DRC-2024-005178

UTAH DIVISION OF RADIATION CONTROL
RML # UT1900479
ENERGY FUELSWHITE MESA MILL
INSPECTION MODULE EM-01
SEMI-ANNUAL EFFLUENT MONITORING REPORT
REPORTING PERIOD: July 1, 2023 through December 31, 2023
References:Utah Administrative Code R313-24-4;
10CFR40.65;
Radioactive Materials License UT1900479;
10CFR20 Appendix BTable II (Accessed April 2, 2024);
NRC Regulatory Guide 4.14;
Standard Operating Procedures (Dated December 19, 2022 and received December 22, 2022)
Inspector: Heather Mickelson Date: April 4, 2024
10CFR40.65(a)(1) requires the licensee to submit a report within 60 days after January 1 and July 1 of each year. The report must specify the quantity of each of the principal radionuclides
released to unrestricted areas in liquid and in gaseous effluents during the previous six months of operation.
1. Did the licensee submit the report within 60 days of the end of the reporting period i.e., January 1st or July 1st? (10CFR40.65(a)(1))Yes No
Comments:
The Semi-Annual Effluent Monitoring Report covering the period from July 1, 2023, to December 31, 2023, was dated February 26, 2024, and was received on February 29, 2024 (DRC-2024-004731).
An updated version of this document, dated March 27, 2024, was received on April 1, 2024 (DRC-2024-005133).
2.Were the stack samples analyzed for U-nat, 230Th, 226Ra and 210Pb? (NRC Reg Guide 4.14)Yes No N/A
Comments:
Stack sampling did not take place as the stacks were not in operation during the reporting period. The stacks for the south yellow cake dryer and the south yellowcake baghouse were last
sampled in the fourth quarter of 2022. The north yellowcake dryer has been out of operation since the third quarter of 2012 and has not been sampled since then.
3.Were site boundary effluent air samples analyzed for U-nat, 230Th, 226Ra and 210Pb? (NRC Reg Guide 4.14) Yes No
10CFR20 Appendix B Table 2 first paragraph states “The columns in Table 2 of this appendix captioned "Effluents," "Air," and "Water," are applicable to the assessment and control of
dose to the public, particularly in the implementation of the provisions of § 20.1302. The concentration values given in Columns 1 and 2 of Table 2 are equivalent to the radionuclide
concentrations which, if inhaled or ingested continuously over the course of a year, would produce a total effective dose equivalent of 0.05 rem (50 millirem or 0.5 millisieverts).”
Comments:
Effluent air samples were collected from the north (BHV-1, BHV-8, and BHV-2), east (BHV-7, BHV-5,BHV-6), and south (BHV-4) of the mill site and were analyzed for U-nat, 232Th, 230Th,
226Ra, and 210Pb. BHV-1 and BHV-8 are surrogate locations for the nearest resident to the north of the mill. BHV-6 was chosen as a surrogate for the White Mesa Ute Community. The locations
for sample collection are shown in Figure 1.
Figure 1. Sample collection locations that represent the Mill Boundaries.
4. Were the site boundary effluent air sample results within applicable limits for U-nat, 230Th, 226Ra and 210Pb? (10CFR20 Appendix B Table II)
Isotope
ECL (µCi/ml in air)*
U-nat
232TH
9E-14
4E-15
230Th
2E-14
226Ra
9E-13
210Pb
6E-13
*10CFR20 Appendix B Table II, ECL’s Yes No
Comments:
Sampling results were below the ECL for all monitoring locations for the last four quarters. See the attached Particulate, Radon, and Gamma Screening analysis for a summary of quarterly
and annual data and a calculated yearly dose at each high-volume air monitoring station.
5. Did the results of the effluent monitoring for this reporting period achieve the site’s ALARA objective of 25% of the ECL’s? (2007 License Renewal Application Vol. 1 Section 6.5;
10CFR20 Appendix B Table II)
Isotope
ECL (µCi/ml in air)*
25 % ECL (µCi/ml in air)
U-nat
232TH
9E-14
4E-15
2.25E-14
1.00E-15

230Th
2E-14
5.00E-15
226Ra
9E-13
2.25E-13
210Pb
6E-13
1.50E-13
*10CFR20 Appendix B Table II, ECL’s Yes No
Comments:
See the attached Particulate, Radon, and Gamma Screening analysis for measured site boundary effluent air sample results.
6. Were gamma measurements (minus background) collected at each monitoring station? Yes No
Comments:
See the attached Particulate, Radon, and Gamma Screening analysis for gamma measurements (minus background).
7.Were soil samples analyzed for U-nat, 226Ra and 210Pb? (NRC Reg Guide 4.14) Yes No N/A
Comments:
Soil samples were collected during the 3rd quarter of 2023. They were analyzed for U-nat, 226Ra and 210Pb, and 232Th.
8.Were vegetation samples analyzed for 226Ra and 210Pb? (NRC Reg Guide 4.14) Yes No
Comments:
Vegetation samples were collected on October 4, 2023and analyzed for U-nat, 232Th, 226Ra, and 210Pb.
9.Were radon samples (minus background) taken at sample stations BHV-1, BHV-2, BHV-4, BHV-5, BHV-6, BHV-7, and BHV-8? (NRC Reg Guide 4.14) Yes No
Comments:
Yes, samples were collected and analyzed for radon. See the attached Particulate, Radon, and Gamma Screening analysis for measured radon concentrations (minus background)?
The comparison of the dose associated with the measured radon concentration and the limit is difficult. The ECLs and threshold limit ECLs in 10 CFR 20 Appendix B Table assume either
no daughters present or 100 % ingrowth and result in a maximum exposure of 50mrems/year. The calculated ECLs account for partial ingrowth using methodology EPA 520/1-88-009 p 2-20 and
result in a maximum exposure of 25 mrem/year. Finally, the regulatory limit is 100 mrem/year.
10. Were radon samples analyzed for 222Rn? (NRC Reg Guide 4.14) Yes No
Comments:
Yes, 222Rn samples were collected and analyzed for. See the attached Particulate, Radon, and Gamma Screening analysis for measured radon concentrations (minus background).
11. Were the 222Rn results within the calculated ECL’s for the calculated ECL’s for the yearly average results for the past four quarters Yes No
Comments:
See the attached Particulate, Radon, and Gamma Screening analysis for the 222Rn results and analysis.
License Condition 11.2.D requires the licensee to utilize lower limits of detection in accordance with Section 5 of the NRC Regulatory Guide 4.14, as amended, for analysis of effluent
and environmental samples.
12. Were lower limits of detection (LLD) for analysis of stack effluent samples 10% or less of the limits found in 10CFR20 Appendix B Table II for U-nat,232Th,230Th, 226Ra and 210Pb?
(NRC Reg Guide 4.14)
Isotope
ECL (µCi/ml)*
10 % ECL (µCi/ml)
U-nat
232TH
9E-14
4E-15
9E-15
4E-16
230Th
2E-14
2E-15
226Ra
9E-13
3E-14
210Pb
6E-13
6E-14
*10CFR20 Appendix B Table II, ECL’sYes No N/A
Comments:
Stack sampling did not occur during the reporting period.
13.Were lower limits of detection (LLD) for analysis of site boundary air effluents within the limits listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, 230Th, 226Ra and 210Pb?
(NRC Reg Guide 4.14)

Isotope
LLD (µCi/ml in air)*
U-nat
1E-16
230Th
1E-16
226Ra
1E-16
210Pb
2E-15
*NRC Regulatory Guide 4.14 Section 5 LLD values (in air) Yes No
Comments:
None
14.Were lower limits of detection (LLD) for analysis of site boundarysoil samples within the limits listed in NRC Regulatory Guide 4.14 Section 5 for U-nat, 226Ra and 210Pb?
Isotope
LLD (µCi/g soil)*
U-nat
2E-7
226Ra
2E-7
210Pb
2E-7
*NRC Regulatory Guide 4.14 Section 5 LLD values (in soil) Yes No N/A
Comments:
The reporting limit for U-nat, 226Ra and 210Pb, and 232Th was 0.2 pCi/g (2E-7 µCi/g).
15.Were lower limits of detection (LLD) for analysis of site boundary vegetation samples within the limits listed in NRC Regulatory Guide 4.14 Section 5 for 226Ra and 210Pb?
Isotope
LLD (µCi/kg vegetation)*
U-nat
2.0E-7
226Ra
5.0E-8
210Pb
1.0E-6
*NRC Regulatory Guide 4.14 Section 5 LLD values (in vegetation) Yes No
Comments:
The LLDs in the data package are referred to as the reporting limit. In addition to the above LLDs, the 232Th LLD was 2.0 E-7 µCi/kg vegetation.
16. Were lower limits of detection (LLD) for analysis of radon samples within the limits listed in NRC Regulatory Guide 4.14 Section 5 for 222Rn?
Isotope
LLD (µCi/ml)*
222Rn
2.0E-10 (0.2pCi/L)
*NRC Regulatory Guide 4.14 Section 5 LLD values for radon Yes No
Comments:
The effective reporting limit for the RadonovaRapidos detector has an effective reporting limit of 0.06 pCi/L.
White Mesa Environmental Protection Manual Section 1.4, STACK EMMISIONS MONITORING PROCEDURES, sub-section 1.0, INTRODUCTION, states, “These sampling methods are also consistent with
guidance contained in the U.S. Nuclear Regulatory Commission’s Regulatory Guide 4.14, “Radiological Effluent and Environmental Monitoring at Uranium Mills.”
17. Were the yellowcake dryer and packaging stacks sampled in accordance with Regulatory Guide 4.14 Section 2.1.1?
Isotope
Sampling Frequency
U-nat
Quarterly
230Th
Semi-Annual
226Ra
Semi-Annual
210Pb
Semi-AnnualYes No N/A
Comments:
Stack sampling did not occur during the reporting period.

18. Did the results of the effluent monitoring for this reporting period achieve the site’s ALARAobjective of 25% of the ECL’s? (2007 LicenseRenewal Application Vol. 1 Section 6.5; 10CFR20
Appendix B Table II)
Isotope
ECL*
(µCi/ml in air)
ALARA Goal (µCi/ml in air)
U-nat
9E-14
2.25E-14
230Th
2E-14
5.15E-15
226Ra
9E-13
2.33E-13
210Pb
6E-13
1.50E-13
*10CFR20 Appendix B Table II, ECL’s: Yes No
Comments:
See the attached Particulate, Radon, and Gamma Screening analysis for the estimated dose.
Prepared By:
Heather Mickelson
Date
Reviewed By:
Phil Goble
Date
Reviewed By:
Adam Wingate
Date