DRC-2010-003915 - 0901a068801a5285

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
June 24, 2010
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
DRC-2010-003915
CERTIFIED MAIL
(Return Receipt Requested)
Mr. David C. Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Subject: RE: June 4, 2010 DUSA Quality Assurance Plan, Revision 7: Request for
Information
Dear Mr. Frydenlund:
On June 4, 2010 Denison Mines (USA) Corp. (hereafter DUSA) submitted by e-mail a revised
Quality Assurance Plan, Revision 7 (hereafter QAP, Rev. 7) to the Division of Radiation Control
(DRC). After reviewing the document, we have the following comments, and requests for
information.
1. Well Penetration Justification/Explanation - The June 4, 2010 DUSA QAP, Rev. 7 does
not specify what monitoring wells are appropriate for low-flow sampling. In the April 2,
2010 Conversion to Low-Flow Sampling and Request for Interim Variance DUSA states:
"Currently all ofthe 23 groundwater monitoring wells at the site are equipped with
dedicated pumps that are amenable to low-flow sampling... " and "As a part of the
sampling program evaluation, DUSA proposes to evaluate the suitability of low flow
sampling techniques for all groundwater, chloroform and nitrate wells at the site for the
low flow sampling method.
In order to assess the suitability of implementing low-flow sampling for each well on site,
the following steps will be taken:
• Review well construction specifications to determine total depth, screen interval,
etc.; and
• Review historical purge and sample data to determine depth to groundwater, past
purge rate, amount of drawdown, etc. "
It is possible that some wells that have dedicated pumps currently installed may not be
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Mailing Address: P.O. Box 144850 • Sah Lake City, UT 84114-4850
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appropriate for micro-purge low-flow sampling (e.g. wells that are not ftiUy penetrating).
Please provide a detailed explanation/justification and well construction As-Built reports
for the wells DUSA is proposing to sample using the micro-purge low-flow sampling
method.
2. Well Screen Length Justification - In both the April 2, 2010 DUSA Conversion to Low-
Flow Sampling and Request for Interim Variant^ and June 4, 2010 DUSA QAP, Rev. 7
DUSA cites two references regarding micro-purge low-flow sampling (Puis and
Barcelona, 1996) and (Yeskis and Zavala, 2002). Regarding well screens, Puis and
Barcelona, 1996 "...suggested that short (e.g., less than 1.6 m) screens be incorporated
into the monitoring design where possible so that comparable results from one device to
another might be expected. "; Yeskis and Zavala, 2002 states "This method is applicable
primarily for short well-screen lengths (less than 5 feet (1.6 meters)) to better characterize
the vertical distribution of contaminants. This method should not be used with well-screen
lengths greater than 10 feet (3 meters). " The monitoring wells at the White Mesa have
well screen lengths greater than 10 feet, please justify how micro-purge low-flow sampling
is appropriate for these wells.
3. Pump Location - On a well-by-well basis, please explain at what location within the well
screen DUSA plans on placing the pump for micro-purge low-flow sampling for each well
(considering well screen length).
4. Training - Please explain how and when DUSA will train its sampling staff for the new
sampling method.
5. TW4-26 As-Built Report - The June 4, 2010 DUSA QAP, Rev. 7 lists a new chloroform
well, TW4-26. Part I.F.6 of the Permit requires that "Groundwater Monitoring Well As-
Built Reports - as-built reports for new groundwater monitoring wells shall be submitted
for Executive Secretary approval within 60 calendar days of well completion.... " The DRC
has not received an As-Built report for this well. Please submit the missing As-Built
reports in accordance with Part I.F.6 of the Permit within 30 calendar days or July 14,
2010.
6. Well Development Demonstration/Issue - Before the DRC can consider any change
regarding Turbidity in the DUSA QAP, DUSA must first resolve item 2 of the June 1,
2010 Request For Infonnation (RFI), as follows: "Please explain and justify how DUSA
used all commonly available well development techniques on the wells in question,
including: bailing, surging, Jetting, and overpumping. For a Standard Operating
Procedure (hereafter SOP) for well development, please see the October 3, 1994 EPA
Well Development SOP. Before the DRC can consider approval of any variance
regarding turbidity in monitoring wells, DUSA has to provide convincing evidence that all
monitoring wells at the Mill have been developed properly and all commonly well
development methods were attempted and exhausted. "
7. Analytical Methods - At an number of locations in the DUSA QAP, Rev. 7, DUSA has
added the following (new wording in bold): "The analytical procedures to be used by the
Analytical Laboratory will be those specified in Table 1, or a more recently EPA
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promulgated version of the method listed or an equivalent, EPA approved method," -
this new wording has been removed from the DUSA QAP, Rev. 7 due to potential conflict
and confusion. This would only be allowed if DUSA received prior authorization of the
method by the Executive Secretary.
8. Attachment 1 - This form needs to provide a separate space for each of the three possible
sampling methods. Each section need to have prompts with spaces or blanks to facilitate
documentation for each method.
9. DRC Changes to Draft QAP - The DRC made a number of changes to the Draft June 4,
2010 DUSA QAP, Rev. 7 at the following locations: Sections 1, 5.2, 6.2.4(e), 6.2.5,
6.2.6(b), 6.2.7(b)(vii), Table under 6.2.7(v)(ix), 8.2, Table under 8.2, Footnote for 8.2,
9.14(a), 9.3(b), and Appendix, Section 4. These changes are highlighted and were e-
mailed to you in a June 24, 2010 e-mail. Please incorporate all of these changes in your
revised submittal (e.g. Revision 7.1).
Please review the above comments, and submit the requested infonnation. The proposed changes
in the June 4, 2010 DUSA QAP, Rev. 7 can not be approved until the items in the June 1, 2010
DRC RFI and the items in this RFI are resolved.
If you have any questions on the above, please contact me @ 801-536-4044.
Sincerely,
Phil Goble
Hydrogeologist