DRC-2011-008296 - 0901a06880363a0a

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MINES
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Denison Mines (USA) Corp.
105017th street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
July 12, 2011
VIA PDF and FEDERAL EXPRESS
Mr. Rusty Lundberg
Executive Secretary
Utah Division of Radiation Control
Utah Department of Environmental Quality nDP Oflll 00090 A
195North 1950 West UrAU-CUiJ--UU0L7VJ
Sah Lake City, UT 84116-3097
Re: Nitrate Investigation Groundwater Phase 2 Detailed Workplan ~ Nitrate
Investigation at the White Mesa MiU Site - Docket No. UGW09-03
Dear Mr. Lundberg:
Pursuant to page 7 of the Tolling Agreement, Revision 2, 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 revisions, dated July 11, 2011, to the Phase 2 White Mesa
Mill Nitrate Investigation Detailed Work Plan and Schedule.
This revision has been prepared in response to comments fi*om Utah Division of Radiation
Control and URS Corporation dated July 7, 2011. The revision has been provided in both clean
and track changes ("redline") format for ease of review.
The responses to comments are summarized below. Each response below has been identified by
the number of the corresponding comment in the July 7, 2011 letter.
1. No response required.
2. A reference section has been added to the Work Plan and QAP as requested.
3. The language has been modified to state "Cryptosporidium is common in cattle and
livestock".
4. No response required.
5. No response required.
6. No response required.
7. The text has been changed as follows "The text below describes how DUSA would
determine whether a site-specific background study would be required, and how the
background would be developed". The text as modified clarifies that the site-specific
background study is required only if positive detections are reported in the initial
sampling. That is different fi-om the text DRC has suggested, which could imply that a
site-specific background study would be required regardless.
8. No response required.
9. The change has been made as requested.
10. The schedule has been changed as requested.
11. The following text has been added to Section 6.2.12 of Attachment 2: "Samples not
shipped on the same day as they are collected will be refiigerated onsite until shipment".
The holding time and schedule for sample shipments for HMX and RDX has been
changed as requested.
12. The change has been made as requested.
13. No response required.
14. The laboratory has been selected. At the time of the initial QAP submission, DUSA was
waiting for a response fi-om the laboratories regarding their ability to analyze the
Cryptosporidium samples. DUSA has chosen Energy Laboratories (EL) in Casper
Wyoming to complete the Cryptosporidium analyses. EL is on the EPA list of acceptable
laboratories. A footnote has been added to Table 1 listing EL as the laboratory that will
be used for Cryptosporidium analyses.
15. DUSA does not believe it is necessary or practicable to obtain Dl water from a third party
commercial source for the following reasons:
1) The Dl water from the Mill Dl system is currently used and is considered suitable for
all groundwater monitoring programs at the Mill which are subject to compliance and
enforcement requirements. 2) The large volume of water necessary for decontamination
and rinsate blanks precludes the ability to have the Dl water produced and shipped from a
third party. Per the currently approved Mill groundwater procedures, the portable pump
is submerged into 55-gallon barrels of decontamination fluids and Dl water and the fluids
are pumped through the portable pump. The procedure proposed for this investigation is
pumping 55-gallons of soap solution made with Dl water followed by dual Dl rinses;
each 55 gallons. The soap solution can be reused for one sampling day; however, the Dl
solutions would be used only once and disposed of after they have been through the
pump. Since there are seven wells that will be sampled using the portable pump, that is
770 gallons of Dl water for that step alone. In addition to the 770 gallons, the added
volume for soap solutions and the initial decontamination of the pump prior to the first
use increases the total Dl usage to over 1,000 gallons. Procurement of over 1,000 gallons
of Dl water from a third party commercial laboratory source is logistically not feasible.
3) Although, DRC has expressed a concem in the past that nitrate may be present in the
Mill Dl system, that concem is not relevant for the Phase 2 investigation in which nitrate
will not be analyzed. 4) DUSA has successfiilly eliminated low-level nitrate from the
rinsate blanks during the second quarter chloroform investigation through the addition of
the second Dl rinse (with an additional 55-gallons of Dl water). The nitrate in the rinsate
blanks is originating from the nitric acid rinse used during the decontamination processes
currently used for the compliance monitoring programs. For this investigation DUSA has
eliminated the nitric acid rinse during decontamination AND has added the second rinse
DENISO MINES
with Dl water. For the foregoing reasons the requested change has not been made to the
QAP.
16. The change has been made as requested.
17. The change has been made as requested.
18. DUSA does not believe that third-party validation is necessary or appropriate for the
following reasons:
1) The current validation procedure used is considered suitable for all groundwater
monitoring programs at the Mill which are subject to compliance and enforcement
requirements. 2) All of the QC sample reviews cited in the conunent including
duplicates, rinsate blanks, and laboratory QC samples are currently completed by the
DUSA QA Manager as discussed in Section 9.0 of the QAP. Again, these reviews are
considered suitable for compliance and enforcement determinations for all of the
groimdwater programs at the Mill. 3) The Executive Secretary has the ability to take
split samples and to perform his own validation on those samples. 4) The scenario
presented in the comment stating that low-level detections may be changed to
nondetected results is in conflict with UDEQ-approved procedures currently enforced
for Mill groundwater data. Changing a low-level detection to a nondetected result is the
effective equivalent of raising the detection limit. To date, UDEQ has not allowed
raising detection limits unless it is the result of a dilution necessary to bring a high
sample result within the calibration range of an instmment. Per the approved QAP, a
raised detection limit may be reported only if the result is greater than the raised
detection limit. DUSA has received NOVs in the past for raising detection limits for
samples with low-level or no detections to compensate for matrix interferences. DUSA
has not been allowed to raise detection limits for the convenience of the laboratory and
prevention of laboratory instrumental damage. 5) Validating data from this study and
application of a different set of criteria would render the current data incomparable to
historic data. None of the constituents being sampled in Phase 2 are present in the
historical suite of data; however, application of differing criteria results in differing
interpretations of data usability for whole data sets thus rendering the data incomparable.
6) Validation criteria need to be specified prior to sample collection and analysis so that
the laboratory can produce data packages which provide the information necessary to
complete the data validation specified. Specialized data package requests need to be
submitted to the laboratory to minimize laboratory costs and laboratory labor.
Requesting larger data packages after the fact causes delays in schedule, and data
packages are difficult and expensive to recreate. Specification of this prior to analysis
allows the timely collection of all of the appropriate data at the time of analysis. 7) If
there are any detections of any of the constituents in Phase 2, Denison would consider
repeat sampling for those constituents. A sentence to that effect has been added to
Section 3.1 of the Phase 2 Nitrate Investigation Detailed Work Plan and Schedule. For
these reasons, the requested change has not been made to the plans.
If the Executive Secretary believes that third-party validation is required to verify the
validity of low level detections, then the Mill's Groundwater Discharge Permit should
DENISO
MINES
Mi
be amended to require third party validation prior to any accelerated monitoring or out
of compliance requirements being triggered.
19. Perchlorate will be analyzed by EPA Method 6850. The RL is 0.5 ug/L, which is
sufficient for meeting the objectives of this investigation. A Utah-certified laboratory
has been chosen to complete the analyses.
20. The change has been made as requested.
If you have any further questions please contact me at 303-389-4132.
Yours very tmly.
Jo Ann S. Tischler
Director, Compliance and Permitting
Enclosure.
cc Robert D. Baird, URS
Daniel W. Erskine, Ph.D, INTERA
David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Katherine A. Weinel
DENISO
MINES
WHITE MESA URANIUM MILL
PHASE 2 NITRATE INVESTIGATION
DETAILED WORK PLAN AND SCHEDULE
July 12,2011
Revision 1
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
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 INVESTIGATION 3
3.1 Project Purpose 3
3.2 Project Scope 4
4.0 SITE DESCRIPTION 5
5.0 PROJECT OBJECTIVES 6
6.0 PHASE 2 SCHEDULE 6
7.0 REFERENCES 6
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 "MiU") Site, near Blanding,
Utah (the "Request") from the Co-Executive Secretary (the "Co-Executive Secretary") of the Utah Water
Quality Board, ofthe 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 Febmary 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-
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 I.
• DUSA to prepare and submit a revised Work Plan(s) 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 fiirther consideration.
2. Assist in quantifying the relative contribution of the 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 I, 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
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 common in 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
constiments 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
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 resuh of military activities. Positive detections of Cryptosporidium and/or
HMX and RDX may also be followed with repeat sampling.
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. Positive detections of perchlorate may also be
followed with repeat sampling.
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 resuhing 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
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.
The text below describes how DUSA would determine whether a site-specific background study would be
required, and how the background would be developed.
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-11
TWN-13
TWN-15
TWN-16
MW-1
MW-2
MW-3
MW-12
MW-18
The basis for the site-specific perchlorate background determination is as follows:
Fram and Bellitz (2011) state: "The data and model results indicate low concentrations (0.1-0.5
fig/L) of perchlorate occur under natural conditions in goundwater 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 /ug/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 fig/L under natural conditions is low (generally <3%)." Therefore, if
perchlorate is detected at concentrations above 1 |Lig/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% UCL).
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
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,
2011.
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 concem; 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.
7.0 REFERENCES
Denison Mines (USA) Corp. and Utah Water Quality Board (Co-Executive Secretary). 2011. Tolling
Agreement.
. 2009. Stipulated Consent Agreement, Docket No. UGW09-03.
Fram, M.S., and Belitz, Kenneth. 2011. "Probability of Detecting Perchlorate under Natural Conditions in
Deep Groundwater in California and the Southwestern United States." Environ. Sci. Technol,
2011,45 (4), pp 1271-1277.
INTERA Inc. 2009. Nitrate Contamination Investigation Report, White Mesa Uranium Mill Site,
Blanding Utah.
. 201 la. Nitrate Investigation Revised Phase 1 Work Plan, White Mesa Mill Site, Blanding Utah.
May 13.
. 201 lb. Nitrate Investigation Revised Phases 2 through 5 Work Plan, Rev. 1.0, White Mesa Mill
Site, Blanding Utah (Draft).
U.S. Environmental Protection Agency (EPA). 2002. "Guidance for Comparing Background and
Chemical Concentrations in Soil for CERCLA Sites." Office of Emergency and Remedial
Response, U.S. Environmental Protection Agency. Washington, DC, EPA 540-R-01-003.
September.
ATTACHMENT 1
Phase 2 Schedule
Activity Date(s)
DUSA submits Phase 2 Nitrate Investigation Detailed Work Plan
and Schedule and QAP to UDEQ
Friday July 1,2011
UDEQ provides comments on Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule and QAP
Monday July 11,2011
DUSA responds to comments and submits revised Phase 2 Nitrate
Investigation Detailed Work Plan and Schedule and QAP
Wednesday July 13,2011
Field Work - Campaign 1 Monday July 18, 2011 -
Friday July 22, 2011
Cryptosporidium and explosives shipped to analytical laboratories
either the same day as collection or the day following collection
(Cryptosporidium and explosives samples will not be collected on
Friday July 22,2011 due to holding time limitations)
Monday July 18,2011 -
Thursday July 21, 2011
Samples (except Cryptosporidium and explosives) shipped to
analytical laboratories
Monday July 25, 2011
Samples (except Cryptosporidium) arrive at analytical laboratories Tuesday July 26, 2011
Analytical data received from analytical laboratories Tuesday August 16, 2011
DUSA completes QA/QC review of data and completes
determination of necessity of campaign 2/background sampling
Friday September 16, 2011
DUSA transmits analytical data packages, EDDs, and QA/QC
review results to UDEQ
Friday September 16, 2011
Field Work - Campaign 2 (if required) Monday September 19, 2011 -
Friday September 30, 2011
Cryptosporidium and explosives shipped to analytical laboratories
either the same day as collection or the day following collection
(Cryptosporidium and explosives samples will not be collected on
Fridays due to holding time limitations)
Monday September 19, 2011 -
Thursday September 29,2011
Samples (except Cryptosporidium and explosives) shipped to
analytical laboratories
Monday September 26, 2011
and Monday October 3, 2011
Samples (except Cryptosporidium) arrive at analytical laboratories Tuesday September 27, 2011
and Tuesday October 4,2011
Analytical data received from analytical laboratories Friday November 4, 2011
DUSA transmits analytical data packages, EDDs, and QA/QC
review results to UDEQ
Thursday December 8, 2011
Final Nitrate Investigation Report As noted in Phases 2 through 5
Work Plan schedule
ATTACHMENT 2
Phase 2 QAP
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN
FOR PHASE 2 NITRATE INVESTIGATION
July 12,2011
Revision 1
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
Quality Assurance Plan
Nitrate Investigation Phase 2
1.0 INTRODUCTION 1
1.2 Scope ofthe 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 QA/QC Program 2
2.3 Data Requestors/Users 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 OBJECTIVES 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 VOCTrip Blanks 6
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 8
6.1.3 Field Sampling Procedures for Groundwater Head Monitoring 8
6.2 Groundwater Compliance Monitoring 9
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 9
6.2.2 Quarterly and Semi-Annual Sampling Required Under Paragraphs I.E. 1 .a) or I.E. 1 .b) of the
GWDP 10
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.I 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 of Field Parameters 12
6.2.8 Samples to be Taken and Order of Taking Samples 14
6.2.9 Field Duplicate Samples 14
6.2.10 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 16
7.3 Record Keeping 17
8.0 ANALYTICAL PROCEDURES AND QA/QC 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 19
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 21
10.1 When Corrective Action is Required 21
11.0 REPORTING 21
Quality Assurance Plan
Nitrate Investigation Phase 2
12.0 SYSTEM AND PERFORMANCE AUDITS 21
12.1 QA Manager to Perform System Audits and Performance Audits 21
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 QA/QC Reporting 23
14.2 Periodic Reporting to Management 23
15.0 AMENDMENT 23
16.0 REFERENCES 23
List of Tables
Table 1 Analytical Methods, Reporting Limits Holding Times, Preservation, Temperature
and Volume Requirements for Phase 2 of the Nitrate Investigation
Table 2 Groundwater Sample Locations
Figure 1
List of Figures
Phase 2 Groundwater Sampling Locations
List of Appendices
Attachment 1 Field Data Worksheets
ill
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.I.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 of field 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 ofthe nitrate
investigation.
1.3 Project Measurements
Project measurements will include field measurements collected during the purging and sampling ofthe
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
Quality Assurance Plan
Nitrate Investigation Phase 2
1.5 Sampling Design
One groundwater sample will be collected from each of the wells specified in Section 6.2 ofthis 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 RESPONSIBILITIES
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 QA/QC Program
The overall responsibility for ensuring that the Quality Assurance/Quality Control ("QA/QC") 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 QA/QC activities
conducted by one or more sampling and quality control/data 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 aU 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 requu-ements of the Analytical Laboratory's own QA/QC program.
Quality Assurance Plan
Nitrate Investigation Phase 2
2.4.1 Sampling and QC 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, ultunately, 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 Analvsis Monitor
The Analysis Monitor is responsible for QA/QC 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 QA/QC program, and in accordance with the requirements for
maintaining National Environmental Laboratory Accreditation Program ("NELAP") and/or National
Voluntary Laboratory Accreditation Program ("TSIAVLAP") certification as applicable.
The State of Utah does not currently have a certification process for Cryptosporidium analyses. An EPA-
Approved laboratory from the December 17, 2010 revision of "Laboratories Approved for the Analysis
of Cryptosporidium under the Safe Drinking Water Act" will be used for the analysis of Cryptosporidium.
NELAC and NAVLAP 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
The QA Manager has broad authority to approve or disapprove project plans, specific analyses and fmal
reports. In general, the QA Manager is responsible for reviewing and advising on all aspects of QA/QC,
including:
Quality Assurance Plan
Nitrate Investigation Phase 2
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 QA/QC
procediu'es;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate sampling
equipment and sample containers, in accordance with this Plan, to mmimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this Plan and determining
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 MiU 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 NAVLAP certification as applicable.
The Analytical Laborator(ies) will be chosen by DUSA and must satisfy the following criteria: (1)
experience in analyzing environmental samples with detail for precision and accuracy, (2) experience
with similar matrix analyses, (3) operation of a stringent intemal quality assurance program meeting
NELAP and/or 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
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 QA/QC measures are deemed more reliable than data without
any QA/QC measures.
Quality Assurance Plan
Nitrate Investigation Phase 2
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 concem. 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 tme 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 = ( | A-B | /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 defined 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
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%.
Quality Assurance Plan
Nitrate Investigation Phase 2
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 determinations and quantitative methodologies.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from extemal 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 wells, to the extent practicable. This ensures, to the extent practicable, that the aquifer zone
water is being drawn into the well 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. This 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:
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.
Quality Assurance Plan
Nitrate Investigation Phase 2
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 defmed as 20 or fewer samples (EPA SW-846, Chapter
1, Section 5.0, page 23).
4.3.5 Deionized Field Blanks
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.
Quality Assurance Plan
Nitrate Investigation Phase 2
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample collection
and analytical instmments. Sampling equipment shall be calibrated in accordance with manufacturers'
recommendations, and Analytical Laboratory equipment shaU 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, Corrective 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.
6.1.2 Equipment Used for Groundwater Head Monitoring
Measurement of depth to groimdwater is accomplished by using a Solinist - IT 300 or equivalent device
(the "Water Sounding Device").
6.1.3 Field Sampling Procedures for Groundwater Head Monitoring
Quality Assurance Plan
Nitrate Investigation Phase 2
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 mto 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 Frequencv of 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
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-20-01. Because TW4-4 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
Quality Assurance Plan
Nitrate Investigation Phase 2
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-1
MW-2
MW-3
MW-12
MW-18
6.2.2 Quarterly and Semi-Annual Sampling Required Under Paragraphs I.E. 1 .a) or I.E. 1 .b) ofthe 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
I.E.I.a) or I.E.l.b) ofthe 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.I or I.G.2 ofthe 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
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.
10
Quality Assurance Plan
Nitrate Investigation Phase 2
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 Muhi-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
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 dmm 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 dmm 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.
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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 of Field 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 ofthe
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
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 pumpmg for the length of time determined
in paragraph (iii);
12
Quality Assurance Plan
Nitrate Investigation Phase 2
(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 m 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;
(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
baUer will be disposed of; and
13
Quality Assurance Plan
Nitrate Investigation Phase 2
(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 wUl 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
• RDX and HMX
Sample containers, chemical preservatives and filters 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 VQCs 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.
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 concem.
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
14
Quality Assurance Plan
Nitrate Investigation Phase 2
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 Heavy 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 10°C and less than or equal to 20°C respectively. The
receipt temperature for RDX and HMX is 6°C.
Samples not shipped on the same day as they are collected will be refrigerated on-site until shipment.
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.
• 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.
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Quality Assurance Plan
Nitrate Investigation Phase 2
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 m waterproof ink on the Field Data Worksheets, which will be mamtained
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 extemal 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
feamre or condition. An example of a Field Data Worksheet that incorporates this information is
provided as Appendix 1.
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 ofthe
following statements applies:
• It is in a person's physical possession or view.
• It is in a secure area with restricted access.
16
Quality Assurance Plan
Nitrate Investigation Phase 2
• 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
COC forms, and retain copies of the forms as permanent records. The Analytical Laboratory sample
custodian will record all pertinent information conceming 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 intemal 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,
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.
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Quality Assurance Plan
Nitrate Investigation Phase 2
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.
The State of Utah does not currently have a certification process for Cryptosporidium analyses. An EPA-
Approved laboratory from the December 17, 2010 revision of "Laboratories Approved for the Analysis
of Cryptosporidium under the Safe Drinking Water Acf will be used for the analysis of Cryptosporidium.
NELAC and NAVLAP 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.
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 QA/QC
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 intemal controls.
8.1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC 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 QA/QC 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 Spike/Matrix 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
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 ofthe matrix
spike/matrix spike duplicate will be completed using the method- and Analytical Laboratory-
established limits.
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Quality Assurance Plan
Nitrate Investigation Phase 2
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 laboratoty 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
Intemal 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 QA/QC 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 Analvte Completeness Review
The QA Manager will review all analytical results to confirm that the analytical results are complete (i.e.,
there is an analytical resuh for each required constituent). The completeness goal for this project is 95%.
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 QA/QC Program, page 119).
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Quality Assurance Plan
Nitrate Investigation Phase 2
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, Febmary 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 of the 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 QAJQC 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
QA/QC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
a) Reporting Limit Comparisons
The QA Manager shall confrnn 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 defined 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);
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory are
those specified in Table 1.
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Quality Assurance Plan
Nitrate Investigation Phase 2
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 defined 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 QA/QC data and records required by the Analytical Laboratory's QA/QC program shall be retained
by the Analytical Laboratory and shall be made available to DUSA as requested.
10.0 CORRECTTVE 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 ofthis 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.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
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Quality Assurance Plan
Nitrate Investigation Phase 2
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 requu^ed 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 resuhs of the blind studies that the Analytical Laboratory must provide to its NELAP
and/or NAVLAP 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 findings 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 instmments have a set maintenance schedule to ensure proper
functioning of the instmments.
Field instruments will be maintained as per the manufacturer's specifications and established sampling
practice. Field instmments wUl be checked and calibrated prior to use, in accordance with Section 5.
Batteries will be charged and checked daily when these instmments are in use. All equipment out of
service will be immediately replaced. Field instmments will be protected from adverse weather
conditions during sampling activities. Instmments will be stored properly at the end of each working day.
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Quality Assurance Plan
Nitrate Investigation Phase 2
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 instmments in
accordance with Analytical Laboratory procedures and as required in order to maintain its NELAP and/or
NAVLAP certifications. Preventive maintenance will be performed on a scheduled basis to minimize
downtime and the potential intermption of analytical work.
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC 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 QA/QC 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 QA/QC measures not within the established control limits. Any QA/QC
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 NAVLAP
requirements and will summarize the data validation efforts and provide an evaluation of the data
qualify.
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.
16.0 REFERENCES
American Public HeaUh Association. 1998. Standard Methods for the Examination of Water and
Wastewater.
23
Quality Assurance Plan
Nitrate Investigation Phase 2
Denison Mines (USA) Corp. 2010. White Mesa Uranium Mill Groundwater Monitoring Qualify
Assurance Plan, Revision 6.
State of Utah, Division of Water Qualify, Department of Environmental Qualify, Utah Water Qualify
Board. 2011. Groundwater Discharge Permit Number UGW370004. Febmary 15.
. 1999. State of Utah Notice of Violation and Corrective Action Order, UDEQ Docket No. UGO-
20-01.
U.S. Environmental Protection Agency (EPA). 1986. "RCRA Ground-Water Monitoring Technical
Enforcement Guidance Document." Office of Waste Programs Enforcement, Office of Solid
Waste and Emergency Response, U.S. Environmental Protection Agency. Washington, DC,
EPA/530/SW-86/055. September.
. 1992. "RCRA Ground-Water Monitoring: Draft Technical Guidance." Office of Solid Waste, U.S.
Environmental Protection Agency. Washington, DC. November.
. 1994a. "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods." U.S.
Environmental Protection Agency Publication SW-846, Third Ed., Chapter 1, Section 5.
, 1994b, "USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data
Review, 9240.1-05-01." Office of Emergency and Remedial Response, U.S. Environmental
Protection Agency. Washington, DC, EPA 540/R-94/013. Febmary. P. 25,
. 2007. "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods." U.S.
Environmental Protection Agency Publication SW-846, Fourth Ed.
. 2005. "Method 1623: Cryptosporidium and Giardia in Water by Filtration/IMS/FA." Office of
Water (4607), U.S. Environmental Protection Agency. Washington, DC, EPA 815-R-05-002.
December.
. 2010. "Laboratories Approved for the Analysis of Cryptosporidium Under the Safe Drinking
Water Act." July 16,
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Quality Assurance Plan
Nitrate Investigation Phase 2
Revised Table 1
Analytical Methods, Reporting Limits Holding Times, Preservation, Temperature and
Volume Requirements for Phase 2 of the Nitrate Investigation
Contaminant Analytical
Methods
to be
Used
Reporting
Limit'
Maximum
Holding
Times
Chemical
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Minimum
Volume/Sample
Container*
Explosives (RDX
and HMX)
EPA
8330'
0.1 ug/L 7 days to
extraction/40
days for
extract
None <6X 3 - 1 liter amber
glass bottles
Perchlorate EPA
6850'
0.5 ug/L 28 days None <10°C 1 -250 ml.
polyethylene
Cryptosporidium^ 1623' NA 96 hours
until
filtration
None <20°C I-10 liter
cubitainer
*Sample containers will be provided by the Analytical Laboratory. Volume requirements listed above are the
minimum volumes. The laboratory may request additional volume or containers.
' The Analytical Laboratory will be required to meet the reporting limits ("RLs") in the foregoing Table, unless the
RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the increased RL
will be used.
^ Method 8330 and 6850 are from EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods.
^Cryptosporidium analyses will be completed by Energy Laboratories in Casper Wyoming..
Method 1623: Cryptosporidium and Giardia in Water by Filtration/IMS/FA, EPA Office of Water (4607), EPA
815-R-05-002, December 2005.
25
Quality Assurance Plan
Nitrate Investigation Phase 2
Table 2 Groundwater Sample Locations
Well ID Sample ID Duplicate/MS/MSDLocation
ID
Analytes'
Campaign 1
TWN-2 TWN-2 X
Cryptosporidium
Perchlorate
Explosives (RDX and HMX)
TW4-22 TW4-22
Cryptosporidium
Perchlorate
Explosives (RDX and HMX)
MW-19 MW-19 Perchlorate
MW-20 MW-20 Perchlorate
MW-27 MW-27 Perchlorate
MW-30 MW-30 Perchlorate
MW-31 MW-31 Perchlorate
TWN-9 TWN-9 Perchlorate
TWN-17 TWN-17 Perchlorate
TWN-19 TWN-19 Perchlorate
TW4-1 TW4-1 Perchlorate
TW4-24 TW4-24 Perchlorate
DIFB DIFB Perchlorate
Campaign 2 (if needed)
MW-19 MW-19 Cryptosporidium
Explosives (RDX and HMX)
MW-20 MW-20 Cryptosporidium
Explosives (RDX and HMX)
MW-27 MW-27 Cryptosporidium
Explosives (RDX and HMX)
MW-30 MW-30 Cryptosporidium
Explosives (RDX and HMX)
MW-31 MW-31 Cryptosporidium
Explosives (RDX and HMX)
TWN-2 TWN-2 Cryptosporidium
Explosives (RDX and HMX)
TWN-9 TWN-9 Cryptosporidium
Explosives (RDX and HMX)
TWN-17 TWN-17 Cryptosporidium
Explosives (RDX and HMX)
TWN-19 TWN-19 Cryptosporidium
Explosives (RDX and HMX)
TW4-1 TW4-1 Cryptosporidium
Explosives (RDX and HMX)
TW4-24 TW4-24 X Cryptosporidium
Explosives (RDX and HMX)
DIFB MW-60 Cryptosporidium
Explosives (RDX and HMX)
Background Wells - Campaign 2
TWN-8 TWN-8 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
26
Quality Assurance Plan
Nitrate Investigation Phase 2
Well ID Sample ID Duplicate/MS/MSDLocation
ID
Analytes'
TWN-11 TWN-11 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-13 TWN-13 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-15 TWN-15 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-16 TWN-16 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-1 MW-1 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-2 MW-2 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-3 MW-3 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-12 MW-12 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-18 MW-18 X Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
Duplicate samples will be labeled as MW-65 or MW-70.
Duplicate samples and extra volume for MS/MSD analyses may be collected from alternate wells if insufficient
volume is unavailable after purging. The decision to move a duplicate sample/extra volume for MS/MSD will be
made in the field based on field conditions and will be documented in the field notes. Cryptosporidium samples are
not analyzed for MS/MSD and as such this does not apply to the Cryptosporidium samples.
27
Appendix 1
Field Data Work Sheet
Mifl - Groundwater Discharge Permit
Groundwater Monitonng Quality Assurance Plan (QAP)
OENISO
MINfS
ATTACHMENT 1
WHITE MESA LTIANIUM MILL
FIELD DATA WORKSHEET FOR GROUND WATER
Date: 03/22/2010 Rev 6
Attachment 1
See instruction
Description of Sampling Event.
Location (well name):
Sampler Name
and initials:
Date and Time for Purging and Sampling (if different)
Weil Piu-ging Equip Used- • pump or • bailer Well Pump (if other than Bennet)
Sampling Event
pH Buffer 7.0
Prev. Well Sampled in Sampling Event
pH Buffer 4.0
Specific Conductance juMHOS/ cm
Depth lo Water Before Purging
Conductance (avgj
Well Water Temp, (avg)
Weather Cond.
Tune
Conductance
Temp. °C
Gal. Purged
pH
Redox Potential Eh (mV)
Turbidity (NTU)
Time
Conductance
Temp. X
Gal. Purged
pH[
RedoK Potential Eh (mV)
Turbidit>^ (NTU)
WeU Depth(O.Olft):
Casing Volume (V) 4" Well
3" Well
(.653h)
(.367h)
pH of Water (avg)
Redox Potential (Eh) Turbidity
Ext'l Amb, Temp. °C (prior sampling event)
Time
Conductance
Temp. X
Gal. Purged
pH
Redox Potential Eh (mV)
Turbidify (NTU)
Time
Conductance
Temp, T
Gal. Purged
pH
Redox Potential Eh (mV)
Turbidity (NTU)
White Mesa Milt
Field Data Worksheet for Groundwater roMPATinrr WITH
1 of 2
' FtJUmnM Al ITV
Mill - Groundwater Discharge Permit
Groundwater Monftonng Quality Assurance Plan (QAP)
Date 03/22/2010 Rev. 6
Volume of W^ater Purged
Pumping Rate Calculation
Flow Rate (Q), in gpm,
S/60 =
gallon(s)
Time to evacuate two casing volumes (2V)
T = 2V/0 =
Number of casing volumes evacuated (if other than tw^o)
If well evacuated to dryness, number of gallons ev acuated
Name of Certified Analytical Laboratory if Other Than Energy Lab
T>pc of Sample Sample Taken Sample Vol 1 indicate
if other than as
specified belo\\ >
Filiered Prescrv ativc
Type
Present ati\e
Added T>pc of Sample
Y N
Sample Vol 1 indicate
if other than as
specified belo\\ > Y N
Prescrv ativc
Type Y
\'OCs • • 3x40 ml • • HCL • •
Nutrients • • 100 ml • • H2S04 • •
Hca\y Metals • • 250 ml • • HN03 • •
All Other Non Radiologics • • 250 mJ • • No Preserv • •
Gross Alpha • • 1,000 ml • • HN03 • •
Other (spccilX )
• • Sample \olume • • • •
If prcservatne is used, specify
Type and C^antitv of
Pre:5er\-ati\ e
^Comment
See instmction
Do not touch this cell (SheetName)
White Mesa Milt
Field Data Worksheet for Groundwater CaptUrX COMCATIBLE WITHy^^ft
2 of 2 FUNCTIOMALIT
Figure
TWN-15
03
TWN-11
TWN-12
0
CORAL CANYON
TWN-19
TWN-16
0
TWN-17
MW-24
MW-02|
MW-23
MVt-27i
fiWMfe) TWN
MW-^28
Ce 7 No. 2
MW-30
^ TW4-19 TW4-5
TW4-24 TW4-20' TW4-9
MW-26 TW4-10
I* : TVV4-.
TW4-16 TW4-11 TW4-13
TW4-2 >
TW4-7
TW4-14
TWN-13
ENTRANCE.SPRING-
WHITE MESA URANIUM MILL
PHASE 2 NITRATE INVESTIGATION
DETAILED WORK PLAN AND SCHEDULE
July 12, 2011
Revision 01
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
I N:\Nitrate Investigation and ClR\PhaGe 2 to 5 Plan Revised'JPh 2 GW Investigation PlanVPhase 2 QAPVPhoflo 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 INVESTIGATION 3
3.1 Project Purpose 3
3.2 Project Scope 4
4.0 SITE DESCRIPTION 6
5.0 PROJECT OBJECTIVES 6
6.0 PHASE 2 SCHEDULE 6
7.0 REFERENCES 6
JJ)^INJRODUCriON
AO_DQCyMENT ORGANIZATI^^^^
^•^0 PUiy^OSE AND SCOPE OF Tm iNVESTIGA™
^. 1 Project Purpose .^^._....^..^.„._.„.„.....„...^..^..^.„.„„.„.^..^.„...^..^.„.^^...„.^^3
^.2 Project Scope..„„.„.„„.„.„„.„.„„^
JJl^SITEDESCRTOON
^X]LPRCyECTOE(JECTI\^^.„
^6.^0 PHASE 2 SCHEDULE .^....^..^^.^.^
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Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
1.0 INTRODLCTION
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 Agreemenf)
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-
^Formatted: Space After: 0 pt
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 Plan(s) 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 muhi-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 of the 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 I Work Plan,
White Mesa Mill Site, dated May 13, 2011. A Phase 2 through 5 Work Plan, describing the remaining
phases ofthe 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
ofthe 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 investigafion 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
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 ofthe 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 nhrate
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 nhrate and
chloride mass observed in groundwater was caused by ehher military and/or agricultural uses ofthe 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 mifitary 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 common in 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 ehher of
these analytes would be indicative of mifitary 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 muhiple military
applications, particularly as an oxidant in solid rocket fuels and incendiary and chemical munitions.
Based on the historic mifitary 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 whh ponds or
pond-like features, whose presence is necessary to generate the hydraulic head needed to carry
consthuents 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 inhial screening in a limited number of wells for Cryptosporidium, RDX
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 activifies. Positive detections of crvptosporidium and/or
HMX and RDX may also be followed with repeat sampling.
Perchlorate was more frequently used in mifitary applications, is relatively mobile, and as such the inifial
sampling and screening will include more existing wells. As whh Cryptosporidium, RDX and HMX, if
any positive detections are reported, then_-a more comprehensive sampling program and background
determination (Cryptosporidium only) will be completed. Posifive detections of perchlorate mav also be
followed with repeat sampling.
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 nhrate/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 locafion 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
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
• TWN-17
• TW4-22
• MW-19
• MW-27
• MW-30
• TW4-24
• TW4-1
These wells were chosen for perchlorate screening due to their locations wrthm the nitrate plume, their
locations near histonc military activities, or their locations near histonc ponds or pond-like features
As previously stated, if positive dotcotions aro reported in tho initial gorconmg, a baokground
determination for perehlorate would bo oompletod—Tho baokground study would be completed as
dosoribed below ITie text below describes how DUSA would determine whether a site-specific
background study would be required, and how the background would be developed
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-11
TWN-13
TWN-15
TWN-16
MW-1
MW-2
MW-3
MW-12
MW-18
The basis for the site-specific -perchlorate background determination is as follows
Fram and Bellitz (2011) state "The data and model results indicate low concentrations (0 1-0 5
fxg/L) ofperchlorate occur under natural conditions in groundwater across a wide range of climates,
beyond the and to semiarid climates in which they mostly have been previously reported The
probability of detecting perchlorate at concentrations greater than 0 I ug/L under natural conditions
ranges from 50- 70% in semiarid to and 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 I /ug/L under natural conditions is low (generally <3%) " Therefore, if
perchlorate is detected at concentrations above 1 jig/L a background will be determined
Perchlorate and cryptospondium results will be tabulated and background will be determined by the 95%
upper confidence level on the mean (95% UCL)
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
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
4 0 SITE DESCRIPTION
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,
2011
5 0 PROJECT OBJECTIVES
The objectives of this phase of the nitrate investigation is to
1 Establish background for companson 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 m the constituents of concem, and
4 Provide data for incorporation in the Conceptual Site Model and decision process regarding
nitrate sources
6 0 PHASE 2 SCHEDULE
Attachment I 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 descnbed 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
7 0 REFERENCES
Denison Mines (USA) Corp and Utah Water Quality Board (Co-Executive Secretary^ 2011 Tolling
Agreement
2009 Stipulated Consent Agreement. Docket No UGW09-03
Fram. M S . and Belitz. Kenneth 2011 "Probability of Detecting Perchlorate under Natural Conditions in
Deep Groundwater in California and the Southwestem United States " Environ Set Technol.
2011.45 (4).pp 1271-1277
INTERA Inc 2009 Nitrate Contamination Investigation Report White Mesa Uranium Mill Site.
Blanding Utah
201 la. Nitrate Investigation Revised Phase 1 Work Plan. White Mesa Mill Site. Blanding Utah
Mav 13
201 lb Nitrate Investigation Revised Phases 2 through 5 Work Plan. Rev 1 0. White Mesa Mill
Site. Blandmg Utah (Draft)
Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule
U S Environmental Protection Agency (EPA) 2002 "Guidance for Comparing Background and
Chemical Concentrations in Soil for CERCLA Sites " Office of Emergency and Remedial
Response. U S Environmental Protection Agency Washington. DC. EPA 540-R-01-003
September
[ Formatted Heading 1, Left
ATTACHMENT 1
Phase 2 Schedule
Activity Date(s)
DUSA submits Phase 2 Nitrate Investigation Detailed Work Plan
and Schedule and QAP to UDEQ
FndayJuly 1,2011
UDEQ provides comments on Phase 2 Nitrate Investigation
Detailed Work Plan and Schedule and QAP
Monday July 11,2011
DUSA responds to comments and submits revised Phase 2 Nitrate
Investigation Detailed Work Plan and Schedule and QAP
Wednesday July 13,2011
Field Work - Campaign 1 Monday July 18,2011 -
FndayJuly 22, 2011
Cryptosporidium and explosives shipped to analytical laboratones MondavJulv 18.2011 -
either the same day as collection or the day following collection Thursday July 21. 2011
(cryptospondium and explosives samples will not be collected on
Fndav July 22. 2011 due to holding time limitations)
Samples (except Cryptosporidium and explosives) shipped to
analytical laboratones
Monday July 25, 2011
Samples (except Cryptosporidium) arrive at analytical laboratories Tuesday July 26, 2011
Analytical data received from analytical laboratones Tuesday August 16,2011
DUSA completes QA/QC review of data and completes
determination of necessity of campaign 2/background sampling
Fnday September 16, 2011
DUSA transmits analytical data packages, EDDs, and QA/QC
review resuhs to UDEQ
Friday September 16, 2011
Field Work - Campaign 2 (if required) Monday October 3 September
19, 2011-Friday©etebef
44Seotember 30. 2011
Cryptospondium and explosives shipped to analytical laboratones Monday September 19. 2011 -
either the same day as collection or the day following collection Thursday September 29. 2011
(cryptospondium and explosives samples will not be collected on
Fridays due to holding time limitations)
Samples (except Cryptosporidium and explosives) shipped to
analytical laboratories
Monday September 26, 2011
and Monday October 4^3,
2011
Samples (except Cryptosporidium) arrive at analytical laboratories Tuesday September 27. 2011
and Tuesday October 4*4,
2011
Analytical data received from analytical laboratories Tuesday Fnday November 84,
2400011
DUSA transmits analytical data packages, EDDs, and QA/QC
review results to UDEQ
Thursday December 8, 2011
Final Nitrate Investigation Report As noted m Phases 2 through 5
Work Plan schedule
WHITE MESA URANIUM MILL
GROUNDWATER MONTFORING
QUALITY ASSURANCE PLAN
FOR PHASE 2 NITRATE INVESTIGATION
July 12,2011
Revision 01
Denison Mines (USA) Corp
PO Box 809
Blanding, UT 84511
Quality Assurance Plan
Nitrate Investigation Phase 2
10 INTRODUCTION I
1 2 Scope ofthe OAP 1
1 3 Project Measurements 1
1 S Sampling Design 2
2 0 ORGANIZATION AND RESPONSIBILITIES 2
2 I Functional Groups 2
2 2 Overall Responsibility For the OA/OC Program 2
2 3 Data Requestors/Users 2
2 4 Data Generators 2
2 4 1 Sampling and OC 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 OUALITY ASSURANCE OBJECTIVES 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 OUALITY ASSURANCE METHODOLOGY 6
4 1 Controlling Well Contamination 6
4 2 Controlling Depth to Groundwater Measurements 6
4 3 Water Oualitv Control Samples 6
4 3 1 VOC Tnp Blanks 7
4 3 2 Equipment Rinsate Samples 7
4 3 3 Field Duplicates 7
4 3 4 Defmition 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 Momtonng 8
6 11 Location and Frequency of Groimdwater Head Monitonng 8
Quality Assurance Plan
Nitrate Investigation Phase 2
6 1 2 Equipment Used for Groundwater Head Monitonng 9
613 Field Sampling Procedures for Groundwater Head Monitoring 9
6 2 Groundwater Compliance Momtonng 9
6 2 1 Location and Frequencv of Groundwater Compliance Monitoring 9
6 2 2 Quarterly and Semi-Annual Sampling Required Under Paragraphs IE 1 a) or IE 1 b) of the
GWDP 10
6 2 3 Quarterly or Monthly Samoling Required Under Paragraphs IG 1 or IG 2 of the GWDP 10
6 2 4 Sampling Equipment for Groundwater Compliance Monitonng 10
6 2 5 Decontamination Procedures 11
6 2 6 Pre-Purging/ Sampling Activities 12
6 2 7 Well Purging/Measurement of Field Parameters 12
6 2 8 Samples to be Taken and Order of Takmg Samples 14
6 2 9 Field Duplicate Samples 14
6 2 10 VOCs and Nutrient Samoling/Perchlorate Cryptospondium, 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 Cham-of-Custody and Analytical Request Record 17
7 3 Record Keeping 18
8 0 ANALYTICAL PROCEDURES AND QA/QC 18
8 1 Analytical Quality Control 18
8 12 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
911 Review of Compliance With the Procedures Contained in this Plan 19
912 Analyte Completeness Review 20
913 Blank Comparisons 20
9 14 Duplicate Sample Comparisons 20
9 2 Analytical Laboratory QA Reviews 20
9 3 QA Manager Review of Analytical Laboratory Resuhs and Procedures 21
9 4 Analytical Data 21
10 0 CORRECTIVE ACTION 21
10 1 When Corrective Action is Required 21
110 REPORTING 21
Quality Assurance Plan
Nitrate Investigation Phase 2
12 0 SYSTEM AND PERFORMANCE AUDITS
12 1 OA Manager to Perform System Audits and Performance Audits
12 2 Systems Audits
12 3 Performance Audits
12 4 Follow-Up Actions
12 5 Audit Records
13 0 PREVENTIVE MAINTENANCE
14 0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14 1 Ongomg QA/QC Reporting
14 2 Periodic Reporting to Management
15 0 AMENDMENT
16 0 REFERENCES
- JNTRODUCTTON
J_2SoopgofdioQAP
A1 ProjojitMgiuiuremonts
^ 5 Sampling Design
- JORGA^nZATION i\ND RESPONSffilLITIES
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2,3 Data Regiystore/Usora _ — ^ 2
^ A Data Generators — —^7-^7-:^ 2———-— 2 ' /' ~ 111 I 41 Sampling^and QC Monitors —— —^-^— —— z~k ' • 11
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ilO FIELD SMlPLINGpU^^ ASSURiWCE METHODOLOGY
A1 Co^l^Iojll°jjy?.lL^Qnhuiuntrtion , - -
A 2 Controjlmg jjepfli jq Groundwater Meimria^^ 6
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Quality Assurance Plan
Nitrate Investigation Phase 2
A j y^S^i^I j^glIty Control Sqmijjep — 6
/Ij-IYQC Jnp Bltmk3_ 7.
^ 3_3_Field Duplioatos
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^ 1 Pggtf? to QroundjvytorMoosuro 8_
^ 2 Water Quality 8_^
6 0 GROUNDWATER SAMPLING A>JD MEASUREMENT OF FIELD PARAMETERS -8
1 9?QPP4^'^P^'Jiogd Mpnitqrmg — 8_ \ \^
^ l l Lqoatpnjmd Froguonoy o/Gr^ Momtormg -\ '
^_l_2_Equipmcnt Used for GroundwaterHoad Momtormg ——— — _9 \\ \
^_1_3 Field Sampling Proogdures fqr Groimdwa^ Monitoring 9 \ \\
^ 2 Groundwater Comjhanco Monitoring 9 \ \ \
^6_2_l_Lqcation_and Fregueno)'_o_f GrqimdwaterCoiiyh Ntop^yfflB P
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^AI-SMnjplmg^Eqmpmont for 10
^_2_5_Deoontamination_Prqoedure3 ^^-^ 11
^JAyj^ PfflJlPg^ Sampling Aotiyities 4k
^A7.WgU PygUig^eastjremont ofField Pqnunoters ^12^^^^'
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^_2_12_Prqoodigqs to Fqlfow After Sam^plmg
44
^_2_l_3_Samplo_Shipmcnt_
J O SAMPLE PpCy\ffiNTATjON TRA^^^^ j^CORD KEEPING
2_ i Fipld Data Worksheets —
2_ 2 Chmn of Ciyrtqdy cmd Anajytiogl Regues
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^ 1 ApalytiocJ Qualit)'_ConU'gl_ 48
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48
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Quality Assurance Plan
Nitrate Investigation Phase 2
j?0_INJEgJ>fAL QUALITY O^^ CHECKS JO.
2.1 FlolAQC Cho_ok Proooduros ^19.
j> 11 Rqvpwqf Comphffloc Wjth t^^ l"_thig Plan 19
J A^^^g. QOi^R^gteness Review ^19
^ISBlonkCqmpansons 20
^ l_4JDiyjioatc SampjqCqmporisoM ,20.
^ 2 Analytical Laboratory QA Reviews
^ 3 QA Manager Review of Analytical Laboratory Results and Prooodures
20
20
^ 1 Analytical Data U
JO 0 CORRECITVE ACTION U
JO 1 When Corrootivc Action is Roguired 24-
JI OREPORTDJG 34-
J2 0 SYSTEM AND PERFORMANCE AUDITS 32
J2 1 QA Manager to Perform System Audits and Porformonoo Audits 22
J2 2 Systems Audits 22
J2 3 Performance Audits 22
J2 4 Follow Up Achons 22
J2 5 Audit Records 22
11 (\ TiTin\rc-KfTT\rc ATXTTTJ-NT AXTr"!?
JI 0 QUALITY ASSURANCE REPORTS TO Mi\NAGEMENT 2^
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J4 2 Penodio Reportmg to Man^cment 2*
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List of Tables
Analytical Methods, Reporting Limits Holding Times, Preservation, Temperature
and Volume Requirements for Phase 2 of the Nitrate Investigation
\ * \ ^
Table 1
Table 2
Figure 1
Groundwater Sample Locations
List of Figures
Phase 2 Groundwater Sampling Locations
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List of Appendices
Attachment 1 Field Data Worksheets
Quality Assurance Plan
Nitrate Investigation Phase 2
Quality Assurance Plan
Nitrate Investigation Phase 2
1 0 IlVTRODl/CTION
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 descnbed 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 Monitonng Program, or the
Chloroform and Nitrate monitonng 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
Monitonng Quality Assurance Plan ("UDEQ-approved GW QAP") submitted by Denison Mines (USA)
Corp (' DUSA") for groundwater monitonng 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 cunent nitrate investigation requirements
differ from the UDEQ-approved QAP, the investigation-specific details are provided herein If the
requirements or procedures descnbed 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 histonc data collected during routine groundwater monitonng 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 of field 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 pnmary
document and descnbes, either directly or through reference, the purpose of this phase of the
investigation, the site descnption 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 dunng this nitrate
investigation Samples will be analyzed for perchlorate, RDX, HMX and Cryptosporidium Analytical
methods are specified in Revised Table I
Quality Assurance Plan
Nitrate Investigation Phase 2
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 RESPONSIBILITIES
2 1 Functional Groups
This Plan specifies roles for a QA Manager as well as representatives of three different flmcttonal groups
the data users, the data generators, and the data reviewers/approvers The roles and responsibilihes of
these representatives are descnbed below
2 2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the Quality Assurance/Quality Control ("QA/QC") 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 relatmg to the operation of the Mill facility, and to be consistent, as far as practicable,
with the reporttng requirements set out m the GWDP Accordingly, the data requesters/users (the "Data
Users") are therefore DUSA's corporate management and regulatory authonties through the
implementation of such permits and regulations The data quality objectives ("DQOs") requu^d for any
groundwater sampling event, such as acceptable minimum detection limits, are specified m 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 activihes, this involves sample collection, record keeping and QA/QC acttvities
conducted by one or more samplmg and quality control/data monitors (each a "Sampling and QC
Momtor") The Samplmg and QC Monitors are radiahon and environmental technicians or other
qualified Mill personnel as designated by the QA Manager The Samplmg and QC Momtors perform all
field sampling activities, collect all field QC samples and perform all data recording and cham of custody
achvities 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, m accordance with
specific requirements of the Analytical Laboratory's own QA/QC program
Quality Assurance Plan
Nitrate Investigation Phase 2
2 4 1 Sampling and QC Monitors
The Samplmg and QC Monitors are responsible for field activtties These mclude
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 mformation, along with the samples, to the
Analytical Laboratory m accordance with this Plan,
c) Maintammg records of all samples, trackmg those samples through subsequent processing and
analysis, and, ultimately, where applicable, appropnately disposing of those samples at the
conclusion of the program,
d) Prepanng quality control samples for field sample collection during the sampling event,
e) Prepanng QC and sample data for review by the QA Manager, and
0 Preparing QC and sample data for reporting and entry into a computer data base, where
appropnate
Ryan Palmer will serve as the Sampling and QC Monitor for Phase 2 of the nitrate investigation
2 4 2 Analvsis Monitor
The Analysis Monitor is responsible for QA/QC acttvities at the Analytical Laboratory These include
a) Trainmg and qualifymg personnel m specified Analytical Laboratory QC and analytical
procedures, prior to receivmg samples,
b) Receivmg samples from the field and verifymg that incoming samples correspond to the packing
list or cham-of-custody sheet, and
Venfying that Analytical Laboratory QC and analytical procedures are being followed as specified in this
Plan, by the Analytical Laboratory's QA/QC program, and in accordance with the requirements for
maintaimng National Envu-onmental Laboratory Accreditation Program ("NELAP") and/or National
Voluntary Latxjratory Accreditation Program ("NAVLAP") certtficatton as applicable
The State of Utah does not currently have a certification process for Cryptosporidium analyses Every
effort will be made to use aAn EPA-Approved laboratory fi-om the December 17. 2010 revision of
"Laboratones Approved for the Analysis of Cryptospondium under the Safe Dnnking Water Act" will be
used for the analysis of Cryptosporidium Tho Deoombor 17, 2010 revision of "Laboratories Approved
for the Analysis of Cryptospondium under the Safe Dnnkmg Water Act" will bo used as the startmg pomt
for contracttng a cryptospondium laboratory If none of those laboratories will accept outside samples, or
ore willing or able to perform the analyses, an altemato laboratory may bo used NELAC and NAVLAP
certification are not available for microbiology laboratones 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
Quality Assurance Plan
Nitrate Investigation Phase 2
The QA Manager has broad authonty to approve or disapprove project plans, specific analyses and final
reports In general, the QA Manager is responsible for reviewing and advismg on all aspects of QA/QC,
includmg
a) Ensunng that the data produced by the data generators meet the specifications set out m this
Plan,
b) Makmg on-site evaluations and submitting audit samples to assist m reviewmg QA/QC
procedures,
c) Determming (with the Sampling and QC Monitor and Analysis Momtor) appropnate samplmg
equipment and sample containers, in accordance with this Plan, to mimmize contammation, and
d) Supervismg all QA/QC measures to assure proper adherence to this Plan and determining
corrective measures to be taken when deviations fi-om this Plan occur
The QA Manager may delegate certain of these responsibilities to one or more Samplmg and QC
Monitors or to other qualified Mill personnel
2 S Responsibilities of Analytical Laboratory
Unless otherwise specified by DUSA corporate management, all environmental analysis of groundwater
samples collected dunng 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 NAVLAP certification as applicable
The Analytical Laborator(ies) will be chosen by DUSA and must sattsfy the following cnteria (1)
experience in analyzing environmental samples with detail for precision and accuracy, (2) experience
with similar matnx analyses, (3) operation of a strmgent intemal quality assurance program meeting
NELAP and/or 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 persormel
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 m the Phases 2 to 5 Work Plan (the
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 cntena are satisfied) Data subject to QA/QC measures are deemed more reliable than data without
any QA/QC measures
3 1 Precision
Precision is defined as the measure of vanability that exists between mdividual sample measurements of
the same property under identical conditions Precision is measured through the analysis of samples
containmg identical concentrations of the parameters of concem For duplicate measurements, precision
is expressed as the relative percent difference ("RPD") of a data pau- and will be calculated by the
followmg equation
RPD = [(A-B)/{(A+B) /2}1 x 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate samples analyses
(or, m the case of analyses performed by the Analytical Laboratory, the percent recovenes for matnx
spike and matnx spike duplicate samples) (EPA SW-846, Chapter I, Section 5 0, page 28)
3 2 Accuracy
Accuracy is defined as a measure of bias m a system or as the degree of agreement between a measured
value and an accepted or tme value The accuracy of laboratory analyses is evaluated based on analyzmg
standards of known concentratton both before and dunng analysis Accuracy will be evaluated by the
followmg equation (EPA SW-846, Chapter 1, Sectton 5 0, page 24)
% Recovery = (| A-B | IC) 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 defined as the degree to which a set of data accurately represents the charactenstics
of a population, parameter, conditions at a samplmg pomt, or an environmental condition
Representativeness is controlled by performing all samplmg 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
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 samplmg conditions, collection techniques, measurement
procedures, methods, and reporttng units are consistent for all samples within a sample set
3 6 Detection/Reporting Limits
The method detection limit ("MDL") is the minimum concenttation 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 matnx 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 rn 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
quanttfication systems for reporting limit determinations and quantitative methodologies
4 0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4 1 Controlling Well Contamination
Well contammation from extemal surface factors, is controlled by mstallatton of a cap over the surface
casing and cementtng the surface section ofthe drill hole Wells have surface covers of nuld steel with a
lockable cap cover Radiahon 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 wells, to the extent practicable This ensures, to the extent practtcable, that the aquifer zone
water is bemg drawn into the well and is a representative sample
4 2 Controlling Depth to Groundwater Measurements
Momtonng of depth to groundwater is controlled by companng histoncal field log data to actual
measurement depth This serves as a check of the field measurements
4 3 Water Quality Control Samples
Quality control samples collected durmg the nitrate investigation are as follows
Quality Assurance Plan
Nitrate Investigation Phase 2
4 3 1 VOC Tnp Blanks
Volatile organic compound ("VOC") tnp blanks will not be collected durmg the nitrate investigation
because the nitrate investigation samples will not be analyzed for VOCs and as such tnp 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 nnsate samples will not be collected when the dedicated pumps are used for
sampling
When the portable pump is used for sampling, equipment nnsate 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 (eg 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 Contt-ol, 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 (EPA SW-846, Chapter
1, Section 5 0, page 23)
4 3 5 Deionized Field Blanks
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 nnsate processes from the deionized water used for
decontamination and equipment rinsate collection
The DIFB wall be labeled with a "false" well number such as MW-60
5 0 CALIBRATION
A fundamental requirement for coUectton of valid data is the proper calibration of all sample collection
and analytical mstmments Samplmg equipment shall be calibrated in accordance with manufacturers'
recommendattons, and Analytical Laboratory equipment shall be calibrated m accordance with Analytical
Laboratory procedures
5 1 Depth to Groundwater Measurements
Equipment used m depth to groundwater measurements will be checked pnor to each use to ensure that
the Water Soundmg Device is functional
5 2 Water Quality
The Field Parameter Meter will be calibrated pnor to each sampling event and at the beginning of each
day ofthe samplmg event according to manufacmrer's specifications (for example, by using two known
pH solutions and one specific conductance standard) Temperature will be checked comparatively by
usmg a thermometer Calibratton results will be recorded on the Field Data Worksheet
6 0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS
6 1 Groundwater Head Monitonng
6 1 1 Location and Frequencv 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. Corrective 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 descnptions and requirements of those
procedures are not required for the nittate investigation The quarterly depth to groundwater
measurements will be collected followmg 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 pnor to samplmg 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 descnbed in Section 6 1 3 of
die UDEQ-approved QAP
Quality Assurance Plan
Nitrate Investigation Phase 2
6 1 2 Equipment Used for Groundwater Head Monitonng
Measurement of depth to groundwater is accomplished by using a Solimst - IT 300 or equivalent device
(the "Water Soundmg Device")
6 1 3 Field Sampling Procedures for Groundwater Head Monitoring
In the case of any well that is bemg sampled for groundwater quality, depth to groundwater is measured
prior to samplmg
Depth to groundwater is measured from the top of the inner well casmg or, for the piezometers, from the
top of the casing, and is recorded on the Field Data Worksheet for Groundwater descnbed in Section 7 I
(the "Field Data Worksheef) Readings are taken by lowermg the Water Soundmg Device into the
casing until the Device alarms, mdicatmg that the water surface has been reached The depth to
groundwater is then determined by reference to the distance markings on the lme 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 Frequencv of Groundwater Compliance Momtormg
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 cryptospondium, RDX
and HMX during the Phase 2 nitrate investigation, campaign 1 are as follows
• TWN-2
• TW4-22
The followmg 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
Quality Assurance Plan
Nitrate Investigation Phase 2
UDEQ proposed that TW4-4 be sampled dunng 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-20-01 Because TW4-4 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 cryptospondium and perchlorate will be determined by a one-time
sampling of groundwater in the following monitor wells (see Figure 1)
TWN-8
TWN-11
TWN-13
TWN-15
TWN-16
MW-1
MW-2
MW-3
MW-12
MW-18
6 2 2 Quarterly and Semi-Annual Sampling Required Under Paragraphs I E 1 a) or I E 1 b) ofthe 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
1 E 1 a) or I E 1 b) of the GWDP The nitrate investigation is being conducted to satisfy the objectives
specified m The Nitrate Investigation Phase 2 Detailed Work Plan and Schedule
The samples collected durmg the nittate investigation will be sampled for the following parameters
• Field parameters - depth to groundwater, pH, temperamre, specific conductance, redox potential
(Eh) and turbidity in the manner specified herein, and
• Analytical parameters - Cryptosporidium, perchlorate, HMX and RDX Analytical methods are
specified m the Revised Table 1 included with this QAP
6 2 3 Quarterly or Monthly Sampling Required Under Paragraphs I G 1 or IG 2 ofthe GWDP
This Section is not applicable to the nittate investigatton 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 samplmg 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 nnsate 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 casmg
• 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 matenals.
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,
(ill) Turbidity
(iv) Standard pH,
(v) Redox potential (Eh)
Sample containers and preservation chemicals (as provided by the Analytical Latxjratory), and
Five gallon bucket
6 2 5 Decontamination Procedures
If the portable (non-dedicated) pump is to be used for purging and sampling, pnor to each sampling event
and between each sampling location (well), decontaminate the portable (non-dedicated) samplmg pump
pnor 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 m 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 dmm 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 contammation unttl used for purging or sampling
All water produced during decontamination will be disposed of in Tailings Cell 1
6 2 6 Pre-Purging/ Sampling Activtties
• 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 m Section 6 2 5,
• If a portable (non-dedicated) pump is to be used, after completion of decontamination prepare one
equipment nnsate sample per day
6 2 7 Well Purging/Measurement of Field Parameters
a) Remove the well casmg cap and measure and record depth to groundwater by following the
procedures set out m paragraph 613 above,
b) Determine the casmg volume (V) m gallons, where h is column height of the water m the well
(calculated by subttacttng the depth to groundwater in the well from the total depth of the well),
V = 0 653*h, for a 4" casmg volume and V = 367*h for a 3" casmg volume Record the casmg
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, pnor to well purging,
d) Purgmg, Where Use of Pump is Effecttve (See paragraph 6 2 7 e)) below, where bailer is
required)
If a portable (non-dedicated) pump is used, ensure that it has been decontammated m accordance with
Section 6 2 5 since its last use m a different well, lower the pump mto the well, makmg sure to keep the
pump at least five feet from the bottom ofthe well Be sure never to drop the pump mto 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 mto the well, or if the well has
a dedicated pump, perform the followmg steps
(i) Commence pumpmg,
(u) Determine pump flow rate by using a stopwatch and a calibrated bucket by measunng the
number of seconds requu-ed to fill to the one-gallon mark Record this in the "pumpmg
rate" sectton of the Field Data Worksheet,
(ui) 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
m paragraph (in),
(v) Take measurements of field parameters (pH, specific conductance, temperature, redox
potential and turbidity) durmg well purging, using the Field Parameter Meter and
turbidity measunng mstrument These measurements will be recorded on the Field Data
Worksheet Purgmg 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 m the
water should be < 5 NTU pnor to sampling (DTG WeU Development 6 7, page 6-48)
unless the well is charactenzed 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 contamers (DTG, Well Purgmg, 7 2 4, page 7-9),
(VI) If the well yields two casing volumes, the individual performing the samphng should
unmediately 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 Pnor to sampling, measure and record depth to groundwater on the Field Data
Worksheet followmg the procedures set out m paragraph 6 I 3 above,
e) Purging, Where Use of Pump is Not Effective
For wells where a pump is not effecttve for purging and/or samplmg (wells with shallow water columns,
I e, where the water column is less than five feet above the bottom of the well casmg 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 followmg procedure will be followed
(i) Use the sound level mstrument to determine the water colunrn and figure the amount of
water that must be evacuated,
(ll) Attach a 3" disposable bailer to a rope and reel.
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Quality Assurance Plan
Nitrate Investigation Phase 2
(ill) Lower the bailer mto the well and listen for contact with the solution Once contact is
made, allow the bailer to gradually smk m the well, being careful not to allow the bailer
to come m contact with the bottom sediment,
(iv) After the bailer is fiill, rettieve the bailer and discharge the water from the bailer mto 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 casmg volumes have been collected
or until no more water can be rettieved When the process is finished for the well, the
bailer will be disposed of, and
(vi) Take field measurements referred to m paragraph 6 2 7(d)(v) above from the water m
the buckets
f) All water produced dunng well purging will be contamerized Contamenzed water will be
disposed of m either Tailings Cell
6 2 8 Samples to be Taken and Order of Taking Samples
For the nittate investigation, samples will be collected from each well in the following order
• Perchlorate
• Cryptosporidium
• RDX and HMX
Sample containers, chemical preservatives and filters 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 Nutnent Sampling/Perchlorate Cryptospondium. RDX. HMX Sampling
VOCs and nutnents will not be collected durmg the nittate 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 Nitroto/nitrite as N and ammonia vn\l bo ooUectod as descnbed below
Per the UDEQ-approved, routine groundwater samplmg 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 m Section 6 2 7 All dedicated pumps used for purging and
sampling are "low flow" pumps and therefore volatilization of constituents is not a concem
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Quality Assurance Plan
Nitrate Investiganon Phase 2
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 wnthin 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 samphng 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 filtenng,
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 die final
sample container (also provided by the laboratory) The filters, bulk sample containers and synnges 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 Heavy Metals, All Other Non-Radiologic and Gross Alpha Sampling
Heavy metals and gross alpha samples will not be collected dunng the nittate 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 10°C and less than or equal to 20°C respectively The
receipt temperature for RDX and HMX is 6°C
Samples not shipped on the same day as they are collected will be refrigerated on-site unttl shipment
6 2 13 Sample Shipment
The following procedures will be implemented when samples collected dunng 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 mside a plastic bag The bag will be sealed and taped to the inside
ofthe 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 tiiat the sample
contains any substance that would require Analytical Laboratory personnel to take safety
precautions
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Quality Assurance Plan
Nitrate Investigation Phase 2
The cooler will be closed and taped shut with packmg tape around both ends If the cooler has a
dram, it will be taped shut both inside and outside of the cooler
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
Mukiple 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
samplmg process and provide a permanent record for sampling acttvities All observations and field
samplmg data will be recorded m waterproof mk on the Field Data Worksheets, which will be maintained
on file at the Mill
The Field Data Worksheets will contam the foUov^ang mformation
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 bader)
previous well sampled durmg the sampling event
well depth
depth to groundwater before purging and sampling
results of in-field measurements (pH, specific conductance, water temperature)
redox potenttal (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, mcluding filtration and preservation
volume of water collected for analysis
types of sample contamers and preservatives
weather conditions and extemal au- temperature
name of certified Analyttcal Laboratory
The Field Data Worksheets will also contam detailed notes descnbmg any other significant factors dunng
the samplmg event, mcluding, as applicable condition of the well cap and lock, water appearance, color,
odor, clanty, presence of debns or solids, any variances from this Procedure, and any other relevant
16
Quality Assurance Plan
Nitrate Investigation Phase 2
feamre or conditton An example of a Field Data Worksheet that incorporates this informatton is
provided as Appendix I
7 2 Cham-of-Custody and Analytical Request Record
Standard sample custody procedures will be used to maintain and document sample mtegnty dunng
collection, ttansportation, storage, and analysis A sample will be considered to be in custody if one ofthe
following statements applies
• It IS in a person's physical possession or view
• It is in a secure area with restncted 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 ttaces 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 fransfer
• 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 ttansport the samples Signed air bills will serve as
evidence of custody transfer between field personnel and the couner, and between the courier and the
Analytical Laboratory Copies of the COC form and die 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
COC forms, and retain copies of the forms as permanent records The Analytical Laboratory sample
custodian will record all pertinent information conceming 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 ttansfer process is complete, the custodian is
responsible for maintaining intemal log books, ttacking reports, and other records necessary to maintain
custody throughout sample preparation and analysis
17
Quality Assurance Plan
Nitrate Investigation Phase 2
The Analytical Laboratory will provide a secure storage area for all samples Access to this area will be
restncted to authorized personnel The custodian will ensure that samples requiring special handlmg,
including samples that are heat- or light-sensitive, radioactive, or have other unusual physical
charactenstics, are properly stored and maintained pending analysis
7 3 Record Keeping
The onginal 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
The State of Utah does not currently have a certification process for cryptospondium analyses An EPA-
Approved laboratory from the December 17, 2010 revision of "Laboratones Approved for the Analysis
of Cryptospondium under the Safe Drinking Water Act" will be used for the analysis of Cryptosporidium
NELAC and NAVLAP certtficatton are not available for microbiology laboratones and as such does not
apply to the cryptospondium laboratory All other analyses will be performed by Utah-certified
laboratories DUSA will use State of Utah oortifiod laboratorios for nitrato/nitnto as N. ammonia as N,
chloride and perehlorate onalyses—As previously stated tho State of Utah does not currently have a
certification process for cryptospondium analyses—Every effort will bo made to use an EPA Approved
laboratory for the analysis of Cryptosporidium—The December 17, 2010 revision of "Laboratories
Approved for tho Analysis of Cryptosporidium under tho Safe Dnnking Water Acf' wall bo used as tho
startmg pomt for conttaotmg a cryptospondium laboratory—If none of thoso laboratories will accept
outside samples, or arc willmg or able to perform tho analyses, an alternate laboratory may be used
Once all the data for the nittate 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 QA/QC
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 intemal conttols
8 1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC 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 QA/QC 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
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Quality Assurance Plan
Nitrate Investigation Phase 2
analysis is a microbiological qualitative analysis and as such some of the QC samples discussed below
may not be applicable QC for cryptospondium will follow the EPA method
a Matnx Spike/Matnx Spike Duplicate
A spiked field sample analyzed m duplicate may be analyzed with every analytical batch
Analytes stipulated by the analytical method, by applicable regulattons, or by other specific
requirements may be spiked into the samples Selection of the sample to be spiked depends on the
information required and die vanety of conditions within a typical mattix The matnx spike
sample serves as a check evaluattng the effect of the sample matnx on the accuracy of analysis
The matrix spike duplicate serves as a check of the analytical precision Assessment ofthe matrix
spike/mattix 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 earned
through the entire analytical procedure Contammation detected m 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 mclude a laboratory control sample ("LCS"), calibration checks, laboratory
fortified blanks, or sample duplicates (Ilheck 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 nittate investigation are
specified in Revised Table I
9 0 INTERNAL QUALITY CONTROL CHECKS
Intemal quality conttol 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 additton, either the QA Manager or a Samplmg and QC Monitor will review
and validate the analyttcal data generated by the Analytical Laboratory to ensure that it meets the DQOs
established by this Plant Fmally, penodic system and performance audits will be performed, as detailed
in Section 12 below
9 1 Field QC Check Procedures
The QA Manager will jjerform the following QA/QC analysis of field procedures
9 1 1 Review of Compliance With the Procedures Contained in this Plan
19
Quality Assurance Plan
Nitrate Investigation Phase 2
Observation of technician performance is monitored by the QA Manager on a penodic basis to ensure
compliance with this Plan Assessment of techmcian performance may be conducted through on-site
observation or through review of field documentation
9 12 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%
9 1 3 Blank Comparisons
Equipment nnsate samples will be compared with ongmal sample results Non-conformance condittons
will exist when contammant levels m the blank(s)/samples(s) are withm an order of magnitude of the
ongmal sample result (TEGD, Field QA/QC Program, page 119)
9 1 4 Duplicate Sample Comparisons
a) Relative Percent Difference
RPDs will be calculated m compansons of duplicate and original field sample resuUs Non-
conformance will exist when the RPD >_20%, unless the measured acttvities are less than 5 times the
required detection hmit (Standard Methods, 1998) (EPA Contract Laboratory Program National
Functional Guidelines for Inorgamc Data Review, February 1994, 9240 1-05-01, p 25)
b) Radiologics Counting Error
Samples collected during the nittate investigation will not be analyzed for radiologic constituents and
therefore this section does not apply
c) Radiologics. Duplicate Samples
Samples collected during the nittate 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 holdmg times and QC samples Overall
data assessment will be a part of the 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) appropnate Analytical
Laboratory procedures are followed, (4) analytical results are correct and complete, (5) QC samples are
within established conttol 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 QA/QC 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
QA/QC analytical results
20
Quality Assurance Plan
Nitrate Investigation Phase 2
9 3 QA Manager Review of Analytical Laboratory Results and Procedures
a) Reporting Limit Compansons
The QA Manager shall confirm that all reportmg limits used by the Analytical Laboratory are m
conformance with the reporttng Imiits set out on Table 1 Non-conformance shall be defined as 1) a
reportmg lunit that violates these provisions, unless the reporting limit must be mcreased due to
sample matnx interference (i e, due to dilution gam),
b) Laboratory Methods Review
The QA Manager shall confirm that die analytical methods used by the Analytical Laboratory are
those specified in Table 1
c) Holding Time Exammation
The QA Manager will review the analytical reports to verify that the holdmg time for each
contammant was not exceeded Non-conformance shall be defined 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 m Table I
Non-conformance shall be defined when the sample temperamre is exceeded
9 4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory's QA/QC 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 anse will be brought to the
immediate attentton of the QA Manager Analytical Laboratory deviattons 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
wrthin 10 days of discovery and analyze again in compliance with all requirements ofthis Plan
U 0 REPORTING
21
Quality Assurance Plan
Nitrate Investigation Phase 2
Reporting of the nitrate investigation results will be completed as described in the schedule contained in
the Phase 2 Nittate Detailed Work Plan and Schedule
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 samplmg program The frequency and timing of system and performance
audits shall be as determined by DUSA
12 2 Systems Audits
System audits are qualitattve evaluations of all components of field and Analytical Laboratory QC
measurement systems They determine if the measurement systems are being used appropnately System
audits may review field and Analytical Laboratory operattons, including samplmg equipment, laboratory
equipment, sampling procedures, and equipment calibrattons, to evaluate the effechveness of the QA
program and to identtfy any weakness that may exist The audits may be earned out before all systems
are operational, dunng the program, or after the completton of the program Such audits typically involve
a companson of the activities requu-ed 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 activittes
12 3 Performance Audits
The performance audit is a quantitative evaluatton of the measurement systems of a program It requires
testmg the measurement systems with samples of known compositton or behavior to evaluate precision
and accuracy With respect to performance audits of the analytical process, either blmd performance
evaluatton samples will be submitted to the Analytical Laboratory for analysis, or the auditor will request
diat It provide results of the blind studies that the Analytical Laboratory must provide to its NELAP
and/or NAVLAP accreditatton agency on an annual basis The performance audit is earned 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 deviattons are found and
corrective actton 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 wdl be retained m Mill Centtal Files These records will contam
audit reports, written records of completion for corrective actions, and any other documents associated
with the audits supportmg audit findmgs or correcttve acttons
22
Quality Assurance Plan
Nitrate Investigation Phase 2
13 0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper mamtenance and care of field and laboratory instruments
Preventive maintenance helps ensure that momtormg data generated will be of sufficient quality to meet
QA objecttves Both field and laboratory mstmments have a set mamtenance schedule to ensure proper
functiomng of the mstmments
Field instruments will be mamtamed as per the manufacturer's specifications and established sampling
practice Field instruments wdl be checked and calibrated pnor to use, m accordance with Section 5
Battenes will be charged and checked daily when these mstmments are in use All equipment out of
service will be immediately replaced Field instmments will be protected from adverse weather
conditions dunng sampling activities Instmments will be stored properly at the end of each working day
Calibration and mamtenance problems encountered will be recorded m the Field Data Worksheets or
logbook
The Analytical Laboratory is responsible for the mamtenance and calibratton of its instruments m
accordance with Analytical Laboratory procedures and as requu-ed m order to maintain its NELAP and/or
NAVLAP certifications Preventive maintenance will be performed on a scheduled basis to mmimize
downtune and the potential intermptton of analytical work
14 0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14 1 Ongoing QA/QC Reporting
The following reporting acttvities shall be imdertaken on a regular basis
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding progress of the
applicable samplmg program The Sample and QC Monitors will also bnef the QA Manager on
any QA/QC issues associated with such samplmg activittes
b) The Analytical Laboratory shall maintain detaded procedures for laboratory record keeping Each
data set report submitted to the Mill's QA Manager or his staff will identtfy the analyttcal methods
performed and all QA/QC measures not within the established conttol lumts Any QA/QC
problems will be brought to the QA Manager's attentton as soon as possible, and
c) After samplmg has been completed and final analyses are completed and reviewed, a bnef data
evaluatton summary report wall 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 m accordance with NELAP and/or NAVLAP
requirements and will summarize the data validation efforts and provide an evaluation of the data
quality
14 2 Periodic Reporting to Management
Penodic reports to management as described in the UDEQ-approved QAP are not applicable to this
nittate investigation The nitrate investtgation descnbed 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 die Phase 2 Nittate
Detailed Work Plan and Schedule
15 0 AMENDMENT
23
Quality Assurance Plan
Nitrate Investigation Phase 2
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 descnbed so as to properly document and
describe the site conditions
16 0 REFERENCES
Amencan Public Health Associatton 1998 Standard Methods for the Examination of Water and
Wastewater
Denison Mines (USA) Corp 2010 White Mesa Uranium Mill Groundwater Monitonng Quality
Assurance Plan, Revision 6
State of Utah, Division of Water Quality., Department of Environmental Quality. Utah Water Quality
Board 2011 Groundwater Discharge Permit Number UGW370004 February 15
1999 State of Utah Notice of Violation and Corrective Action Order. UDEQ Docket No UGO-
20-01
US Environmental Protectton Agency (EPA) 1986 "RCRA Ground-Water Momtonng Technical
Enforcement Guidance Document" Office of Waste Programs Enforcement Office of Solid
Waste and Emergency Response. U S Environmental Protection Agency Washmgton, DC,
EPA/530/SW-86/055 September
1992 "RCRA Ground-Water Momtonng Draft Technical Guidance " Office of Solid Waste, U S
Environmental Protection Agency Washington. DC November
1994a "Test Methods for Evaluattng Solid Waste. Phvsical/Chemical Mediods "US
Environmental Protectton Agency Publication SW-846. Third Ed, Chapter 1. Section 5
— 1994b "USEPA Conttact Laboratory Program National Functional Guidelines for Inorganic Data
Review. 9240 1-05-01 " Office of Emergency and Remedial Response. U S Environmental
Protectton Agency Washington. DC, EPA 540/R-94/013 Febmarv P 25
2007 "Test Mediods for Evaluattng Solid Waste. Phvsical/Chemical Mediods "US
Environmental Protection Agency Publication SW-846. Fourth Ed
2005 "Metiiod 1623 Cryptospondium and Giardia m Water bv Fitotton/IMS/FA " Office of
Water (4607). U S Environmental Protection Agency Washington, DC. EPA 815-R-05-002
December
2010 "Laboratones Approved for the Analysis of Cryptospondium Under the Safe Drmking
Water Act "July 16
24
Quality Assurance Plan
Nitrate Investigation Phase 2
Revised Table 1
Analytical Methods, Reportmg Limits Holding Times, Preservation, Temperature and
Volume Requirements for Phase 2 of the Nitrate Investigation
Contaminant Analytical
Methods to
be Used
Reporting
Limit'
Maximum
Holding
Times
Chemical
Sample
Preservation
Requirements
Sample
Temperature
Requirements
Minimum
Volume/Sample
Container*
Explosives (RDX
and HMX)
EPA 8330^ 0 1 ug/L 44-7_days to
extraction/40
days for
exttact
None <6°C 3 - I liter amber
glass bottles
Perchlorate EPA 40 5 ug/L 28 days None <10°C 1 - 250 ml
3^'^6850^
40 5 ug/L 28 days
polyethylene Formatted No underline, Font color Black,
Cryptospondiun\^ 1623' NA 96 hours None <20°C 1-10 liter Not Superscnpt/ Subsaipt
until
filttation
cubitaine"r"" Formatted No underline. Font color Black,
Superscnpt
•Sample containers will be provided by the Analytical Laboratory Volume requirements listed above are the
minimum volumes The laboratory may request additional volume or containers
The Analytical Laboratory will be required to meet the reporting limits ("RLs") in the foregoing Table, unless the
RL must be increased due to sample matrix interference (i e , due to dilution gain), in which case the increased RL
will be used
^ Method 8330 and 6850 w-are from EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods
Method 331 0 Determination of Perchlorate in E)rinking Water by Liquid Chromatogmphy Elootrospray loniEation
Moss Spoottometry, EPA Toohnical Support Center, OfRoe of Ground Water and Dnnking Water, Cincinnati, No
815 R 05 007CrvptosDondium analyses will be completed bv Energy Laboratones m Casper Wyoming
* Method 1623 Cryptosporidium and Giardia in Water by Filtration/IMS/FA, EPA Office of Water (4607), EPA
815-R-05-002, December 2005
25
Quality Assurance Plan
Nitrate Investigation Phase 2
Table 2 Groundwater Sample Locations
Well ID Sample ID DuDhcate/MS/MSD
Location ID
Analytes'
Campaign 1
TWN-2 TWN-2 X
Cryptospondium
Perchlorate
Explosives (RDX and HMX)
TW4-22 TW4-22
Cryptosporidium
Perchlorate
Explosives (RDX and HMX)
MW-19 MW-19 Perchlorate
MW-20 MW-20 Perchlorate
MW-27 MW-27 Perchlorate
MW-30 MW-30 Perchlorate
MW-31 MW-31 Perchlorate
TWN 2 TWN2 Perchlorate
TWN-9 TWN-9 Perchlorate
TWN-17 TWN-17 Perchlorate
TWN-19 TWN-19 Perchlorate
TWN4-1 TWN4-1 Perchlorate
TWN4-24 TWN4-24 Perchlorate
DIFB DIFB Perchlorate
Campaign 2 (if needed)
MW-19 MW-19 Cryptosporidium
Explosives (RDX and HMX)
MW-20 MW-20 Cryptospondium
Explosives (RDX and HMX)
MW-27 MW-27 Cryptosporidium
Explosives (RDX and HMX)
MW-30 MW-30 Crvptosporidium
Explosives (RDX and HMX)
MW-31 MW-31 Cryptosporidium
Explosives (RDX and HMX)
TWN-2 TWN-2 Cryptosporidium
Explosives (RDX and HMX)
TWN-9 TWN-9 Cryptosporidium
Explosives (RDX and HMX)
TWN-17 TWN-17 Cryptosporidium
Explosives (RDX and HMX)
TWN-19 TWN-19 Cryptospondium
Explosives (RDX and HMX)
TWNTW4-1 TWNTW4-1 Cryptosporidium
Explosives (RDX and HMX)
TWNTW4-24 TWNTW4-24 X Cryptospondium
Explosives (RDX and HMX)
DIFB ©ffBMW-60 Cryptosporidium
Explosives (RDX and HMX)
Background Wells - Campaign 2
TWN-8 TWN-8 Cryptosporidium
Explosives (RDX and HMX)
26
Quality Assurance Plan
Nitrate Investigation Phase 2
Well ID Sample ID DuDhcate/MS/MSD
Location ID
Analytes'
Perchlorate
TWN-ll TWN-11 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-13 TWN-13 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-15 TWN-15 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
TWN-16 TWN-16 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-l MW-1 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-2 MW-2 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-3 MW-3 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-12 MW-12 Cryptosporidium
Explosives (RDX and HMX)
Perchlorate
MW-18 MW-18 X Cryptospondium
Explosives (RDX and HMX)
Perchlorate
Duplicate samples will be labeled as MW-65 or MW-70
Duplicate samples and extta volume for MS/MSD analyses samples mav be collected from alternate wells if
insufficient volume is unavailable after purging The decision to move a duplicate sample/extra volume for
MS/MSD will be made in the field based on field conditions and will be documented in the field notes
Cryptosporidium samples are not analyzed for MS/MSD and as such this does not apply to the cryptospondium
samples
27
Appendix I
Field Data Work Sheet
Figure
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