DRC-2012-001694 - 0901a068802f7aab

DENISO
MINES
DRC-2012-001694
July 11,2012
VIA PDF and FEDERAL EXPRESS
Mr Rusty Lundberg
Director
Division of Radiation Control
Utah Department ofEnvironmental Quality
195 North 1950 West
Salt Lake City, UT 84116-3097
Denison Mines (USA) Corp
1050 17th street, Suite 950
Denver, CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
Re: Stipulated Consent Agreement, Docket No. UGW12-03
Dear Mr Lundberg
Enclosed are two signed and undated copies of the Revised Stipulated Consent Agreement Per
the DRC e-mail dated, July 11, 2012, the attachments will be retumed with the fully executed
copy Please retum one fully executed copy to me for our records
Yours Very
Ddcj/itSl C 'FVydenlund
Vice President, Regulatory Affairs and Counsel
Enclosure
cc Harold R Roberts
Jo Aim Tischler
David Turk
Kathy Weinel
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
IN THE MATTER OF
DENISON MINES (USA) CORP.
1050 17*" Street, SUITE 950
DENVER, COLORADO 80265
STIPULATED CONSENT AGREEMENT
DOCKET No. UGW12-03
A. STATUTORY AUTHORITY
This STIPULATION AND CONSENT AGREEMENT (AGREEMENT) is between Denison
Mines (USA) Corp (DUSA) and the Director of the Utah Division of Radiation Control'
(DIRECTOR) under the Utah Water Quality Act, Utah Code Ann (UCA) §§ 19-5-101 to 19-5-
124 (the ACT), including sections 19-5-104, -106, -111 and -115 This AGREEMENT is also
executed in accordance with the Utah Administrative Procedures Act, Utah Code Ann §§ 6304-
101 to -601 and Administrative Procedure Rules, Utah Admin Code R305-6
Under the Water Quality Act, Utah Code Ann Title 19, Chapter 5, "Director" for purposes of
groundwater quality at a facility hcensed by and under the jurisdiction of the Division of
Radiation Control, means the Director of the Division of Radiation Control Utah Code Ann §
19-5-102(6)
The DIRECTOR may enforce rules made by the Water Quality Board in accordance with Utah
Code Ann § 19-5-106(2)(d)
B. APPLICABLE STATUTORY AND REGULATORY PROVISIONS
1 Utah Code Ann §19-5-107( 1 )(a) requires that
"Except as provided in this chapter or rules made under it, it is unlawful for any person to
discharge a pollutant into waters of the state or to cause pollution which constitutes a
menace to public health and welfare, or is harmful to wildlife, fish or aquatic life, or
impairs domestic, agricultural, industrial, recreational, or other beneficial uses of water,
or to place or cause to be placed any wastes in a location where there is probable cause to
believe it will cause pollution "
2 DUSA was issued Utah Ground Water Quality Discharge Permit No UGW370004
(Permit) on March 8, 2005 Said Pennit was modified by the DIRECTOR on March 17,
2008, January 20, 2010, June 17, 2010, February 15, 2011 and was last modified on July
14,2011
3 The DIRECTOR issued DUSA a May 9, 2011 Notice of Violation and Compliance
Order, Docket No UGWl 1-02 (NOV) for multiple violations of the Permit, including
violations of UCA § 19-5-107 and Part I G 1 of the Permit for exceeding Permit Ground
Water Concentration Limits (GWCL's) m Table 2 of the Permit for two consecutive
sampling events (out-of-compliance status), and Part I G 4(c) of the Permit for failing to
subsequently submit required reports and to conduct required source assessment activities
' Effective May 8, 2012 and m accordance with Utah Code Ann § 19-1-105 the title "Executive Secretary" was
changed to "Division Director "
for wells/monitoring parameters in out-of-compliance status
4 Part E 2 of the NOV required DUSA to submit a report with revised statistics for Field
pH for several of the facility ground water monitoring wells on or before June 30, 2011
This requirement was included to address out-of-compliance status for pH at several
ground water monitoring wells, and as per a DUSA February 1, 2011, letter notifying the
DIRECTOR that the out-of-compliance status appeared to be due to the Permit GWCL's
being based on historic laboratory results instead of field measurements
C. FINDINGS OF FACT
1 DUSA receives and processes natural uranium-beanng ores, including certain specified
altemate feed materials, and possesses byproduct material in the form of uranium waste
tailings and other uranium byproduct waste generated by the Licensee's milling
operations This facility is located approximately six (6) miles south of Blanding, Utah
on White Mesa in Sections 28, 29, 32 and 33, Township 37 South, Range 22 East, Sah
Lake Baseline and Meridian, San Juan County, Utah
2 Part E 2 of the NOV required DUSA to submit a report with revised statistics for Field
pH for several of the facility ground water monitoring wells on or before June 30, 2011
This requirement was included to address out-of-compliance status for pH at several
ground water monitoring wells, and as per a DUSA February 1, 2011 letter notifying the
DIRECTOR that the out-of-compliance status appeared to be due to the Permit GWCL's
being based on historic laboratory results instead of field measurements
3 In response to the NOV, DUSA submitted several documents to provide updates and
work plans to investigate the out-of-compliance wells/monitormg parameters (and
updates regarding the revised pH statistics) in order to comply with the Act, Permit and
NOV A summary of the pertinent updates and documents follows
A) The pH study was not provided according to timelines set m the NOV On June
30, 2011, DUSA e-mailed the DIRECTOR requesting an extension ofthe
submittal date This request included a summary of the suspected root cause of
pH exceedences, a discussion of actions taken and recommended future actions
Based on DUSA's request, the DIRECTOR concurred that additional
coordination was needed in order to agree upon elements of additional pH study
related to the apparent decreasing trends
B) DUSA submitted a Plan and Time Schedule dated June 13, 2011 for violations
cited in the NOV for the l'\ 2"^ 3'^^ and 4^'' quarters of 2010 and also included
actions for GWCL exceedences in the 1^^ quarter of 2011
C) DUSA submitted a Plan and Time Schedule dated September 7, 2011 for out-of-
compliance parameters in the 2"^* quarter 2011
D) DUSA submitted a Plan and Time Schedule dated January 20, 2012, for
assessment of pH under Utah Groundwater Discharge Permit UGW370004
E) DUSA submitted a Plan and Time Schedule dated April 13, 2012, for
assessment of pH under Utah Groundwater Discharge Permit UGW370004
(Revised based on e-mail and telephone communication between representatives
of DUSA and the Division of Radiation Control)
Corrective action for the out of compliance wells/parameters will be in accordance with
the terms of this AGREEMENT, and based on outlined studies, objectives and schedules
m the DUSA Plan and Time Schedules (dated June 13, 2011, September 7, 2011, and
April 13, 2012). If future information indicates that this agreed upon course of action is
inadequate, additional measures may be required by the DIRECTOR through separate
correspondence or formal enforcement action as deemed appropriate DUSA retains all
administrative and judicial rights to appeal or otherwise contest such action(s)
D. AGREEMENT
DUSA will complete an investigation of the causes of out-of-compliance parameters and
decreasing pH trends according to "Plan and Time Schedule" documents dated June 13,
2011, September 7, 2011 and April 13, 2012 (Included as Attachments A, B, and C of
this SCA respectively) DUSA shall follow all elements of the Plan and Time Schedule
Documents, as modified below, and further agrees that
A) A sample of existing cuttings and/or core will be submitted for laboratory analysis
of pyrite for each of the monitoring wells listed on Table 5 of the April 13, 2012
Plan and Time Schedule, regardless of the results of visual examination and XRF
screening Each such cutting and/or core sample will be collected from within the
vertical portion corresponding to the screened interval of the well All other
provisions of the April 13, 2012 Plan and Time Schedule remain unchanged,
except for certain modifications of deliverable timelines as detailed below
DUSA will submit a source assessment report for all activities outlined in the DUSA
June 13, 2011, Plan and Time Schedule to the DIRECTOR within 90 calendar days of
the effective date of this AGREEMENT. The source assessment report will detail the
results of all analysis performed and the conclusions drawn from the analyses, including
any proposed revisions to existing GWCL's The source assessment report will also
identify any further studies that the analysis indicates should be performed, and will
propose, for DIRECTOR review and approval a plan and time schedule for completion
of any such additional studies {per the June 13, 2011, DUSA Plan and Time Schedule,
with modification as to time for submittal)
DUSA will submit a source assessment report for all activities outlined in the DUSA
September 7, 2011 Plan and Time Schedule to the DIRECTOR within 90 calendar days
following the effective date of this AGREEMENT The source assessment report will
detail the results of all analysis performed and the conclusions drawn from the analyses,
including any proposed revisions to existing GWCL's The source assessment report
may be combined with the source assessment report required for the June 13, 2011, Plan
and Time Schedule (Agreement 2 above) The source assessment report will also identify
any further studies that the analysis indicates should be performed, and will propose for
DIRECTOR review and approval a plan and time schedule for completion ofany such
additional studies {per the September 7, 2011, DUSA Plan and Time Schedule, with
modification as to time for submittal)
4 During the pH investigation activities, DUSA will provide a written notice to the
DIRECTOR at least 14 calendar days prior to all collection of core and/or cuttings samples
for pynte analysis DUSA will allow the DIRECTOR the opportunity to inspect the
collection of these samples
5 DUSA will submit a report to the DIRECTOR within 150 calendar days following the
effective date of this AGREEMENT which descnbes the screening, selection and
submission of samples, the results of the sample screening process and the visual and
analytical methods employed The report will provide the visual and analytical results and
will include an assessment of the results with regard to the potential for pyrite oxidation to
affect pH at site perched monitoring wells {per the April 13, 2012, DUSA Plan and Time
Schedule, with modification as to time for submittal)
6 DUSA will submit a report to the DIRECTOR within 120 calendar days of the effective
date of this AGREEMENT which provides statistical analysis of pH in all wells at the Mill
site which will quantify the decreasing trends m pH at the site as a whole and indicate which
monitoring wells have significant decreasing trends in pH DUSA will follow the
Groundwater Data Preparation and Statistical Process Flow Chart for Calculating
Groundwater Protection Standard, White Mesa Mill Site, San Juan County, Utah, included
as figure 17 in the New Wells Background Report {per the April 13, 2012, DUSA Plan and
Time Schedule, with modification as to time for submittal)
1 If It IS detemiined by the DIRECTOR that further analysis is required after DIRECTOR
review of the Source Assessment Reports, required by parts 2 and 3 above, DUSA will
conduct the additional assessments in a timely manner and as approved by the
DIRECTOR
E. STIPULATED PENALTIES
DUSA agrees to pay stipulated penalty amounts for not complying with this AGREEMENT
If DUSA fails to comply with the agreements above, DUSA agrees to pay the stipulated
amounts set forth below
1 If DUSA fails to meet any of the agreed upon timelines for submissions of reports or field
work notification mandated by this AGREEMENT, DUSA agrees to pay stipulated
penalties m the amount of $500 per calendar day per violation
2 If the DIRECTOR determines that any of the required reports listed in the
AGREEMENT above have omitted any information or content requirements or failed to
provide any of the study elements, performance standards or objectives mandated by the
AGREEMENT, (e g failure to provide full statistical analysis for revised GWCL's where
applicable), the DIRECTOR will advise DUSA by written notice and DUSA will be
required to remedy such omissions or failures on or before a due date as determined
appropnate by the DIRECTOR If DUSA fails to remedy such omissions or failures on or
before the due date, DUSA agrees to pay stipulated penalties in the amount of $500 per
calendar day for every day a required report remains incomplete
3 DUSA agrees to pay any required penalties within 30 calendar days of written notice
from the DIRECTOR, in the form of a check, made payable to the State of Utah, and
delivered or mailed to
Division of Radiation Control
Utah Department of Environmental Quality
PO Box 144850
195 North 1950 West
Salt Lake City Utah, 84114-4850
F. NOTICE
Compliance with the provisions of this ORDER is mandatory Providing false information may
subject DUSA to further civil penalties or criminal fines
UCA § 19-5-115 provides that a violation of the ACT or a related order may be subject to a civil
penalty of up to $10,000 per day of violation Under certain circumstances of willfulness or
gross negligence, violators may be fined up to $25,000 per day of violation
AGREED to this day of
DENISONAlINfes (USA) CORR
'Id C frydenlund
Vice President and Counsel
Denison Mines (USA) Corp
,2012
UTAH DIVISION OF RADIATION CONTROL
By.
Rusty Lundberg
Director
F \DUSA\QOC Plan and Time Schedule and pH\SCA\Revised SCA UGW12-03\DUSA White Mesa OOC and pH SCA Final docx
Attachment A
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), June 13, 2011
Attachment B
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), September 7, 2011
Attachment C
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), April 13, 2012
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
IN THE MATTER OF
DENISON MINES (USA) CORP.
1050 IT**" Street, SUITE 950
DENVER, COLORADO 80265
STIPULATED CONSENT AGREEMENT
DOCKET No. UGW12-03
A. STATUTORY AUTHORITY
This STIPULATION AND CONSENT AGREEMENT (AGREEMENT) is between Denison
Mines (USA) Corp (DUSA) and the Director of the Utah Division of Radiation Control'
(DIRECTOR) under the Utah Water Quality Act, Utah Code Ann (UCA) §§ 19-5-101 to 19-5-
124 (the ACT), including sections 19-5-104, -106, -111 and -115 This AGREEMENT is also
executed m accordance with the Utah Administrative Procedures Act, Utah Code Ann §§ 63G4-
101 to -601 and Administrative Procedure Rules, Utah Admin Code R305-6
Under the Water Quality Act, Utah Code Ann Title 19, Chapter 5, "Director" for purposes of
groundwater quality at a facility licensed by and under the jurisdiction of the Division of
Radiation Control, means the Director of the Division of Radiation Control Utah Code Ann §
19-5-102(6)
The DIRECTOR may enforce rules made by the Water Quality Board in accordance with Utah
Code Ann § 19-5-106(2)(d)
B. APPLICABLE STATUTORY AND REGULATORY PROVISIONS
1 Utah Code Ann § 19-5-107(1 )(a) requires that
"Except as provided in this chapter or rules made under it, it is unlawful for any person to
discharge a pollutant into waters of the state or to cause pollution which constitutes a
menace to public health and welfare, or is harmful to wildlife, fish or aquatic life, or
impairs domestic, agricultural, industrial, recreational, or other beneficial uses of water,
or to place or cause to be placed any wastes m a location where there is probable cause to
believe it will cause pollution "
2 DUSA was issued Utah Ground Water Quality Discharge Pennit No UGW370004
(Pemiit) on March 8, 2005 Said Pennit was modified by the DIRECTOR on March 17,
2008, January 20, 2010, June 17, 2010, February 15, 2011 and was last modified on July
14, 2011
3 The DIRECTOR issued DUSA a May 9, 2011 Notice of Violation and Compliance
Order, Docket No UGWl 1-02 (NOV) for multiple violations of the Permit, including
violations of UCA § 19-5-107 and Part I G I of the Permit for exceeding Permit Ground
Water Concentration Limits (GWCL's) in Table 2 of the Permit for two consecutive
sampling events (out-of-compliance status), and Part I G 4(c) of the Permit for failing to
subsequently submit required reports and to conduct required source assessment activities
' Effective May 8, 2012 and m accordance with Utah Code Ann § 19-1-105 the title "Executive Secretary" was
changed to "Division Director "
for wells/monitoring parameters in out-of-compliance status
4 Part E 2 of the NOV required DUSA to submit a report with revised statistics for Field
pH for several of the facility ground water monitoring wells on or before June 30, 2011
This requirement was included to address out-of-compliance status for pH at several
ground water monitoring wells, and as per a DUSA February I, 2011, letter notifying the
DIRECTOR that the out-of-compliance status appeared to be due to the Permit GWCL's
being based on historic laboratory results instead of field measurements
C. FINDINGS OF FACT
1 DUSA receives and processes natural uranium-bearing ores, including certain specified
altemate feed materials, and possesses byproduct material m the form of uranium waste
tailings and other uranium byproduct waste generated by the Licensee's milling
operations This facility is located approximately six (6) miles south of Blanding, Utah
on White Mesa in Sections 28, 29, 32 and 33, Township 37 South, Range 22 East, Salt
Lake Baseline and Meridian, San Juan County, Utah
2 Part E 2 of the NOV required DUSA to submit a report with revised statistics for Field
pH for several of the facility ground water monitoring wells on or before June 30, 2011
This requirement was included to address out-of-compliance status for pH at several
ground water monitoring wells, and as per a DUSA February I, 2011 letter notifying the
DIRECTOR that the out-of-compliance status appeared to be due to the Permit GWCL's
being based on historic laboratory results instead of field measurements
3 In response to the NOV, DUSA submitted several documents to provide updates and
work plans to investigate the out-of-compliance wells/monitoring parameters (and
updates regarding the revised pH statistics) in order to comply with the Act, Permit and
NOV A summary of the pertinent updates and documents follows
A) The pH study was not provided according to timelines set in the NOV On June
30, 2011, DUSA e-mailed the DIRECTOR requesting an extension of the
submittal date This request included a summary of the suspected root cause of
pH exceedences, a discussion of actions taken and recommended future actions
Based on DUSA's request, the DIRECTOR concurred that additional
coordination was needed in order to agree upon elements of additional pH study
related to the apparent decreasing trends
B) DUSA submitted a Plan and Time Schedule dated June 13, 2011 for violations
cited in the NOV for the 1'', 2"^ 3''* and 4"" quarters of 2010 and also included
actions for GWCL exceedences in the l^^ quarter of 2011
C) DUSA submitted a Plan and Time Schedule dated September 7, 2011 for out-of-
compliance parameters in the 2"^^ quarter 2011
D) DUSA submitted a Plan and Time Schedule dated January 20, 2012, for
assessment of pH under Utah Groundwater Discharge Permit UGW370004
E) DUSA submitted a Plan and Time Schedule dated April 13, 2012, for
assessment of pH under Utah Groundwater Discharge Permit UGW370004
(Revised based on e-mail and telephone communication between representatives
of DUSA and the Division of Radiation Control)
Corrective action for the out of compliance wells/parameters will be in accordance with
the terms of this AGREEMENT, and based on outlined studies, objectives and schedules
in the DUSA Plan and Time Schedules (dated June 13, 2011, September 7, 2011, and
April 13, 2012). If future information indicates that this agreed upon course of action is
inadequate, additional measures may be required by the DIRECTOR through separate
correspondence or formal enforcement action as deemed appropriate DUSA retains all
administrative and judicial rights to appeal or otherwise contest such action(s)
D. AGREEMENT
DUSA will complete an investigation of the causes of out-of-compliance parameters and
decreasing pH trends according to "Plan and Time Schedule" documents dated June 13,
2011, September 7, 2011 and Apnl 13, 2012 (Included as Attachments A, B, and C of
this SCA respectively) DUSA shall follow all elements of the Plan and Time Schedule
Documents, as modified below, and further agrees that
A) A sample of existing cuttings and/or core will be submitted for laboratory analysis
of pyrite for each of the monitoring wells listed on Table 5 of the April 13, 2012
Plan and Time Schedule, regardless of the results of visual examination and XRF
screening Each such cutting and/or core sample will be collected from within the
vertical portion corresponding to the screened interval of the well All other
provisions of the April 13, 2012 Plan and Time Schedule remain unchanged,
except for certain modifications of deliverable timelines as detailed below
DUSA will submit a source assessment report for all activities outlined in the DUSA
June 13, 2011, Plan and Time Schedule to the DIRECTOR within 90 calendar days of
the effective date of this AGREEMENT. The source assessment report will detail the
results of all analysis performed and the conclusions drawn from the analyses, including
any proposed revisions to existing GWCL's The source assessment report will also
identify any further studies that the analysis indicates should be performed, and will
propose, for DIRECTOR review and approval a plan and time schedule for completion
of any such additional studies {per the June 13, 2011, DUSA Plan and Time Schedule,
with modification as to time for submittal)
DUSA will submit a source assessment report for all activities outlined in the DUSA
September 7, 2011 Plan and Time Schedule to the DIRECTOR within 90 calendar days
following the effective date of this AGREEMENT The source assessment report will
detail the results of all analysis performed and the conclusions drawn from the analyses,
including any proposed revisions to existing GWCL's The source assessment report
may be combined with the source assessment report required for the June 13, 2011, Plan
and Time Schedule (Agreement 2 above) The source assessment report will also identify
any further studies that the analysis indicates should be performed, and will propose for
DIRECTOR review and approval a plan and time schedule for completion of any such
additional studies {per the September 7, 2011, DUSA Plan and Time Schedule, with
modification as to time for submittal)
4 Dunng the pH investigation activities, DUSA will provide a written notice to the
DIRECTOR at least 14 calendar days prior to all collection of core and/or cuttings samples
for pynte analysis DUSA will allow the DIRECTOR the opportunity to inspect the
collection of these samples
5 DUSA will submit a report to the DIRECTOR within 150 calendar days following the
effective date of this AGREEMENT which describes the screening, selection and
submission of samples, the results of the sample screening process and the visual and
analytical methods employed The report will provide the visual and analytical results and
will include an assessment of the results with regard to the potential for pyrite oxidation to
affect pH at site perched monitonng wells {per the April 13, 2012, DUSA Plan and Time
Schedule, with modification as to time for submittal)
6 DUSA will submit a report to the DIRECTOR within 120 calendar days ofthe effective
date of this AGREEMENT which provides statistical analysis of pH in all wells at the Mill
site which will quantify the decreasing trends in pH at the site as a whole and indicate which
monitonng wells have significant decreasing trends in pH DUSA will follow the
Groundwater Data Preparation and Statistical Process Flow Chart for Calculating
Groundwater Protection Standard, White Mesa Mill Site, San Juan County, Utah, included
as figure 17 in the New Wells Background Report {per the April 13, 2012, DUSA Plan and
Time Schedule, with modification as to time for submittal)
7 If it IS detemiined by the DIRECTOR that further analysis is required after DIRECTOR
review of the Source Assessment Reports, required by parts 2 and 3 above, DUSA will
conduct the additional assessments in a timely manner and as approved by the
DIRECTOR
E. STIPULATED PENALTIES
DUSA agrees to pay stipulated penalty amounts for not complying with this AGREEMENT
If DUSA fails to comply with the agreements above, DUSA agrees to pay the stipulated
amounts set forth below
1 If DUSA fails to meet any of the agreed upon timelines for submissions of reports or field
work notification mandated by this AGREEMENT, DUSA agrees to pay stipulated
penalties in the amount of $500 per calendar day per violation
2 If the DIRECTOR determines that any of the required reports listed in the
AGREEMENT above have omitted any information or content requirements or failed to
provide any ofthe study elements, performance standards or objectives mandated by the
AGREEMENT, (e g failure to provide full statistical analysis for revised GWCL's where
applicable), the DIRECTOR will advise DUSA by written notice and DUSA will be
required to remedy such omissions or failures on or before a due date as determined
appropnate by the DIRECTOR If DUSA fails to remedy such omissions or failures on or
before the due date, DUSA agrees to pay stipulated penalties in the amount of $500 per
calendar day for every day a required report remains incomplete
3 DUSA agrees to pay any required penalties within 30 calendar days of written notice
from the DIRECTOR, in the form of a check, made payable to the State of Utah, and
delivered or mailed to
Division of Radiation Control
Utah Department ofEnvironmental Quality
PO Box 144850
195 North 1950 West
SaU Lake City Utah, 84114-4850
F. NOTICE
Compliance with the provisions of this ORDER is mandatory Providing false information may
subject DUSA to further civil penalties or criminal fines
UCA § 19-5-115 provides that a violation of the ACT or a related order may be subject to a civil
penalty of up to $10,000 per day of violation Under certain circumstances of willfulness or
gross negligence, violators may be fined up to $25,000 per day of violation
AGREED to this day of
DENISON MINEfs (USA) CORR
m\p CI Frydenlund
Vice President and Counsel
Denison Mines (USA) Corp
2012
UTAH DIVISION OF RADIATION CONTROL
By_
Rusty Lundberg
Director
F \DUSA\OOC Plan and Time Schedule and pH\SCA\Revised SCA UGW12-03\DUSA White Mesa OOC and pH SCA Final docx
Attachment A
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), June 13, 2011
Attachment B
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), September 7, 2011
Attachment C
DUSA Transmittal of Plan and Time Schedule under Utah Ground Water Discharge Permit UGW370004
Part I G 4(d), April 13, 2012