0.3 Fluoride (Mg/I.) 0.69 Field pH (S.U.) 6.19 6.5 (6.92) MW-03A (Class III) Sulfate (mg/I.) 3640 3730 3750 Nitrate + Nitrite (as N) (mg/L) TDS (mg/L) 5810 Selenium (ug/L) 95 MW-05 (Class II) Uranium (ug/L) NS NS 10/10/2011 MW-12 (Class III) Selenium (us>/L) 39.0 Field pH (S.U.) 6.43 NS 4/5/2011 MW-15 (Class III) Selenium (uii/L; 128.7 Field pH (S.U.) NS NS 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 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 December 2011 Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ua/1) Sulfate (mg/L) Field pH (S.U.) TDS (mg/l.) 1770 6.27 4/6/2011 NS NA NS NA 8/10/2011 9/21/11 5.95 (6.30) 10/11/2011 6.55 (6.63) NS NS MW-19 (Class III) Field pH (S.U.) NA 6.88 (7.02) Nitrate + Nitrite (as N) (mg/I.) NS NS NA MW-23 (Class III) Field pH (S.U.) 6.56 (6.77) Cadmium (ug/I.) 2.78 2.61 MW-24 (Class III) Fluoride (mg/L) 0.36 NA 0.36 Sulfate (mg/L) 8/4/2011 NS Thallium (ug/I.) Field pH (S.U.) 6.5 - 8.5 5.73 6.12 Nitrate + Nitrite (as N) (mg/I.) 6.3 MW-27 (Class III) Chloride (mg/I.) 46 Sulfate (mg/L) TDS (mg/L) 1090 Gross Alpha minus Rn &U(pCi/L) Chloride (mg/L) MW-28 (Class III) Cadmium (ug/L) 5.2 Uranium (ug/L) 8/8/2011 Vanadium (ug/L) Field pH (S.U.) 5.69 6.01 ((.07(6.11) TDS (mg/L) MW-29 (Class HI) Sulfate (mg/L) 2946 NS Field pH (S.U.) MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 3.33 Chloride (mg/L) 2/9/2011 NS 4/1/201 8/2/2011 8/30/11 Field pH (S.U.) 6.4 - 8.5 6.10 (6-20) 6.35 Notes: GWCL values are taken from August 24. version of GWDP. NS = Not Required and Not Sampled 2012 Exceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for Third Quarter 2015 under the 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 December 2012 Monthly- Result Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 131.29 1/26/2012 4/10/2012 132 5/8/2012 127 135 10/23/2012 12/24/2012 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 6.36 7/11/2012 8/7/2012 9/18/2012 10/23/2012 6.52 Field pH (S.U.) 6.55 6.58 MW-25 (Class III) Chloride (mg/L) 1/25/2012 7/10/2012 8/6/2012 9/18/2012 10/22/2012 Cadmium (ug/L) Uranium (ug/L) 6.72 6.61 Nitrate + Nitrite (as N) (mg/L) 0.62 3.4 7/11/201 Uranium (ug/I.) 59.4 Chloroform (ug/I.) MW-26 (Class III) Chloride (mg/L) 2/15/2012 2900 2900 1700 2400 970 2200 4720 74 82 Field pH (S.U.) 2/LV2UI2 2/21/2012 won 6.72 (6.91) (6.71) 5/7/2012 6/26/2012 6/19/2012 85 78 8/8/201 78 9/19/201 6.39 7.00(7.01) 7/11/2012 8/16/2012 7.10 (6.80) Dichloromelhane (Methylene Chloride) (ug/L) 2/15/2012 24 27 20 Nitrate + Nitrite (as N) (mg/L) 2.5 18 16 Chloride (mg/L) 128 131 139 130 135 Uranium (ug/L) 8.38 7.03 MW-30 (Class II) 2/14/2012 3/14/2012 4/10/2012 5/2/2012 6/18/2012 7/10/2012 Field pH (S.U.) 6.86 Ammonia (mg/l.) NS Selenium (ug/L) 38.5 38.4 36 Nitrate + Nitrite (as N) (mg/L) 21 20 21.6 TDS (mg/I.) 1360 1400 1320 MW-31 (Class III) Chloride (mg/L) Selenium (ug/L) 1/24/2012 2VS 6/18/2012 6/29/2012 7/9/2012 161 175 10/22/2012 157 11/6/2012 189 12/18/2012 Field pH (S.U.) 7.28 (7.63) Sulfate (mg/L) 547 1270 170 Manganese (ue/L) 253 304 272 273 283 253 241 Thallium (ug/l) 0.65 0.71 0.61 0.54 0.517 0.554 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 6.2 4.23 1/24/2012 10/23/201 11/13/2012 12/18/2012 Field pH (S.U.) 6.35 6.48 6.43 Selenium (ug/L) 19.7 Uranium (ug/L) 24.9 22.2 240 Required Semi-Annual Sampling Wells felrahydrofuran (ug/L MW-01 (Class Ii) Chloride (mg/L) Field pH (S.U.) Sulfate [mg/L) NA 10.3 NS 11/27/2012 846 Selenium (ug/L) Field pH (S.U.) MW-03 (Class III) Beryllium (ug/I.; Cadmium ( ui>/L) NS /.inc (ug/L) Sulfate (mg/I.) Nitrate + Nilrile (as N) (mg/L) 0.73 Fluoride (Mg/I.) 1.04 0.96 1.26 Field pH (S.U.) 6.5 - 8.5 MW-03A (Class III) Sulfate (mg/I.) 3700 Nitrate + Nitrite (as N) (mg/L) 1.3 NS 11/29/2012 NS TDS (mg/L) 5730 Selenium (ug/I.) MW-05 (Class II) Uranium (ug/L) 2/28/2012 18.6 11/27/201 NS Selenium (us/L) MW-12 (Class III) Field pH (S.U.) NS NS NS MW-15 (Class III) Selenium (ue/1.) Field pH (S.U.) 2/22/2012 152 11/14/2012 NS Ql 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results Monitoring Well (Water Class) Constituent Exceeding G WCL GWCL in Current GWDP January 2012 Monthly Sample Date January 2012 Monthly Result 01 2012 Sample Date 01 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 III) Thallium (ug/l) Sulfate (mg/I.) Field pH (S.U.) TDS (mg/I.) 6.25-8.5 3.63 3230 NA 3.5/ 3280 3.2 MW-19 (Class I Field pH (S.U.) 6.71 Nitrate + Nitrite (as N)(mg/1.) NS 5/16/2012 3.9 3.7 3.96 MW-23 (Class III) Field pH (S.U.) NS NA 5/16/201; Cadmium (ug/L) NA 2.01 Fluoride (mg/I.) 0.36 MW-24 (Class III) Sulfate (mg/I.) Thallium (ue/L) NS 2490 NS 7/18/2012 1.36 Field pH (S.U.) 6.5 - 8.5 6.45 NA NS Nitrate + Nitrite (as N) (mg/L) 6.7 MW-27 (Class III) Chloride (mg/I.) 45 46 44.2 Sulfate (mg/L) TDS (mg/I.) 1170 Gross Alpha minus Rn&U(pCi/I.) Chloride (mg/I.) 109 114 7/16/2012 8/1/2012 115 Cadmium (ug/I.) MW-28 (Class III) Uranium (ug/L) Vanadium (ug/I.) Field pH (S.U.) 7/16/2012 8/1/2012 6.38 5.98 TDS (mg/I.) 4600 8/1/2012 4430 MW-29 (Class III) Sulfate (mg/I.) NS Field pH (S.U. 7/16/2012 8/1/2012 6.68 (6.45) NA NA Gross Alpha minus Rn & U (pCi/I.) 3.33 2.97 MW-32 (Class III) Chloride (mg/I.) 35.39 2/21/2012 NS 4/30/2012 Field pFHS.U.) 6.4 - 8.5 —Notes: GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled ills — iscquneu ano Fxeeedances are shown in yellow Values in Q parentheses are the Held pH measurements for the resampled analyses Table 1 - GWCL Exceedances for Third Quarter 2015 under the August 24. 2012 GWDP 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) 164 5/14/2013 144 6/25/2013 9/18/2013 11/19/2013 196 MW-14 (Class III) Field pH (S.U.) 6.48 2/26/2013 6.48 4/16/2013 9/19/2013 6.74 Field pH (S.U.) 6.65 6.41 MW-25 (Class III) Chloride (mg/L) 2/20/2013 3/19/2013 4/17/2013 28.1 28 9/17/2013 29.6 Cadmium (ug/L) 1.35 Uranium (ug/L) 6.5 5.68 6.73 31.2 1.23 Nilratc + Nitrite (as N) (mg/L) 1.66 1.61 Uranium (ug/L) 64.3 70 75.8 Chloroform (ug/I.) 1270 1500 1340 MW-26 (Class III) Chloride (mg/I.) 1/24/2013 3/20/2013 73.6 70.4 5/23/2013 6/5/2013 6/25/2013 70.8 63.8 Field pH (S.U.) 6.51 6.70 Dichtoromethane (Methylene Chloride) (ug/L) 6.49 8.31 52.4* [12.1] 2.56 70.4 6.93 7.48 Nitrate + Nitrite (as N) (mg/L) 19.2 14.3 Chloride (mg/L) 128 MW-30 (Class II) Uranium (ug/I.) 6.91 8.57 1/23/2013 Field pH (S.U.) 6.5 - 8.5 Ammonia (mg/L) <0.05 Selenium (ug/L) 42.3 37.3 39.4 36.3 20.7 35.1 Nitrate + Nitrite (as N) (mg/L) 19.3 18.8 20.0 TPS (mg/l.: 1320 1540 1510 1500 MW-31 (Class III) Chloride (mg/I.) Selenium (ug/L) 2/19/2013 4/16/2013 75.9 7/9/2013 75.7 72.6 11/18/2013 74.5 Field pH (S.U.) 6.5 - 8.5 6.37 7.92 Sulfate (mg/L) 611 611 1500 203 Manganese (ug/L) 272 243 252 243 262 240 Thallium (ug/l) 0.7/5 0.946 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/I.) 4.92 5.70 3.92 5.10 5.39 11/19/2013 12/17/2013 Field pH (S.U.) Selenium (ug/L) Uranium (ug/L) 23.6 22.0 23.0 20.2 24.1 260 Required Semi-Annuai Sampling Wells MW-01 (Class II) Tetrafiydrofuran (ug/L) Chloride (mg/L) Field pH (S.U.) Sulfate (mg/L) 6.77 - 8.5 838 3/12/2013 NS 3.26 839 7/23/2013 NS 12/4/2013 Selenium (ug/I.) 52.0 Field pH (S.U.) 7.14 MW-03 (Class III) Beryllium (ug/I.) Cadmium (ug/L) 4.67 NS 3/12/2013 NS /inc (ug/I.) Sulfate (mg/I.) 3663 Nitrate + Nitrite (as N) (mg/L) 0.456 1.21 Fluoride (Mg/L) 0.902 0.994 Field pH (S.U.) MW-03A (Class III) Sulfate (mg/I.) Nitrate + Nitrite (as N) (mg/L) NS NS NS 12/11/2013 1.52 5860 5940 Selenium (ug/I.) MW-05 (Class II) Uranium (ug/L) 3/11/2013 5/14/2013 12/4/2013 20.1 MW-12 (Class III) Selenium (ug/L) Field pH (S.U.) 6.5 - 8.5 NS 3/6/2013 NS MW-15 (Clasi Ill) Selenium (ug/I.) Field pH(S.U.) 6.62 - 8.5 7/18/2013 6.68 NS NS 1/20/2013 NS 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 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 Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/I) Sulfate (mg/L; Field pH (S.U.) TDS (mg/L) NS NA 2.81 I860 3170 3.06 2000 3240 MW-19 (Class III) Field pH (S.U.) 6.91 6.58 7/15/2013 NS NS NS Nitrate + Nitrite (as N) (mg/L) 3.66 3.70 MW-23 (Class III) Field pH (S.U.) 6.37 7/18/2013 NS NS NS Cadmium (ua/L) MW-24 (Class III) Fluoride (mg/L) Sulfate (mg/I.) 3/13/2013 5/22/2013 NS Thallium (ug/L) 1.64 Field pH (S.U.) 6.5 - 8.5 6.29 Nitrate + Nitrite (as N) (mg/I.) 7.94 7.09 MW-27 (Class III) Chloride (mg/l.) 44.2 45.0 Sulfate (mg/I.) 462 TDS (mg/L) 1110 1100 Gross Alpha minus Rn & U (pC\l\.) NA NA NA Chloride (mg/L) 109 MW-28 (Class III) Cadmium (ug/I.) Uranium (ug/L) 3.58 Vanadium (ug/I.) Field pH (S.U.) 6.00 TDS (mg/L) MW-29 (Class III) Sulfate (mg/I.) 5/23/2013 Field pH (S.U.) 6.35 MW-32 (Class III) Gross Alpha minus Rn & U (pOll.) 3.33 5.02 3.72 Chloride (mg/L) 35.39 NS 2/19/2013 NS NS NS 11/18/2013 Field pH (S.U.) 6.4-8.5 Notes: GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled INIV — ixcquueu Exceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for Third Quarter 2015 under Che August 24, 2012 GWDP Ql 2014 Results Q2 2014 Results Q3 2014 Results Q4 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 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 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 (Clas: 11) Manganese (ug/I.) 131.29 2/24/2014 163 134 5/14/2014 128 6/3/2014 166 9/8/2014 10/6/2014 125 12/10/2014 MW-14 (Class 111) Field pH (S.U.) 6.5 - 8.5 6.16 5/13/2014 6/3/2014 8/20/2014 6.41 6.46 6.25 6.40 Field pH (S.U.) 6.10 6.27 6.49 MW-25 (Class III) Chloride (mg/I.) 4/28/2014 5/13/2014 26.4 6/2/2014 7/28/2014 8/18/2014 30 Cadmium (ug/I.) 1.5 1.30 1.30 Uranium (ug/L) 6.26 10.6 7.43 Nitrate + Nitrite (as N) (mg/I.) 1.10 0.704 Uranium (ug/L) SI.7 90.6 74.4 48.4 66.0 Chloroform (ug/L) 2800 894 MW-26 (Class HI) Chloride (mg/L) 58.31 70.4 3/12/2014 61.0 62.1 6/5/2014 63.2 57.7 12/10/14 12/15/14 Field pH (S.U.) 6.50 Dichloromethane (Methylene Chloride) (ug/L) 6.52 25.8 43.3 10.9 7.34 42.5 6.25 (6.44) 28.4 Nitrate + Nitrite (as N) (mg/L) 20.3 18.4 13.8 16.8 11.0 16.2 Chloride (mg/L) 135 144 MW-30 (Class II) Uranium (ug/L) 9.82 7.35 2/25/2014 9/9/2014 10/7/2014 12/10/2014 Field pH (S.U.) Ammonia (mg/I.) Selenium (uit/L) 37.0 35.4 42.9 Nitrate + Nitrite (as N) (mg/L) 26.2 19.1 23.1 15.9 TDS (mg/L) 1510 1440 1510 1400 1410 1520 MW-31 (Class III) Chloride (mg/L) 230 Selenium (ug/L) 74.5 6/2/2014 7/28/2014 210 205 77.9 82.8 73.0 Field pH (S.U.) Sulfate (mg/L) 558 639 620 560 606 687 Manganese (ug/L) 204 202 Thallium (ug/l) 0.582 MW-35 (Class II) Gross Alpha minus Rn & U(pCi/L) 4.12 2.95 4.70 3.92 7/29/2014 Field pH (S.U.) 6.32 Selenium (ug/L) 17.0 13.2 28.9 Uranium (ua/L) 20.6 20.6 26.9 20.3 19.6 4.54 20.3 Required Semi-Annual Sampling Wells MW-01 (Class Tetrahydrofuran (ug/L) Chloride (ma/I.) Field pH (S.U.) Sulfate (mg/I.) 22.1 NS NA 5/28/2014 Selenium (ug/I.) 94.0 62.4 Field pH (S.U.) MW-03 (Class III) Beryllium (ug/L) Cadmium (ug/I.) 2/26/2014 NS Zinc (ug/I.) Sulfate (mg/L) 3663 NA Nitrate + Nitrite (as N) (mg/I.) 0.573 Fluoride (Mg/l.) 0.77/ 1.0 Field pH (S.U.) 6.41 MW-03A (Class III) Sulfate (mg/I.) 3640 Ni[ra(e + Nitrite (as N) (mg/I.) TDS (mg/I.) Selenium (ug/L) 104 MW-05 (Class m Uranium (ug/L) MW-12 (Class III) Selenium (ug/L) Field pH (S.U.) 6.5 - 8.5 2/12/2014 NS 9/16/2014 6.47 6.25 MW-15 (Clas: III) Selenium (ug/L: Field pHlS.U.) 6.62 - 8.5 NS 6/4/2014 273 6.38 6.41 Ql 2014 Results Q2 2014 Results Q3 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 Ql 2014 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 (ue/1) Sulfate (mg/L) Field pH (S.U.) TDS (mg/I,) NS 3080 NS NS NA 3260 6.10 MW-19 (Class III) Field pH (S.U.) 6.33 Nitrate + Nitrite (as N) (mg/l,) 5/27/2014 NS NS 9/11/2014 11/11/2014 3.68 2.91 MW-23 (Class HI) Field pH (S.U.) NS 6/11/2014 6.67 NS NS 9/4/2014 NS 11/19/2014 NS Cadmium (ug/L) 2.91 MW-24 (Class Fluoride (mg/L) 0.36 0.4 Sulfate (mg/L) 3120 Thallium (ug/I.) Field pH (S.U.) 5.89 NS Nitrate + Nitrite (as N) (mg/L) 7.98 MW-27 (Class III) Chloride (mg/I,) 45.9 46.0 42.6 Sulfate (mg/l,) 462 5/28/2014 NS 9/8/2014 TDS (mg/L) 1090 Gross Alpha minus Rn & U(pCi/L) NA NS Chloride (mg/I,) 112 MW-28 (Class III) Cadmium (ug/L) 5.2 NA Uranium (ug/L) 10.6 21.2 Vanadium (ug/L) 29.3 Field pH (S.U.) TDS (mg/L) MW-29 (Class III) Sulfate (mg/I,) Field pH (S.U.) 6.10 6.11 NS MW-32 (Class III) Gross Alpha minus Rn t U (pCi/L) 9/2/2014 3.69 Chloride (mg/L) 35.39 5/23/2014 NS Field pH (S.U.) 6.15 8/26/2014 9/2/2014 6.17 Notes: GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Hxceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for Third Quarter 2015 under the August 24. 2012 GWDP Ql 2015 Results Q2 2015 Results Q3 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 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 July 2015 Monthly Sample Date July 2015 Monthly- Result Q3 2015 Sample Date Q3 2015 Result September 2015 Monthly- Sample Date September 2015 Monthly- Result Sample Frequency Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 3/3/2015 149 4/8/2015 170 5/11/2015 149 178 Quar MW-14 (Class III) Field pH (S.U.) 3/5/2015 6.55 6.30 8/11/2015 9/16/2015 Quari Field pH (S.U.) 6.5 - 8.5 6/1/2015 6/23/2015 6.59. 6.53 6.47 Quari MW-25 (Class III) Chloride (mg/L) 2/4/2015 31.1 7/6/2015 8/10/2015 9/15/2015 Quar Cadmium (ug/I.) 1.37 1.27 Uranium (ug/L) 6.5 6.54 6.S1 6/23/2015 Quar Quan Nitrate + Nitrite (as N) (mg/I.) 0.845 0.606 1.15 Quari Uranium (ug/l.) 78.1 72.6 75.7 63.3 Quari Chloroform (ug/L) 2610 2560 1240 Quari MW-26 (Class III) Chloride (mg/L) 1/21/2015 67.4 Field pH (S.U.) 6/3/2015 6/24/2015 8/10/2015 8/17/2015 88.3 9/16/2015 Quari 6.58, 6.20 Quari Dichloromethane (Methylene Chloride) (ug/I.) 3.99 9.38 Quar Nilrate + Nitrite (as N) (mg/I.) 16.1 15.8 Quari Chloride (me/L) 142 145 165 165 Quari Uranium (ug/L) 8.32 8.23 8.35 8.38 7.72 Quari MW-30 (Class II) 3/3/2015 4/8/2015 5/12/2015 Field pH (S.U.) 6.5-8.5 6.4/ 6.32 6/2/2015 6/24/2015 6.94, 6.32 Quari Ammonia (mg/I.) 0.14 Selenium (ug/I.) 6/24/2015 0.0692 Quar 41.6 39.1 Quar Nitrate + Nitrite (as N) (mg/I.) 18.8 Quar TDS (mg/I.) 1320 /5J0 1680 1700 1480 Quari MW-31 (Class III) Chloride (mg/L) 228 222 264 Selenium (ug/L) 79.2 76.2 75.7 7/. 6 9/15/2015 Quari 79.0 Quar Field pH (S.U.) 6.42 6.40 6/1/2015 6/23/2015 7.14, 7.08 Quar! Sulfate (mg/l.) 66* 691 638 Quari Manganese (ug/L) 228 223 201, 176 Quad Thallium (ug/l) 0.5 <0.5. <0.5 Quar MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 3.81 4.25 Field pH (S.U.) 6.5 - 8.5 6.22 6.26 6/2/2015 6/23/2015 8/10/2015 6.56 6.40 9/15/15 9/22/15 9/28/15 4.81,6.13 Quar1 6.52, 6.41, 6.49 Quari Selenium (ug/l.) 26.6 Quar Uranium (ue/L; 24.4 20.2 22.5 21.3, 22.3 Quar Required Semi-Annual Sampling Wells MW-01 (Class II) ctrahydrofuran (ug/T/ Chloride (mg/I.) Field pH (S.U.) Sulfate (mg/L) 6.77 - 8.5 6.66 7/27/2015 876 NS Semi-Annually Semi-Annually Semi-Annually Sum- Annually Selenium (ug/L) 4/23/2015 5/20/2015 Semi-Annually Field pH (S.U.) 6./2 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 Zinc (ug/L) 4/23/2015 5/20/2015 \ .44, 2.08 5.03, 14.2 NS NS Semi-Annually Semi-Annually 238, 373 Semi-Annually Sulfate (mg/L) 3663 Semi-Annually Nilralc + Nitrite (as N) (mg/L) Semi-Annually Fluoride (mg/I.) 0.68 Semi-Annually Field pH (S.U.) 4/23/2015 4/29/2015 6.59, 6.24 Semi-Annually MW-03A (Class III) Sulfate (mg/L) 3640 Semi-Annually Nitrate + Nitrite (as N) (mg/L) 7/29/2015 Semi-Annually TDS (mg/I.) 5805 Semi-Annually Selenium (ug/L) 94.1 101 Semi-Annually MW-05 (Class II) Uranium (ua/L) NS NS NS 7/21/2015 Semi-Annually Selenium (ug/I.) Semi-Annually MW-12 (Class III) Field pH (S.U.) NS 4/21/2015 4/28/2015 NS Semi-Annually MW-15 (Class III) Selenium (ug/L) 128.7 Field pH (S.U.) 4/13/2015 7/22/2015 Semi-Annually Semi-Annually Ql 2015 Results Q2 2015 Results Q3 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 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 July 2015 Monthly Sample Date July 2015 Monthly- Result Q3 2015 Sample Date Q3 2015 Result September 2015 Monthly Sample Date September 2015 Monthly Result Sample Frequency Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/L) Field pH (S.U.) 3198.77 NS 3240 2.81 NS 1990 Semi-Annua! Semi-Annua: MW-19 (Class III) Field pH (S.U.) 6.78 Nitrate + Nitrite (as N) (mg/L) 2/2/2015 NS 4/14/2015 2.83 2.91 Semi-Annuai Semi-Annual MW-23 (Class III) Field pH (S.U.) 2/10/2015 NS Cadmium (ug/L) Fluoride (mg/L) 0.397 0.293 0.388 MW-24 (Class III Sulfate (mg/I.) 2/12/2015 NS Thallium (ug/L) Field pH (S.U.) 5/28/2015 6/24/2015 5.39, 5.98 Nitrate + Nitrite (as N) (mg/L) 6.27 MW-27 (Class III) Chloride (mg/I.) 44.2 43.7 Sulfate (mg/I.) 2/9/2015 TDS (mg/L) Gross Alpha minus Rn & U (pCi/I.) Semi-Annuai Chloride (mg/L) 105 130 113 Cadmium (ug/L) MW-28 (Class III) Uranium (ug/L) 6.13 Vanadium (ug/L) Field pH (S.U.) 6.1 -8.5 4/21/2015 4/27/2015 6.08, 6.17 5.91 Semi-Annua Semi-Annua] TDS (mg/I.) 4430 MW-29 (Class III; Sulfate (mg/I.) 2/10/2015 2960 7/22/2015 Field pH (S.U.) 6.46 - 8.5 6.42 6.30 Semi-Annua Gross Alpha minus Rn & U (pCi/L) 2/9/2015 2.19 MW-32 (Class III) Chloride (mg/L) 37.8 Field pH (S.U.) 2/9/2015 6.37 GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Fxceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Pursuant to the DRC letter of August H. 2015. these constituents will no longer be monitored on an accelerated schedule. These constituents will he dropped from this report after this •i^HHH^nHHHHHKiHinnHHHHHHi