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HomeMy WebLinkAboutDRC-2012-001703 - 0901a068802f7a6aDRC-2012-001703 Denison Mines (USA) Corp 105017th Street, Suite 950 ^ _ - - _ _ - ^— _ ^ ^ Denver, CO 80265 DENISON^^^Ji MINES Tel 303 628-7798 Fax 303 389-4125 www denisonmines com July 30, 2012 VIA E-MAIL AND OVERNIGHT DELIVERY Mr Rusty Lundberg Executive Secretary Division of Radiation Control Utah Department of Environmental Quality 195 North 1950 West PO Box 144850 Salt Lake City, UT 84114-4820 Re Transmittal of Tailings Cell, Leak Detection System and Shmes Dram Sampling and Analysis Plan, Revision 2 1, Denison Mines (USA) Corp , White Mesa Uranium Mill, near Blanding, Utah, and response to DRC Request for Additional Information Dear Mr Lundberg Reference is made to the Division of Radiation Control ("DRC") letter and Request for Additional Information ("RFI") dated July 26, 2012, regarding the White Mesa Mill Tailings Cell, Leak Detection System and Shmes Dram Sampling and Analysis Plan ("the Plan") dated June 28, 2012 (Revision 2) This letter transmits Denison Mines (USA) Corp's ("Denison's") revisions to the Plan in response to the above referenced DRC letter For ease of review we have provided both redline and clean versions of the document The attached Plan Revision 2 1 has accepted all the redline changes proposed in Denison's June 28, 2012 submittal (Revision 2) as the base version in black type Changes resulting from the above- referenced DRC comment letter are provided in redlme/stnkeout format We have also provided, below, specific responses to each request in DRC's July 26, 2012 letter The sections and numbenng of the remainder of this letter follow the DRC July 26, 2012 letter Each DRC request is shown in italics, below, followed by Denison's response DRC Comment 1 It IS not necessary to purge the Cell 2 slimes dram system in order to have a representative wastewater sample, therefore, the last paragraph of Section 3 3 of the Plan should be modified to read (removed wording shown in strikethrough) Tho Coll 2 GlimoG dram will bo sampled such that roprosontativo fluids aro colloctod Accordingly, samploc will only be colloctod from this location whon tho pump has been operating m accordance with tho approved operating plan for a minimum of 48 hours prior to sampling m order to assure that tho system is purged and ic producing roprosontativo fluids Tho sampling personnel must tako caro not to disturb tho sediment m tho bottom of tho dram A disposable Letter to Mr Rusty Lundberg July 30, 2012 Page 2 bailer will be used to collect Cell 2 slimes dram samples and will be used to fill clean sample containers The bailer will be disposed of and not reused, thereby eliminating the need for decontamination of equipment or rinsate blanks Denison Response The text has been removed as requested DRC Comment The tailings wastewater solutions have pH measurements between 1 and 3 These solutions corrode the field meters during the collection of field measurements (pH, specific conductivity, and temperature) To prevent equipment damage, loss of measurements, and to protect health and safety of mill personnel from the corrosive tailings wastewater solutions, measurements of field parameters are not necessary The parameter pH will still be analyzed by the analytical laboratory The DRC already knows that pH in the tailing wells are very low, we don't need a field measurement to prove it to us Therefore, DRC recommends that Section 3 4 of the Plan be removed Denison Response Section 3 4 of the Plan has been removed as requested Please contact me if you have any questions or require any further information Yours very truly, De^l^oii Mirfes (USA) Corp. Jo Ann Tischler Director, Compliance and Permitting cc David C Frydenlund Harold R Roberts David E Turk KathyA Weinel Attachments DENISO MINES Letter to Mr Rusty Lundberg July 30, 2012 Page 3 ATTACHMENT A Tailings Cell, Leak Detection System and Slimes Dram Sampling and Analysis Plan, Revision 2 1, White Mesa Uranium Mill, near Blanding, Utah, DENISO MINES REDUNE White Mesa Uranium Mill SAMPLING AND ANALYSIS PLAN FOR TAILINGS CELLS, LEAK DETECTION SYSTEMS AND SLIMES DRAINS State of Utah Groundwater Discharge Permit No. UGW370004 Prepared by Denison Mines (USA) Corp. Suite 950, 1050 17"' Street Denver CO 80265 toe-Julv 3830.2012 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2_1 Jtme^Julv 30. 2012 Contents 1 0 Introduction 3 2 0 Sampling Frequency and Monitoring Requirements 3 3 0 Field Sampling Procedures 3 3 1 Tailings Cell Sampling 4 3 1 1 Sampling with a Peristaltic Pump 4 3 12 Sampling with a Ladle 5 3 1 3 Sampling with a Bailer 5 3 2 LDS Samohne 5 3 2 1 Cells 1. 2 and 3 LDS 5 3 2 2 Cells 4A and 4B LDS 5 3 3 Shmes Drain Sampling 5 3 4 Decontamination 6 3 5 Field OC 6 3 5 1 Sample Duplicates 7 3 5 2 Tno Blanks 7 3 5 3 Rinsate Blank Samples 7 4 0 OA and Data Evaluation 7 5 0 Laboratory Analysis 7 5 1 Analytical Ouality Control 8 6 0 ReDortme 8 7 0 Agency Notification 9 Formatted Fontcolor Auto Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2_l Jtme^JuIy 30, 2012 1 0 Introduction This Sampling and Analysis Plan ("SAP") describes the procedures for sampling the tailings cells, Leak Detection Systems ("LDS") and slimes drains at the White Mesa Mill in Blanding, Utah as required under Part I E 10 of the Groundwater Discharge Permit ("GWDP') No UGW370004 The objective of the tailings cell, LDS and slimes drain sampling is to collect annual samples from the locations identified below as required by the GWDP This SAP specifies the sample collection requirements, procedures, analytical methodologies, and associated Quahty Control ("QC") checks, sample handling protocols and reporting requirements for the annual tailings, LDS and slimes dram sampling program 2 0 Sampling Frequency and Monitoring Requirements The sampling frequency and sample monitoring requirements for the tailings cells, LDS and slimes drains are as specified in the GWDP Sampling is required to be conducted on an annual basis in August of each year for the solutions in tailings Cells 1, 3, 4A, and 4B, the solutions in the slimes drains in Cells 2, 3,4A, and 4B (for Cells 3, 4A, and 4B after the commencement of dewatering), the solutions in the LDS in Cells 4A and 4B and any detected solutions m the LDS in Cells 1, 2, and 3 at the time of the August sampling event Sampling locations are shown in Attachment 1 3 0 Field Sampling Procedures The field sampling and data collection program will obtain samples to be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP Analyses will be completed by a State of Utah certified laboratory using methods specified in the currently approved Denison-_Quality Assurance Plan ("QAF") for Groundwater Additionally per the GWDP requirements, tailings cell, LDS and slimes drain samples will be collected and analyzed for Semivolatile Organic Compounds ("SVOCs") Per the GWDP, the SVOCs will be analyzed by Environmental FVotection Agency ("EPA") Method 8270D Minimum detecUon limits or reporting limits for tailings, LDS and slimes drain samples for those analytes which have Groundwater Quality Standards (GWQSs") defined in Table 2 of the GWDP, will be less than or equal to the GWQS The minimum detection or reporting limits for total dissolved solids ('TDS") sulfate, chloride and SVOCs are specified in the GWDP and are • TDS will be less than or equal to 1,000 mg/L, • Sulfate will be less than or equal to 1,000 mg/L, • Chloride will be less than or equal tol mg/L, and • SVOCs will have reporting limits less than or equal to the lower limit of quantitauon for groundwater listed in Table 2 of EPA Method 8270D Revision 4, dated February 2007 Field activities include collecting samples, recording field data and field parameters, and preparing and shipping samples to the analytical laboratory Sampling informaUon will be recorded on the Tailings and Shmes Drain Field Sheet, (or its equivalent), included in Attachment 2 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2J. faft&^July 30. 2012 Sample handling and preservauon requirements for tailings cell, LDS and slimes drain samples are as specified in the QAP, except for SVOCs which are not routinely collected for any other Mill sampling program SVOCs do not require any chemical preservauon per EPA Method 8270D, however, SVOCs are required to be chilled Receipt temperatures, for all analytes except SVOCs, are as specified in the QAP The receipt temperature requirement for SVOCs is less than or equal to 6°C Sample collection procedures for tailings cell, LDS and slimes drain samples are as described below Where more than one sampling method is described, field personnel will choose a sampling method based on field conditions and safety considerations at the time of sampling The gross alpha and metals sample aliquots from the tailings cells, LDSs and shmes drains will not be field filtered or field preserved due to safety concerns associated with the filtering apparatus and the backpressure created by the increased viscosity of these samples The gross alpha and metals aliquots will be filtered and preserved by the analytical laboratory within 24 hours of receipt Field preservation of the gross alpha and metals sample aliquots may interfere with the laboratory's abihty to filter the samples upon receipt It is important to note that field preservation of the samples is to preclude biological growth and prevent the inorganic analytes from precipitating Based on the 2011 field data, the tailings, LDS and shmes dram samples were at a pH of 3 0 or less at the time of collection without additional preservative The addition of preservatives in the field would add minimal if any protection from biological growth or precipitation The VOC sample aliquots will be preserved in the field Clean sample containers utilized for this sampling effort will be provided by the analytical laboratory 3 1 Tailings Cell Sampling As noted in Section 2 0, sampling is required to be conducted on an annual basis in August of each year for the soluUons in tailings Cells 1, 3, 4A, and 4B Taihngs cell samples may be collected using a ladle, a peristaltic pump or a bailer The procedures for each sampling method are described below In all instances the sampling equipment will be either disposable or dedicated and decontamination procedures and rinsate blanks will not be required Sampling equipment will be inert and non-reactive 3 1 1 Sampling with a Peristaltic Pump Tailings samples may be collected using a peristaltic pump Samples collected with the peristaluc pump will be collected by extending collection tubing approximately 6 ft from the edge of the sampling station The tubing will be attached to a horizontal rod with sufficient tubing attached to lower the suction end of the tubing to approximately 1/3 of the distance between the liquid surface and the underlying solids The collecuon tubing will be attached to a peristaltic pump The tubing will be replaced prior to each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Due to the nature of the peristaltic pump, sample fluids do not come in contact with any surface other than the interior of the tubing, and decontamination of the pump or rinsate blanks is therefore not required The sample containers will be filled directly from the peristaltic pump outflow Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required, as noted in Section 3 0 Tailings Cell, Leak Detections System and Shmes Dram Sampling and Analysis Plan Revision 2_1 Jtme^July 30. 2012 3 1 2 Sampling with a Ladle Tailings samples may be collected using a ladle Samples collected with the ladle will be collected by dipping the ladle directly into the tailings solution taking care not to stir up any solids below the liquid surface Sample bottles will be filled directly from the ladle Ladles used for sampling will be dedicated to each location or will be disposed after each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Field filtering and field preservation of the gross alpha and metals sample aliquots will not be completed as noted in Section 3 0 3 1 3 Sampling with a Bailer Tailings samples may be collected using a disposable bailer Samples collected with the bailer will be collected by submerging the bailer into the tailings solution and allowing it to fill, taking care not to stir up any solids below the liquid surface The bailer will withdrawn from the tailings solution and the sample bottles will be filled directly from the bailer Bailers used for sampling will be disposed after each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required as noted in Section 3 0 3 2 LDS Sampling The LDS systems will be sampled as noted below 3 2 1 Cells 1,2 and 3 LDS The Cells 1, 2 and 3 LDSs will only be sampled if there is fluid present during the August sampling event If fluids are present dunng the annual August sampling event, samples will be collected using the dedicated pumps installed in the riser pipe Fluid level will be measured using the electronic pressure transducers currently installed in the LDS systems in the Cells Samples will be collected directly from the pump outflow lines into the sample containers Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as noted in SecUon 3 0 3 2 2 Cells 4A and 4B LDS Solution from the Cell 4A and 4B LDS will be collected into a dedicated stainless steel bucket Sample bottles will be filled from the stainless steel bucket using either the peristaltic pump or a ladle If the peristaltic pump is used to transfer the solution to the sample bottles, the tubing in the pump will be disposed of and not reused, thereby eliminating the need for decontamination of equipment or nnsate blanks If a ladle is used to transfer the solution to the sample botdes, the ladle will be either disposed of or will be dedicated to that location thereby eliminating the need for decontaminauon or rinsate blanks Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as noted in Section 3 0 3 3 Slimes Drain Sampling Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2J. Jtme^JuljL30,2012 Once a tailings cell has started de-watering procedures, a sample should be collected from the shmes drain system At this time Cell 2 is the only shmes drain that should be sampled The location of the slime drain for Cell 2 is depicted on Attachment 1 While Cell 3,Cell 4A and 4B are each equipped with a shmes drain sample access location, these Cells have not started dewatering and the shmes drain will not be sampled until dewatenng operations are underway Because dewatering in Cell 2 is ongoing, this cell will be included in the annual sampling effort The Cell 2 shmes drain will be sampled using a disposable bailer The Cell 2 shmes drain will bc sampled such that representative fluids ore collected—Accordingly, samples will only bo collected from this location when the pump has been operating in accordance with tho approved operating plan for a minimum of 48 hours pnor to sampling in order to assure that the system is purged and is producing representative fluids The sampling personnel must take care not to disturb the sediment in the bottom of the dram A disposable bailer will be used to collect Cell 2 shmes drain samples and will be used to fill clean sample containers The bailer will be disposed of and not reused, thereby eliminaUng the need for decontaminauon of equipment or rinsate blanks 3 1 Field Data In addition to the analytical parameters noted above, field data will be recorded at the time of sample collection—Field parameters required by the GWDP include pH, specific conductance and temperature- One variance from the requirements in tho Permit will be implemented Tho Permit, Section IE 10 (d) 1) requires the collection of field pH, temperature and conducuvity A field pH and temperature measurement will be collectod at tho time of sample collection using pH paper and a glass thermometer respectively Conductivity will bo measured by one of the Mill's contracted laboratories—During a previous sampling event tho tailings wastowater soluUons corroded the field meter after tho collection of the first set of moosuremonts which resulted in tho loss of tho meter and erroneous measurements following tho first sample To prevent equipment damage and loss of measurements, conductivity will no longer be measured m the field The laboratory will be able to complete the conductivity measurements because tho instruments m use by the laboratories aro "sturdier", suitable for corrosive solutions, and loss apt to be affected by the tailings wastewater solutions 3 54 Decontamination Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable sampling equipment is used to collect samples Decontamination procedures will be as described in the approved QAP Rinsate blanks will be collected daily after decontamination of sampling equipment If disposable or dedicated sampling equipment is used to collect samples, then rinsate blanks will not be collected 3 €5 Field QC The field QC samples generated during the annual tailings cell, LDS and shmes drain sampling event will include sample duplicates, trip blanks, and nnsate blank samples as appropriate Tailings Cell, Leak Detections System and Slimes Drain Sampling and Analysis Plan Revision 2_i fefle48July 30. 2012 3 56 1 Sample Duplicates Sample duplicates will be collected at a frequency of one duplicate per 20 field samples Sample duplicates will be collected by filling the sample container for a certain analytical parameter for the duplicate immediately following the collection of the parent sample for that parameter 3 5# 2 Trip Blanks Trip blank samples will be included in every shipment of samples that has field samples to be analyzed for Volatile Organic Compounds ("VOCs") Trip blank samples are VOC sample containers filled by the analytical laboratory with laboratory grade deionized water and shipped to the site Trip blank samples are taken into the field with the sample containers, never opened, and kept with the field samples from collection through shipment to the analytical laboratory for analysis Trip blanks are analyzed to determine if the sample concentration of VOCs have been effected by the "trip" from collection through shipment 3 56 3 Rinsate Blank Samples Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated, reusable sampling equipment is used to collect samples If the sampling equipment has a disposable component that comes in contact with the samples and the component is changed prior to sampling at each location then a rinsate blank sample will not be collected For example, if a peristaltic pump is used to collect and filter tailings, LDS and shmes drain samples and the tubing used in the peristaltic pump is changed at each location and never reused for more than one sample, no rinsate blank sample would be required 4 0 QA and Data Evaluation The Permit requires that the annual taihngs cell LDS and shmes drain sampling program be conducted in compliance with the requirements specified in the Mill's approved QAP, the approved SAP and the Permit itself To meet this requirement, the data validation for the tailings cell LDS and shmes drain sampling program will utilize the requirements outlined in the QAP, the Permit and the approved SAP as applicable The Mill QA Manager will perform a QA/QC review to confirm compliance of the monitoring program with requirements of the Permit, QAP and SAP As required in the QAP, data QA includes preparation and analysis of field QC samples, review of field procedures, an analyte completeness review, and quality control review of laboratory data methods and data The QAP and the Permit identify the data validation steps and data quality control checks required for the tailings cell LDS and slimes drain monitoring program Consistent with these requirements, the Mill QA Manager will performed the following evaluations a field data QA/QC evaluation, a receipt temperature check, a holding time check, an analytical method check, a reporting limit check, a tnp blank check, a QA/QC evaluauon of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory's reported QA/QC information The corrective action procedures descnbed in the approved QAP will be followed as necessary when data validation and QC reviews indicate a non-compliant situation 5.0 Laboratory Analysis Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2J. Jtme^July 30. 2012 As previously stated, samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP and SVOCs using the analytical methods specified in the approved QAP and EPA Method 8270D for SVOCs The Laboratories used for the tailings cell LDS and slimes drain sampling program will be Utah certified as required by the GWDP Part 1 E 6 (c) Laboratory data will be validated as described in the approved QAP and as described in Section 4 0 above Analytical QC is described below 5 1 Analytical Quality Control Analytical QC samples and protocols are described in the approved QAP Laboratory QC procedures will meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for by the State of Utah The analytical QC samples included at least the following a method blank, a laboratory control spike ("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where applicable It should be noted that • Laboratory fortified blanks are equivalent to LCSs • Laboratory reagent blanks are equivalent to method blanks • Post digestion spikes are equivalent to MSs • Post digestion spike duplicates are equivalent to MSDs • For method E900 1, used to determine gross alpha, a sample duplicate was used instead of a MSD All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager The effect on data usability will be discussed in the evaluation secuon of the annual report 6 0 Reporting A Tailings Cells Wastewater Quality Sampling Report will be included with the 3"* Quarter Groundwater Monitoring Report, due each year on December 1'' Each Tailings Cell Wastewater Sampling Report will include the following information • Introduction, • A description of sampling methodology, equipment and decontamination procedures identify all quality assurance samples, e g trip blanks, equipment blanks, duplicate samples, • Analytical data interpretation for each tailing cell, slimes drain, and leak detection system sample, • A wntten summary and conclusions of analytical results, • A table summarizing historic analytical results, • A QA evaluation, • All field data sheets accompanying the sampling event. Tailings Cell, Leak Detections System and Shmes Dram Sampling and Analysis Plan Revision 2_i Jme^Julv 30. 2012 • Copies of the laboratory reports, and • A "Tailings and Shme Drains System Sample Locations Map'' 7 0 Agency Notification At least 30 days advanced notice will be given to DRC prior to sampling activiues descnbed under this TaUings and Shines Drain Sampling Program in order to allow the ExecuUve Secretary to collect split samples of all tailing cell wastewater sources Attachment 1 10 PIEZ-2 a PIEZ-3 d rwjpre OTW4.5 O OTW4-3 OrW4-12 arW4-iq3jvV4-11 OTW4-13 TW4-7{3SifS!^-8 OTW4-1 OfTW4-4 OrW4-14 07W4-6 MW-03 PIEZ-5 MW-17 SCALE r 31,000' Denison Mines (USA) Corp mi\SO\F^kL MINES REVISIONS Proiect vVhite Mesa Mill Date By County San Juan | UT 10-oe Location ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS A""'"'- unknown Aug 2008 SCALE rslOOff Denison Mines (USA) Corp DENlSOlAtif J MINES REVISIONS Proiect VVhite Mesa Mill Data By County San Juan | ^^^^ UT 10-08 GM Location SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS unknown Aug 2008 Attachment 2 11 Field Data Record-Tailings, LDS and Slimes Drain Sampling Location: Sampling Personnel:. Is this a Slimes Drain? • Yes • No If this is a Slimes Drain, measure depth to wastewater immediately before sampling. DTW immediately before sampling (slimes only): Weather Conditions at Time of Sampling: Field Parameter Measurements: -pH -Temperature (°C) Analytical Parameters/Sample Collection Method: Parameter Sample Taken Filtered Sampling IVIethod Lab Name Parameter Sample Taken Filtered Peristaltic Pump Bailer Ladle Lab Name VOCs • Yes • No • Yes • No • • • THF • Yes • No • Yes • No • • • Nutrients • Yes • No • Yes • No • • • Other Non Radiologics • Yes • No • Yes • No • • • Gross Alpha • Yes • No • Yes • No • • • SVOCs • Yes • No • Yes • No • • • Conductivity • Yes • No • Yes • No • • • QC Samples Associated with this Location: • Rinsate Blank • Duplicate Duplicate Sample Name Notes: CLEAN White Mesa Uranium Mill SAMPLING AND ANALYSIS PLAN FOR TAILINGS CELLS, LEAK DETECTION SYSTEMS AND SLIMES DRAINS state of Utah Groundwater Discharge Permit No. UGW370004 Prepared by Denison Mines (USA) Corp. Suite 950, 1050 17* Street Denver CO 80265 July 30,2012 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 Contents 1 0 Introduction 3 2 0 Sampling Frequency and Monitoring Requirements 3 3 0 Field Sampling Procedures 3 3 1 Tailings Cell Sampling 4 3 11 Sampling with a Peristaltic Pump 4 3 1 2 Sampling with a Ladle 5 3 13 Sampling with a Bailer 5 3 2 LDS Sampling 5 3 2 1 Cells 1,2 and 3 LDS 5 3 2 2 Cells 4A and 4B LDS 5 3 3 Shmes Drain Sampling 5 3 4 Decontamination 6 3 5 Field QC 6 3 5 1 Sample Duplicates 6 3 5 2 Trip Blanks 6 3 5 3 Rinsate Blank Samples 6 4 0 QA and Data Evaluation 7 5 0 Laboratory Analysis 7 5 1 Analytical Quality Control 7 6 0 Reporting 8 7 0 Agency Notification 8 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 LO Introduction This Sampling and Analysis Plan ("SAP") describes the procedures for sampling the tailings cells. Leak Detection Systems ("LDS") and slimes drams at the White Mesa Mill in Blanding, Utah as required under Part IE 10 of the Groundwater Discharge Permit ("GWDP") No UGW370004 The objective of the tailings cell, LDS and shmes dram sampling is to collect annual samples from the locations identified below as required by the GWDP This SAP specifies the sample collection requirements, procedures, analytical methodologies, and associated Quahty Control ("QC") checks, sample handling protocols and reporting requirements for the annual tailings, LDS and slimes dram sampling program 2.0 Sampling Frequency and Monitoring Requirements The sampling frequency and sample monitonng requirements for the tailings cells, LDS and shmes drains are as specified in the GWDP Sampling is required to be conducted on an annual basis m August of each year for the solutions in tailings Cells 1, 3,4A, and 4B, the solutions in the shmes drains in Cells 2, 3, 4A, and 4B (for Cells 3, 4A, and 4B after the commencement of dewatering), the solutions in the LDS m Cells 4A and 4B and any detected solutions in the LDS in Cells 1, 2, and 3 at the time of the August sampling event Sampling locations are shown in Attachment 1 3.0 Field Sampling Procedures The field sampling and data collection program will obtain samples to be analyzed for the groundwater compliance parameters listed m Table 2 of the GWDP Analyses will be completed by a State of Utah certified laboratory using methods specified in the currently approved Denison Quality Assurance Plan ("QAP") for Groundwater Additionally per the GWDP requirements, tailings cell, LDS and slimes drain samples will be collected and analyzed for Semivolatile Organic Compounds ("SVOCs") Per the GWDP, the SVOCs will be analyzed by Environmental Protection Agency ("EPA") Method 8270D Minimum detection limits or reporting limits for tailings, LDS and shmes drain samples for those analytes which have Groundwater Quality Standards (GWQSs") defined in Table 2 of the GWDP, will be less than or equal to the GWQS The minimum detection or reporting limits for total dissolved solids ("TDS") sulfate, chlonde and SVOCs are specified in the GWDP and are • TDS will be less than or equal to 1,000 mg/L, • Sulfate will be less than or equal to 1,000 mg/L, • Chlonde will be less than or equal tol mg/L, and • SVOCs will have reporting limits less than or equal to the lower limit of quantitation for groundwater listed in Table 2 of EPA Method 8270D Revision 4, dated February 2007 Field activities include collecting samples, recording field data and field parameters, and prepanng and shipping samples to the analytical laboratory Sampling information will be recorded on the Tailings and Slimes Drain Field Sheet, (or its equivalent), included in Attachment 2 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 Sample handling and preservation requirements for tailings cell, LDS and shmes drain samples are as specified in the QAP, except for SVOCs which are not routinely collected for any other Mill sampling program SVOCs do not require any chemical preservation per EPA Method 8270D, however, SVOCs are required to be chilled Receipt temperatures, for all analytes except SVOCs, are as specified in the QAP The receipt temperature requirement for SVOCs is less than or equal to 6°C Sample collection procedures for tailings cell, LDS and shmes drain samples are as descnbed below Where more than one sampling method is described, field personnel will choose a sampling method based on field conditions and safety considerations at the time of sampling The gross alpha and metals sample aliquots from the tailings cells, LDSs and shmes drains will not be field filtered or field preserved due to safety concems associated with the filtering apparatus and the backpressure created by the increased viscosity of these samples The gross alpha and metals aliquots will be filtered and preserved by the analytical laboratory within 24 hours of receipt Field preservation of the gross alpha and metals sample aliquots may interfere with the laboratory's ability to filter the samples upon receipt It is important to note that field preservation of the samples is to preclude biological growth and prevent the inorganic analytes from precipitating Based on the 2011 field data, the tailings, LDS and shmes drain samples were at a pH of 3 0 or less at the time of collection without additional preservative The addition of preservatives in the field would add minimal if any protection from biological growth or precipitation The VOC sample aliquots will be preserved in the field Clean sample containers utilized for this sampling effort will be provided by the analytical laboratory 3 1 Tailings Cell Sampling As noted in Section 2 0, sampling is required to be conducted on an annual basis in August of each year for the solutions in taihngs Cells 1,3, 4A, and 4B Tailings cell samples may be collected using a ladle, a peristaltic pump or a bailer The procedures for each sampling method are descnbed below In all instances the sampling equipment will be either disposable or dedicated and decontamination procedures and nnsate blanks will not be required Sampling equipment will be inert and non-reactive 3 1 1 Sampling with a Penstaltic Pump Tailings samples may be collected using a penstaltic pump Samples collected with the penstaltic pump will be collected by extending collection tubing approximately 6 ft from the edge of the sampling station The tubing will be attached to a horizontal rod with sufficient tubing attached to lower the suction end of the tubing to approximately 1/3 of the distance between the liquid surface and the underlying solids The collection tubing will be attached to a penstaltic pump The tubing will be replaced pnor to each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Due to the nature of the penstaltic pump, sample fluids do not come m contact with any surface other than the intenor of the tubing, and decontamination of the pump or nnsate blanks is therefore not required The sample containers will be filled directly from the penstaltic pump outflow Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required, as noted in Section 3 0 Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 3 1 2 Sampling with a Ladle Tailings samples may be collected using a ladle Samples collected with the ladle will be collected by dipping the ladle directly into the tailings solution taking care not to stir up any solids below the liquid surface Sample bottles will be filled directly from the ladle Ladles used for sampling will be dedicated to each location or will be disposed after each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be completed as noted in Section 3 0 3 13 Sampling with a Bailer Tailings samples may be collected using a disposable bailer Samples collected with the bailer will be collected by submerging the bailer into the tailings solution and allowing it to fill, taking care not to stir up any solids below the liquid surface The bailer will withdrawn from the tailings solution and the sample bottles will be filled directly from the bailer Bailers used for sampling will be disposed after each use to preclude cross contamination and to eliminate the need for decontamination of sampling equipment Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required as noted m Section 3 0 3 2 LDS Sampling The LDS systems will be sampled as noted below 3 2 1 Cells 1, 2 and 3 LDS The Cells 1, 2 and 3 LDSs will only be sampled if there is fluid present dunng the August sampling event If fluids are present dunng the annual August sampling event, samples will be collected using the dedicated pumps installed in the nser pipe Fluid level will be measured using the electronic pressure transducers currently installed in the LDS systems in the Cells Samples will be collected directly from the pump outflow lines into the sample containers Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required as noted in Section 3 0 3 2 2 Cells 4A and 4B LDS Solution from the Cell 4A and 4B LDS will be collected into a dedicated stainless steel bucket Sample bottles will be filled from the stainless steel bucket using either the penstaltic pump or a ladle If the penstaltic pump is used to transfer the solution to the sample bottles, the tubing in the pump will be disposed of and not reused, thereby eliminating the need for decontamination of equipment or nnsate blanks If a ladle is used to transfer the solution to the sample bottles, the ladle will be either disposed of or will be dedicated to that location thereby eliminating the need for decontamination or nnsate blanks Field filtenng and field preservation of the gross alpha and metals sample aliquots will not be required as noted in Section 3 0 3 3 Shmes Dram Sampling Once a tailings cell has started de-watenng procedures, a sample should be collected from the shmes dram system At this time Cell 2 is the only shmes drain that should be sampled The location of the shme drain for Cell 2 is depicted on Attachment 1 While Cell 3,Cell 4A and 4B are each equipped with a Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 shmes drain sample access location, these Cells have not started dewatering and the shmes dram will not be sampled until dewatering operations are underway Because dewatenng in Cell 2 is ongoing, this cell will be included in the annual sampling effort The Cell 2 shmes dram will be sampled using a disposable bailer A disposable bailer will be used to collect Cell 2 shmes dram samples and will be used to fill clean sample containers The bailer will be disposed of and not reused, thereby eliminating the need for decontamination of equipment or nnsate blanks 3 4 Decontamination Decontarmnation of sampling equipment will be completed if non-dedicated and/or non-disposable sampling equipment is used to collect samples Decontamination procedures will be as descnbed m the approved QAP Rinsate blanks will be collected daily after decontamination of sampling equipment If disposable or dedicated sampling equipment is used to collect samples, then nnsate blanks will not be collected 3 5 Field QC The field QC samples generated dunng the annual tailings cell, LDS and shmes drain sampling event will include sample duplicates, trip blanks, and nnsate blank samples as appropriate 3 5 1 Sample Duplicates Sample duplicates will be collected at a frequency of one duplicate per 20 field samples Sample duplicates will be collected by filling the sample container for a certain analytical parameter for the duplicate immediately following the collection of the parent sample for that parameter 3 5 2 Tnp Blanks Tnp blank samples will be included in every shipment of samples that has field samples to be analyzed for Volatile Organic Compounds ("VOCs") Tnp blank samples are VOC sample containers filled by the analytical laboratory with laboratory grade deionized water and shipped to the site Tnp blank samples are taken into the field with the sample containers, never opened, and kept with the field samples from collection through shipment to the analytical laboratory for analysis Tnp blanks are analyzed to determine if the sample concentration of VOCs have been effected by the "trip" from collection through shipment 3 5 3 Rinsate Blank Samples Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated, reusable sampling equipment is used to collect samples If the sampling equipment has a disposable component that comes in contact with the samples and the component is changed pnor to sampling at each location then a nnsate blank sample will not be collected For example, if a peristaltic pump is used to collect and filter tailings, LDS and shmes drain samples and the tubing used in the peristaltic pump is changed at each location and never reused for more than one sample, no nnsate blank sample would be required Tailings Cell, Leak Detections System and Shmes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 4.0 QA and Data Evaluation The Permit requires that the annual tailings cell LDS and shmes dram sampling program be conducted m compliance with the requirements specified m the Mill's approved QAP, the approved SAP and the Permit itself To meet this requirement, the data validation for the tailings cell LDS and shmes drain sampling program will utilize the requirements outlined in the QAP, the Permit and the approved SAP as applicable The Mill QA Manager will perform a QA/QC review to confirm compliance of the monitonng program with requirements of the Permit, QAP and SAP As required in the QAP, data QA includes preparation and analysis of field QC samples, review of field procedures, an analyte completeness review, and quality control review of laboratory data methods and data The QAP and the Permit identify the data validation steps and data quality control checks required for the tailings cell LDS and shmes dram monitonng program Consistent with these requirements, the Mill QA Manager will performed the following evaluations a field data QA/QC evaluation, a receipt temperature check, a holding time check, an analytical method check, a reporting limit check, a tnp blank check, a QA/QC evaluation of sample duplicates, a gross alpha counting enor evaluation and a review of each laboratory's reported QA/QC information The corrective action procedures descnbed in the approved QAP will be followed as necessary when data validation and QC reviews indicate a non-compliant situation 5.0 Laboratory Analysis As previously stated, samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP and SVOCs using the analytical methods specified m the approved QAP and EPA Method 8270D for SVOCs The Laboratones used for the tailings cell LDS and shmes drain sampling program will be Utah certified as required by the GWDP Part 1 E 6 (c) Laboratory data will be validated as descnbed in the approved QAP and as described m Section 4 0 above Analytical QC is descnbed below 5 1 Analytical Quality Control Analytical QC samples and protocols are descnbed in the approved QAP Laboratory QC procedures will meet, at a minimum, the requirements set forth m the analytical methods that the laboratory is certified for by the State of Utah The analytical QC samples included at least the following a method blank, a laboratory control spike ("LCS"), a matnx spike ("MS") and a matnx spike duplicate ("MSD"), or the equivalent, where applicable It should be noted that • Laboratory fortified blanks are equivalent to LCSs • Laboratory reagent blanks are equivalent to method blanks • Post digestion spikes are equivalent to MSs • Post digestion spike duplicates are equivalent to MSDs • For method E900 1, used to determine gross alpha, a sample duplicate was used instead of a MSD Tailings Cell, Leak Detections System and Slimes Drain Sampling and Analysis Plan Revision 2 1 July 30, 2012 All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager The effect on data usability will be discussed in the evaluation section of the annual report 6.0 Reporting A Tailings Cells Wastewater Quality Sampling Report will be included with the 3"^ Quarter Groundwater Monitonng Report, due each year on December Each Tailings Cell Wastewater Sampling Report will include the following information • Introduction, A descnption of sampling methodology, equipment and decontamination procedures identify all quality assurance samples, e g trip blanks, equipment blanks, duplicate samples, Analytical data interpretation for each tailing cell, shmes drain, and leak detection system sample, A wntten summary and conclusions of analytical results, A table summanzing histonc analytical results, A QA evaluation. All field data sheets accompanying the sampling event. Copies of the laboratory reports, and A "Tailings and Shme Drams System Sample Locations Map" 7.0 Agency Notification At least 30 days advanced notice will be given to DRC prior to sampling activities descnbed under this Tailings and Slimes Drain Sampling Program m order to allow the Executive Secretary to collect split samples of all tailing cell wastewater sources Attachment I PIEZ-2 V • V MW-17 • MW-03 • PIEZ-5 0 SOO' SCALE 1 31000' Denison Mines (USA) Corp oENISOl/Xlii MINES REVISIONS Troject vVhits Mesa Mill Date By County San Juan | ^^'^ UT 10-08 GM Location ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS ANNUAL TAILINGS SAMPLE LOCATIONS unknown Aug 2008 // // ll 32 MW-02 MW-21 • C IVIW-12 MW.03 PiEZ-2 CELL 1 LEAK DETECTION SAMPLE LOCATION «^ W4-21 »XW4r226^ *T%4-20 OTW4-5 M42«TW4.1(P^^-® O 07W4-3 OTW4-12 brW4-1^TVV4-11 OTW4-13 TW4.7(3Si?3l^-8 1DTW4-14 MW-17 PIEZ-5 a f-21 SCALE 1" = 1000 Denison Mines (USA) Corp DENISOI MINES REVISIONS Proiect VVhite Mesa Mill Date By County San Juan | ^^^^^ UT 10-08 GM Location SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS SLIMES AND LEAK DETECTION SAMPLE LOCATIONS '^"««"" unknown Aug 2008 Attachment 2 10 Field Data Record-Tailings, LDS and Slimes Drain Sampling Location: Sampling Personnel:. Is this a Slimes Drain? • Yes • No If this is a Slimes Drain, measure depth to wastewater immediately before sampling. DTW immediately before sampling (slimes only): Weather Conditions at Time of Sampling: Field Parameter Measurements: -pH -Temperature (°C) Analytical Parameters/Sample Collection Method: Parameter Sample Taken Filtered Sampling Method Lab Name Parameter Sample Taken Filtered Peristaltic Pump Bailer Ladle Lab Name VOCs • Yes • No • Yes • No • • • THF • Yes • No • Yes • No • • • Nutnents • Yes • No • Yes • No • • • Other Non Radiologics • Yes • No • Yes • No • • • Gross Alpha • Yes • No • Yes • No • • • SVOCs • Yes • No • Yes • No • • • Conductivity • Yes • No • Yes • No • • • QC Samples Associated with this Location: • Rinsate Blank • Duplicate Duplicate Sample Name- Notes: