DRC-2011-007858 - 0901a068802b155e

State of Utah
GARY R HERBERT
Govenwr
GREG BELL
Lieutenant G( vtinor
Department of
Environmental Quality
Amanda Smith
E\ei utive Diieitoi
DIVISION OF RADIATION CONTROL
Rustv Lundberg
Duectoi
DRC-2011-
November 29 2011
CERTIFIED MAIL
RETURNED RECEIPT REOUESTED
Mr David C Frydenlund
Vice President Regulatory Affairs and Counsel
Denison Mines (USA) Corp (DUSA)
Independence Plaza Suite 950
1050 Seventeenth Street
Denver CO 80265
cr o
LT)
tr
i-R
nj a
•
a
r-=l
CD
n-
U.S. Postal Service n,
CERTIFIED MAIL™ RECEIPT
(Damestic Mail Only; Nm Insurance Caverage Frmviaed)
^•r delivery Inf.rm.tl.n visit .ur website at www.us^s.c.m^
Certf ed Fee
RE 11/29/11 CLOSEOUT LETTER / DH
David C Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
1050 17th ST STE 950
Denver CO 80265
FS F«rm 3tM. August 2Me Sec «ovorse f«r Instiucti.ns
RE 1st Quarter 2011 Chloroform Monitonng Report and 2nd Quarter 2011 Chloroform
Monitonng Report for the Chloroform Contamination Investigation Denmson Mines
(USA) Corp (hereafter DUSA ) White Mesa Uranium Mill near Blanding Utah
Closeout Letter
Dear Mr Frydenlund
The Utah Division of Radiation Control has completed the review of 1st and 2"^^ Quarter 2011
Chloroform Monitonng Reports for the Chloroform Contamination Investigation
The review was based on compliance with the Ground Water Quality Discharge Permit Number
UGW370004 (Penrnt) and the DUSA Quality Assurance Plan (QAP) Dunng the DRC review it
was found that DUSA failed to meet the requirements found in Section 9 1 4(a) of the QAP for
two duplicate samples in the 1st quarter 2011 monitonng event Section 9 1 4(a) of the QAP
requires
a) Relative Percent Difference
RPDs w ill be calculated in comparisons of duplicate and original field sample results Non
conformance will exist when the RPD > 20% unless the measured activities are less than 5 times
the reqmred detection limit {Standard Methods 1998) {EPA Contract Laboratory Program
National functional Guidelines for Inorganic Data Review February 1994 9240 1 05 01
The chloroform analytical results companson between the onginal sample forTW4 19 and its
duplicate sample TW4 65 (49%) and between the onginal sample for TW4 10 and its duplicate
193 North I )50 West Salt Like Cit> UT
Miihn^Addrc s I O Box 144850 Snit Uke City UT 84114 4850
Telephone (801).T 0 4''->0 Fix(80n33 4097 TDD (801 ).-> f 4414
d q r I k
P I I 100 \ I fi p 1
Page 2
sample TW4 70 (27%) had a relative percent difference (hereafter RPD ) > 20% However the
Executive Secretary accepts DUSA explanation in Section 3 4 7 of the 1st Quarter 2011
Chloroform Monitonng Report therefor there will be no enforcement action in this mattei
The remaindei of the items reviewed were found to be conducted in compliance with the Permit
and QAP This letter constitutes a closeout of the 1st and 2""* Quarter 2011 Chloroform
Monitonng Reports for the Chloroform Contamination Investigation
Thank you for your cooperation in this matter If you have any questions or comments regarding
this letter please contact Dean Henderson at [phone]
UTAH WATER QUALITY BOARD
Rusty Lundberg
Co Executive Secretary
RLyDH
State of Utah
GARY R HERBERT
Gove t not
GREG BELL
Lieutenant Goveuioi
Department of
Environmental Quality
Amanda Smith
Exeeutt t Diretti
DIVISION OF RADIATION CONTROL
Dane L Finerfrock
Dll e( tor/
TO
FROM
DATE
SUBJECT
MEMORANDUM
Phil Goble ((/2f/^^ (I
Dean Henderson
November 28 2011
Review of the 1st Quarter 2011 Chloroform Monitonng Report for the Chloroform
Contammation Investigation and 2nd Quarter 2011 Chloroform Monitonng Report
for the Chloroform Contamination Investigation Denison Mines (USA) Corp
(hereafter DUSA )White Mesa Uranium Mill near Blanding Utah
The Division of Radiation Control (hereafter DRC ) has reviewed 1st Quarter 2011 Chloroform
Monitonng Report (hereafter 1^^ Report ) and the 2nd Quarter 2011 Chloroform Monitonng
Report (hereafter 2nd Report ) for the Chloroform Contamination Investigation For the review
of these reports the following regulatory enforcement documents were used
• DUSA was issued Ground Water Quality Discharge Permit No UGW370004 (hereafter
Permit ) on March 8 2005 last revised on January 20 2010
• The DUSA Quality Assurance Plan (hereafter QAP ) March 22 2010 (Revision 6 0)
Review
Both the 1^^ Report and 2"^^ Report appeared to be m compliance with the Permit and QAP with the
exception of the duplicate sample results not meeting the requirements found in Section 9 1 4(a)
of the QAP for the 1^' quarter 2011 This section of the QAP requires
a) Relative Percent Difference
RPDs will be calculated in compansons of duplicate and original field sample results Non
c onfomiance will exist when the RPD > 20% unless the measured activities are less than 5 times
the required detection limit {Standard Methods 1998) {EPA Contract Laboratory' Program
National Functional Guidelines for Inorganic Data Review February 1994 9240 1 05 01
p25)
108 North 1950 W st Salt Lake City UT
MT I Add c s PO Box 144850 Salt Lake C ty UT 84II4 4850
Tel pl in (801):) ('47^0 Fix (801) 5 3 4097 TDD (801)5 6 4414
I q t I I.
Pli 100 y 1 cl p p
Page 2
The chloroform analytical results companson between the sample for TW4 19 and its duplicate
sample TW4 65 and between the sample for TW4 10 and its duplicate sample TW4 70 had a
relative percent difference (hereafter RPD ) > 20% (see the table below)
Parameter GWQS TW4 19 TW4 65 (Duplicate
sample of TW4 19)
RPD
Chloroform (pg/L) 70 3400 5600 49%
TW4 10 TW4 70 (Duplicate
sample of TW4 19)
Chloroform (pg/L) 70 620 810 27%
In section 3 4 7 of the Report DUSA responded to this issue
All analytical results except for chloroform in sample/duplicate pairs TW4 19/TW4 65
andTW 4 10/TW 4 70 were within the 20% RPD acceptance limits The chloroform
results for both sets of duplicate pairs are greater than 5 times the reporting limit and both
sets of duplicate pairs results were diluted 100 fold or more due to the high chloroform
concentration The RPD greater than 20% is most likely due to a dilution error in the
laboratory In addition the results are significantly above the groundwater quality
standard of 70 ug/L and as such the noncompliant RPD results do not affect the quality or
usability ofthe data
DRC staff has determined that DUSA response is reasonable and will not recommend any
enforcement action However DRC will use the higher of the two chloroform concentrations for
both TW4 10 and TW4 19 when reporting chloroform concentrations for the 1st quarter 2011
chloroform monitonng event
Page 3
References
Denison Mines (USA) Corp March 22 2010 White Mesa Uranium Mill Groundwater
Monitonng Quality Assurance Plan (Revision 6 0)
Denison Mines (USA) Corp August 2009 White Mesa Uranium Mill Chloroform Monitonng
Report 1st Quarter (January through March 2011)
State of Utah Division ofWater Quality Department of Environmental Quality January 20 2010
Ground Water Discharge Permit for Denison Mines (USA) Corp at the White Mesa Mill Facility
Near Blanding Utah