DRC-2010-001961 - 0901a0688016b5ff

^^L'-..^0\0- CC)f[i4:i
DENISOIsn/i
MINES
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax:[phone]
www.denisonmines.com
February 17, 2010
VIA PDF AND FEDERAL EXPRESS
Mr. Dane L. Finerfrock
Co-Executive Secretary
Utah Water Quality Board
State of Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Dear Mr. Finerfrock:
Re: Denison Mines (USA) Corp. White IVIesa Uranium iVIili - Proposed Revision to Groundwater
Quality Assurance Plan, Use of EPA Methods SW8260B or SW8260C for Analysis of
Tetrahydrofuran
Reference is made to the Denison Mines (USA) Corp. ("Denison") White Mesa Uranium Mill Ground
Water Monitoring Quality Assurance Plan (QAP), Revision - 4, dated 4/16/09 (the "QAP").
Table 1 in Section 8.2 of the QAP requires that the analytical procedure to be used by the White Mesa
Mill's (the "Mill's") contract analytical laboratory for the analysis of tetrahydrofuran ("THF") will be method
SW8260B.
Denison hereby requests that Table 1 of the QAP be amended to require that the analytical procedure to
be used by the Mill's contract analytical laboratory for the analysis of THF be method SW8260B or
method SW8260C.
Attached to this letter is a letter from American West Analytical Laboratories ("AWAL") that describes the
major differences between methods SW8260B and SW8260C. As can be seen from AWAL's analysis,
the differences are minor, and method 8260C, being a more recent revision, should be considered an
improvement to the method.
If you have any questions or require anything further, please contact the undersigned.
Yours very truly,
DENISOJ(1VIINE/(USA) CORP.
C.-'FiVdenlund
President, Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
David E. Turk
A
AMERICAN
WEST
ANALYTICAL
LABORATORIES
David Frydenlund
Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) Corporation
105017th Street, Suite 950
Denver, CO 80265
February 16, 2010
RE: SW-846 Method 8260B vs. 8260C
463 West 3600 South
Salt Lake City, UT
84115
[phone]
Toll Free [phone]
Fax [phone]
email: [e-mail]
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
Dear David:
As pursuant to your request, I am sending you this letter to define the major difference
between SW-846 Methods 8260B' and 8260C^
The general requirements of these methods are the same in that they employ the same
instrumentation: GC/MS. Both methods allow the use of method 5030 for purge and
trap analysis. The major difference is the change to the acceptance criteria for
evaluating the calibration. The following explains those differences.
In order for a standard to pass under 8260B, only the CCC and SPCC compounds were
required to pass certain limits. The limits were as follows...
chloromethane minimum response >0.1
1,1-dichloroethane minimum response >0.1
chlorobenzene minimum response >0.3
bromoform minimum response >0.1
1,1,2,2-tetrachloroethane minimum response >0.3
chloroform %RSD <20%
vinyl chloride %RSD <20%
1,1-dichloroethene %RSD <20%
1,2-dichloropropane %RSD <20%
Toluene %RSD <20%
Ethylbenzene %RSD <20%
Under 8260B, less emphasis was placed on the remaining analytes, as long as those
listed above passed the required criteria. Under 8260C, all 114 compounds (including
THF) are checked, not just 11 of them. The calibration passes if >80% of the analytes
have a %RSD <20%. Additionally, instead of checking five compounds for minimum RF
factors, there is a requirement to evaluate 49 compounds in method 8260C.
As you can see, these are fairly minor differences but do represent a step forward in
evaluating the entire analyte list instead of choosing a select group of compounds that
may or may not represent the compounds of concern.
Page 1 of 2
All analyses applicable to the CWA, SDWA. and RCRA arc performed in accordance lo NELAC protocols. Pertinent sampling information is located on the attached COC. This report is provided for the exclusive use ofthe
addressee. fVivileges of subsequent useof ihenameof this company or any member of its staff, or reproduction ofihis report in connection with the advertisement, promotion or sale ofanyproduclor process, or in connection
with there-publication of Ihis report for any purpose other than forthe addressee will be granted only on contact. This company accepts no responsibility except for the due perfomiance of inspection and/or analysis in good faith
and according to the rules of the trade and of science.
A
AMERICAN
WEST
ANALYTICAL
LABORATORIES
If you have any questions or require additional information, please do not hesitate to
contact me.
Sincerely,
Kyle F.
Gross
Kyle F. Gross
Di9itii)rlignrdbvK>1er
DN cn=Ky*t F (XOH.
0=AWALOII=AWA1.
iFtniil>kyle»«>vi[.|ib) Com
t=US
C^tr 101007 16M4J'<9
-07^0
463 West 3600 South
Salt Lake City, UT
84115
[phone]
Toll Free [phone]
Fax [phone]
email: [e-mail]
Kyle F. Gross
Laboratory Director
Jose Rocha
QA Officer
' Test Methods for Evaluating Solid Waste, Update III December 1996: United States Environmental
Protection Agency, Officeof solid Waste and Emergency Response, Washington, DC 20460.
' Test Methods for Evaluating Solid Waste, August 2006: United States Environmental Protection Agency,
office of solid Waste and Emergency Response, Washington, DC 20460.
Page 2 of 2
All analyses applicable tothe CWA, SDWA, and RCRA are performed in accordance to NELAC protocols. Pertinent sampling information is located on the attached COC. This report is provided forthe exclusive useof the
addressee. Privileges of subsequent use of the name of this company or any member of its staff, or reproduction of this report in connection with the advertisement, promotion or sale of any product or process, or in coimcction
with the re-pub I ication of this report for any purpose olher than for the addressee will be granted only on contaci. This company accepts no responsibility except for the due performance of inspection and/or analysis in good faith
and according to the rules of Ibeirade and of science.