DRC-2010-003385 - 0901a0688018eec7

State ofUtah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Govemor
June 1, 2010
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
ORC-2010-0033
CERTIFIED MAIL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth St. Suite 950
Denver, Colorado, 80265
Subject: Re: White Mesa Uranium Mill - Plan of Acfion and Schedule for Modification of
Groundwater Monitoring Quality Assurance Plan to Address Turbidity Stabilization and
Conversion to Low-Flow Sampling and Request for Interim Variance: Request for
Information
Dear Ms. Tischler:
On April 5, 2010 the Utah Division of Radiation Control (hereafter DRC) received your April 2,
2010 Request for Interim Variance letter regarding turbidity for the tailings, chloroform, and
nitrate wells. After reviewing the document, we have the following coniments, and requests for
information.
1. As-Built Reports - There are 26 chlorofomi investigafion wells and 19 nitrate
investigation wells at the facility. Part I.F.6 of the Permit requires that "Groundwater
Monitoring Well As-Built Reports - as-built reports for new groundwater monitoring wells
shall be submitted for Executive Secretary approval within 60 calendar days of well
completion.... " The DRC has received As-Built reports for all chloroform wells except for
TW4-23, TW4-24, and TW4-25. The DRC has not received anjj As-Built reports for the
19 nitrate investigation wells. Before the DRC can consider approval of any variance
regarding turbidity in monitoring wells, the DRC must be given the opportunity to verify
that the wells were designed, constructed, and developed appropriately. Please submit the
missing As-Built reports in accordance with Part I.F.6 of the Permit within 30 calendar
daysor July 1,2010.
2. Well Development - Page 10 of the December 30, 2009 Nitrate Contamination
Investigation Report states that nitrate wells "TWN-1 through TWN-19, were drilled,
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114^850
Telephone [phone] • Fax [phone] • T.D.D. (801) 5364414
www.deq, utalt.gov
Printed on 100% recycled paper
Page 2
completed, and developed in the same manner as the chloroform investigation wells... "
Please explain and jusfify how DUSA used all commonly available well development
techniques on the wells in quesfion, including: bailing, surging, jetting, and overpumping.
For a Standard Operating Procedure (hereafter SOP) for well development, please see the
October 3, 1994 EPA Well Development SOP. Before the DRC can consider approval of
any variance regarding turbidity in monitoring wells, DUSA has to provide convincing
evidence that all monitoring wells at the Mill have been developed properly and all
commonly well development methods were attempted and exhausted.
Well Purging - On page 2 of the April 2, 2010 Request for Interim Variance, DUSA gives
examples of problems they have observed with wells that are not meeting the 5 NTU
standard and are having difficultly meeting the requirement for stabilization of turbidity
within 10% over at least two consecutive measurements before sample collection. The
examples DUSA gives for this problem is as follows:
Well 2 Casing Volumes
(Gallons)
Time to Pump 2
Casing Volumes
Turbidity
Measurements
Time Pumped /
Gallons Purged
TW4-22 75.99 7.6 minutes 29.5, 36.9,
111.3, 70.4
7.6 minutes
(75.99 gallons)
TW4-23 74.1 7.4 minutes 136.2, 152,
95.7, 68.9
7.4 minutes
(74.1 gallons)
Secfion 6.2.7(d)(v) ofthe DUSA Quality Assurance Plan (hereafter QAP) states that
"Purging is completed after two casing volumes have been removed and the field
parameters pH, temperature, specific conductance, redox potential (Eh) and turbidity have
stabilized to within 10% over at least two consecutive measurements. " The examples
indicate that DUSA failed to comply with the above referenced QAP requirement. Please
be advised that the DRC cannot grant a variance that is based on evidence or conclusions
rooted in non-compliance.
4. Schedule for Submittal of Revised QAP - Page 5 of the April 2, 2010 Request for
Interim Variance shows that DUSA will submit a revised QAP on May 28, 2010 for DRC
review. On May 27, 2010, Mr. David Frydenlund called the DRC and asked that the
deadline be extended until the following week. Later that day, Mr. Frydenlund submitted
an e-mail which stated "we will submit the proposed amendments to the QAP to reflect the
amended sampling protocol and the most current EPA sampling guidance by June 4,
2010. " The DRC acknowledges the new deadline and will look for the revised QAP on
June 4, 2010.
Please review the above comments, and submit the requested information. If you have any
questions on the above, please contact me @ 801-536-4044.
Sincerely,
Phil Goble
Hydrogeologist