DRC-2011-006977 - 0901a0688024b849

Am 17tH Street, Suite 9S0
Bertve^ CO 8dSt$5
USA
June 30, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mfi Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Nitrate Investigation Phase 2 Detailed Work Plan and Schedule - Nitrate Investigation at the White
Mesa Mill Site - Docket No. UGW09-03
Dear Mr. Lundberg:
Pursuant to Item a. on Page 6 of the Fmal Tolling Agreement, dated June 30, 2011, betwee Denison Mines
(USA) Corp. f Denison") and the Co-Executive Secretary of the Utah Water Quality Board, please find
enclosed Denison's White Mesa Uranium Mill Phase 2 Nitrate Investigation Detailed Work Pfan and Schedule
and Quality Assurance Plan.
Per the Final Toiling Agreement dated June 30, 2011, and in order to meet the schedule provided herein,
Denison assumes that Utah Division of Radiation Control will provide comments by July 13.2^^^^^
Please ojntact me if you have any questions or require an^^^^^^^^
Yours very trulyv
DEMfsON^MiNES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: Robert D, Baird. URS
Daniel W-Erskine, INTERA
Loren Morton
Harold R. Roberts
David E. Turk
Katherine A. Weinel
Enclosures
NrVprate Invesligation and eiRVPha 2 GW Investigation PlanVPhase 2 QAP\06 3011 transmittal
of nitrate Ph 2 V\^ and QA
OENISONI)~~
MINES
June 30, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: Nitrate Investigation Phase 2 Detailed Work Plan and Schedule -Nitrate Investigation at the White
Mesa Mill Site -Docket No. UGW09-03
Dear Mr. Lundberg:
Pursuant to item a. on Page 6 of the Final Tolling Agreement, dated June 30, 2011, between Denison Mines
(USA) Corp. ("Denison") and the Co-Executive Secretary of the Utah Water Quality Board, please find
enclosed Denison's White Mesa Uranium Mill Phase 2 Nitrate Investigation Detailed Work Plan and Schedule
and Quality Assurance Plan.
Per the Final Tolling Agreement dated June 30, 2011, and in order to meet the schedule provided herein,
Denison assumes that Utah Division of Radiation Control will provide comments by July 13, 2011.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
9~~
Jo Ann Tischler
Director, Compliance and Permitting
cc: Robert D. Baird, URS
Daniel W. Erskine, INTERA
Loren Morton
Harold R. Roberts
David E. Turk
Katherine A. Weinel
Enclosures
N:\Nitrate Investigation and CIR\Phase 2 to 5 Plan Revised\Ph 2 GW Investigation Plan\Phase 2 QAP\06 30 11 transmittal
of nitrate Ph 2 WP and QAP.doc
WHITE MESA URANIUM MILL
PHASE 2 NITRATE INVESTIGATION
DETAILED WORK PLAN AND SCHEDULE
Jul y 1,20 11
Revision 0
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
N:\Nitrate Investigation and CIR\Phase 2 to 5 Plan Revised\Ph 2 GW Investigation Plan\Phase 2 QAP\Phase 2 WP .docx
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
Contents
1.0 INTRODUCTION .................................................................................................................................. 1
2.0 DOCUMENT ORGANIZATION .......................................................................................................... 2
3.0 PURPOSE AND SCOPE OF THE INVESTIGATlON ......................................................................... 3
3.1 Project Purpose ................................................................................................................................... 3
3.2 Project Scope ...................................................................................................................................... 4
4.0 81 ~ DESCRIPTIO ............................................................................................................................. 5
5.0 PROJECT OBJECT~8 ....................................................................................................................... 6
6.0 PHAS ~ 2 SCHEDULE ........................................................................................................................... 6
1
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
1.0 INTRODUCTION
Denison Mines (USA) Corp. ("DUSA") received a Request for Voluntary Plan and Schedule to
Investigate and Remediate Nitrate Contamination at the White Mesa Mill (the "Mill") Site, near Blanding,
Utah (the "Request") from the Co-Executive Secretary (the "Co-Executive Secretary") of the Utah Water
Quality Board, of the Utah Department of Environmental Quality ("UDEQ") on September 30, 2008. In
the Request, the Co-Executive Secretary noted that groundwater nitrate as nitrogen levels have exceeded
the State water quality standard of 10 milligrams per liter ("mg/L") in certain monitoring wells at the Mill
Site. For the remainder of this document, any reference to nitrate or ammonia, whether or not the
reference specifies "as N," means the analyte "as nitrogen."
As a result of the Request, DUSA agreed to submit a plan of action and a schedule for Co-Executive
Secretary approval for completion of a Contamination Investigation Report ("CIR") to determine the
physical cause(s), location(s), transfer mechanism(s) and characteristics of all source(s) of the nitrate
contamination in order to form a basis for and facilitate later submittal of a groundwater Corrective
Action Plan ("CAP") that meets the requirements of Utah Administrative Code ("UAC") R317-6-6.15D,
or to demonstrate conclusively that DUSA did not cause or contribute to the nitrate contamination in any
manner and that, as a result, such a CAP is not necessary. Subsequently, in a letter dated December 1,
2009, UDEQ, noting that elevated chloride concentrations exist, apparently coincident with elevated
nitrate concentrations, recommended that DUSA also address and explain the elevated chloride
concentrations.
DUSA and the Co-Executive Secretary entered into a Stipulated Consent Agreement Docket No.
UGW09-03, dated January 27,2009 ("Consent Agreement"), related to nitrate contamination at the Mill.
Pursuant to Item 6.A of the Consent Agreement, DUSA submitted a Nitrate CIR for the White Mesa
Uranium Mill Site, Blanding, Utah, dated December 30, 2009, to the Utah Division of Radiation Control
("DRC"). By a letter dated October 5, 2010, the Co-Executive Secretary notified DUSA of his
determination that the CIR is incomplete. By an email transmitted to the Co-Executive Secretary on
October 20, 2010, and pursuant to Item 11 of the Consent Agreement, DUSA requested an
amendment to the deadline stipulated in item 7.C of the Consent Agreement.
At an October 26,2010, meeting with the Co-Executive Secretary, DRC staff, and legal counsel, DUSA
reported that it was premature to submit a schedule for submittal of performance standards and a CAP for
the nitrate contamination. In tum, DUSA presented a new theory for a possible source of the nitrate and
chloride contamination beneath the Mill, based on DUSA's review of the scientific literature ("New
Theory"), specifically, that the nitrate contamination source is or could be caused by naturally occurring
nitrate and chloride salt deposits located in the vadose zone near or beneath the Mill site area, which have
been mobilized by natural and/or artificial recharge. The parties agreed that this New Theory warranted
additional investigation, along with certain of the other additional studies suggested in the October 5,
2010, DRC Notice. At a November 30,2010, meeting between DRC Staff and DUSA the Co-Executive
Secretary and DUSA further agreed that DUSA would prepare a detailed plan and schedule (the "Plan and
Schedule") for performing additional required studies and for submittal of a revised CIR that meets the
requirements of all applicable regulations on or before February 15, 2011. DUSA's commitment to
prepare and submit the Plan and Schedule is set out in a Tolling Agreement (the "Tolling Agreement")
dated December 15,2010, between DUSA and the Co-Executive Secretary.
DUSA submitted a draft Work Plan on February 14, 2011. During subsequent discussions with DRC
staff, the Co-Executive Secretary and DUSA agreed that the additional studies could require as many as
five phases, and the schedule should include points of consultation between phases at which the Co-
1
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
Executive Secretary and DUSA could evaluate and agree on the redirection, addition, or elimination of
subsequent phases.
The Tolling Agreement was revised on April 28, 2011, to allow time for:
• DUSA to prepare and submit a Revised Work Plan for Phase 1.
• DUSA to prepare and submit a revised Work Planes) for Revised Phases 2 through 5, including a
Conceptual Site Model ("CSM") of potential nitrate sources.
• The Co-Executive Secretary to review and approve the revised Work Plans, including
modifications.
• The Co-executive Secretary and DUSA to agree on a revised or replacement Consent Agreement
Based on discussions culminating in the Revised Tolling Agreement, DRC and DUSA have agreed to
conduct a multi-phased program designed to evaluate a number of potential sources of nitrate and
chloride that may have contributed to the identified plume, both Mill-related sources, non-Mill sources,
and sources resulting from historical use. The phased approach will include development of a CSM that
will be refined as the investigation progresses and will be used by DRC and DUSA at several decision
junctures to:
1. Determine which sources should be removed from further consideration.
2. Assist in quantifying the relative contribution ofthe remaining sources.
3. Determine whether or not to proceed with future phases of the investigation.
Based on agreements between DRC and DUSA, the Tolling Agreement was revised and finalized on June
30, 2011, to allow sufficient time for preparation and DRC approval of work plans and milestones dates
for the remainder of the investigation.
The Phase 1 investigation is described in detail in the Nitrate Investigation Revised Phase 1 Work Plan,
White Mesa Mill Site, dated May 13, 2011. A Phase 2 through 5 Work Plan, describing the remaining
phases of the investigation per the Revised Tolling Agreement, was submitted on June 3, 2011 and is
currently under revision in response to DRC comments. The purpose of Phases 2 through 5 is to collect
data to fill the data gaps, test hypotheses, and update the CSM as described above. Following submittal
of the Phase 2 through 5 Work Plan, the Revised Tolling Agreement required that DUSA would provide a
Phase 2 Detailed Work Plan and Schedule by July 1, 2011.
This document, along with its attachments, is the Phase 2 Detailed Work Plan and Schedule. This Work
Plan, combined with the schedule included as Attachment 1, and the Quality Assurance Plan ("QAP") for
Phase 2 included as Attachment 2, will delineate the investigation-specific procedures and activities
necessary to conduct the Phase 2 groundwater portion (non-isotopic groundwater analyses) of the
investigation contemplated by the Revised Tolling Agreement.
2.0 DOCUMENT ORGANIZATION
Phase 2 of the nitrate investigation as contemplated by the Revised Tolling agreement dated April 28,
2011 includes the non-isotopic sampling and analysis of groundwater from existing wells at the Mill site.
Based on agreements between DRC and DUSA, the Tolling Agreement is currently undergoing revision
to allow sufficient time for preparation and DRC approval of Work Plans and milestones dates for the
remainder of the nitrate investigation. Per this draft Tolling Agreement, a Detailed Work Plan and
Schedule as well as a QAP is required for Phase 2 of the nitrate investigation. This document and the
2
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
Attachments are designed to meet the requirements for the Phase 2 nitrate investigation described in the
draft Tolling Agreement. This document is organized as follows:
• Work Plan -the Work Plan is the primary document and describes, either directly or through
reference, the purpose of this phase of the investigation, the site description and site background,
and the project objectives for Phase 2 of the nitrate investigation.
• Attachment 1 Schedule for Phase 2 -Attachment 1 of this Work Plan delineates the Phase 2
schedule for sampling, data receipt and data submission to DRC.
• Attachment 2 QAP -Attachment 2 of this Work Plan is the QAP for the Phase 2 nitrate
investigation. The QAP provides the Quality Assurance ("QA")/Quality Control ("QC")
sampling, analytical and data review procedures to be used during Phase 2 of the nitrate
investigation. It is important to note that the QAP submitted as Attachment 2 of this Work Plan is
based, where applicable, on the UDEQ-approved QAP currently used for groundwater sampling
at the Mill site.
3.0 PURPOSE AND SCOPE OF THE INVESTIGATION
3.1 Project Purpose
The purpose of groundwater sampling for non-isotopic analytes is to test the hypotheses that nitrate and
chloride mass observed in groundwater was caused by either military and/or agricultural uses of the Mill
site.
To test the hypothesis that non-Mill related historic activities caused the nitrate and chloride mass
observed in groundwater, non-isotopic marker or fingerprint analytes were chosen for analysis during
Phase 2 of the nitrate investigation. The Phase 2 analytes were chosen because they are non-Mill related
and specifically result and represent historical agricultural or military activities. The specific analytes of
interest for the Phase 2 nitrate investigation are cryptosporidium, HMX, RDX, and perchlorate.
Cryptosporidium is a wastebome intestinal parasite specific to cattle and livestock. The presence of
cryptosporidium in the groundwater samples collected during this investigation would be indicative of
agricultural influences in the groundwater at the Mill site.
RDX, HMX and perchlorate are compounds which have historic military uses. RDX and HMX are
military explosive compounds which are not available for commercial uses. The presence of either of
these analytes would be indicative of military influences on the groundwater at the Mill site, particularly
military activities associated involving incendiary devices.
Perchlorate is naturally occurring at extremely low levels, but was also used for multiple military
applications, particularly as an oxidant in solid rocket fuels and incendiary and chemical munitions.
Based on the historic military uses of the Mill site, perchlorate analyses at levels above background would
also be indicative of military influences on the groundwater at the Mill site.
It is assumed that any instances of cryptosporidium, RDX and HMX would be associated with ponds or
pond-like features, whose presence is necessary to generate the hydraulic head needed to carry
constituents to groundwater. Not all locations with elevated nitrate and chloride are associated with an
active pond. However, disturbances visible on aerial imagery far upgradient and far downgradient near
wells containing elevated concentrations of nitrate and chloride may have been related to historical ponds
at those locations. Therefore, an initial screening in a limited number of wells for cryptosporidium, RDX
3
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
and HMX will be completed. If positive detections are reported in the initial well group, a more
comprehensive sampling program and background determination will be completed for cryptosporidium.
RDX and HMX will not have a background determination because they are not natural to the
environment, that is, it is assumed that natural background concentrations would be non-detectable and
any detections would be the result of military activities.
Perchlorate was more frequently used in military applications, is relatively mobile, and as such the initial
sampling and screening will include more existing wells. As with cryptosporidium, RDX and HMX, if
any positive detections are reported, then a more comprehensive sampling program and background
determination (cryptosporidium only) will be completed.
The data resulting from this the Phase 2 nitrate investigation will be used to support the decision
processes which are described in the Phases 2 through 5 Work Plan.
3.2 Project Scope
The scope of this investigation does not include sampling and analysis for nitrate/nitrite as N, chloride
and ammonia as N. Nitrate/nitrite as N, chloride and ammonia as N are routinely sampled under the
groundwater point of compliance ("POC") sampling program and the chloroform and nitrate programs.
The historic data resulting from those programs will be used as necessary to meet the objectives of this
investigation. For these analytes, groundwater has already been established on an intra-well basis as
provided in Table 2 of the Mill's current Groundwater Discharge Permit, and no further background
analyses are necessary.
The scope of Phase 2 of the nitrate investigation includes sampling and analysis of a limited number of
existing groundwater wells for cryptosporidium, RDX and HMX to determine if further investigation into
agricultural and military based analytes is necessary. Additionally, a larger group of wells will be
screened for perchlorate. The initial screening program for cryptosporidium, RDX and HMX will
include sampling wells:
• TWN-2
• TW4-22
These wells were chosen for the initial screening program for cryptosporidium, RDX and HMX because
those wells are located in or near the location of a large historic pond which is visible on historic aerial
photographs. If positive detections are reported for cryptosporidium, RDX or HMX, the sampling
program would be expanded to include a background determination and additional wells. The additional
wells that would be sampled for cryptosporidium, RDX and HMX would include the wells listed below as
the wells to be sampled for perchlorate. The background wells that would be used for cryptosporidium
are also listed below in the background determination section of this Work Plan.
The initial screening program for perchlorate will include sampling wells:
• MW-20
• MW-31
• TWN-19
• TWN-2
• TWN-9
• TWN-17
4
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
• TW4-22
• MW-19
• MW-27
• MW-30
• TW4-24
• TW4-1
These wells were chosen for perchlorate screening due to their locations within the nitrate plume, their
locations near historic military activities, or their locations near historic ponds or pond-like features.
As previously stated, if positive detections are reported in the initial screening, a background
determination for perchlorate would be completed. The background study would be completed as
described below.
Background Determination
EPA (2002) states that a minimum of eight to ten samples are required for a statistically significant
background determination. Background for cryptosporidium and perchlorate will be determined by a
one-time sampling of groundwater in the following 10 monitor wells (see Figure 1 of the QAP):
TWN-8
TWN-ll
TWN-13
TWN-15
TWN-16
MW-l
MW-2
MW-3
MW-12
MW-18
The basis for the perchlorate background determination is as follows:
Fram and Bellitz (2011) state: "The data and model results indicate low concentrations (0.1-0.5
IIg/L) of perchlorate occur under natural conditions in groundwater across a wide range of climates,
beyond the arid to semiarid climates in which they mostly have been previously reported. The
probability of detecting perchlorate at concentrations greater than 0.1 flg/L under natural conditions
ranges from 50-70% in semiarid to arid regions of California and the Southwestern United States to
5 -15% in the wettest regions sampled (the Northern California coast). The probability of
concentrations above 1 flg/L under natural conditions is low (generally <3%)." Therefore, if
perchlorate is detected at concentrations above 1 Jlg/L a background will be determined.
Perchlorate and cryptosporidium results will be tabulated and background will be determined by the 95%
upper confidence level on the mean (95% DeL).
Background does not need to be developed for RDX or HMX because they are not natural to the
environment and therefore, any detection would be the result of military influences.
4.0 SITE DESCRIPTION
5
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
A detailed site description, background, site status, physical setting, and summary of previous
investigations is included in the Phases 2 through 5 Work Plan submitted under separate cover on June 3,
201l.
5.0 PROJECT OBJECTIVES
The objectives of this phase of the nitrate investigation is to:
1. Establish background for comparison to analytes not already addressed in the Mill's existing
background study reports and monitoring programs;
2. Produce valid data for comparison to background;
3. Identify locations of groundwater elevated in the constituents of concern; and
4. Provide data for incorporation in the Conceptual Site Model and decision process regarding
nitrate sources.
6.0 PHASE 2 SCHEDULE
Attachment 1 to this Work Plan is the schedule for sampling, analysis and data submission to DRC. As
indicated by the attached schedule, Phase 2 of the nitrate investigation may be conducted using a multi-
campaign sampling and analysis approach. Samples will be collected for an initial screening of
cryptosporidium, HMX, RDX and perchlorate as described in Section 3 above. The schedule included in
this Work Plan shows the additional analyses and background determination that may be conducted. The
determination of additional sampling will be made based on the analytical data resulting from the initial
sampling campaign.
6
ATTACHMENT 1
Phase 2 Schedule
Activity Date(s)
DUSA submits Phase 2 Nitrate Investigation Detailed Work Plan Friday July 1, 2011
and Schedule and QAP to UDEQ
UDEQ provides comments on Phase 2 Nitrate Investigation Monday July 11, 2011
Detailed Work Plan and Schedule and QAP
DUSA responds to comments and submits revised Phase 2 Nitrate Wednesday July 13, 2011
Investigation Detailed Work Plan and Schedule and QAP
Field Work -Campaign 1 Monday July 18,2011 -
Friday July 22,2011
Samples (except cryptosporidium) shipped to analytical Monday July 25,2011
laboratories
Samples (except cryptosporidium) arrive at analytical laboratories Tuesday July 26,2011
Analytical data received from analytical laboratories Tuesday August 16,2011
DUSA completes QAJQC review of data and completes Friday September 16, 2011
determination of necessity of campaign 2/background sampling
DUSA transmits analytical data packages, EDDs, and QAJQC Friday September 16, 2011
review results to UDEQ
Field Work -Campaign 2 (if required) Monday October 3,2011-
Friday October 14, 2011
Samples (except cryptosporidium) shipped to analytical Monday October 17, 2011
laboratories
Samples (except cryptosporidium) arrive at analytical laboratories Tuesday October 18, 2011
Analytical data received from analytical laboratories Tuesday November 8, 2100
DUSA transmits analytical data packages, EDDs, and QAJQC Thursday December 8, 2011
review results to UDEQ
Final Nitrate Investigation Report As noted in Phases 2 through 5
Work Plan schedule
ATTACHEMNT 2
Phase 2 QAP
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN
FOR PHASE 2 NITRATE INVESTIGATION
July 1, 2011
Revision 0
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
Quality Assurance Plan
Nitrate Investigation Pnase 2
1.0 INTRODUCTION ............................................................................................................................ 1
1.2 Scope of the QAP ............................................................................................................................... 1
1.3 Project Measurements ........................................................................................................................ 1
1.5 Sampling Design ................................................................................................................................ 2
2.0 ORGANIZATION AND RESPONSIBILITIES .............................................................................. 2
2.1 Functional Groups .............................................................................................................................. 2
2.2 Overall Responsibility For the QAJQC Program ............................................................................... 2
2.3 Data RequestorslUsers ........................................................................................................................ 2
2.4 Data Generators .................................................................................................................................. 2
2.4.1 Sampling and QC Monitors ......................................................................................................... 3
2.4.2 Analysis Monitor ......................................................................................................................... 3
2.4.3 Data Reviewers/Approvers .......................................................................................................... 3
2.5 Responsibilities of Analytical Laboratory .......................................................................................... 4
2.6 Special Training and Certification ...................................................................................................... 4
3.0 QUALITY ASSURANCE OBJECTNES FOR MEASUREMENT OF DATA ................................... 4
3.1 Precision ............................................................................................................................................. 5
3.2 Accuracy ............................................................................................................................................. 5
3.3 Representativeness ............................................................................................................................. 5
3.4 Completeness ...................................................................................................................................... 5
3.5 Comparability ..................................................................................................................................... 6
3.6 Detection/Reporting Limits ................................................................................................................ 6
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGy .................................................... 6
4.1 Controlling Well Contamination ........................................................................................................ 6
4.2 Controlling Depth to Groundwater Measurements ............................................................................. 6
4.3 Water Quality Control Samples .......................................................................................................... 6
4.3.1 VOC Trip Blanks ......................................................................................................................... 7
4.3.2 Equipment Rinsate Samples ........................................................................................................ 7
4.3.3 Field Duplicates ........................................................................................................................... 7
4.3.4 Definition of "Batch" ................................................................................................................... 7
4.3.5 Deionized Field Blanks ............................................................................................................... 7
5.0 CALIBRATION ..................................................................................................................................... 8
5.1 Depth to Groundwater Measurements ................................................................................................ 8
5.2 Water Quality ..................................................................................................................................... 8
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS ..................... 8
6.1 Groundwater Head Monitoring .......................................................................................................... 8
6.1.1 Location and Frequency of Groundwater Head Monitoring ....................................................... 8
Quality Assurance Plan
Nitrate Investigation Phase 2
6.1.2 Equipment Used for Groundwater Head Monitoring .................................................................. 9
6.1.3 Field Sampling Procedures for Groundwater Head Monitoring .................................................. 9
6.2 Groundwater Compliance Monitoring ................................................................................................ 9
6.2.1 Location and Frequency of Groundwater Compliance Monitoring ............................................. 9
6.2.2 Quarterly and Semi-Armual Sampling Required Under Paragraphs I.E. La) or I.E.1.b) of the
GWDP ................................................................................................................................................ 10
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP ...... 10
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring .............................................. 10
6.2.5 Decontamination Procedures ..................................................................................................... 11
6.2.6 Pre-Purging/ Sampling Activities .............................................................................................. 12
6.2.7 Well Purging/Measurement ofField Parameters ....................................................................... 12
6.2.8 Samples to be Taken and Order of Taking Samples .................................................................. 14
6.2.9 Field Duplicate Samples ............................................................................................................ 14
6.2.l0 VOCs and Nutrient Sampling/Perchlorate Cryptosporidium, RDX, HMX Sampling ............ 14
6.2.11 Heavy Metals, All Other Non-Radiologic and Gross Alpha Sampling ................................... 15
6.2.12 Procedures to Follow After Sampling ..................................................................................... 15
6.2.13 Sample Shipment ..................................................................................................................... 15
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING ........................................ 16
7.1 Field Data Worksheets ..................................................................................................................... 16
7.2 Chain-of-Custody and Analytical Request Record .......................................................................... 17
7.3 Record Keeping ................................................................................................................................ 18
8.0 ANALYTICAL PROCEDURES AND QAlQC .................................................................................. 18
8.1 Analytical Quality Control ............................................................................................................... 18
8.1.2 Spikes, Blanks and Duplicates ................................................................................................... 18
8.2 Analytical Laboratory Procedures .................................................................................................... 19
9.0 INTERNAL QUALITY CONTROL CHECKS ................................................................................... 19
9.1 Field QC Check Procedures ............................................................................................................. 19
9.1.1 Review of Compliance With the Procedures Contained in this Plan ........................................ 19
9.1.2 Analyte Completeness Review .................................................................................................. 19
9.1.3 Blank Comparisons ................................................................................................................... 20
9.1.4 Duplicate Sample Comparisons ................................................................................................. 20
9.2 Analytical Laboratory QA Reviews ................................................................................................. 20
9.3 QA Manager Review of Analytical Laboratory Results and Procedures ......................................... 20
9.4 Analytical Data ................................................................................................................................. 21
10.0 CORRECTIVE ACTION ................................................................................................................... 2 1
10.l When Corrective Action is Required .............................................................................................. 21
11.0 REPORTING ...................................................................................................................................... 21
11
Quality Assurance Plan
Nitrate Investigation Phase 2
12.0 SYSTEM AND PERFORMANCE AUDITS ..................................................................................... 22
12.1 QA Manager to Perform System Audits and Performance Audits ................................................. 22
12.2 Systems Audits ............................................................................................................................... 22
12.3 Performance Audits ........................................................................................................................ 22
12.4 Follow-Up Actions ......................................................................................................................... 22
12.5 Audit Records ................................................................................................................................. 22
13.0 PREVENTIVE MAINTENANCE ..................................................................................................... 22
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT ........................................................... 23
14.1 Ongoing QAlQC Reporting ............................................................................................................ 23
14.2 Periodic Reporting to Management ................................................................................................ 23
15.0 AMENDMENT .................................................................................................................................. 23
Table 1
Table 2
Figure 1
List of Tables
Analytical Methods, Reporting Limits Holding Times, Preservation, Temperature
and Volume Requirements for Phase 2 of the Nitrate Investigation
Groundwater Sample Locations
List of Figures
Phase 2 Groundwater Sampling Locations
List of Appendices
Attachment 1 Field Data Worksheets
iii
Quality Assurance Plan
Nitrate Investigation Phase 2
1.0 INTRODUCTION
This is the Quality Assurance Plan ("QAP") for the nitrate investigation, as required under the Final
Tolling Agreement, dated June 30, 2011, by and between Denison Mines (USA) Corp. and the Co-
Executive Secretary of the Utah Water Quality Board ("Co-Executive Secretary").
This QAP addresses the investigation-specific details and procedures necessary to complete Phase 2 of
the nitrate investigation as discussed in the Phase 2 Nitrate Investigation Detailed Work Plan and
Schedule. This QAP is in force only for the nitrate investigation described in the Revised Tolling
Agreement. This QAP does not alter, in any way, the other groundwater sampling programs currently
conducted at the Mill such as the groundwater Point of Compliance Monitoring Program, or the
Chloroform and Nitrate monitoring programs. Future revisions and versions of the UDEQ-approved
QAP will not include this Phase 2 QAP.
This QAP is based on the Utah Department of Environmental Quality (UDEQ)-approved Groundwater
Monitoring Quality Assurance Plan ("UDEQ-approved GW QAP") submitted by Denison Mines (USA)
Corp. ("DUSA") for groundwater monitoring activities conducted at the White Mesa Uranium Mill (the
"Mill"), in Blanding Utah. The UDEQ-approved GW QAP referenced herein was submitted by DUSA to
meet the requirements specified in the State of Utah Groundwater Discharge Permit ("GWDP") Number
UGW370004. Pursuant to Part I.E.1.a of the GWDP, "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. " The current UDEQ-approved GW QAP, Revision 6,
dated March 22,2010, was used as the basis for this QAP.
The organization of this QAP is based on the UDEQ-approved QAP. The Section numbers used in this
QAP are the same as those in the UDEQ-approved QAP. If the current nitrate investigation requirements
differ from the UDEQ-approved QAP, the investigation-specific details are provided herein. If the
requirements or procedures described in the UDEQ-approved QAP are to be used unchanged, the Section
is repeated for ease of review and highlighted in grey. Any sections that have been newly developed or
modified for the purposes of this nitrate investigation appear in regular type.
This QAP is based on the UDEQ-approved QAP to maximize the comparability of data collected during
this nitrate investigation to the historic data collected during routine groundwater monitoring conducted at
the Mill. In addition, utilizing UDEQ-approved procedures, where possible, eliminates the necessity for
"re-review" of previously approved procedures and will allow completion offield work expeditiously.
1.2 Scope ofthe QAP
The QAP provides the Quality Assurance ("QA")/Quality Control ("QC") sampling, analytical and data
review procedures to be used during Phase 2 of the nitrate investigation. The Work Plan is the primary
document and describes, either directly or through reference, the purpose of this phase of the
investigation, the site description and site background, and the project objectives for Phase 2 of the nitrate
investigation.
1.3 Project Measurements
Project measurements will include field measurements collected during the purging and sampling of the
wells and the analytical data resulting from the analysis of the samples collected during this nitrate
investigation. Samples will be analyzed for perchlorate, RDX, HMX and cryptosporidium. Analytical
methods are specified in Revised Table 1
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Quality Assurance Plan
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1.5 Sampling Design
One groundwater sample will be collected from each of the wells specified in Section 6.2 of this QAP.
Sampling methodology is described throughout this plan. Groundwater samples will be analyzed for
perchlorate, RDX, HMX, and cryptosporidium to meet the project objectives listed in the Phase 2 Nitrate
Investigation Detailed Work Plan and Schedule.
Data evaluation is described throughout this plan. Specifically QC assessment of the data collected
during this nitrate investigation is discussed in Section 9.0 of this QAP.
2.0 ORGANIZATION AND RESPONSmILITIES
2.1 Functional Groups
This Plan specifies roles for a QA Manager as well as representatives of three different functional groups:
the data users; the data generators, and the data reviewers/approvers. The roles and responsibilities of
these representatives are described below.
2.2 Overall Responsibility For the QAlQC Program
The overall responsibility for ensuring that the Quality Assurance/Quality Control ("QAlQC") measures
are properly employed is the responsibility of the QA Manager. The QA Manager is typically not directly
involved in the data generation (i.e., sampling or analysis) activities. The QA Manager is a qualified
person designated by DUSA corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives of this Plan is necessary for management to make
informed decisions relating to the operation of the Mill facility, and to be consistent, as far as practicable,
with the reporting requirements set out in the GWDP. Accordingly, the data requesters/users (the "Data
Users") are therefore DUSA's corporate management and regulatory authorities through the
implementation of such permits and regulations. The data quality objectives ("DQOs") required for any
groundwater sampling event, such as acceptable minimum detection limits, are specified in this Plan.
2.4 Data Generators
The individuals who carry out the sampling and analysis activities at the request of the Data Users are the
data generators. For Mill activities, this involves sample collection, record keeping and QAlQC activities
conducted by one or more sampling and quality controVdata monitors (each a "Sampling and QC
Monitor"). The Sampling and QC Monitors are radiation and environmental technicians or other
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors perform all
field sampling activities, collect all field QC samples and perform all data recording and chain of custody
activities in accordance with this Plan. Data generation at the contract analytical laboratory (the
"Analytical Laboratory") utilized by the Mill to analyze the environmental samples is performed by or
under an employee or agent (the "Analysis Monitor") of the Analytical Laboratory, in accordance with
specific requirements of the Analytical Laboratory's own QAlQC program.
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Quality Assurance Plan
Nitrate Investigation Phase 2
2.4.1 Sampling and OC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in Plan;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-custody
records, packing lists) is correct and transmitting that information, along with the samples, to the
Analytical Laboratory in accordance with this Plan;
c) Maintaining records of all samples, tracking those samples through subsequent processing and
analysis, and, ultimately, where applicable, appropriately disposing of those samples at the
conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling event;
e) Preparing QC and sample data for review by the QA Manager; and
f) Preparing QC and sample data for reporting and entry into a computer data base, where
appropriate.
Ryan Palmer will serve as the Sampling and QC Monitor for Phase 2 of the nitrate investigation.
2.4.2 Analysis Monitor
The Analysis Monitor is responsible for QAlQC activities at the Analytical Laboratory. These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and analytical
procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to the packing
list or chain-of-custody sheet; and
Verifying that Analytical Laboratory QC and analytical procedures are being followed as specified in this
Plan, by the Analytical Laboratory's QAlQC program, and in accordance with the requirements for
maintaining National Environmental Laboratory Accreditation Program ("NELAP") and/or National
Voluntary Laboratory Accreditation Program ("NA VLAP") certification as applicable.
The State of Utah does not currently have a certification process for cryptosporidium analyses. Every
effort will be made to use an EPA-Approved laboratory for the analysis of cryptosporidium. The
December 17, 2010 revision of "Laboratories Approved for the Analysis of Cryptosporidium under the
Safe Drinking Water Act" will be used as the starting point for contracting a cryptosporidium laboratory.
If none of those laboratories will accept outside samples, or are willing or able to perform the analyses, an
alternate laboratory may be used. NELAC and NA VLAP certification are not available for microbiology
laboratories and as such does not apply to the cryptosporidium laboratory. All other analyses will be
performed by Utah-certified laboratories.
2.4.3 Data Reviewers/Approvers
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Quality Assurance Plan
Nitrate Investigation Phase 2
The QA Manager has broad authority to approve or disapprove project plans, specific analyses and final
reports. In general, the QA Manager is responsible for reviewing and advising on all aspects of QNQC,
including:
a) Ensuring that the data produced by the data generators meet the specifications set out in this
Plan;
b) Making on-site evaluations and sUbmitting audit samples to assist in reviewing QNQC
procedures;
c) Detennining (with the Sampling and QC Monitor and Analysis Monitor) appropriate sampling
equipment and sample containers, in accordance with this Plan, to minimize contamination; and
d) Supervising all QNQC measures to assure proper adherence to this Plan and detennining
corrective measures to be taken when deviations from this Plan occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and QC
Monitors or to other qualified Mill personnel.
2.5 Responsibilities of Analytical Laboratory
Unless otherwise specified by DUSA corporate management, all environmental analysis of groundwater
samples collected during this nitrate investigation will be performed by a contract Analytical Laboratory.
The Analytical Laboratory is responsible for providing sample analyses for groundwater samples and for
reviewing all analytical data to assure that data are valid and of sufficient quality. The Analytical
Laboratory is also responsible for data validation in accordance with the requirements for maintaining
NELAP and/or NA VLAP certification as applicable.
The Analytical Laborator(ies) will be chosen by DUSA and must satisfy the following criteria: (1)
experience in ~n~lyzing environmental samples with detail for precision ~nd ~ccuracy, (2) experience
with similar matrix analyses, (3) operation of a stringent internal quality assurance program meeting
NELAP andlor NAVLAP certification requirements (as applicable to all analyses except
cryptosporidium) and that satisfies the criteria set out in Section 8 below, and (4) where possible, certified
by the State of Utah for and capable of performing the analytical methods set out in Revised Table 1
(except for cryptosporidium as noted above).
A revision of Table 1 from the approved QAP, incorporating additional analytes for the Nitrate Phase 2
Investigation, has been included with this QAP.
2.6 Special Training and Certification
Site-specific training for all field personnel will be completed as required by Mill procedures and will be
conducted by Mill personnel.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this Plan is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, representativeness, completeness, and comparability required for
management purposes and to comply with the reporting requirements established by applicable permits
and regulationstand to meet the data needs for the decision analysis in the Phases 2 to 5 Work Plan (the
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Quality Assurance Plan
Nitrate Investigation Phase 2
Field and Analytical QC samples described in Sections 4.3 and 8.1 below are designed to ensure that
these criteria are satisfied). Data subject to QAlQC measures are deemed more reliable than data without
any QAlQC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample measurements of
the same property under identical conditions. Precision is measured through the analysis of samples
containing identical concentrations of the parameters of concern. For duplicate measurements, precision
is expressed as the relative percent difference ("RPD") of a data pair and will be calculated by the
following equation:
RPD = [(A-B)/ {(A+B) /2}] x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate samples analyses
(or, in the case of analyses performed by the Analytical Laboratory, the percent recoveries for matrix
spike and matrix spike duplicate samples) (EPA SW-846, Chapter 1, Section 5.0, page 28).
3.2 Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a measured
value and an accepted or true value. The accuracy of laboratory analyses is evaluated based on analyzing
standards of known concentration both before and during analysis. Accuracy will be evaluated by the
following equation (EPA SW-846, Chapter 1, Section 5.0, page 24):
% Recovery = (I A-B I /C) x 100
Where:
A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defmed as the degree to which a set of data accurately represents the characteristics
of a population, parameter, conditions at a sampling point, or an environmental condition.
Representativeness is controlled by performing all sampling in compliance with this Plan.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in reference to the
amount that could be obtained under ideal conditions. Laboratory completeness is a measure of the
number of samples submitted for analysis compared to the number of analyses found acceptable after
review of the analytical data. Completeness will be calculated by the following equation:
Completeness = (Number of valid data points/total number of measurements) x 100
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Quality Assurance Plan
Nitrate Investigation Phase 2
Where the number of valid data points is the total number of valid analytical measurements based on the
precision, accuracy, and holding time evaluation. Completeness is determined at the conclusion of the
data validation.
The completeness goal for this investigation is 95%.
3.5 Comparability
Comparability refers to the confidence with which one set of data can be compared to another measuring
the same property. Data are comparable if sampling conditions, collection techniques, measurement
procedures, methods, and reporting units are consistent for all samples within a sample set.
3.6 Detection/Reporting Limits
The method detection limit ("MDL") is the minimum concentration of an analyte that can be reliably
distinguished from background for a specific analytical method. The reporting limit represents the lowest
concentration of an analyte that can be accurately and reproducibly quantified in a sample matrix. Project-
required reporting limits are minimum quantitation limits for specific analytical methods and sample
matrices that are typically several times the MDL to allow for matrix effects. The reporting limits for the
nitrate investigation are specified in Revised Table 1. Reporting limits may be increased due to sample
matrix interference (i.e., due to dilution gain).
A reporting limit is not specified for cryptosporidium in the EPA methodology. Reporting limits are not
applicable to this method as it is a qualitative method and as such does not follow the same rigorous
quantification systems for reporting limit detenninations and quantitative methodologies.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over the surface
casing and cementing the surface section of the drill hole. Wells have surface covers of mild steel with a
lockable cap cover. Radiation Safety staff has access to the keys locking the wells.
Subsurface well stagnation, for pumped wells, is reduced by pumping two well casing volumes of water
from the wens, to the extent practicable. This ensures, to the extent practicable, that the aquifer zone
water is being drawn into the wen and is a representative sample.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field log data to actual
measurement depth. TIris serves as a check of the field measurements.
4.3 Water Quality Control Samples
Quality control samples collected during the nitrate investigation are as follows :
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Quality Assurance Plan
Nitrate Investigation Phase 2
4.3.1 VOC Trip Blanks
Volatile organic compound ("VOC") trip blanks will not be collected during the nitrate investigation
because the nitrate investigation samples will not be analyzed for VOCs and as such trip blanks are not
required.
4.3.2 Equipment Rinsate Samples
Equipment rinsate samples are required when a portable (non-dedicated) pump is used for purging and
sampling. For this investigation both dedicated pumps (in the point of compliance groundwater wells)
and a portable pump (used for the nitrate and chloroform program wells) will be used for purging and
sampling. Equipment rinsate samples will not be collected when the dedicated pumps are used for
sampling.
When the portable pump is used for sampling, equipment rinsate samples will be collected at the
frequency specified by UDEQ personnel (Phil Goble) in e-mail correspondence dated October 4, 2010.
Per the e-mail correspondence, equipment rinsate samples are only required at the beginning of the
sampling event and at the beginning of each day of sampling when the portable pump is used for purging
and sampling. Decontamination of the portable pump is required prior to the first use and after each
subsequent use.
Per standard Mill sampling procedures, if a well is purged dry using the portable pump it is sampled using
a disposable bailer. All bailers used will be disposable and an equipment rinsate sample will not be
required.
Equipment rinsate samples will be collected from the portable pump after the completion of
decontamination as described in Section 6.2.5 of this QAP. The equipment rinsate sample will be
collected from the portable pump by pumping deionized water into the laboratory-supplied sample
containers.
Rinsate samples will be labeled with the name of the subsequently purged well with a terminal letter "R"
added (e.g. TW4-7R).
4.3.3 Field Duplicates
One Duplicate set of samples submitted with each Batch per sampling campaign (defined in Section
4.3.4) of samples (DTG, Field and Laboratory Quality Assurance/Quality Control, 7.8), will be taken
from one of the wells being sampled and will be submitted to the Analytical Laboratory and analyzed for
perchlorate, cryptosporidium, HMX and RDX.
The duplicate sample is scheduled to be collected as noted in Section 6.2 below. Duplicates will be
labeled with a "false" well number such as MW-65 or MW-70.
4.3.4 Definition of "Batch"
For the purposes of this Plan, a Batch is defined as 20 or fewer samples (PA SW-846, Chapter 1,
Section 5.0, page 23).
4.3.5 Deionized Field Blanks
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Quality Assurance Plan
Nitrate Investigation Phase 2
A minimum of one deionized field blank (DIFB) will be collected during this investigation. A DIFB is a
blank sample collected from the Mill deionized water system which is used to asses if any contamination
is introduced into the decontamination and equipment rinsate processes from the deionized water used for
decontamination and equipment rinsate collection.
The DIFB will be labeled with a "false" well number such as MW-60.
5.0 CALmRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample collection
and analytical instruments. Sampling equipment shall be calibrated in accordance with manufacturers'
recommendations, and Analytical Laboratory equipment shall be calibrated in accordance with Analytical
Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to each use to ensure that
the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the beginning of each
day of the sampling event according to manufacturer's specifications (for example, by using two known
pH solutions and one specific conductance standard.) Temperature will be checked comparatively by
using a thermometer. Calibration results will be recorded on the Field Data Worksheet.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS
6.1 Groundwater Head Monitoring
6.1.1 Location and Frequency of Groundwater Head Monitoring
Depth to groundwater is measured quarterly in all point of compliance wells, background wells,
monitoring wells, chloroform monitoring wells, nitrate program wells, and piezometers as stipulated in
the GWDP and other program-specific plans, Con'ective Action Orders, and Consent Agreements. The
quarterly depth to groundwater measurements will be completed as required, independent of this
investigation. Those measurements may be used during the interpretation of the nitrate investigation data,
but are not required as part of the nitrate investigation and as such descriptions and requirements of those
procedures are not required for the nitrate investigation. The quarterly depth to groundwater
measurements will be collected following the procedures described in the UDEQ-approved QAP.
Depth to groundwater will be measured in the wells to be sampled, independent of the above-described
quarterly program, immediately prior to sampling for the purposes of calculating casing/purge volumes.
The pre-sampling depth to groundwater measurements will be recorded on the Field Data sheet for each
well. Procedures for the pre-sample depth to groundwater measurement are described in Section 6.1.3 of
the UDEQ-approved QAP.
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Quality Assurance Plan
Nitrate Investigation Phase 2
6.1.2 Equipment Used for Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist -IT 300 or equivalent device
(the "Water Sounding Device").
6.1.3 Field Sampli ng Procedures for Groundwater Head Monitoring
In the case of any well that is being sampled for groundwater quality, depth to groundwater is measured
prior to sampling.
Depth to groundwater is measured from the top of the inner well casing or, for the piezometers, from the
top of the casing, and is recorded on the Field Data Worksheet for Groundwater described in Section 7.1
(the "Field Data Worksheet"). Readings are taken by lowering the Water Sounding Device into the
casing until the Device alarms, indicating that the water surface has been reached. The depth to
groundwater is then determined by reference to the distance markings on the line attached to the Device.
Data is recorded on the Field Data Worksheet as Depth to Water, to the nearest 0.01 of a foot.
6.2 Groundwater Compliance Monitoring
6.2.1 Location and Frequency o[Groundwater Compliance Monitoring
Groundwater samples will be collected from the wells listed below for this nitrate investigation. Samples
will be named according to the well number specified below.
The purpose of groundwater sampling for the Phase 2 nitrate investigation is to provide data to
supplement the Conceptual Site Model and to support or eliminate hypotheses regarding potential sources
of nitrate and chloride at the site. The sampling delineated herein is not compliance monitoring.
The following wells, which are also presented on Figure 1, will be sampled for cryptosporidium, RDX
and HMX during the Phase 2 nitrate investigation, campaign 1 are as follows:
• TWN-2
• TW4-22
The following wells, which are also presented on Figure 1, will be sampled for perchlorate during the
Phase 2 nitrate investigation, campaign 1 are as follows:
• MW-20
• MW-31
• TWN-19
• TWN-2
• TWN-9
• TWN-17
• MW-19
• MW-27
• MW-30
• TW4-22
• TW4-24
• TW4-1
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Quality Assurance Plan
Nitrate Investigation Phase 2
UDEQ proposed that TW4-4 be sampled during this investigation. TW4-4 is a continuously pumped well
under the chloroform monitoring program conducted under the State of Utah Notice of Violation and
Groundwater Corrective Action Order UDEQ Docket No. UGQ-20-0 1. Because TW 4-4 is a continuously
pumped well it is not representative of groundwater conditions because it is drawing water in a radial
pattern from around the well. The pumping results in groundwater from the well becoming a mixture of
water that has been in contact with a wide variety of aquifer matrices and, therefore, it is not possible to
interpret a water quality analysis from a sample collected from that well. TW4-1 has been substituted for
TW4-4 due to its close proximity to TW4-4 and its location within the nitrate plume.
Background (if necessary) for cryptosporidium and perchlorate will be determined by a one-time
sampling of groundwater in the following monitor wells (see Figure 1):
• TWN-8
• TWN-ll
• TWN-13
• TWN-15
• TWN-16
• MW-l
• MW-2
• MW-3
• MW-12
• MW-18
6.2.2 Quarterly and Semi-Annual Sampling Required Under Paragraphs lE.1.a) or I.E.l .b) of the GWDP
The paragraphs cited in this Section are not applicable to this nitrate investigation because the wells
sampled during this nitrate investigation are not being sampled to satisfy the requirements of Paragraphs
lE.1.a) or lE.1.b) of the GWDP. The nitrate investigation is being conducted to satisfy the objectives
specified in The Nitrate Investigation Phase 2 Detailed Work Plan and Schedule.
The samples collected during the nitrate investigation will be sampled for the following parameters:
• Field parameters -depth to groundwater, pH, temperature, specific conductance, redox potential
(Eh) and turbidity in the manner specified herein, and
• Analytical parameters -cryptosporidium, perchlorate, HMX and RDX. Analytical methods are
specified in the Revised Table 1 included with this QAP.
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.l or LG .2 oftlle GWDP
This Section is not applicable to the nitrate investigation. No monthly or quarterly accelerated sampling
will be conducted as part of the nitrate investigation.
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring
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Quality Assurance Plan
Nitrate Investigation Phase 2
All equipment used for purging and sampling of groundwater which enters the well or may otherwise
contact sampled groundwater, shall be made of inert materials.
For the purposes of this QAP the following equipment defInitions shall apply:
• Disposable Bailer: A bailer that is disposable to be used at one specifIc well for the use of
purging or sampling. Disposable bailers will be disposed of after a single use and will not be
decontaminated. Equipment rinsate samples will not be collected when a disposable bailer is
used to purge or sample a well.
• Dedicated Pump: A pump that is dedicated to one specifIc well for purging and sampling.
Dedicated pumps will remain secured inside the well casing.
• Portable Pump: A pump that is used for purging and sampling at one or more wells.
Sampling will be completed using the equipment listed below or an equivalent. Combinations of the
equipment listed below may be used as necessary to collect samples for this investigation. The equipment
used to collect samples at each well will be determined by site-specifIc conditions encountered at the time
of sampling (for example, volume of groundwater available etc.). Sampling equipment includes:
• Bailers made of inert materials,
• Water level measurement tape/sounding device,
• Field Data sheets,
• Sample labels,
• Sample coolers and ice,
• Disposable gloves,
• Purge water containment system
• Dedicated pumps,
• Sample fIlters for perchlorate (provided by the Analytical Laboratory)
• Generator,
• Flow Cell Multi-Parameter Meter system or equivalent. Field parameters are measured by using
a flow cell system that enables the measurements to be taken on a real-time basis without
exposing the water stream to the atmosphere. The Field Parameter Meter measures the following
parameters:
(i) Water temperature;
(ii) SpecifIc conductivity;
(iii) Turbidity
(iv) Standard pH;
(v) Redox potential (Eh).
• Sample containers and preservation chemicals (as provided by the Analytical Laboratory), and
• Five gallon bucket.
6.2.5 Decontamination Procedures
If the portable (non-dedicated) pump is to be used for purging and sampling, prior to each sampling event
and between each sampling location (well), decontaminate the portable (non-dedicated) sampling pump
prior to its use for purging or sampling using the procedure outlined below. The detergent/deionized
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Quality Assurance Plan
Nitrate Investigation Phase 2
water mixture will be reused for one sampling day per UDEQ personnel (as documented in e-mail
correspondence from Phil Goble dated October 4,2010).
a) Submerse the pump into a 55-gallon drum containing a non-phosphate detergent and deionized water
mixture. Pump the detergent/deionized water mixture through the pump for approximately 5 minutes
to simulate pumping 50 gallons of detergent/water mixture. This decontamination fluid can be reused
for one day of sampling as noted above.
b) Submerse the pump into a 55-gallon drum containing deionized water. Pump the detergent/deionized
water mixture through the pump. Dispose of the deionized water and do not reuse.
c) Repeat step b) above. If an equipment rinsate sample will be collected use the deionized water from
this step.
The pump should then be protected from contamination until used for purging or sampling.
All water produced during decontamination will be disposed of in Tailings Cell 1.
6.2.6 Pre-Purging/ Sampling Activities
• If a portable (non-dedicated) pump is to be used, prior to commencing the event's sampling
activities, check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the samples;
• If a portable (non-dedicated) pump is to be used, prior to each sampling event and at the
beginning of each day during the sampling event, decontaminate the sampling pump using the
procedure set forth in Section 6.2.5;
• If a portable (non-dedicated) pump is to be used, after completion of decontamination prepare one
equipment rinsate sample per day.
6.2.7 Well Purging/Measurement ofField Parameters
a) Remove the well casing cap and measure and record depth to groundwater by following the
procedures set out in paragraph 6.1.3 above;
b) Determine the casing volume (V) in gallons, where h is column height of the water in the well
(calculated by subtracting the depth to groundwater in the well from the total depth of the well),
V = 0.653*h, for a 4" casing volume and V = .367*h for a 3" casing volume. Record the casing
volume on the Field Data Worksheet;
c) If the RSO has advised the field technician that immiscible contaminants (i.e., LNAPLs or
DNAPLs) are known to occur or could potentially occur in the subsurface at the location of the
well, follow the additional procedures, to be provided by the RSO, prior to well purging;
d) Purging, Where Use of Pump is Effective (See paragraph 6.2.7 e» below, where bailer is
required)
If a portable (non-dedicated) pump is used, ensure that it has been decontaminated in accordance with
Section 6.2.5 since its last use in a different well, lower the pump into the well, making sure to keep the
pump at least five feet from the bottom of the well. Be sure never to drop the pump into the well, as this
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Quality Assurance Plan
Nitrate Investigation Phase 2
will cause degassing of the water upon impact. Once the pump is lowered into the well, or if the well has
a dedicated pump, perform the following steps:
(i) Commence pumping;
(ii) Determine pump flow rate by using a stopwatch and a calibrated bucket by measuring the
number of seconds required to fill to the one-gallon mark. Record this in the "pumping
rate" section of the Field Data Worksheet;
(iii) Calculate the amount of time to evacuate two casing volumes;
(iv) Evacuate two casing volumes (if possible) by pumping for the length of time determined
in paragraph (iii);
(v) Take measurements of field parameters (pH, specific conductance, temperature, redox
potential and turbidity) during well purging, using the Field Parameter Meter and
turbidity measuring instrument. These measurements will be recorded on the Field Data
Worksheet. Purging is completed after two casing volumes have been removed and the
field parameters pH, temperature, specific conductance, redox potential (Eh) and
turbidity have stabilized to within 10% RPD over at least two consecutive measurements.
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. In addition, turbidity measurement in the
water should be ::::: 5 NTU prior to sampling (DTG Well Development 6.7, page 6-48)
unless the well is characterized by water that has a higher turbidity. A flow-cell needs to
be used for field parameters. If the well is purged to dryness or is purged such that full
recovery exceeds two hours, the well should be sampled as soon as a sufficient volume of
groundwater is available to fill sample containers (DTG, Well Purging, 7.2.4, page 7-9);
(vi) If the well yields two casing volumes, the individual performing the sampling should
immediately proceed to Section 6.2.8);
(vii) If the well cannot yield two casing volumes,
A. Evacuate the well to dryness and record the number of gallons evacuated on the
Field Data Worksheet; and
B. Prior to sampling, measure and record depth to groundwater on the Field Data
Worksheet following the procedures set out in paragraph 6.1.3 above;
e) Purging, Where Use of Pump is Not Effective
For wells where a pump is not effective for purging and/or sampling (wells with shallow water columns,
i.e., where the water column is less than five feet above the bottom of the well casing or the well takes
over two days to recover from purging), a disposable bailer, made of inert materials, may be used. If a
bailer is used, the following procedure will be followed:
(i) Use the sound level instrument to determine the water column and figure the amount of
water that must be evacuated;
(ii) Attach a 3" disposable bailer to a rope and reel;
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Quality Assurance Plan
Nitrate Investigation Phase 2
(iii) Lower the bailer into the well and listen for contact with the solution. Once contact is
made, allow the bailer to gradually sink in the well, being careful not to allow the bailer
to come in contact with the bottom sediment;
(iv) After the bailer is full, retrieve the bailer and discharge the water from the bailer into 5
gallon buckets. By doing this, one can record the number of gallons purged;
(v) After the bailer is emptied, lower the bailer back into the well and gain another sample
as before. This process will continue until the two casing volumes have been collected
or until no more water can be retrieved. When the process is finished for the well, the
bailer will be disposed of; and
(vi) Take field measurements referred to in paragraph 6.2.7(d)(v) above from the water in
the buckets
f) All water produced during well purging will be containerized. Containerized water will be
disposed of in either Tailings Cell .
6.2.8 Samples to be Taken and Order of Taking Samples
For the nitrate investigation, samples will be collected from each well in the following order:
• Perchlorate
• Cryptosporidium
• RDXandHMX
Sample containers, chemical preservatives and ftlters for perchlorate will be provided by the analytical
laboratory. Sample containers and analytical holding times are specified in Revised Table 1.
6.2.9 Field Duplicate Samples
Per the UDEQ-approved QAP, one set of field duplicate samples is required for each batch of samples per
campaign. Field duplicates will be analyzed for the same parameters as noted above. Field duplicates
will be collected by alternately filling the parent sample followed by filling the duplicate sample
container. Samples will be collected in the order specified in Section 6.2.8 above.
6.2.10 VOCs and Nutrient Sampling/Perchlorate Cryptosporidium, RDX, HMX Sampling
VOCs and nutrients will not be collected during the nitrate investigation. The following procedure will
be used to collect the samples for perchlorate, cryptosporidium, and RDX and HMX.
Sample collection will vary depending on whether a portable pump, dedicated pump or bailer is used for
purging the well prior to sampling. Nitrate/nitrite as N and ammonia will be collected as described below.
Per the UDEQ-approved, routine groundwater sampling procedures in use at the Mill site, the wells with
dedicated pumps will be sampled directly from the pump immediately after purging. If the well does not
run dry, purging will be considered complete after two casing volumes have been removed and field
parameters have stabilized as indicated in Section 6.2.7. All dedicated pumps used for purging and
sampling are "low flow" pumps and therefore volatilization of constituents is not a concern.
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Quality Assurance Plan
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If the wells go dry prior to purging two casing volumes, the stabilization of field parameters or both, the
well will be sampled when it recovers to within at least 90 percent of the static groundwater level before
sampling. If a well is purged dry, stabilization of field parameters is no longer required. If the well is
purged dry, and full recovery exceeds 2 hours, the well will be sampled as soon as a sufficient volume of
water is available to fill the sample containers.
The UDEQ-approved, routine groundwater (chloroform and nitrate sampling programs) sampling
procedures will be used for the wells purged with the portable pump. The portable pump will be used to
purge the well as required in Section 6.2.7, if the well does not go dry. The day following purging, the
wells will be sampled with a disposable bailer. If the wells go dry prior to purging two casing volumes,
the stabilization of field parameters or both, the well will be sampled the following day with a disposable
bailer if there is sufficient water to fill all of the sample containers. If sufficient water is not available for
sampling, the wells will be sampled as soon as sufficient water is available to fill all of the sample
containers.
The perchlorate sample will be filtered prior to filling the sample container. To complete the filtering,
perchlorate samples will be collected as a bulk sample into a clean, unused sample container. A portion
of the bulk sample will be filtered using a syringe and filter provided by the laboratory, into the final
sample container (also provided by the laboratory). The filters, bulk sample containers and syringes will
be disposable and will not require decontamination.
Chemical preservatives will be added to the laboratory-supplied sample containers. The sample is then
added to the preserved container either from the dedicated pump or the bailer depending on the purging
method used.
6.2.11 Heavv Metals, All Other Non-Radiologic and Gross Alpha Sampling
Heavy metals and gross alpha samples will not be collected during the nitrate investigation.
Only perchlorate samples will require filtering in the field. The perchlorate field filter procedure is
described above and as such the filtering procedures in the UDEQ-approved QAP are not applicable.
6.2.12 Procedures to Follow After Sampling
Per the EPA analytical methods for perchlorate and cryptosporidium, the receipt temperatures at the
Analytical Laboratories are less than or equal to lOOC and less than or equal to 20°C respectively. The
receipt temperature for RDX and HMX is 6°C.
6.2.13 Sample Shipment
The following procedures will be implemented when samples collected during the remediation activities
are shipped:
• The cooler will be filled with bubble wrap, sample containers, and packing material. Sufficient
packing material will be used to minimize sample container breakage during shipment.
• The COC forms will be placed inside a plastic bag. The bag will be sealed and taped to the inside
of the cooler lid. The air bill, if required, will be filled out before the samples are handed over to
the carrier. The Analytical Laboratory will be notified if the sampler suspects that the sample
contains any substance that would require Analytical Laboratory personnel to take safety
precautions.
• The cooler will be closed and taped shut with packing tape around both ends. If the cooler has a
drain, it will be taped shut both inside and outside of the cooler.
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Quality Assurance Plan
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• Signed and dated custody seals will be placed on the front and side of each cooler. Wide clear
tape will be placed over the seals.
• The COC form will be transported within the taped, sealed cooler. When the cooler is received at
the Analytical Laboratory, Analytical Laboratory personnel will open the cooler and sign the
COC form to document transfer of samples.
• Multiple coolers may be sent in one shipment to the Analytical Laboratory. The outsides of the
coolers will be marked to indicate the number of coolers in the shipment.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1 Field Data Worksheets
Documentation of observations and data from sampling provide important information about the
sampling process and provide a permanent record for sampling activities. All observations and field
sampling data will be recorded in waterproof ink on the Field Data Worksheets, which will be maintained
on file at the Mill.
The Field Data Worksheets will contain the following information:
• Name of the site/facility
• description of sampling event
• location of sample (well name)
• sampler's name(s) and signature(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• results of in-field measurements (pH, specific conductance, water temperature)
• redox potential (Eh) measurements
• turbidity measurements
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type and condition of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
The Field Data Worksheets will also contain detailed notes describing any other significant factors during
the sampling event, including, as applicable: condition of the well cap and lock; water appearance, color,
odor, clarity; presence of debris or solids; any variances from this Procedure; and any other relevant
feature or condition. An example of a Field Data Worksheet that incorporates this information is
provided as Appendix 1.
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Quality Assurance Plan
Nitrate Investigation Phase 2
7.2 Chain-of-Custody and Analytical Request Record
Standard sample custody procedures will be used to maintain and document sample integrity during
collection, transportation, storage, and analysis. A sample will be considered to be in custody if one of the
following statements applies:
• It is in a person's physical possession or view.
• It is in a secure area with restricted access.
• It is placed in a container and secured with an official seal in such a way that the sample cannot
be reached without breaking the seal.
COC procedures provide an accurate written record that traces the possession of individual samples from
the time of collection in the field to the time of acceptance at the Analytical Laboratory. The COC form
will also be used to document all samples collected and the analyses requested. Information that the field
personnel will record on the COC form includes the following:
• Project name and number
• Sampling location
• Name and signature of sampler
• Destination of sample (Analytical Laboratory name)
• Sample ID
• Date and time of collection
• Number and type of containers filled
• Analyses requested
• Preservatives used (if applicable)
• Filtering (if applicable)
• Signatures of individuals involved in custody transfer, including the date and time of transfer
• Project contact and phone number
Field personnel will sign COC forms. The COC form will be placed in a waterproof plastic bag and taped
to the inside of the shipping container used to transport the samples. Signed air bills will serve as
evidence of custody transfer between field personnel and the courier, and between the courier and the
Analytical Laboratory. Copies of the COC form and the air bill will be retained and filed by field
personnel before the containers are shipped.
The Analytical Laboratory sample custodian will receive all incoming samples, sign the accompanying
coe forms, and retain copies of the forms as permanent records. The Analytical Laboratory sample
custodian will record all pertinent information concerning the samples, including the persons delivering
the samples, the date and time received, sample condition at the time of receipt (e.g., sealed, unsealed, or
broken container; temperature; or other relevant remarks), the sample IDs, and any unique Analytical
Laboratory IDs for the samples. When the sample transfer process is complete, the custodian is
responsible for maintaining internal log books, tracking reports, and other records necessary to maintain
custody throughout sample preparation and analysis.
The Analytical Laboratory will provide a secure storage area for all samples. Access to this area will be
restricted to authorized personnel. The custodian will ensure that samples requiring special handling,
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Quality Assurance Plan
Nitrate Investigation Phase 2
including samples that are heat-or light-sensitive, radioactive, or have other unusual physical
characteristics, are properly stored and maintained pending analysis.
7.3 Record Keeping
The original Field Data Worksheets are maintained at the Mill site.
Electronic copies of the analyses from the Analytical Laboratory, showing the laboratory analytical
results for the groundwater samples are maintained in the DUSA corporate offices. Hardcopies may be
printed by the Mill Staff, however, the record copy is maintained in the DUSA corporate offices.
DUSA will use State of Utah certified laboratories for nitrate/nitrite as N, ammonia as N, chloride and
perchlorate analyses. As previously stated the State of Utah does not currently have a certification
process for cryptosporidium analyses. Every effort will be made to use an EPA-Approved laboratory for
the analysis of cryptosporidium. The December 17, 2010 revision of "Laboratories Approved for the
Analysis of Cryptosporidium under the Safe Drinking Water Act" will be used as the starting point for
contracting a cryptosporidium laboratory. If none of those laboratories will accept outside samples, or are
willing or able to perform the analyses, an alternate laboratory may be used.
Once all the data for the nitrate investigation is received, key data from the Field Data Worksheets and
from the analytical data reports are maintained in a computer file. These computer files are maintained at
the DUSA corporate offices.
8.0 ANALYTICAL PROCEDURES AND QAlQC
Analytical Laboratory QA provides a means for establishing consistency in the performance of analytical
procedures and assuring adherence to analytical methods utilized. Analytical Laboratory QC programs
include traceability of measurements to independent reference materials and internal controls.
8.1 Analytical Quality Control
Analytical QAlQC will be governed by the QAlQC program of the Analytical Laboratory as well as the
analytical method. In choosing and retaining the Analytical Laboratory, DUSA will use Analytical
Laboratories that are certified by the State of Utah and by NELAP and/or NAVLAP for perchlorate,
HMX and RDX (if possible), are capable of performing the analytical procedures specified in Section 8.2,
and have a QAlQC program that includes the analytical method QC requirements.
8.1.2 Spikes, Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses. Following are
descriptions of the types of QC samples that may be used by the Analytical Laboratory to assess the
quality of the data. Analytical QC will be completed as required by the specific method used for analysis.
Assessment of Analytical Laboratory QC samples will be as specified in the method. Cryptosporidium
analysis is a microbiological qualitative analysis and as such some of the QC samples discussed below
may not be applicable. QC for cryptosporidium will follow the EPA method.
a. Matrix SpikelMatrix Spike Duplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical batch.
Analytes stipulated by the analytical method, by applicable regulations, or by other specific
requirements may be spiked into the samples. Selection of the sample to be spiked depends on the
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Quality Assurance Plan
Nitrate Investigation Phase 2
information required and the variety of conditions within a typical matrix. The matrix spike
sample serves as a check evaluating the effect of the sample matrix on the accuracy of analysis.
The matrix spike duplicate serves as a check of the analytical precision. Assessment of the matrix
spike/matrix spike duplicate will be completed using the method-and Analytical Laboratory-
established limits.
b. Method Blanks
Each analytical batch shall be accompanied by a method blank. The method blank shall be carried
through the entire analytical procedure. Contamination detected in analysis of method blanks will
be used to evaluate any Analytical Laboratory contamination of environmental samples which
may have occurred. Method blank detections will be assessed to determine if there is any effect
on the sample data usability. Method blank effects will be discussed and a determination made on
a case-by-case basis.
c. Check Samples
Each analytical batch shall contain a number of check samples. For each method, the Analytical
Laboratory will analyze the check samples or their equivalents specified in the analytical method.
Check samples may include a laboratory control sample ("LCS"), calibration checks, laboratory
fortified blanks, or sample duplicates. Check samples will be reviewed for compliance with the
Analytical Laboratory and method-specified acceptance limits.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory for the nitrate investigation are
specified in Revised Table 1.
9.0 INTERNAL QUALITY CONTROL CHECKS
Internal quality control checks are inherent in this Plan. The QA Manager will monitor the performance
of the Sample and QC Monitors, and, to the extent practicable, the Analysis Monitor to ensure that they
are following this Plan. In addition, either the QA Manager or a Sampling and QC Monitor will review
and validate the analytical data generated by the Analytical Laboratory to ensure that it meets the DQOs
established by this Plant. Finally, periodic system and performance audits will be performed, as detailed
in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QAlQC analysis of field procedures:
9.1.1 Review of Compliance With the Procedures Contained in this Plan
Observation of technician performance is monitored by the QA Manager on a periodic basis to ensure
compliance with this Plan. Assessment of technician performance may be conducted through on-site
observation or through review of field documentation.
9.1.2 Analyte Completeness Review
The QA Manager will review all analytical results to confirm that the analytical results are complete (i.e.,
there is an analytical result for each required constituent). The completeness goal for this project is 95%.
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Quality Assurance Plan
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9.1.3 Blank Comparisons
Equipment rinsate samples will be compared with original sample results. Non-conformance conditions
will exist when contaminant levels in the blank(s)/samples(s) are within an order of magnitude of the
original sample result. (TEGD, Field QAlQC Program, page 119).
9.1.4 Duplicate Sample Comparisons
a) Relative Percent Difference
RPDs will 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
required detection limit (Standard Methods, 1998) (EPA Contract Laboratory Program National
Functional Guidelines for Inorganic Data Review, February 1994, 9240.1-05-01, p. 25).
b) Radiologics Counting Error
Samples collected during the nitrate investigation will not be analyzed for radiologic constituents and
therefore this section does not apply.
c) Radiologics, Duplicate Samples
Samples collected during the nitrate investigation will not be analyzed for radiologic constituents and
therefore this section does not apply.
9.2 Analytical Laboratory QA Reviews
All data will undergo a QC review which will include validating holding times and QC samples. Overall
data assessment will be a part ofthe validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based on the
analytical methods used. The reviewer will check the following: (1) sample preparation information is
correct and complete, (2) analysis information is correct and complete, (3) appropriate Analytical
Laboratory procedures are followed, (4) analytical results are correct and complete, (5) QC samples are
within established control limits, (6) blanks are within QC limits, (7) special sample preparation and
analytical requirements have been met, and (8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The Analytical
Laboratory will report the data along with the QAlQC data. The Analytical Laboratory will provide the
following information: (1) cover sheet listing samples included in report with a narrative, (2) results of
compounds identified and quantified, and (3) reporting limits for all analytes. Also to be included are the
QAlQC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
a) Reporting Limit Comparisons
The QA Manager shall confmn that all reporting limits used by the Analytical Laboratory are in
conformance with the reporting limits set out on Table 1. Non-conformance shall be defmed as: 1) a
reporting limit that violates these provisions, unless the reporting limit must be increased due to
sample matrix interference (i.e., due to dilution gain);
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Quality Assurance Plan
Nitrate Investigation Phase 2
b) Laboratory Methods Review
The QA Manager shall confIrm that the analytical methods used by the Analytical Laboratory are
those specifIed in Table 1.
c) Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defmed when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received by the
Analytical Laboratory at a temperature no greater than the approved temperature listed in Table 1.
Non-conformance shall be defIned when the sample temperature is exceeded.
9.4 Analytical Data
All QNQC data and records required by the Analytical Laboratory's QNQC program shall be retained
by the Analytical Laboratory and shall be made available to DUSA as requested.
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following procedures in
accordance with this Plan. Corrective action should be taken for any procedure defIciencies or deviations
noted in this Plan. All deviations from fIeld sampling procedures will be noted on the Field Data
Worksheets or other applicable records. Any QA/QC problems that arise will be brought to the
immediate attention of the QA Manager. Analytical Laboratory deviations will be recorded by the
Analysis Monitor in a logbook as well.
Non-conformance will be handled as follows:
a) When non-conformance occurs as specifIed in Sections 9.1.3, 9.1.4 or 9.3, the data may be
qualifIed to denote the problem
b) When a sample is lost, sample container broken, or the sample or analyte was omitted, resample
within 10 days of discovery and analyze again in compliance with all requirements of this Plan.
11.0 REPORTING
Reporting of the nitrate investigation results will be completed as described in the schedule contained in
the Phase 2 Nitrate Detailed Work Plan and Schedule.
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Quality Assurance Plan
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12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
DUSA may perform system and performance audits in order to ensure that data of known and defensible
quality are produced during a sampling program. The frequency and timing of system and performance
audits shall be as determined by DUSA.
12.2 Systems Audits
System audits are qualitative evaluations of all components of field and Analytical Laboratory QC
measurement systems. They determine if the measurement systems are being used appropriately. System
audits may review field and Analytical Laboratory operations, including sampling equipment, laboratory
equipment, sampling procedures, and equipment calibrations, to evaluate the effectiveness of the QA
program and to identify any weakness that may exist. The audits may be carried out before all systems
are operational, during the program, or after the completion of the program. Such audits typically involve
a comparison of the activities required under this Plan with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data collection and
management activities.
12.3 Performance Audits
The performance audit is a quantitative evaluation of the measurement systems of a program. It requires
testing the measurement systems with samples of known composition or behavior to evaluate precision
and accuracy. With respect to performance audits of the analytical process, either blind performance
evaluation samples will be submitted to the Analytical Laboratory for analysis, or the auditor will request
that it provide results of the blind studies that the Analytical Laboratory must provide to its NELAP
and/or NA VLAP accreditation agency on an annual basis. The performance audit is carried out without
the knowledge of the analysts, to the extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found and
corrective action is required. Where a corrective action is required, the steps set out in Section 10.2 will
be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records will contain
audit reports, written records of completion for corrective actions, and any other documents associated
with the audits supporting audit fmdings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory instruments.
Preventive maintenance helps ensure that monitoring data generated will be of sufficient quality to meet
QA objectives. Both field and laboratory instruments have a set maintenance schedule to ensure proper
functioning of the instruments.
Field instruments will be maintained as per the manufacturer's specifications and established sampling
practice. Field instruments will be checked and calibrated prior to use, in accordance with Section 5.
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Quality Assurance Plan
Nitrate Investigation Phase 2
Batteries will be charged and checked daily when these instruments are in use. All equipment out of
service will be immediately replaced. Field instruments will be protected from adverse weather
conditions during sampling activities. Instruments will be stored properly at the end of each working day.
Calibration and maintenance problems encountered will be recorded in the Field Data Worksheets or
logbook.
The Analytical Laboratory is responsible for the maintenance and calibration of its instruments in
accordance with Analytical Laboratory procedures and as required in order to maintain its NELAP and/or
NA VLAP certifications. Preventive maintenance will be performed on a scheduled basis to minimize
downtime and the potential interruption of analytical work.
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QAlQC Reporting
The following reporting activities shall be undertaken on a regular basis:
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding progress of the
applicable sampling program. The Sample and QC Monitors will also brief the QA Manager on
any QAlQC issues associated with such sampling activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record keeping. Each
data set report submitted to the Mill's QA Manager or his staff will identify the analytical methods
performed and all QAlQC measures not within the established control limits. Any QAlQC
problems will be brought to the QA Manager's attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a brief data
evaluation summary report will be prepared by the Analytical Laboratory for review by the QA
Manager, by a Sampling and QC Monitor or by such other qualified person as may be designated
by the QA Manager. The report will be prepared in accordance with NELAP and/or NA VLAP
requirements and will summarize the data validation efforts and provide an evaluation of the data
quality.
14.2 Periodic Reporting to Management
Periodic reports to management as described in the UDEQ-approved QAP are not applicable to this
nitrate investigation. The nitrate investigation described herein will be assessed as part of the entire
sampling program as part of an annual assessment. Assessments and specific reporting resulting from the
implementation of this nitrate investigation are discussed throughout this plan and the Phase 2 Nitrate
Detailed Work Plan and Schedule.
15.0 AMENDMENT
Amendment of this plan may be made to accommodate field conditions noted during sampling.
Amendments to this plan will be documented on the Field Data Sheets, logbooks or both as applicable.
Field conditions which prompted the changes will be fully described so as to properly document and
describe the site conditions.
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Quality Assurance Plan
Nitrate Investigation Phase 2
WellID
TWN-2
TW4-22
MW-19
MW-20
MW-27
MW-30
MW-31
TWN-2
TWN-9
TWN-17
TWN-19
TWN-l
TWN-24
DIPB
MW-19
MW-20
MW-27
MW-30
MW-31
TWN-2
TWN-9
TWN-17
TWN-19
TWN-l
TWN-24
DIPB
TWN-8
Table 2 Groundwater Sample Locations
Sample ID Duplicate Analytesl
Location ID
Campaign 1
Cryptosporidium
TWN-2 X Perchlorate
Explosives (RDX and HMX)
Cryptosporidium
TW4-22 Perchlorate
Explosives (RDX and HMX)
MW-19 Perchlorate
MW-20 Perchlorate
MW-27 Perchlorate
MW-30 Perchlorate
MW-31 Perchlorate
TWN-2 Perchlorate
TWN-9 Perchlorate
TWN-17 Perchlorate
TWN-19 Perchlorate
TWN-l Perchlorate
TWN-24 Perchlorate
DIFB Perchlorate
Campaign 2 (if needed)
MW-19 Cryptosporidium
Explosives (RDX and HMX)
MW-20 Cryptosporidium
Explosives (RDX and HMX)
MW-27 Cryptosporidium
Explosives (RDX and HMX)
MW-30 Cryptosporidium
Explosives (RDX and HMX)
MW-31 Cryptosporidium
Explosives (RDX and HMX)
TWN-2 Cryptosporidium
Explosives (RDX and HMX)
TWN-9 Cryptosporidium
Explosives (RDX and HMX)
TWN-17 Cryptosporidium
Explosives (RDX and HMX)
TWN-19 Cryptosporidium
Explosives (RDX and HMX)
TWN-l Cryptosporidium
Explosives (RDX and HMX)
TWN-24 X Cryptosporidium
Explosives (RDX and HMX)
DIPB Cryptosporidium
Explosives (RDX and HMX)
Background Wells -Campai :,1 2
TWN-8 Cryptosporidium
Explosives (RDX and HMX)
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Quality Assurance Plan
Nitrate Investigation Phase 2
Well ID
TWN-ll
TWN-13
TWN-15
TWN-16
MW-l
MW-2
MW-3
MW-12
MW-18
Sample ID
TWN-ll
TWN-13
TWN-15
TWN-16
MW-l
MW-2
MW-3
MW-12
MW-18
Duplicate Analytes1
Location ID
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
X Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
I AnalytIcal methods, sample volumes, contamers and preservatIOn are hsted III Table 1.
Duplicate samples will be labeled as MW-65 or MW-70.
Duplicate samples may be collected from alternate wells if insufficient volume is unavailable after purging. The
decision to move a duplicate sample will be made in the field based on field conditions and will be documented in
the field notes.
26
Appendix 1
Field Data Work Sheet
Figure