DRC-2010-003461 - 0901a06880190309

RC-2010-00346!
DENISO
MINES Received
JUN 2010
Division of
Radiation Corrtrol
June 4,2010
SENT VIA PDF AND FEDERAL EXPRESS
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: White Mesa Uranium
Groundwater Sampling
Mill - Revised Quality Assurance Plan (QAP) for
Dear Mr. Finerfrock:
In accordance with our letter of April 2, 2010, regarding groundwater sampling procedures,
Denison Mines (USA) Corp. ("DUSA) is pleased to provide the attached draft Revision 7.0 of
the White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan (the "QAP"j to
the Utah Department of Environmental Quality ("DEQ") for review and comment. This QAP is
provided under the DUSA State of Utah Groundwater Discharge Permit No. UGW370004 (the
"Permit").
The attached Revision 7 QAP incorporates several proposed changes to field procedures
designed to meet DEQ requirements in compliance with EPA protocols and best professional
practice. As stated in the April 2, 2010 letter, the purpose of the proposed revisions to the QAP
is to revise sampling methods so that representative samples will consistently be obtained from
all monitoring wells at the site, EPA-approved criteria will be met, and the QAP will comply
with this best-practice methodology for the specific groundwater conditions at the Mill site.
Some additional proposed revisions to the QAP, not discussed in the April 2, 2010 letter, are also
proposed, to update the QAP to reflect best industry practice.
The following is a discussion of sections of the QAP that have been revised or modified.
1. Well Purge Procedures
1.1 General
The well purging procedures presented currently in the QAP are tied to both well volume and
stabilization of groundwater field parameters (QAP Section 6.2.7). The wells are required to be
purged of two casing volumes and the measured field parameters are required to be stable before
sampling. This requirement for both well volume and stable parameters has been difficult or
impossible lo achieve using current methods and has motivated DUSA to seek altematives which
are achievable and in compliance with accepted guidance. DUSA's sampling objective, in
compliance with EPA guidance, is to "collect samples that are "representative" of in-situ ground
water conditions and to minimize changes in groundwater chemistry during sample collection
and handling." (Yeskis and Zavala, 2002). As discussed previously, there are a number of ways
to obtain representative groundwater samples, and DUSA suggests that providing these multiple
methods in the QAP will be the best way to obtain representative, defensible samples and also
meet the DEQ regulatory requirements.
As a result, DUSA proposes that three options for purging be available in the QAP: evacuation
of three casing volumes; for wells in which low flow sampling is employed, achieving stable
parameters; or purging a well to dryness.
1.2 Evacuation of Three Casing Volumes
For the first option of evacuating three casing volumes, we are proposing to increase the well
volume criteria from two casing volumes to three casing volumes. DUSA understands that three
casing volumes, as opposed to two casing volumes, is the industry standard for purge volume
from wells with sufficient yields such that the three volumes may be achieved within a
reasonable period of time. It is likely that groundwater parameters would be stable after purging
three casing volumes, although with a maximum of three casing volumes as a purge criteria, the
groundwater would be considered "representative" after three volumes even if some field
parameter measurements (such as turbidity, or other parameters) remained in flux. The three
casing volume evacuation method would be an option for any well on site at any time.
1.3 Low Flow Sampling
DUSA also proposes that parameter stabilization be used as independent criteria for
representative groundwater for low flow wells. In other words, if all field parameters are found
to be stable, as presented in the most current EPA groundwater sampling guidance (Yeskis and
Zavala, 2002) prior to achieving the three casing volume purge, then the groundwater would be
considered representative and sampling could commence.
Low flow sampling, also called minimal drawdown sampling and "low stress" sampling, consists
of sampling a groundwater monitoring well at a rate that is equal to or less than the natural
recharge rate of the aquifer. This sampling method is based on the understanding that water
within the screened interval is "dynamic groundwater" and is representative of aquifer
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conditions. The objective is to obtain the sample directly from the formation within the screened
interval, to the exclusion of water that may be present in the blank casing above the screened
interval. All low flow protocols are designed to maintain this separation between the so-called
"stagnant water" in the blank casing and the representative dynamic aquifer water in the screen
interval. Low flow sampling may be accomplished in wells with the water level above the top of
the screen or with the water level within the screened interval. Low flow sampling is conducted
using dedicated pumps (pumps installed permanently in the well, as opposed to using a portable
pump) so that the water in the blank casing above the screen (if any) is not mixed with the
dynamic water flowing directly from the aquifer through the screen.
Low flow sampling is conducted at flow rates within the range of 0.1 to 0.5 liters per minute
(approximately 0.026 to 0.132 gallons per minute). If a stagnant water column is present in the
well, the bladder pump flow rate is set so that pumping causes little or no drawdown of the water
column. This is determined by measuring the change (if any) in water level during pumping
using an electronic, hand-held water level measuring device. The objective is to set a pumping
rate that causes no drawdown, and EPA guidance provides a drawdown goal of less than 0.1
meter or approximately 0.33 feet (Puis and Barcelona, 1996 and Yeskis and Zavala, 2002). If
there is no stagnant water column in the well, then drawdown is not an issue because any water
entering the pump is dynamic and is considered representative aquifer water.
The purge process for low flow sampling differs significantly from purging by the muhipie
casing volume method. In low flow sampling, the purge consists of evacuating only the volume
of water that may be present in the pump, in the water discharge tubing leading from the pump to
the surface, and the volume of a flow-through cell that may be used to measure water-quality-
indicator parameters. Water-quality-indicator parameters of pH, specific electrical conductance,
oxidation-reduction potential, temperature, dissolved oxygen and turbidity are monitored during
the process of evacuating the pump, tubing, and flow-through cell. The parameters are measured
and recorded every three to five minutes. Once three successive readings of the water-quality-
indicator parameters have stabilized according to the EPA guidance (Yeskis and Zavala, 2002),
as set out in Section 6.2.7 iv) of the QAP, sampling may commence.
1.4 Evacuation to Dryness
The third option, to draw the well to dryness, is retained in the QAP for wells which do not yield
sufficient water to utilize either of the options presented in 1.2 or 1.3 above. In this case, the
well would be sampled as soon as there is sufficient water in the well to provide the required
sample volumes, and by definition, the water would be considered representative. This purge
and sampling option for low-permeability wells is described in the 2002 EPA (Yeskis and
Zavala) guidance, page 9.
2. Equipment Rinsate Samples
Section 4.3.2, Equipment Rinsate Samples, has been changed to clarify that, where a portable
(non-dedicated) pump or non-disposable or non-dedicated bailer is used, one equipment rinsate
sample is collected daily from the decontaminated pump or bailer. The existing language can be
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read to suggest that an equipment rinsate sample is required after each decontamination
procedure following each well sampling.
The Equipment Rinsate Sample is the sample that is collected from the pump or bailer after it has
been cleaned (decontaminated) to determine the effectiveness of the decontamination process,
rather than to verify the effectiveness of each actual decontamination procedure that is
performed.
The rationale for this proposed change is that the previous language was confusing. The
replacement language complies with EPA guidance (EPA, 1986) Technical Enforcement
Guidance Document (TEGD) which recommends that one Equipment Blank (also known as an
Equipment Rinsate Sample) be collected daily.
3. Pump Decontamination Procedure
Section 6.2.5, Pump Decontamination Procedure, has been revised to state that, if a portable
(non-dedicated) pump is to be used, the pump will be decontaminated after each use, according
to the specified procedure.
This language replaces language that was confusing and could be misinterpreted. The objective
of the decontamination procedure is to clean the pump and related equipment after each use in
the monitoring wells. This simplified language ensures that the pump will always be
decontaminated after use in a well and, according to the revised language later in Section 6.2.5,
the pump and related equipment (tubing, wiring, etc.) will be placed in a protective wrapping or
bag during transport between wells so that it will remain clean after the decontamination process
prior to insertion into the next well.
4. Use of Hydrochloric and Nitric Acid for Decontamination
Section 6.2.5 c) has been amended to require the hydrochloric or nitric acid rinse only if the
samples are to be analyzed for heavy metals. The acid rinse was historically used primarily on
superfund sites where metallic contaminants, such as chromium, cadmium, lead, etc. were a
concem. There is no need to use this acid wash for the chloroform or nitrate investigation wells.
In fact, a nitric acid wash could potentially interfere with the nitrate analytical results from those
wells. A thorough cleaning with soap (Liqui-Nox) and dionized water is sufficient, and the
results from laboratory analysis of the Equipment Rinsate Samples will be analyzed to verify
this.
5. Analytical Methods
We have proposed to change Section 8.2 to allow for the use of EPA-approved updated
analytical methods. This is consistent with industry practice and would avoid the situation where
use of an improved, updated method would result in a violation of the
QAP. The QAP should encourage the use of updated methods, not discourage it.
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6. Changes to Field Data Worksheets
We are also proposing some changes to the Field Data Worksheet and other attachments to the
QAP as improvements to the current versions.
7. Other Changes
A number of other minor wording changes are also proposed and are marked in the QAP.
If you have any questions or require any further information, please contact the undersigned.
David C. Frydenlund
Vice President, Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Ryan Palmer
Harold R. Roberts
Rob Sengebush, INTERA
Jo Ann S. Tischler
David E. Turk
Kathy Weinel
DENISO
MINES
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
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Quality Assurance Plan (QAP) Page 1 of 52
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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Quality Assurance Plan (QAP) Page 2 of 52
TABLE OF CONTENTS Page

1. INTRODUCTION……………………………………………………………………. 6

2. ORGANIZATION AND RESPONSIBILITIES…………………………………… 6

2.1. Functional Groups…………………………………………………………….............. 6

2.2. Overall Responsibility For the AQ/QC Program…………………………….............. 6

2.3. Data Requestors/Users..……………………………………………………………… 6

2.4. Data Generators…………………………..…………………………………………... 7
2.4.1. Sampling and QC Monitors…………………………………………………………... 7
2.4.2. Analysis Monitor……………………………………………………………………… 8
2.4.3. Data Reviewers/Approvers…………………………………………………………… 8

2.5. Responsibilities of Analytical Laboratory…………………………………………….. 8

3. QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA… 9

3.1. Precision……………………………………………………………………………… 9

3.2. Accuracy……………………………………………………………………………… 10

3.3. Representativeness……………………………………………………………………. 10

3.4. Completeness…………………………………………………………………………. 10

3.5. Comparability…………………………………………………………………………. 10

4. FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY…………… 11

4.1. Controlling Well Contamination…..…………………………………………………. 11

4.2. Controlling Depth to Groundwater Measurements.………………………….............. 11

4.3. Water Quality QC Samples………………………………………………………….. 11
4.3.1. VOC Trip Blanks…………………………………………………………………….. 11
4.3.2. Equipment Rinsate Samples………………………………………………………….. 11
4.3.3. Field Duplicates………………………………………………………………………. 12
4.3.4. Definition of “Batch”…………………………………………………………………. 12

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5. CALIBRATION……………………………………………………………………… 12

5.1. Depth to Groundwater Measurements……………………………………………….. 12

5.2. Water Quality………………………………………………………………………... 12

6. GROUND WATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS…………………………………………………………………………...
12

6.1. Groundwater Head Monitoring……………………………………………………… 12
6.1.1. Location and Frequency of Groundwater Head Monitoring………………………… 12
6.1.2. Equipment Used For Groundwater Head Monitoring……………………………….. 14
6.1.3. Field Sampling Procedure for Groundwater Head Monitoring……………………… 14

6.2. Ground Water Compliance Monitoring.……………………………………………... 14
6.2.1. Location and Frequency of Groundwater Compliance Monitoring.…………………. 14
6.2.2. Quarterly and Semi-Annual Sampling Required (Paragraphs I.E.1.a) orI.E.1.b) of the
GWDP)…………………………………………………………………………………………
15
6.2.3. Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the
GWDP………………………………………………………………………………...
15
6.2.4. Sampling Equipment for Groundwater Compliance Monitoring……………………. 15
6.2.5. Decontamination Procedure………………………………………………………….. 17
6.2.6. Pre-Purging/Sampling Activities………………………………………………………. 17
6.2.7. Well Purging/Measurement of Field Parameters……………………………………… 18
6.2.8. Samples to be Taken and Order of Taking Samples…………………………………... 22
6.2.9. Field Duplicate Samples……………………………………………………………….. 22
6.2.10. VOCs and Nutrient Sampling…………………………………………………………. 23
6.2.11. Heavy Metals, All Other Non-Radiologics and Gross Alpha Sampling………………. 23
6.2.12. Procedures to Follow After Sampling…………...…………………………………….. 27

7. SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING……. 27

7.1. Field Data Worksheets………………………………………………………………. 22

7.2. Chain-Of-Custody and Analytical Request Record…………………………………. 28

7.3. Record Keeping……………………………………………………………………… 29

8. ANALYTICAL PROCEDURES AND QA/QC…………………………………….. 29

8.1. Analytical Quality Control…………………………………………………………... 29
8.1.2. Spikes, Blanks and Duplicates………………………………………………………. 30

8.2. Analytical Laboratory Procedures…………………………………………………… 30
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9. INTERNAL QUALITY CONTROL CHECKS…………………………………… 34

9.1. Field QC Check Procedures…………………………………………………………. 34
9.1.1. Review of Compliance With the Procedures Contained in this Plan………………... 34
9.1.2. Analyte Completeness Review………………………………………………………. 34
9.1.3. Blank Comparisons………………………………………………………………….. 34
9.1.4. Duplicate Sample Comparisons……………………………………………………... 34

9.2. Analytical Laboratory QA Reviews…………………………………………………. 35

9.3. QA Manager Review of Analytical Laboratory Results and Procedures……………. 36

9.4. Analytical Data………………………………………………………………………. 37

10. CORRECTIVE ACTION……………………………………………………………. 37

10.1. When Corrective Action is Required………………………………………………... 37

10.2. Procedure for Corrective Action…………………………………………………….. 38

11. REPORTING…………………………………………………………………………. 38

12. SYSTEM AND PERFORMANCE AUDITS……………………………………….. 39

12.1. QA Manager to Perform System Audits and Performance Audits…………………... 39

12.2. System Audits……………………………………………………………………….. 40

12.3. Performance Audits………………………………………………………………….. 40

12.4. Follow-Up Actions…………………………………………………………………... 42

12.5. Audit Records………………………………………………………………………... 40

13. PREVENTIVE MAINTENANCE………………………………………………… 40

14. QUALITY ASSURANCE REPORTS TO MANAGEMENT…………………… 41

14.1. Ongoing QA/QC Reporting…………………………………………………………. 41

14.2. Periodic Reporting to Management………………………………………………….. 41

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15. AMENDMENT………………………………………………………………………. 42

16. REFERENCES……………………………………………………………………….. 42

Attachments

Attachment 1 – Sample Field Data Worksheet
Attachment 2 – Sample Chain of Custody Forms Attachment 3 – Instrument Calibration/Check Worksheet

Appendices

Appendix A- Chloroform Investigation Monitoring Quality Assurance Program

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1. INTRODUCTION
This Groundwater Monitoring Quality Assurance Plan (the “Plan”) details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary to
comply with UAC R317-6-6.3(I) and (L) at the White Mesa Uranium Mill (the “Mill”), as
required under paragraph I.H.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 TechnicalGuidance (November 1992) as well as
EPA’s more recent Ground Water Issue, Low Flow (Minimal Drawdown) Ground-Water
Sampling Procedcures (Puls and Barcelona 1996) and Groundwater Sampling Guidelines for
Superfund and RCRA Project Managers, Groundwater Issue Paper (Yaskis and Zavala 2002).

Activities in an integrated program to generate quality data can be classified as management (i.e.,
quality assurance or “QA”) and as functional (i.e., quality control or “QC”). The objective of this
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 of these representatives are described below.

2.2. Overall Responsibility For the QA/QC Program

The overall responsibility for ensuring that the QA/QC measures are properly employed is the
responsibility of the QA Manager. The QA Manager is typically not directly involved in the data
generation (i.e., sampling or analysis) activities. 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 of the Data
Users are the data generators. For Mill activities, this involves sample collection, record keeping
and QA/QC activities conducted by one or more sampling and quality control/data monitors
(each a “Sampling and QC Monitor”). The Sampling and QC Monitors are 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 of custody 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 of the data generators are as follows:

2.4.1. Sampling and QC Monitors

The Sampling and QC Monitors are responsible for field activities. These include:

a) Ensuring that samples are collected, preserved, and transported as specified in 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 of the program;

d) Preparing quality control samples for field sample collection during the sampling event;

e) Preparing QC and sample data for review by the QA Manager; and

f) Preparing QC and sample data for reporting and entry into a computer data base, where
appropriate.

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2.4.2. Analysis Monitor

The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory. These
include:

a) Training and qualifying personnel in specified Analytical Laboratory QC and analytical
procedures, prior to receiving samples;

b) Receiving samples from the field and verifying that incoming samples correspond to the
packing list or chain-of-custody sheet; and

c) Verifying that Analytical Laboratory QC and analytical procedures are being followed as
specified in this 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 of QA/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 personnel.
2.5. Responsibilities Of Analytical Laboratory

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.
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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with the
requirements for maintaining 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 of a 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 radionuclide requirements as stipulated in
the applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical procedures
used by the Analytical Laboratory will be in accordance with Utah Administrative Code R317-6-
6.3L.

3. QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA

The objective of this 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:

RPD = [(A-B)/{(A+B) /2}] x 100

Where A (original) and B (duplicate) are the reported concentration for field duplicate samples
analyses (or, in the case of analyses performed by the Analytical Laboratory, the percent
recoveries for matrix spike and matrix spike duplicate samples) (EPA SW-846, Chapter 1,
Section 5.0, page 28).
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3.2. Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and an accepted reference 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 = (│A-B│/C) x 100

Where:

A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added

3.3. Representativeness

Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an environmental
condition. Representativeness is controlled by performing all sampling in compliance with this
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 of measurements) x 100

Where the number of valid data points is the total number of valid analytical measurements based
on the precision, accuracy, and holding time evaluation. Completeness is determined at the
conclusion of the data validation.

Executive Secretary approval will be required for any completeness less than 100 percent.

3.5. Comparability

Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection techniques,
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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 of
mild steel with a lockable cap cover. Radiation Safety staff has access to the keys locking the
wells.

Subsurface well stagnation, for pumped wells, is reduced by pumping three well casing volumes
of water from the wells or, if Low Flow sampling is used in accordance with Section 6.2.7(b)
below, achieving stable field measurements (sometimes referred to in the literature as water-
quality-indicator parameters) as specified in Section 6.2.7(b)(ix), 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 of the following QC samples:
4.3.1. VOC Trip Blanks

Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds (“VOCs”) through diffusion during sample transport and storage. At
a minimum (at least) one trip blank will be in each shipping container containing samples to be
analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory, transported to the
sampling site, and then returned to the Analytical Laboratory for analysis along with the samples
collected during the sampling event. The trip blank will be unopened throughout the
transportation and storage processes and will accompany the technician while sampling in the
field (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 or non-disposable or non-dedicated bailer is used, collect
an equipment rinsate sample daily from the decontaminated pump or bailer. In the case of
equipment rinsate samples for a pump, the sample will be prepared by pumping de-ionized water
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into the sample containers. In the case of equipment rinsate 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 samples 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 of this 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 of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance with
manufacturers’ recommendations, and Analytical Laboratory equipment shall be calibrated in
accordance with Analytical Laboratory procedures.

5.1 Depth to Groundwater Measurements

Equipment used in depth to groundwater measurements will be checked prior to each day’s use
to ensure that the Water Sounding Device is functional.

5.2 Water Quality

The Field Parameter Meter will be calibrated according to manufacturer’s specifications .
Temperature will be checked comparatively by using a thermometer. Calibration and routine
check results will be recorded on the Instrument Calibration/Check Worksheet which is included
as Attachment 3 .

6. GROUND WATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS

6.1. Groundwater Head Monitoring

6.1.1. Location and Frequency of Groundwater Head Monitoring

Depth to groundwater shall be measured quarterly in the following wells and piezometers:
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a) All Point of Compliance wells listed in paragraphs 6.2.1 a), b) and c) below;

b) Monitoring wells MW-20 and MW-22;

c) All piezometers (P-1, 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-20-01, not already included in paragraph (a). On
June 4, 2010, such chloroform contaminant investigation wells were the following:

• MW-4
• TW4-1
• TW4-2
• TW4-3
• TW4-4
• TW4-5
• TW4-6
• TW4-7
• TW4-8
• TW4-9
• TW4-10
• TW4-11

• TW4-12
• TW4-13
• TW4-14
• TW4-16
• TW4-18
• TW4-19
• TW4-20
• TW4-21
• TW4-22
• TW4-23
• TW4-24
• TW4-25
• TW4-26

e) All Nitrate and Chloride Investigation and Corrective Action Plan wells required
under the January 26, 2009 Stipulated Consent Agreement, Docket No. UGW09-03.
As ofJune 4, 2010, the following wells are part of the Nitrate and Chloride
investigation:

• TWN-1
• TWN-2
• TWN-3
• TWN-4
• TWN-5
• TWN-6
• TWN-7
• TWN-8
• TWN-9
• TWN-10

• TWN-11
• TWN-12
• TWN-13
• TWN-14
• TWN-15
• TWN-16
• TWN-17
• TWN-18
• TWN-19

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f) 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 of Groundwater 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-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24,
MW-27, MW-28, MW-29, and MW-32;

b) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-25,
MW-26, MW-30, and MW-31.;

c) Quarterly, in the following wells: MW-20 and MW-22 for as long as required under
paragraph I.E.2 of the GWDP; and

d) Chloroform 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.1 or I.G.2 of the GWDP. It is
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important to confirm 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.1.a) or I.E.1.b) of
the GWDP

All quarterly and semi-annual samples collected under paragraphs 6.2.1 a), b), c) and d) above
(paragraphs I.E.1b), I.E.1.c) or I.E.2of the GWDP) shall be analyzed for the following
parameters:

a) Field parameters– depth to groundwater, pH, specific conductance, redox potential
(Eh), temperature, dissolved oxygen (DO) and turbidity in the manner specified in
paragraphs 6.2.7 a) or b); and

b) Laboratory Parameters:

(i) All parameters specified in Table 2 of the GWDP; and

(ii) General inorganics – chloride, sulfate, carbonate, bicarbonate, sodium potassium,
magnesium, calcium, and total anions and cations.
6.2.3. Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the
GWDP

Any quarterly or monthly sampling required under paragraphs I.G.1. 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.

6.2.4. Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.

For the purposes of this QAP the following equipment definitions shall apply:

• Dedicated Bailer
•
: A bailer that is dedicated to be used at one specific well for the
use of purging or sampling. Said bailer will 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
of purging or sampling. Said pump will remain with and inside the well
: A pump that is dedicated to one specific well for the use
casing suspended and secured.
• Non – Dedicated Pump
or more wells.
: A pump that is used for purging and sampling at one
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Groundwater compliance monitoring is accomplished by using 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.

e) Turbidity measuring instrument ;

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, clean sample containers as provided by the Analytical Laboratory;

k) De-ionized water;

l) One new, unused, clean disposable single check valve bailer, or the equivalent, for
each well to be sampled for VOCs; unless the well is outfitted with a dedicated pump,
in which case the sample for VOCs is taken directly from the pump discharge; and

m) If any portable (non-dedicated) pumps are used, the following equipment, supplies
and solutions, or the equivalent, necessary for decontamination procedures:

• de-ionized water
• de-ionized water/nonphosphate detergent (such as Liqui-Nox);
• de-ionized water/HNO3 solution (this solution is used during decontamination
only when samples will be analyzed for heavy metals);
• Rubber gloves; and
• Clean, sealed sample containers from the Analytical Laboratory for any
equipment rinsate samples.
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6.2.5. Pump Decontamination Procedure

If a portable (non-dedicated) pump is to be used, the pump will be decontaminated after each use,
according to the following procedure:

a) wash the pump 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 (.1N) hydrochloric or nitric acid (only if
samples will be analyzed for heavy metals; and

d) rinse the Sampling Equipment with de-ionized water.

All water produced during decontamination will be containerized. Containerized water will be
disposed of in Tailings Cell 1.

All sampling and purging equipment that has been decontaminated as per the foregoing
procedure shall be covered with plastic sheeting or plastic bags 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 it is working properly
(for example, no air is leaking into the discharge line, in order to prevent aeration of the
sample);

b) If a portable (non-dedicated) pump is to be used, at the completion of sampling from
each well, 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, collect one Equipment Rinsate Sample
daily using 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 transport
the VOC samples. The Trip Blank(s) in the cooler will accompany the groundwater
samples throughout the monitoring event.

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6.2.7. Well Purging/Measurement of Field Parameters

(Note: 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 subsurface at the location of
the well, follow the additional procedures, to be provided by the RSO.)

There are three methods of purging a well prior to sampling: evacuating three casing volumes;
achieving stable field parameters using low flow sampling; and evacuating a well to dryness.
Purging is completed if any one of the three methods is employed in accordance with the
following provisions:

a)

Evacuating Three Casing Volumes
This method of purging can be used on any well.

(i) Remove the well casing cap and measure and record depth to groundwater by
following the procedures set out in paragraph 6.1.3 above;

(ii) 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
from the total depth of the well), V

= 0.653*h, for a 4” casing volume and V =
.367*h for a 3” casing volume. Record the casing volume on the Field Data
Worksheet;
(iii) Purging, Where Use of Pump is Effective (See paragraph 6.2.7(a)(iv) below,
where bailer is required)

A. 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 agitation of the water upon impact.
Once the pump is lowered into the well, or if the well has a dedicated
pump, perform the following steps:

B. Commence pumping;

C. 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 of the Field Data Worksheet;

D. Calculate the amount of time to evacuate three casing volumes;

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E. Take measurements of field parameters (pH, specific conductance, redox
potential, temperature, dissolved oxygen and turbidity) during well
purging, using the Field Parameter Meter. These measurements will be
recorded on the Field Data Worksheet. At a minimum, measure the field
parameters at the beginning of purging and after each of three casing
volumes have been evacuated;

F. Purging is completed after three casing volumes have been removed.

(iv) Purging, Where Use of Pump is Not Effective (See paragraph (vi) above, where
use of pump is 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 to evacuate the three casing
volumes, or, in those cases where the water column is not shallow but the well takes
over two days to recover, to evacuate the final few feet of water after removing the
portable pump. If a bailer is used, the following procedure will be followed:

A. Use the sound level instrument to determine the water column and figure
the amount of water that must be evacuated;

B. Attach a disposable bailer to a rope and reel;

C. Lower the bailer into the well and listen for contact with the groundwater.
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;

D. 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;

E. After the bailer is emptied, lower the bailer back into the well and fill the
bailer as before. This process will continue until the three casing volumes
have been collected or until no more water can be removed. When the
process is finished for the well and the sample for the well is taken, the
bailer will be disposed of; and

F. Take measurements of field parameters referred to in paragraph
6.2.7(a)(iv)E above from the water in the buckets. At a minimum,
measure field parameters at the beginning of purging and after each of
three casing volumes have been evacuated.
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b)

Low Flow Sampling
Low flow sampling, also called minimal drawdown sampling and “low stress” sampling, consists
of sampling a ground-water monitoring well at a rate that is equal to or less than the natural
recharge rate of the aquifer. Low Flow sampling is only appropriate for wells that meet the
criteria specified in this paragraph (b). The Mill’s RSO will identify which wells are suitable for low flow sampling. However, purging using the Low Flow sampling method will only be considered successful if all of the steps and conditions in this paragraph (b) are followed and satisfied. If all of the steps and conditions are not followed and satisfied, then one of the other purging procedures (evacuation of three casing volumes or evacuation to dryness) will be
required to be used.

(i) The well must be equipped with a dedicated pump capable of pumping at a flow
rate of approximately 0.026 to 0.132 gallons per minute (gpm);

(ii) Remove the well casing cap and measure and record depth to groundwater by
following the procedures set out in paragraph 6.1.3 above;

(iii)The pump flow rate must be set so that the drawdown in the water level during
pumping is not expected to exceed four inches. This is determined by measuring
the change (if any) in the water level during pumping using an electronic hand-
held water level measuring device. Record the depth to the water level every
three to five minutes and at the end of purging. If drawdown is occurring at the
beginning of the pumping cycle, decrease the pumping rate until drawdown does
not occur, and continue pumping to evacuate a water volume equal to the volume
of water in the pump, the discharge line and the flow-through cell, as stated in
paragraph vii below;

(iv) The Mill’s RSO will have designated which wells have a stagnant water column.
If the depth to water is less than the depth to the top of the screened interval, then
the well is considered to have a stagnant water column. If the water level draws
down by more than four inches in any well with a stagnant water column, Low
Flow purging of the well has not been successful and one of the other purging
methods (evacuation of three casing volumes or evacuation to dryness) must be
used;

(v) Commence pumping at a rate of between 0.026 to 0.132 gpm or as appropriate so
that the water level does not draw down by more than four inches;

(vi) Contain all water in a calibrated bucket in order to determine the amount of water
purged;

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(vii) It is only necessary to evacuate the volume of water that may be present in the
pump, in the water discharge tubing leading from the pump to the surface and
the volume of the flow-through cell that is used to measure the field parameters;

(viii) Measure and record the following field parameters every three to five minutes
during the process of evacuating the pump, tubing and flow-through cell: pH,
specific conductance, redox potential, temperature, dissolved oxygen and
turbidity;

(ix) Purging will be complete once three successive readings of the field parameters
have stabilized and meet the following Stabilization Criteria:

Parameter Stabilization Criteria

Temperature +/- 0.1 degree F
pH +/- 0.1 pH unit
specific conductivity +/- 3%
Redox potential (Eh) +/- 10 millivolts
Turbidity +/- 10% (when turbidity is greater than
10 NTUs)
Dissolved oxygen (DO) +/- 0.3 milligrams per liter

(x) If it is not possible to achieve the foregoing Stabilization Criteria while satisfying
the other Low Flow sampling requirements set out in this paragraph (b), then
another method of purging (evacuation of three casing volumes or evacuation to
dryness) must be used;

c)

Evacuation to Dryness
If any well cannot yield three casing volumes,

(i) Evacuate the well to dryness and record the number of gallons evacuated on the
Field Data Worksheet; and

(ii) 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;

d)

Disposal of Purged Water
All water produced during well purging will be containerized. Containerized water
will be disposed of in either Tailings Cells 1, 3, or 4A;

e)

When to Proceed to Sampling
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(i) If the well yields three casing volumes, or Low Flow purging is successfully
accomplished in accordance with Section b) above, the individual performing the
sampling should immediately proceed to Section 6.2.8; and

(ii) If the 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.

6.2.8. Samples to be taken and order of taking samples

For each sampling event, unless sampling for a specific parameter under the accelerated
monitoring requirements of paragraphs I.G.1 or I.G.2 of the 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 unless the well is outfitted
with a dedicated pump, in which case sample for VOCs directly from the pump
discharge);

b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml (a bailer is used
unless the well is outfitted with a dedicated pump, in which case sample for nutrients
directly from the pump discharge);

c) Heavy metals, 1 sample container, 250 ml, filtered;

d) All other non-radiologics (fluoride, general inorganics, TDS, total cations and anions), 1
sample container, 250 ml,; 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; and

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
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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.

6.2.10. VOCs and Nutrient Sampling

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 the dedicated sample pump or 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; and

f) Discard the bailer.

6.2.11. Heavy Metals, All Other Non-Radiologics and Gross Alpha Sampling

When sampling for heavy metals, all other non-radiologics 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 with dedicated pumps or 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;

(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;
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(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) If using a portable (non-dedicated pump), remove the pump from the well; and

(v) If using a portable (non-dedicated pump), decontaminate the pump as per Section
6.2.5. Do not place the decontaminated pump on the ground or on other
contaminated surfaces;

d) When using a bailer to sample (wells without dedicated pumps or 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
of after 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 of sampling 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 of the
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 of the equipment using DI water
• Rinsing the equipment with a mixture of DI water and HNO
• Rinsing the equipment with a mixture of DI water and Liqui-Nox
soap
3
• Rinsing the equipment with DI water
• Finally the collection of the final process rinsate solutions are
placed in the sample collection cooler and labeled as a filtration
equipment rinsate sample;

I. The flask is attached to the vacuum system in the laboratory using Tygon
Vacuum Tubing, or the equivalent;

J. The micro-filtration system is then inserted into the filter flask;
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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;

N. When the flask is full, the vacuum is turned off and the bell is unclamped
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 of sample 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 of the
filtration process is approximately ½ 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.
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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 of sample
• 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;

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 6o C. These samples shall be received by the Analytical Laboratory at less
than or equal to 6o

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 of observations and data from sampling provide important information about the
sampling process and provide a permanent record for sampling activities. All observations and
field sampling data will be recorded in waterproof ink on the Field Data Worksheets, which will
be maintained on file at the Mill.

The Field Data Worksheets will contain the following information:

• Name of the site/facility
• description of sampling event
• location of sample (well name)
• sampler’s name(s) and signature(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump including type of pump or bailer)
• previous well sampled during the sampling event
• well depth
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• depth to groundwater before purging and sampling
• results of in-field measurements (pH, specific conductance, , redox potential,
temperature, turbidity)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory
• sampling event.

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 Field Data Worksheet
that incorporates this information is attached as Attachment 1.

7.2. Chain-Of-Custody and Analytical Request Record

A Chain-of-Custody and Analytical Request Record form (the “COC Form”), provided by the
Analytical Laboratory, will accompany the samples being shipped to the Analytical Laboratory.
Examples of the Chain of Custody Forms used are attached as Attachment 2. If the Chain of
Custody Form changes at any time, the Company shall provide a copy of the new or revised
Chain of Custody Form to the Executive Secretary and substitute the new form for the old form
in Attachment 2. Standard Chain-of-Custody protocol is initiated for each sample set. A COC
Form is to be completed for each set of samples collected in a shipping container (cooler) and is
to include the following:

• sampler’s name
• company name
• date and time of collection
• sample type (e.g., water)
• sample ID
• number of sample containers per location
• analyses requested
• signatures of persons involved in the chain of possession
• internal temperatures of the shipping container when opened at the laboratory
• comments section to identify potential hazards or to relay other information to the
Analytical Laboratory.

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Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.

The person shipping the samples to the Analytical Laboratory will sign the COC Form, document
shipment method, and send the original and the second copy of the COC Form with the samples.
Upon receipt of the samples, the person receiving the samples will sign the COC Form and return
the second copy to the Mill’s RSO.

Copies of the COC Forms and other relevant documentation will be retained at the Mill.

7.3. Record Keeping

The Field Data Worksheets are retained at the Mill.

Original Certificates of Analysis from the Analytical Laboratory, showing the laboratory
analytical results for the water samples, are maintained at the Mill.

Copies of the current Utah certifications of the Analytical Laboratory or Laboratories used to
perform analysis during the monitoring events conducted during the quarter. DUSA will ensure
that the Analytical Laboratory or Laboratories used, have certifications for each parameter and
method required by Section 8.2, Table 1 of the QAP. Copies of these certifications will be
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 I.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 of the 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.

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8.1.2. Spikes, Blanks and Duplicates

Analytical Laboratory QC samples will assess the accuracy and precision of the analyses. The
following describes the type of QC samples that will be used by the Analytical Laboratory to
assess the quality of the data. The following procedures shall be performed at least once with
each Batch of samples:

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 of conditions within a typical
matrix. The duplicate spike (matrix spike) sample serves as a check evaluating the effect
of the sample matrix on the accuracy of analysis.

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 occurred.

c)

Field Samples/Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) analyzed for organic constituents shall be spiked with surrogate
compounds prior to purging or extraction. Surrogates are organic compounds which are
similar to analytes of interest in chemical composition, extraction, and chromatography,
but which are not normally found in environmental samples. Surrogates shall be spiked
into samples according to the appropriate organic analytical methods.

d)

Check Sample
Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.

8.2. Analytical Laboratory Procedures

The analytical procedures to be used by the Analytical Laboratory will be those specified
in Table 1, or a more recently EPA promulgated version of the method listed or an
equivalent, EPA approved method, or as otherwise authorized by the Executive Secretary.
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With respect to Chloroform Investigation sampling, the analytical procedures for
parameters monitored under that program are specified at Item 4) of the Chloroform
Investigation Monitoring Quality Assurance Program (Appendix A to this document).

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Table 1

Contaminant Analytical
Methods
to be Used*
Reporting
Limit
Maximum
Holding
Times
1
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Nutrients
Ammonia (as N) A4500-
NH3 G
0.05 mg/L 28 days H2SO4pH<2
to ≤ 6oC
Nitrate & Nitrite
(as N)
E353.2 0.1 mg/L 28 days H2SO4pH<2
to ≤ 6oC

Heavy Metals
Arsenic E200.8 5 µg/L 6 months HNO3 None to pH<2
Beryllium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Cadmium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Chromium E200.8 25 µg/L 6 months HNO3 None to pH<2
Cobalt E200.8 10 µg/L 6 months HNO3 None to pH<2
Copper E200.8 10 µg/L 6 months HNO3 None to pH<2
Iron E200.7 30 µg/L 6 months HNO3 None to pH<2
Lead E200.8 1.0 µg/L 6 months HNO3 None to pH<2
Manganese E200.8 10 µg/L 6 months HNO3 None to pH<2
Mercury E200.8 0.50 µg/L 28 days HNO3 None to pH<2
Molybdenum E200.8 10 µg/L 6 months HNO3 None to pH<2
Nickel E200.8 20 µg/L 6 months HNO3 None to pH<2
Selenium E200.8 5 µg/L 6 months HNO3 None to pH<2
Silver E200.8 10 µg/L 6 months HNO3 None to pH<2
Thallium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Tin E200.8 100 µg/L 6 months HNO3 None to pH<2
Uranium E200.8 0.30 µg/L 6 months HNO3 None to pH<2
Vanadium E200.8 15 µg/L 6 months HNO3 None to pH<2
Zinc E200.8 10 µg/L 6 months HNO3 None to pH<2

Radiologics
Gross Alpha E900.1 1.0 pCi/L 6 months HNO3 to pH<2 None

Volatile
Organic
Compounds

Acetone SW8260B 20 µg/L 14 days HCl to pH<2 ≤ 6oC
Benzene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
2-Butanone
(MEK)
SW8260B 20 µg/L 14 days HCl to pH<2 ≤ 6oC
Carbon
Tetrachloride
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
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Contaminant Analytical
Methods
to be
Used*
Reporting
Limit
Maximum
Holding
Times
1
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Chloroform SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Naphthalene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Tetrahydrofuran SW8260B or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Toluene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Xylenes (total) SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC

Others
Field pH (S.U.) A4500-H B 0.01 s.u. Immediate None None
Fluoride A4500-F C 0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None ≤ 6oC

General
Inorganics

Chloride A4500-Cl B 1 mg/L 28 days None None
Sulfate A4500-SO4
E
1 mg/L 28 days None ≤ 6oC
Carbonate as CO3 A2320 B 1 mg/L 14 days None ≤ 6oC
Bicarbonate as
HCO3
A2320 B 1 mg/L 14 days None ≤ 6oC
Sodium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
Potassium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
Magnesium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
Calcium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
*The Analytical Laboratories will analyze samples using either the method listed, a more recently EPA promulgated version of
the method listed or an equivalent EPA approved method. 1. The Analytical Laboratory will be required to meet the reporting limits (“RLs”) in the foregoing Table, unless the RL must be
increased due to sample matrix interference (i.e., due to dilution gain), in which case the increased RL will be used, or unless
otherwise approved by the Executive Secretary.
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9. INTERNAL QUALITY CONTROL CHECKS
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 of Compliance 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.1(a) of the Permit. Executive Secretary approval will be required for any completeness
(prior to QA/QC analysis) less than 100 percent. Non-conformance will be defined as a failure to
provide field parameter results and analytical results for each parameter and for each well
required in Sections 6.2.2 and 6.2.3, for the sampling event, without prior written Executive
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)are greater than an
order of magnitude of the original sample result. (DTG Field QA/QC Program, page 7-31).

9.1.4. Duplicate Sample Comparisons

The following analyses will be performed on duplicate field samples:

a)

Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results. Non-
conformance will exist when the RPD > 20%, unless the measured activities are less than 5
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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)

Radiologics Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting variance
that is equal to or less than 20% of the reported activity concentration. An error term may be
greater than 20% of the reported activity concentration when the sum of the activity
concentration and error term is less than or equal to the GWCL.

c)

Radiologics, Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:

│A-B│/(sa2+sb2)1/2

< 2
Where:

A = the first duplicate measurement
B = the second duplicate measurement
sa2
s
= the uncertainty of the first measurement squared
b2

= the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.

(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).

If the QA Manager’s review finds any situations of non-conformance, see Section 10.

9.2. Analytical Laboratory QA Reviews

Full validation will include recalculation of raw data for a minimum of one or more analytes for
ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC review
which will include validating holding times and QC samples. Overall data assessment will be a
part of the validation process as well.

The Analysis Monitor or data validation specialist will evaluate the quality of the data based on
SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following: (1) sample preparation information is correct and complete,
(2) analysis information is correct and complete, (3) appropriate Analytical Laboratory
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procedures are followed, (4) analytical results are correct and complete, (5) QC samples are
within established control limits, (6) blanks are within QC limits, (7) special sample preparation
and analytical requirements have been met, and (8) documentation is complete.

The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the QA/QC
data. The Analytical Laboratory will provide the following information: (1) cover sheet listing
samples included in report with a narrative, (2) results of compounds identified and quantified,
and (3) reporting limits for all analytes. Also to be included are the QA/QC analytical results.

9.3. QA Manager Review of Analytical Laboratory Results and Procedures.

The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:

a)

Reporting Limit (RL) Comparisons
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 of the GWDP.

b)

Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory
are, those specified in Table 1, or a more recently EPA promulgated version of the method listed
or an equivalent, EPA approved method, unless otherwise approved by the Executive Secretary.
Non-conformance shall be defined when the Analytical Laboratory uses analytical methods not
listed in Table 1 and not otherwise approved by the Executive Secretary.

c)

Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.

d)

Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received by
the Analytical Laboratory at a temperature no greater than the approved temperature listed in
Table 1. Non-conformance shall be defined when the sample temperature is exceeded.

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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 of the corrective actions taken. All raw and reduced data will be
stored according to the Analytical Laboratory’s record keeping procedures and QA program. All
Analytical Laboratory procedures and records will be available for on-site inspection at any time
during the course of investigation.

If re-runs occur with increasing frequency, the Analysis Monitor and the 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. Corrective 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.

When non-conformance is identified, DUSA shall:

a) When non-conformance 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 of discovery and analyze again in compliance with all
requirements of this 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

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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 corrective action for non-conformance with the requirements of this Plan, may be
identified by system or performance audits or by standard QA/QC procedures. The procedures to
be followed if the need for a corrective action is identified, are as follows:

a) Identification and definition of the problem;

b) Assignment of responsibility for investigating the problem;

c) Investigation and determination of the cause of the problem;

d) Determination of a corrective action to eliminate the problem;

e) Assigning and accepting responsibility for implementing the corrective action;

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 corrective action will
be documented in a Report prepared in accordance with Section 11.

11. REPORTING

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:

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• Description of monitor 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 of compliance in any particular wells pursuant to Part
I.G.2 of the GWDP
• Copies of Field Data Worksheets
• Copies of Analytical Laboratory results
• Copies of Chain of Custody 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 of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this Plan and all corrective actions taken.
• Recommendations and Conclusions.

With respect to the chloroform investigation reporting requirements, these are specified at Item
5) of the Chloroform Investigation Monitoring Quality Assurance Program (Appendix A to this
document.

In addition, an electronic copy of all analytical results will be transmitted to the Executive
Secretary 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.1
and I.G.2 of the 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 performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined by
DUSA.

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12.2. System Audits
System audits are qualitative evaluations of all components of field and Analytical Laboratory
QC measurement systems. They determine if the measurement systems are being used
appropriately. System audits will review field and Analytical Laboratory operations, including
sampling equipment, laboratory equipment, sampling procedures, and equipment calibrations, to
evaluate the effectiveness of the QA program and to identify any weakness that may exist. The
audits may be carried out before all systems are operational, during the program, or after the
completion of the program. Such audits typically involve a comparison of the activities required
under this 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 performance audit is a quantitative evaluation of the measurement systems of a program. It
requires testing the measurement systems with samples of known composition or behavior to
evaluate precision and accuracy. With respect to performance audits of the analytical process,
either blind performance evaluation samples will be submitted to the Analytical Laboratory for
analysis, or the auditor will request that it provide results of the blind studies that the Analytical
Laboratory must provide to its NELAP 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.

12.4. Follow-Up Actions

Response to the system audits and performance audits is required when deviations are found and
corrective action is required. Where a corrective action is required, the steps set out in Section
10.2 will be followed.

12.5. Audit Records

Audit records for all audits conducted will be retained in Mill Central Files. These records will
contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.

13. PREVENTIVE MAINTENANCE

Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.

Field instruments will be maintained as per the manufacturer’s specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in accordance
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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 performed 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 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 of the 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 performance audits, including any corrective actions;
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 42 of 52

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.

16. REFERENCES

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 of Solid Waste.

16.4. Standard Methods for the Examination of Water and Wastewater, 20th

Edition, 1998.
American Public Health Association, American Water Works Association, Water Environment
Federation. Washington, D.C. p. 1-7.
16.5. United States Environmental Protection Agency, 2002, Ground-Water Sampling
Guidelines for Superfund and RCRA Project Managers, Ground Water Forum Issues Paper,
Yeskis and Zavala.

16.6. United States Environmental Protection Agency, 1996, Ground Water Issue, Low-Flow
(Minimal Drawdown) Ground-Water Sampling Procedures, Puls and Barcelona.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 43 of 52

ATTACHMENT 1
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 44 of 52

MiH _ Grou<>dw.ler Ois<I'IMC. Ptffl'oil
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 45 of 52

SAMPLE CHAIN OF CUSTODY FORMS
ATTACHMENT 2

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 46 of 52

CHAIN OF CUSTODY RICORD
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 47 of 52

ATTACHMENT 3
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 48 of 52

Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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Quality Assurance Plan (QAP) Page 49 of 52

Chloroform 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 Chloroform 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 Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:

1)

Dedicated Purge Pump
Chloroform 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 from an individual well and
disposed subsequent to the sampling or by dedicated pump. The wells without a
dedicated pump are purged by means of a portable pump. Each quarterly pumping
and sample collection event begins at the location least affected by chloroform (based
on the previous quarters sampling event) and proceeds by affected concentration to
the most affected location. Decontamination of all sampling equipment will follow
the decontamination procedure outlined in section 6.2.5 of the QAP.

2)

Chloroform Investigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No. UGQ-20-01. Chloroform wells shall be collected
from the least contaminated to the most contaminated as based on the most recent
quarterly results.

• MW-4
• TW4-1
• TW4-2
• TW4-3
• TW4-4
• TW4-5
• TW4-6
• TW4-7
• TW4-8
• TW4-13
• TW4-14
• MW-26
• TW4-16
• MW-32
• TW4-18
• TW4-19
• TW4-20
• TW4-21
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Quality Assurance Plan (QAP) Page 50 of 52

• TW4-9
• TW4-10
• TW4-11
• TW4-12

• TW4-22
• TW4-23
• TW4-24
• TW4-25

Note:

Wells MW-26 and MW-32 may be monitored under either the Chloroform
Investigation Program or the Groundwater Discharge Permit Monitoring Program.
3)

Chloroform Investigation Sample Containers and Collection Volume
The chloroform investigation sampling program requires a specific number of
sampling containers and the collection of specific volumes of sample. Accordingly,
the following sample volumes are collected by bailer (when the well is not outfitted
with a dedicated pump) from each sampling location:

• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
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Quality Assurance Plan (QAP) Page 51 of 52

4) For Inorganic Chloride, collect one sample into a 250 ml container.Laboratory
Requirements

Collected samples which are gathered for chloroform inve
delivered to an outside laboratory where the requisite analyses are performed. At
stigation purposes are
the laboratory the following analytical specifications or a more recently EPA
promulgated version of the method listed or an equivalent, EPA approved method
must be adhered to unless otherwise approved by the Executive Secretary:

Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.2 0.1 mg/L 28 days H2SO4pH<2
to ≤ 6oC
Carbon
Tetrachloride
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Inorganic
Chloride
A4500-CI B 1 mg/L 28 days None ≤ 6oC

5) Field Parameters

In the case of chloroform pumping wells only one set of field parameters is required
to be measured prior to sampling [see Section 6.2.2(b)(ii)]. This includes the
following wells: MW-4, MW-26, TW4-19 and TW-4-20. However, if a pumping
well has been out of service for 48 hours or more, DUSA shall follow the purging
requirements outlined in Section 6.2.7of the QAP before sample collection.

6)

Chloroform Investigation Reports
The Chloroform Investigation Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

• Description of monitor wells
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Quality Assurance Plan (QAP) Page 52 of 52

• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment rinsate
samples, duplicate samples

c) Data Interpretation

• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, including a discussion
on: 1) a current chloroform isoconcentration map with one of the
isosconentration lines showing the 70 ug/L boundary, 2) graphs showing
chloroform concentration trends in each well through time and, 3)
analytical results for each well summarized in a data table, that includes
historic analytical results for each well.
• Calculate chloroform mass removed by pumping wells. Calculations
would include: 1) total historic chloroform 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 from
each pumping well for the quarter.
d) Conclusions and Recommendations

e) Electronic copy of all laboratory results for groundwater quality monitoring
conducted during the quarter.

f) Copies of DUSA 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
Quality Assurance Plan (QAP).

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 1 of 60 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
Formatted: Width: 8.5", Height: 11"
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 2 of 60 TABLE OF CONTENTS Page
1. INTRODUCTION……………………………………………………………………. 6

2. ORGANIZATION AND RESPONSIBILITIES…………………………………… 6
2.1. Functional Groups…………………………………………………………….............. 6
2.2. Overall Responsibility For the AQ/QC Program…………………………….............. 6
2.3. Data Requestors/Users..……………………………………………………………… 6

2.4. Data Generators…………………………..…………………………………………... 7 2.4.1. Sampling and QC Monitors…………………………………………………………... 7
2.4.2. Analysis Monitor……………………………………………………………………… 8 2.4.3. Data Reviewers/Approvers…………………………………………………………… 8
2.5. Responsibilities of Analytical Laboratory…………………………………………….. 98
3. QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA… 9
3.1. Precision……………………………………………………………………………… 9
3.2. Accuracy……………………………………………………………………………… 10

3.3. Representativeness……………………………………………………………………. 10
3.4. Completeness…………………………………………………………………………. 10
3.5. Comparability…………………………………………………………………………. 110
4. FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY…………… 11

4.1. Controlling Well Contamination…..…………………………………………………. 11
4.2. Controlling Depth to Groundwater Measurements.………………………….............. 11 4.3. Water Quality QC Samples………………………………………………………….. 11
4.3.1. VOC Trip Blanks…………………………………………………………………….. 11 4.3.2. Equipment Rinsate Samples………………………………………………………….. 112
4.3.3. Field Duplicates………………………………………………………………………. 12
4.3.4. Definition of “Batch”…………………………………………………………………. 12
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Quality Assurance Plan (QAP) Page 3 of 60 5. CALIBRATION……………………………………………………………………… 12
5.1. Depth to Groundwater Measurements……………………………………………….. 132
5.2. Water Quality………………………………………………………………………... 132
6. GROUND WATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS…………………………………………………………………………... 123

6.1. Groundwater Head Monitoring……………………………………………………… 132 6.1.1. Location and Frequency of Groundwater Head Monitoring………………………… 132
6.1.2. Equipment Used For Groundwater Head Monitoring……………………………….. 14 6.1.3. Field Sampling Procedure for Groundwater Head Monitoring……………………… 14

6.2. Ground Water Compliance Monitoring.……………………………………………... 1514 6.2.1. Location and Frequency of Groundwater Compliance Monitoring.…………………. 1514
6.2.2. Quarterly and Semi-Annual Sampling Required (Paragraphs I.E.1.a) orI.E.1.b) of the
GWDP)…………………………………………………………………………………………
15
6.2.3. Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the
GWDP………………………………………………………………………………...
1615
6.2.4. Sampling Equipment for Groundwater Compliance Monitoring……………………. 1615
6.2.5. Decontamination Procedure………………………………………………………….. 17
6.2.6. Pre-Purging/Sampling Activities………………………………………………………. 1817 6.2.7. Well Purging/Measurement of Field Parameters……………………………………… 189
6.2.8. Samples to be Taken and Order of Taking Samples…………………………………... 221 6.2.9. Field Duplicate Samples……………………………………………………………….. 221 6.2.10. VOCs and Nutrient Sampling…………………………………………………………. 232
6.2.11. Heavy Metals, All Other Non-Radiologics and Gross Alpha Sampling………………. 232 6.2.12. Procedures to Follow After Sampling…………...…………………………………….. 275

7. SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING……. 276
7.1. Field Data Worksheets………………………………………………………………. 226
7.2. Chain-Of-Custody and Analytical Request Record…………………………………. 287
7.3. Record Keeping……………………………………………………………………… 2928

8. ANALYTICAL PROCEDURES AND QA/QC…………………………………….. 2829
8.1. Analytical Quality Control…………………………………………………………... 2829 8.1.2. Spikes, Blanks and Duplicates………………………………………………………. 3028

8.2. Analytical Laboratory Procedures…………………………………………………… 2930
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Quality Assurance Plan (QAP) Page 4 of 60
9. INTERNAL QUALITY CONTROL CHECKS…………………………………… 342
9.1. Field QC Check Procedures…………………………………………………………. 342 9.1.1. Review of Compliance With the Procedures Contained in this Plan………………... 3432 9.1.2. Analyte Completeness Review………………………………………………………. 3432
9.1.3. Blank Comparisons………………………………………………………………….. 3432 9.1.4. Duplicate Sample Comparisons……………………………………………………... 3432

9.2. Analytical Laboratory QA Reviews…………………………………………………. 353
9.3. QA Manager Review of Analytical Laboratory Results and Procedures……………. 364
9.4. Analytical Data………………………………………………………………………. 375
10. CORRECTIVE ACTION……………………………………………………………. 3537

10.1. When Corrective Action is Required………………………………………………... 3537
10.2. Procedure for Corrective Action…………………………………………………….. 386
11. REPORTING…………………………………………………………………………. 3638
12. SYSTEM AND PERFORMANCE AUDITS……………………………………….. 3839
12.1. QA Manager to Perform System Audits and Performance Audits…………………... 3938
12.2. System Audits……………………………………………………………………….. 3840
12.3. Performance Audits………………………………………………………………….. 3840
12.4. Follow-Up Actions…………………………………………………………………... 3842
12.5. Audit Records………………………………………………………………………... 3940

13. PREVENTIVE MAINTENANCE………………………………………………… 3940
14. QUALITY ASSURANCE REPORTS TO MANAGEMENT…………………… 3941
14.1. Ongoing QA/QC Reporting…………………………………………………………. 3941
14.2. Periodic Reporting to Management………………………………………………….. 4140

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 5 of 60 15. AMENDMENT………………………………………………………………………. 4042
16. REFERENCES……………………………………………………………………….. 4142

Attachments
Attachment 1 – Sample Field Data Worksheet Attachment 2 – Sample Chain of Custody Forms
Attachment 3 – Instrument Calibration/Check Worksheet Appendices

Appendix A- Chloroform Investigation Monitoring Quality Assurance Program

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 6 of 60 1. INTRODUCTION
This Groundwater Monitoring Quality Assurance Plan (the “Plan”) details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental analytical laboratories, data validation, and sampling and other corrective actions necessary to comply with UAC R317-6-6.3(I) and (L) at the White Mesa Uranium Mill (the “Mill”), as
required under paragraph I.H.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) as well as
EPA’s more recent Ground Water Issue, Low Flow (Minimal Drawdown) Ground-Water Sampling Procedcures (Puls and Barcelona 1996) and Groundwater Sampling Guidelines for
Superfund and RCRA Project Managers, Groundwater Issue Paper (Yaskis and Zavala 2002).
Activities in an integrated program to generate quality data can be classified as management (i.e.,
quality assurance or “QA”) and as functional (i.e., quality control or “QC”). The objective of this
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 of these representatives are described below.

2.2. Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QA/QC measures are properly employed is the responsibility of the QA Manager. The QA Manager is typically not directly involved in the data generation (i.e., sampling or analysis) activities. 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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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 7 of 60 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 of the Data Users are the data generators. For Mill activities, this involves sample collection, record keeping
and QA/QC activities conducted by one or more sampling and quality control/data monitors
(each a “Sampling and QC Monitor”). The Sampling and QC Monitors are 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 of custody 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 of the data generators are as follows:
2.4.1. Sampling and QC Monitors

The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in 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 of the program; d) Preparing quality control samples for field sample collection during the sampling event;
e) Preparing QC and sample data for review by the QA Manager; and

f) Preparing QC and sample data for reporting and entry into a computer data base, where appropriate.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 8 of 60 2.4.2. Analysis Monitor
The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory. These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and analytical procedures, prior to receiving samples;

b) Receiving samples from the field and verifying that incoming samples correspond to the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being followed as
specified in this 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 of QA/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 personnel.
Formatted: Outline numbered + Level: 2 +Numbering Style: 1, 2, 3, … + Start at: 1 +Alignment: Left + Aligned at: 0" + Tab after: 0.55" + Indent at: 0"
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Quality Assurance Plan (QAP) Page 9 of 60

2.5. Responsibilities Of Analytical Laboratory
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 of a 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 radionuclide requirements as stipulated in the applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical procedures used by the Analytical Laboratory will be in accordance with Utah Administrative Code R317-6-
6.3L.
3. QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this 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
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 10 of 60 the analysis of samples containing identical concentrations of the parameters of concern. For
duplicate measurements, precision is expressed as the relative percent difference (“RPD”) of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the 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 of bias in a system or as the degree of agreement between a
measured value and an accepted or measuredreference 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 = (│A-B│/C) x 100
Where:
A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample C = the concentration of spike added
3.3. Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an environmental condition. Representativeness is controlled by performing all sampling in compliance with this
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 of measurements) x 100

Formatted: Justified
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 11 of 60 Where the number of valid data points is the total number of valid analytical measurements based
on the precision, accuracy, and holding time evaluation. Completeness is determined at the conclusion of the data validation.
Executive Secretary approval will be required for any completeness less than 100 percent.
3.5. Comparability Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection techniques, measurement procedures, methods, and reporting units are consistent for all samples within a
sample set.
4. FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1. Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over the surface casing and cementing the surface section of the drill hole. Wells have surface covers of
mild steel with a lockable cap cover. Radiation Safety staff has access to the keys locking the wells.

Subsurface well stagnation, for pumped wells, is reduced by pumping two three well casing volumes of water from the wells or, if Low Flow sampling is used in accordance with Section
6.2.7(b) below, achieving stable field measurements (sometimes referred to in the literature as water-quality-indicator parameters) as specified in Section 6.2.7(ab)(ivx)E, 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 of the following QC samples:
4.3.1. VOC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by volatile organic compounds (“VOCs”) through diffusion during sample transport and storage. At
a minimum (at least) one trip blank will be in each shipping container containing samples to be
analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory, transported to the
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 12 of 60 sampling site, and then returned to the Analytical Laboratory for analysis along with the samples
collected during the sampling event. The trip blank will be unopened throughout the transportation and storage processes and will accompany the technician while sampling in the
field (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 or non-disposable or non-dedicated bailer is used, collect
an equipment rinsate sample daily from the decontaminated pump or bailer.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 of each day of the 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 samples 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 of this 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 of valid data is the proper calibration of all sample collection and analytical instruments. Sampling equipment shall be calibrated in accordance with
manufacturers’ recommendations, and Analytical Laboratory equipment shall be calibrated in
accordance with Analytical Laboratory procedures.
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Quality Assurance Plan (QAP) Page 13 of 60
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to each day’s use to ensure that the Water Sounding Device is functional.
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 and routine check results will be recorded on the Field Instrument Calibration/Check Data Worksheet which is included as Attachment 3 .

6. GROUND WATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS
6.1. Groundwater Head Monitoring
6.1.1. Location and Frequency of Groundwater Head Monitoring
Depth to groundwater shall be measured quarterly in the following wells and piezometers:

a) All Point of Compliance wells listed in paragraphs 6.2.1 a), b) and c) below;
b) Monitoring wells MW-20 and MW-22; c) All piezometers (P-1, 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-20-01, not already included in paragraph (a). On November 17, 2006June 4, 2010, such chloroform contaminant investigation wells
were the following:
• MW-4
• TW4-1
• TW4-2
• TW4-3
• TW4-4
• TW4-5
• TW4-6
• TW4-7
• TW4-8
• TW4-9
• TW4-12
• TW4-13
• TW4-14
• TW4-16
• TW4-18
• TW4-19
• TW4-20
• TW4-21
• TW4-22
• TW4-23
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Quality Assurance Plan (QAP) Page 14 of 60
• TW4-10
• TW4-11
• TW4-24
• TW4-25
• TW4-26 e) All Nitrate and Chloride Investigation and Corrective Action Plan wells required
under the January 26, 2009 Stipulated Consent Agreement, Docket No. UGW09-03. As of December 30, 2009June 4, 2010, the following wells are part of the Nitrate and
Chloride investigation:

• TWN-1
• TWN-2
• TWN-3
• TWN-4
• TWN-5
• TWN-6
• TWN-7
• TWN-8
• TWN-9
• TWN-10

• TWN-11
• TWN-12
• TWN-13
• TWN-14
• TWN-15
• TWN-16
• TWN-17
• TWN-18
• TWN-19

f) 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.
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Quality Assurance Plan (QAP) Page 15 of 60
6.2. Ground Water Compliance Monitoring
6.2.1. Location and Frequency of Groundwater Compliance Monitoring Groundwater quality shall be measured in the following wells at the following frequencies:
a) Semi-annually in the following Point of Compliance wells: MW-1, MW-2, MW-3,
MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24,
MW-27, MW-28, MW-29, and MW-32;
b) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-20, MW-22, MW-25, MW-26, MW-30, and MW-31.; and

b)c) Quarterly, in the following wells: MW-20 and MW-22 for as long as required under paragraph I.E.2 of the GWDP; and

c)d) Chloroform 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.1 or I.G.2 of the GWDP. It is important to confirm 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.1.a) or I.E.1.b) of
the GWDP
All quarterly and semi-annual samples collected under paragraphs 6.2.1 a), b), c) and cd) above
(paragraphs I.E.1b.a), or I.E.1.b I.E.1.c) or I.E.2) of the GWDP) shall be analyzed for the following parameters:
a) Field parameters– depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh), temperature, dissolved oxygen (DO) and turbidity in the manner
specified in paragraphs 6.2.7 da) (v) or b); and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics – chloride, sulfate, carbonate, bicarbonate, sodium potassium,
magnesium, calcium, and total anions and cations.

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Quality Assurance Plan (QAP) Page 16 of 60
6.2.3. Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the
GWDP Any quarterly or monthly sampling required under paragraphs I.G.1. 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.
6.2.4. Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may otherwise contact sampled groundwater, shall be made of inert materials.

For the purposes of this QAP the following equipment definitions shall apply:
• Dedicated Bailer
•
: A bailer that is dedicated to be used at one specific well for the
use of purging or sampling. Said bailer will 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 of purging or sampling. Said pump wiell remain with and inside the well : A pump that is dedicated to one specific well for the use
casing suspended and secured.
• Non – Dedicated Pump
or more wells.
: A pump that is used for purging and sampling at one

Groundwater compliance monitoring is accomplished by using 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 an 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.
d) The Field Parameter Meter measures the following parameters:

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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 17 of 60 (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;

e) Turbidity measuring instrument capable of determining if turbidity 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, clean sterile Polyethylene sample containers as provided by the Analytical Laboratory;

k) De-ionized water;
l) One new, unused, clean disposable single check valve bailer, or the equivalent, for each well to be sampled for VOCs; unless the well is outfitted with a dedicated pump, in which case the sample for VOCs is taken directly from the pump discharge; and
m) If any portable (non-dedicated) pumps are used, the following equipment, supplies
and solutions, or the equivalent, necessary for decontamination procedures:

(i)• 15 gallons of de-ionized water
• 5 gallons of de-ionized water/nonphosphate detergent (such as Liqui-Nox);
(ii) (iii) 5 gallons of de-ionized water/HNO3 solution (a mixture of approximately
4 and 1/2 gallons of de-ionized water and ½ gallon of HNO3);
• de-ionized water/HNO3 solution (this solution is used during decontamination
only when samples will be analyzed for heavy metals);
(iv)• Rubber gloves; and
(v)• Sterile Clean, sealed sample containers from the Mill Analytical lLaboratory for any equipment rinsate samples.
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 18 of 60 6.2.5. Pump Decontamination Procedure If a portable (non-dedicated) pump is to be used, the pump will be decontaminated after each use,
according to the following procedure prior to each sampling event, at the beginning of each 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 (.1N) hydrochloric or nitric acid (only if samples will be analyzed for heavy metals; and

d) rinse the Sampling Equipment with de-ionized water.
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 of in Tailings Cell 1.
All sampling and purging equipment that has been decontaminated as per the foregoing procedure shall be covered with a plastic sheeting or plastic bags 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 it is working properly
(for example, no air is leaking into the discharge line, in order to prevent aeration of the
sample);
b) If a portable (non-dedicated) pump is to be used, at the completion of sampling from
each well, If a 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, collect one Equipment Rinsate Sample
daily using after completion of decontamination and prior to the beginning of each day
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 19 of 60 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 transport the VOC samples. The Trip Blank(s) in the cooler will accompany the groundwater samplers throughout the monitoring event.
6.2.7. Well Purging/Measurement of Field Parameters
6.2.7.
(Note: 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 subsurface at the
location of the well, follow the additional procedures, to be provided by the RSO.)
There are three methods of purging a well prior to sampling: evacuating three casing
volumes; achieving stable field parameters using low flow sampling; and evacuating a well to dryness. Purging is completed if any one of the three methods is employed in accordance with
the following provisions:
a)

Evacuating Three Casing Volumes
This method of purging can be used on any well.

a)(i) 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)(ii) 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
from the total depth of the well), V

= 0.653*h, for a 4” casing volume and V = .367*h for a 3” casing volume. Record the casing volume on the Field Data
Worksheet;
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 subsurface at the location of the well, follow the additional procedures, to be
provided by the RSO, prior to well purging; (iii) Purging, Where Use of Pump is Effective (See paragraph 6.2.7(a)(iv)6.2.7 e))
below, where bailer is required)
d)
A. 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
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 20 of 60 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 agitation of the water upon impact. Once the pump is lowered into the well, or if the well has a
dedicated pump, perform the following steps: (i)B. Commence pumping;
(ii)C. 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 of the Field Data Worksheet;

(iii)D. Calculate the amount of time to evacuate two three casing volumes;
(iv) Evacuate two casing volumes (if possible) by pumping for the length of time
determined in paragraph (iii);
E. Take measurements of field parameters (pH, specific conductance,
temperature, redox potential, temperature, dissolved oxygen and turbidity) during well purging, using the Field water-quality-indicator pParameterParameter Meter and turbidity measuring instrument. These
measurements will be recorded on the Field Data Worksheet. At a minimum, measure the field parameters at the beginning of purging and
after each of three casing volumes have been evacuated;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 < 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.
F. Purging is completed after three casing volumes have been removed.
(iv) Purging, Where Use of Pump is Not Effective (See paragraph (vi) above, where
use of pump is 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 to evacuate the three casing
volumes, or, in those cases where the water column is not shallow but the well takes
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 21 of 60 over two days to recover, to evacuate the final few feet of water after removing the
portable pump. If a bailer is used, the following procedure will be followed:
A. Use the sound level instrument to determine the water column and figure the amount of water that must be evacuated;
B. Attach a disposable bailer to a rope and reel;
C. Lower the bailer into the well and listen for contact with the groundwater.
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;
D. 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;

E. After the bailer is emptied, lower the bailer back into the well and fill the bailer as before. This process will continue until the three casing volumes
have been collected or until no more water can be removed. When the process is finished for the well and the sample for the well is taken, the
bailer will be disposed of; and
F. Take measurements of field parameters referred to in paragraph
6.2.7(a)(iv)E above from the water in the buckets. At a minimum, measure field parameters at the beginning of purging and after each of three casing volumes have been evacuated.
b)

Low Flow Sampling or the field water-quality-indicator parameters of pH, specific
conductance, redox potential (Eh), temperature, and turbidity have stabilized, using
Low Flow sampling methods.
Low flow sampling, also called minimal drawdown sampling and “low stress” sampling,
consists of sampling a ground-water monitoring well at a rate that is equal to or less than the natural recharge rate of the aquifer. Low Flow sampling is only appropriate for wells that meet the criteria specified in this paragraph (b). The Mill’s RSO will identify which wells are suitable
for low flow sampling. However, purging using the Low Flow sampling method will only be considered successful if all of the steps and conditions in this paragraph (b) are followed and satisfied. If all of the steps and conditions are not followed and satisfied, then one of the other
purging procedures (evacuation of three casing volumes or evacuation to dryness) will be
required to be used.
(i) The well must be equipped with a dedicated pump capable of pumping at a flow
rate of approximately 0.026 to 0.132 gallons per minute (gpm);
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Quality Assurance Plan (QAP) Page 22 of 60
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(ii) Remove the well casing cap and measure and record depth to groundwater by
following the procedures set out in paragraph 6.1.3 above;
(iii)The pump flow rate must be set so that the drawdown in the water level during pumping is not expected to exceed four inches. This is determined by measuring the change (if any) in the water level during pumping using an electronic hand-
held water level measuring device. Record the depth to the water level every three to five minutes and at the end of purging. If drawdown is occurring at the
beginning of the pumping cycle, decrease the pumping rate until drawdown does
not occur, and continue pumping to evacuate a water volume equal to the volume of water in the pump, the discharge line and the flow-through cell, as stated in
paragraph vii below;
(iv) The Mill’s RSO will have designated which wells have a stagnant water column.
If the depth to water is less than the depth to the top of the screened interval, then the well is considered to have a stagnant water column. If the water level draws
down by more than four inches in any well with a stagnant water column, Low
Flow purging of the well has not been successful and one of the other purging methods (evacuation of three casing volumes or evacuation to dryness) must be
used;
(v) Commence pumping at a rate of between 0.026 to 0.132 gpm or as appropriate so
that the water level does not draw down by more than four inches;
(vi) Contain all water in a calibrated bucket in order to determine the amount of water purged;
(vii) It is only necessary to evacuate the volume of water that may be present in the pump, in the water discharge tubing leading from the pump to the surface and
the volume of the flow-through cell that is used to measure the field parameters;
(viii) Measure and record the following field parameters every three to five minutes
during the process of evacuating the pump, tubing and flow-through cell: pH, specific conductance, redox potential, temperature, dissolved oxygen and
turbidity;
(ix) Purging will be complete once three successive readings of the field parameters
have stabilized and meet the following Stabilization Criteria:

Parameter Stabilization Criteria
Temperature +/- 0.1 degree F pH +/- 0.1 pH unit specific conductivity +/- 3%
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 23 of 60 Redox potential (Eh) +/- 10 millivolts
Turbidity +/- 10% (when turbidity is greater than
10 NTUs)
Dissolved oxygen (DO) +/- 0.3 milligrams per liter

(x) If it is not possible to achieve the foregoing Stabilization Criteria while satisfying the other Low Flow sampling requirements set out in this paragraph (b), then
another method of purging (evacuation of three casing volumes or evacuation to dryness) must be used;

c)

Evacuation to Dryness
(v) If theany well cannot yield two three casing volumes,
A.(i) Evacuate the well to dryness and record the number of gallons evacuated on the Field Data Worksheet; and

B.(ii) 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;

d) Disposal of Purged Water
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 of water 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 solutiongroundwater. 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;
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 24 of 60 (v) After the bailer is emptied, lower the bailer back into the well and gain fill another
samplethe bailer as before. This process will continue until the two three casing volumes have been collected or until no more water can be retrievedremoved. When
the process is finished for the well, the bailer will be disposed of; and (vi) Take field measurements of water-quality-indicator parameters referred to in
paragraph 6.2.7(d)(v) above from the water in the buckets
All water produced during well purging will be containerized. Containerized
water will be disposed of in either Tailings Cells 1, 3, or 4A;.
f) e) When to Proceed to Sampling

(i) If the well yields three casing volumes, or Low Flow purging is successfully accomplished in accordance with Section b) above, the individual performing the
sampling should immediately proceed to Section 6.2.8; and
(ii) If the 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.
6.2.8. Samples to be taken and order of taking samples
For each sampling event, unless sampling for a specific parameter under the accelerated monitoring requirements of paragraphs I.G.1 or I.G.2 of the 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 unless the well is outfitted
with a dedicated pump, in which case sample for VOCs directly from the pump
discharge);
b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml (a bailer is used unless the well is outfitted with a dedicated pump, in which case sample for nutrients
directly from the pump discharge);
c) Heavy metals, 1 sample container, 250 ml, filtered;

d) All other non-radiologics (fluoride, general inorganics, TDS, total cations and anions), 1 sample container, 250 ml, filtered; and
e) Gross alpha, 1 sample container, 1,000 ml, filtered.

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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 25 of 60 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; and a)
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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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 26 of 60 b) 6.2.10. VOCs and Nutrient Sampling
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 the dedicated sample pump or 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; and
f) After each sample container is filled, rinse the lid of the container with water, and
tighten the lid onto the container; and,
g)f) Discard the bailer.
6.2.11. Heavy Metals, All Other Non-Radiologics and Gross Alpha Sampling
When sampling for heavy metals, all other non-radiologics 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 with dedicated pumps or 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;
(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;
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 27 of 60 (ii)
(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) If using a portable (non-dedicated pump), Rremove the pump from the well; and
(v) If using a portable (non-dedicated pump), decontaminate the pump as per Section 6.2.5. Do not place the decontaminated pump on the ground or on other
contaminated surfaces;
d) When using a bailer to sample (wells without dedicated pumps or 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;
A.
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; B.
C. Sample water should be transferred to sample containers in a controlled
manner that will minimize sample agitation and aeration; C.
D. Rinse lid of sample container with any remaining filtered water, after container is filled with filtered water, and tighten lid onto container;
D.
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
E. 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 of after sampling the well;

(ii) Filtering Water Samples at the Mill Laboratory
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Quality Assurance Plan (QAP) Page 28 of 60
A. A new, clean 1 gallon raw sample container must be used to capture waters needed to be filtered;
A. 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;
B. 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;
C. D. Unless the bailer is dedicated to a particular well, it will be disposed of
after completion of sampling in the well;
D. 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; E.
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 of the
sample;
F. 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 of the equipment using DI water
• Rinsing the equipment with a mixture of DI water and HNO
• Rinsing the equipment with a mixture of DI water and Liqui-Nox
soap
3
• Rinsing the equipment with DI water
• Finally the collection of the final process rinsate solutions are
placed in the sample collection cooler and labeled as a filtration equipment rinsate sample;

I. The flask is attached to the vacuum system in the laboratory using Tygon Vacuum Tubing, or the equivalent;
I. J. The micro-filtration system is then inserted into the filter flask;
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Quality Assurance Plan (QAP) Page 29 of 60 J.
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;
K. L. The water sample is then slowly added into the bell and the vacuum is turned on;
L. M. As the vacuum draws the water through the filter paper, additional
solutions are added until the flask is full;
M. N. When the flask is full, the vacuum is turned off and the bell is unclamped
from the frit. The Tygon tubing is then removed from the flask. The glass frit is then pulled out of the flask;
N.
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; O.
P. Rinse lid of sample container with any remaining filtered water, after container is filled with filtered water, and tighten lid onto container;
P.
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 of sample bottles; Q.
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 R.
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 of the
filtration process is approximately ½ 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.

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Quality Assurance Plan (QAP) Page 30 of 60 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 of sample
• 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;
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 6o C. These samples shall be received by the Analytical Laboratory at less than or equal to 6o

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 of observations and data from sampling provide important information about the
sampling process and provide a permanent record for sampling activities. All observations and field sampling data will be recorded in waterproof ink on the Field Data Worksheets, which will
be maintained on file at the Mill.
The Field Data Worksheets will contain the following information:

• Name of the site/facility
• description of sampling event
• location of sample (well name)
• sampler’s name(s) and signaturesignature(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump including type of pump or bailer)
• previous well sampled during the sampling event
• well depth
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Quality Assurance Plan (QAP) Page 31 of 60
• depth to groundwater before purging and sampling
• results of in-field measurements (pH, specific conductance, water temperature, redox potential, temperature, turbidity)
• redox potential (Eh) measurements
• turbidity measurements
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type and condition of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory
• sampling event.

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 Field Data Worksheet that incorporates this information is attached as Attachment 1.
7.2. Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody and Analytical Request Record form (the “COC Form”), provided by the Analytical Laboratory, will accompany the samples being shipped to the Analytical Laboratory.
Examples of the Chain of Custody Forms used are attached as Attachment 2. If the Chain of Custody Form changes at any time, the Company shall provide a copy of the new or revised Chain of Custody Form to the Executive Secretary and substitute the new form for the old form
in Attachment 2. Standard Chain-of-Custody protocol is initiated for each sample set. A COC Form is to be completed for each set of samples collected in a shipping container (cooler) and is
to include the following:

• sampler’s name
• company name
• date and time of collection
• sample type (e.g., water)
• sample locationID
• number of sample containers in the shipping containerper location
• analyses requested
• signatures of persons involved in the chain of possession
• internal temperatures of the shipping container when opened at the laboratory
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Quality Assurance Plan (QAP) Page 32 of 60
• remarks comments section to identify potential hazards or to relay other information to the Analytical Laboratory.
Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratory will sign the COC Form, document
shipment method, and send the original and the second copy of the COC Form with the samples. Upon receipt of the samples, the person receiving the samples will sign the COC Form and return the second copy to the Mill’s RSO.
Copies of the COC Forms and other relevant documentation will be retained at the Mill.

7.3. Record Keeping
The Field Data Worksheets are retained at the Mill.
Original Certificates of Analysis from the Analytical Laboratory, showing the laboratory
analytical results for the water samples, are maintained at the Mill.
Copies of the current Utah certifications of the Analytical Laboratory or Laboratories used to
perform analysis during the monitoring events conducted during the quarter. DUSA will ensure that the Analytical Laboratory or Laboratories used, have certifications for each parameter and
method required by Section 8.2, Table 1 of the QAP. Copies of these certifications will be 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 I.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.
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Quality Assurance Plan (QAP) Page 33 of 60
8.1. Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In choosing and retaining the Analytical Laboratory, DUSA 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 of samples:
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 of conditions within a typical
matrix. The duplicate spike (matrix spike) sample serves as a check evaluating the effect of the sample matrix on the accuracy of analysis.
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 occurred.
c) Field Samples/Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) analyzed for organic constituents shall be spiked with surrogate compounds prior to purging or extraction. Surrogates are organic compounds which are
similar to analytes of interest in chemical composition, extraction, and chromatography,
but which are not normally found in environmental samples. Surrogates shall be spiked into samples according to the appropriate organic analytical methods.
d)

Check Sample
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 34 of 60 Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported. 8.2. Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as those
specified in Table 1, or a more recently EPA promulgated version of the method listed or
an equivalent, EPA approved method, 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 Chloroform Investigation Monitoring Quality Assurance Program (Appendix A to this document).

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Quality Assurance Plan (QAP) Page 35 of 60
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Table 1

Contaminant Analytical Methods
to be Used*
Reporting Limit Maximum Holding
Times
1 Sample Preservation
Requirements
Sample Temperature
Requirements
Nutrients Ammonia (as N) A4500-NH3 G 0.05 mg/L 28 days H2SO4pH<2 to ≤ 6oC
Nitrate & Nitrite (as N) E353.2 0.1 mg/L 28 days H2SO4pH<2 to ≤ 6oC

Heavy Metals
Arsenic E200.8 5 µg/L 6 months HNO3 None to pH<2
Beryllium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Cadmium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Chromium E200.8 25 µg/L 6 months HNO3 None to pH<2 Cobalt E200.8 10 µg/L 6 months HNO3 None to pH<2 Copper E200.8 10 µg/L 6 months HNO3 None to pH<2 Iron E200.7 30 µg/L 6 months HNO3 None to pH<2
Lead E200.8 1.0 µg/L 6 months HNO3 None to pH<2
Manganese E200.8 10 µg/L 6 months HNO3 None to pH<2
Mercury E200.8 0.50 µg/L 28 days HNO3 None to pH<2
Molybdenum E200.8 10 µg/L 6 months HNO3 None to pH<2
Nickel E200.8 20 µg/L 6 months HNO3 None to pH<2
Selenium E200.8 5 µg/L 6 months HNO3 None to pH<2
Silver E200.8 10 µg/L 6 months HNO3 None to pH<2
Thallium E200.8 0.50 µg/L 6 months HNO3 None to pH<2
Tin E200.8 100 µg/L 6 months HNO3 None to pH<2
Uranium E200.8 0.30 µg/L 6 months HNO3 None to pH<2 Vanadium E200.8 15 µg/L 6 months HNO3 None to pH<2 Zinc E200.8 10 µg/L 6 months HNO3 None to pH<2 Radiologics Gross Alpha E900.1 1.0 pCi/L 6 months HNO3 to pH<2 None

Volatile
Organic Compounds

Acetone SW8260B 20 µg/L 14 days HCl to pH<2 ≤ 6oC
Benzene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
2-Butanone (MEK) SW8260B 20 µg/L 14 days HCl to pH<2 ≤ 6oC
Carbon Tetrachloride SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 36 of 60 Contaminant Analytical Methods
to be Used*
Reporting Limit Maximum Holding
Times
1 Sample Preservation
Requirements
Sample Temperature
Requirements
Chloroform SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC Chloromethane SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC Dichloromethane (Methylene
Chloride)
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Naphthalene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Tetrahydrofuran SW8260B
or SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Toluene SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Xylenes (total) SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC

Others
Field pH (S.U.) A4500-H B 0.01 s.u. Immediate None None
Fluoride A4500-F C 0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None ≤ 6oC

General Inorganics
Chloride A4500-Cl B 1 mg/L 28 days None None Sulfate A4500-SO4 E 1 mg/L 28 days None ≤ 6oC
Carbonate as CO3 A2320 B 1 mg/L 14 days None ≤ 6oC Bicarbonate as HCO3 A2320 B 1 mg/L 14 days None ≤ 6oC
Sodium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
Potassium E200.7 0.5 mg/L 6 months HNO3 None to pH<2 Magnesium E200.7 0.5 mg/L 6 months HNO3 None to pH<2 Calcium E200.7 0.5 mg/L 6 months HNO3 None to pH<2
*The Analytical Laboratories will analyze samples using either the method listed, a more recently EPA promulgated version of
the method listed or an equivalent EPA approved method. 1. The Analytical Laboratory will be required to meet the reporting limits (“RLs”) in the foregoing Table, unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the increased RL will be used, or unless otherwise approved by the Executive Secretary.
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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 37 of 60
9. INTERNAL QUALITY CONTROL CHECKS
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 of Compliance 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.1(a) of the Permit. Executive Secretary approval will be required for any completeness (prior to QA/QC analysis) less than 100 percent. Non-conformance will be defined as a failure to provide field parameter results and analytical results for each parameter and for each well
required in Sections 6.2.2 and 6.2.3, for the sampling event, without prior written Executive 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
greater than an order of magnitude of the original sample result. (TEGD,DTG Field QA/QC
Program, page 1197-31). 9.1.4. Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 38 of 60 a)

Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results. Non-
conformance will exist when the RPD >

20%, unless the measured 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)

Radiologics Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting variance that is equal to or less that than 20% of the reported activity concentration. An error term may
be greater than 20% of the reported activity concentration when the sum of the activity
concentration and error term is less than or equal to the GWCL.
c)

Radiologics, Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
│A-B│/(sa2+sb2)1/2

< 2
Where:
A = the first duplicate measurement B = the second duplicate measurement
sa2
s = the uncertainty of the first measurement squared
b2

= the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.
(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).

If the QA Manager’s review finds any situations of non-conformance, see Section 10.
9.2. Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes for
ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC review which will include validating holding times and QC samples. Overall data assessment will be a
part of the validation process as well.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 39 of 60 The Analysis Monitor or data validation specialist will evaluate the quality of the data based on
SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The reviewer will check the following: (1) sample preparation information is correct and complete,
(2) analysis information is correct and complete, (3) appropriate Analytical Laboratory procedures are followed, (4) analytical results are correct and complete, (5) QC samples are within established control limits, (6) blanks are within QC limits, (7) special sample preparation
and analytical requirements have been met, and (8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the QA/QC data. The Analytical Laboratory will provide the following information: (1) cover sheet listing
samples included in report with a narrative, (2) results of compounds identified and quantified, and (3) reporting limits for all analytes. Also to be included are the QA/QC analytical results.

9.3. QA Manager Review of Analytical Laboratory Results and Procedures. The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
a) Reporting Limit (RL) Comparisons
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 of the GWDP.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory are
those specified in Table 1, those specified in Table 1, or a more recently EPA promulgated version of the method listed or an equivalent, EPA approved method, unless otherwise approved
by the Executive Secretary. Non-conformance shall be defined when the Analytical Laboratory uses analytical methods not listed in Table 1 and not otherwise approved by the Executive
Secretary.
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 40 of 60
c) Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each contaminant was not exceeded. Non-conformance shall be defined when the holding time is exceeded.

d)

Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received by
the Analytical Laboratory at a temperature no greater than the approved temperature listed in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.

9.4. Analytical Data
All QA/QC data and records required by the Analytical Laboratory’s QA/QC program shall be retained by the Analytical Laboratory and shall be made available to DUSA as requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the sample
was collected, the date/time the sample was received by the Analytical Laboratory, the date/time
the sample was extracted (if applicable), and the date/time the sample was analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions described as well as the results of the corrective actions taken. All raw and reduced data will be stored according to the Analytical Laboratory’s record keeping procedures and QA program. All
Analytical Laboratory procedures and records will be available for on-site inspection at any time during the course of investigation.

If re-runs occur with increasing frequency, the Analysis Monitor and the 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. Corrective 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 Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 41 of 60 When non-conformance is identified, DUSA shall:
a) When non-conformance 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;
a) .
b) When a sample is lost, sample container broken, or the sample or analyte was omitted, resample within 10 days of discovery and analyze again in compliance with all
requirements of this 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
b) 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 corrective action for non-conformance with the requirements of this Plan, may be
identified by system or performance audits or by standard QA/QC procedures. The procedures to
be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem; b) Assignment of responsibility for investigating the problem;
c) Investigation and determination of the cause of the problem;

d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action; 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 corrective action will be documented in a Report prepared in accordance with Section 11.

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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 42 of 60 11. REPORTING
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 of monitor 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 of compliance in any particular wells pursuant to Part
I.G.2 of the GWDP
• Copies of Field Data Worksheets
• Copies of Analytical Laboratory results
• Copies of Chain of Custody 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 of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this Plan and all corrective actions taken.
• Recommendations and Conclusions.
With respect to the chloroform investigation reporting requirements, these are specified at Item
5) of the Chloroform Investigation Monitoring Quality Assurance Program (Appendix A to this document.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 43 of 60 In addition, an electronic copy of all analytical results will be transmitted to the Executive
Secretary 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.1 and I.G.2 of the 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 performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined by 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 carried out before all systems are operational, during the program, or after the completion of the program. Such audits typically involve a comparison of the activities required
under this 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 performance audit is a quantitative evaluation of the measurement systems of a program. It requires testing the measurement systems with samples of known composition or behavior to
evaluate precision and accuracy. With respect to performance audits of the analytical process,
either blind performance evaluation samples will be submitted to the Analytical Laboratory for analysis, or the auditor will request that it provide results of the blind studies that the Analytical
Laboratory must provide to its NELAP 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.
12.4. Follow-Up Actions
Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 44 of 60 Response to the system audits and performance audits is required when deviations are found and
corrective action is required. Where a corrective action is required, the steps set out in Section 10.2 will be followed.

12.5. Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records will
contain audit reports, written records of completion for corrective actions, and any other documents associated with the audits supporting audit findings or corrective actions.

13. PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer’s specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in accordance with Section 5. Batteries will be charged and checked daily when these instruments are in use.
All equipment out of service will be immediately replaced. Field instruments will be protected from adverse weather conditions during sampling activities. Instruments will be stored properly at the end of each working day. Calibration and maintenance problems encountered will be
recorded in the Field Data Worksheets or 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 performed 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 also
brief the QA Manager on any QA/QC issues associated with such sampling activities.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 45 of 60 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 of the 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 performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and d) Significant QA problems and recommended solutions.
15. AMENDMENT
This Plan may be amended from time to time by DUSA only with the approval of the Executive Secretary.

Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 46 of 60 16. REFERENCES
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 of Solid Waste.
16.4. Standard Methods for the Examination of Water and Wastewater, 20th

Edition, 1998.
American Public Health Association, American Water Works Association, Water Environment
Federation. Washington, D.C. p. 1-7.
16.5. United States Environmental Protection Agency, 2002, Ground-Water Sampling
Guidelines for Superfund and RCRA Project Managers, Ground Water Forum Issues Paper, Yeskis and Zavala.

16.4.16.6. United States Environmental Protection Agency, 1996, Ground Water Issue, Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures, Puls and Barcelona.

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Mill - Groundwater Discharge Permit Date: 6-4-10 Revision 7 Groundwater Monitoring
Quality Assurance Plan (QAP) Page 47 of 60
WHITE MESA URANIUM MILL
ATTACHMENT 1
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Quality Assurance Plan (QAP) Page 48 of 60
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FIELD DATA WORKSHEET FOR GROUND WATER Description of Sampling Event:____________________________________________________ Sampler
Location (well name)_____________________ Name and initials________________________
Date and Time for Purging ______________and Sampling (if different)____________________ Well Purging Equip Used: __pump or __bailer Well Pump (if other than Bennet)___________
Sampling Event________________________ Prev. Well Sampled in Sampling Event_______ pH Buffer 7.0________________________ pH Buffer 4.0___________________________
Specific Conductance _________uMHOS/cm Well Depth_____________________________ Depth to Water Before Purging_____________ Casing Volume (V) 4" Well:__________(.653h)
3" Well:__________(.367h) Conductance (avg)_____________________ pH of Water (avg)_______________________ Well Water Temp. (avg)_____________ Redox Potential (Eh)_____Turbidity _______
Weather Cond.___________________ Ext’l Amb. Temp.(prior to sampling event)__________
_____________________________________________________________________________ Time:__________ Gal. Purged___________ Time:__________ Gal. Purged______________ Conductance_________________________ Conductance____________________________

pH_________________________________ pH____________________________________ Temperature_________________________ Temperature____________________________

Redox Potential (Eh)__________________ Redox Potential (Eh)_____________________ Turbidity___________________________ Turbidity______________________________ _____________________________________________________________________________
Time:__________ Gal. Purged___________ Time:___________ Gal. Purged____________ Conductance_________________________ Conductance____________________________

pH_________________________________ pH____________________________________ Temperature_________________________ Temperature____________________________

Redox Potential (Eh)__________________ Redox Potential (Eh)_____________________
Turbidity___________________________ Turbidity______________________________
Volume of Water Purged When Field Parameters are Measured__________________________
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Quality Assurance Plan (QAP) Page 50 of 60
Pumping Rate Calculation Flow Rate (Q), in gpm. Time to evacuate two casing volumes (2V)
S/60 = =_______________________ T = 2V/Q = _____________________________
Number of casing volumes evacuated (if other than two)________________________________
If well evacuated to dryness, number of gallons evacuated_______________________________ Name of Certified Analytical Laboratory if Other Than Energy Labs_______________________

Type of Sample Sample Taken (circle)
Sample Volume (indicate if other than as specified below)
Filtered (circle) Preservative Added (circle)

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 HNO3 Y N All Other Non-Radiologics Y N 250 ml Y N No Preservative Added
Gross Alpha Y N 1,000 ml Y N H2SO4 Y N
Other (specify)

__________________ __________________
__________________
Y N Sample volume
_____________
Y N Y N

If a preservative is used, Specify Type and
Quantity of Preservative: ____________________
____________________

Comments _____________________________________________________________________
______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________
______________________________________________________________________________ ______________________________________________________________________________
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ATTACHMENT 2
SAMPLE CHAIN OF CUSTODY FORMS

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Quality Assurance Plan (QAP) Page 54 of 60 ATTACHMENT 3
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 55 of 60
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Sheet 1 of 1
CHAIN OF CUSTODY
Samples Shipped to: Contact: Ryan Palmer or David Turk Ph: 435 678 2221
[e-mail]
[e-mail]
Chain of Custody/Sampling Analysis Request Project Samplers Name Samplers Signature

Sample ID Date Collected Time Collected Laboratory Analysis Requested

Please nofify Ryan Palmer of Reciept tempature on these samples Immediately! Thank you.
Relinquished By:(Signature) Date/Time Received By:(Signature) Date/Time
Relinquished By:(Signature) Date/Time Received By:(Signature) Date/Time
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Quality Assurance Plan (QAP) Page 56 of 60

Appendix A
Chloroform Investigation Monitoring Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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Quality Assurance Plan (QAP) Page 57 of 60
Chloroform 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 Chloroform 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 Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set forth below:
1) Dedicated Purge Pump
Chloroform 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 from an individual well and
disposed subsequent to the sampling or by dedicated pump. The wells without a dedicated pump are purged by means of a portable pump. Each quarterly pumping
and sample collection event begins at the location least affected by chloroform (based on the previous quarters sampling event) and proceeds by affected concentration to
the most affected location. Decontamination of all sampling equipment will follow
the decontamination procedure outlined in section 6.2.5 of the QAP.
2) Chloroform Investigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah Notice of Violation and Groundwater Corrective Action Order UDEQ Docket No. UGQ-20-01. Chloroform wells shall be collected
from the least contaminated to the most contaminated as based on the most recent
quarterly results.
• MW-4
• TW4-1
• TW4-2
• TW4-3
• TW4-4
• TW4-5
• TW4-6
• TW4-7
• TW4-8
• TW4-13
• TW4-14
• MW-26
• TW4-16
• MW-32
• TW4-18
• TW4-19
• TW4-20
• TW4-21
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• TW4-9
• TW4-10
• TW4-11
• TW4-12
• TW4-22
• TW4-23
• TW4-24
• TW4-25

Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform Investigation Program or the Groundwater Discharge Permit Monitoring Program.

3) Chloroform Investigation Sample Containers and Collection Volume
The chloroform investigation sampling program requires a specific number of sampling containers and the collection of specific volumes of sample. Accordingly,
the following sample volumes are collected by bailer (when the well is not outfitted
with a dedicated pump) from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 100 250 ml
container.
• For Inorganic Chloride, collect one sample into a 100 250 ml container.
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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 or a more recently EPA
promulgated version of the method listed or an equivalent, EPA approved method must be adhered to unless otherwise approved by the Executive Secretary:
Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding Times
Sample
Preservation Requirement
Sample
Temperature Requirement Nitrate & Nitrite
(as N)
E353.2 0.1 mg/L 28 days H2SO4pH<2
to ≤ 6oC
Carbon
Tetrachloride
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC Dichloromethane (Methylene
Chloride)
SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Inorganic Chloride A4500-CI B 1 mg/L 28 days None ≤ 6oC

5) Field Parameters
In the case of chloroform pumping wells only one set of field parameters is required to be measured prior to sampling [see Section 6.2.2(b)(ii)]. This includes the
following wells: MW-4, MW-26, TW-4-19 and TW-4-20. However, if a pumping
well has been out of service for 48 hours or more, DUSA shall follow the purging requirements outlined in Section 6.2.7(d)(v) of the QAP before sample collection.
6) Chloroform Investigation Reports
The Chloroform Investigation Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan

• Description of monitor wells
Formatted: Space After: 12 pt, Tab stops: 1.13", Left + 3.56", Left
Formatted: Underline
Formatted: Indent: Left: 0.5"
Mill - Groundwater Discharge Permit Date: 3-22-10 Revision 66-4-10 Revision 7
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 60 of 60
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment rinsate
samplesblanks, duplicate samples
c) Data Interpretation

• Interpretation of groundwater levels, gradients, and flow directions. Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an evaluation of rthe effectiveness of hydraulic capture of all contaminants of concern.
• Interpretation of all analytical results for each well, including a discussion
on: 1) a current chloroform isoconcentration map with one of the isosconentration lines showing the 70 ug/L boundary, 2) graphs showing chloroform concentration trends in each well through time and, 3)
analytical results for each well summarized in a data table, that includes historic analytical results for each well.
• Calculate chloroform mass removed by pumping wells. Calculations would include: 1) total historic chloroform 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 from
each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for groundwater quality monitoring conducted during the quarter.
f) Copies of DUSA 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
Quality Assurance Plan (QAP).