DRC-2011-005609 - 0901a0688022e936

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Thomas Rushing li
Work Plan
DRC Review Comments — White Mesa l^ili Site Nitrate Investigation Revised Phase 1
From: Thomas Rushing ii
To: [e-mail]
Date: 5/11/2011 5:08 PM
Subject: DRC Review Comments -- White Mesa Mill Site Nitrate Investigation Revised Phase 1 Worl< Plan
CC: Goble, Phillip; Hochstein, Ron; [e-mail]; Lundberg, Rusty; Morton, Loren;
[e-mail]; [e-mail]; Roberts, Harold; Tischler, Jo Ann
Attachments: DUSA_WP_review_llMay2011_rev2.pdf
Dave,
The DRC review comments regarding the White Mesa Mill Site Nitrate Investigation Revised Phase 1 Work Plan
(Dated May 6, 2011) are attached (Via URS Memorandum). Please ensure that all comments are addressed and
resolved prior to commencement of field activities in order to avoid lost time and additional costs which may
otherwise be incurred.
Let me know if you have questions or concerns regarding the comments.: Thanks.
Tom
Tom Rushing, P.G.
Utah Division of Radiation Contra/
[phone]
[phone] fax
[e-mail]
file://C:\Documents and Settings\Trushing\Local Settings\Temp\XPgrpwise\4DCAC29CEQDOMAINEQRAD10017262741... 5/1 1/2011
MEMORANDUM
To: Tom Rushing (DRG), Loren Morton (DRC), Phil Goble (DRC)
From: Paul Bitter (URS), Jeremy Cox (URS)
cc: Robert Baird (URS)
Date: 11 May 2011
Re: Comments on Nitrate Investigation Revised Phase I Work Plan for AVhite Mesa Mill
Site dated May 6, 2011
This memorandum contains the URS anci DRC comments on the Revised Phase I Work Plan for ^
White Mesa Mill Site (Work Plan) dated May'6, 2011, which was prepared for Denison Mines
USA (DUSA) bylntera Corporation. This review has been performed as a deliverable for
Contract No. 116259 issued through the Utah Department of Environmental Quality, Division of
Radiation Control (DRC). This review also is in accordance with the amended Memorandum of
Understanding (MOU) between the DRC and DUSA dated April 28, 2011. For purposes of
expediency, the URS and DRC comments are edited for conciseness and combined into one
memo. Note that format, grammar, and punctuation were not reviewed for accuracy and
consistency.
The comments regarding the Work Plan are presented below. Several of these comments require
resoludon prior to the start of field work.
1. General Comment: The Phase I Work Plan has incorporated many ofthe recommendations
in the comments provided to DUSA on March 21, 2011 regarding the Feb. 18, 2011
Investigation Work Plan (now superseded). In particular, the objectives of the Phase 1
investigation and the potential source areas are clarified, and more detail is provided in the
Phase I Work Plan when compared to the corresponding sections in the previous work plan.
2. Secdon 1, first paragraph and thereafter: For consistency and accuracy, all measurements of
nitrate in groundwater must be expressed "as nitrogen" and this clarification should be listed
with ever>' concentration. For soil, the nitrate concentrations can be expressed as either
nitrate or as nitrogen, but the unit of measurement must be presented with every
concentration.
3. Section l .,l .l, second paragraph: A disproportionate amount of text is used in this paragraph
to explain the potential for a naturally-occurring nitrate reservoir W'hen compared to the text
explaining the potential for nitrate contamination from other sources. While, the text
regarding the potential nitrate reservoir is useful and appropriate in explaining this concept,
additional text should be added to explain the potential for the groundwater contaminants
originating from the other potential sources.
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4. Section 1.1.1, third paragraph: recommend deleting the phrase "the presence of in this
paragraph; that phrase is unnecessary.
5. Section 1.1.2, paragraph following the list of Potential on-Site sources and preceding the
"Site Status" section: the last sentence ofthis paragraph regarding "...the most plausible
source..." is unsupportable until further field work is produced and die conceptual site model
is created and updated with investigation data. Delete the sentence cited herein, from the
text.
6. Section 1.1.3, fifth paragraph, last sentence: Following tliis sentence, please insert "In the
October 5, 2010 DRC Notice of Additional Required Action (NOTICE), DRC determined
that the 2009 CIR is incomplete, and considered the conclusion regarding the sole source of
the nitrogen contamination to be unsubstantiated with direct and reliable evidence.
Furthermore, the NOTICE stated that DUSA has additionally identified several onsite sources
which have a likelihood of being contributors to the contamination and have yet to be fully
examined"
7. Section 1.2, first paragraph: QuanTab test kits for chloride are mentioned in this paragraph
but are not consistentiy mentioned in the procedures listed in Section 2. If these test kits are
proposed for use by DUSA, they must be consistently cited in the procedures in Section 2,
and the standard procedures for using the test kits must be provided in Appendix E with the
same details requested for the nitrate test kits in comment #28 below.
8. Section 1.2, Page 12, paragraph beginning with "Sources 1-8": The second sentence of this
paragraph refers to a meeting handout. The handout may have been a previous version ofthe
current Table 1 in the Work Plan. Please refer to current table, as appropriate, instead of
referring to the meeting handout.
9. Section 1.4, "data requestors/users" paragraph: The existence of a potential nitrate reservoir
is not the only hypothesis to be tested. Suggest stating that the data generated by the
investigation will be used to "test hypotheses regarding potential sources for nitrate and
chloride contamination, which includes naturally-occurring sources."
10. Section 1.4: The inclusion of the various QC monitors is a positive step initiated by DUSA.
However, no QC monitors are designated. Please designate which DUSA personnel will
function as these monitors in the text of this section or a table. It is not necessary' to designate
which laboratory personnel will act as QC monitors.
11. Section 1.6.1: .The form for the boring logs provided in Appendix C is a substantial
improvement over the boring logs provided in the 2009 CIR. Most of the information
requested by DRC is provided on the form. However, DRC requests that fields for the
sample coordinates and coordinate sy stem also be provided on the form. The inclusion of
survey data (i.e., sample coordinates) on the form was requested by DRC in comment #28 in
the comments submitted to DUSA on March 21, 2011. There appears to be space at the top
of the form where these fields can be entered. Similarly, the text cites Appendix A which
contains the ASTM procedure for description and identification of soils. List the field
obser\ ations/tests that will be conducted on soil cores per the ASTM procedure.
12. Section 2.1, Page 20, Item #2a: Please add a semicolon after "95%" to clarify this text..
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13. Section 2.1, Page 21, last paragraph for Phase la, last sentence: Plugging the borings is the
abandonment. Please delete "prior to abandonment" in this sentence and perform this edit
where this text is repeated in the document.
14. Section 2.1, Page 22, last sentence following hst of potential sources, and Section 2.1, Page
23, fifth paragraph: DRC requires that DUSA cite the reason(s) for the delay in sampling
locations #1, 2, and 15 and the anticipated schedule for sampling these locations. These
samples are required per Attachment 1, p.3 ofthe April 28, 2011 Tolling Agreement (Rev. 1).
DRC will consider the investigation reports to be incomplete if these source locations are not
sampled.
15. Section 2.1, second paragraph on Page 23: A mass balance approach to evaluate potential
source areas is implied by this paragraph but not explained. Please add text to this paragraph
to briefly summarize the approach for a mass balance calculation, and repeat this edit where
appropriate for other investigation phases in the document.
16. Section 2.2, sixth paragraph, number 2: The last sentence cites the sample as
"..."background" or "baseline" sample for this location". DRC prefers to use the term
baseline in the context of sample identification described in this section. Therefore, the
baseline sample discussed in the paragraph cited herein should be designated GP-two digit
.sample number-BL - Phase - boring number. The term "background" should have a unique
application to samples discussed in Section 2.1, Paragraph 1 A.
17. Section 2.2: Equipment decontamination shall be implemented for all non-disposable
equipment that comes in contact with soil before moving direct push equipment to a new
location or collecting a new sample for any non-disposable equipment used to handle samples
prior to placement in laboratory-supplied glassware.
18. Section 2.3.1, last paragraph: DRC recommends that both the top and bottom ofthe sample
interval be included in the sample ID. In addition, the convention for sample IDs for QC
samples should be included in the text of this paragraph.
19. Section 2.5.2: Please provide minimum, detection limits (MDL) and practical quantitation
limits (PQL) for each of the EPA laboratory' methods to be used for analysis of the soil
sample leachates extracted (EPA 1312). Please demonstrate and justify why said MDLs are
sufficientiy sensitive for purposes of this study.
20. Section 2.6.1: As stated in previous meetings and comments, DUSA should provide a
sampling and analysis table as a template for recording sample collection and reporting. The
QC samples must include equipment blanks to assure, among other quality control concems,
no rinsate is carried over to sample results. Equipment blanks must consist of DI water,
obtained from a commercial third party source. The DI water must be contacted with all
surfaces that may come into contact with site soil. Equipment blank samples should be
collected after equipment decontamination at a frequency of one equipment blank per 20 field
samples. Equipment blanks will be analyzed at the same contract laboratory as the soil
samples and for die same analyses as the leachate from the soil samples. Per Table 3-1 ofthe
2011 EPA Contract Laboratory Program Guidance for Field Samplers (EPA 540-R-09-03),
field duplicates must be collected at a minimum rate of one field duplicate for every ten
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samples. Please adjust the text in this paragraph accordingly. This comment can be
combined with comment 26, below.
21. Section 2.6.3.4: The EPA document cited in this paragraph w^as updated in 2010. Please
update the citation here and in Section 5. Also, please modify' the workplan to include the
EPA criteria for accepting RPD results when the concentrations are less than 5-times the PQL
value.
22. Section 2.8: This paragraph states that "Test kits will use the calibration methods set forth in
the instruction manual provided with the test kits." No such calibration procedure appears to
, be included in the instructions for the nitrate test strips in Appendix E. DRC suggests that
analyzing DI water (obtained from a third party commercial source) with the test strips could
ser\'e to verify' that non-detect values register as non-detect on the test strips. Laboratory
results will serve to verify' detectable results for the test strips in Phase IC.
23. Section 3.0, fourth paragraph: DRC recommends that the contracted laboratory make the
conversion between milligrams per liter of extract and milligrams per kilogram of soil and
that the calculation be provided in the report.
24. Figure 2: The chlorate tanks should not have a red outiine, since no sampling is planned
around these tanks.
25. Table 1: Please label Phase lA, IB, and IC on the table and split tiie sampling locations for
each part of Phase lA into separate rows Analyses by field test kits need not be shown on
this table but can be listed at DUSA's preference. If field test kit sampling is shown on the
table, the laboratory analyses and the field test kit analyses must be clearly differentiated.
26. Table 1: The addition of this table to the Phase I Work Plan is an improvement over the lack
of-tables summarizing sampling in the Febmary work plan (now superseded). However,
Table 1 does not include all ofthe information requested by DRC in comment #41 in the
comments submitted to DUSA on March 21, 2011. DRC requested at that time, that "the
planned sampling be summarized in a table showing the sample locations; number, and types
of samples for each location; the types of analyses and the associated container type, holding
time, and preservative; and the planned QA/QC samples at pre-determined locations."
Table I does not include all of this information. Please supplement Table 1 with an
additional table showing the following for each sampling location:
Sample location ID for each planned sample point
Analyses to be performed for each planned sample
Sample containers and minimum sample volume required for each planned sample
Additional QC samples (field dupUcates, equipment blanks, matrix spike/matrix spike
duplicates) to be collected at pre-determined locations, with the previously outiined
iriformation (sample location ID, analyses, sample container, and minimum sample
volume) for each of these samples.
The preservative for the containers in the field (6° C) may be included on the supplemental
table or retained separately in the current Table 2.
27. Table 2: Please cite the source for the information in Table 2 in a note beneath the table.
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28. Appendix E: Per a request by DRC in the April 20, 2011 meeting with DUSA, the minimum
detection limits and error rate for the test kits, as provided by the manufacturer, must be
provided in this Appendix or in the text ofthe Work Plan that refers to this Appendix.
[End of comments]
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