DRC-2012-001541 - 0901a068802e024c

DRC-2012-001541
/^
MAY 2012 2
CO, Division of Radiation ConUc^- ^:
Denison Mines (USA) Corp
105017th Street, Suite 950
Denver, CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
DENISO
MINES
May 25, 2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Executive Secretary
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: State of Utah Groundwater Discharge Permit ("GWDP") No UGW370004
Response to Division of Radiation Control ("DRC") letter dated Apnl 16, 2012
Transmittal of Revised Groundwater Quality Assurance Plan ("QAP"), dated May 25, 2012
Dear Mr. Lundberg.
Reference is made to the Division of Radiation Control ("DRC") letter dated Apnl 16, 2012, regarding
the White Mesa Mill Draft Groundwater Quality Assurance Plan ("QAP"), dated May 25, 2012 (Revision
7).
This letter transmits Denison Mines (USA) Corp's ("Denison's") proposed revisions to the White Mesa
Mill QAP as well as proposed language for the current Groundwater Discharge Permit ("GWDP") as
requested in the comments below These revisions include changes made to:
1. Respond to the DRC Letter dated Apnl 16, 2012, and
2. Correct additional typographical errors in the March 2012 Revision of the QAP.
For ease of review we have provided both redline and clean versions of the document.
The attached QAP Revision 7.1 has accepted all the redline changes proposed in Denison's March 26,
2012 submittal (Revision 7) as the base version in black type. Changes resulting from the above-
referenced DRC comment letter are provided in rediine/stnkeout format.
We have also provided, below, specific responses to each request in DRC's Apnl 16, 2012 letter The
sections and numbenng of the remainder of this letter follow the DRC Apnl 16, 2012 letter Each DRC
request is shown in italics, below, followed by Denison's response.
Summary of DRC/DUSA April 5, 2010 Conference Call Regarding Out-of Compliance (DOC)
Reporting and Monitoring
DRC Comment
DUSA states in the March 26, 2012 response that based on an agreement made between DRC and
DUSA dunng a telephone conference call on April 5, 2010, DUSA is not required to implement
Letter to Mr. Rusty Lundberg
May 25, 2012
Page 2
accelerated monitoring until "the month following the submission of the Exceedence Notice for a specified
quarter." Based on DRC review of notes taken during the Apnl 5, 2010 telephone conference (Loren
Morton 4/5/10,0900), DUSA verbally requested to wait until the end of the quarter to send in the notice of
out-of compliance status - but within 30 days of the last lab report that DUSA receives.
The Groundwater Permit, Part I.G. l.b. requires accelerated monitoring to begin immediately following the
date of receipt of the data showing the GWCL exceedence. This was the basis of the DRC February 7,
2012 NOED which noted that accelerated monitoring should have started dunng Apnl, 2011. Also, the
Groundwater Permit Pari I.G.4.C. requires the submission of a plan and time schedule for assessment of
the sources of the GWCL exceedences within 30 days of detection of the out of compliance status 'but
does not state that the 30 day clock begins upon receipt of the last analytical report for the sample batch.
Therefore, DRC notes that the procedures discussed during the Apnl 5, 2010 telephone discussion do not
agree with the current permit requirements.
In order to formalize the April 5, 2010 discussion items related to out-of-compliance reporting and
sampling, please provide a written request for a groundwater permit modification (groundwater permit,
out-of-compliance notification and accelerated monitoring requirements) for Executive Secretary review
and approval. Note that the DRC will review accelerated monitoring actions by DUSA according to the
currently approved groundwater permit as of the date of DUSA receipt of this letter.
Also, DRC notes that there is currently no specified maximum time limit for the contract laboratory to
deliver the analytical report to DUSA. Per review of the 4th Quarter 2011 White Mesa Ground Water
Monitonng Report, dated February 28, 2012, DRC noted that per Table 1, most of the samples were
collected in early October (October 3, 4, 5, 6, 11, 12 of 2011) but the laboratory analytical package was
not received by DUSA until late December (December 22 and 27, 2011). This is a turnaround time of
approximately 11 weeks which seems unreasonably long.
In order to insure timely data submission, review and acceleration of monitoring frequencies for OOC
parameters, please include a maximum time period for analytical report receipt from the laboratory of 30
days from sample receipt by the contract laboratory.
Denison Response-
Denison appreciates the opportunity to propose changes to the GWDP to formalize the agreements made
in the Apnl 5, 2010 teleconference between DRC and Denison. Denison has prepared a request for a
modification of the GWDP, under separate cover (dated May 25, 2012), which provides proposed
revisions to Parts I.G.1 through 1.G.4 of the GWDP in redline stnkeout format.
Denison agrees that the data turn-around time ('TAT") noted by DRC for the 4*^ Quarter 2011 data was
unusually long. As discussed in the 4*^ Quarter 2011 Groundwater Report submitted February 28, 2011,
during a review of laboratory certifications conducted in late 2011, Denison noted that Energy
Laboratones ("EL's") Utah Department of Health, Bureau of Laboratory Improvement, Environmental
Laboratory Certification ("Utah Certification") for tin expired on June 30, 2011. This loss of certification
necessitated the reanalysis of all of the third and fourth quarter samples for tin by Amencan West
Analytical Laboratones ("AWAL"). The reanalysis of the samples for tin extended the data TAT times.
Additionally, EL reported issues with the ammonia analyses, which prompted resampling in multiple wells
which was conducted in late November 2011. The resampling for ammonia also delayed the submission
of the data.
In response to the data TAT and tin certification issues Denison has contacted EL and held discussions
regarding measures that EL should undertake to improve their performance. Denison is closely
monitonng EL performance and is taking measures to identify other laboratones capable of performing
analytical work in conformance with the Groundwater QAP, Revision 7.1. The QAP Revision 7.1 will
expand the analytical methods allowable for use at the Mill Site and will allow Denison to explore other
DENISO
MINES
Letter to Mr. Rusty Lundberg
May 25, 2012 •
Page 3
laboratory opportunities should the need anse, due to lack of performance or loss of certification by any
contracted laboratory.
It IS important to note that despite Denison's efforts, any contracted laboratory may deliver data beyond
the contractually specified time limits, despite any associated contractual penalties that may apply.
Because Denison does not self-perform the analytical work, Denison cannot completely control the data
reporting timeframes or force delivery of data within a specified timeframe Denison can and does
enforce contractual requirements as practicable; however, a laboratory's performance is sometimes
beyond Denison's control.
It IS Denison's understanding that DRC has made this request for.an improved data TAT to assure timely
implementation for accelerated monitoring frequencies for OOC parameters. Denison has met the GWDP
requirement to sample quarterly, and the GWDP does not require or specify a timeframe within the
quarter for sampling. Denison generally strives to collect the quarterfy samples with sufficient time
remaining in the quarter to resample if necessary to address any shipping, sample, analytical or quality
issues which arise. Denison should not be penalized for laboratory performance if the laboratory does
not provide results within a specified time penod for samples collected earfy in the quarter, provided
Denison meets the quarterly sampling and reporting requirements in the GWDP. In light of DRC's
concern, and as discussed with DRC on May 14, 2012 Denison will agree to provide the Exceedance
Notice 30 days from the receipt of the last data package for the latest samples collected in a quarter
(either quarterly or monthly accelerated) but no later than 60 days after the end of the quarter The Plan
and Time Schedule for addressing OOC parameters will be submitted within 30 days after the
Exceedance Notice. The proposed changes to the GWDP under separate cover (dated May 25, 2012)
reflect these agreements.
As a result of the foregoing and per Denison's discussions with DRC by telephone on May 14, 2012, no
timeframe for data delivery and TAT has been added to the QAP.
DRC Comment
Approval to Return Monitoring Well MW-11 to Baseline Monitoring for Tetrahydrofuran (THF)
DRC acknowledges the DUSA response to the January 25, 2011 DRC RFI regarding confirmation as to
whether THF is stored at and/or used in the White Mesa Mill operations with the March 26, 2012 letter.
Per the response DUSA states "Denison has never purchased, stored or used THF as a reagent, solvent
or additive to the Mill's processes."
Based on the recent monitoring data for THF and well MW -11 (21 consecutive sampling results for THF
below the GWCL of 11.5 (ug/L), the Executive Secretary approves the March 26, 2012 DUSA request to
return monitoring well MW-11 to baseline quarterly ground water monitoring for THF.
Denison Response:
Denison appreciates DRC's consideration in this matter and will return monitonng well MW-11 to baseline
quarterlyground water monitonng for THF beginning in June 2012. ,
DRC Comment
Request for Information, DUSA White Mesa Mill QAP Revision 7:
Based on DRC review of the redline revised QAP, Revision 7, DRC has the following comments
Table of Contents - Add QAP Attachments and Appendices to the table of contents
DENISO
MINES
Letter to. Mr. Rusty Lundberg
May 25, ;2012 :
•Page'4"' ..• , ] '
Denison Response: •
The Attachments and Appendices have been added to theTable of Contents as requested.
General Inclusion - DRC notes that there is no requirement for a maximum time period for the laboratory
to deliver an analytic report to DUSA in the current QAP. In order to insure timely data submission, review
and potential acceleration of monitoring frequencies, please include a maximum time period for analytical
report receipt from the laboratory of 30 days from sample submission.
Denison Response: . •
See response to DRC's first comment, above. '\
Section 4.3 2 Attachment 2-5 Equipment Rinsate Samples - DRC notes that the QAP specifies a rinsate
sample to be taken at the beginning of the day and after decontamination. This implies that a rinsate
sample will be collected after each sampling location. The DRC believes it would be appropriate to collect
equipment rinsate samples for one per every 20 samples collected.
Denison Response* '
The frequency of rinsate samples has been changed as requested. ; . •
Section 7.3 Record Keeping - Add a requirement that copies of the current contract laboratory
certifications and Utah Bureau of Laboratory Improvement approved parameters and methods will be kept
at the White Mesa Mill. j
Denison Response: . !
Section 7.3 has been modified as requested. .
Please contact me if you have any questions or require any further information.
Yours very truly, , _ . . ;
DENispj)/MiNEff (USA) CORP
wl^ JoWrrTisdhler
Director, Compliance and Permitting
cc: David 0 Frydenlund
Ron F. Hochstein
Harold R Roberts
David E Turk .
: Kathy A Weinel
Attachments
DENISO
MINES
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 1 of 61

WHITE MESA URANIUM MILL GROUNDWATER MONITORING QUALITY ASSURANCE PLAN (QAP) State of Utah Groundwater Discharge permit No. UGW370004 Denison Mines (USA) Corp. P.O. Box 809 Blanding, UT 84511
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TABLE OF CONTENTS

1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/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
3.0 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
4.0 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
5.0 CALIBRATION 12
5.1 Depth to Groundwater Measurements 12
5.2 Water Quality 12
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6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 12
6.1 Groundwater Head Monitoring 12
6.1.1 Location and Frequency of Groundwater Head Monitoring 13
6.1.2 Groundwater Head Monitoring Frequency 13
6.2 Ground Water Compliance Monitoring 13
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 13
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the GWDP 14
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP 14
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 14
6.2.5 Decontamination Procedure 15
6.2.6 Pre-Purging/ Sampling Activities 15
6.2.7 Well Purging/Measurement of Field Parameters 15
6.2.8 Samples to be taken and order of taking samples 16
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 16
7.1 Field Data Worksheets 16
7.2 Chain-Of-Custody and Analytical Request Record 17
7.3 Record Keeping 18
8.0 ANALYTICAL PROCEDURES AND QA/QC 18
8.1 Analytical Quality Control 19
8.1.2 Spikes, Blanks and Duplicates 19
8.2 Analytical Laboratory Procedures 20
9.0 INTERNAL QUALITY CONTROL CHECKS 24
9.1 Field QC Check Procedures 24
9.1.1 Review of Compliance With the Procedures Contained in this QAP 24
9.1.2 Analyte Completeness Review 24
9.1.3 Blank Comparisons 24
9.1.4 Duplicate Sample Comparisons 25
9.2 Analytical Laboratory QA Reviews 26
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 26
9.4 Analytical Data 27
10.0 CORRECTIVE ACTION 28
10.1 When Corrective Action is Required 28
10.2 Procedure for Corrective Action 28
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11.0 REPORTING 29
12.0 SYSTEM AND PERFORMANCE AUDITS 30
12.1 QA Manager to Perform System Audits and Performance Audits 30
12.2 System Audits 30
12.3 Performance Audits 31
12.4 Follow-Up Actions 31
12.5 Audit Records 31
13.0 PREVENTIVE MAINTENANCE 31
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 32
14.1 Ongoing QA/QC Reporting 32
14.2 Periodic Reporting to Management 32
15.0 AMENDMENT 32
16.0 REFERENCES 33

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ATTACHMENTS

Attachment 1 Field and Data Forms

Attachment 1-1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example COC Forms
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures Attachment 2-2 Decontamination Procedures Attachment 2-3 Purging Procedures Attachment 2-4 Sample Collection Procedures Attachment 2-5 Field QC Samples APPENDICES Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah
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1.0 INTRODUCTION

This Groundwater Monitoring Quality Assurance Plan (the “QAP”) 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).

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 QAP 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.
2.0 ORGANIZATION AND RESPONSIBILITIES

2.1 Functional Groups

This QAP 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. The QA Manager is designated by
Denison Mines (USA) Corp. (“DUSA”) corporate management.

2.3 Data Requestors/Users

The generation of data that meets the objectives of this QAP 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
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 QAP.

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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
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 QAP. 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 this
QAP;

b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the
samples, to the Analytical Laboratory in accordance with this QAP;

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 computerized database,
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 QAP, by the Analytical Laboratory’s QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program (“NELAP”) 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 QAP;

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 QAP, to
minimize contamination; and

d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP 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 certification.

In addition, to the extent not otherwise required to maintain NELAP 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 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.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA

The objective of this QAP 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 27 - 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 a known 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:

% 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 QAP.

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, measurement procedures, methods, and reporting units are consistent
for all samples within a sample set.

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4.0 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.

4.2 Controlling Depth to Groundwater Measurements

Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.

4.3 Water Quality QC Samples

Quality assurance for groundwater 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.

4.3.2 Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples. Rinsate blanks will be
collected after decontamination and prior to subsequent use. Rinsate blank samples for a
non-dedicated pump are prepared by pumping de-ionized water into the sample containers.
Rinsate blank samples for a non-disposable or non-dedicated bailerare prepared by pouring
de-ionized water over and through the bailer and into the sample containers. Equipment
rinsate blanks will be analyzed only for the contaminants required during the monitoring
event in which they are collected.

Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
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4.3.3 Field Duplicates

Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.

Field duplicate sampling procedures are described in Attachment 2-5.

4.3.4 Definition of “Batch”

For the purposes of this QAP, a Batch is defined as 20 or fewer samples. 5.0 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 use as
noted in Attachment 2 to ensure that the Water Sounding Device is functional.

5.2 Water Quality

The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer’s specifications (for
example, by using two known pH solutions and one specific conductance standard.)
Temperature will be checked comparatively by using a thermometer. Calibration results will
be recorded on the Field Data Worksheet.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS

6.1 Groundwater Head Monitoring

Groundwater head measurements (“depth to water”) will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
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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 the GWDP Parts I.E.1 (b) and (c) and
I.E.2;

b) Monitoring well MW-34;

c) All piezometers (P-1, P-2, P-3, P-4, P-5 and the Dry Ridge piezometers);

d) All contaminant investigation wells required by the Executive Secretary as part of
a contaminant investigation or groundwater corrective action (chloroform and nitrate
wells).

6.1.2 Groundwater Head Monitoring Frequency

Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an
electronic data management system (spreadsheet or database). The data from the quarterly
depth to water measurements will be included in the quarterly groundwater report.

The depth to groundwater measured immediately prior to purging/sampling will be recorded
on data sheet for each well. An example of a Field Data Work Sheet for Groundwater is
included in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.

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:

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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) Semi-annually in the following General Monitoring Wells: MW-20 and MW-22;

c) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-25,
MW-26, MW-30, MW-31, MW-35, MW-36 and MW-37; and

d) Quarterly in the Chloroform Investigation and Nitrate Corrective Action wells.

In addition, quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in Parts I.G.1 or I.G.2 of the GWDP. Sampling
personnel should coordinate with the QA Manager prior to conducting any monitoring well
sampling to determine if any parameters in any wells are subject to accelerated monitoring.

6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the
GWDP

All quarterly and semi-annual samples collected under Parts I.E.1.b) or I.E.1.c) of the GWDP
shall be analyzed for the following parameters:

a) Field parameters – depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; 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 accelerated sampling required under paragraphs I.G.1. or I.G.2. of
the GWDP shall be analyzed for the specific parameters as required by previous sampling
results as determined by the QA Manager.

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.

Purging and sampling equipment is described in Attachment 2-3 of this QAP.

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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;

6.2.5 Decontamination Procedure

Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.

6.2.6 Pre-Purging/ Sampling Activities

Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well’s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.

6.2.7 Well Purging/Measurement of Field Parameters

The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging wells prior to sampling removes the stagnant water column present in the well
casing and assures that representative samples of the formation water are collected. Purging
will be completed as described in Attachment 2-3.

There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
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6.2.8 Samples to be taken and order of taking samples

For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP . The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single
container due to like sampling requirements (filtering) and/or like preservation. The
container requirements will be determined by the Analytical Laboratory and specified with
the bottles supplied to the Field Personnel. Bottle requirements may change if the Analytical
Laboratory is changed or if advances in analytical techniques allow for reduced samples
volumes. The following list is a general guideline.

a) VOCs, 3 sample containers, 40 ml each;

b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml;

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

d) Gross alpha and heavy metals, 1 sample container, 1,000 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.

Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.

7.0 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 initials(s)
 date(s) and time(s) of well purging and sample collection
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 type of well purging equipment used (pump or bailer)
 previous well sampled during the sampling event
 well depth
 depth to groundwater before purging and sampling
 field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
 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.

The Field Data Worksheets will also contain detailed notes describing any other significant
factors noted 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 features or conditions. An example of a Field
Data Worksheet that incorporates this information is attached in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.

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)
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 sample location
 number of sample containers in the shipping container
 analyses requested
 signatures of persons involved in the chain of possession
 internal temperatures of the shipping container when opened at the laboratory
 remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.

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

Data 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 and a
list of Utah Bureau of Laboratory Improvement approved parameters and methods used to
perform analysis during the monitoring events conducted during the quarter will be
maintained at the Mill. 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.

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 data packages are managed using electronic
data management software The data management software will be managed and
administered by the QA Manager or designee. The Mill Personnel will have read-only
access to the electronic data management software.

8.0 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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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, 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 analytical Batch of samples:

a) Matrix Spike/Matrix Spike Duplicate

A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.

b) Method Blanks

Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.

c) Surrogate Compounds

Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) 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.
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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 as specified in
Table 1, or as otherwise authorized by the Executive Secretary. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.

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Table 1

Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Nutrients
Ammonia (as N) A4500-
NH3 G or
E350.1
0.05 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC

Heavy Metals
Arsenic E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Beryllium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Cadmium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Chromium E200.7 or
E200.8
25 µg/L 6 months HNO3 to pH<2 None
Cobalt E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Copper E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Iron E200.7 or
E200.7
30 µg/L 6 months HNO3 to pH<2 None
Lead E200.7 or
E200.8
1.0 µg/L 6 months HNO3 to pH<2 None
Manganese E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Mercury E 245.1 or
E200.7 or
E200.8
0.50 µg/L 28 days HNO3 to pH<2 None
Molybdenum E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Nickel E200.7 or
E200.8
20 µg/L 6 months HNO3 to pH<2 None
Selenium E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Silver E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Thallium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Tin E200.7 or
E200.8
100 µg/L 6 months HNO3 to pH<2 None
Uranium E200.7 or
E200.8
0.30 µg/L 6 months HNO3 to pH<2 None
Vanadium E200.7 or
E200.8
15 µg/L 6 months HNO3 to pH<2 None
Zinc E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None

Radiologics
Gross Alpha E 900.0 or
E900.1
1.0 pCi/L 6 months HNO3 to pH<2

None

Volatile
Organic
Compounds

Acetone SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Benzene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
2-Butanone
(MEK)
SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Naphthalene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Tetrahydrofuran SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
or
SW8260C
Toluene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Xylenes (total) SW8260B
or
SW8260C
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
or E300.0
0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None ≤ 6oC

General
Inorganics

Chloride A4500-Cl
B or
A4500-Cl
E
or E300.0
1 mg/L 28 days None None
Sulfate A4500-
SO4 E or
E300.0
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 to pH<2 None
Potassium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Magnesium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Calcium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
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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9.0 INTERNAL QUALITY CONTROL CHECKS

Internal quality control checks are inherent in this QAP. 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 QAP. 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 QAP. 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 QAP

Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.

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, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).

Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will

1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
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4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.

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 concentrations
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 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 = the uncertainty of the first measurement squared
sb2 = 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).
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Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

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 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,
(3) reporting limits for all analytes, and
(4) 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

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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); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.

b) Laboratory Methods Review

The QA Manager shall confirm that the analytical methods used by the Analytical
Laboratory are those specified in Table 1, 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.

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.

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If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will
be consulted to establish more appropriate analytical approaches for problem samples.

10.0 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 QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. 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 a procedural or systematic non-conformance is identified, DUSA shall:

a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to
be systematic or procedural, 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
groundwater 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 QAP. The results for this sample(s) should be included in
the same quarterly monitoring report with other samples collected for the same
sampling event; and
c) For any other material deviation from this QAP, 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 QAP, 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;

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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.
11.0 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 and Nitrate Corrective Action 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 QAP
 A summary data table of 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 (included in the data packages)
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 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 QAP and all corrective actions taken.
 Recommendations and Conclusions.

With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B 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.
12.0 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 QAP 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.
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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 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.

13.0 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 certifications. Preventive maintenance will be performed on a
scheduled basis to minimize downtime and the potential interruption of analytical work.

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14.0 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 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.

15.0 AMENDMENT

This QAP may be amended from time to time by DUSA only with the approval of the
Executive Secretary.

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16.0 REFERENCES

United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.

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.

United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.

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.
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ATTACHMENT 1
Field and Data Forms
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Attachment 1-1
Quarterly Depth to Water Data Sheet

NAME:   
DATE: 
TIME WELL Static level TIME WELL Static Level TIME WELL Static Level

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ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
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ATTACHMENT 1-3
EXAMPLE CHAIN OF CUSTODY
FORMS

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Sheet 1 of 1

CHAIN OF CUSTODY

Samples
Shipped to:
Contact
:

Chain of Custody/Sampling Analysis Request

Project Samplers Name Samplers Signature

Sample ID
Date
Collecte
d
Time
Collected Laboratory Analysis Requested

Please notify Tanner Holliday of Receipt temperature on these samples Immediately!
Thank you.

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

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ATTACHMENT 2
Field Procedures
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Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures

Measure and record all depth to water data to the nearest 0.01 feet.

Equipment Used For Groundwater Head Monitoring

Measurement of depth to groundwater is accomplished by using a Solinist – IT 300 or
equivalent device (the “Water Level Indicator”).

Equipment Checks

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

Check the Water Sounding Device as follows:
 Turn the Water Level Indicator on.
 Test the Water Level Indicator using the test button located on the instrument.
 If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.

Measurement of Depth to Water

All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:

 For monitoring wells - Measure depth to water from the top of the inner well casing
at the designated measurement point.
 For the piezometers - Measure depth to water from the top of the casing at the
designated measurement point.
 Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
 Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.

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Attachment 2-2
Decontamination Procedures

Non-dedicated sampling equipment will be decontaminated using the following
procedures:

Water level meter

Decontaminate the water level meter with a detergent/deionized (“DI”) water mixture
by pouring the solutions over the water level indicator.

Rinse the water level indicator with fresh DI water rinse by pouring the DI water over
the water level indicator.

Field Parameter Instrument (Hydrolab or equivalent)

Rinse the field parameter instrument probe unit with DI water prior to each
calibration.

Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.

Non-Dedicated Purging/Sampling Pump

Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:

a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;

b) pump the detergent/DI water solution through the pump and pump outlet lines
into the drain line connected to Cell 1;

c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

d) submerge the pump into a 55-gallon drum of DI water;

e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;

f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

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g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;

h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).

All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.

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Attachment 2-3
Purging Procedures

The following equipment will be used for groundwater purging and sampling:

 Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
 Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
 Non – Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
 Field Parameter Meter: A meter used to measure ground water quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:

 Water temperature;
 Specific conductivity;
 Turbidity;
 pH;
 Redox potential (Eh).

 Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
 Diesel Generator: Mobile power supply to provide power for submersible pump.
 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
“bladder” pumps.

Additional supplies for purging and sampling are as follows:

 Field Data Sheets
 45 micron in-line filters (when metals and gross alpha analyses are required)
 Calculator
 Clock, stopwatch or other timing device
 Buckets
 Sampling containers(as provided by the Analytical Laboratory)
 Field preservation chemicals (as provided by the Analytical Laboratory)
 Disposable gloves
 Appropriate health and safety equipment
 Sample labels and COCs (as provided by the Analytical Laboratory)

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Pre-Purging/ Sampling Activities

If a portable (non-dedicated) pump is to be used, prior to commencing the event’s sampling
activities,

1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) into a cooler that will transport
the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC) samples
throughout the monitoring event.

Well Purging

The purging techniques described below will be used for all groundwater sampling
conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery

The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.

Turbidity measurement in the water should be < 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.

A flow-cell needs to be used for field parameters.

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Procedure

a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)

b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;

c) 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;

If a portable (non-dedicated) pump is used:

 Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
 Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.

If a non-dedicated pump or dedicated pump is used:

(i) Commence pumping;

(ii) Determine pump flow rate by using a stopwatch or other timing device 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) Calculate the amount of time to evacuate two or three casing volumes;

(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);

(v) If two casing volumes will be purged:

Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded on the Field
Data Worksheet. Purging is completed after two casing volumes have been
removed and the field parameters pH, temperature, specific conductance,
redox potential (Eh) and turbidity have stabilized to within 10% RPD over at
least two consecutive measurements.

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(vi) If three casing volumes will be purged:

Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements on the Field Data Worksheet.

(vii) If the well is purged to dryness:

Record the number of gallons purged on the Field Data Worksheet.

The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.

Upon arrival at the well after recovery or when sufficient water is available
for sampling measure depth to water and record on the Field Data Worksheet.

Take one set of measurements of field parameters for pH, specific
conductance and redox potential only.

Collect the samples into the appropriate sample containers.

Take an additional set of measurements of field parameters for pH, specific
conductance and redox potential after the samples have been collected.

If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.

If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.

Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.

Purging using a disposable bailer

For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.

When a bailer is used, the following procedure will be followed:

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(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.

(ii) Attach a disposable bailer to a rope and reel.

(iii) Lower the bailer into the well and listen for contact with the solution.
Once contact is made, allow the bailer to gradually sink in the well, being
careful not to allow the bailer to come in contact with the bottom sediment.

(iv) After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.

(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.

(vi) Take field measurements from the water in the buckets.

All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.

After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
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Attachment 2-4
Sample Collection Procedures
Sample Collection Order

Regardless of the purging method employed samples will be collected in the order specified
below.

All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.

VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologics (fluoride, general inorganics, TDS, total cations and anions); and
Gross alpha and heavy metals (filtered).

Sample Filtering

When sampling for heavy metals 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:

(i) Place a new 0.45 micron filter on the sample tubing;

(ii) Pump the sample through the filter, and into the sample container containing
the preservative;

(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;

d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:

(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.

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(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.

(iii) Place clean unused tubing in the peristaltic pump.

(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.

Procedures to Follow After Sampling

a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:

 Sample location
 Date and time of sample
 Any preservation method utilized
 Filtered or unfiltered

b) Immediately after sample collection, place each sample in an ice-packed cooler;
and

c) Before leaving the sampling location, thoroughly document the sampling event on
the Field Data Worksheet, by recording all pertinent data.

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 overnight delivery services to the Analytical Laboratory.
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Attachment 2-5
Field QC Samples
Field Duplicates

Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.

Field duplicate samples should be as near to split samples as reasonably practicable.

Collection of field duplicates is completed as follows:

Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.

Field duplicate samples are labeled using a “false” well number such as MW-65 and MW-70.

Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples.

Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:

Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;

Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).

Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter “R” added (e.g. MW-11R).

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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 52 of 61

Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill - Groundwater Discharge Permit Date: 5-25-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 53 of 61

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/Sampling

Chloroform Investigation samples are collected by means of disposable bailer(s) the
day following the purging .The disposable bailer is used only for the collection of a
sample from an individual well and disposed subsequent to the sampling. The wells
are purged prior to sampling by means of a portable pump. Each quarterly purging
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. Although purging will generally follows this order, the sampling order may
deviate slightly from the generated list. This practice does not affect the samples for
these reasons: any wells sampled in slightly different order have either dedicated
pumps or are sampled via a disposable bailer. This practice does not affect the
quality or usability of the data as there will be no cross-contamination resulting from
sampling order. Decontamination of all sampling equipment will follow the
decontamination procedure outlined in Attachment 2-2 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. UGW-20-01. Chloroform wells shall be purged
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
 TW4-13
 TW4-14
 MW-26
 TW4-16
 MW-32
 TW4-18
 TW4-19
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Quality Assurance Plan (QAP) Page 54 of 61

 TW4-7
 TW4-8
 TW4-9
 TW4-10
 TW4-11
 TW4-12
 TW4-26

 TW4-20
 TW4-21
 TW4-22
 TW4-23
 TW4-24
 TW4-25
 TW4-27

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 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 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements

Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

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Quality Assurance Plan (QAP) Page 55 of 61

Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

5) Field Parameters

Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. This includes the following wells: MW-4, MW-26,
TW4-4, 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
Attachment 2-3 of the QAP before sample collection.

Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.

6) Chloroform Investigation Reports

The Chloroform Investigation Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
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Quality Assurance Plan (QAP) Page 56 of 61

 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
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 Chloroform Investigation
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
QAP.

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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 57 of 61

Appendix B
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill - Groundwater Discharge Permit Date: 5-25-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 58 of 61

Nitrate Corrective Action 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 Nitrate Corrective Action Monitoring (“Nitrate Program”) conducted pursuant to State of
Utah Stipulated Consent Agreement Docket Number UGW-09-03-A.

Specifically, the Mill will use the same sampling regimen for the Nitrate program 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) Purge Pump/Sampling

The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.

Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.

2) Nitrate Program Sampling Frequency, Order and Locations

The Nitrate Program wells listed below are required to be monitored on a quarterly
basis under State of Utah Docket No. UGW-09-03-A. DUSA has submitted a
Corrective Action Plan (“CAP”) as required by the Stipulated Consent Agreement.
In that CAP, DUSA has proposed the abandonment of a number of the wells listed
below. The implementation of the CAP, shall supersede any requirements contained
in this QAP and Appendix. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.

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Quality Assurance Plan (QAP) Page 59 of 61

 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**
 Piezometer-01
 Piezometer-02
 Piezometer-03

*Recommended for abandonment
**Recommended for depth to water measurements only. DUSA has proposed
that monitoring cease.

7) Nitrate Program Sample Containers and Collection Volume

The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:

 For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements

Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 60 of 61

Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

9) Field Parameters

Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.

10) Nitrate Program Investigation Reports

The Nitrate Program Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
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, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
 Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 61 of 61

mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate
mass removed from each pumping well for the quarter.

d) Conclusions and Recommendations

e) Electronic copy of all laboratory results for Nitrate Program 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
QAP.

May 25,2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Executive Secretary
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: 303 628·7798
Fax: 303389·4125
www.denisonmines.com
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Response to Division of Radiation Control ("DRC") letter dated April 16, 2012
Transmittal of Revised Groundwater Quality Assurance Plan ("QAP"), dated May 25,2012
Dear Mr. Lundberg:
Reference is made to the Division of Radiation Control ("DRC") letter dated April 16, 2012, regarding
the White Mesa Mill Draft Groundwater Quality Assurance Plan ("QAP"), dated May 25, 2012 (Revision
7).
This letter transmits Denison Mines (USA) Corp's ("Denison's") proposed revisions to the White Mesa
Mill QAP as well as proposed language for the current Groundwater Discharge Permit ("GWDP") as
requested in the comments below. These revisions include changes made to:
1 . Respond to the DRC Letter dated April 16, 2012, and
2. Correct additional typographical errors in the March 2012 Revision of the QAP.
For ease of review we have provided both redline and clean versions of the document.
The attached QAP Revision 7.1 has accepted all the redline changes proposed in Denison's March 26,
2012 submittal (Revision 7) as the base version in black type. Changes resulting from the above-
referenced DRC comment letter are provided in redline/strikeout format.
We have also provided, below, specific responses to each request in DRC's April 16, 2012 letter. The
sections and numbering of the remainder of this letter follow the DRC April 16, 2012 letter. Each DRC
request is shown in italics, below, followed by Denison's response.
Summary of DRC/DUSA April 5, 2010 Conference Call Regarding Out-of Compliance (OOC)
Reporting and Monitoring
ORCComment
OUSA states in the March 26, 2012 response that based on an agreement made between ORC and
OUSA during a telephone conference call on April 5, 2010, OUSA is not required to implement
Letter to Mr. Rusty Lundberg
May 25,2012
Page 2
accelerated monitoring until "the month following the submission of the Exceedence Notice for a specified
quarter." Based on DRC review of notes taken during the AprilS, 2010 telephone conference (Loren
Morton 415110,0900), DUSA verbally requested to wait until the end of the quarter to send in the notice of
out-of compliance status -but within 30 days of the last lab report that DUSA receives.
The Groundwater Permit, Part 1.G.1.b. requires accelerated monitoring to begin immediately following the
date of receipt of the data showing the GWCL exceedence. This was the basis of the DRC February 7,
2012 NOED which noted that accelerated monitoring should have started during April, 2011. Also, the
Groundwater Permit Part 1.G.4.c. requires the submission of a plan and time schedule for assessment of
the sources of the GWCL exceedences within 30 days of detection of the out of compliance status 'but
does not state that the 30 day clock begins upon receipt of the last analytical report for the sample batch.
Therefore, DRC notes that the procedures discussed during the AprilS, 2010 telephone discussion do not
agree with the current permit requirements.
In order to formalize the April 5, 2010 discussion items related to out-of-compliance reporting and
sampling, please provide a written request for a groundwater permit modification (groundwater permit,
out-of-compliance notification and accelerated monitoring requirements) for Executive Secretary review
and approval. Note that the DRC will review accelerated monitoring actions by DUSA according to the
currently approved groundwater permit as of the date of DUSA receipt of this letter.
Also, DRC notes that there is currently no specified maximum time limit for the contract laboratory to
deliver the analytical report to DUSA. Per review of the 4th Quarter 2011 White Mesa Ground Water
Monitoring Report, dated February 28, 2012, DRC noted that per Table 1, most of the samples were
collected in early October (October 3, 4, 5, 6, 11, 12 of 2011) but the laboratory analytical package was
not received by DUSA until late December (December 22 and 27,2011). This is a turnaround time of
approximately 11 weeks which seems unreasonably long.
In order to insure timely data submission, review and acceleration of monitoring frequencies for OOC
parameters, please include a maximum time period for analytical report receipt from the laboratory of 30
days from sample receipt by the contract laboratory.
Denison Response:
Denison appreciates the opportunity to propose changes to the GWDP to formalize the agreements made
in the April 5, 2010 teleconference between DRC and Denison. Denison has prepared a request for a
modification of the GWDP, under separate cover (dated May 25, 2012), which provides proposed
revisions to Parts 1.G.1 through 1.G.4 of the GWDP in redline strikeout format.
Denison agrees that the data turn-around time ("TAT") noted by DRC for the 4th Quarter 2011 data was
unusually long. As discussed in the 4th Quarter 2011 Groundwater Report submitted February 28, 2011,
during a review of laboratory certifications conducted in late 2011, Denison noted that Energy
Laboratories ("EL's") Utah Department of Health, Bureau of Laboratory Improvement, Environmental
Laboratory Certification ("Utah Certification") for tin expired on June 30, 2011. This loss of certification
necessitated the reanalysis of all of the third and fourth quarter samples for tin by American West
Analytical Laboratories ("AWAL"). The reanalysiS of the samples for tin extended the data TAT times.
Additionally, EL reported issues with the ammonia analyses, which prompted resampling in multiple wells
which was conducted in late November 2011. The resampling for ammonia also delayed the submission
of the data.
In response to the data TAT and tin certification issues Denison has contacted EL and held discussions
regarding measures that EL should undertake to improve their performance. Denison is closely
monitoring EL performance and is taking measures to identify other laboratories capable of performing
analytical work in conformance with the Groundwater QAP, Revision 7.1. The QAP Revision 7.1 will
expand the analytical methods allowable for use at the Mill Site and will allow Denison to explore other
OENISOJ)~~
MINES
Letter to Mr. Rusty Lundberg
May 25,2012
Page 3
laboratory opportunities should the need arise, due to lack of performance or loss of certification by any
contracted laboratory.
It is important to note that despite Denison's efforts, any contracted laboratory may deliver data beyond
the contractually specified time limits, despite any associated contractual penalties that may apply.
Because Denison does not self-perform the analytical work, Denison cannot completely control the data
reporting timeframes or force delivery of data within a specified timeframe. Denison can and does
enforce contractual requirements as practicable; however, a laboratory's performance is sometimes
beyond Denison's control.
It is Denison's understanding that DRe has made this request for an improved data TAT to assure timely
implementation for accelerated monitoring frequencies for ooe parameters. Denison has met the GWDP
requirement to sample quarterly, and the GWDP does not require or specify a timeframe within the
quarter for sampling. Denison generally strives to collect the quarterly samples with sufficient time
remaining in the quarter to resample if necessary to address any shipping, sample, analytical or quality
issues which arise. Denison should not be penalized for laboratory performance if the laboratory does
not provide results within a specified time period for samples collected early in the quarter, provided
Denison meets the quarterly sampling and reporting requirements in the GWDP. In light of DRe's
concern, and as discussed with DRe on May 14, 2012 Denison will agree to provide the Exceedance
Notice 30 days from the receipt of the last data package for the latest samples collected in a quarter
(either quarterly or monthly accelerated) but no later than 60 days after the end of the quarter. The Plan
and Time Schedule for addressing ooe parameters will be submitted within 30 days after the
Exceedance Notice. The proposed changes to the GWDP under separate cover (dated May 25, 2012)
reflect these agreements.
As a result of the foregoing and per Denison's discussions with DRe by telephone on May 14, 2012, no
timeframe for data delivery and TAT has been added to the QAP.
DRCComment
Approval to Return Monitoring Well MW-11 to Baseline Monitoring for Tetrahydrofuran (THF)
DRC acknowledges the DUSA response to the January 25,2011 DRC RFI regarding confirmation as to
whether THF is stored at and/or used in the White Mesa Mill operations with the March 26, 2012 letter.
Per the response DUSA states "Denison has never purchased, stored or used THF as a reagent, solvent
or additive to the Mill's processes. "
Based on the recent monitoring data for THF and well MW -11 (21 consecutive sampling results for THF
below the GWCL of 11.5 (ug/L), the Executive Secretary approves the March 26,2012 DUSA request to
return monitoring well MW-11 to baseline quarterly ground water monitoring for THF.
Denison Response:
Denison appreciates DRe's consideration in this matter and will return monitoring well MW-11 to baseline
quarterly ground water monitoring for THF beginning in June 2012.
DRCComment
Request for Information, DUSA White Mesa Mill QAP Revision 7:
Based on DRC review of the redline revised QAP, Revision 7, DRC has the following comments.
Table of Contents -Add QAP Attachments and Appendices to the table of contents
OENISOJ)~~
MINES
Letter to Mr. Rusty Lundberg
May 25,2012
Page 4
Denison Response:
The Attachments and Appendices have been added to the Table of Contents as requested.
General Inclusion -ORe notes that there is no requirement for a maximum time period for the laboratory
to deliver an analytic report to OUSA in the current OAP. In order to insure timely data submission, review
and potential acceleration of monitoring frequencies, please include a maximum time period for analytical
report receipt from the laboratory of 30 days from sample submission.
Denison Response:
See response to DRC's first comment, above.
Section 4.3.2. Attachment 2-5 Equipment Rinsate Samples -ORe notes that the OAP specifies a rinsate
sample to be taken at the beginning of the day and after decontamination. This implies that a rinsate
sample will be collected after each sampling location. The ORe believes it would be appropriate to collect
equipment rinsate samples for one per every 20 samples collected.
Denison Response:
The frequency of rinsate samples has been changed as requested.
Section 7.3 Record Keepinq -Add a requirement that copies of the current contract laboratory
certifications and Utah Bureau of Laboratory Improvement approved parameters and methods will be kept
at the White Mesa Mill.
Denison Response:
Section 7.3 has been modified as requested.
Please contact me if you have any questions or require any further information.
Yours very truly,
J Tis ler
D rector, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Kathy A. Weinel
Attachments
OENISOJ)~~
MINES
Letter to Mr. Rusty Lundberg
May 25,2012
Page 5
ATTACHMENT A
Revision 7.1 of the Groundwater Quality Assurance Plan
OENISOJ)~~
MINES
REDLINE 

CLEAN 
Mill - Groundwater Discharge Permit Date: 53-265-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 1 of 60

WHITE MESA URANIUM MILL GROUNDWATER MONITORING QUALITY ASSURANCE PLAN (QAP) State of Utah Groundwater Discharge permit No. UGW370004 Denison Mines (USA) Corp. P.O. Box 809 Blanding, UT 84511
Mill - Groundwater Discharge Permit Date: 53-265-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 2 of 60
TABLE OF CONTENTS
1.0 INTRODUCTION 65
2.0 ORGANIZATION AND RESPONSIBILITIES 65
2.1 Functional Groups 65
2.2 Overall Responsibility For the QA/QC Program 65
2.3 Data Requestors/Users 65
2.4 Data Generators 76
2.4.1 Sampling and QC Monitors 76
2.4.2 Analysis Monitor 76
2.4.3 Data Reviewers/Approvers 87
2.5 Responsibilities Of Analytical Laboratory 87
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 98
3.1 Precision 98
3.2 Accuracy 98
3.3 Representativeness 109
3.4 Completeness 109
3.5 Comparability 109
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 109
4.1 Controlling Well Contamination 109
4.2 Controlling Depth to Groundwater Measurements 1110
4.3 Water Quality QC Samples 1110
4.3.1 VOC Trip Blanks 1110
4.3.2 Equipment Rinsate Samples 1110
4.3.3 Field Duplicates 1110
4.3.4 Definition of “Batch” 1110
5.0 CALIBRATION 1210
5.1 Depth to Groundwater Measurements 1211
5.2 Water Quality 1211
Formatted: Font: Times New Roman
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Groundwater Monitoring
Quality Assurance Plan (QAP) Page 3 of 60

6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 1211
6.1 Groundwater Head Monitoring 1211
6.1.1 Location and Frequency of Groundwater Head Monitoring 1211
6.1.2 Groundwater Head Monitoring Frequency 1311
6.2 Ground Water Compliance Monitoring 1312
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 1312
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the GWDP 1412
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP 1413
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 1413
6.2.5 Decontamination Procedure 1413
6.2.6 Pre-Purging/ Sampling Activities 1413
6.2.7 Well Purging/Measurement of Field Parameters 1513
6.2.8 Samples to be taken and order of taking samples 1514
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 1615
7.1 Field Data Worksheets 1615
7.2 Chain-Of-Custody and Analytical Request Record 1716
7.3 Record Keeping 1716
8.0 ANALYTICAL PROCEDURES AND QA/QC 1817
8.1 Analytical Quality Control 1817
8.1.2 Spikes, Blanks and Duplicates 1817
8.2 Analytical Laboratory Procedures 1918
9.0 INTERNAL QUALITY CONTROL CHECKS 2221
9.1 Field QC Check Procedures 2322
9.1.1 Review of Compliance With the Procedures Contained in this QAP 2322
9.1.2 Analyte Completeness Review 2322
9.1.3 Blank Comparisons 2322
9.1.4 Duplicate Sample Comparisons 2423
9.2 Analytical Laboratory QA Reviews 2524
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 2524
9.4 Analytical Data 2625
10.0 CORRECTIVE ACTION 2726
10.1 When Corrective Action is Required 2726
10.2 Procedure for Corrective Action 2726
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11.0 REPORTING 2827
12.0 SYSTEM AND PERFORMANCE AUDITS 2928
12.1 QA Manager to Perform System Audits and Performance Audits 2928
12.2 System Audits 2928
12.3 Performance Audits 2928
12.4 Follow-Up Actions 3029
12.5 Audit Records 3029
13.0 PREVENTIVE MAINTENANCE 3029
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 3029
14.1 Ongoing QA/QC Reporting 3130
14.2 Periodic Reporting to Management 3130
15.0 AMENDMENT 3130
16.0 REFERENCES 3231
ATTACHMENTS
Attachment 1 Field and Data Forms

Attachment 1-1 Quarterly Depth to Water Data Sheet Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater Attachment 1-3 Example COC Forms
Attachment 2 Field Procedures

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Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures Attachment 2-2 Decontamination Procedures Attachment 2-3 Purging Procedures Attachment 2-4 Sample Collection Procedures Attachment 2-5 Field QC Samples APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah
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1.0 INTRODUCTION

This Groundwater Monitoring Quality Assurance Plan (the “QAP”) 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).

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 QAP 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.
2.0 ORGANIZATION AND RESPONSIBILITIES

2.1 Functional Groups

This QAP 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. The QA Manager is designated by
Denison Mines (USA) Corp. (“DUSA”) corporate management.

2.3 Data Requestors/Users

The generation of data that meets the objectives of this QAP 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
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 QAP.

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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
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 QAP. 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 this
QAP;

b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the
samples, to the Analytical Laboratory in accordance with this QAP;

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 computerized database,
where appropriate.

2.4.2 Analysis Monitor

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

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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 QAP, by the Analytical Laboratory’s QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program (“NELAP”) 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 QAP;

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 QAP, to
minimize contamination; and

d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP 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.

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 certification.

In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U. S. EPA Guideline SW-846 and, to the extent
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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 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.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA

The objective of this QAP 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 27 - 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 a known 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:

% Recovery = (│A-B│/C) x 100
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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 QAP.

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, measurement procedures, methods, and reporting units are consistent
for all samples within a sample set.

4.0 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.

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4.2 Controlling Depth to Groundwater Measurements

Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.

4.3 Water Quality QC Samples

Quality assurance for groundwater 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.

4.3.2 Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at the beginning of each day of the sampling event prior to use and after
decontamination. a frequency of one rinsate sample per 20 field samples. Rinsate blanks will
be collected after decontamination and prior to subsequent use. Rinsate blank samples for a
non-dedicated pump are prepared by pumping de-ionized water into the sample containers.
Rinsate blank samples for a non-disposable or non-dedicated bailerare prepared by pouring
de-ionized water over and through the bailer and into the sample containers. Equipment
rinsate blanks will be analyzed only for the contaminants required during the monitoring
event in which they are collected.

Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.

4.3.3 Field Duplicates

Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicateswill be submitted to the Analytical Laboratory and analyzed for the same
consitiuents as the parent sample..

Field duplicate sampling procedures are described in Attachment 2-5.

4.3.4 Definition of “Batch”

For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
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5.0 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 use as
noted in Attachment 2 to ensure that the Water Sounding Device is functional.

5.2 Water Quality

The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer’s specifications (for
example, by using two known pH solutions and one specific conductance standard.)
Temperature will be checked comparatively by using a thermometer. Calibration results will
be recorded on the Field Data Worksheet.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS

6.1 Groundwater Head Monitoring

Groundwater head measurements (“depth to water”) will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.

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 the GWDP Parts I.E.1 (b) and (c) and
I.E.2;

b) Monitoring well MW-34;

c) All piezometers (P-1, P-2, P-3, P-4, P-5 and the Dry Ridge piezometers);

d) All contaminant investigation wells required by the Executive Secretary as part of
a contaminant investigation or groundwater corrective action (chloroform and nitrate
wells).

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6.1.2 Groundwater Head Monitoring Frequency

Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an
electronic data management system (spreadsheet or database). The data from the quarterly
depth to water measurements will be included in the quarterly groundwater report.

The depth to groundwater measured immediately prior to purging/sampling will be recorded
on data sheet for each well. An example of a Field Data Work Sheet for Groundwater is
included in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.

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) Semi-annually in the following General Monitoring Wells: MW-20 and MW-22;

c) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-25,
MW-26, MW-30, MW-31, MW-35, MW-36 and MW-37; and

d) Quarterly in the Chloroform Investigation and Nitrate Corrective Action wells.

In addition, quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in Parts I.G.1 or I.G.2 of the GWDP. Sampling
personnel should coordinate with the QA Manager prior to conducting any monitoring well
sampling to determine if any parameters in any wells are subject to accelerated monitoring.

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6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the
GWDP

All quarterly and semi-annual samples collected under Parts I.E.1.b) or I.E.1.c) of the GWDP
shall be analyzed for the following parameters:

a) Field parameters – depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; 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 accelerated sampling required under paragraphs I.G.1. or I.G.2. of
the GWDP shall be analyzed for the specific parameters as required by previous sampling
results as determined by the QA Manager.

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.

Purging and sampling equipment is described in Attachment 2-3 of this QAP.

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;

6.2.5 Decontamination Procedure

Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.

6.2.6 Pre-Purging/ Sampling Activities

Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well’s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.

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6.2.7 Well Purging/Measurement of Field Parameters

The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging wells prior to sampling removes the stagnant water column present in the well casing
and assures that representative samples of the formation water are collected. Purging will be
completed as described in Attachment 2-3.

There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery

6.2.8 Samples to be taken and order of taking samples

For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP . The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single
container due to like sampling requirements (filtering) and/or like preservation. The
container requirements will be determined by the Analytical Laboratory and specified with
the bottles supplied to the Field Personnel. Bottle requirements may change if the Analytical
Laboratory is changed or if advances in analytical techniques allow for reduced samples
volumes. The following list is a general guideline.

a) VOCs, 3 sample containers, 40 ml each;

b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml;

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

d) Gross alpha and heavy metals, 1 sample container, 1,000 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.

Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
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7.0 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 initials(s)
 date(s) and time(s) of well purging and sample collection
 type of well purging equipment used (pump or bailer)
 previous well sampled during the sampling event
 well depth
 depth to groundwater before purging and sampling
 field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
 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.

The Field Data Worksheets will also contain detailed notes describing any other significant
factors noted 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 features or conditions. An example of a Field
Data Worksheet that incorporates this information is attached in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
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not eliminate any data collection activity without written approval of the Executive
Secretary.

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 location
 number of sample containers in the shipping container
 analyses requested
 signatures of persons involved in the chain of possession
 internal temperatures of the shipping container when opened at the laboratory
 remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.

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

Data 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 and a
list of Utah Bureau of Laboratory Improvement approved parameters and methods used to
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perform analysis during the monitoring events conducted during the quarter will be
maintained at the Mill. 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.

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 data packages are managed using electronic
data management software The data management software will be managed and
administered by the QA Manager or designee. The Mill Personnel will have read-only
access to the electronic data management software.

8.0 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, 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 analytical Batch of samples:

a) Matrix Spike/Matrix Spike Duplicate

A spiked field sample analyzed in duplicate may be analyzed with every analytical batch
(depending on the analytical method requirements and or method limitations). Analytes
stipulated by the analytical method, by applicable regulations, or by other specific
requirements may be spiked into the samples. Selection of the sample to be spiked depends
on the information required and the variety of conditions within a typical matrix. The matrix
spike sample serves as a check evaluating the effect of the sample matrix on the accuracy of
analysis. The matrix spike duplicate serves as a check of the analytical precision.

b) Method Blanks

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Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.

c) Surrogate Compounds

Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) 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 as specified
in Table 1, or as otherwise authorized by the Executive Secretary. With respect to
Chloroform Investigation and Nitrate Corrective Action sampling, the analytical
procedures for parameters monitored under those programs are specified in
Appendix A and B respectively.

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Table 1

Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Nutrients
Ammonia (as N) A4500-
NH3 G or
E350.1
0.05 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC

Heavy Metals
Arsenic E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Beryllium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Cadmium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Chromium E200.7 or
E200.8
25 µg/L 6 months HNO3 to pH<2 None
Cobalt E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Copper E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Iron E200.7 or
E200.7
30 µg/L 6 months HNO3 to pH<2 None
Lead E200.7 or
E200.8
1.0 µg/L 6 months HNO3 to pH<2 None
Manganese E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Mercury E 245.1 or
E200.7 or
E200.8
0.50 µg/L 28 days HNO3 to pH<2 None
Molybdenum E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Nickel E200.7 or
E200.8
20 µg/L 6 months HNO3 to pH<2 None
Selenium E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Silver E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Thallium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Tin E200.7 or
E200.8
100 µg/L 6 months HNO3 to pH<2 None
Uranium E200.7 or
E200.8
0.30 µg/L 6 months HNO3 to pH<2 None
Vanadium E200.7 or
E200.8
15 µg/L 6 months HNO3 to pH<2 None
Zinc E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None

Radiologics
Gross Alpha E 900.0 or
E900.1
1.0 pCi/L 6 months HNO3 to pH<2 None

Volatile
Organic
Compounds

Acetone SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Benzene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
2-Butanone
(MEK)
SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Naphthalene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Tetrahydrofuran SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
or
SW8260C
Toluene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Xylenes (total) SW8260B
or
SW8260C
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
or E300.0
0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None ≤ 6oC

General
Inorganics

Chloride A4500-Cl
B or
A4500-Cl
E
or E300.0
1 mg/L 28 days None None
Sulfate A4500-
SO4 E or
E300.0
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 to pH<2 None
Potassium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Magnesium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Calcium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
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.

9.0 INTERNAL QUALITY CONTROL CHECKS

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Internal quality control checks are inherent in this QAP. 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 QAP. 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 QAP. 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 QAP

Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.

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, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).

Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will

1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

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If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.

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 concentrations
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 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 = the uncertainty of the first measurement squared
sb2 = 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).

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Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

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 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,
(3) reporting limits for all analytes, and
(4) 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

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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); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.

b) Laboratory Methods Review

The QA Manager shall confirm that the analytical methods used by the Analytical
Laboratory are those specified in Table 1, 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.

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.

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If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will
be consulted to establish more appropriate analytical approaches for problem samples.
10.0 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 QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. 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 a procedural or systematic non-conformance is identified, DUSA shall:

a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to
be systematic or procedural, 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
groundwater 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 QAP. The results for this sample(s) should be included in
the same quarterly monitoring report with other samples collected for the same
sampling event; and
c) For any other material deviation from this QAP, 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 QAP, 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;

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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.
11.0 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 and Nitrate Corrective Action 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 QAP
 A summary data table of 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 (included in the data packages)
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 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 QAP and all corrective actions taken.
 Recommendations and Conclusions.

With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B 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.
12.0 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 QAP 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

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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 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.
13.0 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 certifications. Preventive maintenance will be performed on a
scheduled basis to minimize downtime and the potential interruption of analytical work.

14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT

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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 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.

15.0 AMENDMENT

This QAP may be amended from time to time by DUSA only with the approval of the
Executive Secretary.

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16.0 REFERENCES

United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.

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.

United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.

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.
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ATTACHMENT 1
Field and Data Forms
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Attachment 1-1
Quarterly Depth to Water Data Sheet

NAME:   
DATE: 
TIME WELL Static level TIME WELL Static Level TIME WELL Static Level

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ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER

(Insert the Field Data Worksheet Here)
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ATTACHMENT 1-3
EXAMPLE CHAIN OF CUSTODY
FORMS

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Sheet 1 of 1

CHAIN OF CUSTODY

Samples
Shipped to:
Contact
:

Chain of Custody/Sampling Analysis Request

Project Samplers Name Samplers Signature

Sample ID
Date Collecte
d
Time
Collected Laboratory Analysis Requested

Please notify Tanner Holliday of Receipt temperature on these samples Immediately!
Thank you.

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

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ATTACHMENT 2
Field Procedures
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Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures

Measure and record all depth to water data to the nearest 0.01 feet.

Equipment Used For Groundwater Head Monitoring

Measurement of depth to groundwater is accomplished by using a Solinist – IT 300 or
equivalent device (the “Water Level Indicator”).

Equipment Checks

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

Check the Water Sounding Device as follows:
 Turn the Water Level Indicator on.
 Test the Water Level Indicator using the test button located on the instrument.
 If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.

Measurement of Depth to Water

All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:

 For monitoring wells - Measure depth to water from the top of the inner well casing
at the designated measurement point.
 For the piezometers - Measure depth to water from the top of the casing at the
designated measurement point.
 Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
 Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.

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Attachment 2-2
Decontamination Procedures

Non-dedicated sampling equipment will be decontaminated using the following
procedures:

Water level meter

Decontaminate the water level meter with a detergent/deionized (“DI”) water mixture
by pouring the solutions over the water level indicator.

Rinse the water level indicator with fresh DI water rinse by pouring the DI water over
the water level indicator.

Field Parameter Instrument (Hydrolab or equivalent)

Rinse the field parameter instrument probe unit with DI water prior to each
calibration.

Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.

Non-Dedicated Purging/Sampling Pump

Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:

a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;

b) pump the detergent/DI water solution through the pump and pump outlet lines
into the drain line connected to Cell 1;

c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

d) submerge the pump into a 55-gallon drum of DI water;

e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;

f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

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g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;

h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).

All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.

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Attachment 2-3
Purging Procedures

The following equipment will be used for groundwater purging and sampling:

 Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
 Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
 Non – Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
 Field Parameter Meter: A meter used to measure ground water quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:

 Water temperature;
 Specific conductivity;
 Turbidity;
 pH;
 Redox potential (Eh).

 Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
 Diesel Generator: Mobile power supply to provide power for submersible pump.
 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
“bladder” pumps.

Additional supplies for purging and sampling are as follows:

 Field Data Sheets
 45 micron in-line filters (when metals and gross alpha analyses are required)
 Calculator
 Clock, stopwatch or other timing device
 Buckets
 Sampling containers(as provided by the Analytical Laboratory)
 Field preservation chemicals (as provided by the Analytical Laboratory)
 Disposable gloves
 Appropriate health and safety equipment
 Sample labels and COCs (as provided by the Analytical Laboratory)

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Pre-Purging/ Sampling Activities

If a portable (non-dedicated) pump is to be used, prior to commencing the event’s sampling
activities,

1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) into a cooler that will transport
the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC) samples
throughout the monitoring event.

Well Purging

The purging techniques described below will be used for all groundwater sampling
conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery

The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.

Turbidity measurement in the water should be < 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.

A flow-cell needs to be used for field parameters.

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Procedure

a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)

b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;

c) 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;

If a portable (non-dedicated) pump is used:

 Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
 Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.

If a non-dedicated pump or dedicated pump is used:

(i) Commence pumping;

(ii) Determine pump flow rate by using a stopwatch or other timing device 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) Calculate the amount of time to evacuate two or three casing volumes;

(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);

(v) If two casing volumes will be purged:

Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded on the Field
Data Worksheet. Purging is completed after two casing volumes have been
removed and the field parameters pH, temperature, specific conductance,
redox potential (Eh) and turbidity have stabilized to within 10% RPD over at
least two consecutive measurements.

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(vi) If three casing volumes will be purged:

Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements on the Field Data Worksheet.

(vii) If the well is purged to dryness:

Record the number of gallons purged on the Field Data Worksheet.

The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.

Upon arrival at the well after recovery or when sufficient water is available
for sampling measure depth to water and record on the Field Data Worksheet.

Take one set of measurements of field parameters for pH, specific
conductance and redox potential only.

Collect the samples into the appropriate sample containers.

Take an additional set of measurements of field parameters for pH, specific
conductance and redox potential after the samples have been collected.

If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.

If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.

Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.

Purging using a disposable bailer

For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.

When a bailer is used, the following procedure will be followed:
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(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.

(ii) Attach a disposable bailer to a rope and reel.

(iii) Lower the bailer into the well and listen for contact with the solution.
Once contact is made, allow the bailer to gradually sink in the well, being
careful not to allow the bailer to come in contact with the bottom sediment.

(iv) After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.

(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.

(vi) Take field measurements from the water in the buckets.

All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.

After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
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Attachment 2-4
Sample Collection Procedures
Sample Collection Order

Regardless of the purging method employed samples will be collected in the order specified
below.

All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.

VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologics (fluoride, general inorganics, TDS, total cations and anions); and
Gross alpha and heavy metals (filtered).

Sample Filtering

When sampling for heavy metals 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:

(i) Place a new 0.45 micron filter on the sample tubing;

(ii) Pump the sample through the filter, and into the sample container containing
the preservative;

(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;

d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:

(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.

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(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.

(iii) Place clean unused tubing in the peristaltic pump.

(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.

Procedures to Follow After Sampling

a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:

 Sample location
 Date and time of sample
 Any preservation method utilized
 Filtered or unfiltered

b) Immediately after sample collection, place each sample in an ice-packed cooler;
and

c) Before leaving the sampling location, thoroughly document the sampling event on
the Field Data Worksheet, by recording all pertinent data.

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 overnight delivery services to the Analytical Laboratory.
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Attachment 2-5
Field QC Samples
Field Duplicates

Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.

Field duplicate samples should be as near to split samples as reasonably practicable.

Collection of field duplicates is completed as follows:

Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.

Field duplicate samples are labeled using a “false” well number such as MW-65 and MW-70.

Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at the beginning of each day of the sampling event prior to use and after
decontaminationa frequency of one rinsate sample per 20 field samples.

Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:

Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;

Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).

Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter “R” added (e.g. MW-11R).

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Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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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/Sampling

Chloroform Investigation samples are collected by means of disposable bailer(s) the
day following the purging .The disposable bailer is used only for the collection of a
sample from an individual well and disposed subsequent to the sampling. The wells
are purged prior to sampling by means of a portable pump. Each quarterly purging
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. Although purging will generally follows this order, the sampling order may
deviate slightly from the generated list. This practice does not affect the samples for
these reasons: any wells sampled in slightly different order have either dedicated
pumps or are sampled via a disposable bailer. This practice does not affect the
quality or usability of the data as there will be no cross-contamination resulting from
sampling order. Decontamination of all sampling equipment will follow the
decontamination procedure outlined in Attachment 2-2 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. UGW-20-01. Chloroform wells shall be purged
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
 TW4-13
 TW4-14
 MW-26
 TW4-16
 MW-32
 TW4-18
 TW4-19
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 TW4-7
 TW4-8
 TW4-9
 TW4-10
 TW4-11
 TW4-12
 TW4-26

 TW4-20
 TW4-21
 TW4-22
 TW4-23
 TW4-24
 TW4-25
 TW4-27

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 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 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements

Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

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Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

5) Field Parameters

Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. This includes the following wells: MW-4, MW-26,
TW4-4, 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
Attachment 2-3 of the QAP before sample collection.

Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.

6) Chloroform Investigation Reports

The Chloroform Investigation Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
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 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
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 Chloroform Investigation
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
QAP.

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Appendix B
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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Nitrate Corrective Action 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 Nitrate Corrective Action Monitoring (“Nitrate Program”) conducted pursuant to State of
Utah Stipulated Consent Agreement Docket Number UGW-09-03-A.

Specifically, the Mill will use the same sampling regimen for the Nitrate program 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) Purge Pump/Sampling

The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.

Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.

2) Nitrate Program Sampling Frequency, Order and Locations

The Nitrate Program wells listed below are required to be monitored on a quarterly
basis under State of Utah Docket No. UGW-09-03-A. DUSA has submitted a
Corrective Action Plan (“CAP”) as required by the Stipulated Consent Agreement.
In that CAP, DUSA has proposed the abandonment of a number of the wells listed
below. The implementation of the CAP, shall supersede any requirements contained
in this QAP and Appendix. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.

 TWN-1
 TWN-2
 TWN-13*
 TWN-14**
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 TWN-3
 TWN-4
 TWN-5*
 TWN-6**
 TWN-7
 TWN-8*
 TWN-9*
 TWN-10*
 TWN-11*
 TWN-12*

 TWN-15*
 TWN-16**
 TWN-17*
 TWN-18
 TWN-19**
 Piezometer-01
 Piezometer-02
 Piezometer-03

*Recommended for abandonment
**Recommended for depth to water measurements only. DUSA has proposed
that monitoring cease.

7) Nitrate Program Sample Containers and Collection Volume

The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:

 For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements

Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

Mill - Groundwater Discharge Permit Date: 53-265-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 59 of 60

Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

9) Field Parameters

Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.

10) Nitrate Program Investigation Reports

The Nitrate Program Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
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, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
 Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
Mill - Groundwater Discharge Permit Date: 53-265-12 Revision 7.1
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 60 of 60

mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate
mass removed from each pumping well for the quarter.

d) Conclusions and Recommendations

e) Electronic copy of all laboratory results for Nitrate Program 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
QAP.