DRC-2017-006124 - 0901a06880740b01

Div of Waste Management
and Radiation Control
AUG 1 7 2017
WENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
W£-2&7-OOMZ4r
August 15,2017
Sent VIA OVERNIGHT DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: State of Utah Groundwater Discharge Permit (“GWDP”) No. UGW370004
Transmittal of Revised Groundwater Quality Assurance Plan (“QAP”), dated August 15, 2017
Dear Mr. Anderson:
Attached please find the revised White Mesa Mill QAP, Revision 7.3 for your review and approval. The
revisions consist of changes made to correct typographical errors and update field data and sample collection
procedures.
For ease of review we have provided both redline and clean versions of the document.
If you should have any questions regarding this plan please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Mark Chalmers
David Turk
Logan Shumway
Scott Bakken
Garrin Palmer
Tanner Holliday
REDLINE
Mill - Groundwater Discharge Permit Date: 06 06 1208-15-
Groundwater Monitoring
Quality Assurance Plan (QAP)
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
State of Utah
Groundwater Discharge permit No. UGW370004
; Revision 7.33
Page 1 of 67
Denison MinesEnergy Fuels Resources (USA) Gorplnc.
P.O. Box 809225 Union Boulevard. Suite 600
Blanding. UT 84511 Lakewood. CO 80228
Mill - Groundwater Discharge Permit
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Date: 06 06 1208-15-17- Revision 7.33
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TABLE OF CONTENTS
1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/QC Program 6
2.3 Data Requestors/Users 6
2.4 Data Generators 7
2.4.1 Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
2.5 Responsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3.1 Precision 9
3.2 Accuracy 10
3.3 Representativeness 10
3.4 Completeness 10
3.5 Comparability 10
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.1 VOC Trip Blanks 11
4.3.2 Equipment Rinsate Samples 11
4.3.3 Field Duplicates 1343
4.3.4 Definition of “Batch” 1343
5.0 CALIBRATION 1342
5.1 Depth to Groundwater Measurements 1343
5.2 Water Quality 1343
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6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS UU
6.1 Groundwater Head Monitoring 1342
6.1.1 Location and Frequency of Groundwater Head Monitoring 1443
6.1.2 Groundwater Head Monitoring Frequency 4443
6.2 Ground Water Compliance Monitoring 1543
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 1543
6.2.2 Quarterly and Semi-Annual Sampling Required Linder Parts I.E. 1 .b) or I.E. 1 .c) of the GWDP P544
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs LG. 1 or I.G.2 of the GWDP J_644
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 1645
6.2.5 Decontamination Procedure 1645
6.2.6 Pre-Purging/ Sampling Activities 1645
6.2.7 Well Purging/Measurement of Field Parameters 1645
6.2.8 Samples to be taken and order of taking samples 1846
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 1846
7.1 Field Data Worksheets 1846
7.2 Chain-Of-Custody and Analytical Request Record 2042
7.3 Record Keeping 204#
8.0 ANALYTICAL PROCEDURES AND QA/QC 2HS
8.1 Analytical Quality Control 2144)
8.1.2 Spikes, Blanks and Duplicates 2144)
8.2 Analytical Laboratory Procedures 2326
9.0 INTERNAL QUALITY CONTROL CHECKS 2724
9.1 Field QC Check Procedures 2724
9.1.1 Review of Compliance With the Procedures Contained in this QAP 2724
9.1.2 Analyte Completeness Review 2724
9.1.3 Blank Comparisons 2724
9.1.4 Duplicate Sample Comparisons 2825
9.2 Analytical Laboratory QA Reviews 2926
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 2926
9.4 Analytical Data 3027
10.0 CORRECTIVE ACTION M28
10.1 When Corrective Action is Required 3128
10.2 Procedure for Corrective Action 3128
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11.0 REPORTING 3239
12.0 SYSTEM AND PERFORMANCE AUDITS 3330
12.1 QA Manager to Perform System Audits and Performance Audits 3330
12.2 System Audits 3330
12.3 Performance Audits 3434
12.4 Follow-Up Actions 3434
12.5 Audit Records 3434
13.0 PREVENTIVE MAINTENANCE 34^
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 3532
14.1 Ongoing QA/QC Reporting 3532
14.2 Periodic Reporting to Management 3532
15.0 AMENDMENT 3532
363316.0 REFERENCES
ATTACHMENTS
Attachment 1 Field and Data Forms
Attachment 1 -1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example CQC FormsField Data Report
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures
Attachment 2-2 Decontamination Procedures
Attachment 2-3 Purging Procedures
Attachment 2-4 Sample Collection Procedures
Attachment 2-5 Field QC Samples
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APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Date: 06 06 1208-15-17- Revision 7.33
1.0 INTRODUCTION
This Groundwater Monitoring Quality Assurance Plan (the “QAP”) details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary to
comply with UAC R317-6-6.3(1) and (L) at the White Mesa Uranium Mill (the “Mill”), as
required under paragraph I.H.6 ofby the State of Utah Groundwater Discharge Permit No.
UGW370004 (the “GWDP”) for the Mill. This Procedure incorporates the applicable
provisions of the United States Environmental Protection Agency (“EPA”) RCRA
Groundwater Monitoring Technical Enforcement Guidance Document (OSWER-9950.1,
September, 1986), as updated by EPA’s RCRA Ground-Water Monitoring: Draft Technical
Guidance (November 1992).
Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or “QA”) and as functional (i.e., quality control or “QC”). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBIUITIES
2.1 Functional Groups
This QAP specifies roles for a QA Manager as well as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.
2.2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QA/QC measures are properly employed is the
responsibility of the QA Manager. The QA Manager is typically not directly involved in the
data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Denison Mines (USA) Corp. (“DUSA”)Energy Fuels Resources (USA) Inc. (“EFRI”)
corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits and applicable regulations.
Accordingly, the data requesters/users (the “Data Users”) are therefore DUSA’s EFRTs
corporate management and regulatory authorities through the implementation of such permits
and regulations. The data quality objectives (“DQOs”) required for any groundwater
sampling event, such as acceptable minimum detection limits, are specified in this QAP.
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2.4 Data Generators
The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors (each a “Sampling and QC Monitor”). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at the
contract analytical laboratory (the “Analytical Laboratory”) utilized by the Mill to analyze the
environmental samples is performed by or under an employee or agent (the “Analysis
Monitor”) of the Analytical Laboratory, in accordance with specific requirements of the
Analytical Laboratory’s own QA/QC program.
The responsibilities of the data generators are as follows:
2.4.1 Sampling and QC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the samples,
to the Analytical Laboratory in accordance with this QAP;
c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing of
those samples at the conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling
event;
e) Preparing QC and sample data for review by the QA Manager; and
f) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
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2.4.2 Analysis Monitor
The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory’s QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program (“NELAP”) certification.
2.4.3 Data Reviewers/Approvers
The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:
a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;
b) Making on-site evaluations and submitting audit samples to assist in reviewing
QA/QC procedures;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.
2.5 Responsibilities Of Analytical Laboratory
Unless otherwise specified by DUS A EFRI corporate management, all environmental
analysis of groundwater sampling required by the GWDP or by other applicable permits, will
be performed by a contract Analytical Laboratory.
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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining National Environmental Laboratory Accreditation Program
(^NELAP^j certificationT. which is a national accreditation program developed by the
NELAC institute (“TNI”).
In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U.-S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory Guide
4.14.
The Analytical Laboratory will be chosen by DUS A EFRI and must satisfy the following
criteria: (1) experience in analyzing environmental samples with detail for precision and
accuracy, (2) experience with similar matrix analyses, (3) operation of a stringent internal
quality assurance program meeting NELAP certification requirements and that satisfies the
criteria set out in Section 8 below, (4) ability to satisfy radionuclide requirements as
stipulated in the applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the
State of Utah for and capable of performing the analytical methods set out in Table 1. The
analytical procedures used by the Analytical Laboratory will be in accordance with Utah
Administrative Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management purposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QA/QC measures are deemed more reliable than data without any
QA/QC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference (“RPD”) of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
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percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW-846,
Chapter 1, Section 5.0, page 27 - 28).
3.2 Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:
% Recovery = (A-B /C) x 100
Where:
A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:
Completeness = (Number of valid data points/total number of measurements) x 100
Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion of the data validation.
Executive SecretaryThe Director (“Director”) of the Utah Division of Waste Management
and Radiation Control) (“DWMRC”) -approval will be required for any completeness less
than 100 percent.
3.5 Comparability
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Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection
techniques, measurement procedures, methods, and reporting units are consistent for all
samples within a sample set.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.
4.3 Water Quality QC Samples
Quality assurance for groundwater monitoring consists of the following QC samples:
4.3.1 VQC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds (“VOCs”) through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.
4.3.2 Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non­
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples. Rinsate
blanks will be collected after decontamination and prior to subsequent use. Rinsate blank
samples for a non-dedicated pump are prepared by pumping de-ionized water into the sample
containers. Rinsate blank samples for a non-disposable or non-dedicated bailer_are prepared
by pouring de-ionized water over and through the bailer and into the sample containers.
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Equipment rinsate blanks will be analyzed only for the contaminants required during the
monitoring event in which they are collected.
Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
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4.3.3 Field Duplicates
Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.
Field duplicate sampling procedures are described in Attachment 2-5.
4.3.4 Definition of “Batch”
For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers’ recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to each use as
noted in Attachment 2 to ensure that the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer’s specifications (for
example, by using two known pH solutions and one specific conductance standard.) Per the
manufacturer, temperature cannot be calibrated but Temperature will be periodically checked
comparatively by using a thermometer. Conductivity and pH Gcalibration results will be
recorded en the-Field Data Worksheetas described in Section 7.1.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1 Groundwater Head Monitoring
Groundwater head measurements (“depth to water”) will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
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6.1.1 Location and Frequency of Groundwater Head Monitoring
Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a) All Point of Compliance wells listed in the GWDP Parts I.E. 1 (b) and (c) and
b) Monitoring well MW-34;
c) All piezometers (P-1, P-2, P-3 A, P-4, P-5 and the Dry Ridge piezometers);
d) All contaminant investigation wells required by the Executive Secretary Director
as part of a contaminant investigation or groundwater corrective action
(chloroform and nitrate wells).
6.1.2 Groundwater Head Monitoring Frequency
Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an electronic
data management system (spreadsheet and/or database). The data from the quarterly depth to
water measurements will be included in the quarterly groundwater reports.
In addition, weekly and monthly depth to groundwater measurements are taken in the chloroform
pumping wells MW-4. MW-26. TW4-1. TW4-2. TW4-11. TW4-19, TW4-20. TW4-4, TW4-21.
TW4-37, TW4-39 (starting in December 2016). and the nitrate pumping wells TW4-22, TW4-24,
TW4-25. and TWN-2.
The depth to groundwater measured immediately prior to purging/sampling will be recorded
on data sheet for each well as described in Section 7.1.
An example of a Field Data Work Sheet for Groundwater is included in Attachment 1.
The data sheets included herein are examples and may be changed to accommodate
additional data collection.—If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive Secretary.
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6.2 Ground Water Compliance Monitoring
6.2.1 Location and Frequency of Groundwater Compliance Monitoring
Groundwater quality shall be measured in the following wells specified in the GWDP at the
following frequencies specified in the GWDP.t In addition, the Chloroform Investigation and
Nitrate Corrective Action wells will be sampled quarterly as described in Appendix A and
Appendix B of this QAP.
a) Semi annually in the following Point of-Compliance wells: MW -1---MW-2,- MW-
3, MW 3A, MW 5, MW 12, MW 15, MW 17, MW 18, MW 19, MW 23, MW
24, MW 27, MW 28, MW 29, and MW 32;
b) Semi annually in the following General Monitoring Wells: MW 20 and MW 22;
c) Quarterly in the following Point of Compliance wells: MW 11, MW 14, MW 25,
MW 26, MW 30, MW 31, MW 35, MW 36 and MW 37; and
44a) Quarterly in the Chloroform Investigation and Nitrate Corrective Action wells.
In addition,Accelerated quarterly or monthly sampling may be required for certain parameters
in certain wells based on the requirements specified in Parts LG. 1 or I.G:2 of in the GWDP.
Sampling personnel should coordinate with the QA Manager prior to conducting any
monitoring well sampling to determine if any parameters in any wells are subject to
accelerated monitoring.
6.2.2 Quarterly and Semi-Annual Sampling Required Coder lu Accordance With Parts I.E.l.h)
or I.E.l.c) of the GWDP
All quarterly and semi-annual samples collected under in accordance with Parts I.E.l.b) or
I.E.l.c) of the GWDP shall be analyzed for the following parameters:
a) Field parameters - depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics - chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.
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6.2.3 Accelerated Quarterly or Monthly Sampling Required Uttdef-Bv Paragraphs I.G.1-&F
I.G.2 of the GWDP
Any quarterly or monthly accelerated sampling required under paragraphs I.G.l. or I.G.2. of
by the GWDP shall be analyzed for the specific parameters as required by previous sampling
results as determined by the QA Manager.
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.
Purging and sampling equipment is described in Attachment 2-3 of this QAP.
Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;
6.2.5 Decontamination Procedure
Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.
6.2.6 Pre-Purging/ Sampling Activities
Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well’s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.
6.2.7 Weil Purging/Measurement of Field Parameters
The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging wells prior to sampling removes the stagnant water column present in the well casing
and assures that representative samples of the formation water are collected. Purging will be
completed as described in Attachment 2-3.
There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:
1.Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
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6.2.8 Samples to be taken and order of taking samples
For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP-. The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single container
due to like sampling requirements (filtering) and/or like preservation. The container
requirements will be determined by the Analytical Laboratory and specified with the bottles
supplied to the Field Personnel. Bottle requirements may change if the Analytical Laboratory
is changed or if advances in analytical techniques allow for reduced samples volumes. The
following list is a general guideline.
a) VOCs, 3 sample containers, 40 ml each;
b) Nutrients (ammonia, nitrate and-nitritenitrate/nitrite as N). 1 sample container, 400
250 ml:
c) All other non-radiologics (fluorideanions, general inorganics, TDS, total cations and
total anions). L-2_sample containers, 250-500 and 250 ml.; and
d) __Gross alpha and heavy metals, 1 sample container, 1,000 ml, filtered; andr
die) Metals, 1 sample container, 500 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.
Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1 Field Data WorksheetsCollection
Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded in waterproof ink on the Field Data
Worksheets, which will be maintained on file at the Mill.
Field data collection will be completed using either an electronic device (such as a tablet) or a
hardcopy form. Hardcopy forms will be completed in waterproof ink. If field data collection
is completed using an electronic device, a data report for each well sampled will be printed
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after the completion of the sampling event and signed by one member of the sampling crew.
The signed sheets will be maintained on file and the Mill and will be included in the quarterly
reports. The electronic data collection will be accomplished using a standardized collection
module. An example of a hardcopy field collection form as well as an example data report are
included as Attachment 1A and IB respectively.
The hardcopy data sheets and data reports included herein are examples and may be changed
to accommodate additional data collection. If a change is made to a data sheet to
accommodate additional information, a copy will be provided to the Director. Changes to
hardcopy field forms and data reports will not eliminate any data collection activity without
written approval of the Director.
Regardless of the field data collection method. The Field Data Worksheets will contain the
following information will be collected:
• Name of the site/facility
• description of sampling event
• location of sample (well name)
• sampler’s name(s) and/or initials(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type and condition of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
The Field Data WorksheetsField data collection will also contain include detailed notes
describing any other significant factors noted during the sampling event as necessary,
including, as applicable: condition of the well cap and lock; water appearance, color, odor,
clarity; presence of debris or solids; any variances from this procedure; and any other relevant
features or conditions. An example of a Field Data Worksheet that -incorporates this
information is attached in Attachment 1.
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Tfoe- data sheets included herein are examples and may be changed to accommodate
additional data collection.—If a change-is made- to a data sheet to accommodate additional
informatietvra eopy-wiH he-provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive Secretary.
7.2 Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody and Analytical Request Record form (the “COC Form”)? provided by-the
Analytical Laboratory, will accompany the samples being shipped to the Analytical
Laboratory. Examples of the Chain of Custody Forms used are attached as Attachment 2. If
the-Chain-of- CJttstedy Form changes at any time, the Company shall provide a copy of-the
new or revised Chain of Custody Form to the Executive Secretary and substitute the new
form for-the old form in Attachment 2. Standard Chain-of-Custody protocol is initiated for
each sample set. A COC Form is to be completed for each set of samples collected in-a
shipping container (cooler) and is to include the following:
• sampler’s name
• company name
• date and time of collection
• sample type-matrix (e.g.. water)
• sample location
• number of sample containers in the shipping container
• analyses requested
• signatures of persons involved in the chain of possession
• internal temperatures of the shipping container when opened at the laboratory
• remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.
Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratory will sign the COC Form,
document shipment method, and send the original and the second copy-of-the COC Form
with the samples. Upon receipt of the samples, the person receiving the samples will sign the
COC Form and return the seeondan electronic copy to the Mill1* and the RSOQA Manager.
Copies of the COC Forms and other relevant documentation will be retained at the Mill.
7.3 Record Keeping
The Field Data Worksheetsdata collection records are retained in an electronic database and
hardcopies are retained at the Mill.
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Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.
Copies of the current Utah certifications of the Analytical Laboratory or Laboratories and a
list of Utah Bureau of Laboratory Improvement- approved parameters and methods used to
perform—analysis-during the monitoring events conducted during the quarter will be
main-tamed at the Mill.—DUSA EFRI will ensure that the Analytical Laboratory or
Laboratories used, have certifications for each parameter and method required by Section 8.2,
Table 1 of the QAP. The QA Manager will check the Utah certifications at least annually.
Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the Field Data Worksheetsfield and from the data packages are managed using
electronic data management software. The data management software will be managed and
administered by the QA Manager or designee. The Mill Personnel will have read only access
to the electronic data management software-:
8.0 ANALYTICAL PROCEDURES AND QA/QC
Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.
8.1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, DUSA EFRI shall ensure that the
Analytical Laboratory is certified by the State of Utah and by NELAP, is capable of
performing the analytical procedures specified in Section 8.2, and that the QA/QC program
of the Analytical Laboratory includes the spikes, blanks and duplicates described in Section
8.1.2.
8.1.2 Spikes, Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
The following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:
a) Matrix Spike/Matrix Spike Duplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
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spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.
b) Method Blanks
Each analytical batch shall be accompanied by a method blank. The method -blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.
c) Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normally found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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d) Check Sample
Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Executive Secretary Director. With respect to
Chloroform Investigation and Nitrate Corrective Action sampling, the analytical procedures
for parameters monitored under those programs are specified in Appendix A and B
respectively.
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Table 1
Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Nutrients
Ammonia (as N)A4500-
NH3 G or
E350.1
0.05 mg/L 28 days H2SO4 to
pH<2
<6°C
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
< 6°C
Heavy Metals
Arsenic E200.7 or
E200.8
5 pg/L 6 months HN03to pH<2 None
Beryllium E200.7 or
E200.8
0.50 pg/L 6 months HNO3 to pH<2 None
Cadmium E200.7 or
E200.8
0.50 pg/L 6 months HN03 to pH<2 None
Chromium E200.7 or
E200.8
25 pg/L 6 months HN03 to pH<2 None
Cobalt E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Copper E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Iron E200.7 or
E200.8
30 pg/L 6 months HNO3 to pH<2 None
Lead E200.7 or
E200.8
1.0 pg/L 6 months HN03 to pH<2 None
Manganese E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Mercury E 245.1 or
E200.7 or
E200.8
0.50 pg/L 28 days HNO3 to pH<2 None
Molybdenum E200.7 or
E200.8
10 pg/L 6 months HN03 to pH<2 None
Nickel E200.7 or
E200.8
20 pg/L 6 months HNO3 to pH<2 None
Selenium E200.7 or
E200.8
5 pg/L 6 months HNO3 to pH<2 None
Silver E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Thallium E200.7 or
E200.8
0.50 pg/L 6 months HNO3 to pH<2 None
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Tin E200.7 or
E200.8
100 pg/L 6 months HNO.Uo pH<2 None
Uranium E200.7 or
E200.8
0.30 pg/L 6 months HN03 to pH<2 None
Vanadium E200.7 or
E200.8
15 pg/L 6 months HN03 to pH<2 None
Zinc E200.7 or
E200.8
10 pg/L 6 months HN03 to pH<2 None
Radiologies
Gross Alpha E 900.0 or
E900.1
1.0 pCi/L 6 months HN03 to pH<2 None
Volatile
Organic
Compounds
Acetone SW8260B
or
SW8260C
20 pg/L 14 days HC1 to pH<2 <6°C
Benzene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
2-Butanone
(MEK)
SW8260B
or
SW8260C
20 pg/L 14 days HC1 to pH<2 <6°C
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloroform SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloromethane SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
Naphthalene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Tetrahydrofuran SW8260B 1.0 pg/L 14 days HC1 to pH<2 < 6°C
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
or
SW8260C
Toluene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Xylenes (total)SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Others
Field pH (S.U.)A4500-H
B
0.01 s.u.Immediate None None
Fluoride A4500-F C
or E300.0
0.1 mg/L 28 days None None
TDS A2540C 10 mg/L 7 days None <6°C
General
Inorganics
Chloride A4500-C1
B or
A4500-C1
E
or E300.0
1 mg/L 28 days None None
Sulfate A4500-
S04 E or
E300.0
1 mg/L 28 days None < 6°C
Carbonate as
COS
A2320 B 1 mg/L 14 days None <6°C
Bicarbonate as
HCOS
A2320B 1 mg/L 14 days None < 6°C
Sodium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Potassium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
Magnesium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Calcium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
1. The Analytical Laboratory will be required to meet the reporting limits (“RLs”) in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Executive Secretary Director.
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9.0 INTERNAL QUALITY CONTROL CHECKS
Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QA/QC analysis of field procedures:
9.1.1 Review of Compliance With the Procedures Contained in this QAP
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.
9.1.2 Analyte Completeness Review
The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non­
conformance (see Part I.E. 1(a) ofas required by -the Permit. Executive SecretaryDirector
approval will be required for any completeness (prior to QA/QC analysis) less than 100
percent. Non-conformance will be defined as a failure to provide field parameter results and
analytical results for each parameter and for each well required in Sections 6.2.2 and 6.2.3,
for the sampling event, without prior written Executive SecretaryDirector approval.
9.1.3 Blank Comparisons
Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not an order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).
Corrective actions for blank comparison non-conformance shall first determine if the non­
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager wilh 1 2 3
1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
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4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.
9.1.4 Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD >_20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994, 9240.1-05-01, p. 25).
b) Radiologies Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.
c) Radiologies. Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
A-B /(Sa2+Sb2)1/2<2
Where:
A = the first duplicate measurement
B = the second duplicate measurement
sa2 = the uncertainty of the first measurement squared
sb2 = the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.
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(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).
Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non­
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
9.2 Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data assessment
will be a part of the validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following:
(1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
(4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the
QA/QC data. The Analytical Laboratory will provide the following information:
(1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
(4) QA/QC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
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a) Reporting Limit (RL) Comparisons
The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory
are those specified in Table 1, unless otherwise approved by the Executive SeeretaryDirector.
Non-conformance shall be defined when the Analytical Laboratory uses analytical methods
not listed in Table 1 and not otherwise approved by the Executive Secretary Director.
c) Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.
9.4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory’s QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to DUSA EFRI as
requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory’s record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.
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If re-runs occur with increasing frequency, the Analysis Monitor and the -QA Manager will
be consulted to establish more appropriate analytical approaches for problem samples.
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted on the Field Data Worksheetsduring field data
collection or other applicable records. Any QA/QC problems that arise will be brought to the
immediate attention of the QA Manager. Analytical Laboratory deviations will be recorded
by the Analysis Monitor in a logbook as well.
When a procedural or systematic non-conformance is identified, DUS A EFRI shall:
a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to be
systematic or procedural, DUS A EFRI shall determine the root cause, and provide
specific steps to resolve problems(s) in accordance with the procedure set forth in
Section 10.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Executive
Secretary Director on or before submittal of the next quarterly ground water
monitoring report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 10 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in the
same quarterly monitoring report with other samples collected for the same sampling
event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.
10.2 Procedure for Corrective Action
The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QA/QC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem;
b) Assignment of responsibility for investigating the problem;
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c) Investigation and determination of the cause of the problem;
d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action;
f) Implementing the corrective action and evaluating its effectiveness; and
g) Verifying that the corrective action has eliminated the problem.
The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. The corrective actions will be documented either in Aa
memorandum explaining the steps outlined above, which will be placed in the applicable
monitoring files and the Mill Central Files, and-or the corrective action will be documented in
a Reportthe quarterly reports prepared in accordance with Section 11.
11.0 REPORTING
As required under paragraph I.F.l ofby the GWDP, the Mill will send a groundwater
monitoring report to the Executive SecretaryDirector on a quarterly basis. Both the Routine
Groundwater Monitoring Reports (pertinent to Part I.F.l of the Permit) and Chloroform
Investigation and Nitrate Corrective Action Reports shall be submitted according to the
following schedule:
Quarter Period Due Date
First January - March June 1
Second April - June September 1
Third July - September December 1
Fourth October - December March 1
The Routine Groundwater Monitoring Reports (pertinent to Part I.F.l required by the GWDP
of the Permit) will include the following information:
• Description of monitor wells sampled
• Description of sampling methodology, equipment an decontamination
procedures to the extent they differ from those described in this QAP
• A summary data table of groundwater levels for each monitor well and
piezometer
• A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to Part l.G. 1 of the GWDP or are out of compliance in any particular
wells pursuant to Part LG.2 of the GWDP
• Copies of Field Data WorksheetsField data recorded during sample collection
• Copies of Analytical Laboratory results
• Copies of Chain of Custody Forms (included in the data packages)
• A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
• Evaluation of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this QAP and all corrective actions taken?
•—Recommendations and-Ceftelusions:
With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.
In addition, an electronic copy of all analytical results will be transmitted to the Executive
SecretarvDWMRC in comma separated values (“CSV”) format, or as otherwise advised by
the Executive SecretarvDWMRC.
Further reporting may be required as a result of accelerated monitoring under paragraphs
l.G.l and-I.G.2 of the GWDP. The frequency and content of these reports will be defined by
DUSA EFRI corporate management working with the Executive Secretary Director.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
DUSA EFRI shall perform such system audits and performance audits as it considers
necessary in order to ensure that data of known and defensible quality are produced during a
sampling program. The frequency and timing of system and performance audits shall be as
determined by DUS AEFRI.
12.2 System Audits
System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
Mill - Groundwater Discharge Permit Date: 06 06 1208-15-17- Revision 7.33
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 33 of 67
| Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.33
Page 34 of 67
12.3 Performance Audits
The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer’s specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded in the Field Data Worksheets or
logbookand addressed as soon as practical.
The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a scheduled
basis to minimize downtime and the potential interruption of analytical work.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.33
Page 35 of 67
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
The following reporting activities shall be undertaken on a regular basis:
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QA/QC issues associated with such sampling
activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill’s QA Manager or his staff will
identify the analytical methods performed and all QA/QC measures not within the
established control limits. Any QA/QC problems will be brought to the QA
Manager’s attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report (case narrative) will be prepared by the
Analytical Laboratory for review by the QA Manager, by a Sampling and QC
Monitor or by such other qualified person as may be designated by the QA Manager.
The report will be prepared in accordance with NELAP requirements and will
summarize the data validation efforts and provide an evaluation of the data quality.
14.2 Periodic Reporting to Management
The QA Manager shall present a report to DUSA’s EFRI’s ALARA Committee at least once
per calendar year on the performance of the measurement system and the data quality. These
reports shall include:
a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;
b) Results of any performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and
d) Significant QA problems and recommended solutions.
15.0 AMENDMENT
This QAP may be amended from time to time by DUSA EFRI only with the approval of the
Executive Secretary Director.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 36 of 67
16.0 REFERENCES
United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.
United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.
Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
| Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 37 of 67
ATTACHMENT 1
Field and Data Forms
Mill - Groundwater Discharge Permit Date: 06 06 1208-15-17- Revision 7.33
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 38 of 67
Attachment 1-1
Quarterly Depth to Water Data Sheet
NAME:
DATE:
TIME WELL Static level TIME WELL Static Level TIME WELL Static Level
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 39 of 67
e/vertG v ns cl s
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
See inst
Description of Sampling Event:
Location (well name):
Field Sample ID
Sampler Name
and initials:
Date and Time for Purging
Well Purging Equip Used: □pump or □ bailer
Purging Method Used: □ 12 casings □ .3 casings
Sampling Event
pH Buffer 7.0
and Sampling (if different)
Well Pump (if other than Bennet)
Prev. Well Sampled in Sampling Event
pH Buffer 4.0
Specific Conductance pMHOS/ cm Well Depth(O.OIft):
Depth to Water Before Purging Casing Volume (V) 4" Well:(,653h)
3" Well:(,367h)
Weather Cond.Ext'l Amb. Temp. °C (prior sampling event)
Time
Conductance
Temp. °C 1________
Redox Potential Eh (mV)
Turbidity (NTU)
Gal. Purged
pH
Time
Conductance
Temp. °C
Gal. Purged
pH
Redox Potential Eh (mV) [
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged
□ pH
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged [
□ PH |
Redox Potential Eh (mV) [
Turbidity (NTU)
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: Q6-.064208-15-17- Revision 7.23
Page 40 of 67
Volume of Water Purged gallon(s)
Pumping Rate Calculation
Flow Rate (Q), in gpm,
S/60 =
Time to evacuate two casing volumes (2V)
T = 2V/Q =
Number of casing volumes evacuated (if other than two)
If well evacuated to dryness, number of gallons evacuated
Name of Certified Analytical Laboratory if Other Than Energy Labs
Type of Sample Sample Taken Sample Vol (indicate if
other than as specified
below)
Filtered Preservative
Type
Preservative Added
Y N Y N Y N
VOCs □ □3x40 ml □□HCL □ □
Nutrients □□100 ml □□H2S04 □ □
Heavy Metals □ □250 ml □□HN03 □□
All Other Non Radiologies □ □250 ml □□No Preserv.□ □
Gross Alpha □□1,000 ml □□HN03 □□
Other (specify)□□Sample volume
□ □□□
If preservative is used, specify
Type and Quantity of
Preservative:
Final Depth Sample Time
Comment
See instruction
Do not touch this cell (SheetName)
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 41 of 67
MiH -
Gnu
'X Discii orge Penult
itoring Quatty Assnncc rttn (OW)
OENI5
MINES
ON0ii ATTACHMENT 1-2
WHITE MESA CRANIUM MILL
FIELD DATA WORKSHEET FOR GROUND WATER
Date: 5/13/4012 *r». 7.1
Attachment 1
Description of Sampling Event; [
Location (well name) |
Field Sample ID 1
Sampler Name
and initials;
Date and Time far Purging | | and Sampling (if different)
Well Purging Eqmp Used: | □ [pomp or | □ | bailer Well Pnmp (if othei than Beimel)
Purging Method Used; I □ |2 casings | □ |3 casmgs
Sanipluig Event | Pm Well Sampled in Sampling Event
pH Buffer 4 0 |pH Buffer 7 .0
Specific Conductance
]
Depth to Water Before Purging Q
Conductance (avg) |
^pMHOS'cm Well Depth(0.01ft):
Casing Votnme (V) 4” Well:
3" Well:
(653h)
(367h)
pH of Water (avg)
Well Water Temp (avg)
Weather Cond.
Redox Potential (Eh)Q ]Turbidity
Exfl Amb. Temp. *C (prior sampling event)Q
Time I 1 Gal. Purged [Time | 1 Gal Purged [
Conductance | | pH [Conductance | | pH |
Temp. °C | | Teznp °C | 1
Redox Potential Eh (mV)Redox Potential Eh (mV) | |
Turbidity (NTU)Turbidity OiTU)
Time | | Gal. Purged (Time | ...............1 GaL Purged | |
Conductance I I pH I I Conductance I I pH |
Temp. °C | |Temp °C | |
Ii Redox Potential Eh (mV) Q
Turbidity (NTU) Turbidity (NTU)
1 of!
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.33
Page 42 of 67
MiH-GrouHltvatErOvstfiarge Permit
GroundMoter Monitoring Quatety Assurance P»n [C%AP)
Date: 3/23/2012 Rev. 7.1
Volume of Water Purged gallon(s)
Pummn,. Calculation
Floor Rate (Q). m gpm Time to evacuate two ca-ang vohunes (2V)
S/60 = | | T = 2V/Q= | |
Number of casing volumes evacuated (if other than two) | |
If well evacuated to dryness, number of gallons evacuated | |
Name of Certified Analytical Laboratory if Other Than Energy Labs
Type of Sample Sample Taken
Sample Vol (indicate
if other than as Filtered Preservative Type Preservative Added
Y N specified below)Y N Y N
VOCs □ □3x40 ml □□HCL □□
Nutrients □□100 ml □□H2S04 □ □
Heavy Metals □□250 ml □ □HN03 □□
All Other Non Radiologies □ □250 ml □□NoPreserv.□□
Gross Alpha □ □1,000 ml □□HN03 □□
Other (specify-)□ □
Sample volume □□□□
If preservative is used, specify
Type and Quanthy of Preservative:
Final Depth Sample Time |
See instruction
]Do not touch this cell (SheetName)
IMiite Mesa Mil
2 of 2
ENERGY,
LABORATORIES
Chain of Custody and Analytical Request Record
Company Name:
Report Mail Address:
Invoice Address:
Special Report/Formats:
DW
POTW/WWTP
State:________
Other:________
I I EDD/EDT(Eiectronic Data)
Format:
□ LEVEL IV
□NELAC
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Date
Collection
Time
PLEASE PRINT (Provide as much Information as possible.)
Page..of
Project Name, PWS, Permit, Etc.Sample Origin
State:
Contact Name:Phone/Fax:Email:
Invoice Contact S Phone:
MATRIX
Purchase Order:
R
U
S
H
EPA/Slate Compliance:
Yes □ No □
Sampler: (Please Print)
Quote/Bottle Order:
Contact ELI prior to
RUSH sample submittal
for charges and
scheduling - See
Instruction Page
Cooler IO(«):
Comments:Receipt Temp
On Ice:
Custody S®al
On Settle
On Code*
Intact
Signature
Match
Y N
Y H
Custody
Record
MUST be
Retaiqurehed by (print)-----------n.i.rr,™,----------Slflao ure Received by (print)1—iWt.™'---------------~ Signore
Rebnqunbed by (print)Date/Tme Signature Received by (print)DMfTime Signature
Signed Samola Disposal:ReMirn to Client:Lab Dreoosal:
In certain circumstances, samples submitted to Energy Laboratories. Inc. may be subcontracted to other certified laboratories in order to complete the analysis requested.
This serves as notice of this possibility. All sub-contract data will be clearly notated on your analytical report.
Visit our web site at www.enerqvlab.com for additional information, downloadable fee schedule, forms, and links.
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Sheet 1 of 2
White Mesa Mill
Field Data Worksheet For Groundwater
Groundwater Discharge Permit
Groundwater Monitoring Quality Assurance Planc>
ENEffGYFUB-S
Location ID MW-14
Field Sample ID MW-14 12062016
Purge Date & Time 12/21/2016 14:32
Sample Date & Time 12/21/2016 14:32
Sampling Program Baseline
Sampling Event GW Event
| Sampler Timothy
Purging Equipment Pump
Pump Type QED
Purging Method 2 Casings
Casing Volume (gal)19.7
pH Buffer 7.0 7.0
pH Buffer 4.0 4.0
Specific Conductance ()1000
Weather Conditions Cloudy
External Ambient Temperature (C)17
Previous Well Sampled MW-26
Well Depth (feet)118
Well Casing Diameter (inches)4
Depth to Water Before Purging (to O.Otfeet)103.02
Date/Time Gallons Purged Specific Conductance pH Temp (Deg C)Redox Potential Turbidity Before/After
12/6/2016 14:39 39.49 3908 6.4 14.31 363 0 Before
12/6/2016 14:40 39.71 3900 6.38 14.29 362 0 After
Pumping Rate Calculations
| Volume of water purged (gal)40.17 Flow Rate (Q = S/60) (gpm).217
Time to evacuate 2 Casing Volumes (min)181.63
| Final Depth to Water (feet)97.55 Number of casing Volumes 2
Volume, if well evacuated to dryness (gal)0
Name of Certified Analytical Laboratory
AWSL
Sample Analysis Information
Type of Sample/Analysis Sample Collected?Matrix
Container
Sample Filtered?
Preservative
Number Type Type Added?
VOCs Y WATER 1 3x40 ml N HCI Y
Nutrients Y WATER 1 100 ml N H2S04 Y
Heavy Metals Y WATER 1 250 ml N HN03 Y
All other non Radiologies Y WATER 1 250 ml N None N
Gross Alpha Y WATER 1 1000 ml N HN03 Y
Comments:
Not Continuous Well
Signature of Field Technician
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.33
Page 44 of 67
DENISO
MINES
CHAIN OF CUSTODY
eef4—©M-
Co wen *
Contact:
Chain of Custody/Sampling Analysis Request
QomrklA in
Bate Time
----
----
-- --
-- --
----
----
----
----
----
----
----
- ---
- ---
- ---
- ---
-- --
Thank you.
DDw /Qinno + i i m\/ 1 i rY-t r\rvtfotjtvtju py^oiynctiure;Uatt?/ i UHt;
Relinquished By:(Signatu re)Date/Time Received By:(Signature)Date/Time
| Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 45 of 67
ATTACHMENT 2
Field Procedures
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date:1-15-17- Revision 7.33
Page 46 of 67
Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures
Measure and record all depth to water data to the nearest 0.01 feet.
Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist - IT 300 or
equivalent device (the “Water Level Indicator”).
Equipment Checks
Equipment used in depth to groundwater measurements will be checked prior to each day’s
use to ensure that the Water Sounding Device is functional.
Check the Water Sounding Device as follows:
• Turn the Water Level Indicator on.
• Test the Water Level Indicator using the test button located on the instrument.
• If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.
Measurement of Depth to Water
All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:
• For monitoring wells - Measure depth to water from the top of the inner well casing at
the designated measurement point.
• For the piezometers - Measure depth to water from the top of the casing at the
designated measurement point.
• Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
• Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.
Mill - Groundwater Discharge Permit Date: 06 06 1208-15-17- Revision 7.23
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 47 of 67
Attachment 2-2
Decontamination Procedures
Non-dedicated sampling equipment will be decontaminated using the following
procedures:
Water level meter
Decontaminate the water level meter probe with a detergent/deionized (“01”) water.
mixture by-pouring the solutions over the water level indicator.
Rinse the water level indicator-with fresh DI water rinse by pouring the DI water over
the water level indicator.
Field Parameter Instrument (Hydrolab or equivalent)
Rinse the field parameter instrument probe unit with DI water prior to each
calibration.
Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.
Non-Dedicated Purging/Sampling Pump
Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:
a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;
b) pump the detergent/DI water solution through the pump and pump outlet lines
into the drain line connected-to Cell 1;
c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
d) submerge the pump into a 55-gallon drum of DI water;
e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;
f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.23
Page 48 of 67
g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;
h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).
All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 964)6-4208-15-17- Revision 7.23
Page 49 of 67
Attachment 2-3
Purging Procedures
The following equipment will be used for groundwater purging and sampling:
• Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
• Dedicated Pump: A pump that is dedicated to one specific well for the use -of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
• Non - Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
• Field Parameter Meter: A meter used to measure ground-water quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:
> Water temperature;
> Specific conductivity;
> Turbidity;
> pH;
> Redox potential (Eh).
• Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
• Diesel Generator: Mobile power supply to provide power for submersible pump.
• 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
“bladder” pumps.
Additional supplies for purging and sampling are as follows:
• IPad, tablet. Cell phone or Field Data Sheets
• 45 micron in-line filters (when metals and gross alpha analyses are required)
• Calculator
• Clock, stopwatch or other timing device
• Buckets
• Sampling containersJas provided by the Analytical Laboratory)
• Field preservation chemicals (as provided by the Analytical Laboratory)
• Disposable gloves
• Appropriate health and safety equipment
• Sample labels and COCs (as provided by the Analytical Laboratory)
Pre-Purging/ Sampling Activities
If a portable (non-dedicated) pump is to be used, prior to commencing the event’s sampling
activities,
1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) and ice into a cooler that will
transport the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC)
samples throughout the monitoring event.
Well Purging
The purging techniques described below will be used for all groundwater sampling conducted
at the Mill unless otherwise stated in the program-specific QAPs for the chloroform and
nitrate investigations. The program-specific QAPs for the chloroform and nitrate
investigations are included as Appendix A and Appendix B respectively.
Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.
Turbidity measurement in the water should be < 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.
A flow-cell needs to be used for field parameters.
Mill - Groundwater Discharge Permit Date: 06 06 1208-15-17- Revision 7.23
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 50 of 67
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06 06 1208-15-17- Revision 7.33
Page 51 of 67
Procedure
a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)
b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;
c) Determine the casing volume (V) in gallons. When using the electronic data
collection module, input the depth to water in the appropriate location. The module
will calculate the casing volume. Proceed to purging. When the field data are
collected manually, calculate the casing volume -where h is column height of the
water in the well (calculated by subtracting the depth to groundwater in the well from
the total depth of the well), V = 0.653*h, for a 4” casing volume and V = .367*h for
a 3” casing volume. Record the casing volume on the Field Data Worksheet;
If a portable (non-dedicated) pump is used:
• Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
• Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.
If a non-dedicated pump or dedicated pump is used:
(i) Commence pumping;
(ii) For a non-dedicated pump only, Ddetermine pump flow rate by using a
stopwatch or other timing device and a calibrated bucket by measuring the
number of seconds required to fill to the one-gallon mark. Record this in the
“pumping rate” section ef-qnjhe Field Data Worksheet or in the “flow rate”
section in the electronic field collection module;
(iii) Calculate the amount of time to evacuate two or three casing volumes;
(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);
(v) If two casing volumes will be purged:
Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded either
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Page 52 of 67
electronically or on the Field Data Worksheet. Purging is completed after two
casing volumes have been removed and the field parameters pH, temperature,
specific conductance, redox potential (Eh) and turbidity have stabilized to
within 10% RPD over at least two consecutive measurements.
(vi) If three casing volumes will be purged:
Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements either electronically or on the Field Data
Worksheet.
(vii) If the well is purged to dryness:
Record the number of gallons purged either electronically or on the Field Data
Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.
Upon arrival at the well after recovery or when sufficient water is available for
sampling measure depth to water and record either electronically or on the
Field Data Worksheet.
Take one set of measurements of field parameters for pH, specific
conductance and temperature only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.
Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.
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Date: 06 06 1208-15-17- Revision 7.23
Page 53 of 67
Purging using a disposable bailer
For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.
When a bailer is used, the following procedure will be followed:
(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.
(ii) Attach a disposable bailer to a rope and reel.
(iii) Lower the bailer into the well and listen for contact with the solution. Once
contact is made, allow the bailer to gradually sink in the well, being careful
not to allow the bailer to come in contact with the bottom sediment.
(iv) After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.
(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.
(vi) Take field measurements from the water in the buckets.
All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.
After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
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Date: 06 06 1208-15-17- Revision 7.33
Page 54 of 67
Attachment 2-4
Sample Collection Procedures
Sample Collection Order
Regardless of the purging method employed samples will be collected in the order specified
below.
All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.
VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologics (fluoride, general inorganics, TDS, anions, total cations and total
anions); and
Gross alpha and heavy metals (filtered).
Sample Filtering
When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:
a) Obtain the specifically identified sample container for the type of sample to be
taken, as provided by the Analytical Laboratory;
b) Add the quantity of specified preservative provided by the Analytical Laboratory to
each sample container;
c) When using a pump to sample:
(i) Place a new 0.45 micron filter on the sample tubing;
(ii) Pump the sample through the filter, and into the sample container containing
the preservative;
(iii) The pump should be operated in a continuous manner so that it does not
produce samples that are aerated in the return tube or upon discharge;
d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples: (i)
(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.
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(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.
(iii) Place clean unused tubing in the peristaltic pump.
(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.
Procedures to Follow After Sampling
a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:
• Sample location
• Date and time of sample
• Any preservation method utilized
• Filtered or unfiltered
b) Immediately after sample collection, place each sample in an ice-packed cooler;
and
c) Before leaving the sampling location, thoroughly document the sampling event
either electronically or on the Field Data Worksheet, by recording all pertinent
data.
Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6° C. These samples shall be received by the Analytical Laboratory at less than or equal to
6° C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
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Date: 06 06 1208-15-17- Revision 7.23
Page 56 of 67
Attachment 2-5
Field QC Samples
Field Duplicates
Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.
Field duplicate samples should be as near to split samples as reasonably practicable.
Collection of field duplicates is completed as follows:
Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.
Field duplicate samples are labeled using a “false” well number such as MW-65 and MW-70.
Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samplesr collected from non­
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples.
Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:
Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;
Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).
Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter “R” added (e.g. MW-11R).
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06 1208-15-17 Revision 7.33
Page 57 of 67
Appendix A
Chloroform fevestigation Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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Date: 06 06 1208-15-17- Revision 7.23
Page 58 of 67
Chloroform Corrective Action Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
This document sets out the quality assurance plan to be used by Denison Mines (USA)
CerpEFRlT for Chloroform Investigation monitoring conducted pursuant to the Groundwater
Corrective Action Plan (“GCAP”') found in Attachment 1. of the final Stipulation and
Consent Order (“SCO”) dated September 14, 2Q15.State oT Utah-Notice of Violation and
Groundwater Corrective Action Order (UDEQ Docket No. UGW-20-01), (the “Order”).
Specifically, the Mill will use the same sampling regimen for the Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:
1) Dedicated Purge Pump/Sampling
Chloroform Investigation samples are collected by means of disposable bailer(s) the
day following the purging-._The disposable bailer is used only for the collection of a
sample from an individual well and disposed subsequent to the sampling. The wells
are purged prior to sampling by means of a portable pump. Each quarterly purging
event begins at the location least affected by chloroform (based on the previous
quarters sampling event) and proceeds by affected concentration to the most affected
location. Although purging will generally follows this order, the sampling order may
deviate slightly from the generated list. This practice does not affect the samples for
these reasons: any wells sampled in slightly different order have either dedicated
pumps or are sampled via a disposable bailer. This practice does not affect the quality
or usability of the data as there will be no cross-contamination resulting from
sampling order. Decontamination of all sampling equipment will follow the
decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Chloroform Investigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah- Netiee-eF-Violatieft-aRd Groundwater Corrective
Action Order UDEQ Docket No. UGW 20 01SCA and GCAP. Chloroform wells
shall be purged from the least contaminated to the most contaminated as based on the
most recent quarterly results.
•MW-4 •TW4-T320
•TW4-1 •TW4-4421
•TW4-2 •MW 26TW4-22
•TW4-3 •TW4-4623
•TW4-4 •MW 32TW4-24
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 59 of 67
TW4-5 • TW4-4825
TW4-6 • TW4-4926
TW4-7 • TW4-2Q27
TW4-8 • TW4-2428
TW4-9 • TW4-0479
TW4-10 • TW4-2430
TW4-11 • TW4-243!
TW4-12 • TW4-443?
TW4-2613 • TW4-2733
TW4-14 • TW4-34
MW-26 • TW4-35
TW4-16 • TW4-36
MW-32 • TW4-37
TW4-18 • TW4-38
TW4-19 • TW4-39
Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform
Investigation Program or the Groundwater Discharge Permit Monitoring Program.
3) Chloroform Investigation Sample Containers and Collection Volume
The chloroform investigation sampling program requires a specific number of
sampling containers and the collection of specific volumes of sample. Accordingly,
the following sample volumes are collected by bailer from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 100 250 ml
container.
• For Inorganic Chloride, collect one sample into a 400-500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements -and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements
Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
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Page 60 of 67
the laboratory the following analytical specifications must be adhered to:
Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
<6°C
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 gg/L 14 days HC1 to pH<2 < 6°C
Chloroform SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloromethane SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Inorganic
Chloride
A4500-C1 B
or A4500-C1
E
or E300.0
1 mg/L 28 days None <6°C
5) Field Parameters
Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. This includes the following wells: MW 4, MW 26,
TW4 4, TW 4 19 and TW 4 20. However, if a pumping well has been out of service
for 48 hours or more, DUS A EFRI shall follow the purging requirements outlined in
Attachment 2-3 of the QAP before sample collection.
Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.
6) Chloroform Investigation Quarterly Reports
The Chloroform Investigation Quarterly Reports will include the f-el-lowing
informatiom required by Part IP of the GCAP.
a) Introduction
b) Sampling and Monitoring Plan
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•—Description ef monitor wells
•—Description of sampling methodologyr-equipment and decontamination
procedures
•—Identify ali-qttality assurance samples.-e.g. trip-blanks, equipment blanks,
duplicate samples
c) Data Interpretation
•—Interpretation of groundwater levels, gradients; and flow-4k-eetions:
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time.- 3> deptlv-to groundwater measured and
groundwater elevation from each monitor we 11 s un h nari zed-in- a d at a t abler
that includes historic groundwater level data for each well, and 4) an
ev-aluatien-of the effectiveness of hydraulic capture of all contaminants of
concern.
•—Interpretation-of all-analytical results-4dr-each well, including a discussion
on; 1) a current chloroform isoconcentration map with one of the
isosconentration lines showing the 70 ug/L boundary, 2) graphs showing
chloroform concentration trends in each well through time and, 3)
analytical results for each well summarized in a data table, that includes
historic analytical results for each well.
•—Calculate chloroform mass removed by pumping wells. Calculations
would include: 1) total historic chloroform maas removed, 2) total historic
chloroform mass removed for each pumping well, 3) total chloroform
mass removed for the quarter and, 4) total chloroform mass removed from
each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Chloroform Investigation
momtoring c-on^ueted during the quarter;-
f) —Copies-of DC-S-A-field records, laboratory reports and chain of custody forms.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.
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Date: 06 06 1208-15-17- Revision 7.23
Page 62 of 67
Appendix B
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill - Groundwater Discharge Permit
Groundwater Monitoring
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Date: 06-064308-15-17- Revision 7.23
Page 63 of 67
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring (“Nitrate Program”) conducted pursuant to the
Stipulation and Consent Order (“SCO”), Docket Number UGW12-04, which approved the
EFRI CAP, dated May 7, 2012State of Utah Stipulated Consent Agreement Docket Number
UGW 09-03 A.
Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan (QAP), except as set forth
below:
1) Purge Pump/Sampling
The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.
Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross­
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Nitrate Program Sampling Frequency, Order and Locations
The Nitrate Program wells listed below are required to be monitored on a quarterly
basis under State of Utah Docket No. UGW 09 03 Aas required by the SCO, Docket
Number UGW 12-04, which approved the EFRI CAP, dated May 7, 2012. DUS A has
submitted a- Corrective Action Plan (“CAP”) as required by the Stipulated Consent
Agreement. In that CAP, DUS A has proposed the abandonment of a number of the
wells listed below. The implementation of the CAP, shall supersede any requirements
contained in this QAP and Appendix. Nitrate Program wells shall be purged from the
least contaminated to the most contaminated as based on the most recent quarterly
results.
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Date: 06 06 1208-15-17- Revision 7.33
Page 64 of 67
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Date: 06 06 1208-15-17- Revision 7.23
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TWN-1
TWN-2
TWN-3
TWN-4
TWN 5*
TWN-6**
..-TWN.1-3*
• TWN-14**
• TWN 15*
• TWN-16**
• TWN 17*
• TWN-18
TWN-19**
Piezometer-01
Piezometer-02
Piezometer-03A
TWN 11*
TWN 12*
TWN-7 •
--TW-N--8*•
TWN 9*•
TWN 10*•
* Recommended for-abandonment
**Recommended for Ddepth to water measurements only. OTIS A has proposed
that monitoring ceaser
7) Nitrate Program Sample Containers and Collection Volume
The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Nitrate/Nitrite determinations, collect one sample into a 490-250 ml
container.
• For Inorganic Chloride, collect one sample into a 400-500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements
Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
| Mill - Groundwater Discharge Permit
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Date: 06 06 1208-15-17- Revision 7.33
Page 66 of 67
Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
<6°C
Inorganic
Chloride
A4500-C1 B
or A4500-C1
E
or E300.0
1 mg/L 28 days None <6°C
9) Field Parameters
Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.
10) Nitrate Program Investigation Reports
The Nitrate Program Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
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Date: 06 064308-15-17- Revision 7.33
Page 67 of 67
• Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate mass
removed from each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.
f) Copies of BUSA-EFRl field records, laboratory reports and chain of
custody forms.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.
CLEAN
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
State of Utah
Groundwater Discharge permit No. UGW370004
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Page 1 of 60
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Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 2 of 60
TABLE OF CONTENTS
1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/QC Program 6
2.3 Data Requestors/Users 6
2.4 Data Generators 7
2.4.1 Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
2.5 Responsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3.1 Precision 9
3.2 Accuracy 10
3.3 Representativeness 10
3.4 Completeness 10
3.5 Comparability 10
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.1 VOC Trip Blanks 11
4.3.2 Equipment Rinsate Samples 11
4.3.3 Field Duplicates 13
4.3.4 Definition of “Batch” 13
5.0 CALIBRATION 13
5.1 Depth to Groundwater Measurements 13
5.2 Water Quality 13
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 3 of 60
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 13
6.1 Groundwater Head Monitoring 13
6.1.1 Location and Frequency of Groundwater Head Monitoring 14
6.1.2 Groundwater Head Monitoring Frequency 14
6.2 Ground Water Compliance Monitoring 14
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 14
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E. Lb) or I.E.l.c) of the GWDP 15
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.l or I.G.2 of the GWDP 15
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 15
6.2.5 Decontamination Procedure 16
6.2.6 Pre-Purging/ Sampling Activities 16
6.2.7 Well Purging/Measurement of Field Parameters 16
6.2.8 Samples to be taken and order of taking samples 16
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 17
7.1 Field Data Worksheets 17
7.2 Chain-Of-Custody and Analytical Request Record 18
7.3 Record Keeping 19
8.0 ANALYTICAL PROCEDURES AND QA/QC 19
8.1 Analytical Quality Control 19
8.1.2 Spikes, Blanks and Duplicates 20
8.2 Analytical Laboratory Procedures 21
9.0 INTERNAL QUALITY CONTROL CHECKS 25
9.1 Field QC Check Procedures 25
9.1.1 Review of Compliance With the Procedures Contained in this QAP 25
9.1.2 Analyte Completeness Review 25
9.1.3 Blank Comparisons 25
9.1.4 Duplicate Sample Comparisons 26
9.2 Analytical Laboratory QA Reviews 27
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 27
9.4 Analytical Data 28
10.0 CORRECTIVE ACTION 29
10.1 When Corrective Action is Required 29
10.2 Procedure for Corrective Action 29
Date: 08-15-17 Revision 7.3
11.0 REPORTING 30
12.0 SYSTEM AND PERFORMANCE AUDITS 31
12.1 QA Manager to Perform System Audits and Performance Audits 31
12.2 System Audits 31
12.3 Performance Audits 32
12.4 Follow-Up Actions 32
12.5 Audit Records 32
13.0 PREVENTIVE MAINTENANCE 32
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 33
14.1 Ongoing QA7QC Reporting 33
14.2 Periodic Reporting to Management 33
15.0 AMENDMENT 33
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 4 of 60
16.0 REFERENCES 34
Date: 08-15-17 Revision 7.3
ATTACHMENTS
Attachment 1 Field and Data Forms
Attachment 1-1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example Field Data Report
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures
Attachment 2-2 Decontamination Procedures
Attachment 2-3 Purging Procedures
Attachment 2-4 Sample Collection Procedures
Attachment 2-5 Field QC Samples
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 5 of 60
APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
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1.0 INTRODUCTION
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This Groundwater Monitoring Quality Assurance Plan (the “QAP”) details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary to
comply with UAC R317-6-6.3(1) and (L) at the White Mesa Uranium Mill (the “Mill”), as
required by the State of Utah Groundwater Discharge Permit No. UGW370004 (the
“GWDP”) for the Mill. This Procedure incorporates the applicable provisions of the United
States Environmental Protection Agency (“EPA”) RCRA Groundwater Monitoring Technical
Enforcement Guidance Document (OSWER-9950.1, September, 1986), as updated by EPA’s
RCRA Ground-Water Monitoring: Draft Technical Guidance (November 1992).
Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or “QA”) and as functional (i.e., quality control or “QC”). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBILITIES
2.1 Functional Groups
This QAP specifies roles for a QA Manager as well as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.
2.2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QA/QC measures are properly employed is the
responsibility of the QA Manager. The QA Manager is typically not directly involved in the
data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Energy Fuels Resources (USA) Inc. (“EFRI”) corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits and applicable regulations.
Accordingly, the data requesters/users (the “Data Users”) are therefore EFRFs corporate
management and regulatory authorities through the implementation of such permits and
regulations. The data quality objectives (“DQOs”) required for any groundwater sampling
event, such as acceptable minimum detection limits, are specified in this QAP.
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2.4 Data Generators
The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors (each a “Sampling and QC Monitor”). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at the
contract analytical laboratory (the “Analytical Laboratory”) utilized by the Mill to analyze the
environmental samples is performed by or under an employee or agent (the “Analysis
Monitor”) of the Analytical Laboratory, in accordance with specific requirements of the
Analytical Laboratory’s own QA/QC program.
The responsibilities of the data generators are as follows:
2.4.1 Sampling and QC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the samples,
to the Analytical Laboratory in accordance with this QAP;
c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing of
those samples at the conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling
event;
e) Preparing QC and sample data for review by the QA Manager; and
f) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
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2.4.2 Analysis Monitor
The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory’s QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program (“NELAP”) certification.
2.4.3 Data Reviewers/Approvers
The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:
a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;
b) Making on-site evaluations and submitting audit samples to assist in reviewing
QA/QC procedures;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.
2.5 Responsibilities Of Analytical Laboratory
Unless otherwise specified by EFRI corporate management, all environmental analysis of
groundwater sampling required by the GWDP or by other applicable permits, will be
performed by a contract Analytical Laboratory.
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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining National Environmental Laboratory Accreditation Program
(“NELAP”) certification, which is a national accreditation program developed by the NELAC
institute (“TNI”).
In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U.S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory Guide
4.14.
The Analytical Laboratory will be chosen by EFRI and must satisfy the following criteria:
(1) experience in analyzing environmental samples with detail for precision and accuracy, (2)
experience with similar matrix analyses, (3) operation of a stringent internal quality assurance
program meeting NELAP certification requirements and that satisfies the criteria set out in
Section 8 below, (4) ability to satisfy radionuclide requirements as stipulated in the
applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical
procedures used by the Analytical Laboratory will be in accordance with Utah Administrative
Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management puiposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QA/QC measures are deemed more reliable than data without any
QA/QC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference (“RPD”) of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
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percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW-846,
Chapter 1, Section 5.0, page 27 - 28).
3.2 Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:
% Recovery = (A-B /C) x 100
Where:
A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:
Completeness = (Number of valid data points/total number of measurements) x 100
Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion of the data validation.
The Director (“Director”) of the Utah Division of Waste Management and Radiation Control)
(“DWMRC”) approval will be required for any completeness less than 100 percent.
3.5 Comparability
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Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection
techniques, measurement procedures, methods, and reporting units are consistent for all
samples within a sample set.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.
4.3 Water Quality QC Samples
Quality assurance for groundwater monitoring consists of the following QC samples:
4.3.1 VOC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds (“VOCs”) through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.
4.3.2 Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non­
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples. Rinsate
blanks will be collected after decontamination and prior to subsequent use. Rinsate blank
samples for a non-dedicated pump are prepared by pumping de-ionized water into the sample
containers. Rinsate blank samples for a non-disposable or non-dedicated bailer are prepared
by pouring de-ionized water over and through the bailer and into the sample containers.
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Equipment rinsate blanks will be analyzed only for the contaminants required during the
monitoring event in which they are collected.
Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
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4.3.3 Field Duplicates
Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.
Field duplicate sampling procedures are described in Attachment 2-5.
4.3.4 Definition of “Batch”
For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers’ recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to use as noted
in Attachment 2 to ensure that the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer’s specifications (for
example, by using two known pH solutions and one specific conductance standard.) Per the
manufacturer, temperature cannot be calibrated but will be periodically checked
comparatively by using a thermometer. Conductivity and pH calibration results will be
recorded as described in Section 7.1.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1 Groundwater Head Monitoring
Groundwater head measurements (“depth to water”) will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
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6.1.1 Location and Frequency of Groundwater Head Monitoring
Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a) All Point of Compliance wells listed in the GWDP;
b) Monitoring well MW-34;
c) All piezometers (P-1, P-2, P-3 A, P-4, P-5 and the Dry Ridge piezometers);
d) All contaminant investigation wells required by the Director as part of a
contaminant investigation or groundwater corrective action (chloroform and
nitrate wells).
6.1.2 Groundwater Head Monitoring Frequency
Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an electronic
data management system (spreadsheet and/or database). The data from the quarterly depth to
water measurements will be included in the quarterly reports.
In addition, weekly and monthly depth to groundwater measurements are taken in the chloroform
pumping wells MW-4, MW-26, TW4-1, TW4-2, TW4-11, TW4-19, TW4-20, TW4-4, TW4-21,
TW4-37, TW4-39 (starting in December 2016), and the nitrate pumping wells TW4-22, TW4-24,
TW4-25, and TWN-2.
The depth to groundwater measured immediately prior to purging/sampling will be recorded
for each well as described in Section 7.1.
6.2 Ground Water Compliance Monitoring
6.2.1 Location and Frequency of Groundwater Compliance Monitoring
Groundwater quality shall be measured in the wells specified in the GWDP at the frequencies
specified in the GWDP. In addition, the Chloroform Investigation and Nitrate Corrective
Action wells will be sampled quarterly as described in Appendix A and Appendix B of this
QAP.
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a)
Accelerated quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in the GWDP. Sampling personnel should
coordinate with the QA Manager prior to conducting any monitoring well sampling to
determine if any parameters in any wells are subject to accelerated monitoring.
6.2.2 Quarterly and Semi-Annual Sampling Required In Accordance With the GWDP
All quarterly and semi-annual samples collected in accordance with the GWDP shall be
analyzed for the following parameters:
a) Field parameters - depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics - chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.
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6.2.3 Accelerated Quarterly or Monthly Sampling Required By the GWDP
Any quarterly or monthly accelerated sampling required by the GWDP shall be analyzed for
the specific parameters as required by previous sampling results as determined by the QA
Manager.
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.
Purging and sampling equipment is described in Attachment 2-3 of this QAP.
Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;
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6.2.5 Decontamination Procedure
Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.
6.2.6 Pre-Purging/ Sampling Activities
Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well’s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.
6.2.7 Well Purging/Measurement of Field Parameters
The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging wells prior to sampling removes the stagnant water column present in the well casing
and assures that representative samples of the formation water are collected. Purging will be
completed as described in Attachment 2-3.
There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows: 1 2 3
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
6.2.8 Samples to be taken and order of taking samples
For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP. The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single container
due to like sampling requirements (filtering) and/or like preservation. The container
requirements will be determined by the Analytical Laboratory and specified with the bottles
supplied to the Field Personnel. Bottle requirements may change if the Analytical Laboratory
is changed or if advances in analytical techniques allow for reduced samples volumes. The
following list is a general guideline.
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a) VOCs, 3 sample containers, 40 ml each;
b) Nutrients (ammonia, nitrate/nitrite as N), 1 sample container, 250 ml;
c) All other non-radiologics (anions, general inorganics, TDS, total cations and total
anions), 2 sample containers, 500 and 250 ml,;
d) Gross alpha, 1 sample container, 1,000 ml, filtered; and
e) Metals, 1 sample container, 500 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.
Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1 Field Data Collection
Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded.
Field data collection will be completed using either an electronic device (such as a tablet) or a
hardcopy form. Hardcopy forms will be completed in waterproof ink. If field data collection
is completed using an electronic device, a data report for each well sampled will be printed
after the completion of the sampling event and signed by one member of the sampling crew.
The signed sheets will be maintained on file and the Mill and will be included in the quarterly
reports. The electronic data collection will be accomplished using a standardized collection
module. An example of a hardcopy field collection form as well as an example data report are
included as Attachment 1A and IB respectively.
The hardcopy data sheets and data reports included herein are examples and may be changed
to accommodate additional data collection. If a change is made to a data sheet to
accommodate additional information, a copy will be provided to the Director. Changes to
hardcopy field forms and data reports will not eliminate any data collection activity without
written approval of the Director.
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Regardless of the field data collection method, the following information will be collected:
• Name of the site/facility
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• description of sampling event
• location of sample (well name)
• sampler’s name(s) and/or initials(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
Field data collection will also include detailed notes describing any other significant factors
noted during the sampling event as necessary, including, as applicable: condition of the well
cap and lock; water appearance, color, odor, clarity; presence of debris or solids; any
variances from this procedure; and any other relevant features or conditions.
7.2 Chain-Of-Custody and Analytical Request Record
the
set.
the
following:
• sampler’s name
• company name
• date and time of collection
• sample matrix (e.g., water)
• sample location
• number of sample containers in the shipping container
• analyses requested
• signatures of persons involved in the chain of possession
• interna] temperatures of the shipping container when opened at the laboratory
A Chain-of-Custody (the “COC Form”) will accompany the samples being shipped to
Analytical Laboratory. Standard Chain-of-Custody protocol is initiated for each sample
A COC Form is to be completed for each set of samples collected and is to include
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• remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.
Chain-of-Custody reports will be' placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratory will sign the COC Form,
document shipment method, and send the original COC Form with the samples. Upon
receipt of the samples, the person receiving the samples will sign the COC Form and return
an electronic copy to the Mill and the QA Manager.
Copies of the COC Forms and other relevant documentation will be retained at the Mill.
7.3 Record Keeping
The data collection records are retained in an electronic database and hardcopies are retained
at the Mill.
Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.
EFRI will ensure that the Analytical Laboratory or Laboratories used, have certifications for
each parameter and method required by Section 8.2, Table 1 of the QAP. The QA Manager
will check the Utah certifications at least annually.
Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the field and from the data packages are managed using electronic data management
software. The data management software will be managed and administered by the QA
Manager or designee.
8.0 ANALYTICAL PROCEDURES AND QA/QC
Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.
8.1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, EFRI shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP, is capable of performing the
analytical procedures specified in Section 8.2, and that the QA/QC program of the Analytical
Laboratory includes the spikes, blanks and duplicates described in Section 8.1.2.
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8.1.2 Spikes. Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
The following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:
a) Matrix Spike/Matrix Spike Duplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.
b) Method Blanks
Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.
c) Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normally found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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d) Check Sample
Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Director. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.
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Table 1
Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Nutrients
Ammonia (as N)A4500-
NH3 G or
E350.1
0.05 mg/L 28 days H2SO4 to
pH<2
<6°C
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
<6°C
Heavy Metals
Arsenic E200.7 or
E200.8
5 pg/L 6 months HN03 to pH<2 None
Beryllium E200.7 or
E200.8
0.50 pg/L 6 months HNO3 to pH<2 None
Cadmium E200.7 or
E200.8
0.50 pg/L 6 months HNO3 to pH<2 None
Chromium E200.7 or
E200.8
25 pg/L 6 months HN03 to pH<2 None
Cobalt E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Copper E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Iron E200.7 or
E200.8
30 pg/L 6 months HN03 to pH<2 None
Lead E200.7 or
E200.8
1.0 pg/L 6 months HNO3 to pH<2 None
Manganese E200.7 or
E200.8
10 pg/L 6 months HN03 to pH<2 None
Mercury E 245.1 or
E200.7 or
E200.8
0.50 pg/L 28 days HNO3 to pH<2 None
Molybdenum E200.7 or
E200.8
10 pg/L 6 months HNO3 to pH<2 None
Nickel E200.7 or
E200.8
20 pg/L 6 months HNO3 to pH<2 None
Selenium E200.7 or
E200.8
5 pg/L 6 months HN03 to pH<2 None
Silver E200.7 or
E200.8
10 pg/L 6 months HN03 to pH<2 None
Thallium E200.7 or
E200.8
0.50 pg/L 6 months HN03 to pH<2 None
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 23 of 60
Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Tin E200.7 or
E200.8
100 pg/L 6 months HN03 to pH<2 None
Uranium E200.7 or
E200.8
0.30 pg/L 6 months HN03 to pH<2 None
Vanadium E200.7 or
E200.8
15 pg/L 6 months HN03 to pH<2 None
Zinc E200.7 or
E200.8
10 pg/L 6 months HN03 to pH<2 None
Radiologies
Gross Alpha E 900.0 or
E900.1
1.0 pCi/L 6 months HN03 to pH<2 None
Volatile
Organic
Compounds
Acetone SW8260B
or
SW8260C
20 pg/L 14 days HC1 to pH<2 < 6°C
Benzene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
2-Butanone
(MEK)
SW8260B
or
SW8260C
20 pg/L 14 days HC1 to pH<2 <6°C
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloroform SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloromethane SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
Naphthalene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
Tetrahydrofuran SW8260B 1.0 pg/L 14 days HC1 to pH<2 <6°C
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 24 of 60
Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirements
Sample
Temperature
Requirements
or
SW8260C
Toluene SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Xylenes (total)SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Others
Field pH (S.U.)A4500-H
B
0.01 s.u.Immediate None None
Fluoride A4500-F C
or E300.0
0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None <6°C
General
Inorganics
Chloride A4500-C1
B or
A4500-C1
E
or E300.0
1 mg/L 28 days None None
Sulfate A4500-
S04 E or
E300.0
1 mg/L 28 days None < 6°C
Carbonate as
C03
A2320 B 1 mg/L 14 days None <6°C
Bicarbonate as
HC03
A2320 B 1 mg/L 14 days None <6°C
Sodium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
Potassium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
Magnesium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
Calcium E200.7 0.5 mg/L 6 months HN03 to pH<2 None
1. The Analytical Laboratory will be required to meet the reporting limits (“RLs”) in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Director.
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
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Quality Assurance Plan (QAP) Page 25 of 60
9.0 INTERNAL QUALITY CONTROL CHECKS
Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QA/QC analysis of field procedures:
9.1.1 Review of Compliance With the Procedures Contained in this QAP
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.
9.1.2 Analyte Completeness Review
The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non­
conformance as required by the Permit. Director approval will be required for any
completeness (prior to QA/QC analysis) less than 100 percent. Non-conformance will be
defined as a failure to provide field parameter results and analytical results for each parameter
and for each well required in Sections 6.2.2 and 6.2.3, for the sampling event, without prior
written Director approval.
9.1.3 Blank Comparisons
Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not an order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).
Corrective actions for blank comparison non-conformance shall first determine if the non­
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will: 1 2 3
1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
Date: 08-15-17 Revision 7.3
4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.
9.1.4 Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
a) Relative Percent Difference.
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Quality Assurance Plan (QAP) Page 26 of 60
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD >_20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994, 9240.1-05-01, p. 25).
b) Radiologies Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.
c) Radiologies, Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
A-B /(Sa'+Stf)1^ < 2
Where:
A = the first duplicate measurement
B = the second duplicate measurement
sa2 = the uncertainty of the first measurement squared
Sb" = the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.
(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).
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Date: 08-15-17 Revision 7.3
Page 27 of 60
Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non­
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
9.2 Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data assessment
will be a part of the validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following:
(1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
(4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the
QA/QC data. The Analytical Laboratory will provide the following information:
(1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
(4) QA/QC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
a) Reporting Limit (RL) Comparisons
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Date: 08-15-17 Revision 7.3
Page 28 of 60
The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory
are those specified in Table 1, unless otherwise approved by the Director. Non-conformance
shall be defined when the Analytical Laboratory uses analytical methods not listed in Table 1
and not otherwise approved by the Director.
c) Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.
9.4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory’s QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to EFRI as requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory’s record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.
If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will be
consulted to establish more appropriate analytical approaches for problem samples.
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
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Quality Assurance Plan (QAP) Page 29 of 60
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted during field data collection. Any QA/QC problems
that arise will be brought to the immediate attention of the QA Manager. Analytical
Laboratory deviations will be recorded by the Analysis Monitor in a logbook as well.
When a procedural or systematic non-conformance is identified, EFRI shall:
a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to be
systematic or procedural, EFRI shall determine the root cause, and provide specific
steps to resolve problems(s) in accordance with the procedure set forth in Section
10.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Director on or
before submittal of the next quarterly ground water monitoring report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 10 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in the
same quarterly monitoring report with other samples collected for the same sampling
event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.
10.2 Procedure for Corrective Action
The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QA/QC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem;
b) Assignment of responsibility for investigating the problem;
c) Investigation and determination of the cause of the problem;
d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action;
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Date: 08-15-17 Revision 7.3
Page 30 of 60
f) Implementing the corrective action and evaluating its effectiveness; and
g) Verifying that the corrective action has eliminated the problem.
The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. The corrective actions will be documented either in a
memorandum explaining the steps outlined above, which will be placed in the applicable
monitoring files and the Mill Central Files, or the corrective action will be documented in the
quarterly reports prepared in accordance with Section 11.
11.0 REPORTING
As required by the GWDP, the Mill will send a groundwater monitoring report to the
Director on a quarterly basis. Both the Routine Groundwater Monitoring Reports and
Chloroform Investigation and Nitrate Corrective Action Reports shall be submitted according
to the following schedule:
Quarter Period Due Date
First January - March June 1
Second April - June September 1
Third July - September December 1
Fourth October - December March 1
The Routine Groundwater Monitoring Reports (required by the GWDP) will include the
following information:
• Description of monitor wells sampled
• Description of sampling methodology, equipment an decontamination
procedures to the extent they differ from those described in this QAP
• A summary data table of groundwater levels for each monitor well and
piezometer
• A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to the GWDP or are out of compliance in any particular wells
pursuant to the GWDP
• Field data recorded during sample collection
• Copies of Analytical Laboratory results
• Copies of Chain of Custody Forms (included in the data packages)
• A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
• Evaluation of groundwater levels, gradients and flow directions
Date: 08-15-17 Revision 7.3
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this QAP and all corrective actions taken
With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.
In addition, an electronic copy of all analytical results will be transmitted to the DWMRC in
comma separated values (“CSV”) format, or as otherwise advised by the DWMRC.
Further reporting may be required as a result of accelerated monitoring under the GWDP.
The frequency and content of these reports will be defined by EFRI corporate management
working with the Director.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
EFRI shall perform such system audits and performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined
by EFRI.
12.2 System Audits
System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
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Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
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12.3 Performance Audits
The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer’s specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded and addressed as soon as practical.
The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a scheduled
basis to minimize downtime and the potential interruption of analytical work.
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
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Quality Assurance Plan (QAP) Page 33 of 60
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
The following reporting activities shall be undertaken on a regular basis:
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QA/QC issues associated with such sampling
activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill’s QA Manager or his staff will
identify the analytical methods performed and all QA/QC measures not within the
established control limits. Any QA/QC problems will be brought to the QA
Manager’s attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report (case narrative) will be prepared by the
Analytical Laboratory for review by the QA Manager, by a Sampling and QC
Monitor or by such other qualified person as may be designated by the QA Manager.
The report will be prepared in accordance with NELAP requirements and will
summarize the data validation efforts and provide an evaluation of the data quality.
14.2 Periodic Reporting to Management
The QA Manager shall present a report to EFRI’s ALAR A Committee at least once per
calendar year on the performance of the measurement system and the data quality. These
reports shall include:
a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;
b) Results of any performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and
d) Significant QA problems and recommended solutions.
15.0 AMENDMENT
This QAP may be amended from time to time by EFRI only with the approval of the
Director.
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Date: 08-15-17 Revision 7.3
Page 34 of 60
16.0 REFERENCES
United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.
United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.
Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
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Date: 08-15-17 Revision 7.3
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ATTACHMENT 1
Field and Data Forms
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 36 of 60
Attachment 1-1
Quarterly Depth to Water Data Sheet
NAME:
DATE:
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 37 of 60
c/ve/ro v^Lse/. s
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEETFOR GROUNDWATER
See instruction
Description of Sampling Event:
Location (well name):
Field Sample ID
Sampler Name
and initials:
Date and Time for Purging
Well Purging Equip Used:□pump or bailer
Purging Method Used: □ 12 casings □ |3 casings
Sampling Event
pH Buffer 7.0
and Sampling (if different)
Well Pump (if other than Bennet)
Prev. Well Sampled in Sampling Event
pH Buffer 4.0
Specific Conductance pMHOS/ cm Well Depth(O.Olft):
Depth to Water Before Purging Casing Volume (V) 4" Well:
3" Well:
(,653h)
(.367h)
Weather Cond.Ext'l Amb. Temp. °C (prior sampling event)
Time
Conductance
Temp. °C
Gal. Purged
PH
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged
□ PH
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged
pH
Redox Potential Eh (mV) Q
Turbidity (NTU)
Time
Conductance
Temp. °C
Gal. Purged [
□ PH I
Redox Potential Eh (mV) [
Turbidity (NTU)
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Date: 08-15-17 Revision 7.3
Page 38 of 60
Volume of Water Purged
Pumping Rate Calculation
Flow Rate (Q), in gpm.
S/60 =
gallon(s)
Time to evacuate two casing volumes (2V)
T = 2V/Q = '
Number of casing volumes evacuated (if other than two)
If well evacuated to dryness, number of gallons evacuated
Name of Certified Analytical Laboratory if Other Than Energy Labs
Type of Sample Sample Taken Sample Vol (indicate if
other than as specified
below)
Filtered Preservative
Type
Preservative Added
Y N Y N Y N
VOCs □□3x40 ml □□HCL □□
Nutrients □□100 ml □□H2S04 □ □
Heavy Metals □□250 ml □ □HN03 □□
All Other Non Radiologies □□250 ml □□No Preserv.□□
Gross Alpha □□1.000 ml □□HN03 □□
Other (specify)□ □
Sample volume □ □□□
If preservative is used, specify
Type and Quantity of
Preservative:
Final Depth Sample T ime
Comment
See instruction
JDo not touch this cell (SheetName)
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 39 of 60
ATTACHMENT 1-3
EXAMPLE FIELD DATA REPORT
Sheet 1 of 2
White Mesa Mill
Field Data Worksheet For Groundwater
Groundwater Discharge Permit
Groundwater Monitoring Quality Assurance Plan
Location ID MW-14
Field Sample ID MW-14 12062016
Purqe Date & Time 12/21/2016 14:32
Sample Date & Time 12/21/2016 14:32
Sampling Program Baseline
Sampling Event GW Event
Sampler__________________________________________|_________Timothy
Purging Equipment Pump
Pump Type QED
Purging Method 2 Casings
Casing Volume (gal)19.7
pH Buffer 7.0 7.0
pH Buffer 4.0 4.0
Specific Conductance 0 1000
Weather Conditions Cloudy
External Ambient Temperature (C)17
Previous Well Sampled MW-26
Well Depth (feet)118
Well Casing Diameter (inches)4
Depth to Water Before Purging (to 0.01 feet)103.02
Date/Time Gallons Purged Specific Conductance pH Temp (Deg C)Redox Potential Turbidity Before/After
12/6/2016 14:39 39.49 3908 6.4 14.31 363 0 Before
12/6/2016 14:40 39.71 3900 6.38 14.29 362 0 After
Pumping Rate Calculations
1 Volume of water purged (gal)40.17 Row Rate (Q = S/60) (qpm) .217
Time to evacuate 2 Casing Volumes (min)181.63
iFinal Depth to Water (feet) [97.55 Number of casing Volumes 2
Volume, if well evacuated to dryness (qal)0
Name of Certified Analytical Laboratory
AWSL_______________________________
Sample Analysis Information
Type of Sample/Analysis Sample Collected?Matrix
Container
Sample Filtered?
Preservative
Number Type Type Added?
VOCs Y WATER 1 3x40 ml N HCI Y
Nutrients Y WATER 1 100 ml N H2S04 Y
Heavy Metals Y WATER 1 250 ml N HN03 Y
All other non Radiologies Y WATER 1 250 ml N None N
Gross Alpha Y WATER 1 1000 ml N HN03 Y
Comments:
Not Continuous Well
Signature of Field Technician
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 40 of 60
ATTACHMENT 2
Field Procedures
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 41 of 60
Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures
Measure and record all depth to water data to the nearest 0.01 feet.
Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist - IT 300 or
equivalent device (the “Water Level Indicator”).
Equipment Checks
Equipment used in depth to groundwater measurements will be checked prior to each day’s
use to ensure that the Water Sounding Device is functional.
Check the Water Sounding Device as follows:
• Turn the Water Level Indicator on.
• Test the Water Level Indicator using the test button located on the instrument.
• If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.
Measurement of Depth to Water
All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:
• For monitoring wells - Measure depth to water from the top of the inner well casing at
the designated measurement point.
• For the piezometers - Measure depth to water from the top of the casing at the
designated measurement point.
• Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
• Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 42 of 60
Attachment 2-2
Decontamination Procedures
Non-dedicated sampling equipment will be decontaminated using the following
procedures:
Water level meter
Decontaminate the water level meter probe with deionized (“01”) water..
Field Parameter Instrument (Hydrolab or equivalent)
Rinse the field parameter instrument probe unit with DI water prior to each
calibration.
Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.
Non-Dedicated Purging/Sampling Pump
Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:
a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;
b) pump the detergent/DI water solution through the pump and pump outlet lines;
c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
d) submerge the pump into a 55-gallon drum of DI water;
e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;
f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 43 of 60
h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).
All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 44 of 60
Attachment 2-3
Purging Procedures
The following equipment will be used for groundwater purging and sampling:
• Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
• Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
• Non - Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
• Field Parameter Meter: A meter used to measure groundwater quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:
> Water temperature;
> Specific conductivity;
> Turbidity;
> pH;
> Redox potential (Eh).
• Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
• Generator: Mobile power supply to provide power for submersible pump.
• 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
“bladder” pumps.
Additional supplies for purging and sampling are as follows:
• IPad, tablet, Cell phone or Field Data Sheets
• 45 micron in-line filters (when metals and gross alpha analyses are required)
• Calculator
• Clock, stopwatch or other timing device
• Buckets
• Sampling containers (as provided by the Analytical Laboratory)
• Field preservation chemicals (as provided by the Analytical Laboratory)
• Disposable gloves
• Appropriate health and safety equipment
• Sample labels (as provided by the Analytical Laboratory)
Date: 08-15-17 Revision 7.3
Pre-Purging/ Sampling Activities
If a portable (non-dedicated) pump is to be used, prior to commencing the event’s sampling
activities,
1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) and ice into a cooler that will
transport the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC)
samples throughout the monitoring event.
Well Purging
The purging techniques described below will be used for all groundwater sampling conducted
at the Mill unless otherwise stated in the program-specific QAPs for the chloroform and
nitrate investigations. The program-specific QAPs for the chloroform and nitrate
investigations are included as Appendix A and Appendix B respectively.
Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.
Turbidity measurement in the water should be < 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.
A flow-cell needs to be used for field parameters.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 45 of 60
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 46 of 60
Procedure
a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)
b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;
c) Determine the casing volume (V) in gallons. When using the electronic data
collection module, input the depth to water in the appropriate location. The module
will calculate the casing volume. Proceed to purging. When the field data are
collected manually, calculate the casing volume where h is column height of the
water in the well (calculated by subtracting the depth to groundwater in the well from
the total depth of the well), V = 0.653*h, for a 4” casing volume and V = ,367*h for
a 3” casing volume. Record the casing volume on the Field Data Worksheet;
If a portable (non-dedicated) pump is used:
• Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
• Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.
If a non-dedicated pump or dedicated pump is used:
(i) Commence pumping;
(ii) For a non-dedicated pump only, determine pump flow rate by using a
stopwatch or other timing device and a calibrated bucket by measuring the
number of seconds required to fill to the one-gallon mark. Record this in the
“pumping rate” section on the Field Data Worksheet or in the “flow rate”
section in the electronic field collection module;
(iii) Calculate the amount of time to evacuate two or three casing volumes;
(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);
(v) If two casing volumes will be purged:
Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded either
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 47 of 60
electronically or on the Field Data Worksheet. Purging is completed after two
casing volumes have been removed and the field parameters pH, temperature,
specific conductance, redox potential (Eh) and turbidity have stabilized to
within 10% RPD over at least two consecutive measurements.
(vi) If three casing volumes will be purged:
Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements either electronically or on the Field Data
Worksheet.
(vii) If the well is purged to dryness:
Record the number of gallons purged either electronically or on the Field Data
Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.
Upon arrival at the well after recovery or when sufficient water is available for
sampling measure depth to water and record either electronically or on the
Field Data Worksheet.
Take one set of measurements of field parameters for pH, specific
conductance and temperature only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.
Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 48 of 60
Purging using a disposable bailer
For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.
When a bailer is used, the following procedure will be followed:
(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.
(ii) Attach a disposable bailer to a rope and reel.
(iii) Lower the bailer into the well and listen for contact with the solution. Once
contact is made, allow the bailer to gradually sink in the well, being careful
not to allow the bailer to come in contact with the bottom sediment.
(iv) After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.
(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.
(vi) Take field measurements from the water in the buckets.
All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.
After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 49 of 60
Attachment 2-4
Sample Collection Procedures
Sample Collection Order
Regardless of the purging method employed samples will be collected in the order specified
below.
All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.
VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologics (general inorganics, TDS, anions, total cations and total anions);
and
Gross alpha and heavy metals (filtered).
Sample Filtering
When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:
a) Obtain the specifically identified sample container for the type of sample to be
taken, as provided by the Analytical Laboratory;
b) Add the quantity of specified preservative provided by the Analytical Laboratory to
each sample container;
c) When using a pump to sample:
(i) Place a new 0.45 micron filter on the sample tubing;
(ii) Pump the sample through the filter, and into the sample container containing
the preservative;
(iii) The pump should be operated so that it does not produce samples that are
aerated in the return tube or upon discharge;
d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:
(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 50 of 60
(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.
(iii) Place clean unused tubing in the peristaltic pump.
(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.
Procedures to Follow After Sampling
a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:
• Sample location
• Date and time of sample
• Any preservation method utilized
• Filtered or unfiltered
b) Immediately after sample collection, place each sample in an ice-packed cooler;
and
c) Before leaving the sampling location, thoroughly document the sampling event
either electronically or on the Field Data Worksheet, by recording all pertinent
data.
Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6° C. These samples shall be received by the Analytical Laboratory at less than or equal to
6° C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
Date: 08-15-17 Revision 7.3
Attachment 2-5
Field QC Samples
Field Duplicates
Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.
Field duplicate samples should be as near to split samples as reasonably practicable.
Collection of field duplicates is completed as follows:
Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.
Field duplicate samples are labeled using a “false” well number such as MW-65 and MW-70.
Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non­
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples.
Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:
Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;
Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).
Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter “R” added (e.g. MW-11R).
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 51 of 60
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix A
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 52 of 60
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 53 of 60
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
This document sets out the quality assurance plan to be used by EFRI for Chloroform
monitoring conducted pursuant to the Groundwater Corrective Action Plan (“GCAP”) found
in Attachment 1, of the final Stipulation and Consent Order (“SCO”) dated September 14,
2015. (UDEQ Docket No. UGW-20-01).
Specifically, the Mill will use the same sampling regimen for the Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:
1) Dedicated Purge Pump/Sampling
Chloroform samples are collected by means of disposable bailer(s) the day following
the purging. The disposable bailer is used only for the collection of a sample from an
individual well and disposed subsequent to the sampling. The wells are purged prior
to sampling by means of a portable pump. Each quarterly purging event begins at the
location least affected by chloroform (based on the previous quarters sampling event)
and proceeds by affected concentration to the most affected location. Although
purging will generally follows this order, the sampling order may deviate slightly
from the generated list. This practice does not affect the samples for these reasons:
any wells sampled in slightly different order have either dedicated pumps or are
sampled via a disposable bailer. This practice does not affect the quality or usability
of the data as there will be no cross-contamination resulting from sampling order.
Decontamination of all sampling equipment will follow the decontamination
procedure outlined in Attachment 2-2 of the QAP.
2) Chloroform Investigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under SCA and GCAP. Chloroform wells shall be purged from the
least contaminated to the most contaminated as based on the most recent quarterly
results.
• MW-4
• TW4-1
• TW4-2
• TW4-3
• TW4-4
• TW4-5
• TW4-20
• TW4-21
• TW4-22
• TW4-23
• TW4-24
• TW4-25
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 54 of 60
TW4-6
TW4-7
TW4-8
TW4-9
TW4-10
TW4-11
TW4-12
TW4-13
TW4-14
MW-26
TW4-16
MW-32
TW4-18
TW4-19
TW4-26
TW4-27
TW4-28
TW4-29
TW4-30
TW4-31
TW4-32
TW4-33
TW4-34
TW4-35
TW4-36
TW4-37
TW4-38
TW4-39
Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform Program or
the Groundwater Discharge Permit Monitoring Program.
3) Chloroform Sample Containers and Collection Volume
The chloroform sampling program requires a specific number of sampling containers
and the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements
Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 55 of 60
Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
<6°C
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Chloroform SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 < 6°C
Chloromethane SW8260B
or
SW8260C
1.0 pg/L 14 days HC1 to pH<2 <6°C
Inorganic
Chloride
A4500-C1 B
or A4500-C1
E
or E300.0
1 mg/L 28 days None <6°C
5) Field Parameters
Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. However, if a pumping well has been out of service for
48 hours or more, EFRI shall follow the purging requirements outlined in Attachment
2-3 of the QAP before sample collection.
Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.
6) Chloroform Quarterly Reports
The Chloroform Quarterly Reports will include the information required by Part EH of
the GCAP.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.
Date: 08-15-17 Revision 7.3Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix B
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 56 of 60
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 57 of 60
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring (“Nitrate Program”) conducted pursuant to the
Stipulation and Consent Order (“SCO”), Docket Number UGW12-04, which approved the
EFRI CAP, dated May 7, 2012.
Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan (QAP), except as set forth
below:
1) Purge Pump/Sampling
The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.
Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross­
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Nitrate Program Sampling Frequency, Order and Locations
The Nitrate Program wells listed below are required to be monitored on a quarterly
basis as required by the SCO, Docket Number UGW12-04, which approved the EFRI
CAP, dated May 7, 2012. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date:
•TWN-1 •TWN-14**
•TWN-2 •TWN-16**
•TWN-3 •TWN-18
•TWN-4 •TWN-19**
•TWN-6**•Piezometer-01
•TWN-7 •Piezometer-02
••Piezometer-03A
Page 58 of 60
**Ddepth to water measurements only.
7) Nitrate Program Sample Containers and Collection Volume
The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements
Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
<6°C
Inorganic
Chloride
A4500-C1 B
or A4500-C1
E
or E300.0
1 mg/L 28 days None <6°C
Mill - Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 08-15-17 Revision 7.3
Page 59 of 60
9) Field Parameters
Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.
10) Nitrate Program Investigation Reports
The Nitrate Program Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
• Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate mass
removed from each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.
f) Copies of EFRI field records, laboratory reports and chain of custody
forms.
Mill - Groundwater Discharge Permit Date: 08-15-17 Revision 7.3
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 60 of 60
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.