DRC-2015-007959 - 0901a06880597626 (4)

November 6, 2015
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE:Semi-Annual Effluent Monitoring Report (Report) for Period July through December 2014White Mesa Mill (Mill), Blanding, UtahRadioactive Material License UT1900479
Dear Ms. Weinel:
The Division of Waste Management and Radiation Control (Division) has completed its review of the referenced report. The Report presents U-nat, Ra-226, Ra-228, Th-230, Th-232 and Pb-210
data from sampling of the local vegetation, soil, air stacks, fenceline air particulates and fenceline external direct gamma and radon. Also, the Report contains data from sampling the
surface water in Westwater Canyon and the radon flux from the cover of Cell 2.An effluent and environmental monitoring program is required by License Condition 11.2 and UAC R313- 15-301,
“Dose Limits for Individual Members of the Public.”
Attached is a copy of Inspection Module EM-01 which was used to record the review of the Report. Issues identified in the review should be addressed in future Reports.
The reported values from sampling Mill effluents and surrounding environmental media indicate that any contamination in unrestricted areas, from Mill operations, is below regulatory
limits in UAC R313-15-302(2)(b)(i),to protect individual members of the public.The attached memorandum contains comments on the Report.Many of the same comments are in the review of
the January 1 through July 1, 2015, Report. The Report does not need to be resubmitted. Please address these comments in future Reports.
If you have any questions, please call Connie Rauen at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/[CDR/ka
Enclosures:EFR Inspection Module EM-01 and Memorandum to EFR file
c:Worthy Glover, Health Officer, San Juan County Health Department.Rick Meyer, Environmental Health Director, San Juan County Health DepartmentPaul Wright, DEQ District EngineerDavid
Turk, Mill RSO
M E M O R A N D U M
TO:File: Energy Fuels Resources (USA) Inc., White Mesa Mill
THROUGH:Phil Goble, Manager, UMills/RAM Section
FROM:Connie Rauen, P.E., Engineer, UMills/RAM Section
DATE:November 6, 2015
SUBJECT:Review of the White Mesa Mill, Blanding, Utah, Semi-Annual Effluent Monitoring Report (SAER, Report) for Period July 1 through December 31, 2014
The Utah Division of Waste Management and Radiation Control (DWMRC) reviewed the subject document submitted by Energy Fuels Resources (USA) Inc., February 26, 2015, and received March
3, 2015. The Report includes U-nat, Ra-226, Ra-228, Th-230, Th-232 and Pb-210 data from sampling of the local vegetation, soil, air stacks, fenceline air particulates and fenceline external
direct gamma and radon. Also, the surface waters in Cottonwood Creek and WestwaterCnayon, as well as the Radon flux from the cover of Cell 2, were sampled.
With exceptions, the sampling events were conducted according to the revised White Mesa Mill Environmental Protection Manual (Manual), approved December 10, 2014. The revisions include
adding two air particulate samplers North and Northeast of the Mill, in the direction of the nearest resident, and increasing soil, vegetation and air analysis to include Th-232, Ra-228
and Pb-210, to represent constituents in recent alternate feed materials processed at the Mill. Th-232 data was added to air particulates. Th-232 and U-nat added to vegetation. Veg samples
were collected prior to the approval. Ra-228 added to stack sampling. Th-232 and Pb-210 added to soil samples.Sampling and analysis of the soil and for external direct gamma and Radon-222,
at the two new air monitoring stations, were added. The two new air monitoring stations were not operational in time for this monitoring event. There is data from sampling the air
particulates at BHV-8 but no data for BHV-7..
The review was conducted to ensure compliance with the following:
License UT0900480, Conditions 9.69, “Administrative Conditions, SOPs”, and Condition 11.2, “Monitoring, Recording and Bookkeeping”
White Mesa Mill - Standard Operating Procedures, Book #11: “Environmental Protection Manual,”
Section 1.1, “Air Monitoring – Particulate Radionuclides”
Section 1.2, “Air Monitoring – Radon”
Section 2.1, “Surface Water Monitoring Seeps and Springs”
Section 1.4, “Stack Emission Monitoring Procedures, White Mesa Gas Stack Emissions”
Section 4.1, “Surface Soil Monitoring”
Section 4.2, “Vegetation Monitoring”
10 CFR 40.65, “Effluent Monitoring Reporting Requirements”
10 CFR 20, Appendix B, Table 2, “Effluent Concentration Limits for Uncontrolled Area”
NRC Regulatory Guide 4.14, “Radiological Effluent and Environmental Monitoring at Uranium Mills,” proposed Rev. 2, February 2014
D.G. Maldonado, M.J. Diaz, A.J. Boerner, B.K. Price and R.E. Toohey,“Technical Basis Document to Support the Revision of Regulatory Guide 4.14, Revision 1, Radiological Effluent and
Environmental Monitoring at Uranium Mills,” Final Report, February 2014, prepared for the Nuclear Regulatory Commission by Oak Ridge Associated Universities
NRC Regulatory Guide 4.15, “Quality Assurance for Radiological Monitoring Programs – Inception Through Normal Operations to License Termination – Effluent Streams and the Environment,”
Rev. 2,
July 2007
NRC Regulatory Guide 4.16, “Monitoring and Reporting Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Cycle Facilities, December 2010
NUREG-1576, “Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP),” July 2004.
A summary of the reported results is in Table 1. For stack sampling results, when comparing the listed Effluent Concentration Limits (ECLs) to the measured values for the reporting
period, note that the ECLS are based on an air concentration which, if inhaled over the course of a year, would produce a total effective dose equivalent (TEDE) of 100 millirem; whereas,

the measured results are for a three month period.
Depending on the media sampled, reported values were below regulatory limits or within the range of historical values or do not indicate an upward trend in concentration, or indicate
that there is a long-term variation that would indicate deteriorating emission control equipment.
Review of the available field and laboratory QC data indicate that the measured values are from acceptable field sampling and laboratory analysis systems. However, there needs to be
better reporting and evaluation of field and laboratory QC samples. Reporting of QC sample analytical results and analysis of the QC data should be better presented and analyzed in
the Report.
The following pages contain the completed Inspection Module EM-1, documenting review of the Report.
In addition to the comments in the attached Module, the reviewer has the following comments on the Report that should be included in future Reports.
Sampling for Radon-222 Analysis
Pages 7, Section 2.5, “Radon-222,” of the Report, states that the methodology for calculating ECLs is specified in the Semi-Annual Effluent Report for July 2008 through December 2008.
There are “Radon Monitoring Reports” from Landauer which includes the starting and ending date each detector was at each location, the exposure in pCi/l-days and average radon concentration
in pCi/liter, but Division staff did not find a methodology. Future reports or the Manual should contain the conversion equation or “methodology.”
The acronym “ECL” should be reserved for Effluent Concentration Limit or defined in the Manual or Report. The air particulate sampling SOP uses an equation that calculates C as the reported
concentration based on the total air flow through the sampler. Consider using a C value rather than an ECL value and add the equation to either the Report or Section 1.2, “Air Sampling
– Radon,” of the Manual.
Explain how the density of the alpha tracks on the detector is converted to a concentration when the samplers are passive with no measured air flow. Consider adding this information
and equation, as used by Landauer, to the Report.
The Radon-222 SOP, Section 1.2 of the Manual, page 2 states that a field blank will be collected each quarter. The results from the analysis of field blanks should be included in the
Report. Please include in the Report, data from all of the Radtrak samplers as there are four samplers at each air particulate monitoring station.
Include the completed field “Detector Log Sheet” in the Report. Also, include a copy of the “Radon Monitoring Report,” from the analytical laboratory (Landauer) in the Report.
Please state in the Report as to which method, instrument type, manufacturer and model, is used to count the number of tracks. If only some of the Radtrak samplers are analyzed by a
high sensitivity (larger area) method then state so in the Report. Provide in the Report an analysis of comparison of the high and normal sensitivity analysis. State in the Report
the lower limit of detection for the detector.
Include a copy of a completed COC Form for tracking of the samples from the sampler locations to the analytical laboratory to a disposal facility. In the Report, include all data from
sample blanks. According to Section 1.2 of the Manual, one sample blank is prepared each quarter.
External Radiation (Direct Gamma)
Page 7, second paragraph of Section 3.0 of the Report, incorrectly refers to Table 6 as containing results of the OSL measurements. Table 6 contains Air Monitoring Results for Th-232.
Table 7 contains results of the OSL measurements. Please correct the error in future Reports.
Vegetation Samples
Appendix F contains the data from sampling and analysis of vegetation samples. Consider using a bar graph, rather than a line chart, to present the results from the current years’ sampling
events. The line-graph showing historical data is too crowded; there is no more room for data on the horizontal axis.
The completed Chain-of-Custody Form for Gel Laboratories should state that the sampler relinquished the samples to a shipper, i.e. UPS on November 25, 2014, to explain why there is a
break in custody between 11/25/14 and 12/14/14.
Please include in the Report, field data sheets showing the location, number and common name of plants, as well as photos of vegetation collected and containerized.
Stack Sampling
The Division would like all appropriate sections of the Manual to be revised, to reflect the proposed changes to R.G. 3.14 and the latest revision of ANSI N13.1-2011, including the design
criteria and the empirical tests to confirm that the particulates and gases collected are representative of the free flowing gas effluent.
Page 1 of the current revision, November 2015, of Section 1.4 of the Manual, states that the sampling will be 1) isokinetic, 2) representative, and 3) adequate for determination of the
release rates and concentrations of U-nat., Th-230, Ra-226 and Pb-210. The November 2015 revision added quarterly sampling for Th-232, Ra-228 and Th-228. Please revise page 1 of the
Manual.
Also, page 1 of Section 1.4 of the Manual, states that the methods conform to the principles, acceptable methods and materials for gas and particulate samples in ANSI N13.1-1969. This
standard was modified in 1999 and again in 2011. Please correct the date and update requirements in the Manual.
All field data sheets need to be both signed, by the sample collector, and dated. Some of the sheets, e.g. the volume of liquid (H20) in the impingers and the sample port locations are
dated but not signed by the sampler.
The Report states TETCO sampled the stacks but TestAmerica in Richland, Washington, analyzed the samples. A completed COC form from the White Mesa Mill to the analytical laboratory
should be completed, a copy provided in the Report, and the fact that a COC accompanied the samples, indicated on the Receipt of Samples Form.
The COC that was in the Report indicates that the samples were relinquished but does not indicate that anyone received the samples. If the samples were shipped from TETCO in American
Fork, Utah to Richland, Washington, then the name of the carrier should be on the COC form, the carrier/waybill number listed on the COC form and a copy of the carrier’s tracking receipt
included in the Report.
On page 3 of the Manual, it states that a continuous high-volume air sampler located at BHV-3, as a background location, was removed from operation in November 1995 (for air particulates
only). The COC Form does not show that a sample at BHV-3 was shipped to and received by the laboratory. Attachment B, Tab 3 contains a table with reported concentrations of U-nat, Th-230,
Pb-210 for dates that include 3/31/2014, 6/30/2014, 9/3/2014 and 12/29/2014 as well as concentrations since and including 1995. Please explain the discrepancyor add additional information
in the text of the Report.
Surface Water Sampling - Cottonwood Creek_
Page 9 of the Report states ”Concentrations remain low and within the range of typical background levels.” There are no “background levels” for Cottonwood Creek presented in the Report.
Which concentrations were used to compare to as “background”? Include background levels in the Report so that reviewers know which values are compared. For presentation of results
for surface water, soil, air, vegetation and external gamma, compare the results to background concentrations.
Soil Sampling
Based on an inspection of the Facility soil sampling, in August 2015, and the close-out conversations with Facility staff, the Manual, Section 4.1, will need to be revised to state that
a 4 cm depth with the1 ft2 area, at each location, will be sampled. Also, a decontamination procedure for the trowel needs to be added to the Manual.

On page 4, Section 2.3 “Sample Handling and Shipping,” of Section 4.1 of the Manual, state that custody seals will be placed on the shipping containers, before shipment. Please ensure
that custody seals will be used on all sample and shipping containers for all sampled media.
Air Particulate Sampling
The COC Form in Attachment C of the Report, indicates that GarrinPlamer relinquished the samples on 10/1/2014 and Garrin Palmer received the samples? Someone received them on 10/3/14.
Account for, on the COC Form, the time between Garrin relinquishing the samples and someone receiving the samples. If applicable, provide copies of a transporter tracking document with
the name of the transporter, the date(s) the transporter had custody of the samples and the transporter tracking number.
Text on page 8 states that BHV-3 is not sampled yet there is data in the table in Tab 3.V-3H
Cell 2 Radon Flux
Radon flux from Cell 2 is being monitored under the requirements of 10 CFR Part 40 Appendix B, Criterion 6(4) which states that the Licensee shall report results detailing the actions
taken to verify that levels of release of radon-222 do not exceed 20 pCi/m2s when averaged over the entire pile or impoundment. The Mill and Division are currently working on revisions
to a Reclamation Plan that will detail the cover design of impoundments and embankments, including Cell 2. Until and after the Reclamation Plan is approved, the Mill is required to monitor
the radon-222 levels until the concentration of radium in land does not exceed the levels specified in Criterion 6(6).
Table 1 Summary of July through December 2014 Monitoring Results
Media
Highest Reported Result in this Reporting Period or only reported result
Regulatory Limit/Comments
VegetationRa-226
232Th
Unat
210Pb
NE = 7.15E-4 uCi/kg
NE = 1.01E-4 uCi/kg
NE = 3.39E-4 uCi/kg
no real difference in values in any direction, all about the same value of 5E-4 uCi/kg average
No regulatory limit; used for dose assessment. Look for out-of- range values compared to previous sampling. Historical ranges are:
Ra-226 5E-3 to 2E-8 uCi/kg
232Th, first year analyzed
Unat, first year analyzed
210Pb >1E-2 to 1E-7 uCi/kg
Surface Soil
2.8 pCi/g Rn- 226 at BHV-5
3.71 pCi/g Unat at BHV-5
Unat. 2E-7 uCi/kg *
Rn-226 5E-8 uCi/kg
Westwater Canyon
Cottonwood Creek
0.0046 mg/l diss. Ur
0.0017 mg/l sus. Ur
No water in 4th Qtr., TDS and TSS in 3rd Qtr.
**3E-7 uCi/ml for U-238
External Gamma
w/out background
Semiannual cumulative
BHV-5 12.6mrem
BHV-19.6mrem
100 mrem/year TEDE
(UAC R313-15-301(1)(a))
Stack
Unat 2.8E+6pCi/hour from YC Baghouse
No regulatory limit, used for dose assessment and monitoring of effluent control systems
Air Particulate
BHV- 6Unat
BHV-5 Th-230
BHV-5 Ra-226
BHV-3 Pb-210
BHV-6 Th-232
8.92E-15uCi/ml 1stQtr
1.42E-15uCi/ml 1stQtr
3.48E-15uCi/ml 1stQtr
2.69E-14uCi/ml 1stQtr

1.00E-16uCi/ml 3rd Qtr.
**Effluent Concentration Limit
9E-14uCi/ml
3E-14uCi/ml
9E-13uCi/ml
6E-13uCi/ml
6E-15uCi/ml for U-238s
Rn-222
with background
0.6 pCi/l (January 2015 at BHV-5)
0.3pCi/l (September 2014at BHV-5)
0.1pCi/l (June 2014 at BHV-1)
0.54pCi/l (April 2014 at BHV-5)
**1E-10 uCi/ml, with daughters present
Cell 2 Radon Flux
20.4pCi/m2-sec
20 pCi/m2-sec
*R.G. 4.14, Rev.1, Radiological Effluent and Environmental Monitoring at Uranium Mills, April 25, 1980.
** 10 CFR 20 Appendix B, Table 2, “Effluent Concentrations”
UTAH DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
RML # UT1900479
ENERGY FUELS RESOURCES (USA) Inc., WHITE MESA MILL
INSPECTION MODULE EM-01
SEMI-ANNUAL EFFLUENT MONITORING REPORT REVIEW
REPORTING PERIOD: July 1, 2014 through December 31, 2014
Inspector: Connie RauenDate: November 3, 2015
10 CFR 40.65(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 ... to estimate maximum potential annual radiation doses to the public resulting
from effluent releases.
1. Did the licensee submit the report within 60 days of the end of the reporting period i.e., January 1st or
July 1st? Yes No
Comments: The Report for the second half of 2014, July through December, was received on March 3, 2015, and dated February 26, 2015.____________________________________________________
_______________________________________________________________________________
2. Were the air particulate samples, at the site boundary, analyzed for U-nat, Ra-226, Th-230, Th-232 and Pb-210 and was method SW 6020A, and other appropriate extraction and counting
methods used? (NRC Reg. Guide 4.14, Section 6.2 and Table B-1; NUREG 1576, MARLAP, July 2004) Yes No
Comments: Results of U-nat, Ra-226, Th-230, Th-232 and Pb-210 were reported. The laboratory reports in Attachment C, listed the appropriate analytical methods._______________________

3. Were the air stack samples analyzed for U-nat, Ra-226, Th-230, Th-232, Ra-228, Th-228 and Pb-210 and were acceptable extraction and analysis methods used? (NRC Reg. Guide 4.14,
Section 6.2 and Table B-1; NUREG 1576, MARLAP, July 2004) Yes No
Comments: Four test runs were conducted,two on the South yellowcake scrubber and two on the_ yellowcake dryer baghouse. The requirement that stack samples be analyzed quarterly, for
U-nat, Th-230, Ra-226, Pb-210 Th-232, Ra-228 and Th-228 was added to the “Stack Emission Monitoring Procedures,” Section 1.4 of the Environmental Protection Manual (Manual), on December
10, 2014. As such, only analysis for natural uranium (U-234, U-235 and U-238), were reported for this stack sampling event.
Analytical methods were not specifically listed in Appendix G. A table with a cross reference from_ Drinking Water ASTM Methods to Test America SOPs was included but it is not clear
as to how the table relates to the stack air sample analysis. _____________________________________________
4. Were the soil samples, at the site boundary, analyzed for U-nat, Ra-226, Th-230, and Pb-210 and were acceptable extraction and analysis methods used? (NRC Reg. Guide 4.14, Section
6.2 and Table B-1; NUREG 1576, MARLAP, July 2004).Yes No
Comments: Soil samples were analyzed for Uranium and Ra-226. Analytical methods were stated on the laboratory analytical report. Soil samples were collected and analyzed before revisions
to the__ Manual were approved on December 10, 2014, which added analysis for Th-230 and Pb-210.______
5.Were vegetation samples analyzed for U-nat, Ra-226, Th-230, Th-232 and Pb-210 and were acceptable extraction and analysis methods used? (NRC Reg. Guide 4.14, Section 6.2 and Table
B-1; NUREG 1576, MARLAP, July 2004).Yes No
Comments: Results of analysis for Ra-226 and Pb-210 were reported. Additional analysis for U-nat, and Th-232 were added in the latest revisions to the Manual which were after the November
vegetation____ sampling event. DOE RP280 Modified and EPA 900.1 Modified were listed in Appendix F on the____ Certificate of Analysis as the analytical methods.____________________________________________
6. Were samples analyzed for 222Rn and were acceptable extraction and analysis methods used? (NRC Reg. Guide 4.14, Section 6.2 and Table B-1; NUREG 1576, MARLAP, July 2004).Yes
No
Comments: Attachment J does not contain any laboratory reports and does not contain any ECL______
calculation sheets. It could not be determined which analytical or counting method was used as_____
no reports were included. The Report needs to contain field data and raw laboratory data, not merely
data in a table._________ ___________________________________________________
7.Were samples analyzed for direct gamma radiation and were acceptable extraction and counting methods used? (NRC Reg. Guide 4.14, Section 6.2 and Table B-1; NUREG 1576, MARLAP, July
2004) Yes No

Comments: Results of gamma measurements were in Table 7 of the Report. If one exists, please_____ provide a copy of the section of the Manual that contains the procedures for sampling,
analysis,_____ tracking of samples and reporting to monitor for gamma radiation. The Division does not have this__ section of the Manual. Provide additional information on the QC results
and analysis as well as_____ analytical methods, used for monitoring for gamma radiation, in the Report. Do not merely put a table in the Report with the results.__________________________________________________________
License Condition 11.2.D requires the licensee to utilize lower limits of detection in accordance with Section 5 of NRC Regulatory Guide 4.14, (Section 9.0 of draft dated February 2014),
as amended, for analysis of effluent and environmental samples. The Lower Limits of Detection (LLD) or Method Detection Concentrations (MDCs) are to be 10% of the Effluent Concentration
Limits (ECLs) for Uncontrolled Areas in 40 CFR 20, Appendix B, Table 2. Also, NRC Regulatory Guide 4.14, Section 5 “LLD values (in soil)” states: “Minimum Detectable Concentrations (MDCs)
are ten percent of the appropriate concentration values listed in Table 2 of Appendix B to 10 CFR 20”.
8. Were MDCs and/or LLDs used for analysis of each required media?Yes No
Comments: The following table lists the required ECL or LLD and 10% of the ECL or MDC. The last two columns list the lowest reported MDC, or LLD and lowest reported concentrations for
the last___ quarter of 2014 sampling events for each media. All of the reported concentrations are abovethe____
required 10% ECLs orthe MDCs. The MDCs for soil and Rn-22 in air need to be listed in the Report. __________________________________________________________________________
Media
Analyte
ECLs or LLD µCi/ml
10% ECL
µCi/ml
Lowest
Reported MDC*** µCi/ml
Lowest Reported Concentration ***
µCi/ml (location)
Stack effluent air
*ECL
Third quarter
MDL#
U-234
9.0E-14 Unat
9.0E-15
2.64E-5
4.5E-4 all at dryer
U-235
2.64E-5
2.0E-5 baghouse
U-238
3.26E-5
3.49E-4
Site boundary air
**LLD
U-nat
1.0E-16
na
Na
230Th
1.0E-16
3E-17
6E-17
Ra-226
1.0E-16
2E-17
4E-17
210Pb
2.0E-15
7E-17
1.1E-14
232Th
*4.0E-15
3E-17
0
Site boundary soil
**LLD
uCi/gm

U-nat
2.0E-7
not listed on
230Th
2.0E-7
laboratory
Ra-226
2.0E-7
analytical
210Pb
2.0E-7
report
232Th
2.0E-7
Site Boundary
222Rn**
2E-10
not in Report
Gamma
Na
na
na
Vegetation
**LLD uCi/kg
uC/kg
Total alpha
5E-8
7.41E-6
2.98E-5
210Pb
1E-6
1.30E-6
0.000246
Surface water
uCi/ml
pCi/l
mg/l
Cottonwood Creek
diss. Ur
sus. Ur
diss.g.alpha
sus. Ra-226
2E-10
2E-10
na
2E-10
no reported MDC
no reported MDC
1.3
0.37
0.0046
0.0017
7.5
6.5
Westwater Canyon
not sampled- no water
*10CFR20 Table II of Appendix B** NRC Regulatory Guide 4.14, Section 5
*** As reported in the SAER RL is the reporting limit #MDC=MDL adjusted for background, efficiency, chemical yield and volume, and error probability of approximately 5%
SOP EP-4, dated March 28, 2012, contains a “High Volume Air Sampler Calibration Form,” which is to record the indicated flow rate at the time of calibration.
9. Are all sampler calibration data correct and the Calibration Form included in the SAER? (SOP EP-4) Yes No

Comments: _The completed calibration form was not in the Report._____________________________
SOP EP-7, dated March 3, 2012, contains a “High Volume Air Sampling Collection Form” which is to contain the dates and times for beginning and ending sampling and the actual and observed
flow rates, with the calculated volume and average flow rate.
10. Was the “High-Volume Air Sampling Collection Form” included in the report and completed correctly? Yes No
Comments: The completed form was not in the Report._____________________________________
SOP EP-7, dated March 3, 2012, contains a “Surface Water Sampling Form” which is to contain the dates and times for beginning and ending sampling and the actual and observed flow rates,
with the calculated volume and average flow rate.
11. Was the “Surface Water Sampling Form” included in the report and completed correctly?Yes No
Comments: The completed, hand-written form, by the sampler, was not in the Report. However, there was a “Surface Water Field Water Analysis” form that was in the report and contains
the necessary_ information. __________
NUREG-1576, “Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP), Chapter 10.2.3.3 states: “Tamper-proof seals offer an additional measure to ensure sample integrity.
Individually sealing each sample with a custody seal with the collector’s initials and the date the sample was sealed may be required for the project. The seal ensures legal defensibility
and integrity of the sample at collection.” The seals are checked upon receipt at the laboratory to ensure that the samples were not tampered with after collection and during transport.”
12. Were custody seals on the sample containers and the shipping containers to indicate that samples were not tampered with prior to laboratory analysis? Yes No Comments:
_Custody seals were not on all sample containers for all media, as stated on the Laboratory Sample Receipt forms.
____________________________13. QA/ QC data review. Were data from method spikes and blanks included in the report and values within control limits? (NUREG-1576,
“Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP),July 2004,” and NRC Regulatory Guide 4.15, “Quality assurance for Radiological Monitoring Programs –Inception
Through Normal Operations to License Termination – Effluent Streams and the Environment,” Rev. 2, July 2007.) Yes No Comments: The QC results from all field and laboratory
samples were not included for all media. For vegetation samples, the laboratory QC summary sheets in Attachment F, listed the results of QC samples but the text of the report did not
discuss QC samples results and the effect of the results (if any) on the analyzed samples.
For air particulate samples, the Report, did not discuss the results of laboratory QC samples. The SOP does not specify the minimum number of required laboratory QC samples (blanks,
matrix spikes,laboratory control and laboratory duplicate samples) nor acceptable criteria for QC sample analysis. It could not be determined if the type, number, and analysis of QC
samples were adequate. Attachment C of the Report contains a table with information on weekly blank samples but the results from analysis of the samples are not included in the Appendix
nor in the text of the Report. ________________________
14. Were all corrections, in field forms, initialed and dated to indicate whether the data and field notes were tampered with? (NRC Regulatory Guide 4.15, “Quality assurance for Radiological
Monitoring Programs – Inception Through Normal Operations to License Termination – Effluent Streams and the Environment, Rev. 2,” July 2007.) Yes No Comments: Of the
field forms provided, not all were signed and dated by the sampler. However, they were initialed by the sampler and dated. No corrections were noted on the forms provided._________

UAC R444-14-1. States: “A laboratory that analyzes samples for compliance with rules established by the Utah Department of Environmental Quality, that require that the analysis be conducted
by a certified laboratory, must become certified under this rule and comply with its provisions. A laboratory certified under this rule to analyze samples for compliance with rules established
by the Utah Department of Environmental Quality that require that the analysis be conducted by a certified laboratory must also obtain approval under this rule for each analyte by a
specific method.”15. Is the analytical laboratory certified by the Utah Department of Health Environmental Laboratory Certification Program for analysis of U-nat by EPA Method 6010A,
ICPMS and for analysis of Ra-226 by Alpha Scintillation? Yes No Comments: The analytical laboratories included Energy Laboratories, in Casper, Wyoming, for air____particulate
filters and surface water samples,and Test America Inc., in Richland, Washington, for stack filter samples. Of the analytical laboratories noted in the Report, all were reported to
be Utah__certified.___________________________________________________________________________16. Were correctly completed chain-of-custody (COC) forms included in the report, to indicate
that the samples were in custody at all times? (NUREG-1576, “Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP), July 2004,” which references ASTM D4840 - 99(2010),
An ASTM designation number identifies a unique version of an ASTM standard.
D4840 - 99(2010)
D = miscellaneous materials;
4840 = assigned sequential number
99 = year of original adoption (or, in the case of revision, the year of last revision)
(2010) = year of last reapproval
“Standard Guide for Sampling Chain-of-Custody Procedures.”) Yes No Comments: Various COC Forms were completed. Few of them were completed correctly in that there was not
a completed chain.There were breaks in the custody that were not accounted for on the COC Forms. Some laboratory receipt forms contained UPS tracking numbers, but the COC forms did
not state that the samples were relinquished to UPS. __________________________ _______________
18. Is there a certification statement and signature by an authorized person? Yes No
Comments: There was no certification statement in the Report nor in the cover letter to the __________
Report._____________________________________________________________________________
References
License UT0900480, Conditions Sections 11 and 12.
Standard Operating Procedure (SOP) EP-4, High Volume Air Sampler Calibration, Rev. 11, datedMarch 28, 2012
SOP EP-7, High Volume Air Sampling, Rev. 12, dated March 28, 2012
10 CFR 40.65, “Effluent Monitoring Reporting Requirements”
10 CFR 20 Appendix B, Table 2, Effluent Concentration Limits for Uncontrolled Areas
NRC Regulatory Guide 4.14, “Radiological Effluent and Environmental Monitoring at Uranium Mills,” proposed Rev. 2, February 2014.
NRC Regulatory Guide 4.15, “Quality Assurance for Radiological Monitoring Programs – Inception Through Normal Operations to License Termination – Effluent Streams and the Environment,”
Rev. 2, July 2007.
NUREG-1576, “Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP), July 2004.”
ASTM D4840 - 99(2010), “Standard Guide for Sampling Chain-of-Custody Procedures.”
UAC R444-14, “Rule for the Certification of Environmental Laboratories,” revised Aug.1, 2015.

NRC Regulatory Guide 4.16, “Monitoring and Reporting Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Cycle Facilities, December 2010