DRC-2012-003641 - 0901a06880821e50

OENISOJ)C*
*lrNES
March 26,2012
VIA PDF AND FEDEHAL EXPfiESS
Mr. Rusty Lundberg
Co-Executive Secretary
Utah Water Quality Board
Stale of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Dear Mr. Lundberg:
Re: DUSA ltt, 2"", and 3d Quarters 2011 Groundwater ltfionitoring Reports - DRC Review
Findings/Advisorieg, Notice of Enforcement Diecrstion and Request for Information dated
February 7,2A12
This letter is in response to the foregoing DRC Review Findings/Advisories, Notice of Enlorcement
Discretion and Request for Information ("NOED/RFIs") dated February 7, 2012 which Denison Mines
(USA) Corp. ("Danison") received on February 1Q, 2012 related to the White Mesa Mill's (the "Mill's")
Ground Water Quality Discharge Permit No, UGW3700O4 (the 'Permit"), and the Mill's Groundwaler
Monitoring Reports for the 1o, 2*'and 3'o Quarters ol 201 1.
This fetler transmits Denison's respon$es to the February 7,2012 NOED/RFI as well as any
documentation requosted by DHC in the Febru ary 7 , 2012 letter. Listed below are Denison's rasponses to
each item in DRC's February 7, 2012 letter. The numbering of the remainder of this letter follows the
DRC February 7, 2O12 NOED/RFI. Each DRC item is shown in italics, below, followed by Denison's
response.
NOED #'
Based on DRC review ol the Accelented Monthly Slatcp Reports relevant to the review period, the
following violation was not6d.
Ground Wator Concentration Limits (GWCL's) were set for Monibrtng Wetl MW-35 in the February 15,
2011 Permit Modification. The QWCL's w6ro included in the Permit aN are enforceable (lt is noted that
the current GWCL'g at wall MW-35 were calculated by multiplying the Ground Water Qualig Standard
(hereafter WaQ by a factor of 0.25, as allowed by UAC rc17-6-4.5(8)(2), and are interim pending
submission ol backgrou nd sfatbtics and rev ision/approval of th e GWCL'z).
DRC noted that the GWCL's for the tollowing Parameters were exceeded at well tvNV-36 during the
reviewed quarters of dala:
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Drnlson tlinec (USA) Corp.
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I)rntlr, CO 8ft165
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Letter lo Mr. Rusty Lundberg
March 26,2012
Page 2
| - Groundwater Well tvWV-31
7/2011 with Mn, U
Since MW-35 is reguired to be monitored quafterly, aceelerated monthly monitoring should have baen
implemented within 30 days of receipt of the data results per Parl lG.l of the Groundwater Permit. Based
on dates of lab packet receipt, the affected parameters should have been aceelerated aE follows;
Based on these findings and timelines, DUSA vbfated Groundwater Permh No. UGW370004 Part 1.G.1,
Failure to implement accelerated monthly monitoring at well irw-35 for Manganese and Uranium.
NOED Justitication
Per the DUSA Znd Quarter 20ll Ground Water Monitoing Repoft, Section 2.1.2'Actelerated
Groundwater Monitaing,' DUSA did identify the exceedences during tha lst Quafter 2011. According to
DUSA 'lt should be noted that during Ql, tvMv-1i was sampled on February 14, 2011, prior to Denison's
receipt on February 18, 20ll of the revised GWDP cantaining GWCL's dated February 15, 2011. At the
time of the Ql sampling, the current GWCL's werc not applicable to MW-35. Therefore sampling resufts
from MW-35 were not addressed in tha Qt Exceedence Notice dated May 13,2011, because the
GWCLs for this well were not in effect at the time of sampling.'
Enforcement discretion is granted based on:
1, DUSA identified and discussed their interpretation of the GWCL exceadences, and
2, DRC recognizes that there was confusion regarding whether the GWCL exceedences were in lorce
due to GWCL's being incorporated into the Permit during the same guarter.
Note: Per the DUSA field sheets, well MW-35 was purged on A14/2011 to dryness and sampled on
2/15/2011, not /1rU2011 as stated by DUSA in the quote above.
OTNISOJ)*d
ttllNES
Letter to Mr. Rusty Lundberg
March 26,2012
Page 3
Denison Resoonsc:
Denison appreciates DRG's Enforcement Discretion related to the accelerated sampling requirements for
MW-35.
Relative to accelerated monitoring requiremenls, il is Denison's understanding, based on phone
conversations with DRC on April 5, 2010, that accelerated monitoring is required to commence ihe month
following lhe submission of the Exceedance Notice for a specified quarter. In the case of MW-35, the
exceedances for manganese and uranium were noted in the 1"1 Quarler of 201 1 , The Exceedance Notico
for 1 s Quarter of 201 1 was submitted on May 13, 201 1 . MW-35 was not listed in that Exceedance Notice
to DRC but was noted by Denison as requiring accelerated monitoring. Based on Denison's
understanding of the April 5, 2010 phone agreement, accelerated monitoring was required to start in June
2011 for manganese and uranium. A full suite sample for MW'35 was colleted in June 201 1. Since the
accelerated analytes were captured in that sampling event, Denison does not believe that any
accelerated monitoring was missed as a resutt of the 1"'Quarter 2011 exceedances. Further, based on
Denison's understanding, accelorated monitoring resulling from 2d quarter 2011 and 3'd Quarter 2011
would be required to start in September 2011 and December 2011 respectively based on submission
dates for the Exceedance Notes of August 201 't and November 2011.
NOED#2
The Pennit Part l.F.l.g requires DUSA ta submit Tims Concentration Plots for each monitoing well for
chloride, fluortde, eulfate and uranium.
The lhranium Time Concentration Ptot for monitoring well MW-7 included in the * Quarter 2011 is
incorrect (does not match the 2All rqorted laboratory resufts).
Failure ta provide a cunent updated Time Concentration Plot far Uranium at monitoring well MW -S is a
vialation of Parl l.F.l.g af the Permit,
NOED Justification
Enforcament discretion is granted based an:
t. Uranium monitoring at well lvMv-i was accelarated from Semi-Annually to Quarterly starting in the lst
Quarter 2Al | $nitial exceedance wae during the lst Quarter 2010). Additionally, wall MW-i was included
in the OUSA June 13, ZAlt Ptan and Time Schedule under Utah Graundwater Discharge Permit
LJGW370AO4 Paft 1.G.4{d) white Mesa Mill, Specifically, wall tvNV-i is included in a category with wells
which hava continued rising trend, and will be evaluated ta ansure that tha continued trend is consistent
with previous analysis. Thus, the rising trend has been duumented in other reports and evaluation has
been initiated.
2. This ia the first noted violation regarding the Groundwatar Time Concentration Plots. Future
violatbns will be subiect to lormal enforcemant.
Denison Reeoonse:
Denison appreciales DRC's Enforcemsnt Discretion relative to the Time Concentration Plots.
As discussed in our taleconlerences dated February 21, and February 22,2A12, the Time Concentration
Plots submitted through 3'o Quafter 2011 were based on the data retained after stalistical analysis using
the DRC- approved procedures as defined in Figure 19 of the Revised Background Groundwater Quality
Report: Existing Wells ('Background Report") (October 20A7). Cqnsistent with the approved procedures,
several points were not included on the Time Concentration Plots because oi their designation as
oEN'soJld*
'WNE5
Letter to Mr. Rusty Lundberg
March 26,2012
Page 4
'outliers or e)dremes" bassd on lhe statistical process defined in the Background Report. Based on the
above-mentioned teleconferences, slarting with the Q4 2011 Groundwater Quarterly Repofi, all data,
including outliers will be plotted in the Time Concentration Plots and statisticalanalysis and interpretation
ol the data willnot be applied lo the Time Concentration Plots.
Ragueefs for lnformation (RFI)
NFI #I
DRC has concems regarding purge technique when wells were ovacuatad to dryness (low yield welts),
and only one set of tield Wrameters was taken during the initial purge. ln these esas there were no
verifications that the tield parameters were stable prior to, or during sampling. Additionally, DRC noted
that well MW-AA was purged, then allowed to recharge tor 5 days prior to sampling. These wells are
summartzed on the table below:
ln cases where the well is purged dry due to low yield, the DUSA Quality Assurance Plan (QAP)
6.2.7(d)vii reguires that the well be evacuated to dryness and that the number of gallons purged by
reeorded on the field sheet. DUSA is fien requked to measure and record depth to groundwater on the
field sheet. DRC verified that in cases where.the .monitoing well wae evacuated ta dryness, the number
of gallons evacuated was recorded for the lo, t', and { Quarter, 20tl repods. A/so, DRC verified that
depth to groundwater was measured and recorded (comments field) on the field shedt. Therefore, DUSA
has complied with the cunent MP requiremenfs, however, these activities are not consistent with low
yield sampling procdures in the 'United Statss Environmental Protection Agency, September 1986,
BCHA Ground-Water Manitoring Technical Enforcement Guidance Document,' (TEGD) as follows:
According to the TEGD Part 4.2,3 'Well Evacuation," in the case'whan evacuating low-yield wells (wells
that ara incapabla of yialding thrae casing volumas), the owner/aparctor should evacuate wells to drynass
onca, As $oon as the watl recovers sufficiertly, tha ftrct sample should be tested for pH, temperature, and
speciflc conductanca. Samples should then ba collected and containerized in the order of the panmaters
wlatilization sensrtivity. The well shauld be retested for pH, temperdture and specific conductance after
sampling as a measare of purging efficiency and as a check on the stability of the water samples over
time.'
Please update and submit a revised White Mesa QAP, to include procedures tor field sampling law yield
we//s consistent with the TEGD procedures, to DRC within 45 calendar days ol receipt of this letter.
Pleasa base the revised QAP on tha cunently approved QAP (Bev. 6). Speeifically, tha QAP needs to
clarify that in the case where a monitoring wall has been determined to be low yield and is evacuated to
dryness:
a. DUSA will collect the currently required field parameters (pH, specilic conductance, aN
tempenture) as soon as the well recovers sufficiantly lor sample collectbn (cunently defined as
recavory to wtthin at lsast 90% of the measured groundwater static surtace before sampling),' priorto collection of the sample volumes, and
4
WellNo.Sampling Qtr lssus
ttNV-35 1- Quaftar Well purged dry but only one set of field parameters taken during
ouraino.
MW-2A 2- Quarter Well purged on 4/612011, field parameters taken on day of purge,
Sample not collected until4lfiPAl l (5 davs later)
lvw-3A t" Quarter Purged drv, onlv one sat of field parameters taken durino puroino
MW-|2 t" Quarter Pureed drv, onlv one set of field oarameters taken durino puroino
MW-24 {" Quartar Purged dry, anly one set of field parameters taken durino puroino
f,lWf-37 9" Quarter Bailed dry, onlv one set of field parameters taken. from bucket?
DEN'SOJ)JJttilNE5
Letter lo Mr. Rusty Lundberg
March 26,2012
Page 5
b, DU$A will then cotlect field parameters directly after sample collection to ensure that the
parameters show stabilization (according to the criteia currently outlined in the QAP Part 6.2.6.).
Denieon Fesnonse:
Per the DRC request above, a redline and clean copy ol the Revised QAP is attached. The Revised
QAP, Revision 7, dated March 26,2012, is based on the currenlly approved QAP, which is Revision 6,
dated March 22,2A1O. The requested procedure for field sampling low yield wells consistent with the
TEGD has been added.
Per our discussions, proposed additional changes have been made to the QAP to update processes and
address inconsistencies.
BFI #2
DRC notes that for the ld, * and td Quarter 201 t monitoring, Tetrahydrotunn (THF) at wetl MW -11
has been completed monthly (9 monthly samples), and that the laboratory results for all months was
reported balow the reporting limit (<1.0 ug/L), wellbelawthe GWCLfoTTHF (11.5 u{L).
Per a previous DHC reyiew memo, dated 2010 February 8, 2011, pp. 3 and 4, which summarizes review
findings ot the * & * Quarter 2O1O DIJSA Groundwater Monitoring Reports, 'ln a lefter dated January
12, 2011 DUSA submitted a request that accelerated monitortng for THF in well MW-ll be retumed to
quarterly monitoring rather than he accelented rnonthfi monilortng due to THF concentrations in well
MW-|I baing betow tl.S ug/Lin nine conswutive sampling events since the inilial axceedance of 12
ug/l- in the l't Quarter, 2010. The DBC denied this request for the following reasons.' 1) Due to the
history of THF in groundwater at the White Mesa Uranium Mill, 2) Presence of THF recentty identified in
taitings wastewater, 3) Histoic OUSA claims on a THF source is now susp€c,! and 4) Groundwater
hydraulic considerations at well MW-11. The ORC documented fhe$e r€asons in a January 25,2oll
Request for lnformation (RFI) letter, ln the January 25, 2011 RFt the DFIC stated: 'Afthough, DUEA has
previwsty ctaimed that THF is not used in its mill operations, concentrations af THF were detected above
the tftah GWOS (46 ugL) in the Tailing Cell 4A LAS in fwo consecutive samples. Since Tailings Cell4A
is the current taiting eell being used by D|JSA, it appears that the mtll is currently uslng THF in its
operations.'
tt appears that DIJSA has not responded to the DRC January 25, z?lt RFl. The HFI wae for DUSA to
'provide additional intormation as to why the THF concentrations obserued in the on'site wastewater
impoundments are not caused by the milling process and justify why the sampling frequency for THF
should be reducad in wall MW-l1 given the nsw information,"
Ptease provide a resrynse to the January 25, 2OI t DRC RFI within 45 calendar days of receipt of this
Ietter.
Oenison Responsa:
Denison has never purchased, stored or used THF as a reagent, solvent or additive to the Mill's
processes. Moreover, contrary to the statement in DBC's letter of January 25,2A11 that the presence of
THF in lhe Mill's tailings cells is "new informalion,o it has been known to DRC since at least 2003, that the
Mill's tailings cells may contain THF. The Executive Secreiary stated, in a DRC letter of November 12,
2@3, that:
"THF is used as a Grignard reagent in the syntheeis of motor fuels (National Laboratory ol
Medicine Hazardous Substances Data Bank [NLM-HSDB].,.). One motor fuel of interest is JP-5,
which is synonymous with kerosene (Agency for Toxic Substances and Disease Begistry...). As
OEN'SOHD#dfrllNE5
Letter to Mr. Busty Lundberg
March 26,2012
Page 6
you are aware a large volume of kerosene is used in the IUC uranium solvent extraction circuit,
about 1,600 lb/day. As a result, there is a possibility that unintended THF concentrations could
be lound in the tailings cells process and waslewalers."
Denison has never disagreed with this statement of the Executive Secretary, which Denison has
considered to be a determination by the Executive Secretary that THF may be associated with the
kerosene used in the Mill's Solvent Extraction ('SX") circuit. Although THF is not'used as a Grignard
reagent," but as the solvent for thb Grignard reaction in alkane syrthesis, in either case, it can be present
as a residual from the synthesis of branched kerosenes, such as those that comprise the kerosene used
in the Mill's extraction circuit. Additionally, furans and alkoxymethyl furans are known to be added as
conditioners for anti-wear prop€rties and freeze prevention in the formulation of fuels, lubricants and
exlraction solvents from the kerosene lraction distillates, and could be present in Mill kerosene lor this
reason.
While it is understood that THF may be a constituent in the Mill's tailings syslem for the foregoing
rsasons, and tailings wastewater analyses have confirmed that it is present in the tailings system, its
presence in tailings does not explain the detection of THF in wells as far up-gradient as MW-1 and as far
down'gradienl as MW-3, which cannot be affected by the tailings system. There is no plausible scenario
that would account for THF in MW-'l resulting from the Mill operations, because it is approximately 2,200
feet (over 0.4 miles) upgradient of Mill operations. Similarly, MW-3 is approxirnately 2,200 feet (over 0.4
miles) down-gradienl ol Mill operations and too remote to be impacted by the Mill or the tailings syslem.
Denison maintains that, even given the presence of THF in tailings solutions, the most plausible
explanation lor THF detection in wells such as MW-1 and MW-3 is that it results from something intrinsic
to the well or the well sampling. As identi{ied in our letters of October 17, 2003 and December 18, 2003,
Denison mainlains that one source for THF detected in those wells is likely to be the solvents and
adhesives used in well construction. The confirmation by sampling ol the Execulive Secretarly's previous
determination that THF may be presenl in the tailings s)rstem as a resull of the use of kerosene in the
Mill's SX circuit, does not ehange Denison's position on the likely source of THF.
Denison monitors numerous othsr analytes (including metals, cations, nitrate, fluoride, uranium, nilrate),
which are known to be present in the Mill's tailings system. Per the DRC letter of May 30, 2006, eight
conseculive sample results below the GWCL are needed for the discontinuance of acceleratedmonitoring. The Executive Secretary has previously approved Denison to relurn to normal sample
lrequency for parameters in wells that show a minimum ol eight consecutive sample results below the
GWCL, including parameters which are known to be present in the tailings system. Based on the 24
consecutive sampling events from which the monitoring results lor THF in MW-11 have been below the
GWCL of 11.5 ug/L, of which 21 have been non-detect for THF, Denison once again requests that DFiC
allow the accelerated monitoring of THF in MW-11 to return to normal sampling frequency, as requested
in our fetter of January 12, 2011.
nH #3
DHC conducted a review of the blind duplicate samples collected during each of the monitoring guafters.
Per the tacility QAP, one blind duplicate must be collected with each sampte batch. DRC confirmed that
one blind duplicate was callected for each batch.
The duplicates must be within 20% Helative Percent Difference (RPD) per the QAP Part 9.1.4, if any of
the samples do not meet this comparison critaria, then DUSA must conform to the prrcedures for
canective action listad in the current QAP (Per the current language in Part 1A. La of the QAP), these
include:
a. ldentity and define the problem,
b. Assign responsibility for investigating the problem,
c. lnvestigate aN determine the cause of the problem,
d. Determine a conective action to eliminate the problem,
6
DENISOND*d
ftilNES
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Letter to Mr. Rusty Lundberg
March %,2012
Page 8
Collected 5NTU
Footnotes:
1 Data for this well was obtained from Tab B of the lst Quarter 2011 Groundwater Monitaring Report
2. Data for this well was obtained from Tab I of the znd Quarter 2011 Graundwater Monitoring Repod
3. Data for this welt was obtained from Tab C of the 2N Quarter 2Ol I Groundwater Monitoring Aeport
Accelerated
Monitoring Field theets
4. Data for this well was obtained from Tab I of the lrd Quarter 201| Groundwater Monitoing Heport
5. Data for this well was obtained from Tab C of the 1rd Quarter 2A1l Groundwater Monitoring Report
Accelerated
Monitoring Field Sheets
DUSA undertaok a redevelopment proiect tor groundwater monitoring wells during calendar years
2A10/2011, in response ta a DRC letter dated June '1, 2A10. A redevelapment report was preparad and
submitted b DHC on Saptember 30, 2011 (Received by ARC on October 3, 201l). The redevelopment
report is currently under DFIC revlew.
Pelison Response:
No response required.
Table 3 -Groundwater with Turbiditv Measurements z
G roundwater Monitoring Event Well TutbiditvPt
l- Qtn2All MW-j',t 16.2
l" Qtr.2411 MW-|2"7.9
l- Qtr,2411 MW-20"7.5
t" Qtr,2011 MW-32"8.6
t" Qtt,2011 MW-34"tll
f Qn20ll MW-l',"25.4
l- Qtr.201l MW-5'"8.2
2' Qtr.201l MW-|2"8.7
2- Qtr.201l MW-22 8.8
2- Qtr.20l1 MW-29't 9.8
I- Qtr.20ll MW844 256.0
2' Qtr.20ll MW-2f"',to.o
2- Qtr.20l1 MW-25"1 6.2
3" Qtr.2011 MW,t"t 10.0
S" Qtr.2011 MW-ll'"'16.2
3" Qtr.2All MW-23t't 22.1
3" Qtr.201l MW-29("t t7
3" Qtr. 2011 MW32t't t6.9
3" Qtr.201l Resample MW-321''8.0I' Qtr,2011 MW-|1Pt 41.1
OENFOJ)Jd*1lNt5
Lctter to Mr. Rusty Lundberg
March 26,2012
Page 9
lf you have any queslions or require any fuilher in{ormation, ptease contact the undersigned.
Yours very truly,
Demsor.r MrHes (USA)
Director, Compliance and Permitting
David C. Frydenlund
Ron F. Hochstein
Harold R. Floberts
David E. Turk
Katherine Wdnel
OEN'sOFDdd
MINES
Letter to Mr. Flusty Lundberg
March 26,2012
Page 10
APPENDIX A
While Mesa Mill
Drafl Groundwater Quality Assurance Plan
Revision 7, Dated March 26,2012
l0
OEN'SOJ}JJiilNE3
Mill - Groundwater Discharge Permlt
Groundwater Monitoring Quality Assurance Plan (Q P)
Date:03/2212010 Rev. 5
Attachment I
See instructi0nOENISONDddMINES
ATTACHMENT 1.2
WIIITE MESA URANIUM MII,L
FIEI,D DATA WORKSIIEET FOR GROI.]ND WATER
Description of Sampling Event:
Location (wellname
Field Sample ID
Samplcr Name
and initials:
and Sampling (if different)
Well Pump (if other than Bennet)
Prev. Well Sampled in Sampling Event
pH Buffer 4.0
WellDepth(0.0llt):uMHOS/ cm
Conductance (avg)
Casing Volume (V)
pH of Water (avg)
Well Water Temp. (avg)Redox Potential (Eh)f----l turt i<tityl-l
Ext'l Amb. Temp. 'C (prior sampling event)f--lWeather Cond.
Time I I Gal.Purged
Conductance
Temp. oC
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Conductance
Temp. oC
Redox Potential Eh (mV)
Turbidity (NTU)
Date and rime for tuttlnffi
Well Purging Equip Used:lt-lprrp or@l balt"t
Sampling Event
pH Buffer 7.0
Specific Conduct
White Mesa Mill
Field 0ata Wbrkheet for Groundwater
Depth to water Before purgind-l 4" wen:l-l(.653h)
r" wett:[-l(.367h)
Time Gal. Purgcd
Redox Potential tsh (mV)
Time Gal. Purged l-_l
Conductancc
Temp. oC
Redox Potential Eh (mV)
Turbidity (NTU)
1 of2
Mlll - Groundwater Oischarge Permlt
Groundwater MonltorinEQuallty Assurance Plan (QAP)
Volume of Water Purged gallon(s)
PumBin g Rate Calcul ation
Number of casing volumes evacuated (if other than two)
If well evacuated to dryness, number of gallons evacuated
Narne of Certified Analytical Laboratory if Other Than Encrgy
FinalDepth Sample Time
White Mesa Mill
Field Data Worksheet for Groundr,i;ater
Flow Ratc (Q), in epm.
5/60 =
Timc to cvacuate two casing volumcs (2V)
r=2vlQ= [--l
Date:03/2212010 Rev.6
r _t
See instruction
Type of Sample
Sample Taken Sample Vol (indicate
if other than as
specified below)
Filtered Preservative
Type
Preservativc Added
Y N Y N Y N
VOCs tr tr 3x40 ml tr tr HCL tr tr
Nutrients tr tr 100 ml tr n I{2S04 tr B
Heavy Metals tr tr 250 ml tr tr t{N03 tr tr
All Other Non Radiologics EI tr 250 ml tr u No Preserv.tr EI
Gross Aloha tr tr 1,000 ml tr tr HNO3 tr tr
Other (specify)tr tr Sample volume tr n n tr
If preservative is used, sPecifY
Type and Quantity of
Preservative:
Do not touch this cell (SheetName)
2 ol2