DRC-2010-001791 - 0901a068801698da

Department of
Environmental Quality
Amanda Smith
Acting Executive Director
Vy^c-at'io-ojn^i
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
State of Utah
JON M. HUNTSMAN, JR.
Govemor
GARY HERBERT
Lieutenant Govemor
February 4, 2009
CERTIFIED MAIL
(Retum Receipt Requested)
David C. Frydenlund
Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: November 16, 2009 DUSA Letter, White Mesa Uranium Mill Ground Water
Discharge Permit No. UGW370004 - New Decontamination Pad [NDP]; Request
for Information
We have reviewed the subject response from DUSA dated November 16, 2009. As before, our
review is focused on the concrete settling tank system (CST). The CST is to be operated as an
approved best available technology (BAT) facility. The comments given below retain the same
numbering order as in subject letter:
A. DRC proposed modifications to paragraph r) in Attachments - Proposed Modifications to the
DMT Plan found in the letter dated June 29, 2009 by Denison Mines (USA) Corp.:
1. Modify the Daily Inspection Form (found in Section VII) to include a location on the form
to record the daily water level (depth) inspection information for presence of fluid in all
leak detection system (LDS) vertical inspection portals for each of the three chambers in
the concrete settling tank system for the decontamination pad. Said inspection will be
made by physically measuring the depth to water with an electrical sounding tape/device.
Water level depths will be recorded to the nearest 0.01 foot.
2. On a quarterly basis submit with the DMT Performance Standard Monitoring Report a
summary of the daily water level (depth) inspections for the quarter for the presence of
fluid in all LDS vertical inspection portals for each of the three chambers in the concrete
settling tank system for the decontamination pad. The report will also include an
electronic or hard copy of daily inspection forms for the'quarter and reporting of any BAT
failures for the decontamination pad.
168 North 1950 West • Salt Uke City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Page 2
3. Please revise the DMT/BAT Monitoring Plan to include a performance standard for
depth to water in the above mentioned observation pipes, such that the water level shall
not exceed a depth equivalent to 0.1 foot above the concrete floor at any time.
4. Please provide a revised copy of the DMT/BAT Monitoring Plan in its entirety, for
review and approval.
B. Regarding Design issues:
4. No Comment.
5. Permeabilitv of the CST Concrete. The estimated permeability values shown appear to be
in error. The range of permeabilities provided all appear to be too high. For example, the
permeability provided using a 28-day concrete cure time is 1 X 10'^ m^. This value
appears to correspond to a permeability, of about 75 cm/sec. That permeability value
corresponds to very permeable gravel or coarse sand, which is not an approvable value.
An approvable estimate for the concrete penneability needs to correspond to the actual
estimated curing time. Permeability of concrete provided by the Engineering Toolbox'
shows a typical permeability, "k," of normal strength Portland cement concrete to be about
1 X 10''° cm/second, with k given in units of velocity. This value for k is per the equation
V = k-i, as provided by Corbitt.'^
A revised permeability estimate needs to be submitted. Please include the estimated time
for curing of the concrete, corresponding to the revised permeability value.
6. The As-Built Drawings. The DUSA letter of November 16, 2009 states, "Please see the
attached revised as-built drawings, which indicate the as-built elevations and grades of the
concrete floors and elevations of the walls of the Concrete Settling Tank (CST)."
No elevations (famsl) are given on the drawings provided. Please provide all current
changes to the drawings, including the elevations requested in the paragraph above. For
the observation ports the survey elevations should include elevations of the concrete floor
surface directiy below the monitoring ports, and the elevation of the top of the access pipes
(cap removed). Please label a complete set of the drawings "as-built," and submit for
review and approval.
7. Location of the CST Leakage Monitoring Pipes. It appears the CST monitoring ports have
not changed location, per the submitted drawings. Please confirm that the CST floor is
flat.
8. No Comment.
' http://www,engineeringtoolbox.com/concrete-properties-d_I223.html
^ Corbitt, Robert 1990, Handbook of Environmental Engineering, McGraw-Hill p. 5.42.
Page 3
9. No Comment.
10. No Comment.
11. In the DUSA letter of November 16, 2009 it is stated that "DUSA intends to perform a
hydrostatic test [on the steel liner] commencing on December 1, 2009."
Please provide DRC the results of this testing, and ensure they are certified by a Utah
licensed Professional Engineer.
Please provide the formation requested above, so that the review may proceed forward. If you
have any questions on the above, please contact me.
Ldj^n B. Morton, P.G.
Manager, Geotechnical Services Section
LBM:DAR:DH:d.r.
F:\drupp\DUSA\GWDPerniit\RFI2 NDP Monitor&Tech 2-4-2010.doc
File: Documentum
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Groundwater Monitoring
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WHITE MESA URANIUM MILL
GROUND WATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
STATE OF UTAH
GROUNDWATER DISCHARGE PERMIT No.UGW370004
Denison Mines (USA)Corp.
P.O.Box 809
Blanding,UT 84511
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TABLE OF CONTENTS
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Page
1.
2.
2.1.
2.2.
2.3.
2.4.
2.4.1.
2.4.2.
2.4.3.
2.5.
3.
3.1.
3.2.
3.3.
3.4.
3.5.
4.
4.1.
4.2.
INTRODUCTION ..
ORGANIZATION AND RESPONSIBILITIES .
Functional Groups .
Overall Responsibility For the AQ/QC Program ..
Data Requestors/Users .
Data Generators ,.
Sampling and QC Monitors ..
Analysis Monitor.,,'".
Data Reviewers/Approvers .
Responsibilities ofAnalytical LaboratOly ..
QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA...
Precision .
Accuracy .
Representativeness .
Completeness .
Comparability .
FIELD SAMPLING QUALITY ASSURANCE METHODOLOGy .
Controlling Well Contamination , .
Controlling Depth to Groundwater Measurements .
6
6
6
6
6
7
7
8
8
9
9
9
10
10
10
11
11
11
11
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4.3.
4.3.1.
4.3.2.
4.3.3.
4.3.4.
5.
5.1.
5.2.
Water Quality QC Samples .
VOC Trip Blanks ..
Equipment Rinsate Samples .
Field Duplicates .
Definition of "Batch"..
CALIBRATION .
Depth to Groundwater Measurements ..
Water Quality ..
11
11
12
12
12
12
13
13
6.GROUND WATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS .
13
6.1.
6.1.1.
6.1.2.
6.1.3.
Groundwater Head Monitoring ,,.
Location and Frequency ofGroundwater Head Monitoring .
Equipment Used For Groundwater Head Monitoring ,.
Field Sampling Procedure for Groundwater Head Monitoring .
13
13
14
14
6.2.Ground Water Compliance Monitoring...................................................14
6.2.1.Location and Frequency ofGroundwater Compliance MonitOling...14
6.2.2.Quarterly and Semi-Annual Sampling Required (Paragraphs I.E.La)orLE.1.b)ofthe 15
GWDP).
6.2.3.Quarterly or Monthly Sampling Required Under Paragraphs LG.l or LG.2 ofthe 15
GWDP ..
6.2.4.Sampling Equipment for Groundwater Compliance Monitoring...15
6.2.5.Decontamination Procedure....................................................................16
6.2.6.Pre-Purging/Sampling Activities................................................................17
6.2.7.Well Purging/Measurement ofField Parameters.............................................17
6.2.8.Samples to be Taken and Order ofTaking Samples..........................................20
6.2.9.Field Duplicate Samples '"20
6.2.10.VOCs and Nutrient Sampling...21
6.2.11.Heavy Metals,All Other Non-Radiologies and Gross Alpha Sampling...................21
6.2.12.Procedures to Follow After Sampling...........24
7.SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING.......25
7.1.Field Data Worksheets.........................................................................25
7.2.Chain-Of-Custody and Analytical Request Record........................................26
7.3.Record Keeping.....................26
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8.
8.1.
8.1.2.
8.2.
9.
9.1.
9.1.1.
9.1.2.
9.1.3.
9.1.4.
9.2.
9.3.
9.4.
10.
10.1.
10.2.
11.
12.
12.1.
12.2.
12.3.
12.4.
12.5.
13.
ANALYTICAL PROCEDURES AND QA/QC ..
Analytical Quality ControL .
Spikes,Blanks and Duplicates .
Analytical Laboratory Procedures .
INTERNAL QUALITY CONTROL CHECKS ..
Field QC Check Procedures .
Review ofCompliance With the Procedures Contained in this Plan .
Analyte Completeness Review .
Blank Comparisons ..
Duplicate Sample Comparisons .
Analytical Laboratory QA Reviews ..
QA Manager Review ofAnalytical Laboratory Results and Procedures .
Analytical Data .
CORRECTIVE ACTION .
When Corrective Action is Required ,.
Procedure for Corrective Action .
REPORTING .
SYSTEM AND PERFORMANCE AUDITS .
QA Manager to Perform System Audits and Performance Audits .
System Audits ..
Performance Audits ..
Follow-Up Actions ..
Audit Records .
PREVENTIVE MAINTENANCE .
27
27
27
28
31
31
31
31
31
31
32
33
34
34
34
35
35
36
36
36
37
37
37
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14.QUALITY ASSURANCE REPORTS TO MANAGEMENT........................38
14.1.Ongoing QA/QC Reporting...................................................................38
14.2.Periodic Reporting to Management...........................................................38
15.AMENDMENT..................................................................................39
16.REFERENCES............39
Appendices
Appendix A-Chloroform Investigation Monitoring Quality Assurance Program
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1.INTRODUCTION
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This Groundwater Monitoring Quality Assurance Plan (the "Plan")details and describes all
sampling equipment,field methods,laboratOly methods,qualifications of environmental
analytical laboratories,data validation,and sampling and other corrective actions necessary to
comply with UAC R317-6-6.3(I)and (L)at the White Mesa Uranium Mill (the "Mill"),as
required under paragraph LH.6 of 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 ofthis Plan 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.ORGANIZATION AND RESPONSIBILITIES
2.1.Functional Groups
This Plan 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 ofthese representatives are described below.
2.2.Overall Responsibility For the QAlQC 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.At the Mill,the QA Manager is the
Mill's Radiation Safety Officer ("RSO")or other qualified person designated by Denison
Mines (USA)Corp.("DUSA")corporate management.
2.3.Data Requestors/Users
The generation of data that meets the objectives of this Plan 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 corporate
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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 Plan.
2.4.Data Generators
The individuals who carry out the sampling and analysis activities at the request ofthe 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
radiation and environmental technicians or other 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 ofcustody activities in
accordance with this Plan.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 ofthe 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 Plan;
b)Checking that all sample documentation (labels,field data worksheets,chain-of-
custody records,packing lists)is correct and transmitting that information,along
with the samples,to the Analytical Laboratory in accordance with this Plan;
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 ofthe 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 computer data base,
where appropriate.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
2.4.2.Analysis Monitor
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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 Plan,by the Analytical Laboratory's QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program ("NELAP")and/or National Voluntary Laboratory
Accreditation Program ("NAVLAP")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 ofQA/QC,including:
a)Ensuring that the data produced by the data generators meet the specifications set out
in this Plan;
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 Plan,to
minimize contamination;and
d)Supervising all QA/QC measures to assure proper adherence to this Plan and
determining corrective measures to be taken when deviations from this Plan occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personne1.
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2.5.Responsibilities OfAnalytical Laboratory
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Unless otherwise specified by DUSA 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.
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 NELAP and/or NAVLAP certification.
In addition,to the extent not otherwise required to maintain NELAP and or NAVLAP
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 DUSA 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 ofa stringent internal quality assurance
program meeting NELAP and/or NAVLAP certification requirements and that satisfies the
criteria set out in Section 8 below,(4)ability to satisfy radionuc1ide 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 R3l7-6-6.3L.
3.QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective ofthis Plan 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:
Mill-Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
RPD=[(A-B)/{(A+B)/2}]X 100
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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
percent recoveries for matrix spike and matrix spike duplicate samples)(EPA SW-846,
Chapter 1,Section 5.0,page 28).
3.2.Accuracy
Accuracy is defined as a measure ofbias in a system or as the degree ofagreement between a
measured value and an accepted or measured 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 (EPA SW-846,Chapter 1,
Section 5.0,page 24):
%Recovery =(I A-B I/C)x 100
Where:
A =the concentration ofanalyte in a sample
B =the concentration ofanalyte in an unspiked sample
C =the concentration ofspike 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 Plan.
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 ofmeasurements)x 100
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Where the number ofvalid data points is the total number ofvalid analytical measurements
based on the precision,accuracy,and holding time evaluation.Completeness is detennined
at the conclusion ofthe data validation.
Executive Secretary approval will be required for any completeness less than 100 percent.
3.5.Comparability
Comparability refers to the confidence with which one set ofdata 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.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 ofmild steel with a lockable cap cover.Radiation Safety staffhas access to the keys
locking the wells.
Subsurface well stagnation,for pumped wells,is reduced by pumping two well casing
volumes of water from the wells,to the extent practicable.This ensures,to the extent
practicable,that the aquifer zone water is being drawn into the well and is a representative
sample.
4.2.Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field log data to
actual measurement depth.This serves as a check of the field measurements.
4.3.Water Quality QC Samples
Quality assurance for ground water monitoring consists ofthe 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 ("YQCs")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 YQCs.Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site,and then returned to the Analytical LaboratOlY for analysis
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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 (DTG,Field and Laboratory Quality Assurance/Quality control,7.8,
pages 7-30,7-31)
4.3.2.Equipment Rinsate Samples
Where a portable (non-dedicated)pump is used,a rinsate sample will be collected prior to
using and after decontaminating the sampling equipment at the beginning of each sampling
event and at the beginning ofeach day ofthe sampling event (TEGD)Field QA/QC Program,
page 119).Where a non-dedicated bailer is used a rinsate sample will be collected prior to
any well sampling or purging and after decontamination at the beginning of each sampling
event and at the beginning of each day of the sampling event.In the case of equipment
rinsate blank samples for a pump,the sample will be prepared by pumping de-ionized water
into the sample containers.In the case of equipment rinsate blank samples for a non-
disposable or non-dedicated bailer,the sample will be prepared by pouring de-ionized water
over and through the bailer and into the sample containers..During quarterly/semi-annual
monitoring events,equipment rinsate blanks will need to be analyzed only for the
contaminants required during the accelerated monitoring event.
4.3.3.Field Duplicates
One Duplicate set of samples submitted with each Batch (defined in Section 4.3.4)of
samples (DTG,Field and Laboratory Quality Assurance/Quality Control,7.8),taken from
one of the wells being sampled and will be submitted to the Analytical Laboratory and
analyzed for all contaminants listed in Table 2 of the GWDP (EPA SW-846,Chapter 1,
Section 3.4.1).
4.3.4.Definition of"Batch"
For the purposes ofthis Plan,a Batch is defined as 20 or fewer samples (PA SW-846,Chapter 1,
Section 5.0,page 23).
5.CALIBRATION
A fundamental requirement for collection ofvalid 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.
Mill -Groundwater Discharge Pennit
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Quality Assurance Plan (QAP)
5.1.Depth to Groundwater Measurements
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Equipment used in depth to groundwater measurements will be checked prior to each use 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.)
Temperature will be checked comparatively by using a thermometer.Calibration results will
be recorded on the Field Data Worksheet.
6.GROUND WATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1.Groundwater Head Monitoring
6.1.1.Location and Frequency ofGroundwater Head Monitoring
Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a)All Point ofCompliance wells listed in paragraphs 6.2.1 a),b)and c)below;
b)Monitoring wells MW-20 and MW-22;
c)All piezometers (P-l,P-2, P-3,P-4 and P-5);
d)All chloroform contaminant investigation wells required to be monitored during
the quarter under State of Utah Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No.UGQ-20-0l,not already included in paragraph
(a).On November 17,2006,such chloroform contaminant investigation wells
were the following:
•MW-4 •TW4-10
•TW4-1 •TW4-11
•TW4-2 •TW4-12
•TW4-3 •TW4-13
•TW4-4 •TW4-14
•TW4-5 •TW4-16
•TW4-6 •TW4-18
•TW4-7 •TW4-19
•TW4-8 •TW4-20
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•TW4-9 •TW4-21
TW4-22;
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e)In any other wells or piezometers required by the Executive Secretary of the Utah
Radiation Control Board,as indicated by the Mill's RSO.
6.1.2.Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist -IT 300 or
equivalent device (the "Water Sounding Device").
6.1.3.Field Sampling Procedure for Groundwater Head Monitoring
In the case of any well that is being sampled for groundwater quality,depth to groundwater is
measured prior to sampling.
Depth to groundwater is measured from the top of the inner well casing,or for the
piezometers,from the top of the casing,and is recorded on the Field Data Worksheet for
Groundwater described in Section 7.1 (the "Field Data Worksheet").Readings are taken by
lowering the Water Sounding Device into the casing until the Device alarms,indicating that
the water surface has been reached.The depth to groundwater is then determined by
reference to the distance markings on the line attached to the Device.Data is recorded on the
Field Data Worksheet as Depth to Water,to the nearest 0.01 of a foot.
6.2.Ground Water Compliance Monitoring
6.2.1.Location and Frequency ofGroundwater Compliance Monitoring
Groundwater quality shall be measured in the following wells at the following frequencies:
a)Semi-annually in the following Point of Compliance wells:MW-1,MW-2,MW-
3,MW-5,MW-12,MW-15,MW-17,MW-18 and MW-19;
b)Quarterly in the following Point ofCompliance wells:MW-11,MW-14,MW-20,
MW-22,MW-26 and MW-32;and
c)Quarterly in the following new Point of Compliance wells,until 8 quarters of
background data are obtained:MW-23,MW-24, MW-25,MW-27,MW-28,
MW-29,MW-30 and MW-31.Thereafter,these wells will be sampled on a
quarterly or semi-annual basis,as required by the GWDP.
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d)Chlorofonn Investigation sampling will collected from the locations and at the
frequencies listed at Item 2)in the Chloroform Investigation Monitoring Quality
Assurance Program (Appendix A to this document)
In addition,quarterly or monthly sampling may be required for certain parameters in certain
wells for which accelerated monitoring is required under paragraph I.G.l or I.G.2 of the
GWDP.It is important to confinn with the Mill's RSO prior to conducting any monitoring
well sampling,whether or not any parameters in any wells are subject to this accelerated
monitoring.
6.2.2.Quarterly and Semi-Annual Sampling Required Under Paragraphs I.E.I.a)or
I.E.I.b)ofthe GWDP
All quarterly and semi-annual samples collected under paragraphs 6.2.1 a),b)and c)above
(paragraphs I.E.I.a)or I.E.l.b)ofthe GWDP)shall be analyzed for the following parameters:
a)Field parameters -depth to groundwater,pH,temperature,specific conductance,
redox potential (Eh)and turbidity in the manner specified in paragraph 6.2.7 d)
(v);and
b)Laboratory Parameters:
(i)All parameters specified in Table 2 ofthe GWDP;and
(ii)General inorganics -chloride,sulfate,carbonate,bicarbonate,sodium
potassium,magnesium,calcium,and total anions and cations.
6.2.3.Quarterly or Monthly Sampling Required Under Paragraphs I.G.I or I.G.2 ofthe
GWDP
Any quarterly or monthly sampling required under paragraphs I.G.l.or I.G.2.of the GWDP
shall be in the wells and for the specific parameters required by those paragraphs of the
GWDP,as specified by the Mill's RSO.
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6.2.4.Sampling Equipmentfor Groundwater Compliance Monitoring
.All equipment used for purging and sampling ofgroundwater which enters the well or may
otherwise contact sampled groundwater,shall be made ofinert materials.
For the purposes ofthis QAP the following equipment definitions shall apply:
•Dedicated Bailer:A bailer that is dedicated to be used at one specific well for
the use ofpurging or sampling.Said bailer well remain with and in side the
well casing suspended and secured.
•Non -Dedicated Bailer:A bailer that is used for purging and sampling at
one or more well.
•Dedicated Pump:A pump that is dedicated to one specific well for the use
ofpurging or sampling.Said pump well remain with and in side the well
casing suspended and secured.
•Non -Dedicated Pump:A pump that is used for purging and sampling at one
or more wells.
Groundwater compliance monitoring IS accomplished by usmg the equipment,or the
equivalent listed below
a)Bailer made of inert materials for purging (DTG,7.3,page 7-10)
b)If a dedicated pump is installed in the well,use the dedicated pump,otherwise use
a 1.8 inch (outside diameter)air-driven sampling pump,or equivalent;
c)150 psi air compressor and ancillary equipment,or equivalent;
d)Field parameters shall be measured using a YSI-556 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:
(i)Water temperature;
(ii)Specific conductivity;
(iii)Total Dissolved Solids (TDS);
(iv)Standard pH;
(v)Redox potential (Eh).
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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e)Turbidity measuring instrument capable ofdetermining ifturbidity is::::5 NTU;
f)0.45 micron high capacity disposable inline filters;
g)Field preservation chemicals (as provided by the Analytical Laboratory);
h)Five gallon calibrated sample bucket;
i)Stopwatch;
j)Sealed sterile Polyethylene sample containers as provided by the Analytical
Laboratory;
k)De-ionized water;
1)One new,unused,clean disposable single check valve bailer,or the equivalent,for
each well to be sampled for VOCs;and
m)Ifany portable (non-dedicated)pumps are used,the following equipment,supplies
and solutions,or the equivalent,necessary for decontamination procedures:
(i)15 gallons ofde-ionized water
(ii)5 gallons ofde-ionized water/nonphosphate detergent (such as Liqui-Nox);
(iii)5 gallons of de-ionized water/HN03 solution (a mixture of approximately 4
and 1/2 gallons ofde-ionized water and Yz gallon ofHN03);
(iv)Rubber gloves;and
(v)Sterile sample containers from the Mi111aboratory.
6.2.5.Decontamination Procedure
If a portable (non-dedicated)pump is to be used,prior to each sampling event,at the
beginning ofeach day during the sampling event,and between each sampling location (well),
decontaminate the portable (non-dedicated)sampling pump prior to its use for purging or
sampling using the following procedure:
a)wash the pump probe,probe sheath and other pump equipment that may come in
contact with the sampling well inner casing or well water (the "Sampling
Equipment")with a nonphosphate detergent;
b)rinse the Sampling Equipment with de-ionized water;
c)rinse the Sampling Equipment with dilute (.IN)hydrochloric or nitric acid;and
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d)rinse the Sampling Equipment with de-ionized water.
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The probe should then be placed in the decontaminated probe sheath,or otherwise protected
from contamination until used for purging or sampling.
All water produced during decontamination will be containerized.Containerized water will
be disposed ofin Tailings Cell 1.
All sampling and purging equipment that has been decontaminated as per the foregoing
procedure shall be covered with a plastic sheet to shield such equipment from dust or other
materials that may contaminate the equipment when traveling to and between
purging/sampling locations.
6.2.6.Pre-Purging/Sampling Activities
a)If a portable (non-dedicated)pump is to be used,prior to commencing the event's
sampling activities,check the pumping equipment to ensure that no air is leaking
into the discharge line,in order to prevent aeration ofthe sample;
b)Ifa portable (non-dedicated)pump is to be used,prior to each sampling event and at
the beginning of each day during the sampling event,decontaminate the sampling
pump using the procedure set forth in Section 6.2.5;
c)If a portable (non-dedicated)pump is to be used,after completion of
decontamination and prior to the beginning of each day of each sampling event,
prepare one Equipment Rinsate Sample by following the procedure set forth in
Section 4.3.2;and
d)Prior to leaving the Mill office,place the Trip Blank(s)into a cooler that will
preserve the VOC samples.The Trip Blank(s)will accompany the groundwater
samplers throughout the monitoring event.
6.2.7.Well Purging/Measurement ofField Parameters
a)Remove the well casing cap and measure and record depth to groundwater by
following the procedures set out in paragraph 6.1.3 above;
b)Determine the casing volume (V)in gallons,where h is column height of the water
in the well (calculated by subtracting the depth to groundwater in the well fi:om the
total depth of the well),V=O.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;
c)If the RSO has advised the field technician that immiscible contaminants (i.e.,
LNAPLs or DNAPLs)are known to occur or could potentially occur in the
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subsurface at the location of the well,follow the additional procedures,to be
provided by the RSO,prior to well purging;
d)Purging,Where Use of Pump is Effective (See paragraph 6.2.7 e))below,where
bailer is required)
If a portable (non-dedicated)pump is used,ensure that it has been decontaminated in
accordance with Section 6.2.5 since its last use in a different well,lower the pump
into the well,making sure to keep the pump at least five feet from the bottom of the
well.Be sure never to drop the pump into the well,as this will cause degassing ofthe
water upon impact.Once the pump is lowered into the well,or if the well has a
dedicated pump,perform the following steps:
(i)Commence pumping;
(ii)Determine pump flow rate by using a stopwatch 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 ofthe Field Data Worksheet;
(iii)Calculate the amount oftime to evacuate two casing volumes;
(iv)Evacuate two casing volumes (if possible)by pumping for the length of time
determined in paragraph (iii);
(v)Take measurements of field parameters (pH,specific conductance,
temperature,redox potential and turbidity)during well purging,using the
Field Parameter Meter and turbidity measuring instrument.These
measurements will be recorded 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%over at least two consecutive
measurements.The groundwater in the well should recover to within at
least 90%of the measured groundwater static surface before sampling.In
addition,turbidity measurement in the water should be .:S 5 NTU prior to
sampling (DTG Well Development 6.7,page 6-48)unless the well is
characterized by water that has a higher turbidity.A flow-cell needs to be
used for field parameters.Ifthe well is purged to dryness or is purged such
that full recovery exceeds two hours,the well should be sampled as soon as
a sufficient volume of groundwater is available to fill sample containers
(DTG,Well Purging,7.2.4,page 7-9);
(vi)If the well yields two casing volumes,the individual performing the
sampling should immediately proceed to Section 6.2.8);
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(vii)Ifthe well cannot yield two casing volumes,
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A.Evacuate the well to dryness and record the number of gallons
evacuated on the Field Data Worksheet;and
B.Prior to sampling,measure and record depth to groundwater on the
Field Data Worksheet following the procedures set out in paragraph
6.1.3 above;
e)Purging,Where Use of Pump is Not Effective
For wells where a pump is not effective for purging and/or sampling (wells with
shallow water columns,i.e.,where the water column is less than five feet above the
bottom of the well casing or the well takes over two days to recover from purging),a
disposable bailer,made of inert materials,may be used.If a bailer is used,the
following procedure will be followed:
(i)Use the sound level instrument to determine the water column and figure the
amount ofwater that must be evacuated;
(ii)Attach a 3"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 discharge the water from the
bailer into 5 gallon buckets.By doing this,one can record the number of
gallons purged;
(v)After the bailer is emptied,lower the bailer back into the well and gain another
sample as before.This process will continue until the two casing volumes
have been collected or until no more water can be retrieved.When the process
is finished for the well,the bailer will be disposed of;and
(vi)Take field measurements referred to in paragraph 6.2.7 (v)above from the
water in the buckets;
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6.2.8.Samples to be taken and order oftaking samples
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For each sampling event,unless sampling for a specific parameter under the accelerated
monitoring requirements of paragraphs LG.1 or LG.2 ofthe GWDP as specified by the RSO,
the following separate samples shall be taken in the following order from each monitoring
well:
a)VOCs,3 sample containers,40 ml each,(a bailer is used);
b)Nutrients (ammonia,nitrate and nitrite),1 sample container,100 ml (a bailer is
used);
c)Heavy metals,I sample container,250 ml,filtered;
d)All other non-radiologics (fluoride,general inorganics,TDS,total cations and
anions),I sample container,250 ml,filtered;and
e)Gross alpha,1 sample container,1,000 ml,filtered.
f)The sample collection containers and sample volumes for chloroform sampling are
specified at Item 3)of the Chloroform Investigation Monitoring Quality Assurance
Program (Appendix A to this document)
The number of sample containers and the quantities taken shall be as set out above,unless
otherwise dictated by the Analytical Laboratory,as specified by the RSO.
6.2.9.Field Duplicate Samples
a)One duplicate set of samples is required for each Batch of samples (see Section
4.3.4)for definition of Batch)(EPA SW-846,Chapter 1,Section 3.4.1).Field
duplicate samples will be analyzed for the contaminants listed in Table 2 of the
GWDP;
b)The duplicate samples should be as near to split samples as reasonably practicable,
rather than merely taking a second set of samples from the same well after the field
samples have been taken from that well.This can be accomplished by alternately
partially filling the field sample containers and duplicate containers until both sets of
containers are full.
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6.2.10.VOCs and Nutrient Sampling
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When sampling for VOCs and Nutrients,the following procedure shall be followed:
a)Obtain specifically identified sample containers 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)Sample the well using an unused,clean,disposable,single check valve bailer,or the
equivalent;
d)Sample water should be transferred to sample containers in a controlled manner that
will minimize sample agitation and aeration;
e)In the case of VOC samples,be sure that the sample containers are filled as full as
possible with no airspace in the containers;
f)After each sample container is filled,rinse the lid of the container with water,and
tighten lid onto container;and,
g)Discard the bailer.
6.2.11.Heavy Metals,All Other Non-Radiologies and Gross Alpha Sampling
When sampling for heavy metals,all other non-radiologies 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 (wells without shallow water columns,i.e.,where the
water column is more than five feet above the bottom of the well casing or the well
takes less than two days to recover from purging):
(i)Place a new 0.45 micron filter on the sample tubing;
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(ii)Pump the sample through the filtration unit,and into the sample container at
the same rate or a lesser pumping rate than was used to purge the well;
(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;
(iv)Remove pump from the well;and
(v)If using a portable (non-dedicated pump),decontaminate pump as per Section
6.2.5.Do not place decontaminated pump on the ground or on other
contaminated surfaces;
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 or the well
takes over two days to recover from purging),then one of the following two
procedures will be used:
(i)Filtering Water Samples at the Well Head
A.The sample water is collected by use of a 3 inch Teflon bailer,or the
equivalent,that is capable of being attached to a hand-operated
pressure pump,or the equivalent.Only disposable parts of the
pressure pump may come into contact with the sample water;
B.Attach the pump to the disposable bailer and activate the pump in
accordance with manufacturer's instructions,such that the sample
water in the bailer is forced through a clean,un-used,disposable 0.45
micron filter into a clean previously unused sample container,in a
manner such that only disposable parts of the pump mechanism come
into contact with the sample water;
C.Sample water should be transferred to sample containers in a
controlled manner that will minimize sample agitation and aeration;
D.Rinse lid of sample container with any remaining filtered water,after
container is filled with filtered water,and tighten lid onto container;
E.Unless dedicated to a particular well,dispose of the bailer,filter and
any parts of the pump mechanism that come into contact with the
sample water;and
F.No rinsate sample is needed,because everything that comes into
contact with the sample water is clean and unused prior to sampling,
and disposed ofafter sampling the well;
(ii)Filtering Water Samples at the Mill Laboratory
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A.A new,clean 1 gallon raw sample container must be used to capture
waters needed to be filtered;
B.The sample water is collected by use of a 3 inch Teflon bailer,or the
equivalent,and then discharged into the 1 gallon container;
C.After all the samples have been collected for the well and placed in the
field sample container,which contains blue ice to keep the samples at
the required temperature,the sampler will then proceed directly back
to the Mill laboratory and perform the filtration on the sample;
D.Unless the bailer is dedicated to a particular well,it will be disposed of
after completion ofsampling in the well;
E.Upon arrival at the administration building,all other samples from the
well (that do not require filtration)will be placed in the sample holding
refrigerator in the locked sample storage room;
F.The sampler will then carry the sample that requires filtration in the
cooler to the laboratory and set up the equipment to be used for
filtration ofthe sample;
G.The equipment needed for this process consists of:
•2000 ml glass filter flask
•250 ml bell and glass frit for a micro-filtration 0.45 micron
filter setup
•0.45 micron filter paper
H.The glass filter flask and micro-filtration equipment will go through a
cleaning and rinsate process.The processing will included the
following:
•Rinsing ofthe equipment using DI water
•Rinsing the equipment with a mixture ofDI water and HN03
•Rinsing the equipment with a mixture ofDI water and Liqui-
Nox soap
•Rinsing the equipment with DI water
•Finally the collection ofthe final process rinsate solutions are
placed in the sample collection cooler and labeled as a filtration
equipment rinsate sample;
1.The flask is attached to the vacuum system in the laboratOly using
Tygon Vacuum Tubing,or the equivalent;
J.The micro-filtration system is then inserted into the filter flask;
K.A 0.45 micron filter paper is then placed between the bell and the glass
frit and clamped in place to prevent solution leaking out;
L.The water sample is then slowly added into the bell and the vacuum is
turned on;
M.As the vacuum draws the water through the filter paper,additional
solutions are added until the flask is full;
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N.When the flask is full,the vacuum is turned off and the bell is
undamped from the frit.The Tygon tubing is then removed from the
flask.The glass frit is then pulled out of the flask;
O.The filtered solutions are then poured into the various remaining
sample collection bottles.Sample water should be transferred to
sample containers in a controlled manner that will minimize sample
agitation and aeration;
P.Rinse lid of sample container with any remaining filtered water,after
container is filled with filtered water,and tighten lid onto container;
Q.If additional filtered water is required to complete the sample
requirements,the sample bottles will be placed in the field cooler
along with the raw sample and housed there while the filtration system
is being hooked back up and the procedures set out in paragraphs I to P
above are repeated until sufficient sample water has been filtered to fill
up the required number ofsample bottles;
R.After all samples from the well that require filtration have been filtered
in accordance with the foregoing procedure and placed in the proper
sample bottles,the remainder of the raw sample is then discharged into
the laboratory sink,which runs to tails;and
S.The filtered samples are then transported to the locked sample storage
room and placed in the sample holding refrigerator.
The time lapse between the actual sampling times to the completion ofthe
filtration process is approximately Yz hour.Samples are always in the field
sample container,except for when the raw sample is pulled from the cooler
and poured in the bell on the filter flask.
6.2.12.Procedures to Follow After Sampling
a)In each case,once a sample is taken,identify and label the sample container with:
•Sample location/facility
•Date and time ofsample
•Any preservation method utilized
•Sampler's initials
•Filtered or unfiltered
•Parameters requested to be analyzed
b)Place each sample in an ice-packed cooler,immediately upon taking the sample
and labeling the sample container;
c)Replace the casing cap on the well.Lock the well;
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d)Before leaving the sampling location,thoroughly document the sampling event on
the Field Data Worksheet,by recording the items required in paragraph 7.1;and
e)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
postal contract services to the Analytical Laboratory.
7.SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1.Field Data Worksheets
Documentation ofobservations 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.
The Field Data Worksheets will contain the following information:
•Name ofthe site/facility
•description ofsampling event
•location of sample (well name)
•sampler's name(s)and signature(s)
•date(s)and time(s)ofwell purging and sample collection
•type ofwell purging equipment used (pump or bailer)
•previous well sampled during the sampling event
•well depth
•depth to groundwater before purging and sampling
•results of in-field measurements (pH,specific conductance,water
temperature)
•redox potential (Eh)measurements
•turbidity measurements
•calculated well casing volume
•volume ofwater purged before sampling
•volume ofwater purged when field parameters are measured
•type and condition ofwell pump
•description of samples taken
•sample handling,including filtration and preservation
•volume ofwater collected for analysis
•types ofsample containers and preservatives
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•weather conditions and external air temperature
•name ofcertified Analytical Laboratory.
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The Field Data Worksheets will also contain detailed notes describing any other significant
factors during the sampling event,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 feature or condition.An example of a form of Field
Data Worksheet that incorporates this infOlmation is attached as Attachment 1.
7.2.Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody and Analytical Request Record form (the "cac Form"),provided by the
Analytical Laboratory,will accompany the samples being shipped to the Analytical
Laboratory.An example of the Analytical Laboratory's Chain of Custody Form is attached
as Attachment 2.If the Chain of Custody Form changes at any time,the Company shall
provide a copy of the new or revised Chain of Custody FOlm to the Executive Secretary and
substitute the new form for the old fOlm in Attachment 2.Standard Chain-of-Custody
protocol is initiated for each sample set.A cac FOlm 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 (e.g.,water)
•sample location
•number ofsample containers in the shipping container
•analyses requested
•signatures ofpersons involved in the chain ofpossession
•internal temperatures ofthe 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 ofeach cooler.
The person shipping the samples to the Analytical Laboratory will sign the cac Form,
document shipment method,and send the original and the second copy of the cac FOlm
with the samples.Upon receipt ofthe samples,the person receiving the samples will sign the
cac Form and return the second copy to the Mill's RSa.
Copies ofthe cac Forms and other relevant documentation will be retained at the Mill.
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7.3.Record Keeping
The Field Data Worksheets are retained at the Mill.
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Original Certificates of Analysis from the Analytical Laboratory,showing the laboratory
analytical results for the water samples,are maintained at the Mill.
Once all the data for the quarter (all wells sampled during the quarter)is completed,key data
from the Field Data Worksheets and from the Certificates of Analysis are typed into a
computer file.Key data entered into the computer file will include well J.D.,sample date,
depth to groundwater,average field data,and all laboratory analytical data.These computer
files are maintained at the Mill.
8.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 ofthe Analytical Laboratory.In
choosing and retaining the Analytical Laboratory,DUSA shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP and/or NAVLAP,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 Batch ofsamples:
a)Duplicate Spike (Matrix Spike)
A split/spiked field sample shall be analyzed with every analytical batch.Analytes
stipulated by the analytical method,by applicable regulations,or by other specific
requirements must be spiked into the sample.Selection of the sample to be spiked
and/or split depends on the information required and the variety ofconditions within a
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typical matrix.The duplicate spike (matrix spike)sample serves as a check
evaluating the effect ofthe sample matrix on the accuracy ofanalysis.
b)Blanks
Each batch shall be accompanied by a reagent blank.The reagent blank shall be
carried through the entire analytical procedure.Contamination detected in analysis of
reagent blanks will be used to evaluate any Analytical Laboratory contamination of
environmental samples which may have occun-ed.
c)Field Samples/Sun-ogate Compounds
Every blank,standard,and environmental sample (including matrix spike/matrix
duplicate samples)shall be spiked with surrogate compounds prior to purging or
extraction.Sun-ogates 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.
d)Check Sample
Each analytical batch shall contain a number ofcheck 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.With respect to
Chloroform Investigation sampling,the analytical procedures for parameters
monitored under that program are specified at Item 4)of the ChlorofOlm Investigation
Monitoring Quality Assurance Program (Appendix A to this document)
Mill -Groundwater Discharge Pelmit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Table 1
Date:4-16-09 Revision-4
Page 30 of43
Contaminant Analytical Reporting Maximum Sample Sample
Methods Limit!Holding Preservation Temperature
to be Used Times Requirements Requirements
Nutrients
Ammonia (as N)A4500-0.05 mg/L 28 days H2S04 to ::;6°C
NH3G pH<2
Nitrate &Nitrite E353.2 0.1 mg/L 28 days H2S04 to ::;6°C
(as N)pH<2
Heavy Metals
Arsenic E200.8 511g/L 6 months HN03 to pH<2 None
Beryllium E200.8 0.50/-Lg/L 6 months HN03 to pH<2 None
Cadmium E200.8 0.50/-Lg/L 6 months HN03 topH<2 None
Chromium E200.8 25/-Lg/L 6 months HN03 to pH<2 None
Cobalt E200.8 1011g/L 6 months HN03 to pH<2 None
Copper E200.8 10/-Lg/L 6 months HN03 to pH<2 None
Iron E200.7 30/-Lg/L 6 months HN03 to pH<2 None
Lead E200.8 1.0/-Lg/L 6 months HN03 topH<2 None
Manganese E200.8 10/-Lg/L 6 months HN03 to pH<2 None
Mercury E200.8 0.5011g/L 28 days HN03 to pH<2 None
Molybdenum E200.8 10/-Lg/L 6 months HN03 to pH<2 None
Nickel E200.8 20/-Lg/L 6 months HN03 topH<2 None
Selenium E200.8 5/-Lg/L 6 months HN03 to pH<2 None
Silver E200.8 10/-Lg/L 6 months HN03 to pH<2 None
Thallium E200.8 0.50/-Lg/L 6 months HN03 to pH<2 None
Tin E200.8 100/-Lg/L 6 months HN03 topH<2 None
Uranium E200.8 0.30/-Lg/L 6 months HN03 to pH<2 None
Vanadium E200.8 15/-Lg/L 6 months HN03 to pH<2 None
Zinc E200.8 10/-Lg/L 6 months HN03 to pH<2 None
Radiologies
Gross Alpha E900.1 1.0 pCi/L 6 months HN03 to pH<2 None
Volatile
Organic
Compounds
Acetone SW8260B 20/-Lg/L 14 days HCI to pH<2 ::;6°C
Benzene SW8260B 1.0/-Lg/L 14 days HCI to pH<2 ::;6°C
2-Butanone SW8260B 20/-Lg/L 14 days HCI to pH<2 ::;6°C
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Quality Assurance Plan (QAP)
Date:4-16-09 Revision-4
Page 31 of43
1.The Analytlcal Laboratory wIll be reqUlred to meet the reportmg hmits ("RLs")m the foregomg 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.
Contaminant Analytical Reporting Maximum Sample Sample
Methods Limitl Holding Preservation Temperature
to be Used Times Requirements Requirements
(MEK)
Carbon SW8260B 1.0~g/L 14 days HC1 to pH<2 :S 6°C
Tetrachloride
Chloroform SW8260B 1.0~g/L 14 days HCI to pH<2 :S 6°C
Chloromethane SW8260B 1.0~g/L 14 days HCI to pH<2 <6°C
Dichloromethane SW8260B 1.0~g/L 14 days HCI to pH<2 :S 6°C
(Methylene
Chloride)
Naphthalene SW8260B 1.0~g/L 14 days HCI to pH<2 <6°C
Tetrahydrofuran SW8260B 1.011g/L 14 days HCI to pH<2 <6°C
Toluene SW8260B 1.0~g/L 14 days HCI to pH<2 :S 6°C
Xylenes (total)SW8260B 1.0~g/L 14 days HCI to pH<2 :S 6°C
Others
Field pH (S.U.)A4500-H 0.01 s.u.Immediate None None
B
Fluoride A4500-F C 0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None :S 6°C
General
Inorganics
Chloride A4500-CI 1 mg/L 28 days None None
B
Sulfate A4500-1 mg/L 28 days None :S 6°C
S04E
Carbonate as A2320 B 1 mg/L 14 days None :S 6°C
C03
Bicarbonate as A2320 B 1 mg/L 14 days None :S 6°C
HC03
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 topH<2 None
Calcium E200.7 0.5 mg/L 6 months HN03 to pH<2 None..
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9.INTERNAL QUALITY CONTROL CHECKS
Date:4-16-09 Revision-4
Page 32 of43
Internal quality control checks are inherent in this Plan.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 Plan.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 Plant.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 ofCompliance With the Procedures Contained in this Plan
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this Plan.
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.l.(a)of the Permit.Executive Secretary approval will be required
for any completeness (prior to QA/QC analysis)less than 100 percent.Non-confonnance
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 Secretary approval.
9.1.3.Blank Comparisons
Trip blanks,and equipment rinsate samples will be compared with original sample results.
Non-conformance conditions will exist when contaminant levels in the blank(s)/samples(s)
are within an order of magnitude of the original sample result.(TEGD,Field QA/QC
Program,page 119).
9.1.4.Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
Mill -Groundwater Discharge Petmit
Groundwater Monitoring
Quality Assurance Plan (QAP)
a)Relative Percent Difference.
Date:4-16-09 Revision--4
Page 33 of43
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD ~20%,unless the measured activities 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 ElTOf 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 trhe reported activity concentration.An error
term may be greater than 20%of the reported activity concentration when the sum ofthe
activity concentration and elTor telm 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:
Where:
A =the first duplicate measurement
B =the second duplicate measurement
sa2 =the uncertainty ofthe first measurement squared
sb2 =the uncertainty ofthe second measurement squared
Non-conformance exists when the foregoing equation is 2:2.
(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).
If the QA Managers review finds any situations ofnon-conformance,see Section 10.
Mill -Groundwater Discharge Pennit
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Quality Assurance Plan (QAP)
9.2.Analytical Laboratory QA Reviews
Date:4-16-09 Revision-4
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Full validation will include recalculation of raw data for a minimum of one or more ana1ytes
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 ofthe validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality ofthe data based
on SW-846,the applicable portions ofNRC guide 4.14 and on analytical methods used.The
reviewer will check the following:(l)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:(l)cover
sheet listing samples included in report with a narrative,(2)results of compounds identified
and quantified,and (3)reporting limits for all ana1ytes.Also to be included are the QA/QC
analytical results.
9.3.QA Manager Review ofAnalytical Laboratory Results and Procedures.
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
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 gain);or 2)a reporting
limit that exceeds the respective GWQS listed in Table 2 ofthe GWDP.
b)Laboratory Methods Review
The QA Manager shall confilID that the analytical methods used by the Analytical Laboratory
are those specified in Table 1,unless otherwise approved by the Executive Secretary.Non-
confOlIDance shall be defined when the Analytical Laboratory uses analytical methods not
listed in Table 1 and not otherwise approved by the Executive Secretary.
Mill -Groundwater Discharge Pennit
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Quality Assurance Plan (QAP)
c)Holding Time Examination
Date:4-16-09 Revision-4
Page 35 of43
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 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 ofthe cOlTective 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 ofinvestigation.
lfre-runs occur with increasing frequency,the Analysis Monitor and the Mill's QA Manager
will be consulted to establish more appropriate analytical approaches for problem samples.
10.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 Plan.COlTective action should be taken for any procedure
deficiencies or deviations noted in this Plan.All deviations from field sampling procedures
will be noted on the Field Data Worksheets 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.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
When non-confOlmance is identified,DUSA shall:
Date:4-16-09 Revision--4
Page 36 of43
a)When non-confOlmance occurs as specified in Sections 9.1.3,9.1.4 or 9.3,the data
shall be qualified to denote the problem.In addition,DUSA 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 ground water monitoring period will be corrected and reported to
the Executive Secretary 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 ofdiscovery and analyze again in compliance with
all requirements ofthis Plan.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 Plan,the procedure set forth in Section
10.2 shall be followed.
10.2.Procedure for Corrective Action
The need for cOlTective action for non-conformance with the requirements ofthis Plan,may
be identified by system or performance audits or by standard QA/QC procedures.The
procedures to be followed ifthe need for a cOlTective action is identified,are as follows:
a)Identification and definition of the problem;
b)Assignment ofresponsibility for investigating the problem;
c)Investigation and determination ofthe cause of the problem;
d)Determination ofa 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.A memorandum explaining the steps outlined above will
be placed in the applicable monitoring files and the Mill Central Files,and the cOlTective
action will be documented in a Report prepared in accordance with Section 11.
Mill-Groundwater Discharge Pennit
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Quality Assurance Plan (QAP)
11.REPORTING
DateA-16-09 Revision-4
Page 37 of43
As required under paragraph I.F.1 of the GWDP,the Mill will send a groundwater
monitoring report to the Executive Secretary on a quarterly basis.Both the Routine
Groundwater Monitoring Reports (pertinent to Part I.F.1 of the Permit)and Chloroform
Investigation 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.1 of the Permit)will
include the following information:
•Description ofmonitor wells sampled
•Description of sampling methodology,equipment an decontamination
procedures to the extent they differ from those described in this Plan
• A summary data table of historic 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 I.G.1 of the GWDP or are out ofcompliance in any particular
wells pursuant to Part I.G.2 ofthe GWDP
•Copies ofField Data Worksheets
•Copies of Analytical Laboratory results
•Copies of Chain ofCustody Forms
• - 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 ofgroundwater levels,gradients and flow directions
•Quality assurance evaluation and data validation description (see Section 9 for
further details)
•All non-confonnance with this Plan and all corrective actions taken.
•Recommendations and Conclusions.
With respect to the chloroform investigation reporting requirements,these are specified at
Item 5)ofthe Chloroform Investigation Monitoring Quality Assurance Program (Appendix A
to this document.
Mill -Groundwater Discharge Permit
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Date:4-16-09 Revision-4
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In addition,an electronic copy of all analytical results will be transmitted to the Executive
Secretaly in comma separated values (CSV)format,or as otherwise advised by the Executive
Secretary.
Further reporting may be required as a result of accelerated monitoring under paragraphs
I.G.l and I.G.2 ofthe GWDP.The frequency and content of these reports will be defined by
DUSA corporate management working with the Executive Secretary.
12.SYSTEM AND PERFORMANCE AUDITS
12.1.QA Manager to Perform System Audits and Performance Audits
DUSA shall perform such system audits and perfOlmance 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 DUSA.
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 calTied 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 Plan 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.
12.3.Performance Audits
The perfOlmance audit is a quantitative evaluation of the measurement systems ofa program.
It requires testing the measurement systems with samples ofknown 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 ofthe blind studies
that the Analytical Laboratory must provide to its NELAP and/or NAVLAP accreditation
agency on an annual basis.The performance audit is carried out without the knowledge of
the analysts,to the extent practicable.
Mill -Groundwater Discharge Petmit
Groundwater Monitoring
Quality Assurance Plan (QAP)
12.4.Follow-Up Actions
Date:4-16-09 Revision-4
Page 39 of43
Response to the system audits and perfonnance audits is required when deviations are found
and corrective action is required.Where a cOlTective action is required,the steps set out in
Section lO.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 ofcompletion for corrective actions,and any other
documents associated with the audits supporting audit findings or corrective actions.
13.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 ofthe 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
logbook.
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 and/or NAVLAP certifications.Preventive maintenance will be
perfonned on a scheduled basis to minimize downtime and the potential interruption of
analytical work.
14.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
Mill -Groundwater Discharge Pennit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date:4-16-09 Revision-4
Page 40 of43
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 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 and/or NAVLAP requirements and will
summarize the data validation efforts and provide an evaluation ofthe data quality.
14.2.Periodic Reporting to Management
The QA Manager shall present a report to DUSA'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 perfOlmance audits,including any corrective actions;
c)Results of any system audits,including any corrective actions;and
d)Significant QA problems and recommended solutions.
15.AMENDMENT
This Plan may be amended from time to time by DUSA only with the approval of the
Executive Secretary.
Mill-Groundwater Discharge Pennit
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Quality Assurance Plan (QAP)
16.REFERENCES
Date:4-16-09 Revision-4
Page 41 of43
16.1.United States Environmental Protection Agency,November 2004,Test Methods for
Evaluating Solid Waste,EPA SW-846.
16.2.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.
16.3.United States Environmental Protection Agency,November 1992,RCRA Ground-
water Monitoring Draft Technical Guidance (DTG),Office ofSo1id Waste.
16.4.Standard Methods for the Examination ofWater 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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Groundwater Monitoring
Quality Assurance Plan (QAP)
Date:4-l6-09 Revision-4
Page 42 of43
ATTACHMENT 1
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUND WATER
Description ofSampling Event _
Sampler
Location (well name)Name and initials _
Date and Time for Purging and Sampling (ifdifferent)_
Well Purging Equip Used:~ump or _bailer Well Pump (ifother than Bennet)_
Sampling Event _
pH Buffer 7.0 _
Prevo Well Sampled in Sampling Event._
pH Buffer 4.0 _
Conductance (avg)_
Specific Conductance uMHOS/cm Well Depth._
Depth to Water Before Purging Casing Volume (V)4"Well:(.653h)
3"Well:(.367h)
pH ofWater (avg)_
Well Water Temp.(avg)_Redox Potential (Eh)__Turbidity _
Weather Condo--------Ext'l Amb.Temp.(prior to sampling event)_
Time:Gal.Purged _
Conductance-----------
pH _
Temperature _
Redox Potential (Eh)_
Turbidity------------
Time:Gal.Purged _
Conductance-----------
pH _
Temperature-----------
Redox Potential (Eh)_
Time:Gal.Purged _
Conductance------------
pH _
Temperature------------
Redox Potential (Eh)_
Turbidity _
Time:Gal.Purged _
Conductance------------
pH _
Temperature------------
Redox Potential (Eh)_
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Turbidity _
Date:4-16-09 Revision-4
Page 43 of43
Turbidity _
Volume ofWater Purged When Field Parameters are Measured"_
Pumping Rate Calculation
Flow Rate (Q),in gpm.
S/60 =
Time to evacuate two casing volumes (2V)
T=2V/Q =-------------
Number ofcasing volumes evacuated (if other than two)---------------
If well evacuated to dryness,number ofgallons evacuated--------------
Name ofCeliified Analytical Laboratory ifOther Than Energy Labs _
Type of Sample Sample Sample Volume Filtered Preservative Added
Taken (indicate if other (circle)(circle)
(circle)than as specified
below)
VOCs Y N 3x40 ml y N HCL y N
Nutrients y N 100 ml y N H2SO4 Y N
Heavy Metals Y N 250 ml y N RN03 y N
All Other Non-y N 250 ml y N No Preservative Added
Radiologies
Gross Alpha Y N 1,000 ml y N H2SO4 y N
Other (specify)y N Sample volume y N y N
Ifa preservative is used,
Specify Type and
Quantity ofPreservative:
Comments --------------------------------
Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding,Utah
Chlorofonn 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)
Corp.for Chlorofonn Investigation conducted pursuant to State of 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 Chlorofonn
Investigation that is utilized for groundwater sampling under its groundwater discharge
pennit,as set forth in the attached groundwater discharge pennit Quality Assurance Plan
(QAP),except as set forth below:
1)Dedicated Purge Pump
Chlorofonn Investigation samples are collected by means of dedicated bailer(s)that
remain inside the well casing (suspended and secured with a rope)or by means of a
disposable bailer used only for the collection of a sample only from an individual well
and disposed subsequent to the sampling.The wells are purged by means of a pOliable
pump.Each quarterly pumping and sample collection event begins at the location least
affected by chlorofonn (based on the previous quarters sampling event)and proceeds by
affected concentration to the most affected location.-.Decontamination ofAll sampling
equipment will follow the decontamination procedure outlined in section 6.2.5 of the
QAP.
2)ChlorofOlID Investigation Sampling Frequency,Order and Locations
The chlorofonn investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No.UGQ-20-01.ChlorofOlID wells shall be collected from
the least contaminated to the most contaminated as based on the most recent quarterly
results.
•MW-4 •TW4-11
•TW4-1 •TW4-12
•TW4-2 •TW4-13
•TW4-3 •TW4-14
•TW4-4 •(MW-26)
•TW4-5 •TW4-16
•(MW-32)
•TW4-6 •TW4-18
•TW4-7 •TW4-19
•TW4-8
•TW4-9
•TW4-l0
•TW4-20
•TW4-2l
•TW4-22
•TW4-23
•TW4-24
•TW4-25
Note:Wells MW-26 and MW-32may 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 NitratelNitrite determinations,collect one sample into a lOO ml
container.
•For inorganic Chloride,collect one sample into a 100 ml container.
4)Laboratory Requirements
Collected samples which are gathered for chloroform investigation purposes are
delivered to an outside laboratory where the requisite analyses are performed.At
the laboratory the following analytical specifications must be adhered to:
Analytical Analytical Reporting Maximum Sample Sample
Parameter Method Limit Holding Preservation Temperature
Times Requirement Requirement
Nitrate &Nitrite E353.2 0.1 mg/L 28 days H2S04 to :S 6°C
(as N)pH<2
Carbon SW8260B l.°llg/L 14 days HCl to pH<2 :S 6°C
Tetrachloride
ChlorofOlm SW8260B 1.0 Ilg/L 14 days HCl to pH<2 <6°C
Dichloromethane SW8260B l.°llg/L 14 days HCl to pH<2 :S 6°C
(Methylene Chloride)
Chloromethane SW8260B 1.0 Ilg/L 14 days HCl to pH<2 :S 6°C
Inorganic A4500-CI B 1 mg/L 28 days None :S 6°C
Chloride
5)Field Parameters
In the case of chloroform pumping wells only one set offield parameters is
required to be measured prior to sampling.This includes the following weills:
MW-4,MW-26,TW-4-19 and TW-4-20.
6)Chloroform Investigation Reports
The Chloroform Investigation Reports will include the following information:
a)Introduction
b)Sampling and Monitoring Plan
•Description ofmonitor wells
•Description ofsampling methodology,equipment and
decontamination procedures
•Identify all quality assurance samples,e.g.trip blanks,
equipment blanks,duplicate samples
•
c)Data Interpretation
•Interpretation ofgroundwater levels,gradients,and flow
directions.Interpretations wold include a discussion on:1)A
current site groundwater contour map,2)hydrographs to
show groundwater elevation in each monitor well over time,
3)depthe to groundwater measured and groudnwateelevation
form each monitor well summarized in a data table,that
includes historic groundwater level data for each well,and 4)
an evaluation ofrhe effectiveness ofhydraulic capture ofall
contaminants ofconcern.
•Interpretation ofall analytical results for each well,including
a discussion on:1)a current chloroform isoconcentration
map with one ofthe isosconentration lines showing the 70
ug/L boundary,2)graphs showing chloroform concentration
trends in each well thru 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 mass
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 fmID each
pumping well for the quarter.
d)Conclusions and Recommendations
e)Electronic copy ofall laboratory results for groundwater quality
monitoring conducted during the quarter.
£)Copies ofDUSA 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 groundwater discharge permit QAP.