DRC-2010-002857 - 0901a06880186cdc

DENISO
MINES
April 30, 2010
VIA PDF AND FEDERAL EXPRESS
Dane L. Finerfrock, Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
ReceWed
MAY 2010
Division 0^ Radiation ConW^
to
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Denison Mines (USAfcor^
105017th Street, Suite 9S0
Denver, CO 80289
USA
Tel: 303 62^7798
Fax:[phone]
www.denisonmines.com
Re: State of Utah Ground Water Discharge Permit No. UGW370004 (the "GWDP")
White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a)
Dear Mr. Finerfrock:
The White Mesa Mill (the "Mill") performed quarterly groundwater monitoring during the
period from February 2 to February 10, 2010, as indicated in Table 1, below, under the January
20, 2010 version ofthe GWDP (the "Current GWDP"). Draft versions of all analytical results
were received by Denison Mines (USA) Corp ("DUSA") in emails dated April 2, 2010. Final
versions ofthe data reports, prepared following QA/QC review by the Mill's QA Manager and
DUSA's discussions with both laboratories, were received in emails dated April 27, 2010.
Pursuant to Part I.G.I.a) of the Current GWDP, please take notice that the concentrations of the
following constituents in the following monitoring wells, sampled on the dates indicated,
exceeded their respective ground water compliance levels ("GWCLs") in Table 2 of the Current
GWDP:
Table 1 - GWCL Exceedances for First Quarter 2010 under the January 20, 2010 GWDP
Monitoring Well
(Water Class)
Date Sampled Constituent GWCL in
Current GWDP
(ug/L)
Sample Result
(ug/L)
MW-11 (Class II) 2/10/2010 Manganese 131.29 134
MW-30 (Class II) 2/9/2010 Nitrate plus
Nitrite
2.5 16.1
MW-31 (Class III) 2/9/2010 Nitrate plus
Nitrite
5 21.7
As confirmed via email correspondence on February 16 and 17, 2010, as a result of the issuance
of the Current GWDP, which sets revised GWCLs, all requirements to perform accelerated
monitoring under Part I.G.I of the previous GWDP dated March 17, 2008 (the "Previous
GWDP") ceased effective on January 20, 2010, and the effect of the issuance of the Current
GWDP was to create a "clean slate" for all constituents in all wells going forward.
This means that no accelerated monitoring was required under the Current GWDP for the first
quarter of 2010. Accelerated monitoring for subsequent quarters will depend on the application
of Part l.G. 1 of the Current GWDP to results from groundwater samples required to be taken in
the first quarter of 2010 and from any subsequent sample results. The notice requirements of
Part I.G.l.a) ofthe Current GWDP apply to any exceedances observed in groundwater samples
required to be taken in the first quarter of 2010 and fi-om any subsequent sample results.
However, the Mill environmental staff had commenced accelerated sampling of certain wells for
selected parameters, consistent with the Previous GWDP, prior to DUSA's receipt of the January
20, 2010 Permit revision. The January accelerated effort commenced in early January, and
continued through the last week of January, when instructions to cease the program, based on the
newly-approved Permit, reached the Mill's sampling staff Some additional accelerated
monitoring was performed in March 2010, before the sampling staff finally shut down all pre-
scheduled accelerated field activities.
Accordingly, the January and March accelerated monitoring samples were not required under the
Current GWDP. However, for completeness, where non-required accelerated samples have been
collected, analytical results for these samples have been evaluated and compared to the GWCLs
in the Previous GWDP. Results of the comparison are provided in Table 2, below, for
informational purposes only.
Table 2 - GWCL Exceedances for Non-required Accelerated Sampling under the March
17, 2008 GWDP
Monitoring Well
(Water Class)
Date Sampled Constituent GWCL in
Previous GWDP
(ug/L)
Sample Result
(ug/L)
MW-18 (Class III) 3/22/2010 Thallium 0.5 3.91
DENISO
MINES
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron Hochstein
Harold Roberts
David Turk
DENISON
MINES