DRC-2009-008322 - 0901a068809b24f2

DryrsroN oF RADTATION CONTROL
UTAH DEPARTMENT OF EI\'VIRONMENTAL QUALITY
PUBLIC NOTICE
OF A MODIFICATION TO THE
GROr.]i\D WATER QUALTTY DTSCHARGE PERMTT NO. UGW370004
Pumose of Public Notice
The Utah Department of Environmental Quality (DEQ) is soliciting comments on its
proposed modifications to the existing Ground Water Quality Discharge Permit (Permit)
under the authority of the Utah Water Quality Act, Section 19-5-104(1Xi), Utah Code
Annotated 1953, as amended and the Utah Administration Code (UAC) R317-6.
Licensee and Permittee Information :
NAME:
MAILING ADDRESS:
TELEPHONE NUMBER:
FACILITY LOCATION:
PERMIT NO.:
Denison Mines (USA) Corporation
1050 17th Street, Suite 950, Denver, CO 80265
303-628-7798
Blanding Utah
ucw370004
Major changes associated with this Permit modification include, but are not limited to:
. Approval of DUSA Background Ground Water Quality Reports dated October
2007 and April 30,2008o Calculation of a mean and standard deviation for each Point of Compliance
(hereafter POC) groundwater monitoring wells, and the establishment of sampling
frequency for all POC wellso Establishment and revision of Ground Water Compliance Limits for multiple
POC wells
. Update the status of certain POC wells with parameters in Out-of-Compliance
Statuso Addition of BAT Standards and Performance Monitoring for Feedstock Material
Stored Outside the Feedstock Storage Area
o Addition of Performance Monitoring for inspections of Tailing Cell and Pond
Liner Systemso Addition of Seeps and Springs and tailings cell water monitoring.o Resolution of certain previous compliance schedule requirements
Public comments are invited any time prior to 5:00 p.m. on October 8, 2009. Written
comments may be directed to the Division of Radiation Control, P.O. 144850, Salt Lake
City, UT 84114-4850. A public meeting will be held on October 7 ,2009 from 7:00 to
9:00 p.m. at the Blanding Arts and Events Center located 715 West 200 South, Blanding,
Utah. All oral and written comments received at the meeting will be considered in
formulation of final determinations to be imposed on the Permit. .
Further Information
Additional information may be obtained upon request by calling Phil Goble at (801) 536-
4044 or via email at [e-mail]. Written requests for information can also be
directed to the aforementioned address. Related documents are available for review
during normal business hours at the Division of Radiation Control, 168 N. 1950 W. Salt
Lake City, Utah. The draft Permit modification and the Statement of Basis is also
available on the internet at www.radiationcontrol.utah.gov
In compliance with the Americans with Disabilities Act, individuals with special needs
(including auxiliary communicative aids and services) should contact Brooke Baker,
Office of Human Resources at [phone] (TDD 536-4414) at least 10 working days
prior to close of the cornment period.
Permit No. UGW370004
STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALTTY BOARD
SALT LAKE CITY, UTAH 84114-4870
GROUND WATER DISCHARGE PERMIT
ln compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 17th Street
Denver, Colorado 80265
is granted a ground water discharge permit for the operation of a uranium milling and tailings
disposal facility located approximately 6 miles south of Blanding, Utah. The facility is located on a
tract of land in Sections 28,29,32, and 33, Township 37 South, Range 22Bast, Salt Lake Base and
Meridian, San Juan County, Utah.
The permit is based on representations made by the Permittee and other information contained in the
administrative record. It is the responsibility of the Permittee to read and understand all provisions
of this flpermit.
The milling and tailings disposal facility shall be operated and revised in accordance with conditions
set forth in the Ppermit and the Utah Ground Water Quality Protection Regulations.
This modified Ground Water Quality Discharge Permit amends and supersedes all other Ground
Water Discharge permits for this facility issued previously.
This lpermit shall become effective pn
This Epermit shall expire_\4arqh_8. 2018.
Signed this _ day of _, 2008
Co-Executive Secretary
Utah Water Quality Board
Table of Contents
PART I. SPECIFIC PERI\,I1r CONDITIONS...................................................................... I
A. CrrouxuWnr"rn Cl,rsstncl,t'toN I
B. BACIKC;Rot.tND WATER Ou",\LITY.................,.......................-..,".".....""..**..........,,,............... 2
C. PsRHrrr Lwrlrs )
L Ground Water Clor.npliance Lirnits ".""..."".........,"..........."....."......,............."....."................22. Tailings Cell Operations.........-."....,........."..............................................................."."""".".2
3. Prohibited f1iscliarees.....................................................................................................2
f). DrscHeRc;g MrxrMrzet'tox eNp Besl AverLasLE TucFINioLoc;v SI'RNDaltus................... 6
l. DMT Design Standards firr Hxisting Tailings Clells l. 2. and 3 "...."............................... 6
2. Existing Tailings Cell Construction Authorized ............................................................ 8
3. E"xisting Facility DMT Pcrtorrnance Stanclarc|s.............................................................. ll
-1. Best Available Technolog-,- Requirernenls lbr Ncrv Construction .....................,......... I I
5. BAT D$s!gn Stanclardl-fgr Tailings Cell 4A."............,...-".",...-....,..,..,..,,......,...,............... I I
6. BAT Pertbrntance Standarils fiir Tailings Cell =1A......."....."............"......................"..... l4
7. Del'initio:r oI lle.(2) Wasle..........................................."."........"........",......................... l4
8. Closecl CellPerlomrance Requjrements....................................................................... l4
9. Facilitr,Reclamation Requirements....................."........................................................ 15
10. Stormr,vater N,Ianagement and Spill Control Reqr.rireme nts.......................................... 15
I l. Reguirenrents ftir: Ireeclstock klateriill Stor"ed Outsicle the Feedstock Storage Area..... 15
E. GRouNo WlteR Corr,rpr-r,{Ncg axn Trcsxolocy Per.ronn_r.q,Ncs MoivrlpRrsc -."-........ l6
l. RoutineGroundrvaterCrintplianceL'Ionitoring............................................................ l6
2. Grounclwater Monitcring: Ionitoring Wells IVIW-20 :rnd MW-21..........................". l7
3. GrourJdwater Heiid i\[enitorin9......................,..,"...............-.,.,..."............................,..---l*$-
4. Groundwater Monitoring Well Design and Clonstrr"rction Criteriit............................... l8
5. Monitoring Proceclur:es for We]1s..............".""""..."."...".................".....,.........."................ l8
6. Whii.e Nlesa Seep and Spring N4onitoring..........................................-....................... l9
7. f)MT Performance Standard Monitoring,..................................."................................ l9
8. BAT Perfbrnrancc Standard Monitoring......................................................................2l
9. On-site Chernicals lnventor.v .........................................................."".......".................... 22
10. Tailinss Celi Wastewater Oualitv Monitorin{:'r'l
I l. Groundwater Monitorins l\{oclifications .".................................................................... 23
F. REponttxc Rr:eumauENrs......,........................................................................................23
I . Rclutine Grrl.inclwater Monittxing Reporis............................................-*................... 23
2. Routine DX'IT Perfonnance Stanclarri Ntonitoring Report.."......................................... 2-l
3. Routine BAT Pertbr-rnance Standard Monitoring Reports........................................... 24
4. DMT and BAT Per rmance Upset Reports..............,,.-...-.....".."...............................25
6. Groundwatcr Monitoring Well As-Built Reports..........."...........,.........,............,.......... 25
7. White lvlesa.teeps and Sprin$s iVlonitoring Reports.................................................... 26
8. Chemi!:als lnventory Reporl...............................................................".................."......26
9. Tailings CellWastcwater Ouality Reports................................................................... 26
i0. I{.cviseci H}'clre$:ologic Report....................................................................................27
I l. Annuill S.limes f)rain Recovery'Head Reporl....................."...........,"....,..........,.............27
Ci. Ou"r or Ctirl,u,lraNcn Srarus..........................."................................................................ 27
I . Accelerate d Mouitoring Status ..................................... "...."...................,.........,....,....... 28
2. Violation ol Perniit Lirlits -.............."."....""."..."..".."....."........".......,...,.......,...................283. Fai_lure to lv{nintain Dlv{A.or BAT Recluired bLPennit................................................ 28
4. Facility Out of Compliance Status ............................................................................... 29
t
l. On-site Clhemicals Inventon, R
2. Infjltration and Contarninant Transport Modeling Work Plan ancl Report ...........:...... 33
4. Supplemental lsol.opic (]roundwater and Surllce Wgl.er Investigillion and Reporl..... 36
5. Ncw Dccontanrination Pad..................,........................................................................37
6. E-ristin&Deconlamination Pad.....................................................................................38
PART lI. REPORTING REOUIREMENTS...................*...-.."............"..."......,*...*......... :l!)A. RrpnsspsrATrvESnun-wc..39B. ANal"v1rc,q1Pnocenunps. ............................................................................................... 39C. PnN,u,nns rcln TaupERrNc......................................................"........................................ 39ll. RnpoRrmc or MoNrrorwc Rssui-rs............................................................................... 39
E. Col,tpLr.qNC:uSr:uEor;r-us 39F;. Apurrr<tr,,u.lr,loxrrontN<; llt tun PnRmrrrnn............."."....................,............................. 39Ci. Rrr:onos Cr:NJpN:rs.......................................................................................................... 39H. RrrrNrloN orr Rrconns............................................................................................."...... 39
l. lrtrottcrol.NoNc<)Mpt"tANCI:Rlrprx'rrNr;
J. OrlraR NoNcor,rpr.rANCriRr.poRlllc
40
K" lusprctlt-lx lNn Exrny.........40
PART IIL COMPLTANCE RESpONSIBILITIES................................................................4lA. Du'ry -rr: Cc1lrpr.y.........................."....................................,.............."."............................. 4 IB. PnxaLTtgs_pon_Vror-={noNs orPr,Rutr CosomoNs ............,....................................._.... 4lC. Nuep'ro HaLr'oR REplrcE Ac'rrvrly xol e DsFpxsE...................................................... 4l
D. Dulv'roMrlr(;,,1'r'E 4lE. PRopnR OpnR,qrr:N aNn M.ArN:fnxnNC8..,.......................=.............................................. 4l
PART IV. GENERAL REOUTREMENTS ..................""...................................................... 42A" Pt-rrNr.,-En Cnl;:r.-<;ES "..............."."."........................................,......"...................................".. 42B. Axrrcrplrrn Nr:xcotvtpl.tnxr:n................................................................................"........ :12
C. PrnH,rrr Acrrorvs...................................................................,.........................................".. 42
D. Dr;'l'y'r0 Rslpl,Ly ' t1
E. Dt;'t'v'l'o PrrorrroE lxrrxivalloN
C. Src;Natony Rser;rneprss1s..............................................................................................42
H. PgN;rt-Tms xrR [:al.sll"lc.tltoN tx,Rnponts........................".".".......................................,.43
J. PRopsxrv Rrc;srs
4?
43
43
List of Tables
Tabie 5. ;\pproved Tailings Cell4A Engineering Design anci Specifications............................. 1l
Table 6. Croundwater N,Ionitorin8l Reporting ScheduIe...............................................................23
o
Part I
Permit No. uGW370004
PART I. SPECIFIC PERMIT CONDITIONS
A. GnouND WATER Cr-assrrcarloN - the ground-water classification of the shallow aquifer under
the tailings facility has been determined on a well-by-well basis, as defined in Table 1, below:
Footnotes:
I t N = Nunthr:rof Sutrrlos
4;2) Based on historic total dissolved solids (TDS) data provided by $e -Perminee for period between October, 1979 and Dccernlxr, 2{}1)7*4q,
Table 1. Ground Water Classification
Class II Groundwater
Avc'rage l'DS (nrg/L)
DLISA Data
el#U II,I Groqndwater
Arerage]'DS (rrrs/L)
DLISA Data
Well
ID N(,
Average
(loncentration':)
Standmd
f)evia'tiur(:'lVell ID Nl'l)
Averaee
Crincentratior-r'2)
Stanriard
Dr:viati<x(l'
MW-1 +aq6t.2'73 93 MW-2 "77 3$3+3,050 252
MW-5 82 ]{l&+1.05s r70 MW-3 7li .#.005.217 263
MW-
llM{v-
++
rl -i&41'.8J4 178 MW-12 6t 1.8%;#3e :-t1
N,IW-
3QMi#-la
r0 lJAt2#4>87 MW-14 5l :=5{+3191 176
N.lW
-14$]
)#7 I MW-15 A1 3=+is53.8"57 :-13
MW*
-, ,r5r+U
21+73.+MW-17 12 4538{J44 321
MW-
1g(4])
l8 2,60>+297
MW-
l9o-r)
22 2,457 900
lv{W
20(1)M{AL
?0?
l 5"6 r0 57
MW-
22Q5)
-)*x)57.365 36r
MW-3A I 5.547 l]9
MW-23 I 3.443 214
MW-24 l0 4,1t6 t17
MW-
25(:0)
ll 2,84?_2 {1
MW-
26@:t
12 Lr55w{i 65
MW-
ZTCs)
l0 1,019 l8
MW-28 I 87
MW-29 o 4,380 27
MW-
3 lGn)
r0 1,26s 50
MW-
32tE*)
12 3+e0ii69 :4 I
Part I
Permit No. UGW370004
i)B**etl'txrw**tgs<*-DR6*pli+stur+ple*collee+ctl{rtrxr+}re"lVhile lVle**x{}i+y*rer*ec**kyi$gr}.lzui.8egexrbe+l,3$0}
i$"*.J+"1) Backgre-qnrl-smr.ea&trqrs p"Lu13urum-Ln s,e]llr-rill$,L15..l..ir g/t)
ancllhalliunrinMW-19{2.lpg,'L)exceodthe GWQS.30.uu/l-and2.0pgll:respectir.ell-- Tircrltblcthesew'elishavchrrcnclassilieda.s
C'lass III gltilndwater rathrr lhan Class IT.sr'rrintlwater. .
ill) Wells MW-20 and MW-22 are not point df compliance monitoring wells. but instead are groundwater head monitoring wells as per Part I.8.2.
rnti 3"i Ouarters ol'1008 Routine Grounrlwater N'loritoring Rerx*tr.
lll gts:nn$::":*ei.r3$l$l jhaL(:iilr li gr-e,!1lrd}-l"3}Lr.T,
6) Well MW-26 was originally named TW4-15 and was installed as i|"part of thca:-ieoe+rlchloroform contaminant investigation at the facility.
Under this Permit, MW-26 is defined as a Point of Compliance (POC) well for the tailings cells (see Part I.8.1).
Itave tretn (:lirlsilled as Cllss lll trounclwater rather than Chss lI !:toundwatel. -s)
eil
MW-32 was originally named TW4-17 and was installed as.r-part of a-+*:e**.!1e,,-chloroform contaminant investigation at the facility. Under
this Permit it is included as a POC well for the tailings cells in Part I.E. l.
B. BACKGROUNDWATERQUALITY-basedongroundwatersamplescollectedtlrroughAugust200T"
the uppqr boundar-v o1'background groundwater quality jgvi+lb+-determined on a well-by-well
basis,;as oursuant to
Envircnrriental Protection Agency (EPA) suidance. and docurnented in the Permittee's
background groundwater quality reports dated October 2007 - and
-April
-i0.
?gg8-
i*+a{*ts"
C. PnnutrLmns - the Permittee shall comply with the following permit limits:
1. Ground Water Compliance Limits - contaminant concentrations measured in each monitoring' well shall not exceed the Ground Water Compliance Limits (GWCL) defined in Table 2,
below. Ground-water quality at the site must at all times meet all the applicable GWQS and
ad hoc GWQS defined in R317-6 even though this permit does not require monitoring for
each specific contaminant.
2. Tailings Cell Operations - only Il.e.(2) by-product material authorized by Utah Radioactive
Materials License No. UT-2300478 (hereafter License) shall be discharged to or disposed of
in the tailings ponds.
3. Prohibited Discharges - discharge of other compounds such as paints, used oil, antifreeze,
pesticides, or any other contaminant not defined as 1le.(2) material is prohibited.
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Part I
Permit No. UGW370004
D. DtscuaRce MINnaIzATIoN lNo Besr AvaLasr-B TBcuNor-ocy SrRuoaRDS - the tailings
disposal facility must be built, operated, and maintained according to the following Discharge
Minimization Technology (DMT) and Best Available Technology (BAT) standards:
l. DMT Design Standards for Existing Tailings Cells l, 2, and 3 - shall be based on existing
construction as described by design and construction information provided by the permittee,
as summarized in Table 3 below for Tailings Cells 1, Z, and3:
Table 3 DMT E
Footnotes:
4)
l) D'Appolonia Consulting Engineers, Inc., June, 1979, "Engineers Repon Tailings Management System White Mesa Uranium project
Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpublished consultants report, approximately 50 pp., 2 figures, l6 sheets, 2appendices.2) D'Appolonia Consulting Engineers, Inc., February, 1982, "Construction Report Initial Phase - Tailings Management System White MesaUranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpublished consultints ."pJn, upp.o^i1r1utely 7 pp., 6 tables,l3 figures, 4 appendices.
D'Appolonia Consulting Engineers, Inc., May, 1981, "Engineer's Report Second Phase Design - Cell 3 Tailings Management System WhiteMesa Uranium hoject Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpubiished consultanti report, -approximately 20 pp., Ifigure, 5 sheets, and 3 appendices.
Energy Fuels Nuclear, Inc., March, 1983, "Construction Report Second Phase Tailings Management System White Mesa Uranium project
Energy Fuels Nuclear, Inc.", unpublished company report, l8 pp., 3 tables,4 figures, 5 appendices.
a) Tailings cell I :- consisting of the following major design elements:
1) Cross-valley Dike and East Dike ;- constructed on the south side of the pond of
native granular materials with a 3:1 slope, a 20-foot crest width, and a crest elevationof about 5,620 ft above mean sea level (amsl). A dike of similar design was
constructed on the east margin of the pond, which forms a continuous earthen
structure with the south dike. The remaining interior slopes are cut-slopes at 3:l
grade.
Liner System - including a single 30 mil pvc flexible membrane liner (FML)
constructed of solvent welded seams on a prepared sub-base. Top elevation of the
FML liner was 5,618.5 ft amsl on both the south dike and the north cut-slope. A
protective soil cover layer was constructed immediately over the FML with a
thickness of l2-inches on the cell floor and l8-inches on the interior sideslope.
Crushed Sandstone Underlay;- immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
-Beneath this underlay, native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
lnside this layer, an east-west oriented pipe was installed to gather fluids at the
2)
3)
a n$neenn Desisn and fications
Tailings
Cell
Report
Tvoe Ensineerins Reoort Desisn Fipures
Construction
Specifications
Cell 1 Pesign June, 1979 D'Appolonia
Consulting Engineers, Inc (l)Appendix A, Sheets 2,4,8,
9,12-15
Appendix B
Cell2 Design June, 1979 D'Appolonia
Consulting Engineers. Inc (r)Appendix A, Sheets 2,4,7-
10, t2-15
Appendix B
As-Built February, 1982 D'Appolonia
Consulting Engineers, Inc (2)
Figures 1,2, and ll N/A
Cell3 Design May, 1981D'Appolonia
Consulting Engineers, Inc (3)
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear. Inc. (a)
Figures l-4 N/A
t
Part I
Permit No. UGW370004
upstream toe of the cross-valley dike.
b) Tailings Cell2;- which consists of the following major design elements:
1)Cross-valley Dike -:* constructed at the south margin of Cell 2 of native granular
materials with a 3: I slope, a 20-foot crest width, and crest elevation of about 5,615 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3:1 grade. The
Cell 1 south dike forms the north margin of Cell 2, with a crest elevation of 5,620 ft
amsl.
Liner System ;- includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. TopelevationoftheFMLlinerinCell2is5,615.0ftand5,6l3.5ftamslon
the north and south dikes, respectively. Said Cell2 FML liner is independent of all
other disposal cell FML liners. Immediately above the FML, a nominal 12-inch (cell
floor) to 18-inch (inside sideslope) soil protective blanket was constructed of native
sands from on-site excavated soils.
Crushed Sandstone Underlay;- immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
-Beneath this underla), native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
Slimes Drain Collection System immediately above the FML a nominal 12-inch thick
protective blanket layer was constructed of native silty-sandy soil. On top of this
protective blanket, a network of 1.5-inch PVC perforated pipe laterals was installed
on a grid spacing interval of about 5O-feet. These pipe laterals gravity drain to a 3-
inch diameter perforated PVC collector pipe which also drains toward the south dike
and is accessed from the ground surface via a 24-inch diameter, vertical non-
perforated HDPE access pipe. Each run of lateral drainpipe and collector piping was
covered with a 12 to l8-inch thick berm of native granular filter material. At cell
closure, leachate head inside the pipe network will be removed via a submersible
pump installed inside the 24-inch diameter HDPE access pipe.
c) Tailings Cell 3 -- consisting of the following major design elements:
Cross-valley Dike :- constructed at the south margin of Cell 3 of native granular
materials with a 3:1 slope, a 2O-foot crest width, and a crest elevation of 5,610 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3:1 grade. The
Cell2 south dike forms the north margin of Cell 3, with a crest elevation of 5,615 ft
amsl.
Liner System ; includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 3 is 5,613.5 ft and 5,608.5 ft amsl on
the north and south dikes, respectively. Said Cell 3 FML liner is independent of all
other disposal cell FMI liners.
Crushed Sandstone Underlay; immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
2)
3)
4)
l)
2)
3)
o
Part I
Permi
2.
t No. UGW370004
-Beneath this underlay, native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System; immediately above the FML, a nominal
12-inch (cell floor) to l8-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils (707o) and dewatered and
cyclone separated tailings sands from the mill (307o). On top of this protective
blanket, a network of 3-inch PVC perforated pipe laterals was installed on
approximately 50-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a 12-inch diameter, inclined HDPE access pipe.
-Each run of the 3-inch lateral drainpipe and collector pipe was covered with a 12 to
l8-inch thick berm of native granular filter media. At cell closure, leachate head
inside the pipe network will be removed via a submersible pump installed inside the
l2-inch diameter inclined access pipe.
Existing Tailings Cell Construction Authorized;* tailings disposal in existing Tailings Cells
1,2, and 3 is authorized by this lpermit as defined in Table 3 and Part LD.l, above.
Authorized operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authorized by the License. Under no circumstances shall the
freeboard be less than three feet, as measured from the top of the FML. Any modification by
the Permittee to any approved engineering design parameter at these existing tailings cells
shall require prior Executive Secretary approval, modification of this Permit, and issuance of
a construction permit.
Existing Facility DMT Perfornance Standards - the Permittee shall operate and maintain
certain mill site facilities and the existing tailings disposal cells to minimize the potential for
wastewater release to groundwater and the environment, including, but not limited to the
following additional DMT compliance measures:
a) DMT Monitoring Wells at Tailings Cell I :-,at all times the Permittee shall operate and
maintain Tailings Cell 1 to prevent groundwater quality conditions in any nearby
monitoring well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit.
b) Tailings Cells 2 and 3 ;- including the following performance criteria:
I ) Slimes Drain Maximum Allowable Head;- the Permittee shall at all times maintain
the average wastewater recovery head in the slimes drain access pipe to be as low as
reasonably achievable (ALARA) in each tailings disposal cell, in accordance with the
currently approved DMT Monitoring Plan.
2) Monthly SIimes Drain Recover.v Test -- the Pennittee shall conduct a monthly slimes
drain recovery tcst at each tailings cell slirnes drain that meets the tbllowing
minimum requirements:
i. Includes a duration of at least 9O-hours. as measured from the tirne that pumping
ceases. and
J.
Part I
Permit No. UGW370004
ii. Achieves a stable water level at the end of the test. as rneasured by three
consecutive hourly water level depth measurements. with no change in water
level, as measured to the nearest 0.01 fbot.
3) Annual Slinies Drain Compliance - shall be achieved when the average annual
wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to -the curently approved DMT Monitoring Plan, meets the conditions in Equation
l, below:
Equation 1:
lIEv+fEy-r+fEy-zJi[Nr+Ny-r*Ny-zJ<[IEv-r+lEr-z+fEy-r]/[Ny-r+Ny-z+Ny-rJ
Where:
IE, = Sum of all rnonthly slimes drain tailings fluid elevation measurements that meet the test
pertbrmance standa.rds found in Part l.D.-l(b)(2).
ee$ee+e+{*ing{Ud!&the calendar year of interest. Hereafter, these water level measurements are
referred to as slimes drain recovery elevations (SDRE). Pursuant to the Q!"UreJitly approved DMT
Monitoring Plan, these recovery tests are to be conducted monthly and the SDRE values reported in
units of feet above mean sea level (amsl).
IEy_r = Sum of all SDRE measurements made in the year previous to the calendar yelr of
interest.
IEy-z = Sum of all SDRE measurements made in the second year previous to the calendaryearof
interest.
IEy_: = Sum of all SDRE measurements made in the third year previous to the calendar year of
interest.
Ny = Total number of SDRE @ests that meet the test performirnce
standards tound in Part I.D.3(bi(2). conducted during the calendar year of interest.
Ny-r = Total number of SDRE @ests that meet the test performance
standards ibund in Part I.D.3(bX2). conducted in the year previous to the calendar year ofinterest.
Ny_z = Total number of SDRE @ests that meet the test periormance
standards fbund in Part I.D.3(bX2). conducted in the second year previous to the calendar year of
interest.
N.-e = Total number of SDRE @ests that meet the test pedbrmance
standarcls found in Part LD.36X2). conducted in the third year previous to the calendar year of
interest.
Prior to January l,%++U13, the following values for E and N values in Equation -1
shall be based on SDRE data from the following calendar years.
Report for
Calendar
Year
St'rtu'ce of Data Bv Ctrlendar Year lor Equatiort I Variables (r'isht siile)
E.E.E.,,N,,\l
20082010 30072009 20+72009 20{}9 4)W2009 x+72009 200e
2009201 I 20082010 20072009 20{lg 20082010 20072009 2009
x1$u)2 200920r I 200820r0 :009 20s9?sr-02q1
I
200820r0+2009
9
O
Part I
Perm
c)
d)
it No. UGW370004
Failure to satisfy conditions in Equation I shall constitute DMT failure and non-
compliance with this Permit. For Cell 3, this requirement shall apply after initiation of
de-watering operations.
Maximum Tailings Waste Solids Elevation ;- upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailings waste solids does not
exceed the top of the FML liner.
DMT Monitoring Wells;- at all times the Permittee shall operate and maintain Tailings
Cells 2 and 3 to prevent groundwater quality conditions in any nearby monitoring well
from exceeding any Ground Water Compliance Limit established in Table 2 of this
Permit.
Roberts Pond ;-_the Permittee shall operate this wastewater pond so as to provide a
minimum 2-foot freeboard at all times. Under no circumstances shall the water level in
the pond exceed an elevation of 5,624 feet amsl. In the event that the wastewater
elevation exceeds this maximum level, the Permittee shall remove the excess wastewater
and place it into containment in Tailings Cell I within 72;hours of discovery. At the
time of mill site closure, the Permittee shall reclaim and decommission the Roberts Pond
in compliance r,r,ith a the*final Reclamation Plan approved under the License (hereafter
Reclamation Plan).
Feedstock Storage Area ;--open-air or bulk storage of all feedstock materials at the
facility awaiting mill processing shall be limited to the eastern portion of the mill site
area described in Table 4, below. Storage of feedstock materials at the facility outside
this area, shall meet the requirements in Part I.D.1 1. At the time of mill site closure, the
Permittee shall reclaim and decommission the Feedstock Storage Area in compliance
with an approved Reclamation Plan.
Coordinates(r)
Footrrote:
1) Approximate State Plane Coordinates beginning from the exaeme northeast comer and progressing clockwise around
the feedstock area (fuom 612210l *i+- P-l.rSA Response, Attachment K, Site Topographic Map, Revised June, 2001.)
Mill Site Chemical Reagent Storage;* for all chemical reagents stored at existing storage
facilities and held for use in the milling process, the Permittee shall provide secondary
containment to capture and contain all volumes of reagent(s) that might be released at
any individual storage area. Response to spills, cleanup thereof, and required reporting
shall comply with the provisions of1fu approved Emergency Response Plan as found in
Plan
e*lthis'Ser**+. For any new construction of reagent storage facilities, said secondary
10
e)
4. Feedstock Storase Area
Corner Northine (ft)Eastins (ft)
Northeast 323,595 2.580.925
Southeast 322.140 2,580,920
Southwest 322,140 2.580.420
West I 322.815 2,580,410
West 2 323.040 2,580,085
West 3 323.t20 2,580,085
West 4 323.3r5 2.580.285
West 5 323,4t5 2,579,990
Northwest 323,600 2.579.990
able
g)
4.
r No. UGW370004
containment and control shall prevent any contact of the spilled or otherwise released
reagent or product with the ground surface.
Best Available Technology Requirements for New Construction -* any construction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facilities shall require submittal of engineering design plans and specifications, and prior
Executive Secretary review and approval. All engineering plans or specifications submitted
shall demonstrate compliance with all Best Available Technology (BAT) requirements
stipulated by the Utah Ground Water Quality Protection Regulations (UAC R317-6). Upon
Executive Secretary approval this Permit may be re-opened and modified to include any
necessary requirements.
BAT Design Standards for Tailings Cell 4,A. - the BAT design standard for Tailings Cell 4A
shall be defined by and construction conform to the requirements of the June 25,2007
Executive Secretary design approval letter for the relining of former existing Tailings Cell
No. 4,{, and as summarized by the engineering drawings, specifications, and description in
Table 5, below:
o
Part I
Permi
5.
able 5. Approved Tailinss Cell4A Ensineerins Desisn and Specifications
Enqineering Drawings
Name Date Revision
No.
Title
Sheet I of7 June.2007 Title Sheet
Sheet 2 of 7 June 15,2007 Rev. I Site Plan
Sheet 3 of7 June 15,2007 Rev. I Base Gradins Plan
Sheet 4 of 7 June 15, 2007 Rev. I Pioe Lavout Plan
Sheet 5 of7 June 15.2007 Rev. I Linins System Details I
Sheet 6 of 7 June 15- 2007 Rev. I Linins Svstem Details II
Sheet 7 of 7 June 15,2007 Rev. I Linine Svstem Details Itr
Fipure I August. 2{X)8 Spillwav Splash Pad Anclror
Ensineerins Snecifi cations
Date Document Title Prepared bv
June,2007 Revised Technical Specifications for the
Construction of Cell 4,A. Linins Svstem
Geosyntec Consultants
June,2007 Revised Construction Quality Assurance Plan
for the Construction of Cell 4,{ Linins Svstem
Geosyntec Consultants
March 27,2007 Revised Geosynthetic Clay Liner Hydration
Demonstration Work Plan (l)Geosyntec Consultants
November 27,2006 Cell Seismic Study (z)MFG Consulting
Scientists and Engineers
October 6,2006 Calculation of Action Leakage Rate Through
the Leakage Detection System Underlying a
Geomembrane Liner
Geosyntec Consultants
June22,2006 Slope Stability Analysis Cell4,A';- Interim
Conditions
Geosyntec Consultants
Jlune23,2O06 Settlement Evaluation of Berms ("Geosvntec Consultants
August 22,2006 Pipe Strensth Calculations Geosyntec Consultants
1t
o
Pa
Pe
rtI
rmit No. UGW370004
1) As qualified by conditions found in May 2, 2007 Division ofRadiation control letrer.2) As clarified by February 8, 2007 Division of Radiation Control Round 6 Intenogatory.
a)
b)
Tailings Cell 4,A Design and Construction;- approved by the Executive Secretary will
consist of the following major elements:
Dikes:* consisting of existing earthen embankments of compacted soil, constructed by
the Permittee between 1989- 1990, and composed of four dikes, each including a l5-foot
wide road at the top (minimum). On the north, east, and south margins these dikes have
slopes of 3H to lV. The west dike has an interior slope of 2H to lV. Width of these
dikes varies, qEach has a minimum crest width of at least 15 feet to support an access
road. *Base width also varies from 89-feet on the east dike (with no exterior
embankment), to 271-feet at the west dike.
Foundation ; including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90Vo. Floor of Cell 44 has an average slope
of lVo that grades from the northeast to the southwest corners.
Tailings Capacity;* the floor and inside slopes of Cell 4,{ encompass about 40 acres and
have a maximum capacity of about 1.6 million cubic yards of tailings material storage (as
measured below the required 3-foot freeboard).
Liner and Leak Detection Systems;- including the following layers, in descending order:
1) Primary Flexible Membrane Liner (FML) ;- consisting of impermeable 60 mil high
density polyethylene (HDPE) membrane that extends across both the entire cell floor
and the inside side-slopes, and is anchored in a trench at the top ofthe dikes on all
four sides. The primary FML will be in direct physical contact with the tailings
material over most of the Cell 4,A' floor area. In other locations, the primary FML
will be in contact with the slimes drain collection system (discussed below).
lrak Detection System -- includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4,{, and drains to a leak
detection sump in the southwest corner. Access to the leak detection sump is via an
l8-inch inside diameter (ID) PVC pipe placed down the inside slope, located between
the primary and secondary FML liners. At its base this pipe will be surrounded with
a gravel filter set in the leak detection sump, having dimensions of 10 feet by 10 feet
by 2 feet deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to serve as a
filter.
Secondary FML;--consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends across the
entire Cell 4,{ floor, up the inside side-slopes and is also anchored in a trench at the
top ofall four dikes.
Geosynthetic Clay Liner ;* consisting of a manufactured geosynthetic clay liner
(GCL) composed of O.2-inch of low permeability bentonite clay cenrered and stitched
between two Jayers of geotextile. Prior to disposal of any wastewater in Cell 44, the
c)
d)
2)
3)
4)
t2
o
Part I
Permit No. UGW370004
' Permittee shall demonstrate that the GCL has achieved a moisture content of at least
507o by weight. This item is a revised requirement per DRC letter to DUSA dated
September 28,2007,
e) Slimes Drain Collection System ; including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
1)Horizontal Strip Drain System;- is installed in a herringbone pattern across the floor
of Cell 44 that drain to a "backbone" of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed immediately over the primary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection pipe. A
series of continuous sand bags, filled with filter sand cover the strip drains. The sand
bags are composed of a woven polyester fabric filled with well graded filter sand to
protect the drainage system from plugging.
Horizontal Slimes Drain Collection Pipe System ;- includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC) pipe
found at the downgradient end of the strip drain lines. This pipe is in turn overlain by
a berm of gravel that runs the entire diagonal length of the cell, surrounded by a
geotextile fabric cushion in immediate contact with the primary FML. In turn, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter
material. This perforated collection pipe serves as the "backbone" to the slimes drain
system and runs from the far northeast corner downhill to the far southwest corner of
Cell 44. where it joins the slimes drain access pipe.
Slimes Drain Access Pipe ;- consisting of an l8-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell 44' at the southwest corner, above the primary
FML. Said pipe then merges with another horizontal pipe of equivalent diameter and
material, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the primary FML. A reducer connects the horizontal 18-inch pipe
with the 4-inch SDC pipe. At some future time, a pump will be set in this l8-inch
pipe and used to remove tailings wastewaters for purposes of de-watering the tailings
cell.
North Dike Splash Pads 5 three 20-foot wide splash pads will be constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads will consist of an extra layer of 60 mil HDPE membrane that will be installed
in the anchor trench and placed down the inside slope of Cell 4,{, from the top of the
dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
Emergency Spillway 1- o concrete lined spillway will be constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4,{. This
spillway will be limited to a 6-inch reinforced concrete slab set directly over the primary
FML in a 4-foot deep trapezoidal channel. No other spillway or overflow structure will
be constructed at Cell 4A. All stormwater runoff and tailings wastewaters not retained in
2)
3)
s)
l3
o O
Part I
Permit No. UGW3700O4
Cells 2 and 3, will be managed and contained in Cell 4,A., including the Probable
Maximum Precipitation and flood event.
6. BATPerformance Standards forTailings Cell4,A.;-thePermittee shall operate andmaintain
Tailings Cell 4,A' so as to prevent release of wastewater to groundwater and the environment
in accordance with the currently approved Cell -lr\ BAT Monitoring Operations and
Maintenance Plan.
performance standards shaH-includeil_hq-ft{,!-alrulg
a) Leak Detection System (LDS) Maximum Allowable Daily Head; the fluid head in the
LDS shall not exceed I foot above the lowest point on the lower flexible membrane liner
on lhe cell ilopr. Forpurposes o{'cornpliance this elevatiun r.r'ill cqu+tc to I maxinrunr
distance of 2.28 feet above the [,DS transducer. At all tinres $e-Per:rnittee shall_operare
tlte LDS purnp ancl transclucer in a horizontal position at thc lowcst point of the L[)S
s u ntp fl oor{r*wer-*nexlbrttne-}i**r".
b) LDS Maximum Allowable Daily lrak Rate;- shall not exceed 24,160 gallons/day.
Slimes Drain Monthly and Annual Average Recovery Head Criteria _* after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4A, the Permittee will
provide; licontinuous declining fluid heads in the slimes drain layer, in a manner
equivalent to the requirements found in Part I.D.3(b)., and 2) a rnaxin h
in the tailings (as rneilsured fronr the lowest point of upper flexible rnembl'anc liner) in
6.4 yeiirs or less.
Maximum Weekly Wastewater Level - -under no circumstance shall the freeboard be
less then 3-feet -in Cell 44, as measured from the top of the upper FML.
Definitionof IIa(2)Waste.*forpurposesof thisPermit, lle.(2)wasteisdefinedas: "...
tailings or wastes produced by the extraction or concentration of uranium or thorium from
any ore piocessed primarily for its source material content", as defined in Section 11e.(2) of
the U.S. Atomic Energy Act of 1954, as amended; which includes other process related
wastes and waste streams described by a March 7,2003 NRC letter from Paul H. Lohaus to
William J. Sinclair.
Closed Cell Performance Requirements -- before reclamation and closure of any tailings
disposal cell, the Permittee shall ensure that the final design, construction, and operation of
the cover system at each tailings cell will comply with all requirements of an approved
Reclamation Plan, and will for a period of not less than 200 years meet the following
minimum performance requirements :
a) Minimize infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barriery; a*tl
Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML liner elevation internal to any disposal cell, i.e.
create a "bathtub" effect. and,
Ensure that groundwater quality at the compliance monitoring wells does not exceed the
Ground Water Quality Standards or Ground Water Compliance Limits specified in Part
LC.1 and Table 2 of this Permit.
c)
d)
7.
8.
b)
c)
t4
o
Part I
Permi t No. UGW370004
9. Facility Reclamation Requirements ;- upon commencement of decommissioning, the
Permittee shall reclaim the mill site and all related facilities, stabilize the tailings cells, and
construct a cover system over the tailings cells in compliance with all engineering design and
specifications in an approved Reclamation Plan. The Executive Secretary reserves the right
to require modifications of the Reclamation Plan for purposes of compliance with the Utah
Ground Water Quality Protection Regulations, including but not limited to containment and
control of contaminants, or discharges, or potential discharges to Waters of the State.
10. Stormwater Management and Spill Control Requirements:- the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with -the currently approved Stormwater Best Management Practices Plan. Said
plan includes the following minimum provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R3l7-6-6.3(G) and R317-6-6.4(C),
b) Prevent, control and contain spills of stored reagents or other chemicals at the mill site,
c) Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery, aucl
d) Report reagent spills or other releases at the mill site to the Executive Secretary in
accordance with UAC 19-5-114.
Reconstruction of stormwater management and/or chemical reagent storage facilities,
existing at the time of original Permit issuance, may be required by the Executive Secretary
after occurrence of a major spill or catastrophic failure, pursuant to Part IV.N.3 of this
Permit.
Dl#Fl_l-__ BAt Requirements for Feedstock Material Stored Outside the Feedstock Storage
Area _--the Permittee shall store and manage feedstock materials outside the ore storage pad
in accordance wi
pernxr.U* tne folowin
a) Feedstock materials will be stored at all times in water-tight containers. and
b) Aisle ivayr will be pi'ovided at all tim
feedstock container. or
c) Each 4frd every f-eedstock contjriner will be placed inside a water-tight overpack prior tLr
storilgc. or
dt Feedstock containers shall bc storcd on a haldened surfhcc to prevent spillage onto
subsr"rrlace soils. and that confonns ,uvith the killor,ving nrinimun, physical requirements:
I ) 4 storage area composed of a hrrrdenecl engineered sr-u:facQ of asphalt or concrete. and
2) A storage area desisned. constructed. and operated in accordance with cnginccring
plans ancl speciilcations approved in advance by the llxecutive Secretar:r-. All such
engineering plarl,l o"r specil'ications subnritteii shall rleniqns.tr:ate col,llpli!U.l:^e with Part
LD.-l. and
3 ) A storage area that Drovidcs coiltainmcnt bcrms to contrcll stofnl\,viiter rlrn-on and
run-off'. and
15
o
Part I
Permit No. UGW370004
4) Stqrrnwtrter drainage works approved in advance by the Executive Secretary. or
5) Otlrel storage facilities and nreans approvecl in advance by the Executive Secretarr-.
E. GnouNo Waren CoN4PLIANCE AND TEcHNoLocy PERFoRMANCE MoNrroRrNG -; beginning with
the effective date and lasting through the term of this Rpermit or as stated in an approved closure
plan, the Permittee shall sample groundwater monitoring wells, tailing cell wastervaters, seeps
anri springs. monitor groundwater levels, monitor water levels of process solutions, and monitor
and keep records of the operation of the facility, as follows:
l. Routine Groundwater Compliance Monitoring 5 the Permittee shall monitor upgradient,
lateral gradient, and downgradient ground-water monitoring wells completed in the shallow
aquifer in the vicinity of all potential discharge sources that could affect local groundwater
conditions at the facility, as follows:
Ground Water Monitoring Quality Assurance Plan;- all groundwater monitoring and
analysis performed under this Permit shall be conducted in accordance with a Quality
Assurance Plan (QAP) currently approved by the Executive Secretary. Any non-
conformance with QAP requirements in a given quarterly ground*water monitoring
period will be corrected and reported to the Executive Secretary on or before submittal of
the next quarterly ground-water monitoring report pursuant to Part I.F.1.
Quarterly Monitoring;* the Permittee shall monitor on a quarterly basis all monitoring
wells listed in Table 2 of this Permit where local groundwater average linear velocity has
been found by the Executive Secretary to be equal to or greater than 10 feet/year. For
purposes of this Permit, quarterly monitoring is required at the following wells:
l) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-l1, MW-14, N,IW-2.1. MW-25. MW-26
(formerly TW4-15), N{W-30. and N,IW-.3l.tUW 3a gormei.ly
c) Semi-annual Monitoring ;- the Permittee shall monitor on a semi-annual basis all
monitoring wells listed in Table 2 of this Permit where local groundwater average linear
velocity has been found by the Executive Secretary to be less than 10 feet/year. For
purposes of this Permit, semi-annual monitoring is required at the following wells:
1) Upgradient Wells: MW-I, MW-18, MW-19. and MW-27;.
2) Lateral or Downgradient Wells: MW-2, MW-3, MW-3A. MW-5, MW-12, MW-15,
an+MW-17, MW-23, MW-2[], MW-29, and MW-32 (fbrnrerly TW4-17).
d) Compliance Monitoring Parameters ;- all groundwater samples collected shall be
analyzed for the following parameters:
-$*Field Parameters ._*depth to groundwater, pH, temperature, *ne!*specific
conductance, and redox poter .
u_
2) ?|*Laboratory Parameters
a)
b)
t6
Part I
Permit No. UGW370004
i. GWCL Parameters;- all contaminants specified in Table 2.
ii. General Inorganics 3_chloride, sulfate, carbonate, bicarbonate, sodium,
potassium, magnesium, calcium, and total anions and cations.
e) Special Provisions for Groundwater Monitoring _- the Permittee shall ensure that all
groundwater monitoring conducted and reported complies with the following
requirements:
1) Depth to Groundwater Measurements:- shall always be made to the nearest 0.01
foot.
Minimum Detection Limits;- all groundwater quality analyses reported shall have a
minimum detection limit or reporting limit that is less than its respective Ground
Water Compliance Limit concentration defined in Table 2.
Gross Alpha Counting Variance:*Agll gross alpha analysis 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 than2UVo of the
reported activity concentration. An error term may be greater than 20Vo of the
reported activity concentration when the sum of the activity concentration and error
term is less than or equal to the GWCL.
All equipment used for purging and sampling of ground-water shall be made of inert
materials.
2. Groundwater Monitoring: Monitoring Wells MW-20 and MW-22;- Starting with the l't
Quarter 2008 groundwater event the Permittee shall implement a quarterly groundwater
sampling program. Said sampling shall comply with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part I.E.l,
b) Well monitoring procedure requirements of Part I.E.5.
After completion of eight (&|consecutive quarters of groundwater sampling and analysis of
MW-20 and MW-22, the Permittee shall submit a Backglound rR.eport that will include:
I ) Dilto preparation ancl statistical apalysis ol grouldwater qualit.v data. incluciing
treatrlrelt of nog-detectab,le values. sgtistical nrelhri{s- These statisti"cs shlrll be
calculated using the Decision Tree/Fkiwchart used fbr tire previous Background
Reports that rvas conditionally approvecl by the DRC on August 24. 2007.
2) Agtliler test resuits to detennine lopirl hl,draulic concluctivity ancl ctther acluifer
nroperties at rvells IVIW-2O and N4W-22.
-]) Avcragc liricar groundwatcr velocit]'calculated tor Iv{W-20 and MW-22. based on
',vcll specitlc h),ch'aulic crinciuctivit)'. h)'draulic *eradient" and clf'ective aqui{'er
PorositY.
l) the groundwate,r'elua{it}' data, *ncl 2) e*leu{ateel grouneln.ater veloeities in the vieinity erf
Whesaid-.reportshallbesubmittedbyMarch1,20l0.Afterreviewof
this report the Executive Secretary will evaluate i[.rvells lrilW-l0-And IV{W-22 sliould be
added as POC r,velis-re-epe*+heSer**k, and adjust the sampling frequency in accordance
with criteria found in Part I.E.1(b) or (c). ll it is detcnnined that u'ells I{W-20 and NIW-22
shoukl be added as POC wells. the Execut.ive Secretary r.vill re-open this Perrriit and establish
2)
3)
4)
t7
Part I
Permit No. UGW370004
(iroundrvater compliance Limits in Table 2 fbr wells \,{w-20 and MW-22
3. Groundwater Head Monitoring :- oll a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.l, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Point of Compliance Wells ;* identified in Table 2 arrdPart I.E.1 of this permit .
b) Piezometers _- P-l,P-2,P-3, P-4, P-5.
c) Existing Monitoring Wells:- MW-20 and MW-22.
d) Contaminant Investigation Wells;:- any well required by the Executive Secretary as a
part of a contaminant investigation or groundwater corrective action;ilt1€I"
e) Any other wells or piezometers required by the Executive Secretary.
4. Groundwater Monitoring Well Design and Construction Criteria;* all new groundwater
monitoring wells installed at the facility shall comply with the following design and
construction criteria:
Located as close as practical to the contamination source, tailings cell, or otherpotential
origin of groundwater pollution;.
Screened and completed in the shallow aquifer;"
Designed and constructed in compliance with UAC R3l7-6-6.3(I)(6), including rhe EpA
RCRA Ground Water Monitoring Technical Enforcement Guidance Document, 1986,
oswER-9950.1.,
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
5. Monitoring Procedures for Wells -- beginning with the date of Permit issuance, all
monitoring shall be conducted by the Permittee in conformance with the following
procedures:
a) Sampling ;- grab samples shall be taken of the ground-water, only after adequate removal
or purging of standing water within the well casing has been perforqred.
Sampling Plan;- all sampling shall be conducted to ensure collection of representative
samples, and reliability and validity of groundwater monitoring data.
Laboratory Approval;* all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
Damage to Monitoring Wells 1- if any monitor well is damaged or is otherwise rendered
inadequate for its intended purpose, the Permittee shall notify the Executive Secretary in
writing within five calenclar days of discovery.
e) Field Monitoring Equipment Calibration and Records ;- immediately prior to each
monitoring event, the Perminee shall calibrate all field monitoring equipment in
accordance with the respective manufacturer's procedures and guidelines. The Permittee
shall make and preserve on-site written records of such equipment calibration in
a)
b)
c)
b)
c)
d)
l8
o
Pa
Pe
rtI
rmit No. UGW370004
accordance with Part ILG and H of this Permit. Said records shall identify the
manufacturer's and model number of each piece of field equipment used and calibration.
6. White Mesa Seepl and Springl Monitoring -- the Permittee shall conduct annual monitoring
of all*seeps and spdngs identified in the currently iipirroved S0nrpling Plan lpr Seeps ancl
Sprinss in the Vicinit.r, of the White Mesa LIranium N{ill. Said monitoring shall include. but
is not linrited to:
a. Field Measurements -- including: -pH. teniperature. and specific conductivity.
-Water
Oualitv Sarnpling and Analvsis -- the Pennittee shall collect grab samples and
perfbrrn laboratory analr"sis of all +
$rwatcr quality parameters identified in Table 2 of this Pennit. and
Serni t'et*tit
Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified lahoratory.
Anal.ytical Methods = all laboratory analysis shallbe conducted using analytical methods
listed in the currentlly, approved OAP rrursuant to Part I.E.l of this Permit.
-Minimurn
Detection Limits -- all seeps or springs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal Lo th**r-{he
e . Grotredthe respective:
l) Cround Water Quality Standarcls 6eiqtlMi+*i+,concentrations defined in Table
2 of this Permit. ar:c1
2) For TDS. Sulfitte. and Chloride. the N4inimum l)etection Limit for those constituents
fkrr seeps and springs nxrnitoring will be as firlloivs: l0 nrg/L. I ntg/L. ancl 1 mgil-.
respectively
Oualitlr Control Sarnples -- the Permittee will conduct quality control (OC) sampling and
analysis as a part of all seeps and springs sarnpling. in accordance with the requirernents
of Section 4.3 of the currently approved OAPI pursuant to Part I.E. I of this Permit. Said
OC samples shall include. but are not limited to:- trip blanks. duplicate samples. and
equipment rinse blanks.
Prior Notification -- at least l5 calendar days before any fieldwork or water quality
sample collection" the Pennittee shall pr:ovide written notice to allow the Executive
Secretaiv to observe or split sample an)' or all seeps or springs.
Sample Omission -- in the course of each annual sampling event. the Permittee shall
sample and anal),ze all six {6}seeps and springs identified in Table 1 of the curently
approved Sanipling Plan for Seeps and Springs in the Vicinity of the White Mesa
Uranium Mill. The Permittee shall not omit samoling of any seep or spring during said
annual event. without prior written approval from the Executive SecretaDr.
7. DMT Performance Standardl Monitoring ;* the Permittee shall perform technology
performance monitoring in accordance with the currently approved DMT Monitoring Plan to
l9
c.
d.
f.
ob'
h.
O
Part I
Permi
a)
b)
t No. UGW370004
determine if DMT is effective in minimizing and controlling the release of contaminants
pursuant to the provisions of Parts I.D.1 and LD.3 of this Permit, including, but not limited to
the following activities:
Weekly Tailings Wastewater Pool Elevation Monitoring: Cells I and 3 _- the Permittee
shall monitor and record weekly the elevation of wastewater in Tailings Cells 1 and 3 to
ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the License. Said measurements shall be made from a wastewater
level gauge or elevation survey to the nearest 0.01 foot.
Monthly Slimes Drain Water Level Monitoring: Cells 2 and 3 ;- the Permittee shall
monitor and record monthly the depth to wastewater in the slimes drain access pipes as
described in Part I.D.3 of this Perniit and the currently approved DMT Monitoring Plan
at Tailings Cells 2 and 3 to determine the 90*erlrfl*i*recovery head. For purposes of
said monitoring, the Permittee shall at each tailings cell:
1) Perform at least l2 separate slimes drain recovery tests at each disposal cell in each
calendar vear that meet the requirements of Part I.D.3.
2) t}*Designate, operate, maintain, and preserve one water level measuring point at the
centerline of the slimes drain access pipe that has been surveyed and certified by a
Utah licensed engineer or land SUrVelor.;
tr"3) +iMake all slimes drain recovery head test (depth to fluid) measurements from
the same designated water level measuring poinh*Hd, ald
€=.X) S.tRecord and report all fluid depth measurements to the nearest 0.01 foot.
5) For Cell 3 these requirements shall apply upon initiation of tailings de-watering
operations.
c) Weekly Wastewater Irvel Monitoring: Roberts Pond 1- the Permittee shall monitor and
record weekly wastewater levels at the Roberts Pond to determine compliance with the
DMT operations standards in Part I.D.3. Said measurements shall be made in accordance
to the curently approved DMT Monitoring Plan.
e)d) Weekly Feedstock Storage Area Inspection;- the Permittee shall ccxduct lveekly
inspectir:ns of
Ffeedstock Sltorage Are&s-to :
::
i."l)Confirm the bulk feedstock materials are maintained within the approved Feedstock
Storage Area defined by Table 4, and
ii-.'liVerify that all alternate feedstock materials located outside the Feedstock Area defined
in Table 4,
recluilements {buncl irr Pan l.D.l l.
e) Feedstock Material Stored Outside the Feedstock Storage Area M*i*te**nee
Pta$lupcsligu
[_-Weell"v tnspectio qr:ify that
20
Part I
Permit No. UGW370004
e$cir t'eed rnaterial container cornplies with the requirernents of Part I.D.l 1.
2) l{ardened Surface Storage Area -* in the event the Permittee constructs a hardened
surface storage area for feed materials. pursuant to Part I.D.ll. prior Executive
Secretary approval will be secured lor the follorving:
i. Engineering Design and Specifications - in accordance rvith the requirements of
Part I.D.4. and
ii. Operation and Maintenance Plan.
fl Inspcctions of Tailing Cell and Poncl Liner Systerns - the Penrittee shall inspect the liner
s-vstem at Tailing Cells 1.2. ilnd 3 on a clail,v hasis pursqant to the requirements of
gections 2. 1 antl 3.2 ot*tlre cumently ippr:oraed f)lv1T Vlonitrxing tlan. The Pemritlse.
shall conriuct visual inspeotions at the Roberts Pond on a rveekl.v* basis. If a discrepancv
is iclentiijed during a liner s.ystem inspeclion. the Perrnittee shall irnrnediatell/ in:plernent
the curlgntl)' approved I.i ner N{ai n tenance-Frr:-v i si pI s.
d8. Cell-4A BAT Performance Standard; Monitoring 1* in accorrlitnce witlt the currentll-
al:provcd Cell 4A BAT Monitoring Opcrations and Mainteirance Plans*ter-4xeetld+e
Par++J++9-of+hi#-P€rffi+t, the Permittee shall immediately implement_-all monitoring and
recordkeeping requirements therein. ,\t a nrinim*nt st*dThe Cell 4A *BAT monitoring
i ncl ucle s the *h*ltol I owin g}4*ek*de:
pglWeekly kak Detection System (LDS) Monitoring;- including:
Leak Detection System Pumping and Monitoring Equipment _- the Permittee shall
provide continuous operation of the leak detection system pumping and monitoring
equipment, including, but not limited to, the submersible pump, pump controller,
head monitoring, and flow meter equipment approved by the Executive Secretary.
Failure of any pumping or monitoring equipment not repaired and made fully
operational within 24-hours of discovery shall constitute failure of BAT and a
violation of this Permit.
Maximum Allowable Head;- the Permittee shall measure the fluid head above the
lowest point on the secondary flexible membrane by the use of procedures and
equipment approved by the Executive Secretary. Under no circumstance shall fluid
head in the ieak detection system sump exceed a 1-foot level above the lowest point
in the lower flexible membrane liner*gg-".Lhg*gg[-ilegl. M*
Teehrroleg)' and a viel*tien of this Pern{+For purposes of conrpliance rnonitoring tiris
l-fixrt clistairce shall equatc to 2.28 f'eet above tlre leak cletection s.v-sterri tr:ansducer.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS. Under no circumstances shall the
average daily LDS flow volume exceed 24,160 gallons/day.
3-foot Minimum Vertical Freeboard Criteria ;- the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard in
Tailings Cell 4,A'. Said measurements shall be made to the nearest 0.1 foot.
2t
l)
2)
3)
4)
Part I
Permit No. UGW3700O4
i>b) Slimes Drain Recovery Head Monitoring;- immediately after the Permittee initiates
pumping conditions in the Tailings Cell 4,A' slimes drain system, monthly recovery head
tests and fluid level measurements will be made in accordance with the requirenrents of
Pats LD.3 and LE.7(b) of this Pennit and any plan approved by the Executive Secretary.
9. On-site Chemicals Inventory -* the Permittee shall monitor and maintain a current inventory
of all chemicals used at the facility at rates equal to or greater than 100 kglyr. Said inventory
shall be maintained on-site, and shall include, but is not limited to:
a. Identification of chemicals used in the milling process and the on-site laboratory;, ancl
b. Determination of volume and mass of each raw chemical currently held in storage at the
facility.
10. Tailings Cell Wastewater Quality Monitorirg -- on an annual basis, the Permittee shall
collect wastewater quality samples from each wastewater source at each tailings cell at the
facility, including, but not limited to:
-T[rcq surface impounded wastewaters locations at Taili , and
-One slimes drain wastewatersjqgglsJi@2. 3. and 4,{. For C
and hall
operations at these cells. and
c. One leak detection wastewater access pipe at Tailings Cell44.
-All such sampling shall be conducted in August of each calendar year in compliance with
the currently approved White Mesa tjran
a. Field Measurements -* including: pH. ternperature. and specific concluctivity"
is -- the Permittee sh ab samnles a
perfbrm laborator.v analvsis of all:
1 ) Water quality pararneters identified in Table 2 of this permit. and
2) Semi-volatile conrpounds identified in EPA Method 8270D.
certified laboratory.
Analvtical Methods --analvsis shall usins anal
listed in the currently approved OAP pursuant to Part I.E.l of this pernrit.
e. Minimum Detection Limits -- all water qualit), analyses reported shall hai,e a minirnum
n or eoual to
2) For TlS. Sullate. and Chloride, tire Minimunr Detection Lirnir for: those cclnstituents
iiin.e Clelt wastewater monitorins will be as fbllow,s: 1 1.000 ms
and I mg/L, respectively. ancl
3)- Lower limits of qulrntitation for groundwater for serni-volatile organic cornpounrjs
listed in Table 2 of EPA Method 8270D. Revision 4. dated February. 2007.
22
Table 2 of this
I
Part I
Permi t No. UGW37OOO4
f. Ouality Control Samples -- the Perrnittee will conduct quality control (OC) sampling and
analysis as a Dart of all tailinss wastewater sampling, in accordance with the
requirements of Section 4.3 of the currently approved OAP: pursuant to Part LE.1 of this
Permit. Said OC samples shall include. but are not lirnited to: trip blanks. duplicate
saniples. and ecluipment rinse blanks.
g. Prior Notification -- at least 30 calendar days before any fieldwork or water quality
sample collection. the Permittee shall provide written notice to allow the Executive
Secretary to observe or split sample any tailings cell. slimes drain. or leak detection
wastewaters.
h. Sample Onrission -- in the course of each annual san-rpling event. the Permittee shall
sample and anallyze all tailings cell. slirnes drain. and leak detection wastewater sources
identified in the currentllu approved Tailings and Slimes Drain Sarnpling Program (pp. 1-
3). or as required b), this Permit. whichever is greater. The Pernrittee shall not omit
sarnpling of an:v of tailings cell wastewater source during said annual event. withoutprior
written approval fiom the Executive Secretarv.
11. Groundwater_-Monitoring Modificatiorrs*-:* before any modification of groundwater
monitoring or analysis procedures, methods, or equipment, the Permittee must obtain prior
written approval from the Executive Secretary.
F. RBpoRrnqc RpeurnsueNTS - The following reporting procedures for routine and compliance
reports must be met.
l. Routine Groundwater Monitoring Reports - the Permittee shall submit quarterly monitoring
reports of field and laboratory analyses of all well monitoring and samples described in Parts
I.E.l, I.E.2, I.E.3, and I.E.5;+n+tF3 of this Permit for Executive Secretary review and
approval. Reports shall be submitted according to the following schedule:
Table 6. Ground M Schedulewater Monttorrn ln
Quarter Period Due Date
First Januarv -- March June I
Second April -- June September 1
Third Julv -- September December I
Fourth October -- December March 1
Failure to submit the reports by the due date shall be deemed as noncompliance with this
flpermit. Said monitoring reports shall include, but are not limited to, the following
minimum information:
a) Field Data Sheets ;* or copies thereof that provide the following: well name, date and
time of well purging, date and time of well sampling, type and condition of well pump,
R
23
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Part I
Perm
b)
c)
d)
e)
it No. UGW370004
depth to groundwater before purging and sampling, calculated well casing volume,
volume of water purged before sampling, volume of water collected for analysis, types of
sample containers and preservatives.
Laboratory Results -* or copies thereof that provide the following: date and time
sampled, date received by laboratory, and for each parameter analyzed, the following
information: laboratory result or concentration, units of measurement, minimum
detection limit or reporting limit, analytical method, date of analysis, counting error for
radiologic analyses, total cations and anions for inorganic analysis.
Water Table Contour Mup -- which provides the location and identity of all wells
sampled that quarter, the measured groundwater elevation at each well measured in feet
above mean sea level, and isocontour lines to delineate groundwater flow directions
observed during the quarterly sampling event.
Quality Assurance Evaluation and Data Validation;* including a written description and
findings of all quality assurance and data validation efforts conducted by the Permittee in
compliance with the currentlv approved Groundwater Monitoring Quality Assurance
Plan. Said report shall verify the accuracy and reliability of the groundwater quality
compliance data, after evaluation of sample collection techniques and equipment, sample
handling and preservation, analytical methods used, etc.
Non-conformance disclosure - with each quarterly ground-water monitoring report the
Permittee shall fully and completely disclose all non-conformance with requirements of
the currently approved QAP, mandated by Part LE.1(a).
Electronic Data Files and Format -- in addition to written results required for every
sampling report, the Permittee shall provide an electronic copy of all laboratory results
for groundwater quality monitoring conducted. Said electronic files shall consist of
Comma Separated Values (CSV) format, or as otherwise approved by the Executive
Secretary.
g) 'fime Cortcentralit'rn Plcits - with each quarterly groundrvater monitoring rcport the
Permittee sl-lall sqblnit time concenti"ation plots lor each monitoring rvell fbr" tlie
tbllowing constituents: chloridc. fluoride, sulfate. and uranium.
Routine DMT Performance Standardl Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT performance standard$ monitoring required by Partg
LD.3 and I.E.7 of this Permit. DMT monitoring shall be conducted in compliance with this
Perrnit and the currently approved DMT Monitoring Plan. Said monitoring reports and
results shall be submitted for Executive Secretary approval on the schedule provided in Table
6, above.
Routine Cell 4,{ BAT Perfonnance Standardg Monitoring Reports -- the Permittee shall
provide quarterly monitoring reports of all BAT performance standardl monitoring required
by Part I E.8 of this Permit. BAT Monitoring at Cell 4,A' shall be conducted in compliance
with the currently approved BAT N{onitoring Operations and ll,Iaintenance Plan*dar*
+tpprove€f by *re [ixeeutiv . Said monitoring report and
results shall be submitted for Executive Secretary approval on the schedule provided in Table
6 above. At a minimum, reporting of BAT monitoring for cell4,{ will include:
2.
24
o
Part I
Perm
4.
5.
6.
it No. UGW370004
a) LDS Monitoring;- including:
1) Report on the operational status of the LDS pumping and monitoring equipment
during the quarter, including identification of any intervals of non-operational status
and repairs.
2) Measurement of the weekly fluid head at the lowest point of the secondary
membrane,
3) Measurement of the volume of all fluids pumped from the LDS.
b) Measurement of the weekly wastewater fluids elevation in the Cell 4A to determine
freeboard.
c) Slimes Drain Recovery Head Monitoring as per the requirements of Parts I.D.6) and
r.8.8(b).
DMT and BAT Performance Upset Reports:- the Permittee shall report any non-compliance
with the DMT or BAT performance criteria of Part I.D in accordance with the requirements
of Part LG.3 of this Permit.
Other Information - when the Permittee becomes aware of a failure to submit any relevant
facts in the permit application or submittal of incorrect information in apermit application or
in any report to the Executive Secretary, the Permittee shall submit such facts or information
within 10 calendar days of discovery.
Groundwater Monitoring Well As-Built Reports;- as-built reports for new groundwater
monitoring wells shall be submitted for Executive Secretary approval within 60 calenciar
days of well completion, and at a minimum will include the following information:
a) Geologic Logs ;- that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs shall be prepared by a
Professional Geologist licensed by the State of Utah, or otherwise approved beforehand
by the Executive Secretary.
b) Well Completion Diagram;* that detail all physical attributes of the well construction,
including:
l) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties of well casing and screen, including
well screen slot size,
Depth intervals, type and physical properties of annular filterpack and seal materials
used,
Design, type, diameter, and construction of protective surface casing, and
Survey coordinates prepared by a State of Utah licensed engineer or land surveyor,
including horizontal coordinates and elevation of water level measuring point, as
measured to the nearest 0.01 foot.
c) Aquifer Permeability Data; including field data. data analysis. and intemretation of slug
25
3)
4)
s)
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Part I
Permi r No. UGW370004
test, aquifer pump test or other hydraulic analysis to determine local aquifer hydraulic
conductivity in each well.
7. White Mesa Seepg and Springg Monitoring Reports - a seeps and springs monitoring report
shall bS submitted for Executive Secretar.v- revie rv and approval with the 3'''rQuarter Roul.ine
Grounriwater Monitr:rinq Repert due on Decernber I , of each calendar year. Said reoort shall
include, but is not limited to:
e+
seepse++p+in6s-c+Wt*+e++es,r
g|*-fleld Measuret
with the reguirements of Part I.F. l(a) of this Permit.
b) Laboratrtry ResLrlts - for each sample collected that compl), with the requirements of part
LF.I(b) of this Permit.
c') Water Tahle Contour Map - tlrat inclucles groundwater elevations lbr each rvell at the
facility and lJ"le elevations of the plireatic surlaces observed at"each ol tlie seeps and
springs samplecl. The contour map lvill include all lvater level clata measurements fiom
seeps. springs. ancllnonitorin&rvells atthe sitefi,ornthe 3''lOuartcrRoutincGrorrndwater
Monitoring event ol'eii!:h year. 'l'he contour miip shall be at ii map scale. such that. nll
seeps ancl springs listed in the aporoved Sampling Plan fbr Seeps ancl Springs in the
Vicinit,'" of the White Mesa Uraniuni Mill and-tlre monitoring wells on site rna), he secn
0n one milp.
d) Data Evaluation - aruljnterpretal.ien*<;f all groUndrvate r qualit): c1ata collected.
e) Ouality Assurance Evaluation and Data Validation - fbr the seeps and springs water
quality data that meets the requirements of Part LF. I (d).
f) Electronic Data Files and Format - that meet the requirernents of Part LF.l(e) of this
Permit. and
g) Survey data for the secps and springs shall be based on an elevation surve),. conducted
under the direction of and certilieci by a Utah licensed prolbssional engineer or land
suneyor. The sur:ve):_,uvill incLude Stat.e Plan Cloorclinates (northings and slrstings) iinci
vet'tical elevations. Tltc surveycd coorclinates and elevations of the seeps_AllLsprings
shall be within I ftiot o{'the highest point of the saturatecl seepage lhce on the dav ol't}re
survey. This sru:r,py data must be obtairled be re an], saltrples are col-lecltc,C
8. Chemicals Inventory Report ;- at the time of Permit renewal the Permittee shall submit a
report to update the facilities chemical inventory report required by Part I.H.19. Said report
shall provide all inventory information gathered pursuant to Part I.E.9.
9. Tailings Cell Wastewater Quality Reports -- all annual wastewater quality sampling and
analysis required by Part I.E.10 shall be reported to the Executive Secretary with the 3'd
Quarter groundwater quality report due on December 1. of each calendar year. Said report
shall include;
Data evaluation and interpretation of all wastewater quality sarnples collected.
All infbrmation required by Part I.F.1(a). (b). (d), and (e) of this Permit. and
a)
b)
26
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Part I
Permit No. UGW370O04
c) For slimes drain samples. the Permittee shall report depth to wastewater measurements
from the water level measurement ooint. Said wastewater level shall be measured
immediately befbre sample collection.
aF
10. Revised Hydrogeologic Report - pursuant to Part IV.D of this Permit, and at least 180
calendar days prior to Permit expiration, the Permittee shall submit for Executive Secretary
approval a revised hydrogeologic report for the facility and surrounding area. Said report
shall provide a comprehensive update and evaluation of:
Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologic conditions; time relationships and distribution of shallow aquifer head
measurements from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity across
the site, and
Well specific groundwater quality conditions measured at facility monitoring wells for all
groundwater monitoring parameters required by this Permit, including, but not limited to:
-temporal contaminant concentrations and trends from each monitoring well; statistical
tests for normality of each contaminant and well, including univariate or equivalent tests;
calculation of the mean concentration and standard deviation for each well and
contaminant.
11. Annual Slimes Drain Recovery Head Report ;- on or before March 1 of each year the
Permittee shall submit for Executive Secretary approval an annual slimes drain recovery head
report for Tailings Cells 2 and 3. Said report shall conform to the requirements of Part
I.D.3(b),I.E.7(b), and tr.G of this Permit, and:
a) Provide the individual monthly slimes drain recovery head monitoring data for the
previous calendar year, including-, but not limited to: date and time for the start and end
of recovery test, initial water level, final depth to stable water level and equivalent
recovery water level elevation.
b) Calculate the average slimes drain recovery head for the previous calendar year.
c) Include a time series chart to show trends of the monthly recovery water level elevations
at each slirnes drain.
d) lnclude the results of a quality assurance evaluation and data validation. Said
examination shall provide written descriptions and findinss that:
I I -----l+Evaluate all data collected. data collection methods. and all related calculations
required by this Permit. and
2) --*-t)-Verif.v the accuracy and reliability of both the data and calculations reported.
eg) Demonsffate compliance status with the requirements of Part I.D.3(b) and I.8.7(b) of this
Permit.
a)
b)
G. OurorCouplnNcE STATUS
27
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Part I
Permir No. ucw370004
1. Accelerated Monitoring Status - is required if the concentration of a pollutant in any
compliance monitoring sample exceeds a GWCL in Table 2 of the Permit; the facility shall
then:
Notify the Executive Secretary in writing within 30 calendar days of receipt of data": and
Immediately initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring wells .- for wells defined by Part I.E.l(b) the
Permittee shall initiate monthly monitoring;.
2) Semi-annual Baseline Monitoring Wells ;- for wells defined by Part I.E.1(c) the
Permittee shall initiate quarterly monitoring,.
Said accelerated monitoring shall continue at the frequencies defined above until the
compliance status of the facility can be determined by the Executive Secretary.
2. Violation of Permit Limits - out-of-compliance status exists when-+
aHlhe concentration of apollutant in two consecutive samples from a compliance monitoring
point exceed!:
a) A GWCL in Table 2 of this Permit -*n*. or
eal€utate€l Hsin irtrrce
b) The concentration value of any pollutant
statistically significantly higher than the
significance shall be determined using the
Methods for Evaluating Ground Water Monitoring Data from Hazardous Waste
Facilities, Vol. 53, No. 196 of the Federal Register, Oct. 11, 1988.
3. Failure to Maintain DMT or BAT Required by Permit
Permittee to Provide Information - in the event that the Permittee fails to maintain DMT
or BAT or otherwise fails to meet DMT or BAT standards as required by the fpermit, the
Permittee shall submit to the Executive Secretary a notification and description of the
failure according to R3l7-6-6.16(C)(1). Notification shall be given orally within 241
hours of the Permittee's discovery of the failure of DMT or BAT, and shall be followed
up by written notification, including the information necessary to make a determination
under R317-6-6.16(C)(2), within five calendar days of the Permittee's discovery of the
failure of best available technology.
The Executive Secretary shall use the information provided under R3l7-6-6.16.C(l) and
any additional information provided by the Permittee to determine whether to initiate a
compliance action against the Permittee for violation of lpermit conditions. A
compliance action shall not be initiated, if the Executive Secretary determines that the
Permittee has met the standards for an affirmative defense, as specified in R317-6-
6.16(CX3).
c) Affirmative Defense - in the event a compliance action is initiated against the Permittee
28
a)
b)
in two or more consecutive samples is
applicable lpermit limit. The statistical
statistical methods described in Statistical
a)
b)
o
Part I
Permit No. UGW370004
for violation of lpermit conditions relating to best available technology or DMT, the
Permittee may affirmatively defend against that action by demonstrating the following:
1) The Permittee submitted notification according to R317-6-6.139
2) The failure was not intentional or caused by the Permittee's negligence,
action or in failure to act,
The Permittee has taken adequate measures to meet lpermit conditions in a timely
manner or has submitted to the Executive Secretary, for the Executive Secretary's
approval, an adequate plan and schedule for meeting lpermit conditions.* and**rd
The provisions of UCA 19-5-107 have not been violated.
4. Facility Out of Compliance Status *- if the facility is out of compliance, the following is
required:
a) The Permittee shall notify the Executive Secretary of the out of compliance status within
2{*hours after detection of that status, followed by a written notice within 5 calenciar
days of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part LG.l, unless the
Executive Secretary determines that other periodic sampling is appropriate, until the
facility is brought into compliance.
The Permittee shall prepare and submit within 30 c"lrlenclal -days to the Executive
Secretary a plan and a time schedule for assessment of the sources, extent and potential
dispersion of the contamination, and an evaluation of potential remedial action to restore
and maintain ground-water quality to insure that Ppermit limits will not be exceeded at
the compliance monitoring point and that DMT or BAT will be reestablished.
The Executive Secretary may require immediate implementation of the currently
dpplalgd contingency plan in order to regain
and maintain compliance with the lpermit limit standards at the compliance monitoring
point or to reestablish DMT or BAT as defined in the Permit.
e) Where it is infeasible to reestablish DMT or BAT as defined in the fpermit, the Permittee may
propose an alternative DMT or BAT for approval by the Executive Secretary.
H. Coupr-TANCE ScHEDULE REeUIREMENTS. The Permittee
described and summarized below:
comply the schedules as
3)
4)
c)
d)
29
o
Part I
Permi r No. UGW370004
o
Part I
Permit No. uGW370004
? )Identifiier; arrd :i tr sti fi es any greundw ater eeaeentrati e n eutliers;
g)^fty len ing
ff}i}t+i+t}}ir1t#l{tr
3l
t No. UGW370004
t
Part I
Permi
o
Part I
Permit No. UGW370004
iffient
eDeterr*i+ratien ef the l*bor*tery analytie*l nretlreds and the envirer+nre*titl ltiberateiy that
@
f,t*ffplin$and.*nal,vsi*of a{} ground.water eorfip}ianeept}'-€Hl*etens lbu{*d o{{ Table 2 r}+ {his
M
If * er review ion-lii;
ftpprcrv€el by the itteo
rneesHrcr1lent$ i}&d
w*teptarrle elevatie$+ef all the rvelis *f the {aei{it}' tinel the elev+titr*se$tirephreatie sur{eee$
i
@i€{;
h)L On-site Chemicals Inventory Report;* the Permittee shall complete a historical review,
and conduct an inventory of all chemical compounds or reagents stored, used, or currently in
use at the facility. Said report shall include:
a=a)Identification of all chemicals used in the milling and milling related processes at White
Mesa, and'
hb) Determination of the total volumes currently in use and historically used, as data is
available.
At the time of Permit renewal, the Permittee shall submit an updated inventory report
pursuant to Part LF.8.
i)2.Infiltration and Contaminant Transport Modeling Work Plan and Report -_- the Permittee
shall submit for Executive Secretary approval an infiltration and contaminant transport
modeling report that demonstrates the long-term ability of the tailings cells cover system to
adequately contain and control tailings contaminants and protect nearby groundwater quality
of the uppermost aquifer. Said report shall demonstrate how the tailings cell engineering
design and specifications will comply with the minimum performance requirements of Part
LD.6 of this Permit. The Permittee shall submit an infiltration and contaminant modeling for
Executive Secretary approval, that:
n".a)Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
JJ
o
Part I
Permi t No. UGW370004
*b) Determines and justifies all information necessary for infiltration and contaminant
transport modeling, including but not limited to representative input values for vadose
zone and aquifer soil-water partitioning (IQ) coefficients, tailings source term
concentrations, tailings waste leach rates, vadose zone and aquifer groundwater
velocities, vadose zone and aquifer dispersivity, contaminant half-life or other rates of
decay, etc. In the event that any required information is not currently available, the
Permittee may select conservative assumptions for use in the required infiltration and
contaminant transport models.
e'c)Identifies and adequately describes all computer models used to simulate long-term
performance of the tailings cells cover system. All predictive models used shall be
publicly available computer codes that adequately represent field characteristics and
physical processes at the tailings disposal site.- Said description will also include
specific information on model design, including, but not limited to: governing equations
and their applicability to site conditions, grid design, duration of simulation, and
selection of time steps.
*d) Determines the conceptual model used and justifies why it is representative or
conservative of actual field conditions at the site. Said conceptual model will identify the
physical domain(s) and geometries simulated including the tailings cell design and
construction, all boundary and initial conditions assigned in the model(s), and the
shallow aquifer locations where future potential contaminant concentrations have been
predicted.
geUustifies how the infiltration and contaminant transport problem has been adequately
conceptualized, planned, and executed to demonstrate compliance with the requirements
of Part I.D.6 of this Permit.
{.f t Provides, describes and justifies the following:
i."l)Model Results 3 including electronic input and output files from all infiltration,
groundwater flow and contaminant transport models used the report.
ii-2) Model Calibration ;- including description of results and efforts used to
demonstrate how the model adequately reproduced field measured heads, flows, and
contaminant concentrations.
i"ii'-l) Steady State Conditions ;- including a demonstration that the models achieved a
steady state condition during the simulation. This includes, but is not limited to
disclosure, evaluation and justification of water and mass balance error values
reported by the models.
i+t4) Sensitivity Analyses ;--including description of various model simulations run
and evaluated to define the range of model uncertainty. Such uncertainty includes,
but is not limited to: boundary and initial conditions, model input values, and spatial
and temporal distribution of model parameters used in the problem domain.
+'5) Post-model Audit Plan -* including plans to revisit the modeling effort at some
future time to re-assess its ability to represent site characteristics and predict long-
term perfonnance of tailings cell design and construction, and groundwater
protection.
shall complete all modeling in accordance with the requirements of part
34
The
I
Part I
Permi t No. UGW370004
I.H.?.I$ and submit a final report for Executive Secretary approval. In the final report, the
Permittee may include supplemental information to justify modification of certain Permit
requirements, including, but not limited to: the number and types of groundwater
compliance monitoring parameters, tailings cell cover system engineering design and
construction specifications, tailings cell operational requirements, etc. In the event the
Executive Secretary requires additional information, the Permittee will provide all requested
information within a time frame approved by the Executive Secretary. Upon Executive
Secretary approval of the final infiltration and contaminant transport report, the Reclamation
Plan may be modified to accommodate necessary changes to protect public health and the
environment.
ItPlan fqr Evaluation of Deep Supply Well WW-2 ;*-the purpose of this plan is to evaluate the
annular casing seal in water supply well WW-2, and to ensure adequate well casing and annular
seals, in compliance with the regulations of the Utah State Engineer (UAC R655-4-9), with
special emphasis on creating both a physical barrier and hydraulic isolation between the shallow
unconfined and the deep confined aquifers. Prior to Executive Secretary approval of this plan the
Permittee shall resolve all issues within a timeframe approved by the Executive Secretary. After
Executive Secretary approval of the plan, the Permittee shall completely execute all provisions of
the plan on or before decommissioning of the White--Mesa N!**ill'
J.
l2, s upplenrentill
Monitoriflg Pittn fu
ifig*-{"
l-1,( Reserved >
3,e€ndngeney
this Perr+lit-At ti r*rinirnum*he Glenti ngene
itrnee+
35
I
Part I
Permi t No. UGW37O0O4
{&*<*iy,rerved>
4. +g*Isotopic Groundw
days of i.ssuance of this Perrnit, the Permittee shall submit an isotopic groundwater and
surface water investigation report for Executive Secretary approval. The purpose ol'this
investigittion ancl associated report shall be to charticterize"chemical composition. noble gas
ccrntpositititt. and agc of the groundwater monitoring u,ells and surf'ace rvater sites that were
not part r:l'the Jul-v 2007 University of l-ltah StLrcl]'. "llhe lbilowing locations shall be inclurjed
in the investigqjiqn: nronitcl"$g welis MW- l2.MW- 17. MW-20. MW-23. MW-24, MW-?i
i{W-26. NIW-28. N{W--i2" Tailings Cell 4A.. and the northernmost wilcllif'e pond (WP1}.
Thc report slrall inclur-lc" but is not limited to:
An examination of groundrvater age using the tritiun/helium-3 niethod in each
tttonitotjnq rvell anci surface rvater sources (Tailings Clell 4A ancl the northernntost
ivildlif'e poncl). After tritiunr conccntrations have been obtained fbr each rvell. the
Per:rnittee nrust veril] il'an.v ol'the monitoring rvells have been influencecl by ti-re artillcial
recharge from the r.vildlife pqnds.
An examination of isotopes Deutcriunr and Ox),gen-18 in watel at each sampling
not limited to ev
a.
b.
srgnature.
-34 on diss
rvater s;rmples.
se ofthis atiorr and as s I be to establislr
char ni1/surfhce water
n i ttee rlust concl usive that tlre su
tecl is sinrilar ttl tht: one
36
e Universitv oi l.lta
tl(]n
Part I
Permit No. UGW370004
Go*rmeneernent ef rv*steri trter eir ttrilings disehal'ge tre 6ell 4l\ is prohibi+ed witheut prior rvritten
Permit irnd in,el ing:
rates-.-c$e'
eontrtrls $tr p,reve*t release ol*'astew*ter'to the envirennre nt,
5. Ner,r, f)econtaminafion Pad - tJre Permittee shal] not use the Nelv f)econta[rination Pad untii
the i'ollowing conditions are satisfied:
a. Within 30 calenciar da,vs ol'issr.rance ol'the Perrnit. the Perrnittce shall sLrbmit an uptJated
DNIIT Monitoring Plarr for Exec,utive Secretar_y appl'oval that includes but is lrot limited
to the fbllowing:
1) The manner qf weekl), inspections the New f)econtar:iination Pad. including the leak
deteclion systertt and concrete integrity of the decontantination oad.
2) Within 30 calgndar days r:f issuance of the Pennit. thg Permittee shall subnlil an
updatcd Contingenc), PIan that clarifies rvhat steps \,vill be taken if there is watcr
{'ouncl rvithin the leak derection s}'stern and il cliscrepancies are obsenecl qn the
concrete pad.
3) Anlrual lnsncclion - the New Decontamination Pacl will be taken out of service and
inspected auriually dudng the second ql"iarter. to ensu{g* integdtv ol' the concrele
surtaces. If discrcpancies arc identified Ii.e. crack in the concrete with greater than
it No. UGW37O004
a
Part I
Perm
l/B i tion (rviclth) or i sni ficilnt deteriorati ol'the
Irttface]. rqpzri{s shall be made prior to resuming the use of the facilit},. the
i,n.tt .tionjl#*ngt, orrJ,ry,goyrs re",t,ired.*rd r*plir* go,rpl"t*,] .hall.be include.l i,l
)iear.
2"tr Ouarter DMT itor:ins Renort of each calen<1:
ive Secretar the liner an
detectiou s),stem" belbre they are constructed.
c. 'ftre Permittee shall per{bnl a hydr:r:static test that ver:ilies that the steel liper-and leak
detecti brms in iiccorrlance uri rvings and vvill nroviile
ts within 30 cale cornnleti t. Thr: Pennit
provicle at Ieast l0 calendar days notice prior to perfonning the h)'clr:ostatic test to allorv a
DRC inspector to be presernt.
d. The E aooroves all f s-Built drawin
Pad.
6.Decontaminlrtion Pad - w t 30 calenclar uance ol'the Pemni
shall perfbrrn the lbllowing:
a. subrrrit As-Built drawings of the Existin&Decontamination pad (EDp).
b. Subrnit BATIDI\4T Monilori
Decontamination Pad.
tion -ill be takcn out ofscrvicc and i :ted ann
tlie seconcl quru'l.er:. to ensure inl.egr:it), of tjre qteel tank. The inspect.ion f,ilrdings. any
rePiiirs required. anci repairs cornpletecl shall be incluciecl in the in the 2"'l Ouarter DMT
Monitoring Report due Septenrber 1, of cach calendar year.
38
o
Part tr
Permi
B.
C.
D.
E.
F.
t No. UGW370004
PART tr. REPORTING REQUIREMENTS
A. REeRESENTATTvE SaupI-INc. Samples taken in compliance with the monitoring requirements
established under Part I shall be representative of the monitored activity.
ANelyucal PRocEDURES. Water sample analysis must be conducted according to test
procedures specified under UAC R3 1 7- 6-6.3 .12 unless other test procedures have been specified
in this Ppermit.
PpNar-rrcs FoR TAMpEntNG. The Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate, any monitoring device or method required to be maintained under
this lpermit shall, upon conviction, be punished by a fine of not more than $ 10,000 per violation,
or by imprisonment for not more than six months per violation, or by both.
RspoRr[.rc oF MoNrroRrNG RESULTS. Monitoring results obtained during reporting periods
specified in the pflermit, shall be submitted to the Executive Secretary, Utah Division of Water
Quality at the following address no later than the date specified following the completed
reporting period:
Attention: Compliance and Monitoring Program
State of Utah
Division of Water Quality
Department of Environmental Quality
Salt Lake City, Utah 84114-4870
The quarterly due dates for reporting are: June l, December I, and March 1.
G.
CoupllaNce Scgeoulns. Reports of compliance or noncompliance with, or any progress
reports on interim and final requirements contained in any Compliance Schedule of this lpermit
shall be submitted no later than 14 caleirciar days following each schedule date.
AoonroxaI- MoNrroRrNG By rHE PERMITTEn. If the lpermittee monitors any pollutant more
frequently than required by this Ppermit, using approved test procedures as specified in this
flpermit, the results of this monitoring shall be included in the calculation and reporting of the
data submitted. Such increased frequency shall also be indicated.
RBcoRos CoNreNrs.
1. Records of monitoring information shall include:
a) The date, exact place, and time of sampling, observations, or measurements:
b) The individual(s) who performed the sampling, observations, or measurements;
c) The date(s) and time(s) analyses were performed;
d) The name of the certified laboratory which performed the analyses;
e) The analytical techniques or methods used; and,
0 The results of such analyses.
H. RETENTToN oF RBconos. The Ppermittee shall retain records of all monitoring
39
a
Part Il
Permit No. UGW370004
including all calibration and maintenance records and copies of all reports required by this
fpermit, and records of all data used to complete the application for this Rpermit, for a period of
at least five years from the date of the sample, measurement, report or application. This period
may be extended by request of the Executive Secretary at any time.
Norrcp oF NoNCoMpLIANCE RBpoRtlNc.
1. The lpermittee shall verbally report any noncompliance which may endangerpublic health
or the environment as soon as possible, but no later than 24;-hours from the time the
Ppermittee first became aware of the circumstances. The report shall be made to the Utah
Department of Environmental Quality 24*-holr number, [phone], or to the Division
of Water Quality, Ground Water Protection Section at [phone], during normal
business hours (8:00 am - 5:00 pm Mountain Time).
2. A written submission shall also be provided to the Executive Secretary within five calenciar
days of the time that the lpermittee becomes aware of the circumstances. The written
submission shall contain:
a) A description of the noncompliance and its cause;
b) The period of noncompliance, including exact dates and times;
c) The estimated time noncompliance is expected to continue if it has not been corrected;
and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results.
OruBn NoNcouplIANCE RgpoRrrNc. Instances of noncompliance not required to be reported
within 5 calendar days, shall be reported at the time that monitoring reports for Part ILD are
submitted.
K. INSPECTION AND ENrRv. The Ppermittee shall allow the Executive Secretary, or an authorized
representative, upon the presentation of credentials and other documents as may be required by
law, to:
1. Enter upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the Epermit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this fpermit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this pflermit; and,
4. Sample or monitor at reasonable times, for the pufpose of assuring lpermit compliance or as
otherwise authorized by the Act, any substances or parameters at any location.
J.
40
A.
Part trI
Permit No. UGW370004
PART III. COMPLIANCE RESPONSIBILITIES
Dury ro CoMpLy. The Ppermittee must comply with all conditions of this fpermit. Any
lpermit noncompliance constitutes a violation of the Act and is grounds for enforcement action;
for permit termination, revocation and re-issuance, or modification; or for denial of a permit
renewal application. The lpermittee shall give advance notice to the Executive Secretary of the
Division of Water Quality of any planned changes in the permitted facility or activity which may
result in noncompliance with pfermit requirements.
PsNer-rrcs FoR VToLATToNS oF PeRuIr CouotuoNs. The Act provides that any person who
violates a lpermit condition implementing provisions of the Act is subject to a civil penalty not
to exceed $10,000 per day of such violation. Any person who willfully or negligently violates
Ppermit conditions is subject to a fine not exceeding $25,000 per day of violation. Any person
convicted under Section 19-5-115 of the Act a second time shall be punished by a fine not
exceeding $50,000 per day. Nothing in this Ppe*it shall be construed to relieve the lpermittee
of the civil or criminal penalties for noncompliance.
Nsno ro HRr-r oR REDUCE Acrrvrrv Nor A DereNss. It shall not be a defense for a Ppermittee
in an enforcement action that it would have been necessary to halt or reduce the permitted
activity in order to maintain compliance with the conditions of this fpermit.
Du'ry ro MrrrGATE. The Rpermittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this Ppermit which has a reasonable likelihood of adversely affecting
human health or the environment.
PRopeR OpeRerroN AND MAINTENANCE. The tpermittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the lpermittee to achieve compliance with the conditions of this flpermit.
Proper operation and maintenance also includes adequate laboratory controls and quality
assurance procedures. This provision requires the operation of back-up or auxiliary facilities or
similar systems which are installed by a lpermittee only when the operation is necessary to
achieve compliance with the conditions of the Ppermit.
B.
C.
D.
E.
41
Part IV
Permit No. UGW37O004
PART IV. GENERAL REQUIREMENTS
A' PlaNNso CuRNcBs. The Ppermittee shall give notice to the Executive Secretary as soon aspossible of any planned physical alterations or additions to the permitted facility. Notice is
required when the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged.
B. ANrtcrparpo NoNcOMPLIANCE. The Ppermittee shall give advance notice of any planned
changes in the permitted facility or activity which may result in noncompliance with lpermitrequirements.
C.
D.
E.
F.
PeRun AcrIoNS. This lpermit may be modified, revoked and reissued, or terminated for cause.
The filing of a request by the [permittee for a permit modification, revocation and re-issuance,
or termination, or a notification of planned changes or anticipated noncompliance, does not stay
any permit condition.
Durv ro REAPPLY. If the lpermittee wishes to continue an activity regulated by this lpermitafter the expiration date of this lpermit, the lpermittee must apply for and obtain a new permit.
The application should be submitted at least 180 calenclar days before the expiration date of this
lpermit.
Durv ro PRovIor INpoRMATION. The fpermittee shall furnish to the Executive Secretary, within
a reasonable time, any information which the Executive Secretary may request to determine
whether cause exists for modifying, revoking and reissuing, or terminating ihis gpermit, or to
determine compliance with this fpermit. The lpermittee shall also furnish to the Executive
secretary, upon request, copies of records required to be kept by this fpermit.
OrHen INFoRMATIoN. When the lpermittee becomes aware that it failed to submit any relevant
facts in a permit application, or submitted incorrect information in a permit applicati,on or any
report to the Executive Secretary, it shall promptly submit such facts or information.
StcNaroRv RnqumeunNrs. All applications, reports or information submitted to the Executive
Secretary shall be signed and certified.
1. All permit applications shall be signed as follows:
a) For a corporation: by a responsible corporate officer;
b) For a partnership or sole proprietorship:* by a general partner or the
respectively.
c) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
2. All reports required by the Ppermit and other information requested by the Executive
Secretary shall be signed by a person described above or by a duly authorized representative
ofthat person. A person is a duly authorized representative only if:
a) The authorization is made in writing by a person described above and submitted to the
Executive Secretary, and,
G.
proprietor,
42
Part IV
Permit No. UGW370004
b) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or a well field, superintendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position).
Changes to Authorization. If an authorization under Part IV.G.2. is no longer accurate
because a different individual or position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of Part IV.G.2 must be submitted to
the Executive Secretary prior to or together with any reports, information, or applications to
be signed by an authorized representative.
Certification. Any person signing a document under this section shall make the following
certification:
"I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations. "
PnNar-rrss FoR FALSTFTcATIoN oFREnoRTS. The Act provides that any person who knowingly
makes any false statement, representation, or certification in any record or other document
submitted or required to be maintained under this Bpermit, including monitoring reports or
reports of compliance or noncompliance shall, upon conviction be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than six months per violation, or by
both.
Av4u-anu-ny oFREIoRTS. Except for data determined to be confidential by the Ppermittee, all
reports prepared in accordance with the terms of this lpermit shall be available for public
inspection at the offices of the Executive Secretary. As required by the Act, permit applications,
permits, effluent data, and ground-water quality data shall not be considered confidential.
pRoppRry RTGHTS. The issuance of this lpermit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations.
SsvsRasLrry. The provisions of this lpermit are severable, and if any provision of this
lpermit, or the application of any provision of this lpermit to any circumstance, is held invalid,
the application of such provision to other circumstances, and the remainder of this fpermit, shall
not be affected thereby.
L. TnaNsrgns. This lpermit may be automatically transferred to a new Ppermittee if:
l. The current lpermittee notifies the Executive Secretary at least 30 calenclar days in advance
J.
4.
H.
L
J.
K.
43
a
Part IV
Permit
2.
a
No. UGW37O0O4
of the proposed transfer date;
The notice includes a written agreement between the existing and new Ppermittee containing
a specific date for transfer of permit responsibility, coverage, and liability between them;
and,
The Executive Secretary does not notify the existing lpermittee and the proposed new
Ppermittee of his or her intent to modify, or revoke and reissue the permit. If this notice is
not received, the transfer is effective on the date specified in the agreement mentioned in
paragraph 2 above.
SrarBLews. Nothing in this plermit shall be construed to preclude the institution of any legal
action or relieve the lpermittee from any responsibilities, liabilities, penalties established
pursuant to any applicable state law or regulation under authority preserved by Section 19-5-1 l5
of the Act.
ReopBNnR PRovlsIoNs. This lpermit may be reopened and modified (following proper
administrative procedures) to include the appropriate limitations and compliance schedule, if
necessary, if one or more of the following events occurs:
1. If new ground water standards are adopted by the Board, the lpermit may be reopened and
modified to extend the terms of the lpermit or to include pollutants covered by new
standards. The lpermittee may apply for a variance under the conditions outlined in R317-6-
6.4(D).
2. Changes have been determined in background ground-water quality.
3. The Executive Secretary determines permit modification is necessary to protect human health
or the environment.
M.
N.
44
o
WATER QUALITY
o
IT UGGROUNDDISCHARGE PERM w370004
Statement of Basis
For a
Uranium Milling Facility
South of Blanding, Utah
Owned and Operated by
Denison Mines (USA) Corp.
Independen ce Plaza, Suite 950
1050 17th Street
Denver, Colorado 80265
September 2009
PURPOSE
The purpose of this Statement of Basis (herepfter SOB) is to describe the technical and
regulatory basis to proposed modifications to requirements found in a Ground Water Quality
Discharge Permit No. UGW370004, (hereafter Permit) for the Denison Mines (USA) Corp.
(hereafter DUSA) uranium mill facility located about six miles south of Blanding, Utah in
sections 28,29,32, and 33, Township 37 south, Range 22East, salt Lake Baseline and
Meridian, San Juan County, Utah.
Major changes associated with this Permit modification include but are not limited to:
. Approval of DUSA Background Ground Water Quality Reports dated October 2007 and,
April 30,2008.o Calculation of a mean and standard deviation for each Point of Compliance (hereafter
POC) groundwater monitoring well, and the establishment of sampling frequency for all
POC wells.o Establishment and revision of Ground Water Compliance Limits (hereafter GWCL).. Update the status of certain POC wells with parameters in Out-of-Compliance Status.o Addition of Best Available Technology (hereafter BAT) Standards and Performance
Monitoring for Feedstock Material Stored Outside the Feedstock Storage Area.o Addition of Performance Monitoring for inspections of Tailing Cell and Pond Liner
Systems.o Addition of Seeps and Springs and tailings cell water monitoringo Resolution of certain previous compliance schedule requirements.
Other minor Permit changes include but are not limited to: the correction of formatting,
numbering, and other elrors, resetting of some compliance schedule items, and the completion of
several compliance schedule items.
BACKGROUND.
The White Mesa uranium mill was constructed in l97g - 1980 and licensed under federal
regulations by the Nuclear Regulatory Commission (hereafter NRC), Source Material License
suA-13s8.
Page I of 42
On August 16,2004, the NRC delegated its uranium mill regulatory program to the State of
Utah, by extending Agreement State status, As a result, the Utah Division of Radiation Control
(hereafter DRC) became the primary regulatory authority for the DUSA White Mesa mill for
both radioactive materials and groundwater protection. Later, DUSA was issued a State Ground
Water Quality Discharge Permit No. UGW370004 on March 8, 2005. Previous to the
modification proposed herein today, the Permit was last modified on March 17,2008.
Excess Total Uranium Concentrations with Long-Term Increasing Trends in
Downgradient Wells
In the original DRC December 1,2004 Statement of Basis, three wells (MW-14, MW-15, and
MW-17) located downgradient of the tailings cells were found to have long-term increasing
concentration trends for total uranium. These three wells and downgradient well MW-3, had
total uranium concentrations above the Utah Ground Water Quality Standard (hereafter GWQS),
found in UAC R3l7-6-2 (see December 1,2004 DRC SOB, pp. 6-7). These findings were of
concern to the DRC because they appeared to indicate that the tailings cells had possibly
discharged wastewater into the underlying shallow aquifer.
To resolve this concern, the Executive Secretary required DUSA to evaluate groundwater quality
data from the existing wells on site, and submit a Background Ground Water Quality Report for
Executive Secretary approval, in accordance with Part I.H.3 of the Permit. One of the purposes
of this report was to provide a'critical evaluation of historic groundwater quality data from the
facility, and determine representative background quality conditions and reliable groundwater
protection levels or compliance limits for the Permit.
The Permit also required several new monitoring wells be installed around Tailings Cells I and
2, followed by groundwater sampling and analysis, and later submittal of another Background
Ground Water Quality Report to determine reliable background conditions and groundwater
compliance limits for the new wells.
During the course of discussions with DUSA staff, and further DRC review, the DRC decided to
supplement the analysis provided in the background report for the existing wells. On April 3,
2OO7 the DRC notified DUSA in a letter that the State would commission the University of Utah
to perform a geochemical and isotopic groundwater study at White Mesa. DUSA did not
contribute financially to the study, but provided the DRC and the University access to perform
the study (see May 19, 2008 DRC Memo , p.7).
University of Utah Study
The University of Utah conducted a study entitled"Evaluation of Solute Sources at Uranium
Processing Site" (hereafter Study) at the DUSA White Mesa Uranium Mill. The purpose of this
Study was to verify if the increasing and elevated trace metal concentrations (such as uranium)
found in the monitoring wells at the mill were due to leakage from the on-site tailings cells. To
investigate this potential problem, the study examined groundwater flow, chemical composition,
noble gas and isotopic composition, and age of the on-site groundwater. Similar evaluation was
also made on samples of the tailings wastewater and nearby surface water stored'in the northern
wildlife ponds at the facility. Fieldwork for the Study was conducted July 17 - 26 of 2007. A
final report was provided to the DRC via email on May 18, 2008. The May, 2008 University of
Page2 of 42
o
(hereafter University Report) has been i
o
ncluded as Attachment 1,Utah Study Final Report
below.
With respect to the four downgradient wells in question described above, the University of Utah
Study collected groundwater isotopic and other geochemical samples from three wells, MW-3,
MW-14, and MW-15. No sampling was performed in well MW-17 due in part to its more cross-
gradient hydraulic position, in that the other three wells were more directly downgradient of the
tailings cells. Also, the 10-foot long well screen in well MW-17 prevented depth profile
sampling there. Since the same problem was also found in well MW-3, and funding was limited,
the DRC chose to sample MW-3 and MW-3A instead. Consequently, it was assumed that the
isotopic and geochemical conditions in well MW-17 are similar as those found in the other
downgradient wells.
After review of the May, 2008 University Report, DRC staff agreed with DUSA that
downgradient wells Mw-3, Mw-14, Mw-15, and MW-17 (with excess total uranium
concentrations) are likely the product of artiflcial recharge from the wildlife ponds mobilizing
natural uranium in the vados e zone, and not from tailings cell leakage. This conclusion is based
on at least 3 lines of isotopic evidence (see university Report, and May 19, 2008 DRC
memorandum):
Tritium Signature - wells MW-3, MW-3A, MW-14, and MW-15 had tritium signatures in
groundwater at or below the limit of detection (0.3 Tritium Units). These values are
more than an order of magnitude below the corresponding surface water results found in
either the tailings cells or the wildlife ponds. Consequently, the groundwater in these 4
downgradient wells is much older than water in the tailings cells, and is of a different
origin than the tailings wastewater.
Stable Isotopes of Deuterium and Oxygen-18 in Water - the Deuterium and Oxygen-18
content of the groundwater matrix and tailings wastewater matrix was tested in all of the
water sources studied. university results showed that wells Mw-3, Mw-3A, Mw-14,
and MW-15 (all downgradient with the elevated uranium concentrations) had Deuterium
/ Oxygen- 18 signatures that were almost twice as negative as any of the surface water
results. Consequently, groundwater in these downgradient wells had a different
geochemical origin than the tailings cell wastewater.
Stable Isotopes on Dissolved Sulfate - the University Study evaluated 2 stable isotopes
found on sulfate minerals dissolved in the water samples (Oxygen-18, and Sulfur-34).
These samples showed that the sulfate solutes in groundwater from downgradient wells
MW-3, MW-3A, MW-14, and MW-15 had a different isotopic signature than the sulfate
minerals dissolved in the tailings wastewater. In the case of Oxygen- l8 on sulfate, the
downgradient wells showed more negative values than the tailings cells wastewater. For
Sulfur-34, the results were inversed, with groundwater showing more positive values than
the negative values seen in the tailings wastewater. As a result, the sulfate dissolved in
the downgradient wells, with elevated uranium concentrations, has a different origin than
the tailings wastewater.
As a result of these findings, together with the conclusions reached in the DUSA Background
Ground Water Quality Reports, the Executive Secretary has determined that the elevated and
rising total uranium concentrations seen in wells MW-3, MW-14, MW-15, and MW-17 are not
the product of tailings cell leakage. Instead, they are likely the result of changing geochemical
conditions brought on by artificial recharge to the shallow aquifer by mounding from the nearby
l.
2.
3.
Page 3 of 42
south wildlife ponds. These changes are possibly caused when rising water caused by the
recharge mounds, flows along subterranean paths that were previously un-traveled and
unsaturated, thereby dissolving solutes that were once fixated to the geologic formation.
Changes in redox conditions would no doubt also be related to these rising water levels, and
could conffibute to the additional solutes in question. Consequently, the Executive Secretary is
confident that background groundwater concentrations, and GWCLs developed thereon, from
available historic data from these and other DUSA wells located downgradient of the tailings
cells have not been adversely influenced by tailings cell leakage.
Wildlife Ponds
The University Study documented that artificial recharge water from the wildlife ponds has
altered the shallow aquifer geochemistry at the Mill site. The recharge water is from the local
reservoir (Recapture Reservoir). To this day, no lining system has been constructed under any of
the wildlife ponds; therefore, the wildlife ponds provide a nearly constant source of recharge to
the shallow aquifer at the site (see December 1, 2004 DRC SOB, p.4). The University Study
showed that significant and measurable quantities of tritium are present in wells MW-27 and
MW-19, indiciting that recharge to the aquifer from the wildlife ponds is occurring (see
University Report, pp.26 - 27).
Under the Utah Ground Water Quality Protection Rules (UAC R317-6-1.2), background
concentration is defined as a pollutant concentration that "... has not been affected by that
facility, practice, or activity." Under a strict interpretation, the proposed changes to GWCLs in
wells MW-19 and l|l4W-27 may not appear consistent with the Ground Water Quality Protection
Rules, in that the wildlife ponds are on the Mill property, and as a result, could possibly be
considered to be an extension of the uranium milling activity and have altered the tritium and
stable deuterium / oxygen- 18 signatures there. However, this impact is one of a secondary
nature, and not the direct result ofany tailings cell discharge; therefore, the Executive Secretary
has determined that the hydraulic influence of the wildlife ponds will not be considered, for
purposes of monitoring the tailings cells and the setting of GWCLs for downgradient wells.
While the wildlife ponds are related to facility operations, they are not central to tailings
disposal. These ponds provide a habitat for migratory birds, and encourage them to avoid
contact with the acid laden tailings cells. However, if the constant source of artificial recharge
continues at the wildlife ponds, the isotopic signatures seen in the wells near the wildlife ponds
will eventually be propagated to locations that are downgradient of the tailings cells. When this
happens, it is likely that the isotopic tools we have today will be lost or impaired, and therefore it
could be much more difficult in the future for DUSA to prove that a future exceedance of a
GWCL in a downgradient well is not the product of a tailings cell release. In the event that the
DUSA is unable to distinguish natural uranium concentrations from concentrations attributed to
tailings cell leakage, the Executive Secretary would have no other choice, but to require DUSA
to cleanup the aquifer.
However, the loss of these isotopic tools could be prevented if the wildlife ponds were
appropriately lined to minimize seepage losses to groundwater. By denying the artificial
recharge from the wildlife ponds; the underlying groundwater mounds would be reduced in size,
groundwater flow would return to its normal pathways, and the aquifer would eventually return
to equilibrium.
Page 4 of 42
Therefore, DUSA is proceeding at its own risk. If the GWCLs (set herein this Permit
modification) are exceeded in the future, and DUSA is not successful at showing how the
groundwater in the affected wells have a different geochemical signature than the tailings
wastewater, i.e., groundwater is old vs. young tailings wastewater, or different isotopic
fingerprint (S-34, O-18, etc,) - then it will be DUSA's burden to implement GW corrective
action, as per UAC R317-6-6.15.
BACKGROUND REPORTS
Existing Wells
On Decemb er 29,2006, DUSA submitted a Background Ground Water Quality Report for the
on-site Existing Wells (Background Report). An Addendum to the Background Report was
submitted to the DRC on April 19, 2007. DUSA claimed the "purpose of the Addendum is to
supplement the Background Report by focusing exclusively on pre-operational site data and all
available regional data to develop the best available set ofbackground datafor the site that
could not conceivably have been influenced by mill operations."
Review of both reports were conducted by the URS Corporation (URS) on behalf of the DRC.
After review of the Background Report, URS concluded that modifications to the Report were
required in order for the analysis in the Report to more specifically comply with certain
Environmental Protection Agency Guidance (hereafter EPA Guidance) for data preparation and
statistical analysis of groundwater quality data, including treatment of non-detectable values,
statistical methods, etc. In an August 9, 2008 DRC e-mail, the DRC provided DUSA with the
following EPA Guidance to be followed:
L February, 1989, "Statistical Analysis of Ground-Water Monitoring Data at RCRA Facilities
Interim Final Guidance", lJ.S. Environmental Protection Agency, Office of Solid Waste,
530-SW-89-026, and
July, 1992, "Statistical Analysis of Ground-Water Monitoring Data at RCRA Facilities
Addendum to Interim Final Guidance", IJ.S. Environmental Protection Agency, Office of
Solid Waste.
In an August 10,2007 Completeness Review, DRC Findings, and Confirmatory Action Letter
(CAL), the DRC documented ways in which the Background Report needed to be revised in
order to conform to the EPA Guidance before the review process could be completed. The CAL
also outlined the DUSA commitment to revise the Background Report in accordance with the
EPA Guidance and submit a Decision Tree/Flowchart for the groundwater data preparation and
statistical analysis process on or before August 16,2007 (see August 10,2007 DRC CAL).
On August 16,2007 DUSA submitted a Decision Tree/Flowchart diagram. The Decision
Tree/Flowchart was conditionally approved by the DRC on August 24,2007. On October 26,
2007 DUSA submitted a Revised Background Ground Water Quality Report for on-site Existing
Wells (Revised Background Report). A Revised DUSA Addendum was submitted on November
16,2007.
Review of the October 26 and November 16,2007 DUSA reports was conducted by URS on
behalf of the DRC, and is documented in a June 16, 2008 URS Completeness Review for the
Revised Background Groundwater Quality Report: Existing Wells (hereafter URS
2.
Page 5 of 42
Memorandum). The Revised Background Report included new proposed GWCLs for the 38
constituents in each of the 13 existing wells, for a total of 494 individual data sets. As
documented in the URS Memorandum, there were some GWCLs (24 out of a total of 494) where
an unapproved approach (e.g., highest.historic value instead of the Poisson Limit) was used by
DUSA to determine the GWCL. DUSA took this unapproved approach as a means to set
GWCLs for contaminants with increasing concentration trends.
While it is true that the Flowchart did allow a modified approach to setting GWCLs for upward
trending constituents, the August24,2007 Conditional Approval for the Flowchart plainly states
that " Please be advised that before the DRC considers such a proposal, DUSA will be required
to provide sfficient technical explanation and justificationfor why the most recent data is both
representative and protective of local groundwater resources."
Therefore, because there was no discussion with or approval by the DRC about this modified
approach before the Revised Background Report was received by the DRC on October 26,2007',
DUSA failed to correctly follow the approved Flowchart. Consequently, GWCLs proposed for
upward trending constituents were not approved by the Division.
In addition, there were also some GWCLs (31 out of a total of 494) where there was a
typographical error in the value of the GWCL. These DUSA proposed GWCLs that varied from
the Decision Tree/Flow Chart and the GWCLs that contained typographical errors are listed in
Table I of the URS Memorandum, along with the final GWCLs set by the Executive Secretary.
The June 16, 2008 URS Memorandum has been included as Attachment2. In the end, the URS
Memorandum recommended acceptance of 439 of the 494 DUSA GWCLs proposed.
The June 16, 2008 URS Memorandum, was shared with DUSA by e-mail on June 18, 2008. On
July 2,2008, INTERA, Inc. on behalf of DUSA submitted a Response to the URS Memorandum
(Response Memo). In the Response Memo, DUSA presented additional information and asked
the Executive Secretary to take this new information into consideration when determining
GWCLs.
After review of the Revised Background Report, Revised Addendum, URS Memorandum,
DUSA Response Memo, and consideration of the University of Utah Study Final Report; the
Executive Secretary has determined the following: 1) The DRC accepts 439 of the 494 GWCLs
values proposed by DUSA in the Octob er 26,2007 Revised Background Report , and 2) For the
remaining 55 GWCLs, the DRC will adopt the values calculated by URS in Table I of the June
16, 2008 URS Memorandum.
New Wells
Compliance schedule item Part I.H.l required DUSA to install several new monitoring wells,
primarily around the tailings Cells 1 and 2. After at least eight quarters of groundwater quality
data in these new wells, Part I.H.4 required DUSA to also submit a Background Ground Water
Quality Report for the new wells that complied with the information requirements of Part I.H.3.
On December 4,2007, DUSA submitted a Background Ground Water Quality Report for the
New Wells (New Wells Background Report). Review of the New Wells Background Report,
was conducted by DRC Staff. After review of the New Wells Background Report, it was
apparent that the report was not written in conformity with the EPA Guidance.
Page 6 of 42
In a February 14,2008 Completeness Review, DRC Findings, Request for Information, and
Confirmatory Action Letter (CAL), the DRC outlined a number of these issues with the New
Wells Background Report that needed to be resolved before the review process could be
completed. The CAL also summarized the DUSA commitment to revise the New Wells
Background Report to conform to the EPA Guidance provided to them in the August 9, 2008
DRC e-mail, and resubmit the report by April 30, 2008.
On April 30, 2008, DUSA submitted the Revised New Wells Background Report. DRC review
is found in a June 24,2008 DRC Findings and Recommended Action Memorindum (DRC New
Wells Memorandum). The Revised New Wells Background Report concluded that the sampling
results for the new wells confirm that the groundwater at the Mill site and in the region is highly
variable naturally and has not been impacted by tailings cell operations and that varying
concentrations of constituents at the site are consistent with natural background variation in the
area.
The Revised New Wells Background Report included new proposed GWCLs for the 38
constituents in each of the nine new wells, for a total of 342 individual data sets. As documented
in the DRC New Wells Memorandum, there were several GWCLs (146 out of a total of 342)
where DUSA used the wrong approach to determine the GWCL or where there was a
typographical error in the value of the GWCL. These proposed GWCLs are listed in Table 1
along with the corrected GWCL values set by the Executive Secretary in the DRC New Wells
Memorandum, which is included below as Attachment 3.
In 43 of those instances, DUSA recommended an approach that varied from the Decision
Tree/Flow Chart diagram (e.g., mean plus 2O7o instead of the mean plus two standard deviations
for data sets with very low variability). In the Revised New Wells Background Report, DUSA
claimed that during the calculation of GWCLs that were determined by the mean pius two
standard deviations, a condition arose that didn't occur during the same calculation of the
existing wells. Because data from the new wells is limited to around two years and was analyzed
by the same laboratory, the standard deviation could be typically lower than similar values for' the existing wells, in some cases resulting in a GWCL that is very close to the average value of
the data set. Therefore, for the cases where following the flowchart resulted in a GWCL that is
very close to the average value of the data set, DUSA proposed GWCLs that were be based on
the mean plus 20 percent (7 +207o) rather than following the flowchart.
The GWCLs proposed by the i +20Vo method were rejected by the DRC during review of the
New Wells Background Report and during review of the Iuly 2,2008 Response Me-o because
DUSA didn't follow the Decision Tree/Flow Chart diagram, which was created by DUSA, and
was conditionally approved by the DRC on August 24,2007. Additionally, this proposed
method was not based on the EPA Guidance given to DUSA in an August 9, 2008 DRC e-mail.
Further, it is not unexpected to see data sets with low variability when using the same analytical
laboratory over a short period of time. However, this problem can be addressed in the future, if
it occurs, in that DUSA has the ability to provide new descriptive statistics for a given well and
contaminant as more data becomes available, and request the Executive Secretary approval
thereof.
Also, DUSA argues that, assuming a normal distribution, setting a value of two standard
deviations above the mean, virtually guarantees that each well will be out of compliance (falsely)
in about two and a half percent of all concentration values measured in groundwaier samples
PageT of 42
from that well. While it is true that a GWCL that is set at the mean plus the second standard
deviation, which corresponds totheg5%o upper confidence limit, has a2.5Vo (0.025) probability
of any parameter in any well falsely exceeding its GWCL during any given sampling event.
DUSA would not be considered in out of compliance until two consecutive groundwater quality
samples exceed the respective GWCL (7 +2o concentration) for each well and contaminant in
question. On a statistical basis this equates to a0.062Vo (0.025) probability that any given well
and parameter will twice, consecutively, falsely exceed its respective GWCL.
After review of the Revised New Wells Background Report and consideration of the University
of Utah Study Final Report; the Executive Secretary has determined the following: 1) The DRC
accepts 196 of the 342 GWCLs values proposed by DUSA in the April 30, 2008 Revised New
Wells Background Report, and2) For the remaining 146 GWCLs, the DRC will adopt the values
calculated by DRC staff in Table I of the Jrrne24,2008 DRC New Wells Memorandum. For
details on the wells and parameters affected, see Table 1 in Attachment 3, below.
DRAFT PERMIT AND STATEMENT OF BASIS
The Draft Permit and SOB were shared with DUSA on April 7,2009. After DUSA review of the
documents, a meeting was held on May 11,2009 to discuss the Draft Permit and/or SOB.
During the meeting, DUSA voiced a concern about the new compliance schedule item at Part
I.H.4 of the Permit. This new compliance schedule item, required DUSA to conduct an
groundwater study, similar July 2007 University of Utah Study, in the monitoring wells and
surface water sites that were not part of the July 2007 University of Utah Study. DUSA argued
that the study was not repeatable as the July 2007 University of Utah Study was based on new
"cutting edge" or research groundwater analysis technology. DUSA claimed there were other
methods that DUSA could use to determine if the groundwater had been impacted by tailings cell
wastewater. The DRC invited DUSA to submit (in writing) what other methods they might use
in the future. To this date, no other method to determine if groundwater has been impacted by
tailings cell wastewater has been proposed by DUSA; therefore the Supplemental Isotopic
Groundwater and Surface Water Investigation and Report compliance schedule item found at
Part I.H.4 of the Permit stands.
DUSA was also concerned with setting GWCLs for constituents with rising concentration trends.
As discussed above, the Decision Tree/Flowchart does allow a modified approach to setting
GWCLs for upward trending constituents, after consultation and DRC approval. During the May
ll,2OOg meeting, DUSA discussed different options on how to deal with these upward trending
constituents. The DRC asked DUSA to put these options in writing. On June 5,2009, DUSA
submitted a technical memorandum, written by its consultant INTERA, that included a proposal
dealing with upward trending constituents. The proposal was as follows (see July 5,2009
INTERA Memo, p.16):
During each GWDP renewal review, each data set will be evaluatedfor increasing or
decreasing trends.
Each statistically significant increasing trend (decreasing pH) will be evaluated to
determine if it is anributable to causes related to Mill operations. In performing such an
evaluation, consideration will be given to the behavior in the well of the indicator
constituents: chloride, sulfate, fluoride and uranium, among other things. If there have
been no statistically significant rising trends in any of the indicator constituents, then that
would be considered to be prima facie evidence that the trend is due to natural
influences. If one or more indicator constituents demonstrates a significant upward trend,
PageB of 42
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the trend or trends are due tothen afurther analysis would be performed to determine if
natural influences.
If the trend is determined to be unrelated to Mill operations, evidence for that
determination will be documented in a report attached to the renewal application.
The report will include a graph of statistically significant trending data and an
extrapolation of that trend to the next renewal date.
The extrapolated value on the date of the next GWDP renewal will be set as the GWCL
for the period betvveen the two renewals.
The June 5,2009 DUSA proposal was rejected by the DRC because this "extrapolation method"
was not based on any EPA Guidance. Therefore for the time being, the proposed GWCLs for the
constituents with upward trends will be set as shown in Table 2 of the Permit.
MAJOR PERMIT CHANGES
GnouNu Wlrnn CllssmrcluoN
The original Ground Water Quality Discharge Permit was issued by the DRC on March 8, 2005.
As described in the related DRC December l, 2004 Statement of Basis, groundwater
classification was determined on a well-by-well approach in order to acknowledge the spatial
variability of groundwater quality at the DUSA facility, and afford the most protection to those
portions of the shallow aquifer that exhibited the highest quality groundwater. On an interim
basis, the Executive Secretary decided to base the well-by-well groundwater classification on the
mean total dissolved solids (hereafter TDS) concentration available at the time, and omit any
consideration of concentration variance. Part IV.N.2 allows the Permit, to be re-opened and
modified when a change in background groundwater quality has been determined.
Groundwater quality data documented in DUSA's background groundwater quality reports dated
October 2007 (existing wells) and April 30, 2008 (new wells), show an updated mean TDS
concentration and standard deviation for each individual POC well. These reports show the
shallow aquifer at White Mesa has highly variable TDS concentrations, ranging from about
1,019(MW-27)toover7,365 mgll-(MW-22). Table 1of thePermithasbeenupdatedwith
these new mean TDS and standard deviation calculations.
Using the TDS data from the DUSA background reports, and after calculation of average TDS
concentration for all 24POC wells, the Executive Secretary determined that four wells (MW-1,
MW-5, MW-11, and MW-30) at the facility appear to exhibit Class II or drinking water quality
groundwater. Of these four wells, only MW-l is located hydraulically upgradient of the tailings
cells. The 20 other wells appear to exhibit Class III or limited use groundwater at the site. For
details, see Table I of the modified Permit.
A key element in determination of groundwater classification is the presence of naturally
occurring contaminants in concentrations that exceed their respective GWQS. In such cases, the
Executive Secretary has cause to downgrade aquifer classification from Class II to Class III (see
UAC R317-6-3.6). During the review of the DUSA Background Ground Water Quality Reporrs,
the wells where this was necessary are show below:
Page9 of 42
Well Location Parameter GWOS New GWCL Rationale
MW-18 Upgradient of
Cell 1
Uranium 30 pg/L 55.1 pg/L
Well-18 is upgradient of
the tailing cells. In
addition, the U of U Study
showed that well MW-18
had different geochemical
signature than the tailing
cells.
MW-19 Upgradient of
Cell 1
Thallium 2pgtL 2.1ltglL
Well-19 is upgradient of
the tailing cells, therefore
it is unlikely groundwater
in this well has been
affected by tailing cell
wastewater.
MW-25 SE corner of
Tailing Cell 34'Manganese 800 pgll-1,806 pg/L
Manganese concentrations
in MW-25 have been
consistent since GW
sampling began in 2005.
Nearby well MW-ll
analyzed by the U of U
Study had a different
geochemical signature than
the tailine cells.
MW-27 Upgradient of
Cell 1
Uranium 3O yglL 34 ytgll-
Well-27 is upgradient of
the tailing cells, therefore
it is unlikely groundwater
in this well has been
affected by tailing cell
wastewater.
MW-31 Downgradient of
Tailing Cell2 Selenium 50 pg/L 7l pelL
U of U Study showed that
well MW-31 had different
geochemical signature than
the tailing cells. In
addition, the Background
Ground Water Quality
Reports concluded that
there had been no impacts
from tailinss cell disposal.
Revision of Groundwater Compliance Limits, Part I.C and Table 2
During this Permit modification, a new GWCL was calculated for each constituent in each POC
well. For details, see Table 2 of the modified Permit. After review of the October 26,2007
DUSA Revised Background Report, November 16,2007 Revised Addendum, June 16, 2008
URS Memorandum, Jlly 2,2008 DUSA Response Memo, April 30,2008 Revised New Wells
Background Report, and consideration of the May, 2008 University of Utah Study Final Report;
the Executive Secretary has set GWCLs for each of the 38 constituents in each POC well, as
follows:
Page lO of 42
Nutrients
Ammonia (as N) - GWCLs for Ammonia (as N) were calculated by either: 1) the fraction of the
GWQS, be it a Class II (6.25 p{L), or Class III (12.5 ,rglL) aquifer, 2) meanplus two standard
deviations (7 +2o),3) Aitchison's Mean + two standard deviations (Aitchison i +2o), or 4)
Cohen's Mean + two standard deviations (Cohen's 7 +2o). The revised GWCLs for Ammonia
(as N) ranged from 0.21 mg/L (MW-15) to 7.0 mglL (Mw-24). None of the Gwcls for
Ammonia (as N) accepted by the Executive Secretary in this proposed action are above the Utah
GWQS.
Nitrate + Nitrite (as N) - GWCLs for Nitrate + Nitrite (as N) in 15 of the22POC wells were
calculated by the fraction of the GWQS, be it a Class II (2.5 pg/L), or Class III (5.0 pglL)
aquifer. The other 7 wells were calculated by other methods, as shown in the table below:
During review of the New Wells Background Report and other reports, a Nitrate contaminant
plume was identified by DRC staff in five monitoring wells in the mill site area, including wells:
MW-30, MW-3L,TW4-22,TW4-24, and TW4-25. Therefore, the GWCL for Nitrate in wells
MW-30 and MW-31 in this Permit modification were set at the fraction of the GWQS, i.e.,2.5
and 5.0 ltglLfor the Class II and III aquifers, respectively; rather than the GWCLs proposed by
DUSA in these wells. None of the GWCLs for Nitrate + Nitrite (as N) accepted by the
Executive Secretary in this proposed action are above the Utah GWeS.
The presence of this Nitrate contamination plume was brought to the attention of DUSA in a
September 30, 2008 DRC letter. Shortly thereafter, DUSA agreed to investigate the source and
extent of the contamination and submit a report to the DRC on or before January 4, ZOIO, for
Executive Secretary review and approval. This agreement was formalized on January ZB,2OOg
in a Stipulated Consent Agreement signed by both parties. DUSA has identified a number of
potential sources for the contamination, including potential offsite and historic sources. DUSA
has noted thatTW4-Z5 is located nearly one quart;r of a mile upgradient of the Mill's tailings
cells, suggesting that the plume has originated upgradient of the Mill's tailings cells.
Heavy Metals
Arsenic - the GWCLs for arsenic were calculated in the same way as the original March 8, 2005
Permit in each POC well, with some exceptions (see table below). Therefore, the GWCL for
arsenic in the majority of the wells will remain at the fraction of the GWQS (50 prg/L), be it a
Class II (12.5 $elL), or Class lll (25 $g/L) aquifer.
Nitrate (as N) Exceptions
Well New GWCL Calculated Bv
MW-2 0.12 us.lL Highest Historical Value
MW-3 0.73 tts.tL 7 +2o
MW-3A 1.3 tts,lL 7 +2o
MW-15 0.27 pstL 7 +2o
MW-19 2.83 us.tL 7 +2o
MW-26 0.62 lusfi,Cohen's 7 +2o
MW-27 5.6 ttslL 7 +2o
Pagellof42
Arsenic Exceptions
Well New GWCL Calculated By
MW-5 17 lus,fi-H shest Historical Value
MW-11 15 us,tL H shest Historical Value
MW-24 17 tts,lL Aitchison's 7 +2o
MW-28 2l pelL i +2o
None of the GWCLs for arsenic accepted by the Executive Secretary in this proposed action are
above the Utah GWQS.
Beryllium - the GWCLs for beryllium were calculated in the same way as the original March 8,
2005 Permit in each POC well. Therefore, the GWCL for beryllium in all wells will remain at
the fraction of the GWQS (4 ttgll), be it a Class II (1.0 pg/L), or Class III (2.0 pgtL) aquifer.
Cadmium - the GWCLs for cadmium were calculated in the same way as the original March 8,
2005 Permit in each POC well, with some exceptions (see table below). Therefore, the GWCL
for cadmium in the majority of the wells will remain at the fraction of the GWQS (5 tr"tg/L), be it
a Class ll (1.25 pglL), or Class lll (2.5 pelL) aquifer.
The cadmium GWCLs proposed in wells MW-3A, MW-12, and MW-28 are above the Utah
GWQS of 5 pgll-. For the cadmium GWCL in well MW-3A (8.3 pgll-), the Executive Secretary
believes this is acceptable after review of the University of Utah study, which showed that well
MW-3A had a different geochemical signature than the tailing cells (see University Report, pp.
26 - 27). Additionally, well MW-3A is far downgradient of the tailing cells; therefore, it is
highly unlikely that the cadmium concentrations seen in well MW-3A could be attributed to the
tailing cells.
The cadmium GWCL proposed in well MW-12 is likely due to suspect data collected in the past
sampling events, as cadmium concentrations have been non-detect in all sampling events, but
one since 2nd Quarter 2005. However, the statistical methodology agreed to previously, leads the
Executive Secretary to set this GWCL above the GWQS in this well. In the future, if additional
data shows the situation has changed, the GWCL can be adjusted at that time.
Since groundwater sampling began in well MW-28 (2nd Quarter 2005), cadmium concentrations
have been around 4.5 pgtL. Unfortunately, well MW-28 was not part of the University of Utah
Study. However, the Background Ground Water Reports concluded that, the sample results for
Cadmium in MW-28 are within the range established for the site, and the Executive Secretary
Cadmium Exceptions
Well New GWCL Calculated By
MW-1 4.2 us.ll-Hiehest Historical Value
MW-3 4.67 vetL Cohen's T +2o
MW-3A 8.3 ue/L Cohen's 7 +2a
MW-5 2us.lL Poisson Limit
MW-12 7 tts,lL Hiehest Historical Value
MW-25 1.5 uelL x +/.a
MW-28 5.2 tts.lL 7 +2o
MW-32 4.72 rts,lL Cohen's T +2o
Fnntnntc' hnld texf = GWCI -tha the State GWOS.
Page 12 of 42
believes that the cadmium levels in well MW-28 are not likely caused by tailings cell
wastewater, and is therefore proposing a GWCL that is slightly greater rhan the GWQS (5.0
ItglL). A new compliance schedule item was added at Part I.H.4 of the Permit that requires
DUSA to perform a geochemical isotopic investigation in the monitoring wells and surface water
sites that were not part of the July 2007 University of Utah Study. If the new groundwater
isotopic study required by Part I.H.4 shows that groundwater quality in this well has been
adversely affected by the mill operations, Division review and appropriate action will be taken.
Chromium - the GWCLs for chromium were calculated in the same way as the original March
8, 2005 Permit in each POC well. Therefore, the GWCL for chromium will remain at the
fraction of the GWQS (100 prgll-), be it a Class II (251tgll-), or Class III (50 pgtL) aquifer.
Cobalt - the GWCLs for cobalt were calculated in the same way as the original March 8, 2005
Permit in each POC well, with two exceptions (MW-28 and MW-32). Therefore, the GWCL for
cobalt will remain at the fraction of the GWQS (7301tgtL), be it a Class II (182.5 ttglL), or Class
III (365 pglL) aquifer. The GWCLs proposed for cobalt in wells MW-28 @7 pgil,) and MW-32
(75.21 pg/L) were calculated by the mean plus two standard deviations (7 +2o). None of the
GWCLs for cobalt proposed herein by the Executive Secretary are above the Utah GWQS.
Copper - the GWCLs for copper were calculated in the same way as the original March 8, 2005
Permit in each POC well. Therefore, the GWCL for copper will remain at the fraction of the
GWQS (1,300 pglL), be it a class II (325 pelL), or class III (650 perL) aquifer.
Iron - the GWCLs for iron were calculated in the same way as the original March 8, 2005 Permit
in each POC well, with some exceptions (see table below). Therefore, the GWCL for iron in the
majority of the wells will remain at the fraction of the GWQS ( I 1,000 pg/L), be it a Class II
(2,750 pgll-), or Class III (5,500 ttglL) aquifer. The revised GWCLs for iron ranged from 81.7
pg/L (Mw-27) to 14,060 pgll- (MW-32).
The iron GWCL of 14,060 pg/L in well MW-32 is above the Utah GWQS of 11,000 prgil. Well
MW-32 has shown high iron concentrations since groundwater sampling began there in the I't
Quarter of 2005. These iron concentrations are not believed to be related to tailing cell
wastewater, as uranium concentrations found in well MW-32 are among the lowest at the facility
(5.261t9tL). Additionally, there is a significant downward trend in iron in well MW-32.
Therefore, the Executive Secretary believes that the iron levels in well MW-32 are not likely
caused by tailings cell wastewater, and is therefore proposing a GWCL that is greater than the
Iron Exceptions
Well New GWCL Calculated Bv
MW-2 151.6 uelI-Cohen's 7 +2o
MW-3 427.13 us.lL Cohen's 7 +2o
MW-15 81.7 rts.tL Cohen's 7 +2o
MW-18 414.68 tts,lL 7 +2c
MW-24 4,162 uelL 7 +2o
MW-26 2,675.83 us.L 7 +2o
MW-28 299 ps,fi-Cohen's 7 +2o
MW-29 1,869 ttp,lL 7 +2o
MW-32 14,060 usIL 7 +2o
Page 13 of 42
GWQS (11,000 FglL). The Background Ground Water Reports also noted that there is a
statistically significant downward trend in iron in MW-32, and iron is relatively immobile except
at very low pH and would be unlikely to indicate potential tailings cell seepage before other
constituents, such as chloride and uranium. If the new groundwater isotopic study required by
Part LH.4 shows that groundwater quality in this well has been adversely affected by the mill
operations, Division review and appropriate action will be taken.
Lead - the GWCLs for lead were calculated in the same way as the original March 8, 2005
Permit in each POC well, with two exceptions (MW-l and MW-5). Therefore, the GWCL for
lead will remain at the fraction of the GWQS (15 pgll-), be it a Class II (3.75 pgtL), or Class III
(7.5 pelL) aquifer. The GWCL.for lead in wells MW-1 (5.59 pg/L) and MW-5 (4.1 pgil) were
calculated by the Poisson Limit. None of the GWCLs for lead accepted by the Executive
secretary are above the Utah GWQS.
Manganese - the proposed GWCLs for manganese exceed the Utah GWQS (800 pgll) in l l of
22 wells (see table below). For the remaining 11 wells, GWCLs were set at 400 prg/L and below
using the fractions approach. The Background Reports showed the shallow aquifer at White
Mesa has highly variable manganese concentrations, ranging from 6l pgtL (MW-30) to 7 ,507
uell (Mw-24).
For the excess manganese GWCLs proposed in wells MW-3, MW-3A, MW-14, and MW-29 that
are above the Utah GWQS of 800 trrg/L, the Executive Secretary believes this is appropriate
based on the University of Utah study, which showed that these wells had a different
geochemical signature than the tailing cells wastewater (see University Report, pp.26 - 27).
Therefore, it is unlikely that the manganese concentrations seen in these wells could be attributed
to the tailing cells.
Unfortunately, wells MW-12, MW-17, IldW-24, MW-25, MW-26, MW-28, and MW-32 were
not part of the University of Utah Study. A new compliance schedule item was added at Part
LH.4 of the Permit that requires DUSA to perform a geochemical isotopic investigation in the
monitoring wells and surface water sites that were not part of the July 2007 University of Utah
Study. In the meantime, the Executive Secretary believes it is unlikely that the concentrations
found in these wells can be linked to tailing cell wastewater. If the new groundwater isotopic
Manganese Exceptions
Well New GWCL Calculated Bv
MW-3 4,233 ttgll-i +2o
MW-3A 6,287 ltgtL i +2o
MW-12 2,088.80 pell,7 +2a
MW-14 2,230.301t9tL 7 +2a
MW-17 915.4lsIL x +lo
MW-24 7,507 ttglL x +'/.6
MW-25 1,806 usll.x +26
MW-26 l.610 tsIL Hishest Historical Value
MW-28 1,837 ttslL x +Zo
MW-29 5,624$elL x +Zc
MW-32 5,594.9 pelL x +./.o
Page 14 of 42
study required by Part I.H.4 shows that groundwater quality at these wells have been adversely
affected by the mill operations, Division review and appropriate action will be taken.
Mercury - the GWCLs for mercury were calculated in the same way as the original March 8,
2005 Permit in each POC well. Therefore, the GWCL for mercury will remain at the fraction of
the GWQS (2.0 ltgtL), be it a Class II (0.5 pgll-), or Class III (1.0 pgtL) aquifer.
Molybdenum - the GWCLs for molybdenum were calculated in the same way as the original
March 8,2005 Permit in each POC well, with two exceptions (MW-14 and MW-15). Therefore,
the GWCL for molybdenum will remain at the fraction of the GWQS (40ltglL), be it a Class II
(10 pg/L), or Class III (20 pglL) aquifer. The GWCL for molybdenum in wells MW-14 (25
ItglL) and MW-15 (30 pgll) were calculated by the Highest Historical Value. None of the
GWCLs for molybdenum proposed herein by the Executive Secretary are above the Utah
GWQS.
Nickel - the GWCLs for nickel were calculated in the same way as the original March 8, 2005
Permit in each POC well, with some exceptions (see table below). Therefore, the GWCL for
nickel in the majority of the wells will remain at the fraction of the GWQS (100 prg/L), be it a
Class II (251lg[), or Class III (50 pglL) aquifer.
The nickel GwcL of 105 ltglLin well MW-3A is above the utah Gwes of 100 pgl]-.
However, the Executive Secretary believes this is appropriate because the University Study
showed that well MW-3A had a different isotopic geochemical signature than the tailing cells
wastewater (see University Report, pp.26 - 27). Additionally, well MW-3A is far downgradient
of the tailing cells; therefore it is highly unlikely that the nickel concentrations seen in well MW-
3,A. could be attributed to the tailing cells.
Selenium - the GWCLs for selenium were calculated in the same way as the original March 8,
2005 Permit in each POC well, with some exceptions (see table below). Therefore, the GWCL
for selenium in the majority of the wells will remain at the fraction of the GWQS (50 trrg/L), be it
a Class II (12.5 pglL), or Class lll (25 $glL) aquifer).
Nickel Exceptions
Well New GWCL Calculated By
MW-2 60 uslL Hiehest Historical Value
MW-3 100 ueil Hiehest Historical Value
MW-3A 105 ue/L Aitchison's 7 +2o
MW-5 44.1ps./I-Poisson Limit
MW-l1 46.2 us.tL H ghest Historical Value
MW-12 6O tslL H ghest Historical Value
MW-15 97 tts,lL H ghest Historical Value
MW-32 94 uqlL Hiehest Historical Value
Selenium Exceptions
Well New GWCL Calculated Bv
MW-2 26.6 uelL Cohen's 7 +2a
MW-3 37 uslL Hiehest Historical Value
MW-3A 89 u,eIL i +2o
Page 15 of 42
MW-15 128.7 uelL Cohen's 7 +2o
MW-19 28.96 us.lL Cohen's 7 +2o
MW-28 l1.l vs,L Aitchison's 7 +2o
MW-30 34 vs.L 7 +2a
MW-31 7l u,q/L 7 +2o
The selenium GWCLs in wells MW-3A, MW-15, and MW-31 are above the Utah GWQS of 50
trrgll. However, the Executive Secretary believes this is appropriate because the University
Study showed that wells MW-3A, MW-15, and MW-31 had different isotopic geochemical
signatures than the tailing cells wastewater (see University Report, pp.26 - 27). Therefore, it is
unlikely that the selenium concentrations seen in these wells could be attributed to the tailing
cells.
Silver - the GWCLs for silver were calculated in the same way as the original March 8, 2005
Permit in each POC well. Therefore, the GWCL for silver will remain at the fraction of the
GWQS (100 prg/L), be it a Class II (25 pgtL), or Class III (50 pgfD aquifer.
Thallium - the GWCLs for thallium were calculated in the same way as the original March 8,
2005 Permit in each POC well, with some exceptions (see table below). Therefore, the GWCL
for thallium in the majority of the wells will remain at the fraction of the GWQS (2 pglL), be it a
Class II (0.5 pg/L), or Class III (1.0 pglL) aquifer.
The thallium GWCL of 2.1 ltgtL in well MW-19 is slightly above the Utah GWQS ot 2.0 ltgll-.
The Executive Secretary believes this is appropriate because the University Study showed that
there was no isotopic evidence that well MW-19, which is upgradient of the Mill site, had been
exposed to tailing cell wastewater.
Tin - the GWCLs for tin were calculated in the same way as the last Permit modification (March
17 ,2008) in each POC well. Therefore, the GWCL for tin will remain at the fraction of the
GWQS (17,000 u/l), be it a Class ll (4,250 pgtL), or Class III (8,500 ltg/L) aquifer.
Uranium - the proposed GWCLs for uranium exceed the Utah GWQS (30 pg/L) in 9 of 22 wells
(see table below). The remaining 13 wells GWCL are set at221tgll- and below. The
Background Reports showed the shallow aquifer at White Mesa has highly variable uranium
concentrations, ranging from 4.9 pg/L (MW-28) to 98 pg/L (MW-14).
Thallium Exceptions
Well New GWCL Calculated Bv
MW-3 1.6 ps,fi-Hishest Historical Value
MW-3A 1.4 us.ll-Aitchison's T +2o
MW-18 1.95 us,I-Cohen's 7 +2o
MW-19 2.1rtslL Cohen's 7 +2o
MW-25 l.l us.ll-i +2a
MW-29 1.2 us.ll-Hiehest Historical Value
Page 16 of 42
Uranium Exceptions
Well New GWCL Calculated Bv
MW-3 47.32tdL x +2o
MW-3A 35 ue/L 7 +2o
MW-14 98 rtdL Highest Historical Value
MW-15 65.7 lsIL Highest Historical Value
MW-17 46.66rtslL 7 +2a
MW-18 55.1ttslL i +2a
MW-23 32 uc-IL 7 +2o
MW-26 41.8 pstL 7 +2o
MW-27 34 rts.IL 7 +2o
The uranium GWCLs in wells Mw-3, Mw-3A, Mw-14, Mw-15, and MW-1g are above the
Utah GWQS of 30 prg/L. However, the Executive Secretary believes this is appropriate because
the University Study showed that these wells had different isotopic geochemical signatures than
the tailing cells wastewater (see University Report, pp.26 - 27). Therefore, it is unlikely that the
uranium concentrations seen in these wells could be attributed to the tailing cells.
The uranium GWCL of 34 pgtL in well MW-27 is above the Urah GWQS of 30 pglL. Although
the University Study showed that significant and measurable quantities of tritium is present in
well MW-27, indicating that recharge to the aquifer from the wildlife ponds is occurring, there
was no isotopic evidence that well MW-27 had been exposed to tailing cell wastewater.
Unfortunately, wells MW-17, MW-23, and MW-26 were not part of the University of Utah
Study. A new compliance schedule item was added at Part I.H.4 of the Permit that requires
DUSA to perform a geochemical isotopic investigation in the monitoring wells and surface water
sites that were not part of the July 2007 University of Utah Study. In the meantime, the
Executive Secretary believes it is unlikely that the concentrations of uranium found in MW-17,
MW-23, and MW-26 can be linked to tailing cell wastewater. If the new groundwater isotopic
study required by Part I.H.4 shows that groundwater quality at these wells have been adversely
affected by the mill operations, Division review and appropriate action will be taken.
Yanadium - the GWCLs for vanadium were calculated in the same way as the original March 8,
2005 Permit in each POC well, with one exception (MW-15). Therefore, the GWCL for
Vanadium will remain at the fraction of the GWQS (60 prgll-), be it a Class II (15 pg/L), or ClassIII (30 pgtL) aquifer. The GWCL for vanadium in well MW-15 was calculated by the Highest
Historical Value, or 40 pgtL. None of the GWCLs for vanadium proposed by theExecutive
Secretary in this action are above the Utah GWQS.
Zinc - the GWCLs for zinc were calculated by the mean plus two standard deviations (i +2o),
Cohen's 7 +2o, or by the fraction of the GWQS (5,000 pg/L), be it a Class II (1,250 ltgll-), or
Class III (2,500 ttgtL) aquifer. None of the GWCLs for zinc proposed by the Executive
Secretary in this action are above the Utah GWQS.
Radiologics
Gross Alpha - GWCLs for gross alpha in 12 of the 22POC wells were calculated by the fractionof the GWQS (15 pCi/L), be it a Class II (3.75 pCilL), or Class III (7.5 pCi/L) aquifer. The orher
PagelT of42
o
by other10 wells were calculated methods, as shown in the table below:
None of the GWCLs for gross alpha proposed by the Executive Secretary in this action are above
the Utah GWQS.
Volatile Organic Compounds (VOCs)
Acetone - the GWCLs for acetone were calculated in the same way as the original March 8,
2005 Permit in each POC well. Therefore, the GWCL for acetone will remain at the fraction of
the GWQS (700 Ug&), be it a Class II (l751tg/L), or Class'III (350 ttglL) aquifer.
Benzene - the GWCLs for benzene were calculated in the same way as the original March 8,
2005 Permit in each POC well. Therefore, the GWCL for benzene will remain at the fraction of
the GWQS (5 pgll.), be it a Class II (1.25 pelL), or Class III (2.5 PglL) aquifer.
2-Butanone (MEK) - the GWCLs for 2-Butanone (MEK) were calculated in the same way as
the original March 8, 2005 Permit in each POC well. Therefore, the GWCL for 2-Butanone
(MEK) will remain at the fraction of the GWQS (4,000 pglL), be it a Class II (1,000 pg/L), or
Class III (2,000 pglL) aquifer.
Carbon Tetrachtoride - the GWCLs for carbon tetrachloride were calculated in the same way
as the original March 8, 2005 Permit in each POC well. Therefore, the GWCL for carbon
tetrachloride will remain at the fraction of the GWQS (5 pg/L), be it a Class II (1.25 trtglL), or
Class III (2.5 pelL) aquifer.
Chloroform - the GWCLs for chloroform were calculated in the same way as the original March
8, 2005 Permit in each POC well, with one exception (MW-26). Therefore, the GWCL for
chloroform will remain at the fraction of the GWQS (70 1tg/L), be it a Class II (17 .5 ltgtL), or
Class III (35 Ug/L) aquifer.
Well MW-26 is part of the chloroform investigation and cleanup, and is currently operated as a
pumping well for chloroform removal. The Executive Secretary proposes that the well MW-26
chloroform GWCL be set at the State GWQS or 70 pgll-. This is consistent with the on-going
investigation and cleanup process at the facility'
Gross Alpha Exceptions
Well New GWCL Calculated By
MW-2 3.2pCitL Cohen's i +2o
MW-3 1.0 pCi/L Hiehest Historical Value
MW-17 2.8 pCilL Hiehest Historical Value
MW-19 2.36pCill-Cohen's 7 +2o
MW-23 2.86pCifi-Aitchison's i +2o
MW-26 4.69 pCitL x +ZG
}{dW-27 2.0 pCilt-Aitch son's 7 +2o
MW-28 2.42 pCilL A tch son's 7 +2o
MW-29 2.0 pCilL A tch son's 7 +2o
MW-32 3.33 pCilL x +Za
Page 18 of 42
Chloromethane - the GWCLs for chloromethane were calculated in the same way as the
original March 8, 2005 Permit in each POC well, with some exceptions (see table below).
Therefore, the GWCL for chloromethane in the majority of the wells will remain at the fraction
of the GWQS (30 pgll-), be it a class II (15 prg/L), or Class III (30 pgrL) aquifer.
None of the GWCLs for chloromethane accepted by the Executive Secretary are above the Utah
GWQS.
Dichloromethane - the GWCL for dichloromethane was calculated in the same way as the
original March 8, 2005 Permit in each POC well, with one exception (MW-26). Therefore, rhe
GWCL for dichloromethane will remain at the fraction of the GWQS (5 pgll-), be it a Class II
(1.25 petL), or Class III (2.5 pglL) aquifer.
Well MW-26 is part of the chloroform investigation and cleanup, and is currently operated as a
pumping well for chloroform removal. Dichloromethane is a degradation product of chloroform.
In this Permit modification, the Executive Secretary recommends that the well MW-26
dichloromethane GWCL be set at the State GWQS or 5 prg/L. This is consistent with the on-
going aquifer cleanup project.
Naphthalene - the GWCLs for naphthalene were calculated in the same way as the original
March 8, 2005 Permit in each POC well. Therefore, the GWCL for naphthalene will remain at
the fraction of the GWQS (100 pg/L), be it a Class II (25 pelL),or Class III (50 pgtL) aquifer.
Tetrahydrofuran (THF) - has been seen in five historic monitoring wells, including: MW-1,
MW-2, MW-3, MW-5, and MW-12. In the October 2007 Revised Background Ground Water
Quality Report, DUSA proposed GWCLs for THF in these wells at concentrations above the
Permit GWCL and/or the Utah GWQS. In the Background Ground Water Reports and in
previous submittals by DUSA, DUSA has taken the position that the THF in these wells is due to
glues that were used in the completion of the casings for those wells. The Executive Secretary
has denied this proposal in this action because THF is not a naturally occurring constituent in
groundwater, and DUSA has not, to date, provided corroborating evidence to the Executive
Secretary that the THF is caused by glues used in the completion of the wells. Therefore, the
GWCL in each POC well was set at the fraction of the GWQS (46 pglL), be it a Class II (11.5
ttglL), or Class lll (z3pglL) aquifer.
Toluene - the GWCLs for toluene were calculated in the same way as the original March 8, 2005
Permit in each POC well. Therefore, the GWCL for toluene will remain at the fraction of the
GWQS (1,000 pg[L), be it a Class II (2501tglL), or Class III (500 pgtL) aquifer.
Xylenes (total) - the GWCLs for xylenes (total) were calculated in the same way as the original
March 8, 2005 Permit in each POC well. Therefore, the GWCL for xylenes (total) will remain at
Chloromethane Exceptions
Well New GWCL Calculated Bv
MW-23 5.7 uslL i +2c
MW-28 4.6 !s,ll-7 +2o
MW-31 6.1uelL i +2o
MW-3A 9.4 usfi,T +2o
Page 19 of 42
a
), or Clthe fraction of the GWQS (10,000 pgll,>, be it a Class II (2,500 ltglL
aquifer.
Others
ass III (5,000 pglL)
Field pH - the GWCLs for field pH were calculated using the Permit GWCL (6.5 - 8.5 s.u.) or
the mean minus two standard deviations (7 - 2o). The field pH GWCL in wells MW-28 (6.1 -
8.5 s.u.) and MW-29 (6.46 - 8.5 s.u.) exceed the Utah GWQS at the lower end of the range.
For well MW-29, the Executive Secretary believes this action is appropriate because the
University Study showed that well MW-29 had a different isotopic geochemical signature than
the tailing cells wastewater (see University Report, pp.26 - 27). Therefore, it is unlikely that the
low pH concentrations seen in well MW-29 could be attributed to the tailing cells.
Unfortunately, well MW-28 was not part of the University of Utah Study. A new compliance
schedule item was added at Part I.H.4 of the Permit that requires DUSA to perform a
geochemical isotopic investigation in the monitoring wells and surface water sites that were not
part of the July 2007 University of Utah Study. The Executive Secretary believes it is unlikely
that the low pH concentrations found in well MW-28 can be linked to tailing cell wastewater. If
the new groundwater isotopic study required by Part I.H.4 shows that groundwater quality in this
well has been adversely affected by the mill operations, Division review and appropriate action
will be taken.
Fluoride - the GWCLs for fluoride were calculated by the mean plus two standard deviations
(T +2o) or fraction of the GWQS (4 mgtL), be it a Class II ( 1 .0 mg/L), or Class III (2.0 mg/L)
aquifer. None of the GWCLs for fluoride accepted by the Executive Secretary are above the
Utah GWQS.
Chloride - there was no GWQS set for chloride in the original March 8, 2005 Permit, primarily
because the U.S EPA has not determined an appropriate drinking water health standard for this
contaminant. However, as a part of the DUSA's background groundwater quality reports dated
Ocrober 2007 (existing wells) and April 30, 2008 (new wells), DUSA proposed a GWCL be set
at each POC well for chloride. The Executive Secretary believes this is appropriate given the
presence of chloride in the tailings wastewater and its extremely high groundwater mobility. In
the DUSA reports referenced above, the chloride GWCLs were calculated by the Highest
Historical Value or mean plus two standard deviations (7 +2o); ranging from l0 mg/L (MW-23)
to 143 mgil (MW-31).
During review of the 3'd Quarter, 2008 Chloroform and Tailings Cell Groundwater Reports, it
was identified by DRC Staff that certain wells associated with the nitrate plume also showed
high concentrations of chloride ranging from I 13 mglL (TW4-19) to 1,180 mg/L (TW4-24) in
the southwest part of the mill site. Further, some of the new tailings cell monitoring wells also
shows elevated chloride concentrations, e.g., MW-28 (99 mgll-), MW-30 (l2l mglL), and MW-
3l (124 mglL). Therefore, it appears there may be a chloride plume that co-exists with the
nitrate plume. However, because there is not a corresponding human health or Ground Water
Quality Standard for chloride, the Executive Secretary is unable to determine if the chloride
concentrations in these tailings cell wells pose any potential for health risk to the public.
Without such a health limit, a determination was made to set the corresponding chloride GWCLs
in these wells based on the mean plus two standard deviation approach proposed in the DUSA
Page2O of 42
New Well Background Groundwater Quality Report. This resulted in chloride GWCLs of 105mg/L (MW-28),128 mg/L (MW-30), and 143 mgtL (Mw-31), see Draft permit,Tablez.
There is a possibility that the co-existence of the chloride and nitrate plumes could cause theDUSA statistics (upon which the chloride GWCLs in these three wells are based) to be biased
slightly higher than what otherwise may have been calculated. However, it was noted that in the
event that the apparent chloride and nitrate plumes are shown to have a cortmon source, that it islikely that the chloride concentrations in wells MW-28, MW-30 and MW-31, will increase above
the proposed GWCLs; due to the fact that a much higher concentration exists in upgradient wellTW4-24 (1,180 mglL). Under such circumstances two things would happen: 1) non-compliancewould be triggered and the Executive Secretary would call for a contaminant investigation report
under UAC R3l7-6-6.15(D), and2) because nitrate and chloride are both mobile groundwater
contaminants, it is likely that any corrective action for the nitrate plume can be adjusted to
adequately address the chloride problem. For these reasons, the Executive Secretary decided toaccept the chloride GWCLs proposed for these wells by DUSA.
Sulfate - there was no GWQS set for sulfate in the original March 8, 2005 permit, for the same
reason as stated above, the lack of an EPA drinking water standard. However, as part of theDUSA's background groundwater quality reports dated October 2007 (existing *ittr; and April
30, 2008 (new wells), DUSA proposed a GWCL be set at each POC well for sirlfate. Again, theExecutive Secretary believes this is appropriate given the extremely high sulfate concentrations
in the tailings wastewater and its extremely high groundwater mobility. In the DUSA reports
referenced above, the sulfate GWCLs were calculated by the Highest Historical Value or mean
plus two standard deviations (i +2o):ranging from532mg/L (MW-31) to 3,663 mglL(MW-3).
TDS - there was no GWQS set for TDS in the original March 8, 2005 Permit. After review of
the DUSA's background groundwater quality reports dated Octob er 2007 (existing wells) andApril 30, 2008 (new wells) a GWCL was set at each POC well for TDS. The TDS GWCLs were
calculated by the Highest Historical Value or mean plus two standard deviations (i +2o);
ranging from 1,075 mglt- (MW-27) to 6,186 mg/L (MW-3).
Routine groundwater quality monitoring is commonly done on a quarterly basis (4-times/year).
However, the Executive Secretary may allow a reduced frequency of rouiine groundwater
sampling if site specific groundwater conditions warrant [see UAC R317-6-6.16(4)(2)]. Forcertain sites where groundwater velocities have been found to be low (e.g., one to two feet peryear), the Executive Secretary has approved a semi-annual sampling frequency (2-times/year) inorder to avoid statistical problems such as auto-correlation, and allow u b"tt". -"usure of natural
groundwater quality vari ations.
As described in the DUSA Ground Water Quality Discharge Permit - December l,2OO4
Statement of Basis, there are two different frequencies of routine groundwater monitoring at theWhite Mesa Mill, as follows:
o Semi-annual (2-times/year) where groundwater velocity is less than l0 feet/year, ando Quarterly (4-times/year) where groundwater velocity is equal to or greater than l0
feetlyear.
Page2l of 42
partl.H.2 of the Permit required DUSA to submit a Revised Hydrogeologic Report after the
installation of the eight new compliance monitoring wells (MW-23,MW-24,MW-25, MW-27,
MW-28, MW-29, MW-30, and MW-31), as required by Part I.H.l. The new wells were installed
during May 2005 and DUSA submitted the Revised Hydrogeologic Report on August 23,2005.
The Revised Hydrogeologic Report was to include: 1) hydrogeologic data from each of the eight
new wells installed, 2) aquifer test results to determine local hydraulic conductivity at these eight
wells, and existing well MW-32 (formerly TW4-17), and 3) the calculation of linear groundwiiter
velocity for all nine wells.
After review of the Revised Hydrogeologic Report, DRC staff found that DUSA provided
aquifer permeability data and average linear velocity calculations for six of the eight new wells.
Oi ttrese six, three were shown to have average linear velocities of greater than 10 feetlyear,
including: MW-25 (14.5 feet/year), MW-30 (12.9 feetlyear), and MW-31 (10.6 feet /year). As a
result, the Executive Secretary has decided that these three wells should be sampled on a
quarterly basis (see November 16,2007 DRC Memorandum, Table 1), as set forth in Part
r.E.l(b).
The Revised Hydrogeologic Report did not include any DUSA calculation of average linear
groundwater velocities for wells M,W-24 and MW-3A. In the report, DUSA explained that: 1)
ii-it"A water in well MW-24 prevented the determination of aquifer permeability data needed,
and2) no average linear groundwater velocity for well MW-3A was calculated due to its close
proximity ro well MW-3 (within 10 feet); which DUSA determined previously to be 3.6
feeVyear.
In the case of well MW-24, where DUSA failed to provide aquifer permeability and velocity
information, the Executive Secretary has decided to assign a quarterly sampling frequency in
Part I.E.l (a). This approach is conservative, in that it provides more protection of groundwater
thru added sample frequency. In the event that DUSA provides the necessary information, the
Executive Secretary may reconsider this decision and modify the Permit as needed.
For well MW-3A, the Executive Secretary agrees that its close proximity to well MW-3 can be
used as a guide, and semi-annual monitoring frequency has been assigned at Part LE.1(c).
All other existing new DUSA tailings cell monitoring wells were found with local groundwater
velocities of less than 10 feet/year and will be sampled on a semi-annual basis, see Part I.E'l(c).
Average linear groundwater velocity for well MW-32 had previously been estimated by DRC
staff ai lgfeetlyear (seeNovember23,2004DRCMemorandum,Table 1);basedonaquifer
testing in two nearby wells. Therefore, well MW-32 was required to be sampled on a quarterly
basis in the original Permit. The August 23,2005 DUSA Revised Hydrogeologic Report tested
aquifer permeability in well MW-32 and calculated a liner velocity of 3.3 feet/year (see
November 16,2007 DRC Memorandum, Table l). Therefore, the Executive Secretary has re-
assigned a semi-annual sampling frequency to well MW-32 in Parts I.E.l (b) and I.E.1(c) of the
Permit.
Wells with Parameters in Out-of-Comnliance Status
A.c"l"rut"d groundwater monitoring begins when any contaminant in any monitoring well
exceeds its respective GWCL (see Part LG.1). As defined in Part I.G.2 of the Permit, out-of-
compliance status exists when two consecutive samples from a well exceeds the GWCL in Table
2 of the Permit.
Page22 of 42
After review of the October 26,2007 and April 30, 2008 DUSA background groundwater qualityreports and Executive Secretary approval ofbackground concentrations, disctissed above, tlereappear to be a few wells with parameters that will continue to exceed the new GWCLs;therefore, theses wells will remain in accelerated sampling and out-of-compliance status and areexplained below:
Tetrahydrofuran in MW-l
The original Permit provided DUSA the opportunity to develop a plan and complete a study toexplain the occurrence of THF, a man-made chemical, in five tristoric monitoring wells,including: Mw-l, Mw-2, Mw-3, Mw-5, and MW-12. To this end, DUSA sublitted plans
dated April 7 and December 15, 2005 for Executive Secretary review. Said study set out todemonstrate that the THF contamination was caused by PVi solvents and glues used in theoriginal well construction. After completion of the study, which included a series of THFsampling and analysis at well MW-2 during a well purging event, the June 26,2007 DUSA
report concluded that the sample results were inconclusive, because no THF was found in MW-2and the basis for the study in that well was not satisfied. Hence, the DUSA report provided nocause for the THF contamination. In a letter dated Decemberl2, 2007, the Exicutive Secretaryagreed with DUSA and advised the company that, in the absence of meaningful study results,that routine compliance monitoring for THF would be required for the foresieable future at allPOC wells at the facility. Later, the Executive Secretary iemoved the part I.H.1g studyrequirement from the Permit.
Because THF is a man-made chemical, the GWCL in all the POC wells in Table 2 of the permit
was set at the fraction of the GWQS, be it a Class II (1 1.5 prgll-), or Class lll (23 pglL) aquifer.At,well Mw-1, the THF GWCL has been exceeded in every-groundwater sampling event from
2nd qtr 2005 to 4th qtr 2007. Therefore, well Mw-l will remiin in out-of-compliance status forTHF and is required to be sampled on a quarterly basis until the Executive Secfotary determinesotherwise.
Chloroform in MW-26
Well MW-26 is part of the chloroform investigation and cleanup, and is currently operated as apumping well for chloroform removal. The Executive Secretary proposes that the well MW-26chloroform GWCL be set at the State GWQS or 70 pglL. This iJconsistent with the on-goinginvestigation and cleanup process at the facility. Because of the existing contamination, thisGWCL has been exceeded in every DUSA groundwater sampling "r"nirin"" sampling began inthe 2nd Qtr 2005. Therefore, well ivtw-26 will remain in outlof-compliance status for chloroformand is required to be sampled on a monthly basis until the groundwater concentrations fall belowthe GWQS. It should be noted that, because MW-26 is a pumping well for chloroform removal,concentrations of all constituents in that well are subject to potential variation over time as aresult of the pumping activity. This will be taken into account by the Executive Secretary indetermining compliance for this well.
Dichloromethane in MW-26
Well MW-26 is part of the chloroform investigation and cleanup, see discussion above.Dichloromethane is a degradation product of chloroform. In this permit modification, theExecutive Secretary recommends that the well MW-26 dichloromethane GWCL be set at theState GWQS or 5 pglL. Again, this is consistent with the on-going aquifer cleanup project. ThisGWCL has been exceeded in every ground water sampling "r"nt rin." sampling U"iun'i, the 2iT
Qtr 2005. Therefore, well MW-26 will remain in ourof-compliance status for dichloromethane
Page23 of 42
o
led onand is required to be samP
the GWQS.
a monthly basis until the groundwater concentrations fall below
Nitrate + Nitrite (as Nl in Wells MW-30 and MW-31
As part of the April 30, 2008 Revised Background Ground Water Quality Report, DUSA
proiosed a CWC1 for Nitrate + Nitrite (as Nitrogen) [hereafter Nitrate] in wells MW-30 and
MW-:f rhar was above the State GWQS (10 mg/L) [ibid., Table 10]. During review of the New
Wells Background Report and other reports, a Nitrate contaminant plume was identified by DRC
staff in five monitoring wells in the mill site area, including wells: MW-30, MW-31, TW4-22,
TW4-Z4,and TW4-25. Chloroform well TW4-25 is located upgradient of the Mill's tailings
cells.
On September 30, 2008, the Executive Secretary issued a request for a voluntary plan and
schedule for DUSA to investigate and remediate this Nitrate contamination. On November 19,
2008 DUSA submitted a plan and schedule prepared by INTERA, Inc., which identified a
number of potential ,our&r for the contamination, including several potential historic and offsite
sources. On January 27 ,2009, the Executive Secretary and DUSA signed a Stipulated Consent
Agreement by whicir DUSA agreed to conduct an investigation of the Nitrate contamination,
determine the sources of pollution, and submit a report by January 4,2010. After review and
approval of this report, thi Executive Secretary will determine if a groundwater corrective action
piu" ir required. fntil completion of this report and Executive Secretary approval, it would be
premature to set any Nitrate GWCL in excess of the GWQS'
Therefore, the GWCL for Nitrate in wells MW-30 and MW-31 in this Permit modification were
set at the fraction of the GWQS, i.e.,2.5 and 5.0 trrg/L for the Class II and III aquifers,
respectively. Historically, the Nitrate concentrations in both of these wells have exceeded the
GWCL in every groundwater sampling event since sampling began in the 2'd.Qtr 2005.
Therefore, the Executive Secretary expects that wells MW-30 and MW-31 will remain in
accelerated sampling and out-of-compliance status for Nitrate for the foreseeable future.
Uranium in MW-26
In the October 26,2007 Background Report, DUSA calculated the uranium background
concentration in well MW-26 on the mean plus two standard deviations ( 7 +2o), as 41'8 trrg/L,
which is above the State GWQS (30 pgil). This DUSA proposal was based on groundwater
quality data collected through August 2007. However, there have been recent groundwater
sampting events where consecutive uranium exceedances have been seen in well MW-26:.59.2
pglf i, February 2008 and 46.3 1tg/L in March 2008. Therefore, it is possible that MW-26 will
be in accelerated monitoring and out-of compliance status shortly after execution of the Permit.
Because well MW-26 was not included in the recent university of Utah study, it is unclear if the
uranium concentrations seen in well MW-26 are the product of the same processes responsible
for the long-term increasing trends seen existing wells MW-3, MW-14, and MW-15, as
discussed ubor.. A new Compliance Schedule Item has been added at Part I.H.4 of the Permit
and requires DUSA to conduci a groundwater study similar to the July 2007 University of Utah
Study ior the monitoring wells and surface water sites that were not part of the University of
Utahstudy. After DRCreview of the associated report, the Executive Secretary will determine
the sourceTorigin of the uranium concentrations in well MW-26. For more information on the
groundwater investigation, see discussion on Part I.H'4, below'
Page}4 of 42
Manganese in MW-14
In the October 26,2007 DUSA Background Report, the manganese background concentration inwell MW-14 was calculated by the mean plus two standard deviations ( f+2o), as 2,230.30
trrgil, which is in excess of the GWQS (800 prgll-). This proposed GWCL was based ongroundwater data collected through August 2007. However,-in every groundwater sampling
event after August 2007, well MW-14 has had manganese concentrations that exceed the
proposed GWCL' Therefore, the Executive Secretary anticipates that future sampling couldplace well MW-14 in accelerated sampling and out-of "o-piiun"" status, as per partl-G.2.
However, the recent university of utah study indicates that groundwater in well MW-14 is olderin age (lower tritium signature) and more indicative of upgradient groundwater found in wellMW-18 rather than the younger water from the wildlife ponds (higher tritium signature). This issubstantiated by tritium and stable deuterium / oxygen-18 geochemical evidence from the recentUniversity of Utah Study, as presented below:
of Selected Un
Footnotes:
l)irom May' 2008 University of Utah_isoropic groundwater geochemistry study received via email from Dr. Kip Solomon onMay 18,2008, Tables 4 (tritium) and 10.
WP2 = thg pg54 northem wildlife pond located near the northeast comer of the White Mesa mill site area, see Universityof Utah report, Figure 1. WP3 = south wildlife ponds.
TU = a standard tritium unit, or I tritiared molecule of water 1rH'Ho; in 1E+l g molecules of H2o.
P*j:l,lisastableheavyisotopeofhydrogen,2H. Thedeltaor6valuerepresentstheamountofdeviationintheratioof-tu'H ln the sample, as compared to a global reference sample of water.
oxygen-18 is a stable heavy isotope ofoxygen, '8o. The 6 value represents the amount ofdeviation in the ratio ofrso/,6oin the sample, as compared to a global reference sample of water.A second or repeat analysis of tailings cell sample TC3 had a tritium concentrarion of 7 .24 +/ - 0.55 TU.
As a result of this isotopic evidence, the Executive Secretary has determined that the manganese
concentrations in well MW-14 are most likely natural, and not caused by tailings cell leak-age. Itis therefore appropriate to set a GWCL at a concentration that is in excess of tne g00 prg/LGWQS.
However, as per PutLG.2 of the Permit, accelerated sampling for manganese in well MW-14could be required after two consecutive samples are discover"d i, "*c"is of the GWCL. If thiswere the case, the Executive Secretary would expect DUSA to provide definitive evidence toconfirm and verify how the current geochemical conditions areiquivalent to those found in2007by the University of Utah.
2)
3)
4)
5)
6)
u ol Utah Groundwater c Results
Water Source Tritium [TUt"1 6 Deuterium
(%de)6 Oxygen-l8
(%o\6
Surface
Water
North Wildlife
Ponds
wP2("5.98 -45 1.3
South Wildlife
Ponds
wP3 5.94 -60 -5.3
Tailines Cell3 TC3 6.Ot (7.24)\ol -12 4.9
Ground
Water
Upgradient of
Tailinss Cells
MW-l8 (shallow)<0.3 -103 -13.7
MW-18 (deep)0.0s -107 -13.9
Downgradient
of Tailings Cells
MW-14 (shallow)0.36 110 -13.8
MW-14 (deep)<0.3 tt2 -13.9
Page25 of 42
o
NGESMINOR PERMIT CHA
Groundwater Monitorins: Monitorins well Mw-3A. Part I.C. Table 2
@AMonitorWellMW-3Verification,RetrofitorRe-constructionReport
that DUSA submitted on August 8, 2005, the DRC concluded in an April25. 2007 DRC
Findings and Request for Information Letter (RFI), that concentration comparison between wells
MW-31nd MW-3A appeared inconsistent and made it difficult to come to any conclusions
concerning the data that would help determine which well has the best screen placement for
groundwaLr monitoring purposes. Therefore, quarterly sampling must continue in both wells
until sufficient data is available and the DRC can make a conclusion regarding the effects of
partial well penetration and screen length.
DUSA failed to sample well MW-3A for all constituents during the 1't and 3'd quarters of 2008.
Therefore, well MW-3A has been added as a POC well and will be sampled on a semi-annual
sampling frequency (2-times/year)'
@TMonitoringPlanthatoutlinedmonthlyslimesdrainrecoveryhead
testingiirat would be conducted for at least 90-hours and achieve a stable water level condition.
This monitoring program formed the basis for the annual average head calculations (Equation 1)
that were added to the Permit in March, 2008. The first DUSA report related to this matter was
submitted by email on March 2,2OOg (4th Quarter 2008 DMT Performance Standard Monitoring
Report).
DRC review of this and other previous DUSA quarterly DMT reports have found significant
problems in the monthly slimes drain recovery tests, including many tests failed to run for at
ieast 90-hours, and achieve steady or stable water level conditions at the end of the tests. From
this review, the DRC concluded that none of the monthly recovery data collected in 2007, and
only two monthly tests collected in 2008 met the 9O-hour duration and the stable water level
critlria. As a result, it is clear that any averaging of annual recovery head would be significantly
biased bv the larse amount of unreliable data from both these years. Calculation errors were also
found in the 4th {uarter, 2008 DUSA DMT Monitoring Report suggesting that inattention was
apparent in its preparation. Details on these agency findings are found in a March 30, 2009 DRC
Memorandum.
As a result of these findings, the Executive Secretary has decided to clarify the Permit and add
new requirements in order to improve the monthly recovery test data collection process and
reporting. These changes include:
. Specific wording to mandate that each monthly test be run for at least 90-hours, and
achieve a stable water level condition [Part I.D.3(b)],
Minor reference changes in the monitoring requirements in Part I.E.7(b) to mandate that
at least 12 monthly tests be conducted each year that meet the test performance standards
in Part I.D.3, and
Additional reporting requirements, including a quality assurance evaluation and data
validation for both the data collected, and the related calculations (Part I.F.l 1).
- in May 20O7,the
Page26 of 42
The SBMP Plan (dated May 15, 2008) required under th" "o-pliun.e r.hedole ut part I.H.l6
was approved by the Executive Secretary on July l, 2008. Therefore, DUSA has satisfied therequirements of compliance schedule item 16 and the Executive Secretary has struck this
compliance schedule item from the Permit. Reference to compliance schldule item I.H.l6 in thePermit atPart I.D.3(g) has been modified to reference the currently approved plan.
Cell4A
I.D.5. Table 5
This table has
spillway from
19,2009_
for tailings disposal. The BAT Monitoring Operations and Mainienance plan (dated September
16' 2008) was approved by the Executive Secretary on Septemb er 17,2008. To ensure that theapproved plan was enforceable under the Permit, Parts I.D.6, I.E.8, and I.F.3 were modified toreference the currently approved plan. Therefore, DUSA has satisfied the requirements ofcompliance schedule item 19 and the Executive Secretary has struck this compliance scheduleitem from the Permit.
mum-w Moni
Head. Part I.E.8(aX2)
Part I.H.19 of the Permit, required DUSA to submit a Cell4A BAT Operations and MaintenancePlan (hereafter O&M Plan) for Cell4,{ for Executive Secretary review and approval. OnSeptember 16,2008, DUSA submitted a Revised O&M Plan (Revision 1.3). tn tn" O&M plan,
DUSA asked that the datum for the LDS maximum allowable daily head measurement be movedfrom the lowest point of the LDS sump to the lowest point on the Cell 44 floor, i.e., to a point
where the LDS sump meets the Cell4,A floor, as measured on the lower FML. DUSA consultantGeosyntec argued that this approach is allowed under the RCRA rules and guidance. Afterconsultation with URS, the DRC agreed with this change and approved theb&M plan on
September 17 ,2008. DRC staff looked at the LDS sump pump, transducer, and relatedgeometries and determined that transducer reading of 2.28 feei would be deemed a failure ofBAT. For more information, on how the 2.28 feetvalue was calculated, see DRC memorandumof January 6,2009. This new compliance requirement was also added at part LE.8(aX2).
Part I.H.19 of the Permit, required DUSA to submit a Cell 44 BAT Operations and Maintenance
Plan (hereafter O&M Plan) for Executive Secretary review and approval, before use of Cell 44
BeforeCell4Acouldbeplacedintoservice,amonthlyadcriteria
needed to be established. As a part of Cell 4A design approval, DUSA demonstrated that theCell44 tailings could be de-watered in a period of 6.4 yiur.,leaving a final head of 1.0 foot
above the upper Flexible Membrane Liner. To ensure that the cell performs as per thesepredictions, these criteria have been added to part I.D.6(c) of the permit.
been updated to include a revised engineering drawing for the modified overflow
Tailings cell 3 to Tailings cell4,{, which was app.oved by the DRC on August
I.H
Page27 of42
Feedstock Storage Area Manasement Plan. Part I.H.21
@andNRCstaffperformedaninspectionattheMillsite.Duringthe
inspection DRC staff found several hundred 55-gallon drums containing alternate feedstock
11#.iut; many of which were bent, dented, and rusting at the perimeter of the drum pile' While
none were found to be leaking, the DRC staff observed that the drums were triple stacked at least
ten deep, with less than a 3-inch spacing between rows of drums, which made it impossible to
physically enter and visually inspect the condition of each of the drums.
Therefore, in the previous DUSA Permit modification (dated March 17,2008) the Executive
Secretary added u n"* DMT requirement for feedstock materials stored outside the ore feedstock
storage area in Part I.D.1 1 of the Permit. This new DMT requirement required DUSA to submit
u -uiug"-ent plan for Executive Secretary approval to manage feedstock materials stored
outside the ore feedstock storage area.
On June ZO,2OO8,DUSA submitted a White Mesa Mill-Containerized Alternate Feedstock
Material Storage Procedure. After reviewing the submittal, the DRC found that the procedure
again failed to address all of the DRC concerns listed in the April 29, 2OO8 DRC Request for
,{OAitionat Information Letter. In order to expedite resolution of these concerns, the DRC has
modified Part I.D.11 with new performance requirements for storing feedstock material outside
of the ore storage area, with an eye to the following goals: 1) containers are maintained in a
water tight .ondition to prevent soil and groundwater pollution, and 2) aisleways are provided
between containers to allow physical entry and visual inspection, early detection, and timely
remediation of leakage. In the event that DUSA cannot meet goals I and2, options are provided
in part I.D.1l for OUSA to seek out DRC approval and perform said storage over an engineered
surface of concrete or asphalt with certain other performance criteria. Related BAT monitoring
requirements were also added at Part'I.8.7(d) and (e).
As a result of the Executive Secretary's actions described above, the original purpose of Pan
l.H.zl has been satisfied. Therefore, the Executive Secretary has struck this compliance
schedule item from the Permit. Reference to compliance schedule item I.H.2l in the Permit at
Part I.D.1 t has also been removed.
GnouNo Wlrrn Coupr,uNCE AND TTCTN.IOTOGY PERFORMANCE MONTTONTNC, PATt I.E
part I.E was modified to include the sampling of tailing cell waste waters, seeps and springs in
addition to the sampling of groundwater monitoring wells.
- Field rt I.E.l
@arcrmonitoringprogram,thePermitteeisrequiredtocollectfield
parameters. To be consistent with the currently approved DUSA Quality Assurance Plan
(hereafter QAP), redox potential (Eh) has been added as a required field parameter. This will
provide useful information to document the potential for reductive de-chlorination of the
chloroform groundwater contamination plume.
Groundwater Monitorine: Monitorine Wells MW-20 aI4 MW-22. Part I.E.2
@dMw-22wereinstalledin1994andarelocatedatadiStanceof
more than 3,000 feet south of the tailings cells. Because DUSA had not provided any monitoring
data for these wells, the DRC added a new requirement at Part 1.8.2 of the Permit during the last
Page 28 of 42
Permit modification (March 17,2008). This new requirement required DUSA to begin quarterly
monitoring in both wells. After eight consecutive quarters of sampling, DUSA will submit areport determining background groundwater quality and a calculation of groundwater velocitiesin the vicinity of wells MW-20 and MW-22.
During this Permit modification additional requirements have been added at part I.E.2. Thereport that DUSA is required to submit after eight quarters of sampling will be a Background
Report that will include: data preparation and statistical analysis oi groundwater data following
the same Decision Tree/Flowchart used for the previous background reports; aquifer test results
to determine local hydraulic conductivity and other aquifer properties; ind a caiculation of
average liner groundwater velocity based on well specific hydraulic conductivity, hydraulic
gradient, and effective aquifer porosity.
The Background Report is required to be submitted by March l, ZOIO. After review of
Background Report the Executive secretary will evaluate if wells Mw-20 andMW-2}should be
added as POC wells, and adjust the sampling frequency in accordance with criteria found in part
I.E.l(b) or (c). If it is determined that wells MW-20 andMW-22 should be added as pOC wells,
the Executive Secretary will re-open this Permit and establish Groundwater Compliance Limitsin Table 2 for wells MW-20 andMW-22.
.8
Part I.H.8 of the Permit, required DUSA to submit a plan of groundwater sampling and analysisof all seeps and springs found downgradient or lateral gradient from the tailings "Jl, fo1.
Executive Secretary review and approval. The original compliance date to submit the WpR was
180 days of the issuance of the original Permit, or September 8,2005. The WpR (dated
November 20,2008) was conditionally approved by the Executive Secretary on March 3,ZOO9.
Therefore, DUSA has satisfied the requirements of Part I.H.S, and the Executive Secretary hasstruck this item from the Permit. To ensure that the approved plan was enforceable under thePermit, Parts I.E.6 and I.F.7 were modified to reference the currently approved plan and outlinecritical items and requirements. Reference to former compliance schedule item I.H.S at parts
I.E.6 and I.F.7 has also been removed.
WeekhlFeerblqg_k Storase Area Inspection. part I.E.7(d)
Part I.E.7(d) was modified to require weekly inspections of all feedstock storage, as to
demonstrate compliance with the performance standards found in part I.D.1 l.
7bCertainmonitoringrequirementshavebeenaddedtop@terialStored
Outside the Feedstock Storage Area. These changes include weekly inspections and prior
Executive Secretary approval should DUSA construct a storage area with a hardened surface.
Liner
In the DUSA 2006 Annual Technical Evaluation Report, tfre entry for March 24,2}O6refers totears found in the Tailing Cell I liner that were repaired and covered. After review of thisDUSA report, a Request for Information was made by the DRC dated May 4,2007. DUSAprovided a response dated July 13,2007, wherein the method of discovery and repair were
Page29 of 42
described. In their response, DUSA advised that these "tears" were several dime-sized defects
on a small section of the liner that were above the solution level in the cell.
However, since there was no DRC approved liner maintenance provision plan in use by DUSA, a
new compliance schedule was added at Part 1.H.12 in the previous DUSA Permit modification
(dated March 17, 2008). The purpose of the provision was for the equipment, material, training,
and procedures to be used for the timely detection of any openings in the polymer liners, and the
reliable repair and quality assurance testing of any such repairs to the polymer liners for Cells 1,
2,3, and the Roberts Pond.
On September 29,2008, DUSA submitted a Revised Liner Maintenance Provisions for Tailings
Cells 1, 2,3, andRoberts Pond. The DRC approved this plan on October 9, 2008. The new
requirements at Part I.8.7(0 were taken from said plan.
Oualitv Sampline Plan. Part I.H.5
part I.H.5 of the Pe.m-it requi.ed DUSA to submit a Tailings Cells Wastewater Quality Sampling
plan (WQSP) for Executivl Secretary review and approval within 150 days of the issuance of the
original pirmit, or August 8, 2005. The WQSP (dated November 2l , 2008) was approved by the
Executive Secretary on March 3,2009. Therefore, DUSA has satisfied the requirements of
compliance schedule item 8 and the Executive Secretary has struck this compliance schedule
item from the Permit.
To ensure that the approved plan was enforceable under the Permit, Part I.E.10 was modified to
reference the currently approved plan and outline certain key requirements, including:
Identification of seven specific sampling locations required to be sampled' However,
provisions were provided to allow DUSA to forgo sampling of the slimes drains until
iuch time as de-watering operations begin at Tailing Cells 3 and 4A.
Listing of specific field and laboratory parameters required to be measured, sampled, and
analyzed,
Provisions for collection and analysis of quality control samples,
Prior notification, to allow the Executive Secretary to observe and collect split samples,
ando prohibition on omission of any sampling location required, without prior written
permission from the Executive Secretary.
Part I.F.9 was also modified to clarify when and where a depth to wastewater measurement
should be taken during slimes drain sampling. Reference to the former compliance schedule
item I.H.8 in the Permit at Part I.8.10 has been removed.
round
e-t lf.t requires that the Permittee submit quarterly monitoring reports of field and laboratory
analyses of all well monitoring and samples described in Parts 1.8.1,1.8.2,I.E.3, I.E.5, and I.E.7
of this Permit; however the reference to Part I.E.7 is incorrect. Part I.E.7 refers to DMT
performance Standards Monitoring, not Groundwater Monitoring. Therefore, the reference to
Part I.E.7 has been removed from Part I'F.1.
o
o
Re
Page30 of 42
- TimePartI.F.1(g)wasaddedtothePermit,whichrequiresDUSAtosubffisplots
for four constituents (chloride, fluoride, sulfate, and uranium) with each quarterly groundwater
monitoring report. These constituents are the best indicators of potential seepage impacts from
the tailings impoundments. Increasing trends could provide early indicationbfieepage even
before GWCLs are exceeded.
Aquifer Permeabilitv Data. Part I.F.6(c)
Part I.F.6(c) was modified to ensure that aquifer permeability data submitted for the
Groundwater Monitoring Well As-Built Reports will include field data, data analysis, andinterpretation of slug tests, aquifer pump tests, or other hydraulic analyses to determine local
aquifer hydraulic conductivity in each well.
This section has been simplified because many of the ."uir"d GWCL5 i, Tuble 2 already reflect
the mean plus two standard deviation concentrations. Therefore, Part I.G.Z(a)(2) is no longer
needed to determine Out of Compliance Status and has been removed from the permit.
- new
rt I.Eva
WW-2 IPDWI. former Part I.H.11 - new Part I.H.3
Changes in these sections were limited to re-numbering and minor typographical corrections.
Reference to Part I.H.9 of the Permit elsewhere in the Permit part I.F.8) has been updated.
In July 2047, the University of Utah performed a groundwater study to characterize groundwater
flow, chemical composition, noble gas composition, and age at White Mesa. This study
established groundwater age and an isotopic benchmark for each monitoring well, wildiife pond,
and tailings cell sampled during the study. Due to limited funding, the study did not include
sampling and analysis of every POC well or surface water site at White Mesa. Therefore, the
Executive Secretary has determined that the Permittee shall perform an investigation in the
monitoring wells and surface water sites that were not part of the July 2007 University of UtahStudy. The purpose of this supplemental investigation and associated report shall be to establishisotopic benchmarks and a ground/surface water age atthese locatiom. ih" permittee must
conclusively demonstrate that the supplemental investigation conducted is similar to the one
performed by the University of Utah in July 2007.
le Item
During a DRC inspection on November 17,2008, it *u. Oit"ou"."a tf,ut OUSa t uO conitructed
a New Decontamination Pad (hereafter NDP), without prior Executive Secretary approval, as
required by Part I.D.4 of the Permit. In a December 2,2009 DRC e-mail, the DRi explained
that prior authorization for design, construction, or operation of the NDp is not required, so long
as wash water in the sediment basin of either facility does NOT exceed the State dWqS, u*outlined in Table 2 of the Groundwater Permit. DUSA did not consider this to be a practical
solution, and agreed that it would not use the NDP until the Executive Secretary had approved
the design and construction of the NDP. The NDP has not yet been placed into service;
Page 3l of 42
therefore, Part I.H.5 of the Permit was added requiring DUSA to provide information and secure
Executive Secretary approval before the NDP can be placed into service.
Item for I.H.6
Th" E-tstt"g D""ort""rination Pad (hereafter EDP), was constructed prior to the DRC becoming
the primary regulator for the White Mesa Mill in August, 2004. Shortly thereafter, when DUSA
was issued the first State Ground Water Quality Discharge Permit on March 8, 2005, the EDP
was inadvertently omitted. To rectify this situation, Part I.H.6 of the Permit was added requiring
DUSA to submit As-Built drawings, update the DMT Monitoring Plan for the EDP, and perform
an annual inspection of the facility'
RESOLVED COMPLIANCE SCHEDULE ITEMS
Part I.H.l
p".t ttt-1 of the Permit required DUSA to install eight new groundwater monitoring wells within
30 days of Permit issuance, and is a requirement that dates back to the original March 8, 2005
Permit. DUSA compliance is summarized below:
o During May 2005, DUSA installed the new wells required, including: MW-23, MW-24,
MW-25, 1y1W-27,MW-28, MW-29, MW-30, and MW-31. Later, on August 23,2005,
DUSA submitted a report (see Revised Hydrogeological Report discussed below), that
documented how the new wells had been installed in accordance with requirements of
Part I.H.l of the Permit.
As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.1 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the Permit.
the installation of the new compliance monitoring wells, or before July 1, 2005. DUSA
compliance is summarized below:
On August 23,}OO1,DUSA submitted a Perched Monitoring Well Installation and
Testing at the White Mesa Uranium Mill April through June 2005 Report (hereafter
Revised Hydrogeologic RePort).
After review of the Revised Hydrogeologic Report, the DRC concluded in a November
lg,2OO7 Closeout and Notice of Enforcement Discretion Letter that the report did not
include a permeability contour or saturated thickness maps, as specified in the December
l,2OO4 Statement of Basis. Additionally, the report was not certified by a Utah Licensed
professional Geologist, as required by Utah Administrative Code R317-6-6.7; however,
the Executive Secretary decided to use enforcement discretion and accept the August 23,
2005 report on the basis that the report will be revised and resubmitted again as a part of
the Permit renewal application due on September 9,2009 and will include the missing
items described above.
As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.2 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the Permit.
part IJ{2 of the Permit required DUSA to submit a Revised Hydrogeologic Report 60 days after
Page32 of 42
Part I.H.3 of the Permit required DUSA
of the existing POC wells listed in parr
to submit a Background Ground Water euality Report
I.E.1, within 90 days after the issuance of the permii, or
June 8,2005. DUSA compliance with
o on lune 23,2005, DUSA asked the DRC to extend the deadline for filing theBackground Ground Water Quality Report for Exisring Wells to August-31,2005. TheDRC did not respond to the DUSA request.
' DUSA was unable to meet the August 31, 2005 date. In an October 27 , 2006 Final
Consent Agreement DUSA agreed to stipulated penalties in the event they did not submit
the Background Ground Water Quality Report for Existing Wells for Executive Secretaryreview and approval, on or before January 2,2007.
' DUSA submitted the Background Ground Water Quality Report: Existing Wells on
December 29,2006.
On April 19,2007 DUSA submitted an addendum to the December 2g,Z}O6submittal.
Review of both of these reports was conducted by URS Corporation on behalf of theDRC. URS completed the review and presented their findings in an Augu st9,2007
Completeness Review for the Background Groundwater Quality ReportlExisiing WellsMemo.
After the report and addendum were reviewed, the DRC sent DUSA an August lO, ZOOTCompleteness Review, Findings, and Confirmatory Action Letter. This lett"er requiredthat DUSA: l) Submit a Decision Tree/Flowchart that describes groundwater datapreparation and the statistical analysis process on or before August 16, ZOO7 , and Z)Submit a Revised Background Ground Water Quality Report For Existing Wells thatconforms with the EPA Guidance, within 60 days after Eiecutive Secretaly approval ofthe Decision TreelFlowchart.
On August 16,2007 DUSA submitted a Decision Tree/Flowchart diagram which wassubmitted in compliance with the August lO,2OO7 DRC Confirmator! Action Letrer.
The DRC responded in an August24,2007 Conditional Approval Letter that approvedthe Decision Tree/Flowchart based on several conditions. As a result the revised
background report was then due by October 23,ZOO7.
On October 26,2007 DUSA submitted a Revised Background Ground Water eualityReport for Existing Wells.
on November 16,2007 DUSA submitted a revised addendum to said report.
Review of both of the October 26 and November 16,2OO7 DUSA reports was conducted
9V YIS Corporation on behalf of the DRC. URS completed rhe review and presentedtheir final findings to the DRC in a June 16, 2008 memorandum where ,"u"rul questions
were identified with respect to the DUSA proposed GWCLs. The majority of thesequestions were determined to have been caused by DUSA's application oithe DecisionTree / Flowchart.
Based on the June 16, 2008 URS work, the DRC accepted 439 of the 494 GWCLs valuesproposed by DUSA in the October 26,2007 Revised Background Ground Water euality Reportfor Existing Wells. These revised GWCLs were made in Table 2 of the permit. For theremaining 55 GWCLs, the DRC has determined to use the revised values calculated by URS.For additional details, see the June 16, 2008 URS memorandum, in Attachment l, below.As described above, DUSA has satisfied the requirements of Permit compliance schedule itemI.H.3 of the Permit, and appropriate GWCLs have been established in raLle 2 of the permit.
a
o
a
o
Page33 of 42
Therefore, the Executive
Reference to compliance
this compliance schedule item from the Permit'
in the Permit at Part I.B has also been removed.
t
Secreta
schedu
ry has struck
le item I.H.3
Monitorine Wells. Part I.H.4
part I.H.4 of the Permit required DUSA to submit a Background Ground Water Quality Report
for the new wells required to be installed under Part I.H.1. Installations of the new wells were
completed between April and June, 2005. within 60 days after completion of eight consecutive
qrurt"., of groundwaGr sampling and analysis of the new wells, the original Part I'H.l required
OUSA to submit a report for Executive Secretary approval to establish background groundwater
quality for these new wells. Said report deadline would therefore have been June 1, 2007.
DUSA compliance is summarized below:
o DUSA submitted the Background Ground Water Quality Report for New Wells on June
4,2007.
After reviewing the report, the DRC responded in a February 14, 2008 Completeness
Review, pRC FinOingi, Request for Information, and Confirmatory Action Letter. The
letter required DUSA to: 1) submit a Revised Background Ground Water Quality Report
for New Wells that conforms with the EPA Guidance provided to DUSA on August 9,
2OO7 and2) resubmit the revised report by April 30, 2008.
DUSA submitted the Revised Background Ground Water Quality Report for New Wells
on April 30, 2008. DRC review of the April 30, 2008 report is documented in the June
24,;OOBDRC Findings and Recommended Action Memorandum, see Attachment 3,
below.
The DRC acceprs 196 of the 342 GWCLs values proposed by DUSA in the April 30, 2008
Revised Backgiound Ground Water Quality Report for Existing Wells. For the remaining 146
GWCLs propJsed, the DRC will adopt the other values calculated by DRC staff. For details, see
Attachment 3, below.
As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.4 of the permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the permit. Reference to compliance schedule item I.H.4 in the Permit at Part I.B has also
been removed.
I.H.6
Fu-n-l.U.O(u) of the Permit required DUSA to develop seven wells at the facility so that they
produce clear groundwater and comply with the requirements of Part I.8.4(c), including wells:
Mw-5, Mw-l1, Mw-18, Mw-19, Mw-20, Mw-22, and TW4-16. Part I.H.6(b) required DUSA
to complete monitoring well MW-3A with a permanent surface well completion according to
EpA R-CRA TEGD. Said work was to be documented in a report required to be submitted to the
DRC by June 5, 2005. DUSA compliance with these requirements is outlined below:
o DUSA submitted a report dated August 1, 2005. Later DRC determined the August 1,
2005 DUSA submittal to be inadequate, and issued an April 26,2007 Notice of Non-
Compliance.. DUSA submitted, a May l, 2008 Monitor Well Remedial Action Report that documented
proper development of wells: MW-I1, MW-l8, MW-19, MW-20, MW-22, and TW4-16;
and completion of the protective steel casing at well MW-3A'
Page34 of 42
As described above, DUSA has satisfied the requirements of Permit compliance schedule itemI.H.6 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule itemfrom the Permit.
On June 17,2008, the DRC sent DUSA a Confirmatory Action Letter documenting theDUSA commitment to provide written plan and deadlines by June ZO,2OOB for othler
outstanding information, including turbidity issues for wells Mw-5, Mw-20, and MW_
22.
On June 20,2008, DUSA submitted additional data that showed turbidity values below
the 5 NTU standard for wells MW-5, MW-20, and,MW-2}. After reviewing the June 20,2008 letter, it was apparent that DUSA had fulfilled the requirement of part LH.6(a),
therefore on August 5, 2008 the DRC sent DUSA a closeout Letter.
Reconstruction Report. Parts I.H.7(l) and I.H.7(2)
Part I'H.7(l) of the Permit required DUSA to complete monitoring well MW-3A, as follows: 1)with a permanent surface well completion according to EPA RCRA TEGD, and part {.H.6(b) ofthis Permit, and2) provide an elevation survey certified by a state of Utah licensed engineer orland surveyor by August 4, 2005. DUSA compliance with these requirements is outlined below:o DUSA submitted a report dated August 8, 2005.
On April 25,2007, the DRC issued a Request for Information which summarized aDUSA commitment to provide the requirid information by septemb er ll, z0o7.
On May 1, 2008, DUSA submitted, by e-mail, a Monitor Well Remedial Action Report
that documented that monitoring well MW-3A had been retrofitted with a protective steel
casing during the 2nd Quarter of 2007. However, no elevation survey data was included
as required.
On June 17,2008, the DRC sent DUSA a Confirmatory Action Letter documenting aDUSA commitment to provide a written plan and deadline by June 20, ZOO8 for seieralactivities, including submittal of the missing elevation survey for well Mw-3A.
on June 20,2008, DUSA submitted written commitment to supply the well Mw-3A
certified elevation survey data by July 7, 2008.
on July 10,2008, DUSA submitted, by e-mail, the well Mw-3A elevation survey dataperformed by Fisher & Sons Surveying, a Utah Licensed Professional Land Survlyor.After reviewing the elevation survey data, it was apparent that DUSA had fulfilled the
requirement of Part 1.H.7(2), therefore on August 5, 200g the DRC sent DUSA aCloseout Letter.
As described above, DUSA has satisfied the requirements of Permit compliance schedule itemI.H.7 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule itemfrom the Permit.
Part I.H.12 of the Permit required DUSA to submit I-iner tvtaintenance provisionilo beincorporated into the existing DMT Monitoring Plan for Executive Secretary review andapproval within 90 days of Permit issuance, i.e., by June 15, 2008. DUSA compliance with thisrequirement is summarized below:
o On June 12, 2008, DUSA submitted by email Liner Maintenance provisions for Tailingscells l, 2,3, and Roberts Pond as Appendix D of the white Mesa Mill railings
Page 35 of 42
o
tem and
o
ogy (hereManagement Sys
Monitoring Plan.
Discharge Minimization Technol after DMT)
After review of the June 12, 2008 submittal, the DRC sent DUSA a Request for
Information, Plan Revision, and Confirmatory Action ktter dated August 1, 2008, which
summarized the DUSA commitment to provide a revised plan on or before September l,
2008.
On September 29,2008, DUSA submitted, by e-mail, a Revised Liner Maintenance
Provislons for Tailings Cells l, 2,3, and Roberts Pond - Appendix D of the White Mesa
Mill DMT Plan.
After review of the revised plan, the DRC sent DUSA a Conditional Approval Letter on
the condition that DUSA submit a final version of the Liner Maintenance Provisions for
DRC records by November l, 2008.
DUSA submitted a final copy of the Liner Maintenance Provisions by a letter dated
October 22,2008. The DRC accepted the submittal and issued a Closeout Letter dated
October 30, 2008.
The performance monitoring standards for liner inspections and repair were added to Part
I.E.i(g of the Permit. As described above, DUSA has satisfied the requirements of Permit
compliance schedule item I.H.12 of the Permit. Therefore, the Executive Secretary has struck
this compliance schedule item from the Permit.
completion of compliance Item 15. Continsency Plan.,Part I.H.15
prrt Il{15 "f the Permit required DUSA to submit a Contingency Plan for Executive Secretary
approval that provides a detailed list of actions DUSA will take to regain compliance with Permit
timits and DMT or BAT requirements, as defined in Parts I.C and I.D of the Permit within 180
days of issuance or by September 8, 2005. DUSA compliance is summarrzed below:
. DUSA submitted a Draft Contingency Plan, dated April 14,2006 for Executive Secretary
review.o After review of the plan, the DRC sent DUSA a Request for Additional Information
Letter on September 5,2007.o On October 12,2007, DUSA sent the DRC a Revised Draft Contingency Plan.
o After review of the revised plan, the DRC sent DUSA a May 2,2008 Conditional
Approval Letter that required DUSA to provide an update Plan prior to placing Cell4,{
into operation.. DUSA submitted a revised Contingency Plan dated August 8, 2008, which is currently
under DRC review.
As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.15 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule
item from the Permit. Reference to compliance schedule item I.H.15 in the Permit at Part
I.G.4(d) has also been removed.
Well II.18
Part I.H.18 of the Permit required DUSA
monitoring well MW-5 on or before May
to submit an As-Built report for the repairs of
l, 2008. DUSA compliance is summarized below:
o DUSA submitted an April 29,2008 Repair of Monitor Well MW-5 report. DRC review
found there was no evidence that the elevation survey was performed by a Utah licensed
Page36 of 42
Professional Engineer or Land Surveyor. Additionally, the elevation given in the reportwas unclear whether it was the ground surface or the groundwate. ,nonitorirg point.
On June 17,2008, the DRC sent DUSA a Confirmatory Action Letter documentingDUSA's commitment to provide by June 20,2OO8 u *.itt"n deadline for completing theelevation survey.
In a June 20,2008letter, DUSA committed that the well MW-5 elevation survey datawould be completed and transmitted to the DRC by July 7, z0og.
on July 10, 2008, DUSA submitted, by e-mail, the MW-5 survey data performed byFisher & Sons Surveying (Utah Licensed Professional Land Surveyor). After reviewingthe survey data and the June 20,20OB letter, it was apparent that DUSA had fulfilled therequirement of Part I.H. 18, therefore on August S, ZOOS the DRC sent DUSA a CloseoutLetter.
As described above, DUSA has satisfied the requirements of Permit compliance schedule itemI.H.l8 of the Permit. Therefore, the Executive Secretary has struck this compliance scheduleitem from the Permit.
DUSAwasrequiredtosubmitarevisedversionoAssurance
Plan (QAP) on or before April 30, 2008 for Executive Secretary review anO approral, that wouldmandate DUSA to resolve all non-conformance with QAP requirements on oibefore submittalof the next quarterly groundwater monitoring report. DUSA ctmpliance is summarized below:
ion of Comnliance
o on March 14,2008 DUSA submitted, by e-mail, Revision 1 of the eAp.o After review of the document, DRC staff determined that additional modifications to the
QAP were needed. A conference call was held with DRC and DUSA representatives onMay 5, 2008 where potential QAP modifications were discussed and agreed on. Thisresulted in a May 8, 2008 DRC Request for Additional Information and ConfirmatoryAction Letter that documented the DUSA commitment to make certain changes and re-submit the revised QAp on or before June 6, 200g.o on June 5, 2008 DUSA submitted, by e-mail, Revision 2 of the eAp.o During the review of Revision 2 of the eAp, the DRC identified additional changes thatneeded to be made. These additional changes were outlined in an e_mailon June 13,2008.o one June 18, 2008 DUSA submitted, by e-mail, Revision 3 of the eAp.o After reviewing Revision 3 of the eAp, the DRC sent DUSA a eAp Revision 3Approval Letter on June 20.2008.
As described above, DUSA has satisfied the requirements of Permit compliance schedule itemLH.22 of the Permit- Therefore, the Executive Secretary has struck this compliance scheduleitem from the Permit.
The Compliance items from Parts I.H. 13, I.H.14, I.H. 17, and I.H.20 0f the permit have beenremoved. All of these items in Part I.H of the Permit are listed as <Reserved>. These"<Reseryed>" items are former placeholders of compliance items whose requirements have beensatisfied and were removed during the March 17,2oog permit modification.
sent to DUSA
Page37 of42
Correction of Formattins and Other Changes
erofformattinginconsistencieswereidentified;
therefore, the following items were colrected and/or changed:
o Various Font types and sizes were used as the Normal text in paragraphs in the Permit;
therefore, to be ionsistent throughout the Permit, paragraphs were changed to one Font
type and size (Times 12Pt)'
o To be consistent, all paragraph alignment throughout the Permit has been changed to
Justified.o Incorrect numbering was found at Parts I.E.7(b) and I.E.7(d), the numbering at these
locations *"r" "o.rJ.rcd.
Additionally, numbering at several locations in the Permit were
out of alignment with the correct indentation; therefore, they were moved into the correct
position.o Different hyphens (- or -) were used throughout the Permit. To be consistent, the (-)
hyphen *ur .hor", as one to be used, the other hyphen was changed, accordingly.
o Inadvertent Extra spaces, periods, commas, etc... have been removed, accordingly.
o Missing spaces, periods, corunas, etc... have been added, accordingly'
o At several locations in the Permit, the first letter of a word was either incorrectly
capitalized or was not capitalized as needed; therefore, these instances have been
corrected aPProPriatelY.
. In the previous DUSA Permit modification (dated March 17,2008), as result of a merger
IUC changed its name to Denison Mines (USA) Corp. (DUSA). This name change was
made throughout the Permit. However, a few IUC references were identified in this
Permit modification and have been changed to DUSA, accordingly.
o References to deadlines - throughout the Permit the Permittee is required to
reporVsubmit/complete something by XX days, wherever this is mentioned, the qualifier
..clalendar" has been inserted. This protocol has been used throughout the document.
o Reference to an approved plan - throughout the Permit, where an approved plan is
mentioned, ttre quainer "currently approved" has been inserted. This protocol was
already in use at some locations in the Permit, now it is throughout.
Page38 of 42
References
Denison Mines (DUSA) Cotp., September 2008, "white Mesa Mill Tailings Managemenr
System and Discharge Minimization Technology (DMT) Monitoriig plan,'; 17 pp,5appendices.
Denison Mines (DUSA) Co.p., June 5,2009, ..Re:
Discharge permit No. UGW3700O4 _ New
Frydenlund to Loren Morton, 2 pp.
White Mesa Uranium Mill; Groundwater
Decontamination Pad," letter from David
Denison Mines (DUSA) Co.p., June 5, 2009, "Re: White Mesa Uranium l\4ill; GroundwaterDischarge Permit No. UGW370004 - Seeps and Springs Monitoring," letter from DavidFrydenlund to Loren Morton, 2 pp.
EPA (U.S' Environmental Protection Agency), 1989, "statistical analysis of ground-watermonitoring data atRCRA facilities: Interim final guidance," 530-SW--gg-O26,Office ofSolid Waste, Permits and State Programs Division, U.S. Environmental protection
Agency,401 M Street, S.W. Washington, D.C.20460.
EPA (U.S. EnvironmentalProtection Agency), 1992, "statistical analysis of ground-water
monitoring data at RCRA facilities: Addendum to Interim final guidaice,,,Office ofSolid Waste, Permits and State Programs Division, U.S. Envirorimental protection
Agency, 401M Street, S.W. Washington, D.C. 20460
Hurst, T.G. and D.K. Solomon, May, 200g, "summary of work completed, Data Results,Interpretations and Recommendations for the July,20o7 sampting Event at the DenisonMines, USA, White Mesa Uranium Mill Near Blanding Utah," unlpublished report by theUniversity of Utah Department of Geology and Geopt-yri.s, OZ pi. [transmitted via5/18/08 email from Kip Solomon to Loren Morron tbnC)].
INTERA, Inc., Prepared for Denison Mines (usA) corp., Aprillg, 2oo7,,,Addendum:Evaluation of Pre-Operational and Regional Background Data, Background Groundwater
Quality Report: Existing Wells for Denison tvtines gse) Corp.'s w[ite Mesa Mill Site,San Juan County, Utah."
INTERA, Inc., Prepared for Denison Mines (USA) Corp., October 2007, "Revised BackgroundGroundwater Quality Report: Existing Wells. For Denison Mines (USA) Corp.,s WhiteMesa Mill Site, San Juan County, Utah.,,
INTERA, Inc., Prepared for Denison Mines (usA) corp., November 16, zoo7,.,RevisedAddendum: Evaluation of Pre-Operational and Regional Background Data, BackgroundGroundwater Quality Report: Existing wells for Dinison Mines (usA) corp.,s whiteMesa Mill Site, San Juan County, Utah.,,
INTERA, Inc., Prepared for Denison Mines_(USA) Corp., April 30, 2008. ,.Revised BackgroundGroundwater Quality Report: New Wells. For Denison Mines (USA) Corp.,s White MesaMill Site, San Juan County, Utah.,,
INTERA, Inc., Prepared for Denison Mines (usA) co.p., July 2,200g. .,Re: state of UtahGround Water Discharge Permit No. UGW370041the "GwDp,,) White Mesa Mill -Response to URS Memorandum: Completeness Review for the Revised BackgroundGroundwater Quality Report: Existing Wells for Denison Mines (USA) Corporation,sWhite Mesa Mill Site, San Juan County, Utah.,,
Page 39 of 42
INTERA, Inc., Prepared for Denison Mines (DUSA) Corp., July 5, 2009' "Denison Mines
(DUSA) Co.p. -- Determination of Ground Water Compliance Limits (GWCLS),"
unpublished consultants memorandum from Daniel W. Erskine Ph.D' (INTERA) to
Loren Morton (UDEQ DRC) and Phillip Goble (UDEQ DRC), 2O pp.,1 figure.
uRS Corporation, April 30, 2008, "completeness Review for the Revised Background
Groundwateieuality Report: Existing Wells for Denison Mines (USA) Corporation's
White Vtesa tvtitt Siie, San Juan County, frtah," unpublished consultants memorandum, 4
pp., I figure, 3 tables [transmitted via 5/6/08 email from Bob Sobocinski (URS) to Loren
Morton (DRC)1.
URS Corporation, June 16, 2008, "Completeness Review for the Revised Background
Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corporation's
White Mesa Mill Siie, San Juan County, lJtah," unpublished consultants memorandum,4
pp., I figure, 3 tables [transmitted via6116l}S email from Bob Sobocinski (URS) to
Loren Morton (DRC)1.
Utah Division of Radiation Control, November23,2004, "Review of Hydro Geo Chem,Inc'
Report - Report on Perched ZoneWater Movement, White Mesa Mill Site, near
Blanding, u1ah, october 20,2004," unpublished regulatory document from Dean
Henderson to Loren Morton 3 pp.,Z tables, and 4 figures'
Utah Division of Radiation Control, December l,2OO4, "Statement of Basis for a Uranium
Milling Facility at White Mesa, South of Blanding, LJtah," unpublished regulatory
document, 57 pp., and 12 attachments'
Utah Division of Radiation Control, August lO,2OO7 , "December, 2006 Background
Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.'s White
Mesa Mill Site, San luan County, Utah; and October 27,2006 Utah Water Quality Board
Final Consent Agreement (Docket No. UGW06-03): Completeness Review, DRC
Findings, and Confirmatory Action Letter," from Dane Finerfrock to David
Frydenlund 3 PP., 1 attachment.
Utah Division of Radiation Control, August 24,2007 , "August 16,2007 DUSA Decision Ttee I
Flow Chart for Statistical Analyiis for Background Groundwater Quality: Conditional
Approval," letter from Dane Finerfrock to David Frydenlund 3 pp,2 attachments.
Utah Division of Radiation Control, November 16,2OO7, "Revised Hydrogeologic Report -
Groundwater Discharge Permit (Permit), Part I.H.2, Denison Mines (USA) White Mesa
Mill, near Blanding, Utuh," unpublished regulatory document from Dean Henderson to
Loren Morton 5 PP., 1 figure, 3 tables'
Utah Division of Radiation Control, February 14, 2008, "May 31,2007 Background
Groundwater euality Report For New Wells at the Denison Mines (USA) Corp.'s White
Mesa Mill Site, San Juan County, Utah. State of Utah Ground Water Discharge Permit
No. UW370004): Completeness Review, DRC Findings, and Confirmatory Action
Letter," from Dane Finerfrock to David Frydenlund 4 pp'
Utah Division of Radiation Control, February 22,2008, "As-Built Report for New Tailings
Monitoring Wells - Groundwater Discharge Permit (Permit), Part I.H.1, Denison Mines
(USA) Wtrite Mesa Mill, near Blanding,Ijtah," unpublished regulatory document from
Dean Henderson to Loren Morton, 1 pp'
Utah Division of Radiation Control, March 14,2008, Public Participation Summary, Ground
Water Discharge Permit, DUSA, Permit No' UGW370004'
Page 40 of 42
utah Division of Radiation control, April 29,zoo8,"April l4,2oog DUSA Drummed FeedstockManagement Procedure: Groundwater Discharge Permit UGW37004 p art l.H.2l :
Request for Additional Information," letter from Dane Finerfrock to David Frydenlund2 pp.
utah Division of Radiation Control, May 2,2oo8, "october 12. 2007 Draft contingency plan forDenison Mines Corporation (DMC), as Required Under Part I.H.16 of the State of UtahGWDP #UGW37004: Conditional Approval," letter from Dane Finerfrock to DavidFrydenlund I pp.
Utah Division of Radiation Control, May l9,2008, "Denison Mines Corporation (USA) andProposed Background Groundwater Quality for Existing Wells (October, 2007lntera
Report); April28, 2008 URS Finding and DRC Recommended Action," unpublishedregulatory document from Loren Morton to Dane Finerfrock, 9 pp.
Utah Division of Radiation Control, June 19,200g,
Background Groundwater Quality Report -
David Frydenlund I pp.
Utah Division of Radiation Control, June 20,2008, "June 18, 2008 White Mesa Uranium MillGround water Monitoring Quality Assurance Plan (QAP) Proposed Revision 3.0, GroundWater Discharge Permit No. UGW370004 (Permit): Approval," letter from DaneFinerfrock to Steven Landau2 pp.
utah Division of Radiation control, July l, 200g, "June 13,2oog DUSA Letter; June 200gWhite Mesa Mill Revised Storm Water Best Management practices plan (SWBMpp);
March 17 ,2008 Utah Groundwater Discharge Permit No. UGW37004; Febru ary 2007DUSA Storm Water Best Management Practices Plan: Approval of Revised plan,,' letterfrom Dane Finerfrock to Steven Landau I pp.
Utah Division of Radiation Control, July 2,2008,"RE: DUSA Cell44 Construction: Two Itemsnoted," e-mail from Greg corcoran (Geosyntec) to David Rupp (DRC) I pp.
Utah Division of Radiation Control, August 5, 2008, "Part I.H.6, Monitoring Well RemedialAction and Report; part I.H.7 Monitor well MW-3 verification, ReIofit, orReconstruction Report; and Part LH.18 Repair of Monitor Well MW-5 for the White
Mesa Mill, Ground Water Discharge Permit No. UGW37O0O4 (permit): CloseoutLetterr" from Dane Finerfrock to Steven Landau 1 pp.
Utah Division of Radiation Control, August 19,2008, "White Mesa Uranium Mill Cell44overflow Spillway from cell 3 to 4A: Design Modilication Approval,,, from DaneFinerfrock to Harold Roberts 2 pp., I attachment.
utah Division of Radiation control, September 17 ,20o8, "september 16,2oog DUSA E-mailConveying Proposed Revisions to the Cell4,A' BAT Monitoring, Operations, andMaintenance Plan (O&M Plan); September 16,2008 DRC E-mail with Comments on theO&M Plan; September 12,2008 DUSA E-mail Conveying Proposed Revisions to theWhite Mesa Mill Tailings Management System; and Discharg. tutiri1niration
Technology (DMT) Monitoring Plant (DMT Plan) and the O&M plan: O&M and DMTPlan Approval, and Authorization to operated railings cell4A,,,letter from DaneFinerfrock to Ron Hochstein I pp.
utah Division of Radiation control, october 9, 2008, "white Mesa - June 12, 200g DUSA LinerMaintenance Provisions - Cells 1,2,3, and Roberts Pond, Groundwater Discharge permit
"Denison URS Findings on 10/07 Intera
Existing Wells," e-mail from Loren Morton to
Page 41 of 42
o
): Conditiona
o
Dane Finerfroc k to Steven(No. UGW370004
Landau 2 pp.
I Approval," letter from
Utah Division of Radiation Control, December 2,2OO8, "Denison Mines Decontamination Pad -
Reply After Conference Call," e-mail from Loren Morton to David Frydenlund I pp'
Utah Division of Radiation Control, January 6,2OO9, "Engineering Module 75E - Tailings Cells
1 - 3 and Roberts Pond DMT and Cell4A BAT Performance Standards and Monitoring
Inspection," unpublished regulatory document from Dave Rupp to Loren Morton 7 pp., 1
photo.
Utah Division of Radiation Control, February 26,2009, "November 20,2008 Work Plan for
Tailings and Slimes Drain Sampling Program, Groundwater Discharge Permit (Part
I.H.5)-- Denison Mines (USA) White Mesa Uranium Mill, near Blanding,IJtah,"
unpublished regulatory document (Memorandum to File) by Dean Henderson 7 pp.
Utah Division of Radiation Control, March 2,2009, "Seeps and Springs Sampling Plan,
Groundwater Discharge Permit (Part I.H.8) - Denison Mines (USA) White Mesa
Uranium Mill, near Blanding,IJtah," unpublished regulatory document from Dean
Henderson to Loren Morton 6 PP.
Utah Division of Radiation Control, March 30,2009, "Technical Memorandum on Changes
proposed to the Ground Water Discharge Permit for Slimes Drain Head Recovery Testing,"
unpublished regulatory document from Dave Rupp to Loren Morton.
Utah Division of Water Quality, January 19,2007, Administrative Rules for Ground Water
Quality Protection, R3l6-6, Utah Administrative Code'
Utah Division of Water Quality, March 8, 2005, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.
Utah Division of Water Quality, June 13, 2006, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.
Utah Division of Water Quality, March 17,2}O8:,,Ground Water Discharge Permit, DUSA,
Permit No. uGW370004.
PRG:prg
Page 42 of 42
Utah Division of Radiation Control
Summary of work completed, data results, interpretations and recommendations
For the July 2007 Sampling Event
At the Denison Mines, USA, White Mesa Uranium Mill
Near Blanding, Utah
Prepared by T. Grant Hurst and D. Kip Solomon
Department of Geology and Geophysics
University of Utah
Submitted
May 2008
EXECUTIVE SUMMARY
lncreasing and elevated trace metal concentrations in monitoring wells at a
uranium processing facility near Blanding, UT, may indicate leakage from tailings cells
is occurring. To investigate this potential problem, a groundwater study was done to
characterize groundwater flow, chemical composition, noble gas composition, and age.
The White Mesa Uranium Mill, operated by Denison Mines Co., USA (DUSA), is
located near the western edge of the Blanding Basin. The stratigraphy underlying
surficial aeolian deposits is composed of alternating sandstones and shales of varying
thicknesses. The principle formation in which groundwater is found is the Burro Canyon
Formation of Early Cretaceous age (100 Ma). This formation is composed of sandstone
interbedded with shale, and is generally considered to be of low to moderate
permeability.
Temperature and salinity profiles taken in each of the wells indicate that
stratification of the water column is present. This is supported by dissolved noble gas
compositions determined by collecting passive diffusion samples at two depths in most
wells. Dissolved noble gases had distinct compositions at two depths in allwells
sampled at different depths. Low-flow sampling was employed to attempt to isolate flow
paths within the water column, and samples were collected for tritium, sulfur and oxygen
isotopes of sulfate, hydrogen and oxygen isotopes of water, nitrate and sulfate, and
trace metal concentrations in groundwater. Based on temperature and salinity profiles
and dissolved gas compositions, stratification of the water column is evident. However,
stratification is not delineated in low-flow sampling results of trace metal concentrations
or isotopic fingerPrinting.
Measurable levels of tritium were found in several welts in the northeast portion
of the site. Because these wells also indicated stable isotope fingerprints similar to
those of surface water sites, it is likely that they are being influenced by hydrologic
loading from the wildlife ponds in the northeast corner of the Mill. lsotopic similarities
between wildlife ponds and tailings cells suggest some interaction among surface water
sites. Tritium concentrations of less than 0.5 TU in a number of monitoring wells
suggest water infiltrated the land surface more than 50 years ago, while small but
measurable amounts of chlorofluorocarbons indicates recharge to the saturated zone is
occurring. Trace metal concentrations observed in monitoring wells are similar to
concentrations measured recently in routine groundwater sampling at the Mill.
The data show that groundwater at the Mill is largely older than 50 years, based
on apparent recharge dates from chlorofluorocarbons and tritium concentrations. Wells
exhibiting groundwater that has recharged within the last 50 years appears to be a
result of recharge from wildlife ponds near the site. Stable isotope fingerprints do not
suggest contamination of groundwater by tailings cell leakage, evidence that is
corroborated by trace metal concentrations similar to historically-observed
concentrations. While analysis of trace metal concentrations, age-dating methods, and
stable isotope fingerprinting do not indicate significant leakage from the tailing cells,
active vertical and horizontal groundwater flow is clearly evident. The fact that active
groundwater flow occurs at the site confirms the need for on-going monitoring in order
to evaluate the future performance of the tailing cells..
TABLE OF CONTENTS
t.
t1.
Executive Summary
lntroduction
Methods
A. Deployment and collection of Diffusion Samplers
B. Temperature-SalinitY Profi les
C. Low-Flow Sampling
D. Sampling of Surface Water Sites
E. Decontamination Procedures
F. Equipment Blank SamPles
Field Results
A. Temperature and Salinity Profiles
B. Low-Flow Sampling: Well-Pumping Field Notes and Observations
Analytical Results
A. Chlorofluorocarbon Age Dating
B. Tritium/Helium-3 and Noble Gas Analysis
C..Anions
D. Trace Metals
E. 6 D and 6180 lsotope Ratios in Water
F. 6345 and 6180 lsotope Ratios in Sulfate
V. Discussion
V]. Conclusions and Recommendations
Vll. References
1il.
tv.
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6
6
7
B
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13
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39
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48
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57
tv
I. INTRODUCTION
The White Mesa Uranium Mill, operated by Denison Mines Co., USA, is located 6
miles south of the town of Blanding in southeastern Utah. lt sits on White Mesa near
the western edge of the Blanding Basin within the Canyonlands section of the Colorado
Plateau physiographic province. Elevations range from approximately 3,000 feet at the
bottom of deep canyons in the southwest portion of the region to more than 11,000 feet
in the Henry, Abajo, and La Sal Mountains. The average elevation at the Mill is 5,600
feet above mean sea level (Titan, 1gg4).
The stratigraphy of White Mesa is composed of the following units, in descending
order: aeolian silts and fine-grained aeolian sands of variable thickness (several feet to
25 or more feet); the Dakota Sandstone and the Burro Canyon Formation (totat
thickness ranging from 100 to 140 feet); the Morrison Formation; the Summerville
Formation; the Entrada sandstone; and the Navajo sandstone. The Morrison
Formation is composed of the Brushy Basin Member (shale), the Westwater Canyon
Member (sandstone), the Recapture Member (shale), and the Salt Wash Member
(sandstone). The Summerville Formation is primarily sandstone with interbedded shale
layers' Approximately 1,000 to 1,100 feet of material with low average vertical
permeability separates the Entrada and Navajo Sandstones from the Brushy Basin
Member (HGC, 2003).
Titan Environmental's 1994 report on the hydrogeology of the Mill, and supported
by Hydro Geo chem, lnc.'s, 2005 site hydrogeology study, identified the primary
formations in which groundwater is found beneath the Mill site as the Dakota Sandstone
and the Burro Canyon Formation (sandstone interbedded with shale). HGC (2003)
reports the geometrically averaged permeability of the Dakota Sandstone based on field
tests as 3.8g x 10-5 cm/sec. Titan (1994) reported the geometrically average hydraulic
conductivity of the Burro Canyon Formation as 1.1 x 10-5 cm/sec. The Brushy Basin
Member of the Morrison Formation has generally been considered as impermeable
(lntera, 2OO7),leading to the conclusion that groundwater within the Mill site is perched
(Titan, 1994; HGC, 2003; HGC, 2005; lntera, 2007; and others). Water level data
collected in June 2007 indicate that groundwater flow is generally from the northeast to
the southwest of the site (lntera, 2007).
The White Mesa Uranium Mill became operational in 1980. To date, 4 million
tons of conventionally-mined and alternate feed uranium ores have been processed,
recovering more than 25 million pounds of UsOa and 34 million pounds of Vanadium.
The Millwas in standby status from November 1999 to April 2002 during which alternate
feed materials were received and stockpiled. After processing these alternate feed
materials, from April 2OO2to May 2003, the Mill returned to standby status, where
alternate feed materials were again received and stockpiled. The Mill resumed
processing of alternate feed materials in March 2005. Processing of conventionally-
mined ores is expected to resume in 2008.
ln order to evaluate sources of solute concentrations at the Denison Mines Co',
USA, White Mesa Uranium Mill, low-flow groundwater sampling was implemented in 15
monitoring wells. Furthermore, surface water samples were collected from three tailings
cells and two wildlife ponds. Passive diffusion samplers were also deployed and
collected in order to characterize the dissolved gas composition of groundwater at
different depths within the wells. Samples were collected and analyzed for the
following: tritium, nitrate, sulfate, deuterium and oxygen-18 of water, sulfur-34 and
oxygen-18 of sulfate, trace metals (uranium, manganese, and selenium), and
chlorofluorocarbons.
Depth profiles of temperature and salinity measurements were taken in the wells
to determine the extent of stratification of different formation waters. Differences in
temperature and salinity throughout the water column can indicate flow-paths of
differing travel times, as well as potential differences in recharge location. Furthermore,
these profiles provided insight regarding the water quality conditions existing in the wells
before purging and sampling was conducted.
Our approach for evaluating solute sources is as follows. lndicators of
groundwater age have been correlated to solute concentrations of the trace metals
uranium, manganese, and selenium. Young groundwater found down-gradient of the
Mill, that is associated with high levels of solute concentrations, would suggest a solute
source at or near the mill. High solute concentrations in waters both up- and down-
gradient of the Mill would indicate an aquifer source (i.e. background) for solute
concentrations. Old groundwater found up- or down-gradient of the Mill, associated with
high solute concentrations, would also indicate an aquifer source for solute
concentrations.
Chlorfluorocarbons (CFCs) are anthropogenic gases that have been released to
the atmosphere since the early 1940's. CFC's in the vadose zone are likely to be
similar to the current atmospheric CFC concentrations, and dissolve in groundwater to
provide an apparent age of when water recharged the saturated zone. Tritium, the
radioactive isotope of hydrogen containing one proton and two neutrons, was reteased
to the global hydrosphere during above-ground nuclear weapons testing in the 1950's
and 1960's. As part of the water molecule, tritium provides an estimate of the time at
which water infiltrated ground surface. The presence of tritium in a water sample, or the
presence of tritiogenic helium-3, indicates that water recharged the saturated zone
within the last 50 years. These methods are used to determine apparent recharge
dates for groundwater within the Mill site.
Analytical results for sulfur-34 and oxygen-18 isotopes of sulfate, and deuterium
and oxygen-18 isotopes of water provide a possible fingerprint of water originating from
the Mill tailings cells. Down-gradient waters with a similar isotopic fingerprint as the
tailings cells, in addition to a significantly different isotopic fingerprint up-gradient of the
tailings cells, may imply the tailings cells as contamination point-sources'
Aerial View of White Mesa Mill
Figure 1: Aerial View of White Mesa Miil displaying sample points
Legend
+ Sudace Sites
r Monitonng Wells
N
A
lt.
A.
METHODS
Deployment and Collection of Diffusion Samplers
passive diffusion samplers designed to collect dissolved gases were deployed at
two different depths in Monitoring Wells (MW) 1,2,3A,5,11,14,15,18, 19, 22,27,29,
30, and 31. One diffusion sampler was deployed in MW-3 in the center of the saturated
portion of the screened interval. Upon arrival at each well, a water level measurement
was made, and appropriate depths for sampler placement were determined. Samplers
were deployed approximately 1m above the bottom of the screened interval and 1m
below the top of the screened interval. ln wells that did not have a fully saturated
screened interval (MW-2, 3, 3A, 5, 14, 15,27,29, 30, 31), the top diffusion sampler was
placed approximately 1m below the top of the water level.
A cluster of 6 stainless steel 3/8" nuts were attached to the bottom of the
diffusion sampler line in order to counter any buoyant effect from the volume of air
inside the samplers at depth. Samplers were attached to nylon line, which was used to
avoid twisting of the line while being lowered into the well. Samplers were attached
using nylon zip-ties at either end of the sampler. The samplers were attached in such a
way to allow stretching in the sampler line, thereby preventing potential separation of
the gas-permeable membrane from the copper tubing. Sampler line was secured to the
outer well casing, which was then locked and wrapped in security tamper-evident tape.
Diffusion samplers were allowed to equilibrate inside the wells for at least 48
hours. This was to ensure that the dissolved gases in groundwater were at equilibrium
with the gaseous volume inside the diffusion samplers. Samplers were removed from
the wells prior to taking temperature-salinity profiles and prior to low-flow sampling.
Approximately two-minutes elapsed between commencing removal of the samplers
from the well and the time by which all four sample volumes (two sample volumes for
one sampler, and one sampler at two different depths for each well) were sealed. This
was to minimize any re-equilibration between the sample volume and atmosphere from
taking place, preserving the dissolved gas signature of the well water. This time-frame
was monitored and all samplers were removed within the two-minute window. The
diffusion samplers were sealed using a crimping tool that seals the copper tubes such
that they are impermeable to gas leakage, creating a representative sample of the
dissolved gases in the groundwater.
Each sample volume was labeled according to the order in which it was sealed,
and electrical tape was wrapped around the exposed ends to protect the sealed ends.
Samplers were then sealed in zip-lock plastic bags and stored for transport to the
laboratory.
B. Temperature-Salinity Profiles
Profiles of temperature and satinity with depth were measured using a Hydrolab
MiniSonde 4A and Surveyor 4A handheld unit. Dedicated bladder pumps installed
previously by DUSA were left in the well to prevent disturbance of any temperature or
salinity gradient that may have been present within the water column. pump head-caps
were secured to the side of the well casing to allow for insertion of the Hydrolab probe
into the well.
Measurements of temperature (oC) and specific conductance (pS cm-1; were
made at one-foot intervals throughout the saturated interval in the well. Total dissolved
gases (mm Hg) and dissolved oxygen (mg L-1)were made at the depths at which the
passive diffusion samplers were deployed. The probe was allowed to equilibrate until
the total dissolved gas measurement did not fluctuate by more than 0.17o over a period
of 5 minutes (generally 0.1o/o equaled approximately 1 mmHG). This equilibration
process lasted from 15 minutes to more than one hour at some wells. Profiles were
taken until the Hydrolab probe reached the bottom of the well, or until it could not be
lowered below the DUSA dedicated bladder pumps.
Upon completion of temperature and salinity profile measurements, the
dedicated bladder pump was removed from the well by DUSA employees and stored in
plastic bags for the duration of sampling.
C. Low-Flow SamPling
A Grundfos Redi-Flo 2 submersible pump was used for low-flow groundwater
sampling in the aforementioned wells. The pump was controlled using the Grundfos
Variable FreQuency Drive (VFD) control unit, powered by a generator. Generally, the
pump was lowered to approximately 1.5 m below the top of the screened interval, or 1.5
m below the top of the water level in wells that did not have fully saturated screened
intervals. ln severalwells (MW-14, MW-18, MW-19, and MW-22), the pump was then
lowered to a second sampling depth approximately 1.5 m above the bOttom of the
screened interval. A pressure transducer was lowered to a depth determined at each
well individually in order to monitor the head present above the pump, allowing for
drawdown to be monitored while pumping. This was done to ensure low-flow conditions
were maintained during the well sampling process.
The discharge tube from the pump was connected to a flow-through cell on the
Hydrolab probe. This was used to monitor temperature (oC), dissolved oxygen (mg L-'),
total dissolved gases (mm Hg), and specific conductance (pS cm-1). Discharge from the
flow{hrough cell was monitored periodically using a 1000 mL beaker and a stopwatch.
After turning on the pump, the frequency on the VFD unit was increased slowly
until water began flowing from the discharge tubing. Head was monitored constanly
while increasing the frequency, and upon filling the flowthrough cell on the Hydrolab
probe, water quality parameters were then monitored. Parameters were considered
stable when their change was less than 5% over a period of 5 minutes. Furthermore, a
minimum purge volume of 2 pump tubing volumes (1 pump tubing volume is
approximately 3 gallons for the length of tubing installed onto the pump) was removed
before sampling occurred. With the exception of MW-18 the field parameters were
stable prior to sampling. After t hour of purging the field parameters in MW-1g were not
stable. Nevertheless, samples were collected in accord with the sampling plan that
called for a maximum purge time of t hour.
When the field water quality parameters were considered stable, and when the
minimum purge volume of two tubing volumes had been pumped, sampling began.
Samples were generally taken in the following order: tritium (1 L sample), nitrate (125
mL sample), sulfate (125 mL sampre), 6D/618o (15 mL sample), 634s/618o (1 L sample),
trace metals (1x250 mL sample;2x12s mL samples), CFC,s (sx12s mL samples).
Bottles containing samples for tritium, 6D/618O, and 6345/618cl, were rinsed three times
to eliminate contamination from atmospheric or other sources. Nitrate, sulfate, and
trace metal sample bottles were not rinsed because bottles were pre-acidified by the
analyzing laboratory.
Trace metals collected as 1x250 mL sample were unfiltered, while one 125 mL
sample was filtered and the second was left unfiltered. 125 mL trace metal samples
were collected using a field collection hood made of a sterile garbage bag clipped to a
pVC frame. Pump discharge tubing was run through the top of the garbage bag, and
samples were collected within the bag to decrease the possibility for contamination of
the samples by the atmosphere. Dust particles or other atmospheric input to the
sample could contaminate the sample and create interference in analyzing for trace
amounts of metals. Filtered samples were obtained using a Waterra FHT-45 micron
inline disposable filter, attached directly to the end of the discharge tubing, and
disposed ofafter each use.
Upon finishing trace metal sample collection, discharge tubing was disconnected
from the pump reel connection and a length of 3/8" diameter copper tube was attached
to the pump reel. This was used to collect CFC samples in order to eliminate as much
plastic from the pump line as possible, and also to allow for the discharge tubing to be
inserted directly into the sample bottles. CFC sampling procedures were followed as
specified by the United States Geological Survey Reston CFC Laboratory (USGS,
2OO7). A 3 gallon glass desiccator was used as the sample collection vessel, and was
filled with purge water after the minimum purge volume had been removed from the
well. Bottles were submerged and the copper discharge tube was inserted into the
bottles, which were then positively purged for approximately 10 bottle volumes (1250
mL). Bottles were filled underwater in order to eliminate any contact with the
atmosphere, and caps were also submerged and placed securely on bottle mouths
underwater. After checking for bubbles within the sample bottle, the cap was wrapped
tightly with electrical tape to protect the cap from any dislodgement during transport'
10
After collecting all of the samples, the pump was disengaged. ln the four wells
that sampling was to occur at multiple depths, the water was allowed to discharge from
the pump tubing into the well, and then the pump was lowered to the next depth.
Purging was then only completed for 2 tubing volumes before sampling began again,
which was completed in the same fashion as for the previous depth.
D. Sampling of Surface Water Sites
To sample the wildlife ponds, a S-foot long, 4-inch diameter section of perforated
PVC pipe (well-screen pipe) was lowered onto the sloping bank of each pond and
completely submerged. The Grundfos pump was then lowered into the tubing, and
connected to the control unit and Hydrolab flowthrough cell. Pumping and sampling
was then conducted as previously described. Purging was conducted for two pump
tubing volumes before sampling commenced.
For sampling the tailings cells, a Global Water lnstrumentation, lnc., super
submersible pump (part number GP92168)was used to collect water samples.
Because these pumps are inexpensive, replaceable, and easily disposed of, it was used
in place of the Grundfos submersible. For tailings cells 1 and 3, the pump tubing was
draped over and secured to the railing of platforms on top of the pond. The pump was
lowered to several feet below the water surface, and was then purged for approximately
two tubing volumes. Purge water was collected and returned back to the tailings celts.
For sampling the Tailings Cell 2 slimes drain, the pump was simply lowered down the
vertical drain access pipe and lowered several feet below the observed water surface.
Purge water was collected and disposed of in what was previously Tailings Cell 2.
During sampling of the tailings cells, heavy rubber gloves were worn because of the
11
acidity of the solution.
E. Decontamination Procedures
Decontamination procedures of the pump and pump tubing were conducted in
order to eliminate the possibility of well-to-well cross contamination. Upon removal of
the pump from the well, it was lowered into a 5 foot long, 4 inch diameter vertical PVC
column that was capped and sealed on the bottom end. De-ionized (Dl) water was then
poured into the column, and the pump was turned on. Approximately 5 gallons of Dl
water was then purged through the system to eliminate residual well water in the pump
tubing. This water was collected and containerized in the same fashion as well purge
water.
After purging the pump and pump tubing with Dl water, the pump was
disconnected from the pump tubing and connected to a tank of compressed Nitrogen
gas. N2 gas was allowed to flow through the pump tubing for approximately 60 seconds
in order to flush residual Dl water from the pump tubing. ln order to more effectively
purge Dl water from the pump tubing, the pump reel was placed on its side while
purging with Nz gas. This purged Dl water was also containerized in the same fashion
as the well purge water.
F. Equipment Blank SamPles
Equipment blank samples were collected at the conclusion of the sampling event.
These samples were collected for the following constituents: nitrate (125 mL sample),
sulfate (125 mL sample), and trace metals (1x125 mL sample, 1x250 mL sample).
Blanks were collected after sampling the final well and immediately after purging the
pump and pump tubing with 5 gallons Dl water. Equipment blank samples were
12
collected using Dl water directly from the pump discharge tubing.
III. FIELD RESULTS
A. Temperature and Salinity Profiles
Temperature and salinity profiles with depth are presented below for the 15 wells
sampled. Salinity is presented as specific conductance in units of pS cm-1, which is
nominally about 1.5 times the level of total dissolved solids in mg L-1. Vertical
stratification of specific conductance and temperature are apparent in all of the wells,
with a general increasing trend in specific conductance with depth in the saturated
interval and a general decreasing trend in temperature with depth in the saturated
interval. Dashed lines represent the top of the well screens, while dotted lines represent
the bottom of the well screens. Figures marked with an asterisk (*) are profiles taken
entirely within the screen and saturated interval; therefore neither the top or bottom of
the wellscreen is indicated. These wells are MW-2 and MW-S (Figures 3 and 6,
respectively). Figures marked with a dagger (f) are sites at which the static water level
was below the top of the well screen and do not include a dashed line. These wells are
MW-3, MW-3A, MW-14, MW-1s,Mw-27, MW-29, MW-30, and MW-31 (Figures 4,s,g,
9, 13, 14,15, and 16, respectively).
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Temperature and Salinity vs. Depth (MW'l)
Spociic Condus{ance (IS/m)
1770 t78o 1790 1800 1810 1A20 1830
Figure 4: MW-3 t
Temperature and Specific Conductance vs. Depth (MW-S)
Spocifi c Conduclane (PS/cm)
2726 272a 2730 2732 273/ 2736 273A 2740 2742
14.2 14.3 14A 14.5 14.6 14.7
Tempentue fC)
+ Specmc Conductance + TemPemture
1850
Temperaturs and Specific Conductance vs. Depth
Specific conductance (ps cm'i)
34E0 3500 3520 3540 3560 3580 3600 3620
13.7 13.8 13.9
0
5
10
20
=25-
30
35
40
45
E
!
o
Bio
6
c
d
I
!
o
B'o
oE
6
!fo
='o
o
!oo
o
E=trgo{
=
a
I!
o
6'{
=
q
1
e
o
!4
oE.oa{
o:t
,
13.80 ',14.00 14.20 14.40 14.60 14.80 15.00
TompentuE fC)
14 14.1 14.2 14.3 144 14.5 14.6
TempsratuE fc)
E@ryrlr1-el
Figure 3: MW-2.
__l
Temperaturc and Specific Conductance Ys. Depth
Specific Conductane ffi cm't1
5800 5850 5900 5950 6000 6050 6100
o
!
6e-o{
€
o
a
,
o
!
6g.o{
E
o
a
,
E
o
3
'o
o
ao
2
1
5
8
10
12
14.60 14.80 15.00 15.20 15.40 15.60
Tempsraiure CC)
--'-.. Well ScEen Bottom +Specific Conductance +TempeEtuE
Figure 5: MW-3A t
Specific Conductanca OS cm't)
2550 2600 2650 2700 2750 2800 28sO 2900 2950
13.5 14 14.5 15 15.5 ',16 16.5 17 17.5 18
TempeEture fC)
Figure 2: MW-1
1,
+,
t:"1.
+,l"
ii
:l
:l
o
J
Ec.oI{
a
a
=
i
o
='E
eo
Temperature and Specific Gonductance vs' Depth
Specific Conductane (S mn)
sss0 5600 5650 5700 5750
14.47 14.48 ',14.49 14.5 14.51 ',14.52 ',14.53 14 54 14.55 14.56
TemPenhrB FC)
--.-.-. WellSc@n Bottom +Spsiic Conductance +Tempetalure
Temperaturc and Specific Conductance vs. Depth
Figure 6: MW-S.Figure 7: MW-11
14
Temperature and Specific Gonductanr
Spscific Conduc{ancc (pS cm'r)
3760 3780 3800 3A20 3840
14.60 14.E0 1s.00 15.20
TempsEture eC)
-.....- Well Scrn Bottom +Sp6ifc Conductance
Figure 8: MW-14 t
Temperature and Specillc Conductance vs. Depth
Specific Conduclanc. (pS cm{)
4050 4100 4150 1200 4250 4300
o9,E
6'{
=
o
a
oc
C
to
B'.g
E
c6
o
!too
o-{
fqo
o
a
E
:r
,;]
,a ]
,al
,. J"
.,L
1
0
,0
20
30
40
50
60
70
80
90
1:
t0ls
1,n
1;:
1,.
+,+3s
1oo
-t+4s
0
€s
8ro!, 15ob20
=2sl
-9 30.
I.u
Eooo
45
11
0
5
10
20
25
30
14.30 14.40 ,t4.50 14.60 14.70 14.80 14.90 15.00
Tempsrature fC)
Figure 9: MW-151
Specifc Conductanc. (tf,S cm'r)'1500 1700 1900 2100
Figure'11: MW-19
Spocif,c Conduc{an6 (pS m'r)
1150 1250 1350
1445 14.50 14.55 14.60 14.65 14J0 I
TsmpentuB eC)
..----- Well ScEen Bottm +Specific Cqtductance +TempeBturc
t=o
Eq
=io
ot
o
:i
20 .l*]
,,f-
uol
..1,
^L
Temperature and Specific Conductance vs. Depth
Speci6c Conduqtane (pS cm'r)
2200 2400 2600 2800 3o0o 32oo 3400
13.80 14.00 14.20 11.40 14.60 1,r.80 ls.oo
Tempe6tuB fC)
0 oro€t2ot
ogo{
=40*
650E
soBezo-
Figure 10: MW-18
Temperature and Specific Conductance vs. Depth
0
EilI I I Iil I
jI$E::1.|ru'+::3" | | ,-*'++, o=sft i*
13 00 13 s0 1,r.00 l4.s0 ,;::rj,::- laoo 16.s0 17.00 17.50 r8.oo
l
| - - - -W"t, S"o"n fop . - -.... Wdt Sc@n Bottom +Speifc Condrctance * r**orr1
0sFErof_-P,- o^^ttul
2s3
30oEasi
aol,4s-
Temperature ahd Specific Conductance vs. Depth
Sprcific Conducianco (pS cm-t)
6200 6400 6600 6800
Figure 12:MW-22
a":
,"1L-
,ol
,rl
I,.l
sol
f-.
e
€ao
3
'oE6
q
o
Temperaturc and Specific Conductance ys. Depth
Figure 13: MW-27 t
15
!
o
c
='o
oteo
0 o
!5,EE.o.^{',=
15oc
20oe
,f
;l
Temperature and Specific Conductance vs' Depth
Spocifc conduclan@ (lf,l m'r)
/t535 4545 4555 4565 4575
't4.2 14.3 14A ',14.s 14.6 147 14.8
TemPeEtuc fc)
..----. WellScEn Bottom +Specifc Condrctance +TmpeEture
+O
1,
I
l'o
t"I'+2sEd
15.50 ',r6.00 16.50
)ratuB fC)
Specifi c Cqductance +TemFEEtuc
Note:
Figure 14: MW-29 t Figure 15: MW-30 t
* lndicates the profile was taken entirely within the screened and saturated interval; neither well
screen bottom or top are displayed in the figure.t lndi"rt"s the static water level was below the top of the well screen, therefore well screen
bottom is not displayed in the figure'
e
Eto
3!o
o!co
Temperature and Specific Conductance vs. Depth
Specific Conductancs (IS cm'r)
1700 1705 1710 ',1715 1720 1?25
14.20 14.40 14.60 14.80 15.00 15.20
Tempe6tuB fC)
.,..... w6ll Sc@n Bottom +Speci6c Conductarce +TempeEtuc
T:
1,0
I
1','
1.0
Il'1so
o
!
Jo
oa
E
oca
a
Figure 16: MW-31 t
B. Low-Flow sampling: well-Pumping Fierd Notes and observations
Low-flow sampling techniques were implemented for collecting groundwater
samples from the Mill. Theoretically, this technique allows for sampling a specific depth
in the water column, ostensibly isolating the groundwater flow path at that depth. From
this specific sample depth, stratification within the water column, if present, with respect
to groundwater ages and solute concentrations can be determined. Solute
concentrations can then be correlated to groundwater ages, information that can
ultimatety be used in identifying potential sources of solUte concentrations.
While very dependent on the hydrogeology of individual sites, flow rates used in
low-flow sampling are often on the order of 0.1-0.5 L min-1 (100-500 ml min-1), but can
be as high as 1 L min-1 (1000 mL min-1). This is the rate at which the pump is extracting
water from the formation at the depth at which the pump is placed, assuming the
formation is able to produce water at that rate. lf the formation is unable to produce
water at the rate demanded by the pump, drawdown occurs in the water column. Thus,
the term "Low-flow" sampling is often referred to as "Minimal Drawdown,,sampling.
Minimal drawdown is considered less than 0.1 m (10 cm) during purging (puls and
Barcelona, 1995).
Pumping was conducted at the Mill so as to produce minimal drawdown within
each well (i.e., <0.1 m)during purging. Water levels in the wells were monitored during
pumping using a pressure transducer that converted the pressure head of the water
column into a reading in feet of hydrostatic head above the instrument. The transducer
was generally placed approximately 15-20 feet below the measured surface of the
water, or immediately above the pump unit when the pump was within 15 to 20 feet of
17
the surface of the water.
ln some instances where wells were extremely low-yielding, drawdown was
occurring even when the pump was being operated at or near 0.1 L/min (100 ml/min).
This was the case for wells MW-1, MW-3, and MW-3A. For this type of situation, the
pump was lowered to the bottom of the well, at which time the wells were pumped to a
water level near the bottom of the screened interval. MW-1 was pumped to only 1
meter below the top of the screened interval because purging had been taking place for
almost 60 minutes. MW-1 was allowed to recover for approximately 12 hours
(overnight). Well MW-3A was pumped to approximately 1 m above the bottom of the
well screen. MW-3 was pumped to approximately 0.25 m above the bottom of the well
screen. Wells MW-3 and MW-3A were allowed to recover for a period of 3 days due to
both exhibiting extremely low-yielding properties during previous pumping events.
Water levels were monitored periodically during this recovery period in MW-3 and MW-
3A. MW-1 was sampled using the Grundfos pump, while MW-3 and MW-3A were
sampled with DUSA's dedicated bladder pumps. A full suite of samples was taken from
MW-1 during well pump-down, and also after recovery. Samples taken after recovery
are hereafter denoted as MW-18.
The passive sampler initially placed at the lower depth in MW-22 is suspected to
have been resting on sediment at the bottom of the well. A second passive diffusion
sampler was installed following removal of the first set, and is denoted as "MW-22(b)
deep" in tables where noble gas data are presented.
18
IV. ANALYTICAL RESULTS
A. Chlorofluorocarbon Age Dating
Chlorofluorocarbons in the atmosphere can be used to provide an estimate of
groundwater recharge date due to their changing concentration over time and their
solubility in water. Samples were collected from all 15 wells, including 4 wells sampled
at two depths, 2 wildlife ponds, tailings cells 1 and 3, and cell 2 slimes drain. Analyses
were conducted on most sites, analyzing a minimum of three bottles per site, with
analysis of the fourth and fifth sample bottles if necessary. This was needed when
outliers were found during the analysis of the first three bottles at a site (MW-2, MW-1g
Deep, and MW-27). Tailings cells 1 and 3, and the cell 2 slimes drain, have not been
analyzed because of potential damage that extremely high levels of organics could
inflict on the analytical equipment. Both sampling depths in MW-22,and MW-30 have
not yet been analyzed because of strong signal interference with the CFC-12 signal,
potentially attributable to dissolved COz or NzO gases. This interference could
potentially damage the laboratory instruments; therefore, these samples were not
analyzed. CFC concentrations are presented in Table 1.
19
Table 1: Mean CFC concentrations in White Mesa water
SAMPLE ID Mean CFC-11
(pmoles/kq)
Mean CFC-12
(omoles/ko)
Mean CFC-113
(omoles/ko)
MW-1 2.594 1.896 0.092
MW-18 2.750 1.683 0.093
MW.2 2.157 1.272 0.154
MW-3 1.285 0.826 0.130
MW-34 2.759 1.885 0.223
MW.5 0.693 0.284 0.000
MW-11 0.179 0.090 0.000
MW-14 shallow 0.305 0.118 0.000
MW-14 deep 0.262 0.129 0.000
MW-15 0.686 0.678 0.014
MW-18 shallow 0.510 0.000 0.000
MW-18 deeo 1.428 0.140 0.026
MW-19 shallow 1.503 0.974 0.028
MW-19 deep 1.622 1.1 10 0.087
MW-22 shallow nla nla nla
MW-22 deep nla nla nla
MW.27 0.809 3.709 0.016
MW-29 0.511 0.244 0.000
MW-30 nla nla nla
MW-31 0.846 0.982 0.000
WP2 0.000 0.849 0.010
WP3 1.675 0.961 0.056
Tailinqs Cell 1 nla nla nla
Tailinqs Cell2 nla nla nla
Tailings Cell2
Slimes Drain nla nla nla
ffieSwerenotanalyzedbecauseofpotentialdamagetoanalyticalequipmentfrom
sample composition.
Results are reported in units of pico-moles per kilogram, or 10-12 moles of CFC
per kilogram of water sample. Samples MW-1 , MW-18, MW -2, and MW -3A show a
moderate amount of CFC-11, with MW -3, MW -18 deep, and both depths for MW -19
show slightly lower amounts of CFC-11. The remaining samples have very little
dissolved CFC-11. CFC-12 concentrations range from below detection to 3.7 pmoles
kg-1. Only small amounts of CFC-113, if any, were detected in the samples. CFC
concentration in the atmosphere since introduction of CFC's in the 1940's and 1950's
have been monitored, and a historical record of CFC concentrations over the last 60
years allow groundwater ages to be estimated. These concentrations are plotted in
20
Figure 17. Measured CFC concentrations in a groundwater sample are compared with
corresponding atmospheric concentrations, and a groundwater recharge date is
obtained. These ages should be considered as apparent ages as a given sample may
contain a range of ages, and there are numerous processes such as degradation that
can affect CFC concentrations. The ranges are represented by the different calculated
recharge date for each CFC and are presented in Table 2. Samples collected near the
water table are always higher in concentration than deeper samplers. Because higher
concentrations are associated with younger water, this indicates that some recharge is
occurring at the site (i.e. placing younger water on top of older water.)
Atmospheric CFC Concentrations since 1940
1970
Year
--+- CFC-1 1 - t- CFC-12 --x- CFG1 13
o
CLg 4oo
C)]Lo
.3 eooos
CLoI zoo
Figure 17: CFC's in the atmosphere since 1g40
21
Table 2: Calculated CFC date ES
Site CFC-l1 Recharqe Year CFC-12 Recharqe Year CFC-113 Recharge Year
MW.1 1984 2001.5 1980
MW-18 1985 1991 1980
MW-2 1979.5 1983 1984
MW.3 1971 1972.5 1980
MW-34 1981.5 1989.5 1985.5
MW.5 1969.5 1966.5 1943
MW-11 1961.5 1958 1943
MW-14 Shallow 1962 1957 1943
MW-14 Deeo 1961.5 1958 1943
MW-15 1967 1971 1963.5
MW-18 Shallow 1967.5 1943
MW-18 Deep 1974.5 1961.5 1971
MW-19 Shallow 1975 1978.5 1971.5
MW-19 Deep 1975.5 1981.5 1979.5
MW-22 Shallow nla nla nla
MW-22 Deep nla nla nla
MW-27 1967.5 2001.5 1963.5
MW-29 1967 1965 1943
MW-30 nla nla nla
MW-31 1970.5 1978.5 1943
wP2 1973.5 1962
WP3 1973.5 1975 1974.5
notei n/a 'lldicates sarnptes were not analyzed because of potential damage to analytical equipment
from sample comPosition
Table 2 cells in which no data values are reported (-) represent situations in
which either no CFC's were detected, giving a recharge date of pre-modern (before
1g50's), or CFC contamination occurred (i.e. values greater than equilibrium with the
modern atmospheric concentration). No recharge date is presented for wildlife pond 2
(CFC-11 and 113) or MW-18 shallow (CFC-1 2 and 113) because analytical errors
occurred for two of the three CFC compounds. Samples from wildlife pond 2 and MW-
18 shallow can be considered to have age ranges of t5 years from the presented
recharge year.
Recharge elevations and temperatures are presented in Table 3. The recharge
temperature for most samples was obtained from noble gas analyses presented in
Section lV B. Samples for which noble-gas recharge temperatures were unavailable
22
were assumed to recharge at 1soC. All samples were assumed to have recharged at
1830 m elevation, or 6000 ft. This is based on the assumption that recharge occurs at
an elevation that is intermediate between the elevation of the study site (1700 m) and
the adjacent topographic highlands (i.e. the Abajo Mountains north of Blanding at about
3000 m.) The uncertainty in apparent age due to uncertainty in the recharge elevation
is about 1 yearl1000 m for water that recharged in 1975. The uncertainty in the CFC
recharge year that results from uncertainty in recharge temperature is approximately 1
yearfC (Solomon and Cook, 2000).
Most sites exhibited cFC recharge date ranges of 1g60's and 1970,s, with
several sites in the early and mid 1980's. only MW-1 (B sampte) and MW-3A had
CFC's representative of the late 1980's or early 1990's. ln both cases, wells were
pumped dry (according to Section lV) because of low-yielding characteristics, and well
MW-3A was subsequently sampled using DUSA dedicated bladder pumps. potential
CFC contamination could have occurred in these wells, as well as MW-3, because of
exposure to atmosphere after pumping the boreholes dry. Furthermore, MW-3 and
MW-3A could have been contaminated because of the plastic tubing in the DUSA
dedicated bladder pumps. Plastics are often a source of contamination in CFC
analysis, and while the Grundfos pump and tubing had been tested for cFC
contamination prior to the sampling event, no such tests had been conducted on the
DUSA bladder pumps.
23
Sites
B. Tritium/Helium-3 and Noble Gas Analysis
Water samples from all 15 wells, including 4 wells sampled at two depths, 2
wildlife ponds, and tailings cell 3 and cell 2 slimes drain, were analyzed for tritium (3H),
the only radioactive isotope of hydrogen, and a suite of dissolved noble gases. Tailings
cell 1 was not analyzed for tritium due to complications that arose during the helium-3
in-growth period (the acid water corroded the metal holding flask). Using the ratio of
tritium and 3He, the daughter product of decayed tritium, in water, an approximate age
of the water sample can be calculated. This age is representative of the time at which
the water parcel was last in equilibrium with the atmosphere in the last 40 to 50 years,
as the tritium incorporated into water molecules has been steadily changing since a
wide-scale atmospheric injection of tritium during above-ground thermonuclear weapons
Table 3:Elevation and Temperature of S
Site Recharge Elevation (m)Recharge Temperature (oC)
MW-1 1830 15.00
MW-18 1830 15.00
MW-2 1830 13.96
MW-3 1830 7.95
MW-34 1830 11.04
MW.5 1 830 15.00
MW.11 1830 15.00
MW-14 Shallow 1830 6.93
MW-14 Deeo 1830 7.60
MW-15 1830 7.79
MW-18 Shallow 1830 15.00
MW-18 Deeo 1830 15.00
MW-19 Shallow 1830 15.00
MW-19 Deep 1830 15.00
MW-22 Shallow nla nla
MW-22 Deeo nla nla
MW-27 1830 6.50
MW-29 1830 13.10
MW-30 nla nla
MW.31 1830 15.00
wP2 1830 10.25
WP3 1830 10.25
24
testing in the 1950s and 1960s. As such, tritium concentrations in water samples give a
good idea of when groundwater recharged to the saturated zone. Tritium
concentrations for each site are presented in Table 4.
25
Table 4: Tritium concentrations in White Mesa water
Site Tritium Tritium - repeat
(TU)(error t)fiu)(error +)
MW-1 0.02 0.34 <0.3
MW-18 0.03 0.11 nla
MW-2 0.24 0.73 nla
MW-3 <0.3 nla
MW.3A <0.3 nla
MW.5 <0.3 nla
MW-11 <0.3 0.16 0.05
MW-14 Shallow 0.36 1.05 0.04 0.05
MW-14 Deeo <0.3 nla
MW-15 <0.3 <0.3
MW-18 Shallow <0.3 <0.3
MW-18 Deep 0.05 0.40 <0.3
MW-19 Shallow 3.11 0.31 nla
MW-19 Deep 3.96 0.37 nla
MW-22 Shallow <0.3 nla
MW-22 Deeo 0.87 0.31 <0.3
MW-27 8.67 o.92 nla
MW-29 <0.3 0.07 0.16
MW-30 <0.3 nla
MW.31 <0.3 nla
TC1 nlar nla
TC2 Slimes Drain 0.93 0.68 1.04 0.13
TC3 6.01 1.37 7.24 0.55
wP2 5.98 0.39 nla
WP3 5.94 0.40 nla
Note:n/aindicatesnosionofmetalholdingflaskpreventdanalysis'
Error reported is 1o. Concentration units are reported as tritium units (TU), which
represents a single molecule of 3H1HO in 1018 molecules of 1HzO, or 6.686x107 tritium
atoms kg-1 lsolomon and Cook, 2000). Analyses were repeated on samples that were
not completely degassed during sample preparation. These analyses provided better
resolution in the final concentration and are presented in the "Tritium - Repeat" column.
Most sites exhibited very low to no tritium levels, with a few exceptions. Wildlife
ponds 2 and 3 had about 6 TU in both, in concert with the nature of a surface water site
receiving modern water from the atmosphere. MW-19 had tritium levels of 3.1 and
nearly 4.0 TU for the shallow and deep sampling points, respectively. MW-27 also
26
exhibited elevated tritium levels (8.67 TU). Small amounts of tritium were observed in
the deep sampling point at MW-22 (0.87 TU).
MW-19 (shallow and deep) and MW-27 are close to the northern wildlife ponds and are
likely to be influenced by recharge from the ponds. Recharge occurring due to the
wildlife ponds would contain some amount of tritium due to pond water interacting with
the atmosphere. This means groundwater flow near the wildlife ponds is being
influenced by artificial recharge and the tritium seen in MW-19 and MW-27 is evidence
of water derived from the wildlife ponds. Tritium in MW-22 deep indicates a small
amount of recharge taking place near the well. The southern margin of artificial
recharge is likely to be between MW-27 and MW-31 while the northern margin appears
to be between MW-18 and MW-19.
That MW-27 has the highest tritium levels of all sites, including surface water
sites, does not necessarily mean that it is the youngest water. Atmospheric tritium
concentrations have varied over time, therefore tritium concentrations alone do not
provide an absolute age-date for a given sample. Heilwell et. al (2006) plotted Tritium
concentrations in the atmosphere for the western United States, shown in Figure 18.
The fact that significant and measurable quantities of tritium are present in MW-27, MW-
19, and the wildlife ponds, indicates recharge to the aquifer from the wildlife ponds is
occurring. Tritium in MW-22 deep suggests that an extremely localized area of
recharge is occurring near that well.
27
c,tzJE 2,000)
EIE
t---
1,500
4,000
3,500
3,000
2,500
0t950 1955 1965 .t975 1980 1985 1990 1995 2000
Figure 18: Atmospheric tritium concentrations in the southwest United States (Heilwell et. al, 2006)
Ten of the wells have small but measurable amounts of CFCs (excluding
samples where contamination during sampling may have occurred), but contain
essentially no tritium. This is likely the result of differences between where the CFC and
tritium "clocks" start. Tritium is part of the water molecule and the travel time associated
with this tracer starts at the land surface. ln contrast, CFCs are gases that can dissolve
into water and the clock associated with this tracer is set near the water table. ln the
unsaturated zone, CFCs from the atmosphere may be transported as a gas phase by
way of either diffusion or advection. Since transport in the gas phase is typically much
more rapid than transport in the aqueous phase, CFCs can be transported to the water
table in much less time than tritium. ln other words, the observation of small amounts of
CFCs with no tritium is interpreted to mean that aqueous phase transport through the
+Safl LakeCity, Ulah
+ Albuquerque, New Mexico
-*--..* Flagstaft, Arizona
- + - - Salt Lak€ Ciry (e$1imal6d)
. . *'-Albu,querqu€ (6stimatod)
' " '| ' 'Flagsaf, (esilimaled)
Hollow (esli
28
unsaturated zone requires more than 50 years, whereas gas phase transport of CFCs
requires much less time. Nevertheless, the mere presence of CFCs below the water
table does suggest that recharge is occurring (if there were no downward water
movement across the water table CFCs from the unsaturated zone woutd not be
transported to depth.)
Passive diffusion samplers were used to measure dissolved gas composition of
groundwater. These analyses provide insight to the temperature at which a parcel of
groundwater recharged to the saturated zone, and also information about the origin of
water using the ratios of helium-3 to helium-4, and helium-4 to neon-20, along with the
theoretical solubility of noble gases in water. Of the two sample volumes sealed on-site
(two sample volumes for each sampler at each depth), the first volume was initially
analyzed to get the best possible result for dissolved gas concentrations. The first
volume sealed had less time to equilibrate with the atmosphere after being removed
from the well and will therefore be more representative of the rn srtu dissolved gases.
Concentrations of dissolved gases are presented in Table 5.
An unusually high amount of helium-4 was present in the cell2 slimes drain
sample (sample TC2 SD). While some amount of helium4 would be present due to
uraniumthorium decay since construction of the cells, it is highly unlikely that the
majority of helium-4 seen in the sampte (9x10-6 ccSTP/g) is due to recent uranium-
thorium decay because of the extremely long half-life of the major isotopes of uranium.
lnstead, it is likely that the milling process has accelerated the release of helium that
accumulated within the sediment over geologic time.
Table 6 presents concentrations of measured total helium-4 and Rl/R", along with
29
calculated concentrations of terrigenic helium-4. R is the measured 3He/oHe ratio in a
sample and R" is the 3He/He ratio of a global air standard (1.384 X 10-6.) Thus, R/&
represents the 3He content of the sample and is the customary manner used to report
helium isotope measurements. To obtain the absolute concentration of 3He, the R/R"
value can be multiplied by R" (1.384 X 10-6) and the measured concentration of aHe.
Total helium-4 (4He1o1) is the total measured amount of helium-4 in the sample and is
representative of the amount of helium-4 dissolved in water. Terrigenic helium-4
(4He,",,) is calculated by subtracting the amount of helium-4 expected to be present in
water due to interaction with the atmosphere at the time of recharge from the measured
total helium-4 in water, assuming all other sources of helium-4 are negligible. The
helium-4 derived from atmospheric solubility is determined by combining estimates of
recharge temperature and elevation with laboratory measurements of the solubility. The
amount of atmospheric helium in excess of solubility (known as excess air).was
determined using neon measurements. Terrigenic helium-4 is helium-4 that is derived
from Uranium-Thorium series decay in the aquifer material and subsequently escapes
from the rock structure into the water via diffusion.
30
Table 5: ln situ Dissolved Gas Concentrations
Site Nz *Ar soKr 20Ne nHe ,rtxe
(ccSTP/o)(ccSTP/o)(ccSTP/q)(ccSTP/o)(ccSTP/o)(ccSTP/q)
MW-1 Shallow 1.69E-02 5.05E-04 6.37E-08 2.25E-07 6.12E-08 3.89E-09
MW-1 Deep 1.96E-02 5.66E-04 7.17E-08 2.53E-07 7.08E-08 4.57E-09
MW-2 Shallow 9.56E-03 2.64E-04 3.40E-08 1.28E-07 3.26E-08 2.25E-09
MW-2 Deep 1.19E-02 3.19E-04 4.20E-08 1.52E-07 4.15E-08 2.78E-09
MW-3 1.25E-O2 3.35E-04 4.24E-08 1.56E-07 3.98E-08 3.'10E-09
MW-3A Shallow 1.26E-02 3.48E-04 4.45E-08 1.66E-07 4.31E-08 2.71E-09
MW-3A Deep 1.38E-02 3.31E-04 3.88E-08 1.88E-07 4.96E-08 2.65E-09
MW-5 Shallow 1.68E-02 4.12E-04 5.27E-08 1.72E-07 4.80E-08 3.67E-09
MW-5 Deep 1.75E-02 3.99E-04 5.14E-08 1.81E-07 5.20E-08 3.43E-09
MW.11 Shallow 1.79E-02 4.67E-04 5.96E-08 2.27E-07 8.69E-08 3.63E-09
MW-11 Deep 2.05E-02 4.86E-04 6.05E-08 2.66E-07 1.05E-07 3.84E-09
MW-14 Shallow 1.41E-02 3.90E-04 4.93E-08 1.78E-07 4.34E-08 3.12E-09
MW-14 Deep 1.66E-02 4.40E-04 5.38E-08 2.18E-07 5.48E-08 3.36E-09
MW-15 Shallow 1.52E-02 4.06E-04 4.88E-08 1.92E-07 4.87E-08 2.86E-09
MW-15 Deep 1.63E-02 3.79E-04 4.40E-08 2.21E-07 6.58E-08 2.74E-09
MW.18 Shallow 1.81E-02 4.85E-04 5.92E-08 2.34E-07 6.96E-08 3.64E-09
MW-18 Deep 1.81E-02 5.32E-04 6.67E-08 2.28E-07 7.18E-08 3.95E-09
MW.19 Shallow 2.63E-02 7.16E-04 8.60E-08 3.56E-07 9.62E-08 4.70E-09
MW-19 Deep 2.72E-02 7.08E-04 8.42E-08 3.63E-07 9.44E-08 4.80E-09
MW-22 Shallow 1.20E-02 3.24E-04 4.01E-08 1.71E-07 4.89E-08 2.47E-09
MW-22b Deep 1.19E-02 3.24E-04 4.02E-08 1.66E-07 4.91E-08 2.52E-09
MW-22 Deep 1.22E-02 3.26E-04 4.14E-08 1.84E-07 5.68E-08 2.41E-09
MW-27 Shallow 1.04E-02 3.58E-04 5.32E-08 1.30E-07 3.33E-08 3.39E-09
MW-27 Deep 1.10E-02 3.69E-04 5.38E-08 1.37E-07 3.42E-08 3.36E-09
MW.29 Shallow 1.75E-02 3.49E-04 4.20E-08 2.52E-07 6.34E-08 2.76E-09
MW.29 Deep 2.01E-02 3.93E-04 4.52E-08 3.02E-O7 8.37E-08 2.84E-09
MW-30 Shallow 1.24E-02 3.62E-04 4.69E-08 1.55E-07 3.96E-08 2.94E-09
MW-30 Deep 1.35E-02 3.85E-04 4.94E-08 1.64E-07 4.11E-08 3.35E-09
MW.31 Shallow 1.48E-02 4.19E-04 5.60E-08 1.95E-07 6.16E-08 3.52E-09
MW-31 Deep 1.62E-02 4.48E-04 5.84E-08 2.12E-O7 6.53E-08 3.85E-09
TC1 1.66E-02 4.19E-04 9.49E-08 6.70E-08 2.73E-08 8.31E-09
TC2 SD 1.31E-02 7.32E-04 1.57E-07 7.85E-08 9.00E-06 2.80E-09
TC3 4.72E-03 2.84E-04 5.13E-08 5.86E-08 1.85E-08 6.35E-09wP21.45E-02 7.39E-04 1.50E-07 1.49E-07 3.46E-08 3.53E-08
WP3 7.50E-03 3.76E-04 7.05E-08 7.74E-08 1.70E-08 3.18E-08
31
able 6:m S
Site oHgr^,"Hg,--'Her^t R/Ra
(ccSTP/g)(ccSTP/g)(ccSTP/g)
MW-lshallow 7.65E-14 4.85E-09 6.12E-08 0.903
MW-1deep 8.55E-14 <1.0E-10 7.08E-08 0.872
MW-2shallow 4.46E-14 2.87E-09 3.26E-08 0.987
MW-2deep 5.42E-14 2.87E-09 4.15E-08 0.944
MW.3 5.46E-14 2.25E-10 3.98E-08 0.992
MW-3Ashallow 5.95E-14 4.03E-10 4.31E-08 0.999
MW-3Adeep 6.77E-14 <1.0E-10 4.96E-08 0.986
MW-5shallow 5.34E-14 5.64E-09 4.80E-08 0.805
MW-Sdeep 5.44E-14 6.91E-09 5,20E-08 0.757
MW-llshallow 7.14E-14 2.99E-08 8.69E-08 0.594
MW-11deep 8.49E-14 3.76E-08 1.05E-07 0.584
MW-l4shallow 5.87E-14 <1.0E-10 4.34E-08 0.979
MW-14deeo 7.18E-14 <1.0E-10 5.48E-08 0.946
MW-l5shallow 6.32E-14 <1.0E-10 4.87E-08 0.938
MW-1Sdeep 7.60E-14 7.05E-09 6.58E-08 0.835
MW-lSshallow 7.91E-14 1.07E-08 6.96E-08 0.821
MW-18deep 8.19E-14 1.64E-08 7.18E-08 0.824
MW-l9shallow 1.31E-13 7.44E-09 9.62E-08 0.989
MW-19deep 1.24E-13 4.07E-09 9.44E-08 0.952
MW-22shallow 6.82E-14 4.01E-09 4.89E-08 1.007
MW-22(b)deep 6.81E-14 5.95E-09 5.68E-08 0.965
MW-22deep 7.58E-14 5.25E-09 4.91E-08 1.003
MW-2Tshallow 4.74E-14 1.32E-09 3.33E-08 1.029
MW-27deep 4.76E-14 1.32E-09 3.42E-08 1.006
MW-29shallow 8.58E-14 <1.0E-10 6.34E-08 0.978
MW-29deep 1.14E-13 <1 .0E-10 8.37E-08 0.991
MW-30shallow 5.55E-14 5.26E-10 4.1 1E-08 1.013
MW-3Odeeo 5.37E-14 3.37E-10 3.96E-08 0.9M
MW-3lshallow 6.58E-14 1.30E-08 6.16E-08 o.773
MW-31deeo 7.59E-14 1.24E-08 6.53E-08 0.840
TC1 3.35E-14 1.26E-08 2.73E-08 0.887
TC2 Slimes Drain 1.96E-14 8.96E-06 9.00E-06 0.002
TC3 2.17E-l4 6.42E-09 1.85E-08 0.853
wP2 4.72E-14 <1.0E-10 3.46E-08 0.987
WP3 2.26E-14 2.99E-09 1.7E-08 0.963
of Helium Concentration
ln general, higher concentrations of helium-4 indicate older water relative to
waters with lower concentrations of helium-4. High terrigenic helium-4 values are
expected in waters that have been in contact with aquifer material for longer periods of
time as these waters will have had more time to accumulate helium-4 derived from
sediment and rocks thru the in-growth of progeny from the Uranium and Thorium decay
series. Rl/R" values greater than one may be an indication of tritiogenic helium-3 in the
32
water. Because helium-3 is the daughter product of tritium decay, water that contained
tritium at one point in time will exhibit relatively higher concentrations of helium-3 than
water that did not contain tritium. R/R" of less than one may be indicative of an
accumulation of terrigenic helium-4 in the water being sampled.
Measurable amounts of tritium in MW-19 shallow and deep, MW-22 deep, and
MW-27 suggest the presence of younger water mixing with older groundwater (see
Table 4, above). Additionally, the proximity of MW-19 and MW-21to the northern
wildlife ponds supports the possibility of young water mixing with older groundwater in
those wells. Tritium would be expected in water that is recharging from ponds that were
constructed within the last 15 years, and this tritium is now observable in MW-19 and
MW-27.
MW-30 shallow exhibited an Rl/R, value greater than one, suggesting a small
amount of tritiogenic 3He near the top of the water column (see Tables 4 and 6). MW-
19.deep had a tritium concentration of nearly 4ru, but exhibited an R/R"e value less
than one (compare Tables 4 and 6). This is likely the result of a small amount of
tritiogenic 3He with a larger amount of terrigenic aHe. Excluding MW-1g shallow, which
also had an Rl/R, less than one, other samples that contained tritium exhibited R/R"
values greater than one. This is expected from the decay of tritium to helium-3,
increasing the ratio of helium-3 to helium-4 to a value greater than that of the
atmosphere. Thus, some samples near the wildlife ponds have helium isotope values
that are consistent with transport of young water being recharged at the ponds [e.g.,
MW-27 (shallow and deep) and MW-30 (shallow)]. With the exception of MW-22, the
remainder of samples exhibited R/R" values less than one, indicating helium-3 was
33
proportionally lower, or helium-4 was proportionally higher to that of the atmosphere.
Evaluating the contribution of various sources for helium-3 and helium-4 inputs
can be accomplished by plotting the following:
t He,o,-'Hern
o He,o,-oHeuu
4 H€.,ot*'
^ H"^ jH%
where'He,o, is the measured total helium-3 in the sample, 'He.o is the excess air
component of helium-3 in the sample, oH",o, is the measured total helium-4 in the
sample, 4He.o is the equilibrium solubility of helium-4 in the sample, and aHeen is the
excess air component of helium-4 in the sample (Solomon, 2000). Excess air results
when the water table rises and traps small amounts of the soil atmosphere as bubbles
that are now below the water table. Due to the increased fluid pressure that now exists
on these bubbles, they partially or completely dissolve thereby imparting extra gas
above thermodynamic equilibrium. The solubility component of helium is determined by
using estimates of the temperature and elevation at which the water sample recharged
combined with laboratory measurements of solubility. lf there was no helium-4 input
from excess air or from alpha-decay in the subsurface (i.e. decay from uranium-238,
thorium-236, radium- 226, radon-222, etc.), the left-hand side of the equation would
simply be the helium-3/helium-4 ratio observed in the atmosphere, or 1.384 x 10-6. The
right-hand side of the equation, or the fraction of atmospheric helium-4, in this case
would be 1.
Table 7: E
Note:Bold-facedtypeindicatessampleswithex
that of atmospheric. Excess air corrections are not needed for the surface water siteslseeprevious discussion regarding the formation of excess air.)
The amount of helium-3 in the sampre due to excess air input (3Hes,q) was
calculated using the ratio in the sample of helium-3 to neon-2O multiplied by the
difference of the measured neon-20 in the sample and the theoretical solubility of neon-
: Excess air-corrected helium ratiOS
Site 'H",o,tH"ro nH"=o 4Hg=ot oH",o,("He1o1-"Hesj/
(oHer^,-aHe.^i
'Hesol/
(4He.^.-4He.^)
(ccSTP/o)(ccSTP/q)(ccSTP/o)(ccSTP/o)(ccSTP/o)
MW-lshallow 8.55E-14 3.90E-14 2.82E-08 3.94E-08 7.08E-08 1.09E-06 9.24E-01MW-1deeo 7.65E-14 2.66E-14 1.92E-08 3.94E-08 6.12E-08 1.19E-06 9.38E-01MW-2shallow 5.42E-14 1.93E-15 1.39E-09 3.73E-08 4.15E-08 1.30E-06 9.29E-01MW-2deeo 4.46E-14 0.00E+00 0.00E+00 3.60E-08 3.26E-08 1.37E-06 1.00E+00
MW.3 5.46E-14 2.87E-15 2.07E-09 3.76E-08 3.98E-08 1.37E-06 9.98E-01MW-3Ashallow 6.77E-14 2.01E-14 1.45E-08 3.67E-08 4.96E-08 1.36E-06 1.00E+00MW-3Adeeo 5.96E-14 7.64E-15 5.52E-09 3.75E-08 4.31E-08 1.38E-06 9.97E-0'1MW-5shallow 5.45E-14 9.63E-15 6.96E-09 3.87E-08 5.20E-08 9.95E-07 8.60E-01MW-Sdeeo 5.35E-14 4.66E-15 3.37E-09 3.91E-08 4.80E-08 1.09E-06 8.76E-01MW-l lshallow 8.50E-14 4.48E-14 3.24E-08 3.93E-08 1.05E-07 5.52E-07 5.41E-01MW-11deeo 7.14E-14 2.80E-14 2.03E-08 3.92E-08 8.69E-08 6.51E-07 5.89E-01MW-l4shallow 7j8E-14 2.96E-14 2.14E 08 3.77E-08 5.48E-08 't.26E-06 1.00E+00MW-14deeo 5.88E-14 1.16E-14 8.41E-09 3.78E-08 4.34E-08 1.35E-06 1.00E+00MW-l5shallow 7.61E-14 3.23E-14 2.33E-08 3.73E-08 6.58E-08 1.03E-06 8.78E-01MW-1Sdeeo 6.32E-14 1.72E-14 1.24E-08 3.80E-08 4.87E-08 1.27E-06 1.00E+00MW-lSshallow 8.19E-14 2.80E-14 2.03E-08 3.94E-08 7.18E-08 1.05E-06 7.64E-01MW-18deeo 7.91E-14 3.08E-14 2.22E-08 3.93E-08 6.96E-08 1.02E-06 8.29E-01MW-l9shallow 1.24E-13 8.74E-14 6.32E-08 3.92E-08 9.44E-08 1.18E-06 '1.00E+00
MW-19deep 1.32E-13 8.56E-14 6.19E-08 3.89E-08 9.62E-08 1.34E-06 1.00E+00MW-22shallow 7.58E-14 1.79E-14 1.29E-08 3.68E-08 5.68E-08 1.32E-06 8.39E-01MW-22deeo 6.82E-14 9.33E-15 6.74E-09 3.69E-08 4.91E-08 1.39E-06 8.72E-01MW-22deeo(b)6.82E-14 1.40E-14 1.01E-08 3.64E-08 4.89E-08 1.40E-06 9.36E-01MW-2Tshallow 4.76E-14 0.00E+00 0.00E+00 3.80E-08 3.42E-08 1.39E-06 1.00E+00MW-27deeo 4.74E-14 0.00E+00 0.00E+00 3.77E-08 3.33E.09 1.42E46 1.00E+00MW-29shallow 1.15E-13 6.97E-14 5.04E-08 3.68E-08 8.37E-08 1.35E-06 1.00E+00MW-29deep 8.58E-14 4.76E-14 3.44E-08 3.67E-08 6.34E-08 '1.32E-06 1.00E+00MW-30shallow 5.38E-14 3.26E-15 2.36E-09 3.85E-08 4.1 1E-08 1.30E-06 9.91E-01MW-30deep 5.55E-14 1.09E-15 7.88E-10 3.79E-08 3.96E-08 1.40E-06 9.77E-01MW-3lshallow 7.59E-14 2.13E-14 1.54E-08 3.93E-08 6.53E-08 1.09E-06 7.88E-01MW-31deep 6.58E-14 1.55E-14 1.12E-08 3.89E-08 6.16E-08 1.00E-06 7.72E-01Tailinqs Cell 1 3.35E-14 0.00E+00 0.00E+00 4.11E-08 2.73E-08 1.23E-06 1.00E+00Tailings Cell2
Slimes Drain 1.97E-14 0.00E+00 0.00E+00 4.1 1E-08 9.00E-06 2.19E-09 4.57E-03Tailinqs Cell 3 2.18E-14 0.00E+00 0.00E+00 4.1 1E-08 1.85E-08 1.18E-06 1.00E+00Wildlife Pond 2 4.73E-14 0.00E+00 0.00E+00 4.33E-08 3.46E-08 1.37E-06 1.00E+00Wildlife Pond 3 2.26E-14 0.00E+00 0.00E+00 4.33E-08 1.70E-08 1.33E-06 1.00E+00
Atmospheric lelium 1.37E-06 1
35
20. The calculation was conducted as follows:
^ "y'^ *"*
('o N" ^"^ -'o Ne "o'Yt' "'u
where R13He/20Ne) is determined as the ratio of helium-3 to neon-20 in the atmosphere,
'oN"r"", is the measured amount Of 20Ne in the sampte, and 2oNe.or is the expected
solubility of neon in the water. Neon is useful in this calculation because the ratio of
neon-2g to helium-3 in the atmosphere is constant. Furthermore, the expected solubility
of neon is only a weak function of the temperature and salinity of the water.
Helium-4 dissolved in the sample due to excess air input was calculated in much
the same way as helium-3 due to excess air, but with the ratio of helium-4 to neon-20 in
the atmosphere only. lt was conducted as follows:
R o ,- / * ('o N" ,"o" -'o Ne ,o,Yo ," ,n
/)oN"
where R14He/2oNe) is the ratio of helium-4 to neon-2O in the atmosphere, 20Ner"", is the
measured amount of 20Ne in the sample, and 2oNe.or is the expected solubility of neon in
the water.
The expected solubility of helium-4 in the sample, 4He.or, is calculated based on
the salinity and temperature of the well water at the time of the sample. Lastly, the total
amount of helium-4 in the sample, oH",o,, is the total amount of helium-4 in the sample
measured in the laboratory.
The helium-3/helium-4 ratio of He produced in Earth's crust is lower than the ratio in
the atmosphere (Solomon, 2000.) Therefore, as a parcel of water moves through the
aquifer and acquires helium generated within the aquifer, both the helium-3ihelium-4
ratio and the fraction of helium-4 derived from atmospheric equilibration will decline.
Figure 19 plots the above helium isotope relationships for monitoring wells at the Mill.
Samples from MW-11 plot at one end of the graph as they contain the largest amounts
of terrigenic helium and thus contain the largest components of old water. Figure 20
plots the above helium isotope relationships for surface water sites (tailings cells and
wildlife ponds) at the Mill.
r
Isotope Ratios of Helium - Monitoring Wells
1.6E46
1.4E-06
1.2E-06
1.0E-06
8.0E-07
6.0E-07
4.0E47
2.0E-07
0.0E+00
0.6 0.8
aHe"ol/1aHe,o"oHe.o)
+ Monitoring Wells o Rtro"ltoric Hffi
Figure 19: Helium isotope ratios, corrected for input due to excess air; monitoring wells only
?uror*.
ooIt
?lr.to
oo
1.21.0
+
+*++
+{++++
+,+
+ MW-11 shallow
helium
+
MW-11 deep
37
lsotope Ratios of Helium 'Surface Water Sites
?
UJo
I*,
oo!3
?uto
I
oo
1.6E-06
1.4E-06
1.2E-06
1.0E-06
8.0E-07
6.0E.07
4.0E-07
2.0E-07
0.0E+00
:\
Atmospheric helium
TC 2 Slimes Drain
0.6
aHe"ol/1aHe1o"oH"=o)
Figure 20: Helium isotope ratios, corrected for input due to excess air; surface water sites only
C. Anions
Nitrate and Nitrite levels as nitrogen, and sulfate levels in water samples were
analyzed by the Utah State Department of Health, Division of Laboratory Services. The
Utah groundwater quality standard (GWOS) of 10 mg L-1 was exceeded by wells MW-30
and MW-31 (UAC R317-6-2).
Sulfate concentrations can be compared with the National Secondary Drinking
Water Regulation, as set by the United States Environmental Protection Agency
(USEpA, 2003), at 250 mg L-1 sulfate in a community water system. This concentration
was exceeded by all monitoring wells except MW-27. This value was also greatly
exceeded by the tailings cells and Cell2 slimes drain. No GWQS or site-specific
groundwater protection limit (GWPL) is currently in effect for sulfate concentrations.
0.40.20.0
f- friling. Cells o Wildlife Ponds x Atmospheric Helium
Table 8 presents the concentrations of inorganic constituents in monitoring wells and
surface water sites.
Table 8: Concentrations of Anions
Site NO2+NO3, N Sulfate
(mq/L)(mq/L)
MW.O1 0.35 644
MW-O1B 0.25 708
MW-02 <0.1 1.780
MW-03 0.19 2,960
MW-O3A 1.07 3,070
MW.O5 <0.1 980
MW-11 <0.1 947
MW-14 Shallow <0.1 2.120
MW-14 Deep <0.1 2.050
MW-15 0.13 2,200
MW-18 Shallow 0.36 1,690
MW-18 Deep <0.1 1,810
MW-19 Shallow 2.62 556
MW-19 Deeo 2.69 581
MW-22 Shallow 3.36 5,060
MW-22 Deep 3.24 5,100
MW-27 5.46 52.1
MW.29 0.79 2,830
MW-30 15.5 859
MW-31 24.6 598
TC1 113 2.500.000
TC2 Slimes Drain 5.19 666.000
TC3 19.6 107,000
wP2 <0.1 39.9
WP3 <0.1 33.1
Eouioment Blank <0.1 <20.0
Note: Bold-faced type indicates samples that exceedeO the stbte Gt/VeS
D. Trace Metals
Concentrations of manganese, selenium, and uranium in groundwater samples
and surface water samples were analyzed by the Utah State Department of Health,
Division of Laboratory Services. Uranium concentrations exceeded the Utah State
GWQS of 30 pg L-1 in 8 of the monitoring wells, and in all three tailings cells (UAC
R317-6-2). MW-3, both depths sampled at MW-14, MW-15, both depths sampled at
MW-18, and both depths sampled atMW-22 had uranium concentrations greater than
39
30 pg L-1.
Concentrations of manganese exceeded the ad-hoc groundwater quality
standard of 800 pg L-1 as put forth in the Groundwater Discharge Permit for
lnternational Uranium (USA) Corporation, now Denison Mines, Co., in 7 monitoring well
samples (Utah Water Quality Board). Wells MW-3, MW-3A, both depths sampled at
MW-14, both depths sampled at MW-18, both depths sampled atMW-22,and MW-29
had concentrations greater than 800 Ug L-1. The equipment blank likely exhibits a
presence of manganese because it was taken after decontamination of the pump
following sampling MW-22, the wellwith highest manganese concentrations. Residual
manganese in the pump tubing following MW-22 sampling thus may have been present
in the equipment blank samPle.
Only MW-3A, MW-15, and MW-31 had concentrations of selenium that exceeded
the State GWQS of 50 pg L-1 set forth by the Utah Division of Water Quality (UAC
R317-6-2). Tailings cell 3 was reported to have a selenium concentration of 1550 pg L-
1, while the sample from cell 2 Slimes Drain was reported only as having a
concentration of selenium less than 400 pg L-1. Trace metal concentrations are
presented in Table 9.
40
Table 9: Trace Metal Concentrations
Site Selenium (uq/L)Manqanese (uo/L)"6u (uq/L)
MW-o1 <2.0 78.8 <1.0
MW-O1B <2.0 115 <1.0
MW.O2 8.7 <10.0 10.5
MW-03 10.2 2,460 35.9
MW-O3A 74.2 1,360 19.9
MW.O5 2.42 190 <1.0
MW-11 <2.0 64.7 <1.0
MW-14 Shallow <2.0 2,080 59.4
MW-14 Deeo <2.0 2,020 59.4
MW-15 96.4 <10.0 42.9
MW-18 Shallow 2.5 84 41.2
MW-'18 Deeo 2.3 202 33.3
MW-19 Shallow 10.4 <10 6.94
MW-19 Deep 10.4 <10.0 7.68
MW-22 Shallow 15.2 32.900 38.8
MW-22 Deeo 15.3 35,500 39.7
MW-27 10.1 <10.0 29.5
MW-29 3.35 5,100 10.2
MW-30 32.6 <10.0 6.31
MW-31 58.7 <10.0 7.O1
TC1 16.200 869.000 581.000
TC2 Slimes Drain <400.0 139.000 23.700
TC3 1.550 248,000 68,100
wP2 <2.0 17 9.92
WP3 <2.0 16.2 <1.0
Equioment Blank <2.0 31.5 <1.0Note:bold-facedtypeindicatessamplesthatexceerd(GWQS)
or, in the case of manganese, the ad-hoc GWQS
E. D and 18O lsotope Ratios in Water
Deuterium and oxygen-18 can be used as environmental tracers of groundwater
because they are part of the water molecule and have a conservative nature.
Enrichment of deuterium and oxygen-18 (i.e. isotopically heavier) may indicate
significant evaporation is occurring at the recharge point, while depletion of deuterium
and oxygen-18 (i,e. isotopically lighter) may indicate groundwater recharge is occurring
at higher elevations and lower temperatures. Enriched values are less negative and
represent a relatively heavier isotopic composition, while depleted values are more
negative and represent a relatively lighter isotopic composition. Groundwater and
41
surface water samples were analyzed for deuterium and oxygen-18 isotope ratios, the
results of which are presented in Table 10 below.
18oTable 10: 6D and 6 ratios in water
Site Depth 6D (7oo)6D o (t7oo)6'o0 (%o)6'o0 o 1f/*;
MW-o1 -1 13 1.6 -14.8 0.13
MW.O1B -113 0.3 -14.3 0.02
MW-02 -1 13 0.5 -14.2 0.01
MW-o3 -106 1.0 -13.2 0.16
MW-O3A -107 1.4 -13.3 0.19
MW.O5 -112 2.3 -14.1 0.03
MW-11 -1 15 0.3 -15.6 0.04
MW.14 shallow -1 10 0.0 -13.8 0.05
MW-14 deep -112 0.5 -13.9 0.03
MW.15 -111 0.5 -14.0 0.09
MW-22 shallow -1 10 1.7 -13.5 0.23
MW-22 deep -107 0.2 -13.2 0.05
MW-27 -&3 0.5 -9.8 0.07
MW-29 -107 2.0 -13.3 0.00
MW-30 -95 0.3 -11.7 0.09
MW-31 -95 1.1 -11.9 0.22
MW-18 shallow -103 1.7 -13.7 0.05
MW-18 deep -107 2.1 -13.9 0.18
MW.19 shallow -81 1.5 -9.6 0.05
MW-19 deep -81 2.0 -9.5 0.04
wP2 -45 1.9 -1.3 0.15
WP3 -60 0.3 -5.3 0.14
TC1
TC2 Slimes
Drain
TC3 -12 7.9 4.9 o.92
trg1rcg
Note: isotope ratios are carcutated as 0"o,o,,,, =( ,\:r'?,::?)*'" - rl- roooz,ovsMow, where'Pte llt'ol'uo),",",",," )
VSMOW is the name of the reference.
lsotope ratios for deuterium relative to the standard VSMOW for monitoring wells
ranged from -1 15%o to -8170o. The highest values of -81%o and -8370o were found in
wells MW-19 at both depths and MW-27, respectively. Wildlife ponds 2 and 3 showed
deuterium isotope ratios of -45oho and -60%0, respectively. Tailings cell 3 had a
deuterium isotope ratio of -12oloo.
lsotope ratios for oxygen-18 relative to the standard VSMOW for monitoring wells
ranged from -15.6%o to -9.5%0. The highest values of -9.67o0, -9.5%o, ?nd -g.8yoo wer€
found in MW-19 shallow, MW-19 deep, and MW-27, respectively. Wildlife ponds 2 and
3 had oxygen-18 isotope ratios of -1.3%o and -5.3%o, respectively. Tailings cell 3 had an
oxygen-18 isotope ratio of 4.9o/oo.
Tailings cell 1 and cell2 slimes drain were not analyzed by the contract laboratory
because of damage that could have been incurred upon the laboratory equipment due
to the low-pH of the wastewater collected.
Figure 21 plots the deuterium and oxygen-18 isotope ratios for each sample site.
Figure 22 plots the regressed isotope ratio data along with the Global Meteoric Water
Line after Craig (1961) and the Utah Meteoric Water Line after Kendal and Coplen
(2001).
6D & 6180 isotope ratios of water
20
0
-20
-40
I -60
_80
-100
-120
-'t40
. TC3
MW-31
'\" "r)-€'w-1e (deep & sharrow), Mw-27
MW-30
-20.0 -15.0 10.0-10.0 -5.0
618o
Figure 21: 6D and 6180 isotope ratios of water
43
6D & 61EO isotope ratios of water
20
0
-20
40
B -60
-80
-100
-120
-140
-10
___.UMWL
-5
618
-
Surface Sites o Wells
""" Monitoring Wells (Regressed. Surface Sites
Figure 22: anddlsO isotope ratios of water, regressed d-Deuterium vs. 6180 data with Global Meteoric
Water Line and Utah Meteoric Water Line
The monitoring wells plot along a line of similar slope to the Utah (local) meteoric
water line, but offset slightly. The surface water sites plot along a line with a slope one
might expect to see in evaporated waters. Wells MW-19 (shallow and deep) , MW'27 ,
MW-30, and MW-31 have enriched (more positive) values for 6180 and plot along the
evaporation line suggesting that these wells have been influenced by evaporated
surface water from the wildlife ponds. Nevertheless, the 6D values for evaporated
versus meteoric water for these wells is small suggesting the presence of non-
evaporated background water (i.e. a mixture of pond and background water.) Well MW-
11 does not show an evaporated signal suggesting that neither pond water or leakage
from tailing cells is present at this well today.
Monitoring wells MW-3, MW-3A, MW-14 (shallow and deep), MW-15, MW-18
(shallow and deep), and MW-22 (shallow and deep) have more depleted 6180. These
wells have elevated uranium concentrations, but as they do not bear an evaporated
44
stable isotope signal it does not appear that the elevated uranium values are the result
of leakage from tailing cells (or wildlife ponds.)
F. 34S and 18O lsotope Ratios in Sulfate
Sampled wells and surface water sites were analyzed for isotope ratios of 34S/32S
and 180/160 as sulfur-34 and oxygen-18 in the dissolved sulfate molecule. These
isotope ratios can be used in fingerprinting waters of a common source, i.e. if leakage
from tailings cells were occurring, wells impacted by leakage might have similar isotopic
fingerprints of sS and 18O as the tailings cells wastewater. Conversely, if no leakage
from tailings cells were occurring, wells might have significanfly different isotopic
fingerprints of 3aS and 18O as compared to the tailings cells. This is because of
fractionation processes occurring in the ore refining process, and the use of sulfuric acid
from an outside source in ore refinement. Furthermore, evaporation from the surface
water sites would preferentially fractionate for oxygen-18 over oxygen-16, meaning the
residual solution would become enriched in oxygen-18. This means that if isotopic
ratios are different between wells and surface water sites, it is expected that surface
water sites would have enriched (e.g. isotopically heavier) isotopic ratios of oxygen-1g
relative to well waters. Table 11 shows analytical results for 3aS and 18O isotope ratios
as they pertain to the sulfate ions in solution.
45
T 3as and 18o i ratios ofable 11: ""S SU
Site 6180 - sor (%o)634s - so, (%o)
MW-1 -2.36 9.17
MW.1B -2.22 9.88
MW-2 -8.59 12.13
MW-3 -7.03 13.69
MW.3A -6.69 12.66
MW-5 -3.93 9.55
MW-11 -5.08 9.34
MW-14 -2.69 9.63
MW-14 -1.81 9.86
MW-15 -4.61 9.07
MW.18 -4.03 5.05
MW.18 -3.63 5.23
MW.19 -4.08 7.40
MW-19 -4.88 7.27
MW-22 -9,99 -2.44
MW-22 -10.27 -3.07
MW-27 2.02 -0.20
MW-29 -5.58 9.73
MW-30 -3.31 11.O4
MW-31 -2.18 6.39
TC1 3.97 -0.89
TC2 Slimes
Drain 4.58 -0.93
TC3 4.34 -1.04
wP2 4.52 0.90
WP3 3.15 0.19
t+ g 1t+
Note: isotope ratios are catculated as d3as,,o ( ("sl"s| ampte - -rl* tooox, . The reference," =lpT/.^iE-r*- t
)'
twv/oo ' '|1'|8I
standard is Canyon Diablo Troilite having a *Sf'S ratio of 0.04500451.
lsotope ratios for 18O of sulfate ranged from -10.30/oo to -1.8%o in monitoring wells'
Wildlife ponds 2 and 3 had positive 18O isotope ratios of 4.5700 and 3.170o, respectively.
Ratios in tailings cell 1, Cell2 slimes drain, and tailings cell 3 were also positive at
3.9%0, 4.So/oo,and 4.37o0, respectively. tos isotope ratios ranged from -3.0o/oo to 13.67oo in
monitoring wells. Wildlife ponds 2 and 3 had 3aS isotope ratios of 0.97oo and 0'19%0,
respectively. *S isotope ratios in tailings cell 1, Cell 2 slimes drain, and tailings cell 3
were -0.89o/oo, -0.92o/oo, ond -1.04o1oo, respectively'
6sS & 6180 lsotope ratios of Sulfate
16.00
14.00
12.00
10.00
8.00
6.00
4.00
2.00
0.00
-2.00
-4.00
-12.0O -10.00 -8,00 6.00 4.00 -2.0O
6"0 g-;
Figure 23 shows the results of analyses done at the University of Waterloo
Environmental lsotope Laboratory for 3aS and 18O isotope ratios in sulfate. Several
distinct relationships are apparent. The surface water sites (wildlife ponds and tailings
cells) are heavily enriched in 18O, and yet depleted in sS relative to monitoring wells.
This is likely due to evaporative fractionation of lighter water molecules, causing
enrichment of heavier water molecules in the ponds, and subsequent enrichment of
oxygen-18. MW-27 is also similar in isotopic composition to the surface water sites.
This suggests groundwater there has been influenced by the wildlife ponds found
directly upgradient.
Most monitoring well sites exhibit a slight depletion of oxygen-18 with significant
enrichment of sulfur-34. Both sampling depths for MW-22 exhibited 3aS isotope ratios
similar to surface water sites, but 18O-SO+ is distinct from the surface water sites. This
ESo
tO
4.00
MW-31.. MW-15 MW-14 shallow
'
--'
' .1 MW-14 deep
aa
F MW-18 shalow and deep
/**-22
shattow and deep ,'**-rr/
tro
xxX
47
may be explained by a recharge of surface water that isn't evaporated. Wells MW-3,
MW-14 shallow and deep, MW-15, and MW-18 all exhibited elevated concentrations of
uranium, but are isotopically distinct from the surface water sites.
6sS vs. SO4 Goncentration
15.00
13.00
11.00
9.00
7.00
5.00
3.00
1.00
-1.00
-3.00
-5.00
o.
\,*-,,
r<-MW-3
o
<r-MW-14 shallow and deep
.ta
a)\r*-,u
18 shallow and deeP
a
U'
r,
o
MW-
Mw-22 shallow and deeP6)
1 000
SOa Concentration (mg L'l)
o Monitorirg Wells a Wildlife Ponds
Figure 24 presents sulfate concentration versus the sS isotopic ratios for each
site. Because of extremely high sulfate levels in the tailings cells and Cell2 slimes
drain, those points are not included in Figure 24. Figure 25 below presents the log of
sulfate concentration versus the 34S isotopic ratios on the sulfate ions for each site.
Figure 24:'asisotope ratios ofSulfate vs. dissolved SOr Concentration
48
:s
art
ro
,. c*
: \*-ro shauow and deep; MW-15
MW-22 shallow and deep
,/d
1000 10000
loglSOl (mg/L)I
OMonitoring Wells XTailings Cells oWildlife Ponds
16.00
14.00
12.O0
10.00
8.00
6.00
4.00
2.O0
0.00
-2.00
4.00
6sS vs. log of SOa Concentration
MW-3\f
ro
a
Xx\r*_r,
6180 vs. SOn Concentration
tt
aqO
O1
o
ooo
MW-22 shallow and deeo
\\o
aa
6.00
4.00
2.00
0.00
-2.00
4.00
-6.00
-8.00
-10.00
-12.00
IoPb
Figure 25: sS isotope ratios of Sulfate vs. log dissolved SOa concentration
Figure 26: 18O isotope ratios of Sulfate vs. dissolved SO4 concentration
Figure 26 relates the oxygen-18 isotope ratios to the dissolved sulfate
concentration for each of the sample sites. A very general inverse correlation between
increasing sulfate concentrations and oxygen-18 depletion is seen. MW-27 exhibits an
isotopic fingerprint very similar to that of the wildlife ponds, as well as similar sulfate
concentrations. MW-22 is anomalous in that it exhibits a significantly more depleted
6sS value but has elevated sulfate. However, because of its location it is unlikely MW-
22 is being influenced by similar aspects of the groundwater system as the other
monitoring wells.
Figure 27: 18O-SO+ isotope ratios of sulfate vs. log of dissolved sulfate concentration
Figure 27 plots oxygen-18 isotope ratios of sulfate to the log of sulfate
concentrations for each of the sample sites in order to include tailings cells. ln this case
the tailings cell wastewater is seen to exhibit both an enriched 18O signature and
extremely high sulfate content.
6"0 vs. log of SO4 concentration
6.00
4.00
2.00
0.00
-2.00
4.00
6.00
-8.00
-10.00
-'r2.00
tr
o
xx x
Eo
l.)
o v_ MW-14 shallow and deep\rrrw-zz //r0
ata
lMonitoring Wells yTailings cells gWildlife Ponds
,, MW-22 shallow and deep
Mw.z/ O
1000 10000
loglS04 (ms/L)I
50
V. DISCUSSION
Most groundwater samples from the Mill contain significant amounts of terrigenic
helium-4, indicative of older waters. Several samples have tritiogenic helium-3,
indicative of young water, however these are only found in areas influenced by the
wildlife ponds (MW-19, and MW-27). Tritiated water is introduced into the system by
recharge from the wildlife ponds and appears in wells around the wildlife ponds. As
recharge water from the wildlife ponds propagates through the system, evidence of
tritiated water will appear in successive monitoring welts further from the ponds.
Wells MW-19 (both sample depths) and MW-27 exhibited the most enriched
(heaviest) 6D/6180 isotopic signatures of all the monitoring well samples. This can likely
be attributed to the water table mounding that is occurring because of the nearby wildlife
ponds. Water that is isotopically enriched due to evaporation, the wildlife ponds, when
mixed with water that is isotopically depleted, groundwater, would produce an isotopic
fingerprint that is isotopically heavier than that of groundwater but isotopically lighter
than that of surface water. That the isotopic signatures of MW-19 and MW-27 are being
influenced by recharge from the wildlife ponds is also supported by the elevated tritium
concentrations in both wells. Significant amounts of tritium in MW-19 and MW-27
suggest younger water, and because of only modest amounts of precipitation, recharge
is likely to mostly be occurring from the nearby wildlife ponds.
The influence of evaporated isotopic signatures is most prominent in MW-19 and
MW-27,but is not evident in wells immediately down-gradient from MW-1g and MW-27,
such as MW-30 and MW-31. This suggests the southern margin of artificial recharge
due to the wildlife ponds, and the southernmost extent of the water table mound, is
51
likely between MW-27, and MW-30 and MW-31. Furthermore, mixing of the evaporated
isotopic signatures with groundwater in MW-18 is not apparent, suggesting that the
northern extent of the water table mound is likely between MW-19 and MW-18.
Because of the consistent similarities seen in 63aS values, 6180 values, and
sulfate concentrations between MW-27 and the wildlife ponds, it is likely that water in
MW-27 has its origin in the wildlife ponds. Furthermore, young water as evidenced by
the presence of tritium in MW-27 indicates a tritiated recharge source, whereas tritium-
free waters in the majority of the other monitoring wells indicates a recharge source
composed of older water. Tritiated waters from the wildlife ponds that are likely
recharging the aquifer system would show similar isotopic signatures between the
monitoring wells and the wildlife ponds, as is seen in analytical data. This strongly
suggests the influence of recharge from the wildlife ponds is propagating through the
aquifer and has, to date, reached downgradient at least as far as MW-27.
Potential causes of similarities in sulfur isotope ratios between the wildlife ponds
and tailings cells include: eolian transport of aerosols from the tailings cells, surface
runoff from the Mill facility, and/or rainout of sulfuric acid released to the atmosphere
from the Mill. When compared with isotope fingerprints observed in the tailings cells,
fingerprints of monitoring wells exhibit strong differences, with the exception of MW-27.
This suggests that elevated concentrations of trace metals seen in wells down-gradient
of the facility are not being caused by tailings cell leakage.
The uniqueness of the stable isotope fingerprints of the tailings cells provide a
valuable tool in monitoring groundwater wells for evidence of leakage from the tailings
cells. Because of the extremely high concentrations of sulfate in the tailings cells, even
52
small amounts leakage could dramatically alter the isotopic signature of the monitoring
wells, evidence that would appear much earlier than elevated trace metal
concentrations. For example, consider a mixture of 2 mL of water from a tailing cell
having a 63aS value of -1.0 %o and a SO+ concentration of 1,000,000 mg/L with 998 mL
of background water having a 63aS value of 8.0 %o and a SO+ concentration of 1,800
mg/L. The mixture would have a SOa concentration of 3,800 mg/L and 63aS value of 3.3
%o. The change in SO+ concentration from 1,800 to 3,800 mg/L would be difficult to
attribute to leakage from tailings cells as the SOa concentrations in background water
varies from less than 1,000 mg/L to more than 5,000 mg/L. However, a change in 6sS
value from 8.0 %o to 3.3 %o could identify the tailings as the source of contamination.
However, the stable isotope fingerprints of the tailings cells are very similar to that
of the wildlife ponds. This may pose a problem for using stable isotopes of sulfate in the
future. As the wildlife ponds continue to recharge the groundwater system, the isotopic
fingerprint they bear will also be introduced into the aquifer. lt is likely that eventually
the entire groundwater system will bear an isotopic fingerprint similar to that of both the
tailings cells and wildlife ponds, rendering 63aS and 6180 on sulfate irrelevant for
detecting tailings cell leakage.
. ln a letter dated 31 January 2008 from Denison Mines (USA) Corp. to the
Executive Secretary of the Utah Radiation Control Board, Mr. David Frydenlund, the
Vice President of Regulatory Affairs Counsel, stated that several areas of low ground on
the Mill site may have had an effect on the isotopic signature of sulfur-34 from sulfate in
MW-27. He states that while the site is graded such that surface water runoff drains
toward Tailings Cell 1, two areas up-gradient of MW-27 have historically experienced
53
water pooling to six inches deep after heavy rains. This water is a combination of direct
precipitation and runoff from the northern portion of the mill area. This area of the Mill
site has since been re-graded to remedy this issue. Although, it is possible that such
water may have infiltrated through the vadose zone and recharged the saturated zone,
this is a relatively small area and it seems unlikely that such an ephemeral head source
could produce the isotopic signature observed in MW-27. More investigation is needed
to better understand the occurrence of young water in the vicinity of MW-27.
Mr. Frydenlund also suggested that historical stock watering ponds up-gradient
of M\N-22 may have influenced the isotopic signature of sulfur-34 of sulfate and the
presence of tritium in that well. Reportedly, these stock watering ponds were used
during spring and fall from the early 1980s to 2001, but water was not maintained in the
ponds for the entire year. The ponds were not utilized between 2001 and 2005, and
were filled once between 2005 and 2006. Because the water used to fill the ponds from
the 1980s to 2001 was pumped from the deep Entrada/Navajo aquifer, it is unlikely
these waters were tritiated, though some tritium input may have occurred due to
precipitation. Additionally, water used to fill the ponds in 2005-2006 originated in
Recapture Reservoir (north of Blanding). While this water would possibly have been
tritiated and, depending on the regional isotopic signature of sulfur-34 on sulfate, may
have had a similar isotope fingerprint as the wildlife ponds and tailings cells, it is unlikely
for that water to have recharged before the July 2007 sample event. While it seems
unlikely that several years of tritiated water versus nearly 20 years of nontritiated water
could produce the young isotopic signature in well MW-22, more investigation is needed
and the cause the isotopic signatures is currently unknown.
54
VII. CONCLUSIONS AND RECOMMENDATIONS
A number of important conclusions can be made about the groundwater system
at Denison Mine, Co.'s White Mesa Mill based on the presented information.
Temperature and salinity profiles suggest that the water column in the aquifer is
stratified with respect to chemical composition, as salinity systematically increased with
depth. Furthermore, some wells (e.9. MW-1, MW-3, MW-s, MW-15) exhibited markedly
different levels of salinity at different depths, differentiated by a drastic change in salinity
across a very small depth. Also, noble gas compositions, particularly with respect to
helium-4, suggest the water column is stratified with respect to age. Helium-4
concentrations determined from diffusion samplers were in every case greater at depth
than samples taken near the water table (with the exception of well MW-19); suggesting
longer subsurface residence time or age. Although not delineated by low-flow sampling
at multiple depths, the systematic changes in temperature and salinity with depth, as
well as helium-4 concentrations at depth, suggest the water column is stratified.
Furthermore, this suggests that the existing monitoring wells sample a range of flow
paths and groundwater ages. Passive samples from near the top of the well screens
are more likely to detect leakage from the tailing cells than samples collected from the
bottom of screens. While conventional low-flow sampling at this site does not appear to
be practical or effective, passive sampling for dissolved ions (e.9. using dialysis
membranes) might be effective.
Helium ratios corrected for inputs from excess air suggest older water farther
away from the wildlife ponds. 3He/aHe ratios closer to atmospheric values suggest
water that is younger than 50 years. Most samples exhibiting this characteristic were
55
located close to the wildlife ponds, while samples farther away from the ponds had
ratios less than atmospheric.
Low-flow sampling methods employed in monitoring wells were unable to
distinguish stratification in the water column when a monitoring wellwas sampled at two
depths. No significant differences were seen in concentrations of metals or anions, or in
isotopic fingerprints, between samples taken at two depths. Additionally, age dating
techniques that required active pumping for sample collection did not indicate marked
differences in groundwater age between shallow and deep samples. However, this is
likely the result of the inability of active pumping to collect depth-specific samples, rather
than the lack of an age gradient.
Small but measurable quantities of chlorofluorocarbons were found in 10 wells
(MW-1 , MW-2, MW-s, MW-1 1 , MW-14 shallow and deep, MW-1 5, MW-18 deep, MW-
29, and MW-31) that did not contain tritium. CFCs are present in the unsaturated zone
as gases at near-modern atmospheric concentrations. That CFCs are present in some
samples near the water table indicates that water does propagate downward through
the vadose zone and ultimately recharge the aquifer, again suggesting stratification in
the aquifer. However, the absence of tritium in those waters suggests it takes infiltration
water longer than 50 years to travel through the vadose zone. Because some amount
of recharge to the aquifer is taking place, as evidenced by the recharge mound near the
wildlife ponds, the system elsewhere can therefore be considered recharge-limited and
not permeability-limited. Active groundwater flow clearly occurs vertically and
horizontally, and if leakage from tailing cells occurs in the future a contaminated plume
is likely to result at the water table.
56
Tritium measured in monitoring wells near the wildlife ponds suggests young
water is recharging to those wells (MW-19 and MW-27). Surface water sites also
contained significant amounts of tritium. The wildlife ponds contained atmospher.ic
concentrations of tritium. The presence of tritium in the wildlife ponds and nearby
monitoring wells strongly suggests recharge is occurring from the wildlife ponds to the
aquifer. Because the wildlife ponds were constructed in the mid-1990's, water
recharging from the ponds would bear a tritium concentration indicative of the
atmospheric tritium in the last 10 to 15 years. Recharge from the wildlife ponds can
potentially shift the flow dynamics of the system significantly, as is evidenced by
mounding of the water table around the ponds. Such a shift in flow paths could result in
temporal variations in groundwater chemistry.
Nitrate concentrations in two wells (MW-30 and MW-31)exceeded the Utah
State Groundwater Quality Standard (GWOS) of 10 mg/L. All wells except for one
(MW-27) exceeded the National Secondary Drinking Water Standard for sulfate set by
the United States Environmenta! Protection Agency (250 mg/L). Five wells exceeded
the GWQS for uranium (30 pg/L), including: MW-3, MW-14, MW-15, MW-18, and MW-
22. Five wells exceeded the ad-hoc standard for manganese (800 pg/L), including:
MW-3, MW-3A, MW-14, Mw-22, and MW-29. Three wells exceeded the GWes for
selenium of 50 pg/L (MW-03, MW-15, and MW-31). The majority of welts that exceeded
water quality standards were tritium-free, contained very small amounts of CFCs, and
did not bear isotopic signatures similar to those of either the tailings cells or the wildlife
ponds. This suggests natural, background values of trace metal contamination in the
groundwater system.
57
Evaporative enrichment of 6D and 6180 is seen in surface water samples.
Values in monitoring wells fall along a line similar to the Utah Meteoric Water Line, but
offset slightly. Some apparent enrichment of both 6D and 6180 is seen in wells MW-27
and MW-19 shallow and deep. This suggests mixing that is occurring between enriched
water recharging from the wildlife ponds and older, depleted groundwater. There are no
other indications enriched water in any of the other monitoring wells. Even though
several wells down-gradient of the tailings cells exhibited elevated levels of uranium
concentrations, the stable isotope data does not indicate any amount of mixing between
evaporated, enriched surface water and isotopically lighter groundwater. Therefore, it is
unlikely that elevated and increasing uranium concentrations in MW-3, MW-14, MW-15,
MW-18, and MW-22 can be attributed to leakage from the tailings cells. However, the
stable isotope value of groundwater is insensitive to additions of trace amounts of
enriched (surface) water.
6sS and 618O isotopic signatures on dissolved sulfate provide distinction
between surface water sites and monitoring wells. The tailings cells and wildlife ponds
exhibit significantly enriched 618O-SOa values relative to monitoring wells, and depleted
63aS-SOa values relative to monitoring wells. MW-27 is the only monitoring well to bear
an isotopic fingerprint closely related to that of the surface water sites, suggesting
recharge from the wildlife ponds has reached MW-27 and further evidence that the
wildlife ponds are providing recharge to the aquifer. Sites with high concentrations of
metals (MW-3, MW-14 shallow and deep, MW-15, MW-18, and MW-22) bear very
different isotopic fingerprints than those of the surface water sites.
ln general, the data collected in this study do not provide evidence that tailings
58
cell leakage is leading to contamination of groundwater in the area around the White
Mesa Mill. Evidence of old water in the majority of wells, and significantly different
isotopic fingerprints between wells with the highest concentrations of trace metals and
surface water sites, supports this conclusion. The only evidence linking surface waters
to recharging groundwater is seen in MW-27 and MW-19. Measurable tritium and CFC
concentrations indicate relatively young water, with low concentrations of selenium,
manganese, and uranium. Furthermore, stable isotope fingerprints of 6D and 6180
suggest mixing between wildlife pond recharge and older groundwater in MW-19 and
MW-27. 63aS-SOa and 6180-50+ fingerprints closely relate MW-27 to wildlife pond
water, while the exceptionally low concentration of sulfate in MW-27, the only
groundwater site to exhibit sulfate levels below 100 mgil, suggest no leachate from the
tailings cells has reached the well.
CFC concentrations in tritium-free sites suggest a recharge-limited aquifer. This
means that if a contaminated fluid was introduced to the system, it would likely be
transported by the vertical flow of groundwater and would propagate through the
system. This site is, therefore, susceptible to contamination due to tailings cell leakage,
and must thereford be carefully monitored for such contamination. Sulfur-34 and
oxygen-18 isotopes of sulfate will be useful until the isotopic fingerprint of the surface
water sites has propagated through the entire system.
Sulfur isotopes that begin indicating input of water with a similar fingerprint as
that of tailings cells may be an early indication that a leak in the tailings cell liner has
developed. This signal would appear much earlier than elevated metal concentrations
because mixing of isotope ratios, with sulfate concentrations as drastically different as
59
between tailings cells and wildlife ponds, is observable after only a very small amount of
water has infiltrated (approximately 1% tailings cell water to g9% groundwater). Trace
metal concentrations as well as inorganic anions should also be monitored on a regular
basis.
60
Vll.. Sources Cited
Craig H. 1961.lsotopicvariation in meteoricwaters. Science.133, 1702-1703.
Denison Mines, 2008. Letter from Mr. David Frydenlund, Vice President of Regulatory
Affairs and Counsel, to Mr. Dane Finerfrock, Executive Secretary of the Utah
Radiation Control Board. Re: White Mesa Uranium Mill, Background
Groundwater Quality Report for Existing Wells-Additional lnformation Relating
to MW-27 and MW-22. 31January 2008.
Hydro Geo Chem lnc. Site Hydrogeology and Estimation of Groundwater Travel Times
in the Perched Zone; White Mesa Uranium Mill Site Near Blanding, Utah. 30
January 2003.
Heilwell, V. M., D. K. Solomon, and P. M. Gardner. 2006. Borehole Environmental
Tracers for Evaluating Net lnfiltration and Recharge Through Desert Bedrock.
Vadose Zone Journal. 5, 98-120.
2007. Revised Background Groundwater Quality Report Existing Wells For
Denison Mines (uSA) corp.'s white Mesa Uranium Mill Site, san Juan county,
UT. October 2007.
Kendall C. and T.B. Coplen. 2001. Distribution of oxygen-18 and deuterium in river
waters across the United States. Hydrological Processes. 15, 1363-1393.
Puls, RobertW. and Michael J. Barcelona. 1995. Low-Flow (Minimal Drawdown)
Ground-water Sampling Procedures. U.S. Environmental Protection Agency
Ground Water lssue, EPA/540/S-95/504.
Solomon D.K. 2000. oHe in Groundwater. Environmental Tracers in Subsurface
Hvdroloqv.
61
Solomon D.K. and P.G. Cook.2000. 3H and 3He. Environmental Tracers in Subsurface
Hvdroloqv.
Titan Environmental Corporation. 1994. Hydrogeologic Evaluation of White Mesa
Uranium Mill. July 1994.
United States Environmental Protection Agency. 2003. National Primary Drinking Water
Regulations. EPA 81 6-F-03-01 6.
United States Geological Survey. 2007. CFC Sampling Method - Bottles.
http:/iwater.usqs.qovilab/chlorofluorocarbons/samplinq/bottles/ . Accessed 1 2
October 2007.
Utah Administrative Code Rule R317-6. December 2007.
Utah Department of Environmental Quality. 2005. Monitoring and Water Quality:
Drinking Water Standards. R309-200.
Utah Water Quality Board. Ground Water Discharqe Permit. Permit No. UGW370004.
62
Denison Mines Corp. White Mesa Mill Site
URS 39400260.10100; Summary of Calculated GWCLs
June 16,2008
To: Loren Morton, UDRC
From: Robert Sobocinski and Brian Harper
Date: June 16,2008
completeness Review for the Revised Background Groundwater euality Report:
Based on comments provided by the Utah Division of Radiation Control (the Division) in letters
dated August 10 and August 24,2007, Denison Mines (USA) Corporation (DUSA) submiued
the Revised Background Groundwater Quality Report: Existing Wells for DUSA's White Mesa
Mill Site, San Juan County, Utah (the Revised Background Report) to the Division in October
2007. URS has performed a completeness review of the Revised Background Report. This is a
revised version of the completeness review issued on April 30, 2008. Findings and observations
from the review are as follows.
l.DUSA performed the data evaluation and statistical analysis in accordance with the
statistical process flowchart (attached Figure 19r) conditionatty approved by the Division
on August 24, 2007. The statistical analysis was performed in accordance with U.S.
Environmental Protection Agency (EPA) guidance and adequately addressed the presence
and variable percentage of non-detect values in the background water quality data sets.
There are 13 wells with 38 constituents for each well, resulting in494 individual data sets,
each of which has a corresponding Groundwater Compliance Limit (GWCL) proposed by
DUSA in Table 16 of the Revised Background Report. Each data set represents a single
constituent at a single well (e.g., uranium at MW-05). For the most part, the proposed
GWCLs appear to have been calculated correctly following the flow chart process.
However, there are some GWCLs (24 out of a total of 494) where the wrong approach
(e.g., highest historic value instead of the Poisson limit) was used to determine the GWCL.
These incorrect GWCLs are listed in attached Table 1 along with the correct GWCL. The
incorrect GWCLs appear to be the result of inadvertent errors and not due to a
misunderstanding or deliberate misrepresentation. Attached Table I also contains
corrections that appear to be simple errors (see items 7 and 8 below).
Attached Table 2 categoizes the GWCLs based on the percentage of non-detects and the
statistical approach. Table 2 assumes the 24 flowchart errors have been corrected and that
the issues listed in items 5, 6,7,and 8 below have been addressed (see attached Table l).
The following observations are made from Table 2:
o Most of the data sets consist of a majority of non-detects. Slightly more than half of
the 494 data sets consist of greater thang}Yo non-detects.
I Intera Figure l9 included herein has been updated to reflect the requirements of the August 24,ZOO7 DF{C
Conditional Approval.
File: 39400260.10200
2.
aJ.
Existing Wells for Denison Mines (USA) Corporation's White Mesa Mill Site, San Juan
Page I of4
Denison Mines Corp. White Mesa Mill Site
URS 39400260.10100; Summary of Calculated GWCLs
June 16,2008
4.
5.
6.
Largely because most data sets consist of a majority of non-detects, only 16.40/o of
the 494 proposed GWCLs were established as a mean plus two standard deviations.
These GWCLs were calculated following the first two paths shown on the attached
Figure 19 flowchart.
28.9% of the 494 proposed GWCLs were established following the 'Non-
Parametric Statistics" approach (third path on the attached Figure 19 flowchart):
l0.l% were the highest historical result in the data set (based on the non-parametric
statistical method), and 18.8% were established as a fraction of the Groundwater
Quality Standard (GWQS) as allowed by the process shown on the flowchart. The
conditionally approved process allows the option of using the greater of the highest
historical result or the fraction of the GWQS to represent the GWCL.
53.8% of the 494 proposed GWCLs were established following the fourth path of
the attached flowchart (non-detects > 90%): 2.0o/o of the GWCLs were calculated as
the Poisson prediction limit, and 51.8% were established as a fraction of the GWQS
as allowed by the process shown on the Figure 19 flowchart. The fact that over half
of the GWCLs were established as a fraction of the GWQS following the fourth
path on the flowchart illustrates that for many constituents, the data sets consist of
primarily non-detected results.
Attached Table 3 shows that 16 of the proposed GWCLs (about 3.2%o of the total) are
higher than the respective GWQSs. Refer to attached Table 2 for the breakdown by
approach of these GWCLs that exceed the GWQS.
For cadmium in wells MW-I, MW-2, MW-3, and MW-5, it appears that the proposed
GWCL exceeds the GWQS because of the extreme concentration range observed in the
early data (pre-March 1982). For this reason, URS removed the pre-March 1982 data from
the cadmium data sets for the four wells and revised the GWCL. The revised GWCLs,
which are less than the GWQS, are listed in attached Table l.
The proposed GWCLs for tetrahydrofuran in wells MW-l and MW-3 exceed the GWQS,
and in wells MW-5 and MW-l2,the proposed GWCLs exceed the fraction of the GWQS.
Because tetrahydrofuran is a man-made chemical, and the purpose of the groundwater
monitoring is detection monitoring, the GWCL should be set at the fraction of the GWQS
(see attached Table 1). In general, based on the assumption that background levels of man-
made organic chemicals (with the possible exception of chlorofluorocarbons) are not
present in detectable concentrations in groundwater at the White Mesa Mill Site, the
GWCLs for all organic chemicals should be set at the fraction of the GWQS. This would
include the organic chemicals in well MW-26 not associated with the chloroform plume
remediation. In accordance with Utah Administrative Code R317-6-6.15.F, the GWCL for
chloroform, chloromethane (degradation product), dichloromethane (degradation product),
and carbon tetrachloride (trace co-contaminant) in well MW-26 should be set at the
GWQS. Well MW-26 is discussed further in item 10 below.
Page 2 of 4
Denison Mines Corp. White Mesa Mill Site
URS 39400260.10100; Summary of Calculated GWCLs
June 16,2008
9.
For cobalt, the correct approach for establishing the compliance limit (fraction of the
GWQS) is identified in wells MW-2, MW-3, MW-12, MW-14, MW-15, MW-17, and
MW-26; however, there is a typographical error in the value of the GWCL. The fraction of
the standard for cobalt for these wells should be 365 micrograms per liter \ry/D instead of
3621tg/L (see attached Table 1).
For xylenes, the correct approach for establishing the compliance limit (fraction of the
GWQS) is identified for all the wells; however, there is a typographical error in the value
of the GWCL for each of the wells. For Class II groundwater (MW-I, Mw-5, and MW-
1 1), the fraction of the GWQS should be 2,500 pgll. instead of 2.5 pglL, and for Class III
groundwater (MW-2, MW-3, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-
26, and Mw-32), the fraction of the GWQS should be 5,000 pgll- instead of 5 pgll- (see
attached Table l).
In Section 9.3 of the Revised Background Report, DUSA states that seepage from the
tailings impoundments would be indicated by rising concentrations of chloride, sulfate,
fluoride, and uranium. URS agrees with this because: l) these constituents are abundant in
tailings wastewater (see Table 15 of the Revised Background Report), and 2) these
constituents are relatively mobile and conservative in the groundwater environment. In
contrast, many other constituents are either not present in relatively high concentrations in
tailings wastewater and/or are reactive in the subsurface environment. URS recommends
that for the four conservative constituents listed above, DUSA considers preparing and
including time-concentration plots in the groundwater monitoring reports. Increasing
trends could provide early indication of seepage even before GWCLs are exceeded. Also,
to provide confirmation that seepage has or has not occurred, DUSA might consider
analyzing groundwater, tailings wastewater, and wildlife pond water for isotopic uranium.
If significant differences exist in the ratio of U-234toIJ-238 between these waters, isotopic
uranium analyses may provide another tool for determining whether GWCL exceedances
are related to impacts from the impoundments.
With regards to special consideration for well MW-26 (Section 13.3.4 of the Revised
Background Report), URS believes that given the location of MW-26, along the eastern
edge of Tailings Cell2, it should be retained as an impoundment monitoring well. GWCLs
were established and presented in the "Flow Sheet GWCL" column of Table 16 of the
Revised Background Report; these values should be used as the groundwater discharge
permit GWCLs for well MW-26 (with the error shown in attached Table I corrected and
the exceptions discussed in item 6 above). However, URS agrees with DUSA, that
exceedences of GWCLs at MW-26 should be interpreted in the context of its use as a
pumping well for the chloroform plume remediation.
DUSA proposes that the groundwater at wells MW-18 and MW-l9 be reclassified as ClassIII water (Section 13.3.1 of the Revised Background Report). The GWCLs proposed in
Table l6 of the Revised Background Report assume that this reclassification has occurred.
If the Division does not approve reclassification of groundwater at wells MW-18 and MW-
11.
Page 3 of4
Denison Mines Corp. White Mesa Mill Site
URS 39400260.10100; Summary of Calculated GWCLs
June 16,2008
19, defers reclassification, or reclassifies groundwater at other wells, then the proposed
GWCLs based on the fraction of the GWQS for these wells need to be revised in Table 16.
12. In Section 13.3.1 of the Revised Background Report, DUSA also notes that consideration
should be given to reclassifuing groundwater at wells MW-l and MW-5 because the
proposed GWCLs for cadmium and lead in MW-1 and cadmium in MW-5 exceed the
GWQS. However, when the GWCLs are corrected as shown in Table l, none of the
proposed GWCLs for wells MW-l and MW-5 exceeds respective GWQSs. Therefore,
reclassification is not necessary.
In summary, with the exception of the errors that will require correction, DUSA established
GWCLs in accordance with the methodology given in the conditionally approved flowchart.
This methodology was developed in accordance with EPA guidance, and it takes into account
that much, if not the majority, of background data consists of non-detected results. After
correcting errors and revising the GWCLs for cadmium and tetrahydrofuran, 16 proposed
GWCLs still exceed the corresponding GWQSs (Table 3). Despite exceeding GWQSs, it
appears that these proposed GWCLs were established in accordance with the conditionally
approved flowchart (with a few exceptions). As such, URS recommends that the Division
approves these l6 proposed GWCLs (with exceptions corrected), because there is no physical or
chemical basis for a background concentration to be limited to the GWQS. Even in approving
these proposed GWCLs, several upward-trending data sets may require additional attention
during future monitoring events.
REFERENCES
Utah Department of Environmental Quality (UDEQ), Division of Radiation Control (DRC)
2007a. Completeness Review, DRC Findings, and Confirmatory Action Letter. Letter from D.L.
Finerfrock (DRC) to D. Frydenlund (DUSA). August 10,2007.
Utah Department of Environmental Quality (UDEQ), Division of Radiation Control (DRC)
2007b. DUSA Decision Tree/Flow Chart for Statistical Analysis for Background Groundwater
Quality: Conditional Approval. Letter from D.L. Finerfrock (DRC) to D. Frydenlund (DUSA).
August 24,2007.
Denison Mines (DUSA) Corporation 2007. Revised Background Groundwater Quality Report:
Existing Wells. Prepared for Denison Mines (USA) Corporation, Denver, CO. October,2007.
Page 4 of 4
&lrtsrl P.roctr. Fh* f{r-
lffi@hqifut6r@'
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retu6.n6um..@e 6imrd q,euileh..id.dntsddd.G.q.,<10s$<,.o4). h.fr.es.ins r6s.vr6h.d.b*(!!,<t0v.8.3.54) Ar,nssd.Mid**nu,
udw.,cmd.r(ne.whtuk., ". "..,,i,9-,l,r,f iffi
Table I - Revisions to Proposed GWCLS
Well Parametar GWQS
Percentage
Detects
DUSA Proposed
GWCL
DRC Revised
GWCL Comment
MW-1 Cadmium 5 ug/L 31.6%l3 ug/L 4.2 uglL'
fhe prcposed GWCL included early data that is suspst becaus of the
)xtreme concentration range obseryod within a short time period. All data prio
o March 1982 was removed from the dala set. Of the remaining data, 10.6%
rre detects; therelore, the GWCL should be the highest historical value or the
Ection of the GWQS, whichever is greater. The GWCL should be 4.2 ug/L
MW-1 Lead 1 5 ug/L 20 ug/L 5.59 ug/L
fhis GWCL is proposd based on ths highest historicalvalue. Ac@rding to th
lowchart, it should be the greater of the Pois$n limit or the fraction of the
sr^d^rd whi^h i.5 5a !r^/l /P6issnn limit\
MW-1 fetEhydrofurar 46 ug/L a1.ao/"94.41 ug/L 1 1.5 ug/L
fhis GWCL is proposed based on the Cohen's mean plus 2 o. However,
)ecause letEhydrofuran is not a naturally occuring constituent, background
!h^,,|i ha cal al rha Ladi^^ ^{ }h6 al^r^Q
MW.,I Xylenes 10,000 ug/L 0.0%2.5 ugr'L 2,500 ug/L The pmposed GWCL is based on the fraction of the GWQS and follows the
flowchart @rrectly; however, the propo*d GWCL @ntains a typographical
eror The fraclion of the GWOS should be 2-500 uo/L instead of 2.5 uc/L.
MW-2 Cadmium 5 ug/L 40.5yo '17 uglL 2.5 usr'L'
Ihe prcposed GWCL included eady data that is suspect because ot the
:xtreme concentration range obseNed within a short time period. All data prior
io Marctr 1982 was removed frcm the data set. Of the remaining data, 10.6%
tre detects; therefore, the GWCL should be the highest historical value or the
rrection of the GWQS, whichever is greater. The GWCL should be 2.5 ug,/L
MW-2 Cobalt 730 ug/L 0.0%362 ug/L 365 ug/L The prcposed GWCL is based on the fEclion of the GWQS and tollows the
lowchart corectly; however, the prcposed GWCL @ntains a typographical
!ror. The fraction of the GWOS should be 365 uo/L instead ot 362 uo/L.
MW-2 Lead 1 5 ug/L 9.5%20 ug/t 7.5 ug/L
fhis GWCL is prcposed based on the highest historical value. According to thr
lowchart, it should be the greater of the Poi$on limit or the fraction of the
rtan.lard which is 7 5 uo/L tfEclion of standardl
MW-2 Selenium 50 ug/L 66.7%25 ug/L 26.6 ug/L
This cWcL is proposed based on the fraction ol the groundwater standard
\ccording lo the flowchart, it should be Cohen's mean plus two standard
{rvietidnc-,66uo/l
MW-2 Xylenes '10,000 uq/L o.o%5 ug/L 5,000 ug/L the prcposed GWCL is based oo the fEction of the GWOS and folloffi the
lowchart @rrectly; however, the prcposed GwcL contains a typographi€l
)ror. The fraction of the GWOS should be 5.000 uc/L instead of 5 uo/L.
MW-3 Cadmium 5 ug/L 66.7./"20 us/L 4.67 ug/L'
he prcposd GwcL included early data that rs suspect because ol the
rxtreme concentEtion range obseNed within a sho( time period. All data prio
o March 1982 was removed frcm the data set. Of the remaining data,52.4o/o
rre detects; therefore, the data set was tested for normality, and normality
puld not be rejected and the GWCL should be Cohen's mean plus 2 q. The
;WCL should be 4.67 uo/L.
MW.3 Cobalt 730 ug/L o.0%362 ug,/L 365 ug/L ihe prcposed GWCL is based on the fraction of the GWQS and follows the
lowchart correctly; however, the prcposed GWCL @ntains a typographical!r^r ThE fraclion of thc GWOS shoul.l hc 365 ud/t instead of 362 uo/L
MW-3 Lead 1 5 ug/L 4.7%20 uq/L 7.5 ug/L
this GWCL is prcposed based on the highest historical value. Ac@rding to thr
lowchart, it should be the greater of the Poisson limit or the fraction of the
itandard. which is 7.5 uo/L (fEction of standard).
MW-3 46 ug/L a5.70/"123.55 ug/L 23 ug/L
'his GWCL is Droposed basd on the mean plus 2 o. However, because
MW-3 Ucnium 30 ug/L 9A.7y"67.'16 ug/L 47.32 uglL lhis GWCL is proposed based on the highest historical value. Ac@rding to thr
law.had it shoill.l he lhe mcen nhrs tud sian.iar.l .levialions - 47 32 uo/L
MW.3 Xylenes 10,000 ug/L o.oo/.5 ug/L 5,000 ug/L The proposed GWCL is based on the fEction of the GWQS and follows ihe
flowchart corectly; however, the prcposd GWCL contains a typographical
Eror The fractioh of the GWOS should be 5 000 uo/L instead of 5 ud/L.
MW-5 Cadmium 5 us/L 40.0%20 ug/L 2.0 ug/L-
The proposed GWCL included early data that is suspect because of the
extreme concentration Enge obseNed within a short time period. All data prio
to March 1982 was Gmoved from the data set. Of the remainiog dala,4.2y.
are detects; theretore, ths GWCL should be the Pois$n limit or the fraction of
th6 GWQS, whichever is greater. The GWCL should be 2.0 ug/L (Poisen
MW-s Nitrate/ite 10 mgr'L 50.0./"0.3 mg/L 2.5 mg/L
This GWCL is propo*d basd on the highest historical value, but according to
the flowchart, the fraction of the groundwater siandard can be used becaus it
MW-5 Lead 15 ug./L 5.30/"10 ug/L 4.1 ug/L
fhis GWCL is prcposd based on the highest historjcal value. Ac@rding to th,
lowchart, it should be the greater of the Poissn limit or the fraction ot the
rl.ndrd whi.h ie d I r'6/l lPnisson limitl
MW-5 Mercury 2 ug/t 3.1%0.5 ug/L 1 ug/L
fhis GWCL is prcposed based on the fractaon of the groundwater standard, bu
amording to the flowchart, the Poison limit €n be used be@use it is higher -
I uo/L-
MW-5 Fluoride 4 mg/t 100.0%1.68 mg/L 1.42mglL fhis GWCL is proposed based on the highest historical value. Ac@rding to th
l6w.hrd it sho' tlrl he the mcan nhrs tuo slan.lard devialions - 1 42 uo/L
- Revisions to Proposed GWCLS
Well Parameter GWQS
Parcentage
Detecis
DUSA Proposed
GWCL
DRC Revised
GWCL Comment
MW-5 46 ug/L 57.1%22.03 aslL 1 1.5 us/L ollows the flwchart. However, because tetrahydrofuran is not a naturally
MW-5 Xylenes 10,000 ug/L o.oo/"2.5 us/L 2,500 us/L lhe proposd GWCL is based on the fEction of the GWQS and ,ollows the
lowchart @rec'tly; however, the pEp6ed GWCL @ntains a typogEphical
rror The fra.lion of ihe GWOS should be 2 5O0 uo/L instead of 2 5 ud/l
MW-11 Beryllium 4 ug/L 5.3%2uglL 1 ug/L
this GWCL is prcposed based on the highest historical value. Ac@rding to th
lowchart, it should be the greater of the Poisson limit or the fraction of the
rtandard both ofwhi.i aE 1 uo/t
MW-'l1 Manganese 800 ug/L 100.0%200 ugr'L 131.29 ug/L
lhis GWCL is prcposed ba*d on the fraction of the groundwater standard.
\6ording to the flowchart, it should be the mean plus two standard deviations
31.29 uolL.
MW-l1 Nickel 100 ug/L 4.46/o 50 ug/L 46.2 u91L
this GWCL is prcposed based on the highest historacal value. Ac@rding to th
lowchari, it should be the greater of the Poisson Iimit or the fraction of the
t.^i..d u,hi^h i. lA,,,^n /p^i.e^- limil\
MW-1,I Xylenes 10,000 us/L 0.0%2.5 ug/L 2,500 ug/l-fhe prcposed GWCL is based on the fraction of the GWQS and tollows the
lowcharl @rrectly; however, lhe proposed GWCL @ntains a typographical
aror. The fraction ofihe GWOS should be 2.500 uo/L instead of2.5 uo/L
MW-12 Cobalt 730 ug/L o.oo/o 362 ugr'L 365 ug/L Ihe prcposed GWCL is based on the tEction of the GWOS and follows the
lowchart @rrectly; however, the prcpGed GWCL contains a typographical
!,. fh6a.6ri^^J eaE"^n i6-ra-i^fear..^n
MW-12 Nitrate/ite 10 mg/L 14.3yo O.12 mglL 5 mg/t Js the tEction of the groundwater standard (5 mg/L) until there are at least E
MW-l2 Mercury 2 ugll-7.1%3 ug/L 1 ug/L
lhis GwcL is proposd based on the highest histoncal value. Ac@rding to thi
Rowchart, it should be the greater ot the Poisson limit or the fraction of the.irndrd whi.h ic 1 r6n ffrr.tinn ^I<t.ndrd\
MWl2 fetrahydrofurar 46 ug/L 75.0./.42.18 ugl|-23 ug/L This GWCL is proposed based on the Cohen's mean plus 2 o and corectly
follows the flowchart, However, be€use tet€hydrofuran is not a naturally
G61 -l th6 lr5^ri^^ ^a rha arir e
MW-12 Xylenes 10,000 ug/L o.o"/.5 ug/L 5,000 us/L The proposed GWCL is based on the fEciion of the GWQS and follows lhe
flowchart corectly; however, the prcposed GWCL @ntains a typographical
-r r Th- fr-^li^h ^l tha awna .h^'ild h6 < nnn',^/l i-.t--A ^, <'h/l
MW-14 Cobalt 730 ug/L 0.0%362 ug/L 365 ugr'L The proposd GWCL is based on the fraction of the GWOS and follows the
flowchart @rectly; however, the prcposed GWCL @ntaios a typographical
MW-14 Zinc 5000 ug/L 71.40/6 2500 ug/L 35.04 ug/L
I hrs GWCL ts prcposed based on the lraction ot the groundwater standard, bu
a@ording to the flowcirart, it should be Cohen's mean plus two standarddEviati^n(-35Mild/l
MW-l4 Xylenes 10,000 ug/L o.o%5 ug/L 5,000 ug/L The prcposed GWCL is based on the fraction of the GWQS and follows the
flowchart corectly; however, the proposed GWCL contains a typographical
aF' Tha +.-ii^- ^, lha n\lrne ch^, Ji h6 E nnn,,^n i^.+aai ^+ A,'^/l
MW.15 Ammonia 25 ms/L 76.90/"12.5 mg,/L 0.2'1 mglL
This GWCL is pDposed based on the fraction of the groundwater standad, bu
a@ording to the flowciart, it should be Cohen's mean plus two standard
MW.,I5 Cobalt 730 ug/L o.oo/"362 ug/L 365 us/L The proposed GWCL is based on lhe frection ot the GWOS and follows the
flowchart @rrectly; however, the prcpGed GWCL @ntains a typographicalero.. The fraciion of the GWOS should be 365 u./L instead ot 362 u./L
MW.15 lmn 1 1000 ug/L 50.0%5500 us/L 81.7 us/L
This GWCL is prcposed based on the fraclion of the groundwater standard, b!
according to the flowchart, it should be Cohen's mean plus two standard
.lavietinns-A1 7'rdll
MW-15 Xylenes 10,000 ug/L 5 ug/L 5,000 ug/L The prcpced GWCL is based on the fraction of the GWQS and follows the
flowchart @rrectly; however, the proposed GWCL @ntains a typographical
etror The fradion of lhe GWOS should b€ 5 0O0 uo/L instead of 5 uo/L
MW-17 Cobalt 730 ug/L o.o%362 ug/L 365 ug/L The proposed GWCL is based on the fEction of the GWQS and follows the
flowchart correctly; however, the prcposd GWCL @ntains a typographical
MWlT Nitrate/ite 10 mg/L 14.3%0.1 mg/L 5 mg/L Us6 the Iractaon of the grcundwater standard (5 mg/L) until thera are at least I
rl.ia nointc for enalvcis
MW-17 Uranium 30 ug/L 100.0%46.8 ugA 46.66 ug,/L This GWCL is prcposed based on the highest historical value. Ac@rding to th
flowcharl. it should be the mean olus two siandard deviations - 46.66 uo./L.
MW-17 Xylenes 10,000 ug/L 0.0%5 ug/L 5,000 ug/L The proposed GWCL is based on the fEction of the GWOS and follows the
flowcharl corectly; however, the prcposd GWCL @ntains a typographical
eror. The fraclion of the GWOS should be 5.000 uo/L instead of 5 uo/L.
MW-18 Sultate NA 100.0%1940 mg/L 1938.9 mg/L This GWCL is prcposed based on the highest historical value. Ac@rding to thr
flowchart. it should be the mean olus two standard deviations - 1938.9 mo/L-
Well Parameter GWQS
Percentage
Detects
DUSA Proposed
GWCL
DRC Revised
GWCL Comment
MW-18 Xylenes 10,000 ug/L 0.00/.5 us/t 5,000 ugr'L The prcposed GWCL is based on the fEction of the GWQS and follows the
nowchart @rectly; however, the prcposed GWCL contains a typographi@l
eror. The fraction of the GWOS should be 5 ooo ud/l instra.l d 5 r hn
MW-19 Ammonia 25 mg/L 60.00/"12.5 mg/L 0.31 mg/L r@ording to the flowchart, it should be Cohen's mean plus two standard
lEvirii^nc-O?1 h^/l
MW.lS Fluoride 4 mg/L 100.0%1.4 mg/L '1.39 mg/L This GWCL is propced based on the highest hislorical value. According to th(
flowchart- it should be lhe mean ohrs Mn standerd dEvirtinhe - 1 ?q mdx
MW-19 Xylenes 10,000 ug/L o.Oo/o 5 uS/L 5,000 ugr'L Ihe prcposed GWCL is based on the fraction of the GWQS and follows the
lowchart correctly; however, the proposed GWCL ontains a typographical
)ror. The fraction of the GWOS should bc 5 OOO rrn/l inslrrd 6f 4 "dn
MW.26 Benzene 5 ug/L 3.8%4.75 ug/L -'2.5 ug/L lhe Yow sheet" GWCL is based on the Poi$on Limit and @rrecfly follows the
lowchart. However, be€use benzene is not a natuElly oGurring constifuent,
he comoliancc limil shdrl.l ha sei .i the fradidn ^f thc nwos
MW-26 Carbon
TetEchloride 5 ug/L 3.80/o 4.75 ug/L "5 ugr'L
The "flow sheet" GWCL is based on the Poisson Limit and @rectly follows the
lowchart. HMever, because carbon tetrachloride is a trace cc@ntaminant ol
he chlorofom plume, in accordance with UAC R317-&6.15.F, the compliance
mit should be set at the GWOS
MW-26 30 ug/t 30.8%6.6 ug/L'30 ug/L
Ihe "flow sheet" GWCL is the highest historical value and corectly follows the
'lowchart. However. beeuse chloromelhane is a .ieora.lrlinn nrndr rd ^Ilhlorofom, in amordane with UAC R317-G6.15.F, the complian@ limit shoul
)e set at the GWOS.
lvlw-26 Cobalt 730 ug,/L o.ov"362 ug/L *'365 usr'L The "ffow sheet" GWCL is based on the fraction of the GWQS and follows the
flowchart @rrectly; however, the proposed GWCL @ntains a typographi€l
eror. The fraction of the GWOS should be 365 uo/L instead of 362 rm/l
MW-26 Nitrate/ite '10 mg/L 70.00/o 0.623 mg/L "0.623 mg/L
Ihe'flow sheet" GWCL is the corect value; however, the @mment in
ncorect. The comment states that the proposed GWCL is the fraction of the
3WQS, but the proposed GWCL is actually Cohen's mean plus lwo standardlevialions-O623md/l
MW-26 Xylenes 10,000 ug./L o.0%5 ug/L'-5,000 ug/t The Slow sheet' GWCL is based on the fEction of the GWQS and follore lhe
flowchart correctly; however, the GWCL @ntains a typographical ercr..The
lraction ofthe GWOS should be 5 000 uo/l instce.t ofs udI
MW-32 Nitrate/ite 10 mg/t 10.o%0.1 mg/L 5 mg/L
This GWCL is proposed based on the highest historical value, but according to
the llowchart, the fmction of the groundwater standard €n be used becaus itishioher-5mo/l
MW-32 Xylenes 10,000 ug/L 0.0%5 ugr't 5,000 ug/L The prcposed GWCL is based on the fmction of the GWOS and follows the
flowchart correctly; however, the prcposed GWCL @ntains a typographicaleror. The fraction of the GWOS should he 5 O0O "o/l insierd 6{ q rd/l
Table 1 - Revisions to Proposed GWCLS
'These revised GWCLs were elculated by URS and should be verified by DUSA.
'- For MW-26, DUSA does not propose GwCLs. The GWCL is from the "Flow Sheet GWCL' column of Table 16 of the Revised Background Report (see item l0
of the URS Completeness Review).
3of 6 6/16/2008
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Well Parameter
DUSA
Proposed
GWCL
(us/L)
Proposed GWCL
Based on
GWQS
(ug/L)
Error in DUSA Proposed
GWCL? (from Table 1)
DRC
Proposed
GWCL
(us/l)
MW-1 None
MW-2 None
MW-3 Manganese 4,233.03 Normal
Mean + 2o 800 No 4,233.0
MW-3 Uranium 67.16
Non-parametric
Highest Historical
Value*
30
This GWCL is proposed
based on the highest
historical value. According
to the flowchart, it should be
the mean plus two standard
deviations - 47.32 uolL.
47.32
MW-5 None
MW.11 None
MW-12 Cadmium 7
Non-parametric
Highest Historical
Value
5 No 7
MW-12 Manganese 2,088.80 Log Normal
Mean + 2o 800 No 2,088.8
2,230.30 Normal
ean + 20MW-14 Manganese 800 No 2,230.3
MW.14 Uranium 98
Non-parametric
Highest Historical
Value
ug/L No 98.0
MW-15 Selenium 128-72 Mean + 20 50 No 128.7
MW-15 Uranium 65.67
Non-parametric
Highest Historical 30 No 65.7
MW-17 Manganese 915.39 Log Normal
Mean + 20 800 No 915.4
MW-17 Uranium 46.8
Non-parametric
Highest Historical
Value*
30
This GWCL is proposed
based on the highest
historical value. According
to the flowchart, it should be
the mean plus two standard
deviations - 46.66 uo/L.
46.66
MW-l8 Uranium 55.1 Normal
Mean + 2o 30 No 55.1
o
Table
o
GWQSs3 - Proposed GWCLs That Exceed
6t1612008
3 - Proposed GWCLs That Exceed
I
GWQSs
* Method is not correct according to Figure 19 flowchart. DRC proposed GWCL assumes correct method is used.
Well Parameter
DUSA
Proposed
GWCL
(us/L)
Proposed GWCL, Based on
GWQS
(us/L)
Error in DUSA Proposed
GWCL? (from Table 1)
DRC
Proposed
GWCL
(us/l)
MW.19 Thallium 2.15 Normal
Cohen's Mean + 2o 2 No 2.1
MW-26 Manganese 1,610
Non-parametric
Highest Historical
Value
800 No 1,610.0
MW-26 Uranium 41.85 Log Normal
Mean + 2o 30 No 41.8
MW-32 lron 14,060 Normal
Mean + 2o 1 1,000 No 14,060
MW-32 Manganese 5,594.95 Normal
Mean + 2o 800 No 5,594.9
,o*r.rfr,,o*,,*
GARYHERBERT
Ucutenan Govcmor
State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executivc Dircctor
DTVISION OFRADIAfiON
CONTROL
Dane L. Enerfrock
Director
THRU:
FROM:
MEMORANDUM
l,oren Morton 'l-gn
Phir Goble fr@
DATB: June 24,2008
SI'JBJECT: Denison Mines Corporation (USA) and Proposed Background Ground Water
Quality for New Wells (April 30, 2008 Intera Report); DRC Findings and
Recommended Action.
The purpose of this memorandum is to summarize DRC findings regarding the April30,200gBackground Ground Y1?. Quality Report forthe New Wells (hereafterNiw wetts Background
Re,p_ort), to propose a DRC course of action for setting Ground Water Compliance lrvels(GWCLs) forthe Denison Mines Corporation (USA) IhereafterDUSAI uranium milling facility
near Blanding, Utah.
Jne o_-fC-n1 ryrfgrmed a completeness review of the Background Ground Water euality forNew wells (Mw-23, NNV-zt+, Mw-25, MNt-z7,Mw-2g, Mw-29, Mw30, Mw-31, and-Mw-3A). Finding and observations from the review are as follows:
l.DUSA performed the data evaluation and statistical analysis in accordance with the
statistical process flowchart (attached Figure 17) conditionally approved by the DRC onAugust U,2007. The statistical analysis was performed in aicoidance wiih the U.S.Environmental Protection Agency (EPA) guidance and adequately addressed the presence
and variable percentage of non-detect values in the background water quality data sets.
There are 9 wells with 38 constituents for each well, resultin gin342individual data sets,
each of which has a corresponding GWCI, proposed by DUSA in Table l0 of Revised
Background Report for New Wells. Each dataset represents a single constituent at a singlewell (e.g., arsenic at Mw-23). Most of the proposed-GWCls appear to have been
calculated correctly following the flowchartprocess. However.there are several GWCLg(146 out of a total of 342) where the wrong approach was used to determine the GWCL orwhere there was a typographical error in the value of the GwcL.
168 North 1950 west ' Po Box 144850 . Salt r ^te ciry, ur 841 I4-4850 . phooe [phone] . fax (8ol) 533-4097," fl,i:"ff::#;I1:'^*"
2.
Page2
Of the 146 GWCI5 needing correction, 87 represented an increase over those proposed by
DUSA. 82 of the 87 GWCLS increased were caused by the change in classification from
Class tr to Class Itr for three wells (MW-25, NN,l-27, and MW-31) which changed the
fraction value used in setting GWCIs under the approved flowchart approach (see Section 5
below). 50 of the 146 GWCLs needing correction resulted in a decrease; while in 9 other
cases, DUSA failed to propose a GWCL for Tin in each of the new wells (see Section 6
below). These incorrect GWCI-s are listed in attached Table I along with the corrected
GWCL. Forthe remaining 196 cases, the DRC agrees with the GWCLs proposed by
DUSA.
In 43 of these instances, DUSA recommended an approach that varied from the Flow Chart
diagram for data sets with very low variability. In the Revised New Wells Background
Report, DUSA claimed that during the calculation of GWCLs that were determined by the
mean plus two standard deviations, a condition arose that didn't occur during the same
calculation of the existing wells. Because data from the new wells is limited to around two
years and was analyzed by the same laboratory, the standard deviation could be typically
io*er than similar values for the existing wells, in some cases resulting in a GWCL that is
very close to the average value of the data set. Therefore, for the cases where following the
flowchart resulted in a GWCL that is very close to the average value of the data set, DUSA
proposed GWCI5 that were be based on the mean plus 20 percent (7 +ZOVo) rather than
following the flowchart
This 1 +2y2omethod used by DUSA is not based on the EPA Guidance given to DUSA in
an August 9, 2008 DRC e-mail. Additionally, DUSA has failed to follow the Decision
Tree/Flow Chart diagram, which was created by DUSA, and was conditionally approved by
the DRC on August 24,2W7. It is not unexpected to see data sets with low variability
when using the same analytical laboratory over a short period of time. However, this
problem cin be addressedin the future, if it occurs, in that DUSA has the ability to provide
new descriptive statistics for a given well and contaminant as more data becomes available,
and requesi the Executive Secretary approval thereof. Therefore, the DRC rejects the
proposed i +20Vo method. These incorrect GWCLs are listed in attached Table 1 along
with the corrected GWCL.
DUSA also argues in the Revised New Wells Background Report "that assuming a normal
distribution, setting the GWCL at a value of two standard deviations above the mean,
virfually guarantees that each well will be out of compliance (falsely) in about two and a
half percint of all concentration values measured in groundwater samples from that well."
While it is true that a GWCL that is set at the mean plus the second standard deviation,
which corresponds to the 95Vo upper confidence limit, has 2.5%o (0.025) probability of any
parameter in any well falsely exceeding its GWCL during any given sampling event.
DUSA would not be considered in out of compliance status until two consecutive
groundwater quality samples exceed the respective GWCL (x +2o concentration) for each
well and contaminant in question. On a statistical basis this equates to a0.062Vo (0.025')
probability that any given well and parameter will twice, consecutively, falsely exceed its
respective GWCL.
Page 3
3.
4.
5.
Attached Table 2 categoizes the GWCLs based on the percentage of non-detects and
statistical approach. Table 2 assumes the 146 flowchart errors have been corrected and the
issues listed in items 5 and 6 below have been addressed (see attached Table 1). The
following observations are made from Table 2:
o Most of the data sets consist of a majority of non-detects. 59.9Vo of the 342 data sets
consist of greater than9OVo non-detects.
Largely because most data sets consist of a majority of non-detects, only 23Vo of the
342 proposed GWCLs were established as a mean plus two standard deviations. These
GWCIs were calculated following the first two paths shown on the attached flowchart.
l6.6Vo of the 342 proposed GWCIs were established following the "Non-Parametric
Statistics" approach (hird path on the attached flowchart): 2.6Vo were the highest
historical result in the data set (based on the non-parametric statistical method), and
l4.O7o were established as a fraction of the Groundwater Quality Standard (GWQS) as
allowed by the process shown on the flowchart. Note that the conditionally approved
process gives DUSA the option of using the greater of the highest historical result or the
fraction of the GWQS to represent the GWCL.
59.9Vo of the 342 proposed GWCIs were established following the fourth path of the
attached flowchart: OVo of the GWCLs were calculated as the Poisson prediction limit,
and.59.9Vo were established as a fraction of the GWQS as allowed by the process
shown on the flowchart (DUSA has the option of using the greater of the Foisson limit
or the fraction of the standard). The fact that over half of the GWCLs were established
as a fraction of the GWQS following the fourth path on the flow chart illustrates that for
many constituents, the data sets consist of primarily non-detected results.
Attached Table 3 shows that 15 of the proposed GWCLs (about 4.4Vo of the total) are
higher than the respective GWQS. Refer to Table 2 for the breakdown of these GWCIs
exceeding the GWQS.
Groundwater Classification Utah Administrative Code R3l7-6-3.6 states: "Class Itr ground
water has one or both of the following characteristics: A. Total dissolved solids greater
than 3,000 mgl[- and less than 10,000 mgL,or; B. One or more contaminants that exceed
the ground water quality standards." So it is not unreasonable to have GWCLs, based on
background groundwater quality data, for Class III groundwater that are higher than the
GWQS, since by definition Class III groundwater can have contaminant concentrations that
exceed the corresponding standard. Most of the monitoring wells (seven of eight) are
classified as having Class III groundwater; while the other well (MW-30) is classified as
having Class tr groundwater. Change in classification for three wells MW-25, NNV-27,
and MW-31) will change the fraction value used in setting GWCIs under the approved
flowihart approach. As a result, under the fractions approach; the GWCL valuii will now
be set at 50Vo of the GWQS instead of 25Vo. This calculation was not incorporated into the
New Wells Background Report for these wells; therefore they have been updated on the
attached Table l. See below for the groundwater classification rationale for each new well:
Page 4
MonitorWell Groundwater Classification Comment
MW-23 Class III TDS GWCL -3.670 uelL
MW-24 Class III mS GWCL - 4.450 usIL
MW-25 Class III*TDS GWCL -2,976 pg[L:The
proposed GWCL for manganese
(1,806 pglL) is above the GWQS in
MW-25 and changes the
Groundwater Protection kvel to
Class III in this well.
lvlW-n Class III*TDS G-WCL - 1,075 pg[L:The
proposed GWCL for uranium (34
pgll.) is above the GWQS in MW-27
and changes the Groundwater
Protection Level to Class III in this
well.
MW-28 Class III TDS GWCL - 4,852 uslL
MW-29 Class Itr TDS GWCL - 4,4N rtslL
MW-30 Class II TDS GWCL - 1,918 uslL
MW-31 Class III*TDS GWCL - 1,320 ltglL:The
proposed GWCL from selenium (71
pdl) is above the GWQS in MW-31
and changes the Groundwater
Protection Level to Class III in this
well.
MW-3A Class III TDS GWCL'- 5,805 rell-
7.
8.
In the April 30, 2008 New Wells Background Report, DUSA failed to propose a GWCL for
Tin in all new wells. However, according to the Flowchart, if there is not at least eight data
points remaining, DUSA should defer analysis until eight data points available. DUSA was
required to start analysis for Tin in on-site wells when the White Mesa Uranium Mill began
to receive and process alternate feed material from Fansteel Inc. Analysis for Tin began in
June, 2006 and there have been seven monitoring events where Tin has been analyzed.
With the help of EPA Region 8 toxicology staff the DRC adopted an ad hoc groundwater
quality standard for tin of 17,000 ug/L (See LOl27l05 EPA memorandum). Since the Tin
concentrations in all new wells have been IOOVo non-detect, the GWCL will be set at the
fraction GWQS for Class III water - 8,500 ltgtL and4,250 ltgtLfor Class II water.
In the Intera Report, DUSA proposes a GWCL of 36 ltgtLfor uranium in well NNV-24.
Before calculating this GWCL, DUSA correctly removed the uranium outliers (223 and
78.9 ltglL). However, DUSA should have also removed the uranium outlier, 46 ttilL.
After removing the uranium 46 pdLoutlier, the GWCL(x+2o) calculates at ll.90 1tglL.
The corrected GWCL is shown in the attached Table 1.
In the Intera Report, DUSA proposes GWCIJ for pH in all nervs wells based on the mean
minus 20 percent (7 -20Vo'). This 7 -2A7o method used by DUSA is not based on the EPA
Guidance given to DUSA in an August 9,2008 DRC e-mail. Additionally, DUSA has
failed to follow the Decision Tree/Flow Chart diagram. Therefore, the DRC rejects the
proposed 7 - 2OVo method for pH GWCIT. These incorrect GWCIs are listed in attached
Table I along with the corrected GWCL.
Page 5
In summary, with the exception of some erors that will require correction, DUSA established
GWCIs in accordance with methodology given in the conditionally approved flowchart. This
methodology was developed in accordance with EPA guidance, and it takes into account that
much, if not the majority, of background data consists of non-detected results. In 15 instances, the
established GWCIs exceed corresponding GWQS's. Of these 15, it appears that only I may be
an issue in future monitoring (may cause noncompliance) if the GWCL is established as the
GWQS. The DRC agrees with all 15 instances where the proposed GWCL exceeds the GWQS,
determined by DUSA (after correcting all errors), because there is no physical or chemical basis
for a background concentration to be limited to the GWQS. Even in approving these proposed
GWCLS, several upward-trending data sets may require additional attention during future
monitoring events.
After review of the Revised New Wells Background Report and consideration of the University of
Ulah Study Final Report; DRC staff recommends the following: 1) The DRC should accept 196 of
the342 GWCLs values proposed by DUSA in the April 30, 2008 Revised New Wells Background
Report, 2) For the remaining 146 GWCIT, the DRC will adopt the values calculated by DRC staff
which can be found in the attached Table l, and 3) It is recommend this be done with a major
Permit modification, in conjunction with a public comment period and Statement of Basis.
Page 6
References
Hurst, T.G. and D.K. Solomon, May, 2008, "summary of Work Completed, Data Results,
Interpretations and Recommendations for the luly,20O7 Sampling Event at the Denison
Mines, USA, White Mesa Uranium Mill Near Blanding lJtah" unpublished report by the
University of Utah Department of Geology and Geophysics, 62pp. [transmitted via
5/18/08 email from Kip Solomon to Loren Morton (DRC)].
INTERA, Inc., Prepared for Denison Mines (USA) Corp., April 30, 2008. "Revised Background
Groundwater Quality Report: New Wells. ForDenison Mines (USA) Corp.'s White Mesa
Mill Site, San Juan County, Utah."
Utah Division of Radiation Control, December l,z}Ol,"Statement of Basis for a Uranium
Milling Facility at White Mesa, South of Blanding, LItah," unpublished regulatory
decument,5T pp., and 12 attachments.
Utah Division of Radiation Control, May 19,2008, "Denison Mines Corporation (USA) and
Proposed Background Groundwater Quality forExisting Wells (October, 2W Intera
Report); April 28, 2008 URS Finding and DRC Recommended Action," unpublished
regulatory document from Loren Morton to Dane Finerfrock, 9 pp.
URS Corporation, June 16, 2008, "Completeness Review for the Revised Background
Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corporation's
White Mesa Mill Site, San Juan County, IJtah," unpublished consultants memorandum, 4
pp., I figure, 3 tables [transmitted via 6/16/08 email from Bob Sobocinski (URS) to hren
Morton (DRC)].
PRG:prg
F/.../DUSA New Wells Memo.doc
Frle: DUSA Background GWQ Report - New Wells
3:iJJ[,HJ%,',.*"il}i';:l:il3"'$Hff :[t",,ff ;L'":ffi ,.*1",u"n"o,n,,,uon
EtilVtuASFdk hksIdR@
a ,w€M @n#6d .inenjts' wilt E h mxtum cpode timfr h a tut and wil cx@rd oth6r ,ed.bd! by, br e[mpEandlrdm!ilrud.(c.9,<10_vgu!<1.08[). tn!@€e3,henJtEm"ae"myiuerw&M&[e-mail]&t (e.9., <10 v€rsB 3 5 E^)
Juan Conty, Uteh
Table 1 - Revisions to Proposed GWCLS
Well
Protectlon
Level Parametel GWOS
Percentage
Detec-ls
DUSA Proposed
GWCL
DRC Revlsed
GWCL Comment
MW-23 Class lll Tin 17,000 Ug/L 100%None 8,500 Ig/L )USA lailed to provide a GWCL for Tin in MW-23. Since the Tin
)oncentrations in Mw-23 has been 1oo% non-detect, the GWCL
vill be set at the fraction GWQS lor Class lll water - 8,500 !g/L.
MW-23 Clss lll Chloromethane 30 pg/t 50%l5 Ug/L 5.7 Ug/L
fire GWCL proposed is based on the Permit GWCL for Clas lll
uater. According to the flowchart, it should be the mean plus tw
:lrn.ter.l rlpvirtions - 5 7 !d/L
MW-23 Class lll Fluoride 4 mg/L 90.9%0.7 mg/L 2mglL
i6e GWCL proposed is based on the mean plus two standard
leviations. Accolding to lhe flowchart, it should be the greater ol
he fraclion ol the standard or the highest historic value. The
SWCL should be 2 ms/L (fraction of lhe GWOS).
MW-23 Class lll pH (s.u.)6.5 - 8.5 t00%5.8 - 8.5 6.5 - 8.5
The GwcLproposed is based on the mean minus 20%. With
he lowest obserued value (6.9) being within the range of the
}WQS. the GWCL should be sel at as the GWQS - 6.5 - 8.5.
MW-23 Class lll Sullate TBD 100%2,669 mg/L 2,524m91L
lhe GWCL proposed is based on the mean plus 20%.
\ccording to lhe llowchart, DUSA should consider a modilied
lpproach to set a GWCL. However, setting the GWCL at the
nean plus 20% is not protective of human health aM the
)nvironmental. lt would be more appropriate to set the GWCL a
he mean plus lwo standard deviations - 2,524 mg/L
*frd ;ffi- 8"" !il$s:
MW-24 Class lll Tin 1 7,000 Fg/L 1009/"None 8,500 fg/L )USA lailed to provide a GWCL lor Tin in MW-24. Since the Tir
)oncentrations in MW-24 has been '100% nondeiect' the GWCL
vill be set at lhe lraction GWQS for Class lllwater - 8,500 Ug/L.
MW.24 Class lll Uranium 30 !g/L 100%36 uq/L 1 1.9 !g/L
)USA lollowed the llowchan correcry Dy setrlng me uwuL at
he mean plus two slandard deviations. However, DUSA lailed
o remove an outlier (46 ug/L) belore calculating the GWCL.
\hor ram^vind tha orflier the GWCL is 11.9 uo/L.
MW-24 Class lll Fluoride 4 mg/L 100"/.0.3 mg/L 0.36 mg/L
fne GWCL proposed is based on the mean plus 20%. Accordin(
o the llowchart, it should be the mean plus two standard
{6r,i.ri^n.-deAh^/l
MW-24 Class lll pH (s.u.)6.5 - 8.5 100%5.7 - 8.5 6.5 - 8.5
the GWCL proposed is based on the mean minus 2070. wllh
:he lowest observed value (6.9) being within the range of the
3wOS. the GWCL should be set at as the GWOS - 6.5 - 8 5.
MW-24 Class lll Sullaie TBD I 000/.3,113 mg/L 2,903 mg/L
lhe GWCL proposed is based on the mean plus 20'l". Accordin(
o the flowchart, it should be the mean plus two standard
teviaiions - 2.903 mo/L.
MW-24 Class lll TDS TBD 100%4,932 mEL 4,450 mgr'L
fhe GWCL proposed is based on the mean plus 20%. Accordin(
o lhe flowchart, it should be the mean plus two standard
'lFvietions - 4 450 mo/L.
MW-25 Class lll'Ammonia 25 mglL 100%0.8 mq/L 0.77 mgy't
)USn coirectty uased the proposed GWCL on the mean plus
wo standard deviations. However, the GWCL was calulated
rcnrrecJlv the GWCL should be 0.77 mo/L.
MW.25 Class lll'Nitrate + Nilrite
(as N)10 mg/L o"/"2.5 mg/L 5 mgy'L
)usA followed lhe llowcnan correcny Dy serung tne UYYUL at
he fraction of the GWOS (25'l") for Class ll water- However,
iince manganese is above the GWQS in MW-25, it changes the
:roundwatel Prolstion Levelto Clas lll in this well. Therelore,
he GWCL will be set al 50% of the GWQS for Class lllwater - 5
no/L-
MW-25 Class lll-Arsenic 50 gg/L oo/"12.5 Ug/L 25 ug/L
)USA followed the flowchari correctly by setling the GWCL at
he fraction ol the GWOS (25%) tor Class ll water. However,
;ince manganese is above the GWQS in MW-25, it changes lhe
Sroundwater Protection Level to Class lll in this well. Thefelore,
he GWCL will be set al 50% of lhe GWOS foI Class lllwater -
MW-25 Class lll'Beryllium 4 udL o/"1 uyL 2vglL
fuSA tollowed the flowchart correctly by setting the GWCL al
he fraction ol the GWQS (25%) lor Class ll water. However,
iince manganese is above the GWOS in MW-25, il changes the
iroundwater Protection Level to Class lll in this well. Thelefore,
he GWCL will be set at 50% of the GWQS tor Class lll water - 2
MW-25 Class lll'Cadmium 5 uq/L 100%1.7 Ug/L 1.5 ug/L
ihe GWCL proposed is based on the mean plus 20%. Accordin(
o lhe flowcharl, it should be the mean plus two standard
lavialidns- 1 Srrd/l
MW-25 Class lll'Chromium 10O Ug/L eh 25 us/l-50 [g/t
)USA followed the flowchart correctly by setting the GwuL al
he fraclion of the GWQS (25%) lor Class ll water. However,
iince manganese is above the GWQS in MW-25, il changes the
iroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS for Class lll water -
MW-25 Class lll'Cobalt 730 Ug/L 72.7"k 182.5 ug/L 365 ug/L
IUSA lollowed lhe aowcnan correcny oy setrlng lrE uvYuL at
he fraction of the GWQS (25%) lor Class llwaler. However,
;ince manganese is above the GWQS in MW-25, it changes lhe
Sroundwaler Protection Level to Class lll in this well. Theretore,
he GWCL will be set at 50% ol the GWOS for Class lll water -
. Revlslons to Proposed GWCLS
Well
Protection
Level Paramelel GWOS
Percentage
Detects
DUSA Proposed
GWCL
DRC Revlsed
GWCL Commenl
MW-25 Class lll'Copper 1,300 Ug/L o"/.325 ggA 650 us/L
rubA roilowed lhe tiowchart correcfly by setting lhe GWCL al
he lraction of the GWOS (25%) for Ctass llwaler. However,
;ince manganese is above the GWQS in MW-25, il changes the]roundwater Protection Level to Class lll in lhis well. Therelore
he GWCL will be set at 50% of lhe GWQS for Class lllwater -
)50 u0/1.
MW-25 Class lll'lron 1 1,000 gg/L o7.2,750 tlglL s,500 pg/L
JUSA roloweo the flowchart correcily by setting the GwcL athe fraclion ol the GWQS (2S%) tor Class ll water. However,
;ince manganese is above the GWQS in MW-25, it changes theiroundwater Protection Level to Class lll in this well. Therelore,
he GWCL wiil be set at 50% of the GWOS for Class lllwater -
;,500 xs/L.
MW-25 Class lll'Lead 1 5 Ug/L o/"3.75 pg/t 7.5 USA
ruoA rorowfl rne lowcnan corredty Dy sening the GwcL al
he fraction of the GWQS (25%) for Ctass ll water. However,
;ince manganese is above the GWQS in MW-25, it changes thefroundwaler Protection Level to Class lll in this well. Theretore,
he GWCL will be set at 50% of the GWOS for Ctass lltwaler -
'.5 uq/L.
MW-25 Class lll'Manganese 800 Ig/L '1000/.2,037 VgtL 1,806 trgA
I he GWCL proposed is based on the mean plus 2O%. ACcordinl
ro the flowchart, it should be the mean plus two standard,evialions - 1,806 !g/L. With manganese being above the
SWQS in MW-25, it changes the Groundwater protection Levelo Class lll in this well.
MW-25 Class lll'Mercury 2 tS/L o./"0.5 Uq/L I [q/L
JUoA roloweo rne lowcnan correcity by selting the GwcL athe fraction of the GWQS (25%) tor class llwater. However,
;ince manganese is above the GWQS in MW-2S, it changes lheiroundwater Protmlion Level to Ctass lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS ror Class illwater - 1
rO/L.
MW-25 Class lll'Molybdenum 40 Bg/L 100%l2tglL 20 pglL
I he GWCL proposed is based on the hiohest historical value.
\ccording lo the flowcharl, it should be the greater of the fraction
)f lhe slandard or the highesl historic value. The GWCL shoutdE 20 uo/L (lraclion of the GWOSI
MW.25 Class lll'Nickel 100 Ug/L oo/"25 uq/L s0 ug/L
JUSA foflowed the flowchart correctly by setting theGwe L at-he fraction of the GWQS (25%) lor Ctass llwater. However,
;ince manganese is above the GWQS in MW-25, it changes theiloundwater Protstion Level to Class lll in this well. Therefore.
he GWCL will be set at 5O% of the cWeS tor Ctass il water -
;0 lrdll
MW-25 Class lll.Selenium 50 ug/L o./"12.5 Ug/L 25t!Sl\
DUSA rolowed the ftowchart correcfly by setting the GWCL at
:he fraction ol the GWQS (25%) for Class ltwaler. However,
;ince manganese is above the GWeS in MW-2S, il changes the3roundwater Protection Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of lhe GWQS for Class lll water -
25 uc/L.
MW-25 Class lll'Silver 100 ug/L oyo 25 rglL 50 sg/t
JUSA lollowed the llowcharl corecty by setting the GWoL athe fraclion ot lhe GWQS (25%) for Class ll water. However,
;ince manganese is above the GwQs in Mw-25, it changes lhefroundwater Protstion Level to Class lll in this well. Therefore.
he GWCL will be set al 50% of the GWOS ,or Ctass il water -
io uq/L.
MW.25 Class lll'Thallium 2tglL 100v"1.2 ltglL 1.1 ug/L
he GWCL proposed is based on the mean plus 202. Accordir4
o the tlowchart, it should be the mean plus two standard
leviations - 1.1 uo/L
MW-25 Class lll'Tin 17,000 ug/L 100y"None 8,500 us/L )USA lailed to provide a GWCL for Tin in MW-25. Since the Tin)orcentrations in MW-25 has been IOO% nondetecl, the GWCL
vill be set at the fraction GWQS for Class lll water - 8.5oo [d/t
MW-25 Class lll'Uranium s0 Ugr'L 1000/0 7.1 uq/L 6.5 ttg/L
rne GwuL proposed is based on the mean plus m%. Accordin(
o the flowchart, it should be lhe mean plus two standard
,evialions - 6.5 uo/1.
MW-25 Class lll'Vanadium 60 Ug/t 0/"l5 Bg/L 30 !g/L
,uSA lollowed the flowchart cotrecily by setting the GWCL alhe fraction ol the GwQs (25%) lor class ll water. However,
iince manganese is above the GWQS in Mw-25, it changes the3roundwater Protection Level to Class lll in this well. Thirefore,
he GWCL will be set at 50% of the GWQS tor Class lllwater -
l0 us/1.
MW.25 Class lll'Zinc 5,000 gg/L 1oyo 1,250 Uq/L 2,s00 pg/L
JUSA toilowed the llowchart correctly by setting lhe GWCL athe fraction ol the GWQS (25%) lor Ctass llwater. However,
;ince manganese is above the GWQS in MW-2S, it changes the]roundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS for Class l[ waler -
1,500 uo/L.
MW-25 Class lll'Gross Alpha l5 pCi/L 2Ao/o 3.75 DC|/L 7.5 pCi/L
JUSA tollowed the flowchart correctly by setting the GWCL athe fraction of the GWQS (2S%) for Ctass llwater. However,
iince manganese is above the GWOS in MW-25, it changes theiroundwaler Protection Level to Class lll in this well. Therelore,
he GWCL will be set at 50% ot the GWQS lor Class Il waler -
2.5 pci/1.
Table 1 - Revisions to Proposed GWCLS
Well
Protection
Level Parameter GWOS
Percentage
Iletects
DUSA Proposed
GWCL
DRC Revlsed
GWCL Comment
MW-25 Class lll'Acetone 7@ uq/L o"/"175 ug/L 350 rg/L
he traction of the GWQS (25%) lor Class ll water. However,
iince manganese is above the GWQS in MW-25, it changes lhe
]roundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Class lllwater -
MW.25 Class lll.Benzene 5 us/L o"/"1.25 ug/L 2.5rglL
)USA lollowed the flowchart correclly by setting the GwoL al
he kaction of the GWQS (25%) lor Class ll water. However,
;ince manganese is above the GWQS in MW-25, it changes lhe
iroundwater Proteclion Level to Clas lll in lhis well. Therefore,
he GWCL will be set al 50% of the GWQS for Class lll water -
MW-25 Class lllt 2-Butanone
(MEK)4,000 udL o"/"1,000 ug/L 2,000 Ug/L
)USA lollowed the llowchan cofiefily 0y senlng tne uwuL aI
he fraction of the GWQS (25%) for Class llwater. However,
;ince manganese is above the GWQS in MW-25, it changes the
iroundwater Protection Level to Class lll in this well. Therelore,
he GWCL will be set at 50% ot the GWQS foI Class lll watel -
MW-25 Cl6s lll'Carbon
Tetrachloride 5 pdL e/.1.25 uo/L 2.5 ug/L
)USA followed the llowchart correclly by setting the GwcL al
he fraction ol the GWQS (25%) foI Class llwaler. However,
;ince manganese is above the GWQS in MW-25, it changes the
Sroundwater Proteclion Level to Class lll in this well. Therelore,
he GWCL will be set at 50% ot the GWQS tor Class lll water -
MW-25 CIass lll'Chlorolorm 70 ug/L 0L 17.5 Ug/L 35 Ug/l-
)USA lollowed the llowchan correclly oy setrlng lne uwuL al
he fraction ol the GWQS (25%) for Class llwaler. However,
iince manganese is above the GWOS in MW-25, it changes the
iroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Class lll water -
MW-25 Class lll'Chloromethane 30 ug/L 400 7.5 UgiL 1 5 ug/L
DUSA followed the flowchart correctly by seltrng the uwuL at
lhe fraction of the GWQS (25%) lor Class ll water. However,
since manganese is above the GWQS in MW-25, it changes the
Groundwater Protection Level lo Class lll in this well. Therefore,
the GwcL will be set at 50% of the GWQS for Class lll water -
15 uo/L.
MW-25 Class lll'Dichloromethane 5 udL o./.1.25 ug/L 2.5 [g/L
)USA followed the flowchart correctly by setting the GWCL at
:he fraclion ol lhe GWQS (25%) lor Class ll water. However,
since manganese is above the GWQS in MW-25, it changes the
Groundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS for Class lll water -
MW.25 Class lll'Naphthalene 100 us/L oq"25 pglL 50 us/L
)USA followed lhe flowchart correclly by setting the GWOL at
he lraction of lhe Gwos (25%) ,or class ll waterwater.
lowever, since manganse is above the GWQS in MW-25, it
)hanges the Groundwater Protection Level to Class lll in this
flell. Therefore, the GWCL will be set at 50% of the GWOS fol
llass lll water - 50 uo/L.
MW-25 Class lll'Tetrahydrofuran
(THF)46 us/L ov"'I 1.5 ug/L 23 Ug/L
)USA followed lhe flowchan corlectly 0y senlng lne uwuL ar
he lraclion of the GWOS (25%) for Class llwaler. However,
iince manganese is above the GWQS in MW-25, it changes the
iroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set al 50% of the GWQS for Class lll water -
MW-25 Class lll'Toluene 'l,000 [g/L 250 Bg/L 500 Ug/L
)USA lollowed the tlowchart correclly by setting lhe GwcL al
he lraction of the GWQS (25%) for Class llwaler. However,
;ince manganese is above the GWQS in MW-25, it changes the
lroundwater Proteclion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Class lllwaler -
MW-25 Class lll'xylenes (total)10,000 Ug/L o%2,500 us/L 5,000 Ug/L
fusA lollowed tne nowcnan correqly Dy setrrng Ine UYYUL ar
he kaction of the GWOS (25%) foI Class ll water. However,
;ince manganese is above the GWQS in MW-25, it changes the
3roundwaler Protection Level to Class lll in this well. Therefore,
rhe GWCL will be set at 50% ol the GWOS for Class lllwater -
5 O00 uo/L.
MW-25 Class lll'Chloride TBD 100%38.8 ms/L 35 mg/L
fhe GWCL proposed is based on the mean plus 20%. Accordin!
o the flowchart, it should be the mean plus two standard
leviations - 35 mo/L.
MW-25 Class lllt Fluoride 4 mg/L 1 000/.I mg/L 0.42 mg/L
The GWCL proposed is based on the mean plus 20%. Accordin!
to lhe llowchart, it should be the mean plus two standard
d^',iari^h.-nlrm^/l
MW-25 Class lll'pH (s.u.)6.5 - 8.5 100%5.8 - 8.5 6.5 - 8.5
-he GWCL proposed is based on the mean minus 20%. with
he lowest obssved value (6.9) being within the range ol the
;wos. the GWCL should be sel at as the GWQS - 6.5 - 8.5.
MW-25 Class lll'Sulfate TBD 100%2,075 ms/L 1,933 mgL
the GWCL proposed is based on the mean plus 20%. Accordin(
o the llowchart, it should be the mean plus two standard
laviiti^n<-tqmmn/l
Table'l - Revislons lo Proposed GWCLS
Well
Protectiorl
Level Parameler GWOS
Percentage
Oetects
DUSA Proposed
GWCL
DRC Revlsed
GWCL Comment
MW-25 Class lll'TDS TBD 100v"3,411 mg/l-2,976mslL
the GWCL proposed is based on the mean plus 20%. According
o the flowcharl, it should be the mean plus two standard
ievialions - 2,976 mo/L.
MV'l-27 Class lll'Ammonia 25 mglL 14v"6.25 mg/L 12.5 mg/L
uusA rolowed the lowchart correcfly by setting the GWCL al
the fraction of the GWQS (25%) tor Class llwater. However,
since uranium is above lhe GWQS in MW-27, it changes the
Groundwaler Protection Level to Class lll in lhis well. Therefore,
the GWCL will be set at 50% of the GWQS lor Ctass lll water -
12.5 ms/1.
MW-27 Class lll'Nitrate + Nitrite
(as N)l0 mg/L 100./.6.1 mg/L 5.6 mgiL
I he GWCL proposed is based on the mean plus 20%. Accordin(
o the rlowchart, it should be the mean plus two standard
,eviations - 5.6 mo/L
MW-27 Class lll'Arsenic 50 Ug/L o"/.12.5 !g/L 25 !g/t
)usA toilowed the ftor,i'chart corectly by setting tne GW-L at
he fraction of the GWQS (25%) tor Ctass llwater_ However,
iince uranium is above the GWOS in MW-27, il changes lhe
iroundwater Protection Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Ctass lllwater -
15 uo/1.
MW-27 Class lll*Beryllium 4 VS|L o/"1 Ug/L 2lglL
)USA lollowed tho flowcharl correctly by setting the GWCL at
he fraction ol the GWOS (25%) for Class llwater. However,
iince uranium is above the GWOS in MW-27, it changes lhe
Sroundwaler Protection Level to CIass lll in this well. Therefore,
he GWCL will be sel al 50% of the GWOS tdr Ctass ilt water - 2
rS/L.
MW-27 Class lll'Cadmium 5 ug/L oyo 1.25 Ug/L 2.5 ttslL
JU5A toilowed the ilowchart correcfly by setting the GWCL at
he fraction of the GWQS (25%) for Class il water. However,
;ince uranium is above lhe GWQS in MW-27, it changes the
iroundwaler Protfftion Level to Class lll in this well. Therefore,
he GWCL will be set al 5,0% of th€ GWOS ,or Ctass ilt waier -
1.5 uo/L.
MW-27 Class lllt Chromium 1 0O Ug/L o%25 Ug/L 50 uq/L
JUSA roiloweo rne flowchart correcily by sening the GWCL at
he lraciion of the GWOS (25%) for Class ll water. However,
iince uranium is above the GWQS in MW-27, il changes the
sroundwaler Prot*tion Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of the GWQS tor Ctass lll waler -
i0 uc/1.
MW-27 Class lU'Coball 73O trg/L 0.0%182.5 Uq/L 365 us/L
)USA tollowed the flowcharl correcfly by setting the GWCL at
he lraclion ot the GWQS (25%) lor Class il water. However,
;ince uranium is above lhe GWQS in MW-27, il changes the
froundwater Protslion Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of the GWQS for Ctass lll water -
|65 uo/L.
MW-27 Class lll'Copper 1,300 Ug/L o./.325 us/L 650 Ug/L
JUI,A lollowed the flowchart correcfly by sening the GWCL at
he lraction ol the GWOS (25%) for Class ll water. However,
iince uranium is above lhe GWQS in MW-27, il changes the
Sroundwaler Protmlion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS tor Class lll water -
;50 uo/L
MW-27 Class lll'lron I 1,000 uo/L 0"/"2,750 ttglL 5,500 Ug/L
JUSA loltowed the ftowcharl correctly by sefling the GWCL al
he lraction ol the GWQS (25%) tor Ctass ll water. However,
iince uranium is above the GWQS in MW-27, it changes the
iroundwater Prot*lion Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of the GWQS tor Class lll water -
t,500 us/L.
MW-27 Class lll'Lead 1 5 Ug/L o%3.75 us/L 7.5t glL
UUSA lollowed the flowchart correctly by sefling the GWCL al
the fraclion of the GWOS (25%) tor Ctass ll waler. However,
since uranium is above lhe GWQS in MW-27, il changes the
Groundwater Protection Level to Class lll in this well. Therefore,
the GWCL will be sel at 50% ot the GWQS lor Class ill water -
7.5 uq/L.
MW-27 Class lll-Manganese 800 !g/L oo/"200 Ug/L 400 !g/L
JUSA lollowed the flowcharl correctly by setting the GWCL athe fraction ol the GWQS (25%) for Class llwaler. However,
iince uranium is abov€ the GWQS in MW-27, it changes the
]rouMwater Prolection Level to Class lll in this well. Therelore,
he GWCL will be set at 50% of the GWOS for Ctass l[ water -
100 uc/1.
MW-27 Class lll'Mercury 2 yglL ov"0.5 ug/L 1 IS/L
JUUA roilowed the fiowchart correcily by setting lhe GWCL at
he fraction of the GWQS (25%) lor Class ll waler. However,
iince uranium is above the GWQS in MW-27, it changes the
iroundwaler Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWeS lor Class iltwater - 1rdL.
MW-27 Class lll'Molybdenum 40 Ug/L oq"10 pgiL 20 gg/L
JUSA roilowed the flowchart correcily by setting the GWCL athe traction ol the GWQS (25%) for Class I water. However,
;ince uranium is above the GWQS in MW-27, it changes thefroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS for Class lltwater -
l0 uo/L.
Table 1 - Bevlsions to Proposed GWCLS
well
Prolection
Level Parameler GWOS
Percenlage
Detecls
DUSA Proposed
GWCL
DRC Revlsed
GWCL Commenl
MW-27 Class lll'Nickel lm pg/L oy"25 gg/t 50 Ug/L
)usA lollowed the flowchan corredly Dy se[lng me uwul aI
he fraction of the GWOS (25'l") for Class llwaler. However,
iince uranium is above the GWOS in MW-27, il changes lhe
iroundwater Protection Level to Class lll in this well. Thelelore,
he GWCL will be set at 50% ol the GWQS for Class lll water -
MW-27 Class lll'Selenium 50 Ug/L 100%12.5 Ug/L 2s pg/L
)USA lollowed the tlowchart correctly by setting the GwCL at
he fraction of the GWOS (25%) lor Class llwater. However,
iince uranium is above the GWQS in MW-27, it changes lhe
iroundwaler Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS for Class lll waler '
MW-27 Class lll'Silver 100 Ug/L oy"25 Ug/L 50 ug/L
)USA followed the flowchart correctly by setting the GWCL at
he rraction ol the GWOS (25%) for Class llwaler. Hffiever,
;ince uranium is above lhe GWQS in Nrw-27, it changes the
Sroundwaler Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS lor Class lll waler -
MW-27 Class lll'Thallium 2 UYL oo/"0.5 ug/L I ug/L
)USA lollowed lhe flowchan corredly Dy senmg tne uwul al
he fraction of lhe GWQS (25%) for Class llwater. However,
iince uranium is above the GWOS in MW-27, it changes lhe
3roundwater Protection Level to Class lll in lhis well. Thelelore,
:he GWCL will be set at 50% of the GWQS for Class lll water - 1
MW-27 Class lll'Tin 1 7,000 ug/L 100%None 8,500 pg/L )USA failed to plovide a GWCL for Tin in Mw-27. Snce the Tin
)oncenlrations in MW-27 has been 10O'/" nondetect, the GWCL
Mill he set at the fraction GWOS lor Class lllwater - 8.500 uc/L.
MV't-27 Class lll'[Jranium 30 udL 'too%37.7 pgtL 34 udL
fhe GWCL proposed is based on the mean plus 20%. According
o the tlowcharl, it should be the mean plus two standard
ieviations - 34 Ug/L. With uranium being above lhe GWOS in
r,lw-27, it changes the Groundwaler Protection Levelto Class lll
MW-27 Class lll'Vanadium 60 trg/L oo/"1 5 Ug/L 30 Ug/L
)USA lollowed the flowchart correctly by setting the GwCL at
he lraction ol the GWQS (25%) for Class llwater. However,
iince uranium is above the GWOS in MW-27, it changes the
iroundwaler Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS for Class lll water -
MW-27 Class lll'Zi,nC 5,000 Ug/L o"/"1,250 uO/L 2,500 pg/L
)USA followed the flowchart cotreclly by settlng the GwuL at
he fraction of the GWQS (25%) for Class ll water- However,
iince uranium is above the GWQS in Mw-27, it changes the
lroundwater Protstion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWOS lor Class lllwater -
MW-27 Class lll'Acetone 700 Ug/t oy"175 uq/L 350 uq/L
)USA lollowed the flowcharl correctly by setting the GwCL at
he fraction ol the GWQS (25'ld lor Class llwater. However,
iince urmium is above the GWQS in MW-27, il changes the
iroundwaler Protstion Level lo Class lll in lhis well. Therefore,
he GWCL will be set al 50% of the GWQS for Class lllwaler -
MW-27 Class lll'Benzene 5 udL o%1.25 uq/L 2.5 ug/L
)USA tollowed lhe flowchart correctly by settrng lhe GwuL at
:he lraction of the GWQS (25%) for Class llwater. However,
lince uranium is above the GWOS in Mw-27, it changes the
3rouMwater Protstion Levello Class lll in this well. Theretore,
:he GWCL will be set at 50% of the GWQS for Class lllwater -
2-5 uo/L.
MW-27 Class lll'2-Butanse
(MEK)4,000 uqA 0%1,000 ug/L 2,000 Ug/L
)USA tollowed the flowchart cotreclly by sentng tne GWUL at
he lraction of the GWOS (25%) for Class ll waler. However,
;ince uranium is above the GWQS in MW-27, it changes the
iroundwater Proltrtion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Class lllwater -
, OOO rd/l
M\ t-27 Class lll'Carbon
Tetrachloride 5 udL o"/"1.25 ttglL 2.5 [g/L
)usA followed the flowchan corrstly by se[lng lne UVYUL al
he fraction ol the GWQS (25'ld for Class llwater. However,
)ince uranium is above the GWQS in MW-27, il changes the
iroundwater Protetion Levelto Clas lll in this well. Therelore,
he GWCL will be set at 50% of the GWQS for Class lll water -
) q il6/l
MW-27 Class lll-Chlqoform 70 trg/L o/.17.5 BgiL 35 us/L
)USA lollowed the flowchan cotreclly by setlng lhe uwuL aI
he fraction of the GWQS (25%) for Class ll water. However,
iince uranium is above the GWos in Mw-27, it changes the
iroundwaler Protection Level lo Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS lor Class lllwaler -
Table 1 - Fevlslons to Proposed GWCLS
Well
Protectlon
Level Parametel GWOS
Percenlage
Detects
DUSA Proposed
GWCL
DRC Revlsed
GWCL Comment
MW-27 Class lll'Chloromethane 30 ug/L 44.40/"7.5 pg/L 15 us/L
JUDA TOilOWW tne rOWCnan Correcfly Dy Sentng the GwuL al
he fraclion of lhe GWQS (25%) for Class il water. However,
;ince uranium is above the GWQS in MW-27, il changes the
froundwater Prolection Level lo Class lll in this well. Therefore,
he GWCL will be sel at 50% ot the GWQS lor Class ill water -
5 udll
MW-27 Class lll'5lidl oo/1.25 Ug/L 2.5 Ug/L
)USA lollowed the llowchart correclly by selting the GWCL at
he fraction of the GWOS (25%) for Class llwater. However,
iince uranium is above lhe GWOS in MW-27. it chanoes the
iroundwaler Protection Level to Class lll in this well. Therelore,
he GWCL will be set at 50% ol the GWOS for Ctass lll water -
1.5 uoiL.
MW-27 Class lll'Naphthalene 100 pg/L o"/"2s pg/L 50 !g/L
IUSA lollowed the flowchart corectly by sefling the GWCL at
he lraction ot the GWQS (25%) lor Class il water. However,
;ince manganese is above the GWQS in MW-25, il changes lhe
Sroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set al 50% of lhe GWQS lor Ctass lllwater -
i0 uq/L.
MW-27 Class lll'Tetrahydrofuran
(THF)46 us/L o"/"'l '1.5 Ug/L 23 pg/L
)USA followed the flowchart correctly by setting the GWCL at
he lraction of the GWOS (25%) for Ctass ll water. However,
;ince uranium is above the GWOS in MW-27, it changes the
iroundwater Prolection Level to Class lll in this well. Therefore,
he GWCL will be set at 50o/o of the GWOS for Ctass It water -
l3 uc/L.
MW-27 Class lll'Toluene I,000 us/L o%250 gg/L 500 ug/L
DUSA tollowed the flowchart correctly by setting the GWCL al
:he fraction of the GWQS (25%) lor Ctass il water. However,
;ince uranium is above lhe GWQS in MW-27, it changes the
3roundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWOS for Ctass lll water -
i00 uq/L.
MW-27 Class lll'Xylenes (Total)10,000 Ug/L ooa 2,500 Ug/L 5,000 Uq/L
)USA lollowed lhe flowcharl correctly by setting the cWCL at
he fraclion ol the GWQS (25%) for Class ll water. However,
iince uranium is above the GWOS in MW-27, il changes the
iroundwater Prolection Level lo Class lll in this well. Therefore
he GWCL will be set al 50% ol the GWOS tor Ctass lllwater -
i.000 uc/L.
MV't-27 Class lll'Chloride TBO 'looo/o 41.6 mg/L 38 mg/L
fhe GWCL proposed is based on lhe mean plus 20%. Accordin(
o the llowcharl, it should be the mean plus two slandard
,eviations - 38 mo/L
MW-27 Class lll'Fluoride 4 mglL loo./"1 ms/L 0.85 mg/L
The GWCL proposed is based on the Permit GWCL for Ctass lllvattr. According to the llffichart, it should be the mean plus tw(
itandard de-vialions - o Rs mo/l
MW-27 Class lll'pH (s.u.)6.5 - 8.5 100%8.5 6.5 - 8.5
Ihe GWCL proposed is based on the mean minus 20%. Wilh
he lowest observed value (7.4) being within the range ol lheiwos, rhe GWCL shoutd be set at as the GwQs - 6.5 - 8.5.
MW-27 Class lll'Sullate TBD 100"/"486 mg/[462mglL
he GWUL proposed is based on lhe mean plus 20%. Accordin(
o the flowchart, il should be lhe mean plus two standard
leviations - 462 mo/L-
MV'l-27 Class lll-TOS TBD 1 00%1,223 ngll 1,075 mq/L
-he GWCL proposed is based on the mean plus 20%. Accordin(
o the flowchart, it should be the mean plus two slandard
leviations - 'l 075 md/l
MW-28 Class lll Tin 17,000 Ug/L 100v"None 8,500 pg/L )USA failed to provide a GWCL for Tin in MW-28. Since the Tir
)oncentralions in MW-28 has been 100% non-detect, the GWCL
vill be set at the fraction GWOS Ior Class lll wrtar - R qnn "d/l
MW-28 Class lll Chloromethane 30 Ug/L 54.5y.1 5 Ug/L 4.6 Ug/L
rne GWUL proposed E based on the Permit GWCL for Class lllvaler. According to the lloM/chart, it should be the mean plus tw
ilandard devialions - 4.6 uo/1.
MW.28 Class lll Chloride TBD 100yo 107 mg/L 105 ms/L
lhe GWCL proposed is based on the mean plus 20%. Accordin(
o the llowchart, it should be the mean plus two standard
leviaiions - 105 mo/t
MW-28 Class lll Fluoride 4 mg/L 1000/.2mg/L 0.73 mg/L
the GWCL proposed is based on the Permil GWCL tor Class m
valer. According to the flwchart, it should be the mean plus tw(
ilandard de-viations - 0 73 mn/l
MW-28 Class lll pH (s.u.)6.5 - 8.5 100%5_4 - 8.5 6.1 - 8.5
I he GWCL proposed is based on the mean minus 20%. With
:he lowesl observed value (6.3) being below the range of the
3WQS, the GWCL should be set on lhe basis of the mean minur
wo standard deviations - 6.1 - g 5
MW-28 Class lll Sulfate TBD 100%2,833 mg/L 2,533 mg/L
fhe GWCL proposed is based on the mean plus 20%. Accordin(
o the tlowcharl, it should be the mean plus two standard
levialions-25i3m6/l
MW-28 Class lll TDS TBD 100%4,413myL 3,852 mg/L
I he GWCL proposed is based on the mean plus 20%. Accordine
o lhe flowchart, il should be the mean plus two slandard
,eviations - 3.852 mo/L
MW-29 Class lll Tin 17,000 [gil 100%None 8,500 Ug/L )USA failed to provide a GWCLlor Tin in MW-29. Since the Tin
)oncentrations in MW-29 has been 100% non-detect, the GWCL
vill be set at the ,raction GWQS lor Class lllwater - 8.500 uo/L.
Table 1 - Bevlslorls to Proposed GWCLS
Well
Protection
Level Parameter GWOS
Percentage
D,etects
DUSA Proposed
GWCL
DRC Bevised
GWCL Comment
MW-29 Class lll Manganese 800 rgiL 100%6,033 [g/L 5,624 uo/L
l'he GWCL proposed is based on the mean plus 20%. Accordin(
o the llowchart, it should be the mean plus two standard
{6r,iati^h. - < Arl',^/l
t\4w-29 Class lll Chloride TBD 1 00"/"46 mg/L 41 mg/L
Ihe GWCL proposed is based on the mean plus 2070. Accordrn(
o lhe flowcharl, it should be the mean plus two standard
leviaiions - 41mo/L-
MW-29 Class lll pH (s.u.)6.5 - 8.5 100%5.6 - 8.5 6.46 - 8.5
-he GWCL proposed is based on lhe mean minus 20%. With
he lowest obserued value (6.5) being at the lower range of the
)WQS, the GWCL should be set on the basis ol the mean minu
,^,^.r'6d.d d6vi.ti^6c - A 1A - e E
MW-29 Class lll Sulfate TBD 100%3,342 mgiL 2,946 mg/L
"he GWCL proposed is based on the mean plus 2O%. Accordrn(
o the flowchart, it should be the mean plus two standard
leviations - 2.946 mc/L.
MW-30 Class ll Nitrate r Nitrite
(as N)l0 mg/L 100%16.7 mg/L 2.5 mg/L
the GWGL proposed is based 0n the mean plus 20%. However,
ntera concludes in Strtion 2.54 ol the Background Report that
he Nitrate + Nitrte (as N) lound in MW-30 is associated with lhe
)n-site chloroform contamination. Since this Nitrate + Nitrte (as
'l) contamination is associated with the on-site chloroform
:ontamination, il is a man-made contaminant; therefore,
)ackground should not be set above the lraction ol the GWQS -
MW-30 Class ll Tin 1 7,000 Ug/L 100%None 4,250 [g/L )USA lailed to provide a GWCL for Tin in MW-30. Since the Tin
)oncentraliore in MW-30 has been 100% nondetect, the GWCL
vill be sel at lhe fraciion GWOS lor Class lll water - 4.250 uo/L-
MW-30 Class ll Uranium 30 Ug/L 100%8.5 UgiL 8.32 Ug/L
Ihe GWCL proposed is based on the mean plus 2070. A@ordrn(
o the flowchart, it should be the mean plus two standard
,eviations - 8.32 uo/L.
MW-30 Class ll Chloride TBD 1001"150 ms/L 128 mg/L
l'he GWCL proposed is based on the mean plus 20%. Accordin(
o the llowchart, it should be the mean plus two standard
ie-viations - 128 uo/L
MW-30 Class ll Fluoride 4 mg/L 100%1 mg/L 0.51 mg/L
the GWCL proposed is based on lhe Permit GWCL for Class lll
ilater. According to the flowchart, it should be the mean plus tw
:r-nd.ri d6vi.ii^^. - 6 Cl m^/l
MW-30 Class ll pH (s.u.)6.5 - 8.5 100%5.9 - 8.5 6.5 - 8.s
The GWCL proposed is based 0n the mean mrnus 2o7o. wrth
the lowest obserued value (6.9) being within the range ol the
GWOS. the GWCL should be set at as the GWQS - 6.5 - 8.5.
MW-30 Class ll Sullate TBD r00%1,060 mg/L 972m}/L
fhe GWCL proposed is based on the mean plus 2o%. Accordine
:o the llowcharl, it should be the mean plus two stildard
leviations - 972 mc/1.
MW-30 Class ll TDS TBD 100%2,094 mgr'L 1,918 mq/L
lhe GWCL proposed is based on the mean plus 20%. Accordin(
o lhe llowchart, il should be lhe mean plus two standard
la,i.ti^hc - I OIA h^/l
MW-31 Class lll'Ammonia 25 mg/L 14.3/"6-25 mg/L 12.5 mg/L
DUSA lollowed the flowchart correctly by setting the GwCL at
he fraction of the GWOS (25%) lor Class llwater. Horever,
since selenium is above the GWQS in l\4W-31 , it changes the
Groundwater Protection Level to Class lll in this well. Therefore,
the GWCL will be sel at 50% of the GWQS for Class lll waler -
12 \ rdll
MW-31 Class lll'Nitrate + Nitrite
(as N)10 mg/L '100%2A.7 mslL 5 mg/L
fhe GWCL proposed is based on the mean plus 2070. However,
ntera concludes in Section 2.54 ol the Background Report lhal
he Nitrale + Nitrte (as N) f@nd in MW-31 is associated with lhe
)n-site chlorotorm contamination. Since lhis Nitrate + Nitrte (as
.l) contamination is associated with the on-site chlorolorm
)ontamination, it is a man-made conlaminant; therelore,
)ackground should not be set above the lraction ol the GWQS -
MW-31 Class lll'Arsenic 50 Ug/L o/"12.5 Ug/L 25 rglL
)USA lollowed the llowchart coilectly by setting the GwCL al
he fraction of the GWQS (257d for Class llwater. However,
rince selenium is above the GWQS in MW-31, it changes the
iroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be sel at 50% ol the GWOS lor Class lllwater -
MW-31 Class lll'Beryllium 4 udL ov"1 us/L 2rgtL
)USA lollowed the llowchart cotreclly by selting the GWCL at
he fraction of the GWQS (25%) for Class ll water. However,
iince selenium is above lhe GWQS in MW-31, it changes the
iroundwater Protection Level to Class lll in lhis well. Therelore,
he GWCL will be set at 50% ol lhe GWQS lor Class lllwater - 2
MW-31 Class lll'Cadmium 5 udL ov"1.25 Ug/L 2.5 us/L
)USA lollowed the llowchart cotrectly by setting the GwCL at
he fraction ot lhe GWQS (25"/d for Class ll waler. However,
;ince selenium is above the GWQS in MW-31, il changes the
froundwater Protstion Level to Class lll in this well. Thelelore,
he GWCL will be set al 50% of the GWQS lor Class lll water -
1.5 uo/1.
Table 1 - Revislons to Proposed GWCLS
Well
Prolecilon
Level Parameler GWOS
Percentage
D,etects
DUSA Proposed
GWCL
DRC Revlsed
GWCL Comment
MW-3'l Class lll'Chromium 100 UEL 0%25rglL 50 ug/L
f,USA lollowed the llowchart correctly by sefling the GWCL at
he fraction of the GWQS (25%) for Class ll water. However,
iince selenium is above the GWOS in MW-31, it changes lhe
Sroundwater Protslion Level to Class lll in this well. Theretore,
he GWCL will be set at 50% of the GWOS for Ctass lllwaler -
i0 uo/L.
MW-3r Class lll'Coball 730 gg/L 0%182.5 pg/L 365 [g/t
IUSA rollowed the tlowcharl corectly by setting the GWCL at
he lraction of the GWQS (25%) for Class ll water. However,
;ince selenium is above the GWQS in MW-3'1, it changes the
iroundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be sel at 50% ot the GWQS for Class lllwater -
,65 uo/L.
MW-3'l Class lll'Copper 1,300 Ig/t o./.325 us/L 650 Ug/L
,u:iA roilowed the flowchan correcily by seting the GWCL at
:he lraction ol the GWQS (25%) for Class llwaler. However,
;ince selenium is above lhe GWQS in MW-31, it changes the
3roundwaler Prolection Level lo Class lll in this well. Theretore,
:he GWCL will be set al 5070 of the GWQS for Ctass lll water -
i50 uo/L.
MW-31 Class lll'lron 1 1,000 uq/L o%2,750 ttglL 5,500 pg/L
DUSA followed the flowchart correctly by setting the GWCL at
the fraction ol the GWOS (25%) for Class llwater. However,
since selenium is above the GWQS in MW-31, it changes the
Groundwaler Prottrtion Level to Cla$ lll in lhis well. Therefore,
lhe GWCL will be set al 50% of the GWQS tor Class lil water -
5.50O uo/L.
MW-31 Class lll'Lead 1 5 gg/L o./.3.75 us/L 7.5 ug/L
JU5A roilowed the ilowchan cotreclty by seting the GWCL al
he fraction ol the GWQS (25%) for Class ll water. Htrever,
;ince selenium is above the GWQS in MW-31, it changes the
iroundwaler Protection Level to Class lll in this well. Theretore,
he GWCL will be set at 50% of the GWQS for Class lllwater -r.5 uo/L.
MW-s1 Class lll'Manganese 800 UgiL o./.200 Ug/L 400 pg/L
)USA lollowed lhe flowchart co.rectly by setting the GWCL at
he fraction of lhe GWOS (25%) tor Class llwater. However,
iince selenium is above the GWQS in MW-31, it changes the
iroundwater Prot*tion Level to Clas lll in this well. Theretore,
he GWCL will be set at 50% of the GWQS for Class ltlwaler -
IOO r'6/l
MW.31 Class lll'Mercury 2rglL oo/"0.5 ug/L I udL
)USA tollowed the flowchart correctly by setting the GWCL at
he kaction of the GWOS (25%) for Class llwater. However,
iince selenium is above the GWQS in MW-31, it changes the
iroundwater Protmtion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS for Class lltwater - 1
td/l
MW-31 Class lll'Molybdenum 40 Ug/L o./"1 0 us/L 20 ttgll*
JUSA followed the flowchart correctly by setting the GWCL at
he traction of lhe GWQS (25%) for class ll water. However,
;ince selenium is above the GWQS in MW-31, it changes the
Sroundwater Protmtion Level lo Class lll in this well. Therefore,
he GWCL will be sel at 50% of the GWQS for Class Itwater -
lo uo/L
MW.3,I Class lll'Nickel 1 00 Ug/L o./.25 Ug/L 50 ug/L
)USA tollowed the flowchart correctly by selting the GWCL at
he fraction of the GWQS (25%) for Class lt water. However,
iince selenium is above the GWOS in MW-31, il changes the
lroundwaler Protection Level to Class lll in this well. Therefore,
he GWCL will be sel at 50% of the GWQS lor Ctass lll waler -
i0 uo/L.
MW-31 Class lll'Silver I 00 pg/L 0%25 Ug/L 50 Ug/t
LJU!iA tollowed the tlowchad correctly by setting the GWCL at
:he lraction of the GWQS (25%) for Ctass I water. However,
since selenium is above lhe GWQS in MW-31, it changes the
3roundwater Protection Level to Class lll in this well. Therefore,
:he GWCL will be set at 50% of the GWQS for Class lllwater -
;0 uo/L.
MW-31 Class lll'Thallium 2rglL od/"0.5 ug/L I Ug/L
I he GWCL proposed is based on the mean plus 20%. Accordin!
o the flowchart, it should be the mean plus two standardlpviaiidnc - I u^/l
MW-31 Class lll'Tin 1 7,000 us/L 100%None 8,500 uq/L )USA lailed to provide a GWCL for Tin in Mw-31. Since the Tin
)oncenlrations in MW-3'l has been 100% nondetect, the GWCL
ilill be set al the fraction GWOS tor Class lll water - I 5oo rrd/t
MW-31 Class lll'Vanadium 60 ug/L o"/"15 Ug/L 30 us/L
IUSA lollowed lhe llowchart correctly by setting the GWCL at
he fraction ol the GWos (25%) tor class llwater. However,
;ince selenium is above the GWQS in MW-31, it changes the
froundwaler Prottrtion Level to Clas3 lll in this well. Therelore,
he GWCL will be set at 50% of the GWQS for Class lllwater -
,0 uo/L.
MW-31 Class lll'Zinc 5,000 ua/t o"/"1,250 [g/L 2,500 [g/L
JUSA roilowed lhe ilowchart correcily by setting lhe GWCL at
he fraction ol the GWQS (25%) Ior Class ll water. However,
iince selenium is above the GWOS in MW-31, it changes the
iroundwater Protstion Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of the GWQS for Class lltwater -
1.500 uo/L.
- Revlsions to Proposed GwCLs
Well
Protection
Level Parameter GWOS
Percentage
Detecls
DUSA Proposed
GWCL
DRC Revised
GWCL Commenl
MW-31 Class lll"Gross Alpha 15 pCiA o"/"3.7s poi,4-7.5 pCYL
)usA lollowed the llowchan correcily by settrng lhe GwcL ai
he fraction of the GWQS (25%) for Class llwater. However,
iince selenium is above the GWQS in MW-31, it changes the
3roundwaler Protection Level to Class lll in this well. Therefore,
:he GWCL will be sel al 50% ot the GWQS for Class lll water -
MW.31 Class llf Aceione 700 ug/t o./"'t75 pglL 350 Ug/L
)USA followed the llowcharl correclly by settrng the GWUL al
he lraction ol the GWQS (25%) tor Class llwater. However,
iince selenium is above the GWQS in MW-31, it changes the
iroundwater Prolection Level to Class lll in this well. Therelore,
he GWCL will be sel at 50% of the GWQS for Class lllwater -
MW-31 Class lll'Benzene 5 udL o"1.25 pg/L 2.5 Bg/L
)usA lollowed lhe llowchan correcfly by settrng lhe GwuL at
he fraclion of the GWQS (25%) for Class llwaler. However,
;ince selenium is above the GWOS in Mw-31, it changes the
froundwater Protection Level to Class lll in this well. Therefore,
he GWCL will be set at 50% ol the GWQS for Class lllwater -
MW-31 Class lll'2-Butanone
(MEK)4,000 pg/t 0/"1,000 ug/L 2,000 us/L
)usA followed lhe flowcha( correclly by settng the GwuL al
he fraclion of the GWQS (25%) for Class ll waler. However,
;ince selenium is above the GWQS in Mw-31, it changes the
iroundwater Protection Levdl to Class lll in this well. Therelore,
he GWCL will be set at 50% of the GWOS lor Class lllwater -
MW-31 Class lll'Carbon
Tetrachloride 5 u/L o"/"1.25 uq/L 2.5t glL
)USA lollowed the llowchan correctly by senrng the GwL;L al
he fraction ol the GWQS (25%) lor Class llwaler. However,
;ince selenium is above the GWQS in MW-31, it changes lhe
Sroundwater Prolection Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% of lhe GWQS for Class lll waler -
2.5 uo/L.
MW-31 Class lll'Chloroform 70 tlglL oo/"17.5 pq/L 35 Ug/L
)USA lollowed the llowchart corectly by setting the GWCL at
he lraction ot the GWQS (25%) for Class llwater. However,
rince selenium is above the GWOS in Mw-31, it changes the
iroundwater Protection Level to Class lll in lhis well. Therefore,
he GWCL will be set at 50% ol the GWQS for Class lll water -
lA rn/l
MW-31 Class lll'Chloromelhane 30 ug/L 55.60/.7.5 Ug/L 6.'l fg/L
ihe GWCL proposed is based on the Permit GWCL tor Class lll
vater. Acctrding to the flwchart, it should be the mean plus tw
itandard deviations - 6.1 uo/L.
MW-31 Class lll'5 udL o"/.1.25 pg/L 2.5 tglL
)USA lollowed the flowchart correctly by setting the GWCL at
he fraction ol lhe GWQS (25%) for Class llwater. HoweveI,
iince selenium is above lhe GWOS in MW-31, it changes the
iroundwater Proteclion Level to Class lll in lhis well. Therelore,
he GWCL will be set at 50% ol the GWQS tor Class lll water -
1.5 uo/L.
MW-31 Class lll'Naphthalene 100 pg/L o"/"25 uq/L 50 us/L
)USA followed ihe tlowchart correctly by setting the GWCL at
he fraction of the GWOS (25%) for Class ll waler. However,
iince selenium is above the GWQS in MW-3'1, it changes the
]roundwater Protstion Level to Class lll in this well. Therefore,
he GWCL will be set at 50% of the GWQS for Class lllwaler -
;0 uo/L.
MW-31 Class lll'Tetrahydroluran
(THF)46 lrg/L oo/"1 1.5 uq/L 23tSlL
JUSA tollowed tne llowcnan correcly Dy senrng lne uwul- aI
he lraction of lhe GWQS (25'ld lor Class llwater. However,
;ince selenium is above lhe GWQS in MW-31, il changes lhe
iroundwater Protection Level to Class lll in lhis well. Therelore,
he GWCL will be sel at 50% ol the GWOS for Class lll water -
MW-31 Class lll'Toluene 1,000 gg/L oyo 250 ug/L 500 pg/L
)USA lollowed the flowchart correctly by setling the GwCL at
he fraction of the GWQS (25%) for Class ll water. However,
;ince selenium is above the GWOS in Mw-31, it changes the
Sroundwater Prot*tion Level to Clss lll in this well. Therefore,
he GWCL will be set al 50% of the GWQS tor Class lllwater -
MW-31 Class lll'Xylenes (Total)10,000 Ug/L o./"2,500 Ug/L 5,000 ug/L
DUSA followed the flowchart corectly by setting the GwCL at
the fraction of the GWQS (25ol") lor Class llwater. Horever,
since selenium is above the GWQS in MW-31, it changes lhe
Groundwater Prolection Level to Class lll in lhis well. Therefore,
the GWCL will be sel at 50% of the GWQS for Class lll water -
5.000 uo/L.
MW-31 Class lll'Chloride TBD 100%159 mg/L '143 mg/L
the GWCL proposed is based on the mean plus 20ol.. Accordin(
o the flowchart, it should be the mean plus two standard
lpviriinnq - 1A.l md/l
MW-31 Class lll'Fluoride 4 mg/L 100%1.2 mq/L 2nglL
the GWCL proposed is based on the highesl hislorical value.
\ccording to the flowchart, it should be the greater of lhe fraclion
)f the standard or the highesl historic value. The GWCL should
)e 2 mc/L lfraction ol the GWOS).
MW-31 Class lll'pH (s.u.)6.5 - 8.5 100%5.0 - 8.5 6.5 - 8.5
fhe GWCL proposed is based on the mean minus 20%. With
he lowest observed value (6.8) being within the range ol the:r^rnQ rh6 a\Ar^l .h^, ili h6 .61 -r -. th6 nWnQ - A q - q E
Table 1 - Fevlslons to proposed GWCLS
Well
Protectlor
Level Parametel GWOS
Percentage
Detects
DUSA Proposed
GWCL
DRC Revised
GWCL Comment
MW.3A Class lll Tin 17,000 Ig/t 100y"None 8,50o Uq/L )USA lailed to provide a GWCL tor Tin in MW-3A. Since the Tir)oncentraliore in MW-3A has been 1OO% non{etect, the GWCI
vill be set at the fraction GWQS for Class lllwater - 8.500 uo/t
MW.3A Class lll Chloromelhane 30 Uq/L 75%15 ugll 9.4 Ug/L
rne uwuL proposeo E Dased on the permit GWCL for Class lllvaler. According to lhe flffichart, it should be the mean plus twrtandard deviations - 9.4 ucr/L.
MW-3A Class lll Chloride TBD 1001"73.7 milL 70 fig/L
I he GWCL proposed is based on the mean plus 2O%. Accordin(
o the flowchart, il should be lhe mean plus two standard
Jwiations - 70 mg/L.
MW.3A Class lll pH (s.u.)6.5 - 8.5 tooo/o 5.8 - 8.5 6.5 - 8.5
rne uwUL proposed s based on the mean minus 20%. Wilh
he lowest obsfled value (6.9) being within the range ol theiWQS, the GWCL shoutd be ser at as the GWOS - 6.5 - s.s
MW-3A Class lll Sulfate TAD -tooo/o 4,144, mg/L 3,640 mgr'L
r ne uwuL proposed is based on the mean plus 20%. Accordin(
o the flowchart, it should be the mean plus two standard
leviations - 3.640 mo/1.
MW-3A Class lll TDS TBD 1000/"6,657 mg/L 5,805 mgiL
he GWCL proposed is based on the mean plus 2O%. Accordiry
o the flowchart, it should be the mean plus two standard
levialions - 5.805 mo/L
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BLANDING, UTAH
Permit Modification
PUBLIC MEETING
7:00 - 9:00 p.m.
October 7,2009
Please Print
NAME
(Please Print )
Will You Be Making
Comments?
Yes/IIo
Organization/Affi Iiation
Phone Number and Email
Address:
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Monticello
4770 S. 5600 W.
P.O. POX 704()05
\\/EST \/ALLEY CIT\'. UTAH 84 I70
FED.TAX t.D.# 87-02 t7663
*, | ^kr @ribunr IrLF,_U_4?. Ar\lorniiiij Ne,r,"
PROOF OF PUBLICATION
CUSTOMER'S
COPY
: OF A MODIFICAIION
QUALIIY DISCMRGE f
uGw370004
Seeps qnd Sprlngs ond tqlllngs @ll wot
. Resolutlon of certoln prevlos campllqnce sdedule rcqulr
ments
Purpo* of Publlc Noll@
Tho tlloh Deportmcnt of Envtronmenlol Quollty (DEO) ls lollc'
Itlnd bmmeirh on lls propored modlflcollom lo lhe oxlsnn!
e;;lil-iV;i;i Quoltt| Disaorge Psrmll (Psrmlt) undor^lhe
outhorlty of lhe Uioh Woter Quollty Ad, sectlon I v')'
lo4lllth. utoh Code Annololed 1953, o! omendcd ono m'
L,toh'Aaniinlstrotlon Code (UAC) R3 I 7-6.
U@ns6e qnd Petmlttoe lnformotlon:
ilflt',i 3'lBBlST:i 6'r'd\9ilorT'iXil*re e5o, Denver, c(
80265
TETEPHONE NUMBER, 303-624-7798
FACILITY LOCATION, Blonding Utoh
PERMIT NO.: UGw370004
Moior dlongcs ossocioled wllh hl3 Permll fiodilldtlon lf,
clude, bui ore nol llmlled to!
. ADorovol o{ DUSA Bockoround Ground Wol€r Quollty Re'p5hi doiea OJouer 2067 ond Aprll 30, 2008
. Coldlolion of o meon ond stondqrd d'vlqtlon for coc
iil"i oi Cimptlonce (hereolter POC) groundw-oler monltor
Ing wellt, ona lhe eslobllshmeni of sompllng treqwncY t0
oll POC wells
. Btoblhhnent ond revlllon of Ground Wotor CompllqN
Llmlt! for multlple POC well!
. Ljodole the 3toius o, certoln POC wells wlth Porometer! ll
Oul-oI-ComPlione Stotus
. Addttion of BAT Stondord! ond Performore Monliolng f(
iJJiiioiri r"riiiriot stored ouislde lhe Fredstock storog
Areo
. Addltlon of Performorce Monltorlng for insPectlons of Tol
lng Cell ond Pond Liner Systems
. Addltion of
monlloring.
Publlc @mments ore lnvlted ony tlm Prlor to.-5:00
8,i:BT & i3!l"i'"Y'lxil,."T'fl31'i fiJ'B: sliii:mqY be ollgqeo ro r
44850. solt loke cll
Publlc @mments ore lnvlted ony tlm Prlor lo.-5:uu P'm'
8,i.:BT & i3!l"i'"Y',lxil,."T'fl31'i fiJ'B: Sliii:i"itoI
Dlvision
AFFIDAVIT OF PUBLICATION
AS NEWSPAPER ACENCY CORPORATION LECAL BOOKER. I CERTIFY THAT THE ATTACHED ADVERTISEMENT OF
DIVISION OF RADIATION CONTROL UTAH DEPAR
CONTROL,
FOR DIV OF RADIATION
WAS PUBLISHED BY THE NEWSPAPER ACENCY
CORPORATION. AGENT FOR THE SALT LAKE TRIBUNE AND DESERET NEWS. DAILY NEWSPAPERS PRINTED IN THE
ENCLISH LANCUACE WITH GENERAL CIRCULATION IN UTAH. AND PUBLISHED IN SALT LAKE CITY, SALT LAKE COUNTY
IN THE STATE OF UTAH.
Start 0910212009 End 0910212009 EE m A:, lrr .:rr. rEll FFfbm'* "rPUBLISHED
SICNATURE
L/
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ili'n7irj-iiaso. I puottc meeflns wlll be hold on octob
ii"ilii:"1ff ,l;g,l,i", ?,"*:;T 16[, $,,lil', jl3,ffvr",
all orol ond wrltten comm€nts recelv€d ot fte meerng wlll.
""".ri-"rJ-fn io.mutqtlon o{ finol delormlnolions to b6 I
posd on lhe Permll.
Further lnformollonliiiir]onii irio.mqtion moY be oblolned upon requesl
cdlllno Phll Goble ot [phone] or vlq emqil
li"ii.raJrotr,oov. wrlf;n r;quelis Ior lnformollon con q
#-;i;;;'d io ttt; oforementl6ned oddres!' Reloled do'
ii"t "iii.rirltJirt" for revlew durlns nomol bwlneis ho
,iii'.fri'ri"-r""i iodiotlon control,-l68 N. 1950 w.s
iidi''citr.-uiirti '-itp orofi Permil modlfi@tlon ond
ii;i..;i'oi' Bqsls ls ols ovolloble on lhe lnlernel
ww.rodiolionconlrol.utoh'gov
ln comDllonce wllh lhe Amerlcqns wlth Dliqbllltles Acl, indlv
iiiii riiii soe.roi needs (includlng quxlllory comounlcol
t* i::":*t,tal'i ;ii'.u
"iiig
tt:i?f 1i'"i1.
1O working doys prior lo close of the mmmnl Derloq'
491 3ot UPAX
IASETH'G. CONIltlVAICtEaWda2f,)t{,utr t|dvoilgrolu, UhhS.tAo E
CI.ISTOMER NAil4EAND AEDRES S.ACCOUNTNUMBER .DATE
DIV OF RADIATION CONTROL,
ATTN DANE L. FINERFROCK
P.O. BOX r44850
SALT LAKE CITY, UT 84114
9001 387637 91312009
DIVISION OF RADIATION CONTROIrras oipmtruNT oF ENVIRoNMEI'{TA! QUAUTY- pusLic Nortc: oF A MoDlFlcATloN To THEcpirirxo uren ouALtTY DISCHARGE PERMIT No.
Reserving the BAEC Page I of I
)
ERRESVING THIS BIJI
a
LDING
Reservations for this building can be made through the Qgllege {lgstern Utah - San Juan
Campus by calling Kathy Rawlings at435-678-8103 or IG mai I I
Return to BAEC Home Page
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U]OFFICIAL COP\T
UTAH DEPARTMENT OF ENVTRONMENTAL QUALITY
PURCHASE REQUISITION
Office Division: DIVISION OF RADIATION CONTROL
Requested By: LOREN MORTON/PHIL ( Piepared By:Brent Christensen
Date Required: 00/00/0000 Prepared Date: 09/09/2009 PO Type: GAE
Prog.Function
DEFAULT
Excutive Director Aporoval
by: Date: 00/00/0000
Items Requisitioned
Item Description
TRANSCRTpT COST ($6.25 pER PAGE X 40
PAGES PER HOUR X 2 HOURS)
ROUNDTRIP MILAGE COST TO TRAVEL TO
BLANDING, UT ($0.+S PER MILE X 620 MILES
ROUND TRtP)
APPEARANCE FEE
HOTEL AND PER DIEM FOR 1 NIGHT
LEGAL TRANSCRIPTION SERVICES FOR PUBLIC
MEETING/HEARING PERTAINING TO DENISON
MINES WHITE MESA URANIUM MILL
GROUNDWATER DISCHARGE PERMIT
MODIFICATION. MEETING TO BE HELD
OCTOBER 7,20Og FROM 7:00PM TO 9:00PM AT
790 WEST 2OO SOUTH, BLANDING, UT 84511
DP-1 No: 59599
PO No.: 05000000015
Fiscal Year: 2010
ELCID #
Date:09/10/2009
Unit ExtendedPrice Price
$500.00 $s00.00
$279.00 $279.00
$150.00 $1s0.00
$10s.00 $105.00
$0.00 $0.00
Fund Dept. Unit
100 480 5250
App. ExpUnit Obj
NAD 6137
Cost Alloc.
$1,034.00
RECOMMENDED VENDOR
Name: CITICOURT REPORTING GROUP
Attention: KIM
Address:170 SOUTH MAIN STREET SUTTE 300. SALT LAKE CITY
Phone No.: [phone] Fax No.: [phone]
Branch Manaqer Approval
by: Date:
Division/Office Director Approval
O Approved C Disapproved O pending
]
by: Dane Finerfrock Date: 09/09/2009
Finance Approval
]O Approved C Disapproved C pending
I
by: Andrea Riddle Date: 09/09/2009 by: Craig Silotti
SHIP TO ADDRESS
Street: 168 N 1950 W
SALT LAKE CITY UT 84116-
Special lnstruction:
CHRISTENSEN
Support Services Coordi nator Approval
by: Brent Christensen Date:09/09/2009
lnformation Technoloqv Approval
Approved
by: Date:00/00/0000
Director of Suoport Services Approval
UT 84101- PLEASE SEND BILLATTN: BRENT
C Approved C Disapproved O pending I lO Approveo O Disapproveo C pending
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EstimatedCosts: $1,034.00
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Phillip Goble - Citicouft Contact Information
From:
To:
Date:
Subject:
Brent Christensen
Phillip Goble
91912009 9:37 AM
Citicou rt Contact Information
Phil,
Below is the contact information for Citicourt who I booked the legal transcription seryices through
Contact: Kim
Phone: [phone]
ema il : sched u [e-mail]
If there is anything you need let me know.
Brent
file://C:\Documents and Settings\Pgoble\Local Settings\Temp\XPgrpwise\4AA7775EEQD... lOlStZOOg