DRC-2016-008485 - 0901a0688064bfb2

Div of Waste Management
and Radiation Control
Energy Fuels Resources (USA) Inc.JUL 1 2 2016 225 Union Blvd. Suite 600
-nw-* ^ Lakewood, CO, US, 80228
303 974 2140^ www.energvfuels.com
July 9, 2016
Sent VIA OVERNIGHT DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Revised Sampling and Analysis Plans (“SAPs”) for Annual Wastewater Sampling
and Seeps and Springs Sampling for White Mesa Uranium Mill
Dear Mr. Anderson:
This letter transmits Energy Fuels Resources (USA) Inc.’s (“EFRFs”) proposed revisions to the White Mesa
Mill SAPs for annual wastewater sampling and seeps and springs sampling. These revisions include changes
made to:
1. Incorporate changes requested by the Division of Waste Management and Radiation Control
(“DWMRC”) personnel during an inspection.
2. Correct typographical errors.
For ease of review we have provided both redline/strikeout (text only) and clean versions (text and figures) of
each document.
If you should have any questions regarding these plans please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Harold R. Roberts
David E. Turk
Logan Shumway
Scott Bakken
REDLINE
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
SEEPS AND SPRINGS
Revision 2
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Denison Mines (USA) Corp.
Suite 950, 1050 IT^-Street
Denver CO 80265Energy Fuels Resources (USA) Inc.
225 Union Boulevard. Suite 600
Lakewood, CO 80228
■Iulv8.2016Junel0.2011
Table of Contents
1.0 Introduction and Objectives...................................................................................................................3
2.0 Seeps and Springs Sampling Locations...................................................................................................3
2.1 Timing of Sample Collection...............................................................................................................3
3.0 Field and Sampling Procedures...............................................................................................................4
3.1 Field Data............................................................................................................................................5
3.2 Decontamination................................................................................................................................5
3.3 Field QC.............................................................................................................................................65
3.4 Sample Handling.................................................................................................................................6
4.0 QA and Data Evaluation..........................................................................................................................6
5.0 Laboratory Analysis.................................................................................................................................7
5.1 Analytical Quality Control.............................................................................................................7
5.2 Evaluation of Analytical Data..............................................................................................................7
6.0 Reporting.........................................................................................................................................87
Attachments
Tab A Seeps and Springs Location Map
Tab B Bureau of Land Management Letter
Tab C Field Data Form
Tables
Table 1 Seeps and Springs Survey Information
1.0 Introduction and Objectives
This Sampling and Analysis Plan (“SAP”) describes the procedures for sampling seeps and springs in the
vicinity of the Denison Mines (USA) Corp. (“Denison”)Energy Fuels Resources (USA) Inc. (“EFRI”)
White Mesa Uranium Mill (“the Mill”) in Blanding, Utah as required by the State of Utah Groundwater
Discharge Permit (“GWDP”) No. UGW370004.
The objective of the seeps and springs sampling program is to collect annual surface water samples from
the locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies and associated quality control (“QC”) checks, sample
handling protocols and reporting requirements for the annual seeps and springs sampling program.
2.0 Seeps and Springs Sampling Locations
The annual seeps and springs sampling locations correspond with those seeps and springs sampled for the
initial site characterization performed for the Environmental Assessment as shown on Plate 2.6-10 of the
Environmental Report (Dames & Moore, 1978), and additional sites located by DemsonEFRI, the Bureau
of Land Management (“BLM”) BUM-and Ute Mountain Tribal representatives. The locations included in
the annual seeps and springs sampling event are:
• Cottonwood Seep
• West water Seep
• Ruin Spring
• Corral Canyon Seep
• Entrance Spring
• Corral Springs
The Permit Section I.F.7 (g) requires that survey data for the seeps and springs be submitted prior to the
| collection of samples. UDEO The Division of Waste Management and Radiation Control (“DWMRC”)
previously clarified the requirement to submit survey data only prior to the first sampling and not on an
annual basis. The survey data submitted with the first annual seeps and springs report in 2009 was
| incorrect. In response to the incorrect data, DUSA EFRI completed another survey of the seeps and
springs in December 2009. Those survey data are included in Table 1 of this SAP and the locations are
| shown on Figure 1 included in Tab A. The surveyed coordinates and elevations of the seeps and springs
were within 1 foot of the highest point of the saturated seepage face on the day of the survey
2.1 Timing of Sample Collection
EFRI representatives conducted reconnaissance visits to the locations listed in Section 2.0 above in June
2008 in order to determine the status of the listed springs and seeps and to evaluate the feasibility of
physical development with hand tools in order to better accommodate sampling at dry locations. It was
observed at that time that water flow was available for sampling at Ruin Spring. Cottonwood Seep and
Entrance Spring. Alternatively. Westwater Seep, Corral Canyon Seep and Corral Springs were entirely
dry or exhibited only barely moist soil. Annual sampling events conducted from 2009 through 2016
noted that dry conditions continued at Westwater Seep. Corral Canyon Seep and Corral Springs with no
opportunity for sampling even with limited hand tool development. Based on the data collected to date
regarding the conditions at the six locations specified in Section 2.0 above, the following schedule for site
visits and possible sampling will be employed:
• Once per calendar quarter, the Westwater Seep. Corral Canyon Seep and Corral Springs will be
visited. If sufficient water is present, a sample will be collected and no further visits will be
completed for the year. If no sample is collected prior to the annual event, these locations will be
visited during the annual sampling event. If these locations are dry during the annual sampling
event, the calendar quarter checks will continue until either a sample is collected or 4 quarterly
checks (one per calendar quarter) have been completed. NOTE: The annual report is due
December 1 of each year. The fourth quarter check will be limited to October and November to
meet the report deadline.
• Annually, between May 1 and July 15 of each year, a sample will be collected from Ruin Spring.
Cottonwood Seep and Entrance Spring. Should any of these locations be dry during the annual
event, quarterly checks (for the remaining calendar quarter) will be completed starting after the
annual event.
Should a visit reveal a change in conditions at any of these dry locations which may yield water sampling
opportunities. DemsenEFRI will proceed with limited hand tool excavation of the sampling location. The
hand-dug excavation will be left open for a maximum of 48 hours and allowed to fill with water. If water
collects in the excavation, it will be sampled. If the location is excavated with hand tools, it will be filled
after sampling has been completed, with the soil that was removed from it per the Bureau of Land
ManagemeftHBLIVD request included in Tab GB.
Seeps and spring sampling-will be-eonducted on an-annual-basis and will be scheduled between May 1
and July 15 of each year. This sampling period is aimed at maximizing the opportunity- for flow-but
excludes the potential for surface water influence occasioned by late summer “monsoon” eonditions. For
each annual sampling period, the locations noted above will be visited a minimum of three times in-order
to attempt collection of a sample.—Should a visit reveal a change in conditions at any of these dry
location#-vvhteh-may yield water sampling opportunities. Dcnir.on will proceed with limited hand tool
excavation of the sampling location. The hand dug excavation will be left open for a maximum of 18
hours and allowed to filh-with wafer- If water colkvtvnvtbe^cxeavation. it will be sampled.— If the
location is excavated with hand toolr,, it w ill be tilled after sampling has been complctcdv with the soil that
three annual visits at seeps and springs-locations reveal only dry conditions-and a continued absence of
physical development opportunities, a sample will not be collected and such conditions (and the inability
to sample) will be recorded on the field data sheet and reported along with the results of-eoHeeted samples
for that annual-sampling event.
Denison EFRI will provide at least 15 days notice of the annual sampling event conducted between May 1
and July 15 in order to allow the Executive SecretaryDWMRC to collect split water quality samples of
the seeps and springs.
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 the methods specified in the currently approved Denison EFRI Quality
Assurance Plan for Groundwater sampling (“QAP”). Minimum detection limits or reporting limits for
seeps and springs analyses will be less than or equal to the Groundwater Quality Standards defined in
Table 2 of the GWDP. The minimum detection limits for total dissolved solids (“TDS”), sulfate, and
chloride will be 10 mg/L, 1 mg/L, and 1 mg/L respectively.
Field activities include collecting samples, recording of field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling procedures employed at each location will be dependent on the site location and access.
Several sampling methodologies may be employed during one annual event based on access limitations
and flow rates of the seeps and springs that are sampled. Potential sampling methodologies are briefly
described below.
Direct Collection
Direct collection of the samples involves collecting the sample directly into the sample container from the
surface water feature or from spring out-flow. In instances where direct collection is employed the
parameters which require filtration will be collected by one of two methods. In the first method, the
peristaltic pump will be used to draw the sample from the out-flow and pump it through a 0.45 micron
filter directly into the appropriate sample container. The second method is used in situations with limited
access for the generator required to run the peristaltic pump. When the generator cannot be used, a large,
unused sample jug will be used to collect the sample. The peristaltic pump will then be used to transfer
the sample from the large sample jug to the sample bottles through a 0.45 micron filter. This filtration
and pumping will be completed at a location where there is access for the generator.
Peristaltic Pump
Sample collection with a peristaltic pump involves collecting the sample from the source or out-flow
using the peristaltic pump. The peristaltic pump is used to deliver the sample from the source or out-flow
to the sample bottles. Filtered parameters are pumped through a 0.45 micron filter prior to delivery to the
sample bottle.
Sample Ladle
Sample collection using a ladle involves dipping or filling a ladle made from an inert material into the
surface water source or out-flow and filling the ladle. The sample is transferred from the ladle to the
sample bottles. This process is repeated until the sample bottles are filled. Filtered parameters are
collected into a large, unused sample jug. The peristaltic pump is then used to transfer the sample from
the large sample jug to the sample bottles through a 0.45 micron filter.
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.
| Additional field parameters such as oxidation reduction potential (“REDOX”) and turbidity may be
measured as available sample volume allows. Field data will be recorded on the Field Data Record
| included in Tab B-C_of this SAP.
As previously noted, tThe dates of the site visits, the availability of surface water for sampling, and the
possibility for development will be recorded on the field data sheets for inclusion -in the annual report.
3.2 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.
3.3 Field QC
The field QC samples generated during the annual seeps and springs sampling event will include sample
duplicates, trip blanks, and rinsate blank samples as appropriate.
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.
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.
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 seeps and springs samples and the tubing used in the peristaltic is changed at each
location and never reused for more than one sample, no rinsate blank sample would be required.
3.4 Sample Handling
Seeps and springs sampling events will be subject to the applicable sample handling requirements noted
in the approved White Mesa Mill Groundwater Quality Assurance Plan (“QAP”), Revision 6, dated
March 22, 20 K).
4.0 QA and Data Evaluation
The Permit requires that the annual seeps and springs 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 seeps and springs 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
seeps and springs 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 trip blank check, a QA/QC
evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory’s
reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
Samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP
using the analytical methods and specified reporting limits contained in the approved QAP. Laboratories
used for the seeps and springs 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 section of the annual report.
5.2 Evaluation of Analytical Data
An evaluation of the analytical data will be completed in the annual report. A discussion of the results
will be included which will summarize the data relative to any detections reported in the samples with
comparisons as appropriate to the Mill groundwater quality data.
6.0 Reporting
BUSA-EFRI will collect seeps and springs samples -annually as required by the GWDP Part l.F.7. Each
report will: 1) document the sampling event by means of providing the field sheets recorded at the time of
sampling; 2) transmit copies of all field measurements and laboratory results; 3) provide a water table
contour map that includes water table elevation of all groundwater monitoring wells at the facility and the
elevations of the phreatic surfaces observed at each of the seeps and springs sampled; and 4) provide an
evaluation and interpretation of the groundwater quality data collected. Specific reporting requirements
for the seeps and springs sampling program will include but are not limited to:
• The annual seeps and springs monitoring report will be included with the 3rd quarter Routine
Groundwater Monitoring Report due on December 1, of each year.
• The seeps and springs water table contour map will include all water level data measurements
from all monitoring wells at the site from the 3rd quarter groundwater monitoring event for each
year.
• The seeps and springs water table contour map shall be at the map scale such that all seeps and
springs listed in this Plan and monitor wells at the site may be seen on one map.
Table 1
Seeps and Springs Survey Information
December 2009 Survey
Location Latitude (N)Longitude (W)Elevation
FROG POND 37°33'03.5358"109°29’04.9552" 5589.56
CORRAL CANYON 37°33'07.1392"109°29T 2.3907" 5623.97
ENTRANCE SPRING 37°32'01.6487"109°29’33.7005"5559.71
CORRAL SPRINGS 37°29'37.9192"109o29'35.8201"5383.35
RUIN SPRING 37o30'06.0448”109o31'23.4300"5380.03
COTTONWOOD 37°31'21.7002"109o32'14.7923"5234.33
WESTWATER 37°3r58.5020"109°3r25.7345"5468.23
Verification Survey July 2010
RUIN SPRING 37°30’06.0456"109°31'23.4181"5380.01
COTTONWOOD 37031'21.6987"109°32'14.7927" 5234.27
WESTWATER 37°31'58.5013"109°31'25.7357" 5468.32
CLEAN
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
SEEPS AND SPRINGS
Revision 2
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
July 8, 2016
Table of Contents
1.0 Introduction and Objectives...................................................................................................................3
2.0 Seeps and Springs Sampling Locations...................................................................................................3
2.1 Timing of Sample Collection...............................................................................................................3
3.0 Field Sampling Procedures......................................................................................................................4
3.1 Field Data............................................................................................................................................5
3.3 Field QC...............................................................................................................................................5
3.4 Sample Handling.................................................................................................................................6
4.0 QA and Data Evaluation..........................................................................................................................6
5.0 Laboratory Analysis.................................................................................................................................6
5.1 Analytical Quality Control.............................................................................................................7
5.2 Evaluation of Analytical Data..............................................................................................................7
6.0 Reporting...........................................................................................................................................7
Attachments
Tab A Seeps and Springs Location Map
Tab B Bureau of Land Management Letter
Tab C Field Data Form
Tables
Table 1 Seeps and Springs Survey Information
1.0 Introduction and Objectives
This Sampling and Analysis Plan (“SAP”) describes the procedures for sampling seeps and springs in the
vicinity of the Energy Fuels Resources (USA) Inc. (“EFRI”) White Mesa Uranium Mill (“the Mill”) in
Blanding, Utah as required by the State of Utah Groundwater Discharge Permit (“GWDP”) No.
UGW370004.
The objective of the seeps and springs sampling program is to collect annual surface water samples from
the locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies and associated quality control (“QC”) checks, sample
handling protocols and reporting requirements for the annual seeps and springs sampling program.
2.0 Seeps and Springs Sampling Locations
The annual seeps and springs sampling locations correspond with those seeps and springs sampled for the
initial site characterization performed for the Environmental Assessment as shown on Plate 2.6-10 of the
Environmental Report (Dames & Moore, 1978), and additional sites located by EFRI, the Bureau of Land
Management (“BLM”) and Ute Mountain Tribal representatives. The locations included in the annual
seeps and springs sampling event are:
• Cottonwood Seep
• Westwater Seep
• Ruin Spring
• Corral Canyon Seep
• Entrance Spring
• Corral Springs
The Permit Section I.F.7 (g) requires that survey data for the seeps and springs be submitted prior to the
collection of samples. The Division of Waste Management and Radiation Control (“DWMRC”)
previously clarified the requirement to submit survey data only prior to the first sampling and not on an
annual basis. The survey data submitted with the first annual seeps and springs report in 2009 was
incorrect. In response to the incorrect data, EFRI completed another survey of the seeps and springs in
December 2009. Those survey data are included in Table 1 of this SAP and the locations are shown on
Figure 1 included in Tab A. The surveyed coordinates and elevations of the seeps and springs were within
1 foot of the highest point of the saturated seepage face on the day of the survey
2.1 Timing of Sample Collection
EFRI representatives conducted reconnaissance visits to the locations listed in Section 2.0 above in June
2008 in order to determine the status of the listed springs and seeps and to evaluate the feasibility of
physical development with hand tools in order to better accommodate sampling at dry locations. It was
observed at that time that water flow was available for sampling at Ruin Spring, Cottonwood Seep and
Entrance Spring. Alternatively, Westwater Seep, Corral Canyon Seep and Corral Springs were entirely
dry or exhibited only barely moist soil. Annual sampling events conducted from 2009 through 2016
noted that dry conditions continued at Westwater Seep, Corral Canyon Seep and Corral Springs with no
opportunity for sampling even with limited hand tool development. Based on the data collected to date
regarding the conditions at the six locations specified in Section 2.0 above, the following schedule for site
visits and possible sampling will be employed:
• Once per calendar quarter, the Westwater Seep, Corral Canyon Seep and Corral Springs will be
visited. If sufficient water is present, a sample will be collected and no further visits will be
completed for the year. If no sample is collected prior to the annual event, these locations will be
visited during the annual sampling event. If these locations are dry during the annual sampling
event, the calendar quarter checks will continue until either a sample is collected or 4 quarterly
checks (one per calendar quarter) have been completed. NOTE: The annual report is due
December 1 of each year. The fourth quarter check will be limited to October and November to
meet the report deadline.
• Annually, between May 1 and July 15 of each year, a sample will be collected from Ruin Spring,
Cottonwood Seep and Entrance Spring. Should any of these locations be dry during the annual
event, quarterly checks (for the remaining calendar quarter) will be completed starting after the
annual event.
Should a visit reveal a change in conditions at any of these dry locations which may yield water sampling
opportunities, EFRI will proceed with limited hand tool excavation of the sampling location. The hand-
dug excavation will be left open for a maximum of 48 hours and allowed to fill with water. If water
collects in the excavation, it will be sampled. If the location is excavated with hand tools, it will be filled
after sampling has been completed, with the soil that was removed from it per the BLM request included
in Tab B.
EFRI will provide at least 15 days notice of the annual sampling event conducted between May 1 and July
15 in order to allow DWMRC to collect split water quality samples of the seeps and springs.
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 the methods specified in the currently approved EFRI Quality Assurance Plan
for Groundwater sampling (“QAP”). Minimum detection limits or reporting limits for seeps and springs
analyses will be less than or equal to the Groundwater Quality Standards defined in Table 2 of the
GWDP. The minimum detection limits for total dissolved solids (“TDS”), sulfate, and chloride will be 10
mg/L, 1 mg/L, and 1 mg/L respectively.
Field activities include collecting samples, recording of field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling procedures employed at each location will be dependent on the site location and access.
Several sampling methodologies may be employed during one annual event based on access limitations
and flow rates of the seeps and springs that are sampled. Potential sampling methodologies are briefly
described below.
Direct Collection
Direct collection of the samples involves collecting the sample directly into the sample container from the
surface water feature or from spring out-flow. In instances where direct collection is employed the
parameters which require filtration will be collected by one of two methods. In the first method, the
peristaltic pump will be used to draw the sample from the out-flow and pump it through a 0.45 micron
filter directly into the appropriate sample container. The second method is used in situations with limited
access for the generator required to run the peristaltic pump. When the generator cannot be used, a large,
unused sample jug will be used to collect the sample. The peristaltic pump will then be used to transfer
the sample from the large sample jug to the sample bottles through a 0.45 micron filter. This filtration
and pumping will be completed at a location where there is access for the generator.
Peristaltic Pump
Sample collection with a peristaltic pump involves collecting the sample from the source or out-flow
using the peristaltic pump. The peristaltic pump is used to deliver the sample from the source or out-flow
to the sample bottles. Filtered parameters are pumped through a 0.45 micron filter prior to delivery to the
sample bottle.
Sample Ladle
Sample collection using a ladle involves dipping or filling a ladle made from an inert material into the
surface water source or out-flow and filling the ladle. The sample is transferred from the ladle to the
sample bottles. This process is repeated until the sample bottles are filled. Filtered parameters are
collected into a large, unused sample jug. The peristaltic pump is then used to transfer the sample from
the large sample jug to the sample bottles through a 0.45 micron filter.
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.
Additional field parameters such as oxidation reduction potential (“REDOX”) and turbidity may be
measured as available sample volume allows. Field data will be recorded on the Field Data Record
included in Tab C of this SAP.
The dates of the site visits, the availability of surface water for sampling, and the possibility for
development will be recorded on the field data sheets for inclusion in the annual report.
3.2 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.
3.3 Field QC
The field QC samples generated during the annual seeps and springs sampling event will include sample
duplicates, trip blanks, and rinsate blank samples as appropriate.
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.
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.
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 seeps and springs samples and the tubing used in the peristaltic is changed at each
location and never reused for more than one sample, no rinsate blank sample would be required.
3.4 Sample Handling
Seeps and springs sampling events will be subject to the applicable sample handling requirements noted
in the approved QAP.
4.0 QA and Data Evaluation
The Permit requires that the annual seeps and springs 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 seeps and springs 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
seeps and springs 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 trip blank check, a QA/QC
evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory’s
reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
Samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP
using the analytical methods and specified reporting limits contained in the approved QAP. Laboratories
used for the seeps and springs 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 section of the annual report.
5.2 Evaluation of Analytical Data
An evaluation of the analytical data will be completed in the annual report. A discussion of the results
will be included which will summarize the data relative to any detections reported in the samples with
comparisons as appropriate to the Mill groundwater quality data.
6.0 Reporting
EFRI will collect seeps and springs samples annually as required by the GWDP Part l.F.7. Each report
will: 1) document the sampling event by means of providing the field sheets recorded at the time of
sampling; 2) transmit copies of all field measurements and laboratory results; 3) provide a water table
contour map that includes water table elevation of all groundwater monitoring wells at the facility and the
elevations of the phreatic surfaces observed at each of the seeps and springs sampled; and 4) provide an
evaluation and interpretation of the groundwater quality data collected. Specific reporting requirements
for the seeps and springs sampling program will include but are not limited to:
• The annual seeps and springs monitoring report will be included with the 3rd quarter Routine
Groundwater Monitoring Report due on December 1, of each year.
• The seeps and springs water table contour map will include all water level data measurements
from all monitoring wells at the site from the 3rd quarter groundwater monitoring event for each
year.
• The seeps and springs water table contour map shall be at the map scale such that all seeps and
springs listed in this Plan and monitor wells at the site may be seen on one map.
Table 1
Seeps and Springs Survey Information
December 2009 Survey
Location Latitude (N)Longitude (W)Elevation
FROG POND 37°33'03.5358"109°29'04.9552"5589.56
CORRAL CANYON 37°33'07.1392"109°29'12.3907"5623.97
ENTRANCE SPRING 37°32'0L6487"lOg^GSYOOS"5559.71
CORRAL SPRINGS 37°29,37.9192" 109°29'35.8201" 5383.35
RUIN SPRING 37°30'06.0448"109°3r23.4300"5380.03
COTTONWOOD 37°3r21.7002"109°32'14.7923"5234.33
WESTWATER 37o31'58.5020" 109°31’25.7345" 5468.23
Verification Survey July 2010
RUIN SPRING 37°30,06.0456" 109°31'23.4181"5380.01
COTTONWOOD 37°31'2L6987"109°32T4.7927" 5234.27
WESTWATER 37°31,58.5013"109°31'25.7357"5468.32
Attachment A
W:
\
L
e
g
a
c
y
\
U
S
A
\
U
T
A
H
\
M
i
l
l
\
S
e
e
p
s
_
a
n
d
_
S
p
r
i
n
g
s
_
0
9
-
2
0
1
1
\F
l
G
U
R
E
S
\
W
o
r
k
0
1
\
S
e
e
p
s
_
a
n
d
_
S
p
r
i
n
g
s
L
o
c
a
t
i
o
n
M
a
p
2
0
1
1
_B
L
M
2
.
d
w
g
Se
e
p
s
an
d
Sp
r
i
n
g
s
Lo
c
a
t
i
o
n
s
GM
o
s
e
l
e
y
Attachment B
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Monticello Field Office
Take Pride' in^m ERICA
P.0. Box 7
Monticello, Utah 84535
http://www.blm.gov/utah/monticello
IN REPLY REFER TO:
MAY 0 3 2011
LOAs
UTY020
RECEIVED
Jo Ann Tischler
Denison Mines (USA) Corp.
Director, Compliance and Permitting
1050 17th Street, Suite 950
Denver, CO, US, 80265
Dear Ms. Tischler:
As per your phone conversation with Realty Specialist Maxine Deeter last week, this letter
authorizes Denison to do water sampling on public lands administered by the Bureau of Land
Management adjacent to the White Mesa Mill south of Blanding, Utah. We understand that the
sampling will consist of hand digging two cubic feet square holes at springs which do not contain
standing water and leaving the holes to fill with water so that it can be tested in compliance with
Department of Environmental Quality (DEQ) requirements. As Maxine stated on the phone, we
do not consider this to be “development” of these springs but rather meets the definition of
casual use of public lands. We would request that these test holes be filled again with the soil
that was removed from them.
If you have questions or concerns, please contact Maxine at 435-587-1522 or via email.
Sincerely,
Thomas A. Heinlein
Field Office Manager
Attachment C
Field Data Record-Seeps and Springs Sampling
Seep or Spring Location: _______________________________
Date For Initial Sampling Visit:Time:_
Sample Collected: □ Yes □ No
Date For Second Sampling Visit:Time:
Sample Collected: □ Yes □ No
Date For Third Sampling Visit:Time:_
Sample Collected: □ Yes □ No
Sampling Personnel: ________________________________
Weather Conditions at Time of Sampling:_________________
Estimated Seep or Spring Flow Rate: ____________________
Field Parameter Measurements:
-PH
-Temperature (°C)
-Conductivity pMHOC/cm
-Turbidity (NTU) (if measured)
-Redox Potential Eh (mV) (if measured)
Analytical Parameters/Sample Collection Method:
Parameter Sample Taken Filtered Sampling Method
Direct Peristaltic
Pump
Ladle Other
(describe in
notes section)
VOCs □ Yes □ No □ Yes □ No □□□□
Metals □ Yes □ No □ Yes □ No □□□□
Nutrients □ Yes □ No □ Yes □ No □□□□
Other Non
Radiologies
□ Yes □ No □ Yes □ No □□□□
Gross Alpha □ Yes □ No □ Yes □ No □□□□
QC Samples Associated with this Location:
□ Rinsate Blank
□ Duplicate
Duplicate Sample Name:___________
Notes:
REDLINE
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
THE TAILINGS GELLSMANAGEMENT SYSTEM.
LEAK DETECTION SYSTEMS AND SLIMES
DRAINS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Denison Mines (USA) Corp.
Suite 950, 1050 IV^-Street
Denver CO 80265Energy Fuels Resources (USA) Inc.
225 Union Boulevard. Suite 600
Lakewood, CO 80228
July 30. 2012.1ulv 8, 2016
Tailings GeHManagement System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 2^3.0
July 308,20422016
Contents
1.0 Introduction...........................................................................................................................................3
2.0 Sampling Frequency and Monitoring Requirements......................................................................3
3.0 Field Sampling Procedures.................................................................................................................3
3.1 Cell Solution Sampling...................................................................................................................4
3.1.1 Sampling with a Peristaltic Pump..........................................................................................4
3.1.2 Sampling with a Ladle............................................................................................................5
3.1.3 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 Slimes Drain Sampling...................................................................................................................6
3.4 Decontamination..............................................................................................................................6
3.5 Field PC............................................................................................................................................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
2
Tailings GeMManagement System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 2r4-3.0
July 308, 20322016
1.0 Introduction
This Sampling and Analysis Plan (“SAP”) describes the procedures for sampling solutions in the tailings
eelismanagement system. 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-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 Quality Control (“QC”) checks,
| sample handling protocols and reporting requirements for the annual tailingscell solution, LDS and slimes
drain sampling program.
2.0 Sampling Frequency and Monitoring Requirements
| The sampling frequency and sample monitoring requirements for the tailings-eeHscell solutions. 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 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 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 Energy Fuels Resources
(USA) Inc. (“EFRI”) Quality Assurance Plan (“QAP”) for Groundwater. Additionally per the GWDP
requirements, tailings cell solutions, 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 tailingscell solutions, 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 toj 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 preparing and
shipping samples to the analytical laboratory.
3
| Sampling information will be recorded on the Tailings-Tailings Management System and Slimes Drain
Field Sheet, (or its equivalent), included in Attachment 2.
| Sample handling and preservation requirements for tailings cell solutions, 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 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 solutions, 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 of the tailings cell solutionss, LDSs and slimes 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 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 2Q4J-previous field
data, the tailingscell solutions. LDS and slimes 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 Solution 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 tailings Cells 1, 3, 4A, and 4B.
Tailings-eCell solution 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 Cell solution samples may be collected using a peristaltic pump. Samples collected with the
peristaltic 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 4^32 feet below the surface of the distance between the
liquid surface and the underlying solids. The collection 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
Tailings (SeHManagement System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision Td-3.0
July TQ8, 304-22016
4
peristaltic pump outflow. Field filtering and field preservation of the gross alpha and metals sample
aliquots will not be required, as noted in Section 3.0.
Tailings €eMManagement System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 243.0
July 208,20+22016
3.1.2 Sampling with a Ladle
Tailings Cell solution samples may be collected using a ladle. Samples collected with the ladle will be
collected by dipping the ladle directly into the tailmgs-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 Cell solution samples may be collected using a disposable bailer. Samples collected with the
bailer will be collected by submerging the bailer into the tailmgs-solution and allowing it to fill, taking
care not to stir up any solids-below the liquid surfaceallow the bailer to contact the bottom of the celL
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 filtering 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 during 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 cGells. Samples will be collected directly from
the pump outflow lines into the sample containers. Field fdtering 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 fdled 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 rinsate
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 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.
5
3.3 Slimes Drain Sampling
Once a tailings cell has started de-watering procedures, a sample should be collected from the slimes
drain system. At this time Cell 2 is the only slimes 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 slimes drain sample access location, these Cells have not started dewatering and the slimes drain will
not be sampled until dewatering operations are underway. Because dewatering in Cell 2 is ongoing, this
cell will be included in the annual sampling effort. The Cell 2 slimes drain will be sampled using a
disposable bailer.
A disposable bailer will be used to collect Cell 2 slimes drain 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.
3.4 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 solution. LDS and slimes drain sampling
event will include sample duplicates, trip blanks, and rinsate 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 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.
3.5.3 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 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 slimes drain samples and the tubing used in the peristaltic pump is
Tailings GeHManagement System' Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 2t4-3.0
July 308, 30432016
6
Tailings Cell-Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 2rl-3.0
July 308.30422016
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 tailings cell LDS and slimes 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-e-ell LDS and slimes 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 trip blank check, a
QA/QC evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each
laboratory’s reported QA/QC information.
The corrective action procedures described 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 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.
7
• 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 section of the annual report.
6.0 Reporting
An annual -Tailings €efe-Svstem Wastewater Quality Sampling Report will be included with the 3rd
Quarter Groundwater Monitoring Report, due each year on December 1st.
Each Tailings CefKSvstem 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 written summary and conclusions of analytical results,
• A table summarizing historic analytical results,
• A QA evaluation,
• All field data sheets accompanying the sampling event,
• Copies of the laboratory reports, and
• A “Tailings and Slime Drains System Sample Locations Map”.
Tailings GeHManagement System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3tL3.0
July m, m22016
7.0 Agency Notification
At least 30 days advanced notice will be given to PRG-Division of Waste Management and Radiation
Control (“DWMRC”) prior to sampling activities described under in this Tailings Management
System, Leak Detections System and Slimes Drain SAPTailings and Slimes Drain Sampling
Program in order to allow the Executive SecretaryDWMRC to collect split samples of all tailing cell
wastewater sourcessamples.
8
CLEAN
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
THE TAILINGS MANAGEMENT SYSTEM, LEAK
DETECTION SYSTEMS AND SLIMES DRAINS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
July 8, 2016
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
Contents
1.0 Introduction...........................................................................................................................................3
2.0 Sampling Frequency and Monitoring Requirements......................................................................3
3.0 Field Sampling Procedures.................................................................................................................3
3.1 Cell Solution Sampling...................................................................................................................4
3.1.1 Sampling with a Peristaltic Pump......................................................................................... 4
3.1.2 Sampling with a Ladle............................................................................................................5
3.1.3 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 Slimes Drain Sampling...................................................................................................................5
3.4 Decontamination.................
3.5 Field QC...............................
3.5.1 Sample Duplicates......
3.5.2 Trip Blanks...................
3.5.3 Rinsate Blank Samples
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
2
ON
On ON
O'
CT
\
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
1.0 Introduction
This Sampling and Analysis Plan (“SAP”) describes the procedures for sampling solutions in the tailings
management system, 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 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 Quality Control (“QC”) checks, sample handling protocols and reporting
requirements for the annual cell solution, LDS and slimes drain sampling program.
2.0 Sampling Frequency and Monitoring Requirements
The sampling frequency and sample monitoring requirements for the cell solutions, 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 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 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 in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using methods specified in the currently approved Energy Fuels Resources (USA) Inc.
(“EFRI”) Quality Assurance Plan (“QAP”) for Groundwater. Additionally per the GWDP requirements,
cell solutions, 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 cell solutions, 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 to 1 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 preparing and
shipping samples to the analytical laboratory.
Sampling information will be recorded on the Tailings Management System and Slimes Drain Field
Sheet, (or its equivalent), included in Attachment 2.
3
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
Sample handling and preservation requirements for cell solutions, 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 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 cell solutions, 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 of the cell solutions, LDSs and slimes 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 fdtered 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 previous field data, the cell solutions,
LDS and slimes 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 Cell Solution 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 Cells 1, 3, 4A, and 4B.
Cell solution 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
Cell solution samples may be collected using a peristaltic pump. Samples collected with the peristaltic
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 2 feet below the surface. The collection 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 filtering and field preservation of the gross alpha
and metals sample aliquots will not be required, as noted in Section 3.0.
4
3.1.2 Sampling with a Ladle
Cell solution samples may be collected using a ladle. Samples collected with the ladle will be collected
by dipping the ladle directly into the solution. 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
Cell solution samples may be collected using a disposable bailer. Samples collected with the bailer will
be collected by submerging the bailer into the solution and allowing it to fill, taking care not to allow the
bailer to contact the bottom of the cell. The bailer will withdrawn from the 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 filtering 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 during 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 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 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 rinsate
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 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
Once a tailings cell has started de-watering procedures, a sample should be collected from the slimes
drain system. At this time Cell 2 is the only slimes 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
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
5
a slimes drain sample access location, these Cells have not started dewatering and the slimes drain will
not be sampled until dewatering operations are underway. Because dewatering in Cell 2 is ongoing, this
cell will be included in the annual sampling effort. The Cell 2 slimes drain will be sampled using a
disposable bailer.
A disposable bailer will be used to collect Cell 2 slimes drain 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.
3.4 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 cell solution, LDS and slimes drain sampling event
will include sample duplicates, trip blanks, and rinsate 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 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.
3.5.3 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 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 slimes 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.
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
6
4.0 QA and Data Evaluation
The Permit requires that the annual 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 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 trip blank check, a
QA/QC evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each
laboratory’s reported QA/QC information.
The corrective action procedures described 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 Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
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 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.
7
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
An annual Tailings System Wastewater Sampling Report will be included with the 3rd Quarter
Groundwater Monitoring Report, due each year on December T'.
Each Tailings System 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 written summary and conclusions of analytical results,
• A table summarizing historic analytical results,
• A QA evaluation,
• All field data sheets accompanying the sampling event,
• Copies of the laboratory reports, and
• A “Tailings and Slime Drains System Sample Locations Map”.
7.0 Agency Notification
At least 30 days advanced notice will be given to Division of Waste Management and Radiation Control
(“DWMRC”) prior to sampling activities described in this Tailings Management System, Leak
Detections System and Slimes Drain SAP in order to allow DWMRC to collect split samples of all
samples.
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
8
Attachment 1
9
S:
\
S
o
u
r
c
e
\
U
T
\
W
h
i
t
e
M
e
s
a
M
i
l
i
\
M
a
p
s
\
T
a
i
l
i
n
g
s
Ma
n
a
g
e
m
e
n
t
\
A
n
n
u
a
l
Ta
i
l
s
Re
p
o
r
t
Fi
g
u
r
e
s
.
d
w
g
Pa
g
e
?
RE
I
I
i
s
Energy Fuels Resources (USA) Inc.
500' 0 500' 1,000'
REVISIONS Project: White Mesa Mi||
Date By County: San Juan | sta,e: Utah
10/8/14 RE Location: T37Si R22E
11/24/15 RE Annual Tailings System,
Cell Solution
Sample LocationsSCALE: I" = 1,000'
Author:_____ | Date: ^ 1/24/15 | Drafted By;
Attachment 2
10
Field Data Record-Tailings Solutions, 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:
Analytical Parameters/Sample Collection Method:
Parameter Sample Taken Filtered Sampling Method Lab
NamePeristaltic Pump Bailer Ladle
VOCs □ Yes □ No □ Yes □ No □□□
Metals □ Yes □ No □ Yes □ No □ □□
Nutrients □ Yes □ No □ Yes □ No □ □□
Other Non
Radiologies
□ Yes □ No □ Yes □ No □□ □
Gross Alpha □ Yes □ No □ Yes □ No □□□
SVOCs □ Yes □ No □ Yes □ No □□□
pH/Conductivity □ Yes □ No □ Yes □ No □□□
QC Samples Associated with this Location:
□ Rinsate Blank
□ Duplicate
Duplicate Sample Name:___________
Notes: