DRC-2013-004622 - 0901a06880426b85

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
w w w .energy fuels .corn
February 19, 2014 DRC-2013-004622
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Submittal of Radiological Characterization of Sewage at White Mesa Mill
Notice of Violation - Radioactive Materials License Number UT1900479
Dear Mr. Lundberg:
This letter provides Energy Fuels Resources (USA) Inc's ("EFRFs") follow-up to our letter of September
20, 2013 regarding a Notice of Violation received as a result of Utah Division of Radiation Control's
("DRC's") June 13, 2013 inspection at the White Mesa Mill.
Utah DRC performed an inspection of the White Mesa Mill (the "Mill") on June 13, 2013. The inspection
resulted in DRC's issuance of a Notice of Violation ("NOV") which was received by EFRI on July 8, 2013.
The NOV listed two violations of the Utah Radiation Control Rules. Violation 1, regarding documentation
of delivery driver training, was fully addressed in EFRFs letter of August 6, 2013. DRC confirmed in a
letter dated August 22, 2013, that EFRFs response to Violation 1 was satisfactory. Correspondence related
to Violation 2 is discussed and summarized below.
During the June 13, 2013 inspection, DRC's inspector reviewed documentation indicating that a vacuum
truck collected sewage from the Office Building Sewage Vault (the "admin Vault") on March 1, 2013 for
off-site release to the Blanding municipal sewage plant. The Admin Vault receives wastes from the main
office area which is outside the Mill's restricted area boundary; however, the vault itself is within the
restricted area boundary. The March 1, 2013 event was the first time in the history of the Mill that the
Admin Vault had been pumped out. The records reviewed by the inspector stated that the sewage truck was
surveyed for dose rate prior to release for off-site transfer of the material; however the sewage material was
not sampled for radiological characterization.
EFRI initially requested, in the letter of August 6, 2013, that Violation 2 be rescinded. The letter provided
technical rationale why the Admin Vault would not contain radionuclides of concern at levels above the
permissible limit for releases of uranium to sewers listed in 10 CFR 20 Appendix B, Table 3. Mr. Phil
Goble and Mr. Kevin Carney of DRC discussed the letter with EFRI during a telephone conference on
August 19, 2013. As a result of that telephone conversation, EFRI withdrew its contention that Violation 2
should be rescinded, and agreed to provide sampling and analysis of the radionuclide content of the Admin
Background
Letter to R. Lundberg
February 19, 2014
Page 2 of 4
Vault to confirm that the vault contents complied with the limits in 10 CFR 20 Appendix B Table 3 for the
radionuclides of concern at the Mill.
Subsequent to the phone call, DRC provided a letter on August 22, 2013, requiring EFRI to prepare a
written response including the root cause analysis and description and timing of the agreed-upon corrective
actions to address Violation 2. EFRI provided this response in a letter of September 20, 2013, which
committed to three corrective steps to address the non-compliance and prevent a recurrence, as follows:
1. Addition of language to the Mill's Radiation Protection Manual, Section 2.7, requiring that prior to
off-site shipment of any sewage or recyclable fluids from the Mill, samples will be collected and
analyzed for radionuclide content.
2. Sampling of all four sewage vaults on site and storage of current radiological characterization data
for sewage at the Mill, in the event that any sewage vault needs to be pumped out in the future. The
sampling of the Admin Vault would confirm that the sewage released off site on March 1, 2013
complied with the requirements of 10 CFR 20. Sampling of the other vaults would provide data
necessary to determine whether the contents of these vaults, if they were to be pumped out, could
be shipped off site or would need to be managed and disposed on site.
3. Re-education of the Mill Manager, Environmental Manager, RSO, and radiation technicians,
regarding the need for radiological characterization of materials leaving the Mill's restricted area.
As discussed in EFRFs letter of September 20, 2013, corrective steps 1 and 3, above, were completed
during September of 2013. The remainder of this letter demonstrates that since the submittal of the
September 20 2013 letter, EFRI has completed corrective step 2, and has confirmed that that the material
released on March 1, 2013 was in compliance with the limits in 10 CFR 20 Appendix B Table 3 for the four
radionuclides of concern at the Mill.
Field Sampling Program
On October 3, 2013, the Mill conducted sampling of the following sources of sewage that could potentially
be released from the Mill site:
Sample Number Sample Location
001 Admin Vault
002 CCR Vault
003 Change Room Vault
004 Scale House Vault
To sample each of the four sewage vaults, Mill personnel entered each vault and stirred the contents to
produce a homogenous sample. Mill personnel then collected a sample from the vault by use of a specially
rigged dipper.
One method blank, one sample duplicate (of the Admin Vault) and one laboratory control sample were
prepared and analyzed by the contract laboratory. Sample handling followed the same chain of custody
procedures used for other types of sampling conducted pursuant to the Mill's Radioactive Materials
License.
2
Letter to R. Lundberg
February 19, 2014
Page 3 of 4
Analytical Methodology
Soil samples were analyzed by a third party contract laboratory, GEL Laboratories LLC ("GEL").
As discussed with Kevin Carney of DRC on September 16, 2013, EFRI agreed to have samples analyzed
for the same four radionuclides of concern as monitored and reported in the Mill's Semi-Annual Effluent
Report, specifically:
• Pb-210
• Ra-226
• Th-230
• U-nat
The laboratory was required to provide limits of detection equal to or lower than the limits for each
radionuclide as listed in 10 CFR 20 Appendix B Table 3. Table 3 specifies monthly average concentration
limits for releases to sewers.
Results and Conclusions
Attachment 1 of this letter provides a comparison of the laboratory analytical to the limits in 10 CFR 20
Appendix B Table 3. Analytical data package from GEL is provided in Attachment 2. The results are
summarized and discussed below.
Admin Vault
Each of the four radionuclides of concern was below its respective detection limit in the Admin Vault
sample. Assuming that the sample collected on October 3, 2013 is representative of the sewage that was
collected in the Admin Vault from the Mill's inception until the vacuum truck emptied it for the first time
on March 1, 2013, these results confirm that the material released from the Mill on March 1, 2013 complied
with the limits in 10 CFR 20 Appendix B.
CCR Vault
Pb-210 and Ra-226 in the CCR Vault sample each exceeded their respective limits in 10 CFR 20 Appendix
B. All other radionuclides analyzed were below their respective detection limits.
Change Room Vault
Pb-210 and Th-230 in the Change Room Vault sample each exceeded its respective limit in 10 CFR 20
Appendix B. All other radionuclides analyzed were below their respective detection limits.
Scale House Vault
Each of the four radionuclides of concern was below its respective detection limit in the Scale House Vault
sample. Theoretically, if this vault needed to be pumped out, its contents could be released for off-site
transfer to the Blanding sewage plant.
3
Letter to R. Lundberg
February 19, 2014
Page 4 of 4
Proposed Management of Analyzed Materials
Based on the analytical results discussed above, the contents of both the Admin Vault, which were released to
the municipal sewage plant on March 1, 2013 and the Scale House Vault, which were not released and do not
require release at this time, comply with the requirements in 10 CFR 20 Appendix B to be released to municipal
sewer systems. As discussed above, the contents of the CCR Vault and Change Room Vault exceeded the
acceptable limits for discharge to municipal sewers at this time, based on the October 2013 sampling event. The
contents of these two vaults have never been pumped for release off site and do not require removal at this time.
EFRI proposes to manage sewage vault contents as follows. The Mill will sample and analyze sewage vault
contents for radionuclide concentrations once every two years or prior to pumping of a sewage vault as needed.
The resulting radiological characterization data will be used to determine whether the pumped material will be
managed on site in the Mill's tailings system or released to the municipal sewage plant. Current
characterization data will be maintained at the Mill for DRC review.
If a sewage vault requires pumping or removal of its contents, EFRI will evaluate the most current data for that
vault. If each of the four radionuclides of concern is present at levels below the limit in 10 CFR 20 Appendix B
for sewer discharge, EFRI may choose to ship the material off site to the Blanding municipal sewage plant. If
any of the four radionuclides of concern exceeds its limit in 10 CFR 20 Appendix B, the sewage vault materials
will be managed on site. The sewage materials will be transferred into steel or plastic drums, which will be
sealed and transferred to the tailings system for on-site disposal. Sewage will be disposed in the tailings cell or
cells currently approved for disposal of Mill waste. Drums of sewage will be disposed consistent with the
currently approved version of the Mill Waste Disposal SOP, PBL-7, to ensure protection of the liner of the cell
in which it is placed.
In addition, prior to any off-site shipment of recyclable fluids from the Mill, appropriate surveys and/or analysis
will be performed to assure that applicable release standards are met.
Achievement of Full Compliance Relative to the NOV
As discussed with DRC on the phone call of August 19, 2013 and in a subsequent meeting on November
12, 2013, submittal of the analytical characterization data accompanying this letter completes the corrective
action steps required to achieve full compliance with requirements applicable to the sewage release.
Yours-very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
cc: Kevin Carney, Utah DRC
David C. Frydenlund
Philip Goble, Utah DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Attachments
4
ATTACHMENT 1
SUMMARY OF SEWAGE SAMPLE RESULTS
AND
RELEASE LIMITS
10 CFR 20 Appendix B
Release Limits
Appendix B Table 3 Monthly Average Concentration Limits for Releases to Sewers
Isotope
Release Limit
(uCi/ml)
Sample 01 Admin
Vault (uCi/ml)
Sample 02 CCR Vault
(uCi/ml)
Sample 03 Change
Room Vault
(uCi/ml)
Sample 04 Scale
House Vault
(uCi/ml)
Pb-210 1.0E-07 ND 4.80E-07+/-3.73E-08 1.09E-06+/-3.95E-08 ND
Ra-226 6.0E-07 ND 6.22E-07+/-1-06E-07 ND ND
Th-230
U-235/236
U-238
1.0E-06
3.0E-06
3.0E-06
ND
ND
ND
ND
ND
ND
1.30E-06+/-4.51E-08
ND
ND
ND
ND
ND
NOTE:
ND indicated that the analyte was not detected at the required reporting limit.
Entries on this page flagged as "ND" were flagged with the data qualifier "U" in the data package
from GEL Laboratories.
ATTACHMENT 2
GEL ANALYTICAL DATA PACKAGE
# GEL LABORATORIES £b
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company s
Address :
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Report Date: February 18, 2014
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lake wood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Admin Vault
335208001
Mise Liquid
03-OCT-13 09:25
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
3arameter Qualifier Result Uncertainty MDC RL
lad Alpha Spec Analysis
Uphaspec Th, Liquid "As Received"
Tjorium-230 U -7.0 IE-10 +/-3.I6E-09 1.45E-08 1.00E-06
Uphaspec U, Liquid "As Received"
Jranium-235/236 U -3.98E-10 +/-I.75E-09 7.95E-09 3.00E-06
Jranium-238 U 1.72E-09 +/-2.41E-09 8.19E-09 3.00E-06
tad Gas Flow Proportional Counting
}FPC, Pb210, Liquid "As Received"
,ead-2IO U 8.83E-08 +/-2.94E-08 9.02E-08 1.00E-07
tad Radium-226
.ucas Cell, Ra226, liquid "As Received"
Ladium-226 U 2.44E-07 +/-9.55E-08 2.82E-07 6 OOE-07
The following Analytical Methods were perfonned:
vlethod Description
DOE BML HASL-300, Th-01-RC Modified
: DOE EML HASL-300, U-02-RC Modified
: DOE RP280 Modified
i EPA 903. i Modified
Surrogate/Tracer Recovery ' o>l
Tx>rium-229 Tracer Alphaspec Th, Liquid "As Received"
Jranium-232 Tracer Alphaspec U, Liquid "As Received"
,ead Carrier GFPC, Pb210, Liquid "As Received"
Units
uCi/rnL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
DF Analyst Date Time Batch Method
JXH2 10/25/13 1101 1338432 1
JXH2 10/24/13 1014 1338429 2
KDF1 11/06/13 0955 1338156 3
KSD1 10/28/13 2035 1338764 4
Analyst Comments
Result Nominal Recovery% Acceptable Limits
84.6 (15%-125%)
108 (!5%-125%)
92.5 (25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
3RL *= Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
;he greater of either the adjusted MDL or the CRDL.
# GEL LABORATORIES *
2040 Savage Road Charieston SC 29407 - [phone] - www.gel.com
Certificate of Analysis
Company:
Address :
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Report Date: February 18, 2014
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
CCR Vault
335208002
Misc Liquid
03-OCT-13 09:45
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
'arameter Qualifier Result Uncertainty MDC
Lad Alpha Spec Analysis
dphaspec Th, Liquid "As Received"
horiurn-230 U 4.80E-07 +/-2.90E-08 1.15E-08
dphaspec U, Liquid "As Received"
lranium-235/236 U 8.84E-08 +/-1.15E-08 8.09E-09
iranium-238 U 1.69E-06 +A4.48E-08 8.74E-09
Lad Gas Flow Proportional Counting
iFPC, Pb210, Liquid "As Received"
ead-210 4.80E-07 +/-3.73E-08 5.32E-08
Lad Radium-226
,ucas Cell, Ra226, liquid "As Received"
.adium-226 6.22E-07 +/-1.06E-07 2.19E-07
The following Analytical Methods were performed:
Method Description _____
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903.1 Modified
.urrogate/Tracer Recovery Test _^
horium-229 Tracer Alphaspec Th, Liquid "As Received"
Iranium-232 Tracer Alphaspec U, Liquid "As Received"
.ead Carrier GFPC, Pb210, Liquid "As Received"
RL
1.00E-06
3.00E-06
3.00E-06
I.OOE-07
6.00E-07
Units
uCi/mL
uCi/mL
uCi/mL
uCi/mL
DF Analyst Date Time Batch Method
JXH2 10/25/13 1101 1338432
JXH2 10/24/13 1014 1338429
KDF1 11/06/13 0934 1338156
uCi/ml KSD1 10/28/13 1400 1338764
Analyst Comments
Result Nominal Recovery0/
84.1
97.3
98.5
Acceptable Limits
(15%-125%)
(15%-125%)
(25%-125%)
^otes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
>RL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
he greater of either the adjusted MDL or the CRDL.
# GEL LABORATORIES fftb
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Company 1
Address:
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Certificate of Analysis
Report Date: February 18, 2014
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Change room Vault
335208003
Misc Liquid
03-OCT-13 09:55
09-OCT-13
Client
Project:
Client ID:
DNM100108
DNMI001
^rameter Qualifier Result Uncertainty MDC RL
Lad Alpha Spec Analysis
jjphaspec Th, Liquid "As Received"
borium-230 1.30E-06 +M.5IB-08 1.84E-08 1.00E-06
Uphaspec U, Liquid "As Received"
iranium-23 5/236 II 6.78E-08 +/-9.85E-09 8.40E-09 3.00E-06
'ranium-238 U 1.40E-06 +/-3.95E-08 7.33E-09 3.00E-06
Lad Gas Flow Proportional Counting
iFPC, Pb210, Liquid "As Received"
ead-210 1.09E-06 +/-5.46E-08 6.19E-08 1.00E-07
Lad Radium-226
-ucas Cell, Ra226, liquid "As Received"
adium-226 U 5.60E-07 +/-I.19E-07 2.60E-07 6.00E-07
The following Analytical Methods were performed:
vlethod Description
DOE EML HASL-300, Th-0I-RC Modified
DOE EML HASL-300, U-02-R.C Modified
DOE RP280 Modified
EPA 903.1 Modified
urrogate/Tracer Recovery Test
horium-229 Tracer Alphaspec Th, Liquid "As E^cceived"
lranium-232 Tracer Alphaspec U, Liquid "As Received"
ead Carrier GFPC, Pb210, Liquid "As Received"
Units
uCi/mL
uCi/mL
uCi/mL
uCi/raL
uCi/mL
DF Analyst Date Time Batch Method
JXH2 10/25/13 1102 1338432
DCH2 10/24/13 1014 1338429
KDF1 11/06/13 0935 1338156
KSDi 10/28/13 1400 1338764
A paly s t Comments
Result Nominal Recovery% Acceptable Limits
95.9
103
99.8
(15%-125%)
(15%-125%)
(25%-125%)
•Jotes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
JRL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
he greater of either the adjusted MDL or the CRDL.
# GEL LABORATORIES l#
2040 Savage Road Charleston SC 29407 - [phone] - www.gel.com
Company :
Address :
Contact:
Project:
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Certificate of Analysis Report Date: February 18, 2014
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Scale house Vault
335208004
Misc Liquid
03-OCT-13 10:15
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
L131-08
7.67E-09
8.68E-09
'arameter Qualifier Result Uncertainty MDC
Lad Alpha Spec Analysis
dphaspec Th. Liquid "As Received"
horium-230 U 1.17E-08 +/-5.00E-09
Uphaspec U, Liquid "As Received"
Iranium-235/236 U 7.20E-10 +/-2.04E-09
franium-238 U 1.48E-09 +/-2.37E-09
Lad Gas Flow Proportional Counting
}FPC, Pb210, Liquid "As Received"
,ead-210 U 3.I0E-08 +/-2.01E-08 6.68E-08
Lad Radium-226
Aicas Cell, Ra226, liquid "As Received"
;adium-226 U 3.26E-07 +/-1.10E-07
The following Analytical Methods were performed:
vlethod Description
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903.1 Modified
Surrogate/Tracer Recovery Test
"horium-229 Tracer Alphaspec Th, Liquid "As Received"
Jranium-232 Tracer Alphaspec U, Liquid "As Received"
,ead Carrier GFPC, Pb210, Liquid "As Received"
RL
1.00E-06
3.00E-06
3.00E-06
1.00E-07
3.09E-07 6.00E-07
Units
uCi/mL
uCi/mL
uCi/mL
uCi/ml,
uCi/mL
DF Analyst Date Time Batch Method
JXH2 10/25/13 1102 1338432 |
JXH2 10/24/13 1014 1338429 2
KDFI 11/06/13 0936 1338156 3
KSD1 10/28/13 1400 1338764 4
Analvst Comments
Result Nominal Recovery%
^91.2
97.7
102
Acceptable Limits
(15%-125%)
(15%-125%)
(25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
5RL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
he greater of either the adjusted MDL or the CRDL.
GEL LABORATORIES LL1
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
Contact:
Workorder:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado
Ms. Kathy Wei tie!
QC Summary
335208
Parmname
*ad Alpha Spec
Batch 1338429
QC 1202966026 335208001 DUP
Uranium-235/236
Uraniurri-238
QC 12 02966027
Uranium-235/236
Uranium-238
QC 1202966025
Uranium-235/236
Uranium-238
LCS
MB
3atch 1338432
QC 1202966029 335208001 DUP
rhorium-230
QC 1202966030 LCS
Thorium-230
QC 1202966028
Thorium-230
MB
*ad Gas Flow
3atch 1338156
QC 1202965399 335208001 DUP
Lead-210
QC 1202965400 LCS
Lead-210
QC 1202965398
Lead-210
MB
lad Ra-226
3atch 1338764
QC1202966807 335208001 DUP
Radium-226
QC 1202966809 LCS
NOM Sample Qual QC Units
U -3.98E-10 U
Uncertainty +/-1.75E-09
U 1.72E-09 U
Uncertainty +/-2.41E-09
Uncertainty
5.41E-07
Uncertainty
Uncertainty
Uncertainty
U
U
u
U
U -7.01 E-10 U
Uncertainty +/-3.16E-09
4.28E-07
Uncertainty
Uncertainty
U
U
2.37E-09
+/-2.77E-09
4.43E-09
+/-2.86E-09
1.36E-08
+/-4.93E-09
6.27E-07
+/-2.81E-08
8.98E-10
+/-2.96E-09
6.54E-09
+/-3.50E-09
3.74E-09
+/-3.39E-09
4.58E-07
+/-2.73E-08
1.92E-09
+/-3.61E-09
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
U 8.83E-08 U 3.95E-08
Uncertainty +/-2.94E-08 +/-1.67E-08
0.000297
Uncertainty
Uncertainty
0.000268
+/-6.72E-07
U 5.11E-09
+/-9.09E-09
uCi/mL
uCi/mL
uCi/mL
U 2.44E-07 U 2.12E-07
Uncertainty +/-9.55E-08 +/-9.34E-08
uCi/mL
Reoort Date: February 18, 2014
Page 1 ol
RPD%
N/A
N/A
REC% Range Antst Date Tim«
N/A JXH2 10/24/13 10:
N/A
10/24/13 10:
116 (75%-125%)
10/24/13 10:
N/A N/A JXH2 10/25/13 11:1
107 (75%-125%) 10/25/13 11:(
10/25/13 11:(
N/A N/A KDF1 11/06/13 09:.
90.3 (75%-125%) 11/06/13 09::
1/06/13 09::
N/A N/A KSD1 10/28/13 21:
w GEL LABORATORIES LLu
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
vV'orkorder: 335208
'armname
tad Ra-226
latch
Radium-226
N'OM
QC Summary
Sample Qual QC Units RPD% REC% Range AnLst
1338764
QC1202966806
ladium-226
MB
QC1202966808 335208001 MS
ladium-226
1.76E-06
Uncertainty
Uncertainty
1.23E-05 U 2.44E-07
Uncertainty +/-9.55E-08
U
1.60E-06
+/-6.01E-08
2.18E-08
+/-1.21E-08
1.13E-05
+/-4.35E-07
uCi/mL
uCi/mL
uCi/mL
90.5 (75%-125%)
91.9 (75%-125%)
Page 2 of
Date Time
10/28/13 14:2
KSD1 10/28/13 14:(
10/28/13 14:2
Notes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
< Result is less than value reported
> Result is greater than value reported
A The TIC is a suspected aldoi-condensation product
B For General Chemistry and Organic analysis the target analyte was detected in the associated blank.
BD Results are either below the MDC or tracer recovery is low
C Analyte has been confirmed by GC/MS analysis
Results are reported from a diluted aliquot of the sample
Estimated Value
Analytical holding time was exceeded
Analyte present. Reported value may be biased high. Actual value is expected to be lower.
Analyte present. Reported value may be biased low. Actual value is expected to be higher.
M if above MDC and less than LED
Matrix Related Failure
N/A RPD or %Recovery limits do not apply.
Nl See case narrative
ND Analyte concentration is not detected above the detection limit
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
One or more quality control criteria have not been met. Refer to the applicable narrative or DER.
Sample results are rejected
Analyte was analyzed for, but not detected above the CRDL.
Gamma Spectroscopy-Uncertain identification
Gamma Spectroscopy-Uncertain identification
Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
QC Samples were not spiked with this compound
D
F
H
K
L
M
M
NJ
Q
R
U
UT
UJ
UL
X
Y
w GEL LABORATORIES LLu
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 335208 Page 3 of
Date Time "armname NOM Sample Qual QC Units RPD% REC% Range Anlst
A RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry,
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike cone, by a factor of 4 or more.
A The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than
five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of+/- the
RL is used to evaluate the DUP result.
* Indicates that a Quality Control parameter was not within specifications.
For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.
Where the analytical method has been performed under NELAP certification, the analysis has met ail of the
requirements of the NELAC standard unless qualified on the QC Summary.
Energy Fuels Resources (USA), Inc.
Sewage Sample Analysis
SDG: 335208
#
This data package was revised lo report sample "used oil storage" under a separate SDG.
Receipt Narrative
for
Energy Fuels Resources (USA), Inc.
SDG: 335208
February 18,2014
Laboratory Identification:
GEL Laboratories LLC
2040 Savage Road
Charleston, South Carolina 29407
[phone]
Summary:
Sample receipt: The samples arrived at GEL Laboratories LLC, Charleston, South Carolina on October 09,
2013 for analysis. The samples were delivered with proper chain of custody documentation and signatures. All
sample containers arrived without any visible signs of tampering or breakage. There are no additional comments
concerning sample receipt.
Sample Identification: The laboratory received the following samples:
Case Narrative:
Sample analyses were conducted using methodology as outlined in GEL's Standard Operating Procedures. Any
technical or administrative problems during analysis, data review, and reduction are contained in the analytical
case narratives in the enclosed data package.
The enclosed data package contains the following sections: Case Narrative, Chain of Custody, Cooler Receipt
Checklist, Data Package Qualifier Definitions and data from the following fractions: Radiochemistry.
Laboratory ID Client ID
Admin Vault
CCR Vault
335208001
335208002
335208003
335208004
Change room Vault
Scale house Vault
Heather Shaffer
Project Manager
?3»<."
Ff0ject#:
GEL Quote #:
COC Number
PO Number:
of
(i).
GEL Chain of Custody and Analytical Request
GEL Work Order Number:
GEL Laboratories, LLC
2040 Savage Road
Charleston, SC 29407
Phone: [phone]
Fax: [phone]
Client Name: gj^y^ |w<U Phone Sample Analysis Requested (5) (Fill in the number of containers for each test)
Project/Site Name: l^p^U ^ g\£ V' g^U
Address: (fc gU^V^v, vJT jjj&jj 1
Should this
sample be
considered;
Collected by: [\26L i^^OOZA Send Results To: \\>cWv^
Sample ID
' For composites - indicate start and stop date/time
•Dale Collected
(mm-dd-yy)
•Tims
Collected
(Military)
(hhmm)
QC Code Field
Filtered 1
Sample
Matrix il
4.
IL
N5
<-- Preservative Type (6)
Comments
Note: extra sample is
required for sample
specific QC
$7 w 2-
-1-1$ 04H^> X- i/l! i ^ 11 HI1 V
u
J
TAT Requested: Normal: PC Rush: Specify. (Subject to Surcharge) Fax Results: Yes No Circle Deliverable: C of A / QC Summary / Level 1 / Level 2 / fLevel 3; / Level 4
Eastern Pacific
Central Other
Remarks: Are there any known hazards applicable to these samples? If so, please list the hazards
Sic rl^^ - Sc^pUs ixre. ^rc— Stw^r l/twl+S,
Chain of Custody Signatures Sample Shipping and Delivery Details
Rchnau*s$hc4 3v*i> gncd
/I //A
Date Time
1 IDO
Received by (signed) Date Time
16^-1% fr\()S
GEL PM:
Method of Shipment: (Date Shipped:
T, Airbill H;
Airbill
!.) Chain of Custody Number = Client Determined
2. ) QC Codes: N - Normal Sample.TB = Trip Blank. FD = Field Duplicate. EB - Equipment Blank, MS « Matrix Spike Sample. MSD*= Matrix Spike Duplicate Sample. G - Grab, C » Composite
3. ) Field Filtered: For liquid matrices, indicate with a - V - tor yes the sample was field filtered or - N - for sample was not field filtered.
4. ) Matrix Codes: DW=Drinking Water, GW=Groundwater. SW=Surface Water, WW»Waste Water, W=Water. SO-Soil. SD=Sedimcm. SL=Sludge, SS^Solid Waste. 0*09. F=Filter, P=Wipe. INUrine. F*Fecal, N=Nasal
5. ) Sample Analysis Requested: Analytical method requested (i.e. 8260B. 6010B/7470A) and number of containers provided for each (i.e. 8260B - 3, 6QIOB/7470A -1).
6. ) Preservative Type: HA • Hydrochloric Acid. Nl *= Nitric Acid. SH = Sodium Hydroxide, SA • Sulfuric Acid, AA = Ascorbic Acid, HX • Hexane, ST - Sodium Thiosulfatc. If no preservative is added - leave field blank
muiTp _ 1 A nrxn A TriDv vci I niv — ril v PTMW = iTl I IT NT
For Lab Receiving Use Only
Custody Seal Jniact?
YES NO
Cooler Temp:
C
Laboratories LLC SAMPLE RECEIPT & REVIEW
Client: lt: C • SDG/AR/COC/Work Order: ^flZfirf
Received By: P Date Received:
Suspected Hazard Information *If Net Counts > lOOcpm on samples not marked "radioactive", contact the Radiation Safety Group for further
investigation.
COC/Samples marked as radioactive? Maxitnum Net Counts Observed* (Observed Counts - Area M.icKitK.uiui t oi»mO ^ _ / | \ ,
If yes, Were swipes taken of sample containers < action levels? Classified Radioactive II or III by RSO?
COC/Samples marked containing PCBs?
Package, COC, and/or Samples marked as
beryllium or asbestos containing? A If yes, samples are to be segregeated as Safety Controlled Samples, and opened by the GEL Safety Group,
Shipped as a DOT Hazardous? Hazard Class Shipped: UN#:
.Samples identified as Foreign Soil?
Sample Receipt Criteria 55 Comments/Qualifiers (Required for Non-Conforming Items)
Shipping containers received intact
and sealed?
Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
Preservation Method: Ice bags Blue ice Dry ice / None ) Other (describe)
*all temperatures are recorded in Celsius"'' Samples requiring cold preservation
within (0 < 6 deg. C)?* /
Daily check performed and passed on
IR temperature gun?
Temperature Device Serial ti: j ^OMtvO^fvLP \
Secondary Temperature Device Serial # (ifApplicable}:
Chain of custody documents included
with shipment?
Sample containers intact and sealed?
Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
Samples requiring chemical
preservation at proper pH?
Sample ID'S, containers affected and observed pH:
If i'resgrvaiian adtl&jLLfll£L
VOA vials free of headspace (defined
as < 6mm bubble)?
Sample ID's and containers affected:
Are Encore containers present?
Samples received within holding
time?
Sample ID's on COC match ID's on
bottles?
0f yes, immediately deliver to Volalilcs lafeoratojy)
ID's and tests affected:
Sample. iD's am! containers affected:
10 Date & time on COC match date &
time on bottles?
Sample ID's affected:
11 Number of containers received match
number indicated on COC?
Sample ID'S affected:
A
12 Are sample containers identifiable as
GEL provided?
13 COC form is properly signed in
relinquished/received sections?
Car ic Applicable:
FedEx Air FedEx Ground UPS I Field Services Courier Other
14 Carrier and tracking number.
Comments (Use Continuation Form if needed):
PM (or PMA) review: Initials Date IP l ' J j _. Page of.
GEL Laboratories LLC - Login Review Report
GEL Work Order/SDG: 335208
Client SDG:
Project Manager:
Project Name:
Purchase Order:
Package Level:
EDD Format:
335208
Heather Shaffer
DNMI00108 Sewage Sample Analysis
DW16138
LEVEL3
EIM DNM1
Work Order Due Date: 07-NOV-13
Package Due Date:
EDD Due Date:
Due Date:
HXS1
04-NOV-13
07-NOV-13
07-NOV-13
Report Date:18-FEB-14
Work Order: 335208
Page 1 of 4
Collector: C
Prelogin#: 20131009001
Project Workdef ID: 1330620
SDG Status: Closed
Logged by:
GEL ID Client Sample ID Client Sample Desc.
Collect
Date & Time
Receive Time # of
Date & Time Zone Cont.
Lab
Matrix
Fax Days to
Due Date Process
Prelog Lab Field
CofC# Group QC
335208001 Admin Vault
335208002 CCR Vault
335208003 Change room Vault
335208004 Scale house Vault
335208005 used oil storage
03-OCT-13 09:25 09-OCT-13 09:05 -2 2
03-OCT-13 09:45 09-OCT-13 09:05 -2 2
03-OCT-13 09:55 09-OCT-13 09:05 -2 2
03-OCT-13 10:15 09-OCT-13 09:05 -2 2
03-OCT-1310:25 09-OCT-13 09:05 -2 1
MISC LIQUID
MISC LIQUID
MISC LIQUID
MISC LIQUID
MISC LIQUID
21
21
21
21
21
Client Sample ID Status Tests/Methods
Product
Reference Fax Date PM Comments Aux Data
Receive
Codes
-001 Admin Vault
-002 CCR Vault
-003 Change room Vault
-004 Scale house Vault
-005 used oil storage
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Waste Oil
REVW Alphaspec U, Liquid Waste Oil
REVW GFPC, Pb210, Liquid Waste Oil
REVW Lucas Cell, Ra226, liquid Waste Oil
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
Cooler Seal Undisturbed
Temperature (C)
Cooler Seal Undisturbed
Temperature (C)
Cooler Seal Undisturbed
Temperature (C)
Cooler Seal Undisturbed
Temperature (C)
Cooler Seal Undisturbed
Temperature (C)
y
18
y
18
y
18
y
18
y
18
GEL Laboratories LLC - Login Review Report
Product: ASP_THL WorkdefID: 1331646 In Product Group? No
Method: DOE EML HASL-300, Th-01 -RC Modified
Product Description: Alphaspec Th, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Group Name:
Client RDL or
PQL & Unit
Group Reference:
Report Date:18-FEB-14
Work Order: 335208
Page 2 of 4
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
14269-63-7 Thorium-230 .0000001 uCi/mL REG No
Product: ASP UUL WorkdefID: 1331647 In Product Group? No Group Name:
Method: DOE EML HASL-300, U-02-RC Modified
Product Description: Alphaspec U, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Client RDL or
PQL & Unit
Group Reference:
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
15117-96-1/13982- Uranium-235/236
7440-61-1 Uranium-238
.0000003
.0000003
uCi/mL
uCi/mL
REG
REG
No
Product: GFC PBL WorkdefID: 1331648
Method: DOE RP280 Modified
Product Description: GFPC, Pb210, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS # Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Reporting
Units
Group Reference:
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? in QC? List?
14255-04-0 Lead-210 .00000001 uCi/mL REG No
Product: LUC26RAL
Method:
Product Description:
Samples:
Parmname Check:
CAS#
WorkdefID: 1331649
EPA 903.1 Modified
Lucas Cell, Ra226, liquid
005
All parmnames scheduled properly
Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Group Reference:
Reporting
Units
Parm
Function
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Included Included Custom
in Sample? in QC? List?
13982-63-3 Radium-226 .00000006 uCi/mL REG Y Y No
GEL Laboratories LLC - Login Review Report
Product: ASP___THL WorkdefID: 1331642 In Product Group? No
Method: DOE EML HASL-300, Th-01 -RC Modified
Product Description: Alphaspec Th, Liquid
Samples: 001, 002, 003, 004
Parmname Check: All parmnames scheduled property
CAS# Parmname
Group Name:
Client RDL or
PQL & Unit
Group Reference:
Report Date:18-FEB-14
Work Order: 335208
Page 3 of 4
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
14269-63-7 Thorium-230 .000001 uCi/mL REG Yes
Product: ASP_UUL WorkdefID: 1331643 In Product Group? No
Method: DOE EML HASL-300, U-02-RC Modified
Product Description: Alphaspec U, Liquid
Samples: 001, 002, 003, 004
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Group Name:
Client RDL or
PQL & Unit
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
15117-96-1/13982- Uranium-235/236
7440-61-1 Uranium-238
.000003
.000003
uCi/mL
uCi/mL
REG
REG
Yes
Product: GFC__PBL
Method:
Product Description:
Samples:
Parmname Check:
CAS#
WorkdefID: 1331644
DOE RP280 Modified
GFPC, Pb210, Liquid
001,002, 003, 004
All parmnames scheduled properly
Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
14255-04-0 Lead-210 .0000001 uCi/mL REG Yes
Product: LUC26RAL WorkdefID: 1331645
Method: EPA 903.1 Modified
Product Description: Lucas Cell, Ra226, liquid
Samples: 001,002,003,004
Parmname Check: All parmnames scheduled properly
CAS# Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
13982-63-3 Radium-226 .0000006 uCi/mL REG Y Y Yes
GEL Laboratories LLC - Login Review Report
Action Product Name Description
Report Date:18-FEB-"14
Work Order: 335208
Page 4 of 4
Samples
Contingent
Tests
Login Requirements:
Requirement Include? Comments
Peer Review by:. Work Order (SDG#), P0# Checked?. C of C signed in receiver location?
Radiochemistry Case Narrative
Energy Fuels Resources (DNMI)
SDG 335208
Method/Analvsis Information
Product: Alphaspec U, Liquid
Analytical Method: DOE EML HASL-300, U-02-RC Modified
Analytical Batch Number: 1338429
Sample ID
335208001
335208002
335208003
335208004
1202966025
1202966026
1202966027
Method Blank (MB)
335208001 (Admin Vault) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
Client ID
Admin Vault
CCR Vault
Change room Vault
Scale house Vault
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-011 REV# 24.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a N1ST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
None of the samples in this sample set required reprep or reanalysis.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Manual Integration
No manual integrations were performed on data in this batch.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Method/Analysis Information
Product: Alphaspec Th, Liquid
Analytical Method: DOE EML HASL-300, Th-01-RC Modified
Analytical Batch Number: 1338432
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Sample ID
335208001
335208002
335208003
335208004
1202966028
1202966029
1202966030
Change room Vault
Scale house Vault
Method Blank (MB)
335208001 (Admin Vault) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
Client ID
Admin Vault
CCR Vault
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-038 REV# 16.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
None of the samples in this sample set required rcprep or reanalysis.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Manual Integration
No manual integrations were performed on data in this batch.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required. Method/Analysis Information
Product: GFPC, Pb210, Liquid
Analytical Method: DOE RP280 Modified
Analytical Batch Number: 1338156
Sample ID
335208001
335208002
335208003
335208004
1202965398
1202965399
1202965400
Change room Vault
Scale house Vault
Method Blank (MB)
335208001 (Admin Vault) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
Client ID
Admin Vault
CCR Vault
The samples in this SDG were analyzed on an "as received" basis,
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-018 REV# 13.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples meet the required acceptance limits with the following exceptions: The blank,
1202965398 (MB), did not meet the detection limit due to keeping the blank volume consistent with the other
sample aliquots. All other samples met the detection limits.
Technical Information: Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
Samples were refoiled and recounted due to a suspected blank false positive. The recounts are reported.
Chemical Recoveries
All chemical recoveries meet the required acceptance limits for this sample set.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC,
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Method/Analysis Information
Product: Lucas Cell, Ra226, liquid
Analytical Method: EPA 903.1 Modified
Analytical Batch Number: 1338764
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
Sample ID
335208001
335208002
335208003
335208004
1202966806
1202966807
1202966808
1202966809
Method Blank (MB)
335208001 (Admin Vault) Sample Duplicate (DUP)
335208001 (Admin Vault) Matrix Spike (MS)
Laboratory Control Sample (LCS)
Client ID
Admin Vault
CCR Vault
Change room Vault
Scale house Vault
GL-RAD-A-008 REV# 14.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
Samples 1202966807 (Admin Vault) and 335208001 (Admin Vault) were recounted due to high relative percent
difference/relative error ratio. The recounts are reported. Samples were degassed and recounted due to a
suspected blank false positive and low recovery. Recounts are reported.
Miscellaneous Information;
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Certification Statement
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
Qualifier Definition Report
for
DNMI001 Energy Fuels Resources (USA), Inc.
Client SDG: 335208 GEL Work Order: 335208
The Qualifiers in this report are defined as follows:
* A quality control analy te recovery is outside of specified acceptance criteria
** Analyte is a surrogate compound
U Analyte was analyzed for, but not detected above the CRDL.
Review/Validation
GEL requires all analytical data to be verified by a qualified data reviewer. In addition, all CLP-like deliverables
receive a third level review of the fractional data package.
The following data validator verified the information presented in this data report:
Signature. Name: Theresa Austin
Date: 18 FEB 2014 Title: Group Leader
II DRC-2013-003161
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
September 20, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: Inspection Conducted June 13, 2013; Notice of Violation: Radioactive Materials License
Number UT1900479
Division of Radiation Control ("DRC") Letter Dated August 22, 2013
Dear Mr. Lundberg:
This letter responds to the above-referenced DRC letter of August 22, 2013. Energy Fuels Resources
(USA) Inc. ("EFRI") received a Notice of Violation ("NOV"), on July 8, 2013, which lists two
violations of the Utah Radiation Control Rules, based on an inspection of the White Mesa Mill (the
"Mill") conducted by representatives of the Utah Division of Radiation Control ("DRC") on June 13,
2013. EFRI responded by letter on August 6, 2013, requesting that Violation 2, regarding EFRI
shipping sewage to an off-site treatment facility without radiological characterization be rescinded. As a
result of a telephone conversation with Mr. Phil Goble and Mr. Kevin Carney on August 19, 2013, EFRI
withdrew its contention that Violation 2 should be rescinded. This letter responds to DRC's August 22,
2013 letter which required that EFRI provide a response containing the following items for Violation 2:
1) The corrective actions which have been taken and the results achieved;
2) The corrective steps which have been taken to prevent recurrence; and
3) The date full compliance will be achieved.
Violation 1 was fully addressed in our letter of August 6, 2013. The root cause of Violation 2 was also
addressed in the same letter. The response below summarizes the root cause, and addresses the three
remaining items listed above, for Violation 2.
10 CFR 20 Appendix B, Radionuclide Table lists the Effluent Concentration Limit, Annual Limit of
Intake and Derived Air Concentration for radionuclides. Each radionuclide listed includes three (3)
tables: Table 1, Occupational Values; Table 2, Effluent Concentrations (air and water); and Table 3,
Violation 2
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Letter to Rusty Lundberg
September 20, 2013
Page 2 of 4
Releases to Sewers.
Utah Rule R313-15-1 003, Disposal by Release into Sanitary Sewerage states, in part:
"(1) A licensee or registrant may discharge licensed or registered material into sanitary sewerage if
each of the following conditions is satisfied:
(a) The material is readily soluble, or is readily dispersible biological material, in water;
and
(b) The quantity of licensed or registered radioactive material that the licensee or registrant releases
into the sewer in one month divided by the average monthly volume of water released into the sewer by
the licensee or registrant does not exceed the concentration listed in Table III of Appendix B of 10 CFR
20.1001 to 20.2402,(201 0), which is incorporated by reference"
Utah Rule R313-15-501. Surveys and Monitoring - General states, in part:
"(I) Each licensee or registrant shall make, or cause to be made, surveys that:
(a) Are necessary for the licensee or registrant to comply with Rule R313-15; and
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(H) Concentrations or quantities of radioactive material; and
(Hi) The potential radiological hazards. "
Contrary to the above requirements, the DRC inspector found, based on a records review, that on
March 1, 2013, a contractor had entered the Mill's Restricted Area (RA) to pump out the Office
Building's Sewage Vault. Although the vault's contents are from the rest rooms located outside of the
RA, the vault itself resides inside of the RA. A review of the release form for this event entitled the
'Radiation Survey of Equipment Released for Unrestricted Use' shows that the contents that were
removed from the vault and pumped into the contractor's truck were only surveyed for dose rate. The
release form contains a comment that reads, "Material was wet, did not take an alpha reading. The
inspector agrees that since the material was volumetric in nature, (i.e., liquid, sludge and/or soil-like
material), an alpha scan or swipe sample would not be an appropriate survey method. However, this
type of material would necessitate bulk sampling and analysis to determine its isotopic concentrations.
The truck was released with an external alpha survey and documented on the form entitled 'Daily
Vehicle Scan for Vehicles Leaving the Restricted Area1. Although process knowledge would assume that
the material inside the truck was radiologically releasable, radioanalysis of the material was not
conducted to confirm this prior to it being released from the RAfor unrestricted use.
As a follow up, I asked a member of Energy Fuels' staff to contact the contractor to determine where the
material was taken. Via email from the Energy Fuels' staff member on June 19, 2013, the DRC was
informed that the material was taken, "directly to the sewer lagoons." This would confirm that the
material was released to sanitary sewerage which is defined by 10 CFR 20.1003 as, "a system of public
sewers for carrying off waste water and refuse, but excluding se wage treatment facilities, septic tanks,
Letter to Rusty Lundberg
September 20, 2013
Page 3 of 4
and leachfields owned or operated by the licensee.
The violations of Utah Rule R313-15-501, Utah Rule R313-15-1003 and 10 CFR 20 Appendix B
identified during the June 13, 2013 inspection have been characterized as Severity Level IV. The base
penalty for this Severity Level is $750. Level IV Violations are of more than a minor concern; however,
if left uncorrected, could lead to a more serious concern. In this case, the DRC does not believe that
radioactive material had been released for unrestricted use. However, the Mill made no effort to verify
that the material was suitable for release. If left uncorrected, similar materials that contain significant
radioactive concentrations may unknowingly be released to the general public.
EFRI Response
Root Cause of Noncompliance
A review of the circumstances indicates that the event on March 1, 2013 was the first time in the
history of the Mill that the main office septic leachfield required pumping out by vacuum truck. Since
the off-site shipment is such an untypical activity (that is, has never occurred before), neither the RSO
and radiation staff, nor the Mill management were aware that additional requirements beyond release
surveys were applicable to the shipment.
Corrective Actions Which Have Been Taken and the Results Achieved
As discussed with DRC during our phone call on August 19, 2013, EFRI has agreed to perform
sampling and radiological analysis of the main office sewage vault. Preparations for sampling of the
main office sewage vault are underway. The Mill Environmental Management has reviewed Utah
State Health Department regulations to determine what immunizations are required for workers in
potential contact with human sewage. The designated sample team is scheduled to begin the series of
hepatitis injections beginning the week of September 23, 2013. Sampling is scheduled to begin during
or after the first week in October 2013. As discussed with Kevin Carney of DRC on September 16,
2013, samples will be analyzed for the same radionuclides of concern as monitored and reported in the
Mill's Semi-Annual Effluent Report, specifically:
• Pb-210
• Ra-226
• Th-230
• U-nat
Corrective Steps Which Have Been Taken to Prevent Recurrence
To prevent a recurrence, EFRI has made the following steps:
1. Language has been added to the Mill's Radiation Protection Manual, Section 2.7, requiring that
prior to shipment of any sewage or recyclable fluids off-site from the Mill, samples will be
collected and analyzed for radionuclide content, for the same radionuclides of concern as
monitored and reported in the Mill's Semi-Annual Effluent Report. The revision to Section 2.7
#
Letter to Rusty Lundberg
September 20, 2013
Page 4 of 4
of the RPM is provided in Attachment 1 to this letter.
2. In addition to sampling of the Main office sewage vault, the Mill has scheduled sampling of
the remaining four septic sewage vaults on site. All five septic sewage vaults will be
resampled and analyzed periodically to ensure relatively current radionuclide data is available
for each vault in the event of a future need to evacuate and ship any sewage vault contents.
3. The Mill Manager, Environmental manager, RSO and radiation technicians have been re-
educated regarding the need for radiological characterization (in addition to vehicle surveys) of
materials leaving the Mill's restricted area.
Date Full Compliance Will Be Achieved.
Compliance will be achieved when analytical data is received from the laboratory confirming that the
radionuclides of interest are at or below the limits in 10 CFR 20 Appendix B for the four radionuclides
of concern listed above for the samples from the Main Office sewage vault. EFRI expects that the
data will be available by early to mid-November 2013. A copy of the radiological results will be
available at the Mill for DRC review at that time.
As mentioned in our letter of August 6, 2013, a copy of the NOV has been posted in the
Administration Building, in accordance with R313-18-1 l(l)(d).
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Kevin Carney, Utah DRC
Ronnie Nieves
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
ATTACHMENT 1
#
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Date: 4209/123 Revision: EFR 34
Book: Radiation Safety Manual, Section 2 Page 1 of 17
2.0 RADIATION MONITORING - AREA
2.1 HIGH VOLUME AIRBORNE AREA AIR SAMPLING
Area air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sampler or similar high
volume pump will be used for this purpose. Samples will be analyzed as per standard
gross alpha analysis procedures using a sensitive alpha detector.
2.1.1 Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of 40 1pm or
greater for one hour or longer. A variety of equipment may be used for area air sampling,
however normally the equipment used is an Eberline RAS-1, Scientific Industries Model
H25004, or equivalent. Equipment is calibrated prior to each usage as per Section 3.6 of
this manual.
2.1.2 Frequency/Locations
Area dust monitoring frequency is monthly for the locations shown in Table 2.1.2-1.
Table 2.1.2-1
Airborne Radiation Sample Locations
Code
BA1
BA2
BA6
BA7
BA8
BA9
BA10
BA11
BA12
BA12A
BA12B
BA13
BA13A
BA14
BA15
Location/Description
Ore Scalehouse
Ore Storage
Sample Plant
SAG Mill Area
Leach Tank Area
Washing Circuit CCD Thickness
Solvent Extraction Building/Stripping Section
Solvent Extraction Building/Control Room
Yellowcake Precipitation & West Storage Area
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Drying & Packaging Area
Yellowcake Packaging Enclosure
Packaged Yellowcake Storage Room
Metallurgical Laboratory Sample Preparation Room
White Mesa Mill - Standard Operating Procedures Date: +309/123 Revision: EFR-34
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 2 of 17
Code Location/Description
BA16 Lunch Room Area (New Training Room)
BA17 Change Room
BA18 Administrative Building
BA19 Warehouse
BA20 Maintenance Shop
BA21 Boiler
BA22 Vanadium Panel
BA22A Vanadium Dryer
BA23 Filter Belt/Rotary Dryer
BA24 Tails
BA25 Central Control Room
BA26 Shifter's Office
BA27 Operator's Lunch Room
BA28 Dump Station
BA29 Emergency Generator Station
BA30 Truck Shop
B A31 Women's Locker Room
BA32 Oxidation
BA33A AF South Pad
BA33B AF North Pad
Areas BA-10 and BA-12 are soluble uranium exposure areas. These areas are areas
where the uranium compounds that are produced are soluble in lung fluids and are
comparatively quickly eliminated from the body. All the other areas are insoluble
exposure areas. Insoluble uranium areas are areas where the uranium compounds are not
readily soluble in lung fluids and are retained by the body to a higher degree.
Temperature of drying operations has a significant impact on solubility of uranium
compounds. High drying temperatures produce insoluble uranium compounds. Area
uranium dust monitoring, during production periods, is weekly in the designated
yellowcake production areas. Monitoring increases to weekly in other monitored areas
with the observance of levels exceeding 25% of 10 CFR 20 limits and reverts to monthly
upon a continued observance of levels below 25% of 10 CFR 20 limits as determined by
the RSO. The RSO may also perform any additional samplings at his or her discretion.
The RSO will designate those areas involved in area monitoring during non-production
periods. Non-production period monitoring becomes effective one month following the
cessation of production.
Annually, the licensee shall collect, during mill operations, a set of air samples covering
eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40
liters per minute), in routinely or frequently occupied areas of the mill. These samples
shall be analyzed for gross alpha. In addition, with each change in mill feed material or at
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SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 3 of 17
least annually, the licensee shall analyze the mill feed of production product for U-Nat,
Ra-226 and PB-210 and use the analysis and results to assess the fundamental constituent
composition of air sample particulates.
1. A RAS-1 or similar high volume pump shall be used for area grab sampling. Insure
the pump has been recently calibrated within the past month.
2. The locations selected for area air samples should be representative of exposures to
employees working in the area.
3. For routine sampling, the sampling period should be for a minimum collection
duration of 60 minutes at a flow of 401pm or greater.
4. Insert a clean filter into the filter holder on the sampler. Note start time of pump and
record unusual mill operating conditions if they exist.
A. Stop sample collection and note time. Normally, an automatic timer is
connected to the sampler and a 1 hour sample collection time is used.
6. Remove the filter from the sampler and place in a clean glassine envelope or the
package supplied by the manufacturer for delivery to the Radiation Department.
7. Count the sample by gross alpha counting techniques and enter the result and
sampling information into the record.
2.1.4 Calculations
Perform calculations as specified in Section 4.0.
2.1.5 Records
Logs of all samples taken are filed in the Radiation Safety Officer's files. Data is utilized
to calculate radiation exposures as specified in Section 4.0.
2.1.6 Quality Assurance
Calibration checks on each air sampler are made at least monthly to ensure accurate
airflow volumes are being collected. Usage of tweezers and new filter storage containers
minimizes contamination potential. Field logging of data during sampling and logging of
identifying data on sampled filter containers minimizes sample transposition. Samples
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2.1.3 Sampling Procedures
I White Mesa Mill - Standard Operating Procedures Date: +209/123 Revision: EFR-34
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 4 of 17
may periodically be submitted for chemical analysis and a comparison of these results to
the radiometric measurements will be made.
Review of data by the RSO and by the ALAR A audit committee further assure quality
maintenance.
2.2.1 Definitions
Working Level:
A. The exposure to 1.3E + 05 MEV of alpha energy or the potential alpha energy
in one liter of standard air containing 100 pCi each of RaA (Polonium-218), RaB
(Lead-214), RaC (Bismuth-214), and RaC prime (Polonium-214). (Exposure
level, not a dose rate)
Kusnetz Method: Method of radon progeny measurement and calculation based
upon a 10 liter sample and at least 40 minutes decay time before counting.
2.2.2 Equipment
The equipment utilized consists of the following, or appropriate equivalents:
• Portable personal sampler
• Gelman 25 mm filter holder with end cap, or equivalent
• Gelman Type A/E 25 mm diameter glass fiber filters, or equivalent
• Counter-Sealer - Eberline MS-3 with SPA-1 probe, or equivalent
2.2.3 Frequency/Location
Radon progeny samples are obtained monthly at those locations included for area
particulate uranium monitoring during production periods. Monitoring is increased to
weekly upon observance of levels exceeding 25% of 10 CFR 20 limits. Monitoring is
reduced to monthly upon the continued observance of levels below 25% of 10 CFR 20
limits. During non-production periods, monitoring is done monthly for only those
locations occupied by personnel where exposures may have the potential of exceeding
25% of 10 CFR 20 limits. The RSO shall so designate those areas to be monitored during
non-production periods.
2.2.4 Procedures
The procedures to be utilized are as follows:
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2.2 RADON PROGENY
I White Mesa Mill - Standard Operating Procedures Date: 4309/123 Revision: EFR-34
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 5 of 17
1. Assemble filter trains.
2. Ensure pump batteries are fully charged.
3. Calibrate pump (see Section 3.5).
4. Attached filter trains at sample locations; disconnect end plug.
5. Collect sample in the breathing zone of the employee.
6. Collect sample for five minutes at 4.0 1pm.
7. Log sample site, time started, time stopped, and filter pump number prior to leaving
each site on the field log notebook.
8. Samples are counted between 40 minutes and 90 minutes after collection using
sensitive alpha detector.
9. Check the calibration and function check information to ensure the detector is
calibrated and operating.
10. If the calibration check correlates, proceed with sample analysis.
11. Radon progeny samples are normally counted for three minutes, however any sample
count time may be selected for counting.
12. Run background detector count prior to running sampled filters.
13. After counting, calculate working levels.
Equation: (CPM - Bkg)
(oceff) (20 liters) (Time Factor) = W.L.
Where: CPM - sample count per minute 'i
Bkg - counter-detector background count per minute
a Efficiency - The efficiency of the counting system (See Section
3.2.3.3)
Time Factor - Values determined from Kusnetz method (See
attached Table 2.2.4-1)
W.L. - Working Levels
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SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 6 of 17
TABLE 2.2.4-1
Time Factors
Min. Factor Min. Factor
40 150 71 89
41 148 72 87
42 146 73 85
43 144 74 84
44 142 75 83
45 140 76 82
46 138 77 81
47 136 78 78
48 134 79 76
49 132 80 75
50 130 81 74
51 128 82 73
52 126 83 71
53 124 84 69
54 122 85 68
55 120 86 66
56 118 87 65
57 116 88 63
58 114 89 61
59 112 90 60
60 110
61 108
62 106
63 104
64 102
65 100
66 98
67 96
68 94
69 92
70 90
2.2.5 Exposure Calculations
The personnel exposure calculations are a job-weighted average of those areas and
concentrations that an individual is exposed to. The procedure is:
1. Determine areas and durations (hrs.) each individual worked during the period (month
and quarter).
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SOP PBL-RP-2
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2. Determine monitored concentrations (W.L.) for each area so noted.
3. The multiplication of the hours worked in each area by the area concentration (W.L.)
noted is added to the result for each area involved in the period.
4. The result is the Working Level Hours exposed (WLH) for the period.
5. The working level hours (WLH) divided by 173 (30 CFR 57.5-40 note); or hours per
month gives the working level months (WLM) exposure. (The limit is 4 working
level months exposure per year.)
6. If calculated per quarter, the working level hours summed for the quarter are divided
by 519 (173 X 3) to obtain the working level quarter exposure.
See Section 4.0 for details on how to perform exposure calculations and maintain the
exposure records.
2.2.6 Records
Data records, which are filed in the Radiation Safety files, include:
1. Sample location
2. Date and time of sample
3. Time on and off of sample pump
4. Counts per minute of sample
5. Elapsed time after sampling
6. Background detector count
7. Appropriate Kusnetz time factor
8. Working level
9. Sampler identification
Employee exposure records include:
1. Month monitored
2. Areas and duration worked
3. Employee identification
4. Concentrations (W.L.) observed
5. Calculated WLMs
2.2.7 Quality Assurance
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SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 8 of 17
Calibration checks each month assure proper calibration of the counting equipment.
Documented semi-annual calibrations of the counting equipment using certified alpha
calibration and pulse meter sources ensure proper calibration of the equipment over the
anticipated ranges. The air sampling system has documented calibration prior to each
use, ensuring sampling the appropriate air volumes. Duplicate counts of select data may
be counted to assure instrument precision. Field documentation is maintained for each
sample during monitoring. This methodology provides assurance in data quality.
Review of data by the RSO and the ALARA audit committee further assures quality
maintenance.
2.3 ALPHA SURVEYS
2.3.1 Equipment
Equipment to be utilized in area alpha surveys is shown in Appendix 1. Pre-use function
checks will be performed on all radiation survey equipment as specified in Section
3.1.2.3.2.
2.3.2 Frequency/Locations
Fixed and removable alpha surveys are made at those general locations on the Table
2.3.2-1, "Alpha Area Survey Locations." Surveys are completed weekly during
production periods. During non-production periods, only those areas designated by the
RSO as authorized lunchroom/break areas are monitored. Designated eating areas are
listed in Table 2.3.2-2.
Table 2.3.2-1
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Benches
Maintenance Lunchroom Tables
CCR Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
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Book: Radiation Safety Manual, Section 2 Page 9 of 17
Table 2.3.2-2
White Mesa Mill
Designated Eating Area Locations
Maintenance Supervisor Break Room
Main Lunch/Training Room
Administrative Break/Conference Rooms
Administrative Office Desks
2.3.3 Procedures
2.3.3.1 Respirators
Respirators are monitored utilizing a removable alpha smear that is read using alpha
scaler meter such as a Ludlum Model 2200 or other equivalent radiological instruments.
Readings exceeding 100 dpm/100 cm2 result in re-cleaning or discarding of the respirator.
Respirator cleaning and monitoring is a function of the Radiation Safety staff assigned to
this duty. The meter's performance is checked prior to each use period.
2.3.3.2 Fixed Alpha Surveys
Alpha surveys for fixed alpha contamination are performed using a variety of alpha
detecting instruments, as listed in Appendix 1. Each instrument is checked using a
calibrated alpha source for proper function and operation prior to use, as described in
Section 3.1.2.3.2.
Adjustments to the surface area being measured must be made to convert from the
particular detector's surface area to the commonly used surface area of 100 square
centimeters. Therefore when converting a measurement to the commonly used unit of
dpm/ 100cm2, a multiplying area factor must be applied to the measurement. For the
Ludlum instrument with a 43-1 detector of 75 cm2 surface, multiply the value by 1.33 (i.e.
100cm2 divided by 75cm2).
The procedures are:
1. Turn the meter on and check the meter battery condition.
2. Check alpha detector mylar surface for pinholes, etc. Replace if necessary and repeat
calibration.
3. As specified in Section 3.1.2.3.2, perform a function calibration check using
calibrated alpha source.
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4. If check is acceptable, proceed with monitoring.
5. At each designated site, monitor designated surfaces, table tops, etc., holding within
VA inch of the surface.
6. Record data, location, cpm/cm2 monitored on data sheet.
7. At the conclusion of the survey, transpose results to the file log, correcting to
dpm/100 cm2, using correction for detector's surface area and cpm/dpm conversion
factor.
2.3.3.3 Removable Alpha Surveys
The Ludlum Model 2200 scaler with 43-17 detector, or a variety of other sensitive alpha
detection instruments such as Model 2929 or equivalent, counts wipe samples collected
during removable alpha surveys. Glass fiber filters, sized to fit the detector sample slot,
are utilized as the wipe medium. A template having a 100 square centimeter surface area
maybe used to standardize the surface area wiped.
The procedure is:
1. Perform function check calibration of the sealer/detector. Ensure that this
measurement is within ± 10% of the value obtained from the calibration laboratory.
2. If so proceed with the survey and counting.
3. Obtain clean filters and clean envelopes for filter storage.
4. At a location to be surveyed, remove the filter from the envelope and wipe the surface
covering approximately 100 cm2. This is easily accomplished by making a "S"
shaped smear for approximately 10 inches using normal swipes (approximately 2.5
cm diameter).
5. Record on envelope the date and location of the sample.
6. Upon returning to counting lab, place an unused filter in the counting unit for at least
1 minute and obtain a background count rate.
7. Repeat procedure for each used filter, extracting filter from envelope, immediately
prior to counting, using tweezers and placing in the detector slot with the wiped
surface facing the detector, and count for at least 1 minute.
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8. Convert results from cpm/filter to dpm/filter (100 cm2 wiped) after subtracting the
blank background count.
9. Record on the alpha survey form the following information:
A. Sample location and conditions
B. Sample date
C. Sampler identification
D. Wipe count dpm/100 cm2
10. Discard the filters and envelopes
2.3.4 Action Limits
2.3.4.1 Respirators
Levels greater than 100 dpm/100 cm2 squared require re-cleaning or discarding of a
respirator.
2.3.4.2 Fixed Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action by management.
ALARA criterion ensures that the RSO takes action where necessary to maintain levels as
low as reasonably achievable.
2.3.4.3 2.3.4.3 Removable Alpha Surveys
Levels greater than 1,000 dpm/100 cm2 squared require remedial action and
decontamination. ALARA criteria ensures that the RSO takes action where necessary to
maintain levels as low as reasonably achievable.
2.3.5 Records
Records of fixed and removable alpha surveys are maintained in the Radiation Safety
office files. Records include:
1. Sample location/conditions
2. Sample date
3. Sampler identification
4. Fixed alpha determination - dpm/100 cm2
5. Removable alpha determination - dpm/100 cm2
6. Remedial action taken, where necessary
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I White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 4309/123 Revision: EFR-34
Page 12 of 17
2.3.6 Quality Assurance
Calibration function checks of detector performance and visual observation of detector
surfaces prior to each survey ensures counting reliability and consistency. Usage of clean
containers and tweezers minimizes contamination of wipe samples. Field logs of sample
I.D.'s on sample containers minimizes transposition of samples. Data review by the RSO
and by the Audit Committee further assures quality maintenance.
Beta/Gamma surveying instruments used for beta-gamma surveys are listed in Appendix
1 and the sources used are listed in Appendix 2.
Some instruments read directly in mrem/hour while others read in cpm (with a conversion
to mrem/hour). The model 44-6 detector has a removable beta shield allowing
discrimination between beta and gamma contributions. Each instrument has a
manufactures user's manual which describes the function, use and capability of each
instrument. These manuals must be understood before surveying proceeds. Calibration
of Beta/Gamma and functional checks are performed using calibrated Cs-137 or Sr-Y 90
sources
2.4.2 Frequency/Locations
The sites noted on Table 2.4.2-1 are monitored on a monthly basis by of the Radiation
Safety staff during production periods. During non-production periods, only areas
routinely occupied by personnel are monitored as designated by the RSO.
2.4 BETA-GAMMA SURVEYS
2.4.1 Equipment
Table 2.4.2-1
Beta-gamma Survey Locations
Description of Possible
Identification Number Source of Area of Exposure
Mill Feed Hopper & Transfer Chute
SAG Mill Intake-Feed Chute
Screens-Area Floor Between Screen
Leach Operator's Desk
Leach Tank Vent #3
Leach Tank #3-Wall
CCD Thickeners
Pumphouse Tailings Discharge
Oxidant Makeup Room-Sump Pump
Shift Foreman's Office-Work Desk
Distance from Source in cm
WM-1
WM-2
WM-3
WM-4
WM-5
WM-6
WM-7
WM-8
WM-9
WM-10
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Book: Radiation Safety Manual, Section 2 Page 13 of 17
Description of Possible
Identification Number Source of Area of Exposure Distance from Source in cm
WM-11 SX Operator's Area 1
WM-12 Precipitation Tanks #1 Tank; Wall 1
WM-13 Precipitation Section "Lab Bench" 1
WM-14 Precipitation Vent 1
WM-15 Yellowcake Thickener #1; Wall 1
WM-16 Centrifuge Discharge-Chute Wall 1
WM-17 Yellowcake Thickener #2; Wall 1
WM-18 Yellowcake Packaging Room 1
WM-19 Yellowcake Dryer 1
WM-20 Yellowcake Dust Collector 1
WM-21 SX Uranium Mixer #1 Extractor 1
WM-22 SX Uranium Mixer #1 Stripping 1
WM-23 SX Vanadium Mixer #1 Stripping 1
WM-24 Vanadium Dryer 1
WM-25 Mill Laboratory Fume Hood 1
WM-26 Chemical Laboratory Work Area 1
WM-27 Metallurgical Laboratory Work Area 1
WM-28 Lunchroom Eating Area 1
WM-29 Lunchroom Wash Area 1
WM-30 Maintenance Shop - Work Area 1
WM-31 Maintenance Shop - Rubber Coating 1
WM-32 Tailings Impoundment Discharge 1
WM-33 Tailings Impoundment Dike 1 1
WM-34 Tailings Impoundment Dike 2 1
WM-35 Tailings Impoundment Dike 3 1
WM-36 Scalehouse 1
WM-37 Tailings Impoundment Dike 4 1
2.4.3 Procedures
The monitoring procedures are:
1. Check meter battery condition.
2. Check detector using a check source.
3. If the calibration function check indicates that the instrument is operating within
calibration specifications, proceed with monitoring.
4. Survey each designated location on Table 2.4.2-1 and record in the field log:
A. Site location/condition
B. Date
C. Instrument used
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D. Sampler's initials
E. Meter reading (beta + gamma)
F. Meter reading (gamma)
5. Upon returning to the office, record the mr/hr reading into a permanent file which is
maintained for beta-gamma exposure evaluation.
2.4.4 Action Levels
The ALARA concept is utilized in action levels. Responses include operative cleaning of
the area or isolation of the source. The Radiation Safety Department will ensure levels
ALARA.
2.4.5 Records
Records maintained in the Radiation Safety office files include:
1. Date monitored
2. Site location/condition
3. Instrument used
4. Sampler's initials
5. Beta/Gamma level, mr/hr
6. Remedial action taken, if necessary
2.4.6 Quality Assurance
Quality of data is maintained with routine calibration and individual function checks of
meter performance. Personnel utilizing equipment are trained in its usage. Records of
the operational checks and calibrations are maintained in the files. The RSO routinely
reviews the data and the ALARA audit committee periodically analyzes the performance
of the management of the monitoring and administrative programs.
2.5 EXTERNAL GAMMA MONITORING
External gamma area monitoring is conducted at various locations around the Mill site in
order to provide Radiation Safety Staff with area-specific gamma measurements. The
procedures applicable to such monitoring are set out in Section 4.3 of the Mill's
Environmental Protection Manual.
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2.6 EQUIPMENT RELEASE SURVEYS
2.6.1 Policy
Materials leaving a Restricted Area going to unrestricted areas for usage must meet
requirements of NRC guidance for "Decontamination of Facilities and Equipment Prior
to Release for Unrestricted Use" (dated May 1987).
All material originating within the restricted area will be considered contaminated until
checked by the Radiation Safety Department. All managers who desire to ship or release
material from the facility will inform the RSO of their desires. The RSO has the authority
to deny release of materials exceeding NRC guidance for "Decontamination of Facilities
and Equipment Prior to Release for Unrestricted Use" (dated May, 1987). No equipment
or materials will be released without documented release by the RSO or his designee.
2.6.2 Limits
The release limits for unrestricted use of equipment and materials is contained in the
NRC guidance listed above in Section 2.6.1 and are summarized as follows:
Limits for Alpha emissions for U-Nat and its daughter products are:
Average 5,000 dpm/100 cm2
Maximum 15,000 dpm/100 cm2
Removable 1,000 dpm/100 cm2
Limits for Beta-gamma emissions (measured at a distance of one centimeter) for
Beta/Gamma emitting radioisotopes are:
Average 0.2 mr/hr or 5,000 dpm/100 cm2
Maximum 1.0 mr/hr or 15,000 dpm/100 cm2
2.6.3 Equipment
Radiological survey instruments are listed in Appendix 1.
2.6.4 Procedures
Upon notification that materials are requested for release, the Radiation Safety
Department shall inspect and survey the material. Surveys include fixed and removable
alpha surveys and beta-gamma surveys. An equipment inspection and release form is to
be prepared and signed by the RSO or his designee. Any material released from the mill
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SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 16 of 17
will be accompanied with the appropriate release form. If contamination exceeds levels
found in NRC guidance "Decontamination of Facilities and Equipment Prior to Release
for Unrestricted Use", dated May, 1987, then decontamination must proceed at the
direction of the RSO. If the material cannot be decontaminated, then it will not be
released.
2.6.5 Records
Documented records for each released item are filed in the Radiation Safety Department
The RSO and the ALARA Audit Committee periodically review the policy and
documented release forms to ensure policy and regulatory compliance.
2.7.1 Policy
The Radiation Safety Department, prior to shipment release, will survey product
shipments from the facility. Product shipments include uranium concentrate and solid
vanadium products.
The Radiation Safety Department is to be notified in advance of each shipment. The
shipment will not be released prior to the Radiation Safety Department's authorization.
2.7.2 Equipment
Equipment used for product shipment surveys is the same as equipment used for material
release surveys and is listed in Appendices 1 and 2.
2.7.3 Frequency
All barrels are fixed alpha and gamma scanned prior to shipment. A minimum of 25
percent of the barrels consigned are also wipe tested.
2.7.4 Solid Vanadium Shipments
The procedure to be followed for solid vanadium shipments were detailed in the
Radiation Safety Manual in Section 2.7.4. These procedures have been replaced with
procedures No.: PBL-15 Book 10, "Release and Shipping of Vanadium Blackflake".
files.
2.6.6 Quality Assurance
2.7 PRODUCT SHIPMENT SURVEYS
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Book: Radiation Safety Manual, Section 2 Page 17 of 17
2.7.5 Uranium Concentrate Shipments
The procedures for exclusive use uranium concentrate shipments are:
1. Inspect each product barrel that makes up the consigned shipment for leaks, holes in
the barrels, cleanliness, etc.
2. Barrels requiring repair shall be repaired prior to the radiation survey.
3. Perform a total and removable alpha survey of each barrel, using the procedures and
equipment specified in Section 6.0. The release limits for total and removable alpha
radiation contamination is an average of 5,000 dpm/100 cm and a maximum of
15,000 dpm/100 cm2. Any barrel that exceeds 1,000 dpm/100 cm2 total alpha
radiation contamination requires a removable alpha smear/wipe test to be performed.
Perform a removable alpha survey of each barrel exceeding 1,000 dpm/100 cm total
alpha contamination. The release limit for removable alpha radiation contamination is
1,000 dpm/100 cm". Perform a smear/wipe test and analyze filters for removable alpha on
25% of the barrels at a minimum, and perform a smear/wipe test and analyze the filters
for removable alpha on any barrels that exceed 1,000 dpm/100 cm2 total alpha
contamination.
2.7.6 Records
The attached form serves as a record of shipment and is retained in the Radiation Safety
files.
2.7.7 Quality Assurance
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
2.1.6% Miscellaneous Releases
The Radiation Safety Department will monitor, prior to leaving the Restricted Area, any
material that will shipped off-siter not permit any sewage or recyclable fluids to leave the
Restricted Area unless (a) a characterization sample of the sewage or fluid, which is
analyzed for Ra-226, Pb-210, U-naL and Th-230, is taken or is on file at the Mill; and (b)
based on the results of the sample, the release is in compliance with the requirements of
R313-15-1003 and R313-15-302(2Xb)(i). as applicable. A copy of the results of each
characterization sample will be maintained on file at the Mill.—This includes, but not
limited to, sewage and oil. Along with radiological survey information, these materials
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Book: Radiation Safety Manual, Section 2 Page 18 of 17
will also have laboratory analysis performod for a sot list of radioisotopes as specified by
Corporate Management and a copy of those results maintained on frier
2.7.7 Records
The attached form serves as a record of shipment and is retained in the Radiation Safety
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
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files.
2.7.8 Quality Assurance
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com OF
Wf ENE
c. C! ENERGY FUELS
17
v August 29, 2013
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
"DRC-2013-003058"
Dear Mr. Lundberg:
Re: Energy Fuels Resources (USA) Inc. ("EFRI") Notice of Violation ("NOV") for Inspection
Conducted June 13, 2013, 30 Day Payment Demand
This letter is in response to your letter dated August 22, 2013 which EFRI received on August 28,
2013 relating to the above-referenced matter.
Pursuant to your August 22, 2013 letter enclosed is a check in the amount of $750.00 in payment of
the imposed penalty for Violation number 1 cited in the Notice of Violation and Order dated July 2,
2013.
Your letter of August 22, 2013 also requests a written response to Violation 2 of the NOV dated July
2, 2013. EFRI will submit the requested response under separate cover.
If you have any questions or require anything further, please contact the undersigned.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Licensing and Compliance
CC: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
(—x
f ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC-2013-002917 www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
August 6, 2013
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: Inspection Conducted June 13,2013; Notice of Violation: Radioactive Materials License
Number UT1900479
Dear Mr. Lundberg:
This letter responds to the above-referenced Notice of Violation ("NOV"), received by Energy Fuels
Resources (USA) Inc. ("EFRI") on July 8, 2013, which lists two violations of the Utah Radiation
Control Rules, based on an inspection of the White Mesa Mill (the "Mill") conducted by representatives
of the Utah Division of Radiation Control ("DRC") on June 13, 2013.
The NOV requires EFRI to provide a written response within 30 days after receipt of the Notice,
including:
• The corrective actions which have been taken and the results achieved;
• The corrective steps which have been taken to prevent recurrence; and
• The date full compliance will be achieved.
EFRI is also aware that R313-18-1 l(l)(d) requires that EFRI post a copy of the NOV in a conspicuous
place.
The specific violations listed in the NOV and EFRFs response to each, are discussed below.
Violation 1
The Mill's Security Program, Section 1.4, Reagent and Ore Carriers, states:
"Truck drivers hauling reagent and ore into the restricted area of the facility are to receive documented site
safety and radiation protection training prior to access to the site. Access is limited by controlling and
documenting gate access. Safety and radiation training consists of appropriate training for the activity
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Letter to Rusty Lundberg
August 6, 2013
Page 4 of 7
Utah Rule R313-15-50L Surveys and Monitoring - General states, in part:
"(I) Each licensee or registrant shall make, or cause to be made, surveys that:
(a) Are necessary for the licensee or registrant to comply with Rule R313-15; and
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(H) Concentrations or quantities of radioactive material; and
(Hi) The potential radiological hazards. "
Contrary to the above requirements, the DRC inspector found, based on a records review, that on
March 1, 2013, a contractor had entered the Mill's Restricted Area (RA) to pump out the Office
Building's Sewage Vault. Although the vault's contents are from the rest rooms located outside of the
RA, the vault itself resides inside of the RA. A review of the release form for this event entitled the
'Radiation Survey of Equipment Released for Unrestricted Use' shows that the contents that were
removed from the vault and pumped into the contractor's truck were only surveyed for dose rate. The
release form contains a comment that reads, "Material was wet, did not take an alpha reading. The
inspector agrees that since the material was volumetric in nature, (i.e., liquid, sludge and/or soil-like
material), an alpha scan or swipe sample would not be an appropriate survey method. However, this
type of material would necessitate bulk sampling and analysis to determine its isotopic concentrations.
The truck was released with an external alpha survey and documented on the form entitled 'Daily
Vehicle Scan for Vehicles Leaving the Restricted Area'. Although process knowledge would assume that
the material inside the truck was radiologically releasable, radioanalysis of the material was not
conducted to confirm this prior to it being released from the RAfor unrestricted use.
As a follow up, I asked a member of Energy Fuels' staff to contact the contractor to determine where the
material was taken. Via email from the Energy Fuels' staff member on June 19, 2013, the DRC was
informed that the material was taken, "directly to the sewer lagoons." This would confirm that the
material was released to sanitary sewerage which is defined by 10 CFR 20.1003 as, "a system of public
sewers for carrying off waste water and refuse, but excluding sewage treatment facilities, septic tanks,
and leachfields owned or operated by the licensee.
The violations of Utah Rule R313-15-501, Utah Rule R313-15-1003 and 10 CFR 20 Appendix B
identified during the June 13, 2013 inspection have been characterized as Severity Level IV. The base
penalty for this Severity Level is $750. Level IV Violations are of more than a minor concern; however,
if left uncorrected, could lead to a more serious concern. In this case, the DRC does not believe that
radioactive material had been released for unrestricted use. However, the Mill made no effort to verify
that the material was suitable for release. If left uncorrected, similar materials that contain significant
radioactive concentrations may unknowingly be released to the general public.
EFRI Response
A review of the circumstances indicates that pumping of the main office leachfield was a singular
event in the Mill's history to date. The event observed by DRC on March 1, 2013 was the first and
Letter to Rusty Lundberg
August 6,2013
Page 5 of 7
only time in the 33-year history of the Mill that the main office septic leachfield required pumping out
by vaccuum truck. It is not anticipated that this action will be required for decades, and may
potentially not be required for the remainder of the Mill's life cycle.
Because the Mill operates on-site septic leach systems which have never required either discharge of
sewage to a municipal system, or pumping of the sewage vaults, the monthly quantity of licensed or
registered radioactive material and the average monthly volume of water that the Mill releases into the
public sewer system in one month have been zero for the 399 consecutive months of the Mill's life
prior to March 1, 2013.
Although the Main Office septic system (sewage vault and leachfield) are within the Restricted Area
("RA"), two lavatories associated with the Main Office septic system are in the main office building
outside the RA. The contents of this septic system come from individuals who have either not entered
the RA, or have scanned out to leave the RA.
R313-15-501 states that:
"Each licensee or registrant shall make, or cause to be made, surveys that:
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(ii) Concentrations or quantities of radioactive material; and
(iii) The potential radiological hazards. " [Emphasis added]
EFRI believes that surveys of the sewage material were not necessary to determine the magnitude and
extent of radiation levels for the following reasons.
1. As mentioned above, the contents of this septic system come from individuals who have either
not entered the RA, or have scanned out to leave the RA.
2. The Mill's ongoing bioassay program, which has provided decades of urinalysis data, indicates
that the radionuclide levels in urine samples over the past 33 years have been low enough that
the anticipated level of radionuclides in the main office sewage, which contains sewage both
from individuals who do and do not enter the RA or have access to radiological materials,
would be immeasurably small.
3. The Mill is not licensed for the extraction of thorium from source material. Fecal bioassays for
intestinal uptake and concentration of thorium are not required and not appropriate at the Mill.
4. It was anticipated that the need for sewage removal and offsite disposal from the main office
vault would not occur more than once or twice over in Mill's entire life cycle, if at all.
5. The only wastewater sources supplying the sewage vault are the Main Office building
restrooms. The only access to the sewage vault is a covered manhole, which cannot readily be
opened. No laboratory, process, or floor drains enter the sewage vault, as those types of
wastewaters are piped either to Cell 1 or to be recycled into the Mill circuit. That is, there are
Letter to Rusty Lundberg
August 6,2013
Page 6 of 7
no plausible sources of radiological contamination to the sewage vault other than human waste,
whose radionuclide content is monitored through the bioassay program.
6. The volume of sewage removed during the March 2013 single event was approximately 1,500
gallons or 5,700 liters (the capacity of the single sewage truck).
A worst case, overly-conservative estimate of U-nat activity level in the sewage vault based on historic
urinalysis data is provided in Attachment 1. Comparison of the result to the 10 CFR 20 Appendix B
Table 3 levels for Releases to Sewers demonstrates that the overly conservative estimate of 7.25E-8
uCi/ml of U-nat in the sewage is 40 times lower than the Table 3 limit of 3E-6 uCi/ml of U-nat. Since
U-nat is well below its limit in Table 3, it can be assumed that individual uranium isotopes, would be
below their respective isotopic activity limits. Since uranium is the primary constituent of concern in
the Mill's bioassay program, it can be assumed that other radionuclides are also below their respective
isotopic activity limits. EFRI therefore asserts that surveys or analyses were not "necessary under the
circumstances."
The Mill believes this estimation approach is especially appropriate when considering the potential
health risks associated with, and limited number of qualified individuals and laboratories available for,
the collection, handling, radiological analysis, and disposal of human waste material samples.
Root Cause of Noncompliance
EFRI believes that based on the conservative estimate discussed above, the Mill has not exceeded the
limits in 10 CFR 20 Appendix B. Therefore, EFRI contends that there has been no non-compliance
situation.
Corrective Actions Which Have Been Taken and the Results Achieved
As discussed above, EFRI has provided a conservative estimate of radioactivity of the vault sewage to
demonstrate that that measurement was not "necessary under the circumstances."
Corrective Steps Which Have Been Taken to Prevent Recurrence
As discussed above, EFRI has provided a conservative estimate of radioactivity of the vault sewage to
demonstrate that that measurement was not "necessary under the circumstances."
EFRI does not expect that the sewage vault will be pumped again for the remainder of the Mill's life.
However, the Mill will maintain the attached calculation on file in the event that pumping is required,
to demonstrate that measurement was not "necessary under the circumstances." The Mill will update
the calculations, if circumstances, such as a significant increase in worker population, a significant
increase in bioassay results, or a change in facility piping, indicate a revision is warranted.
Date Full Compliance Will Be Achieved.
As discussed above, EFRI believes that the Mill is in compliance with the requirements cited in this
violation.
Letter to Rusty Lundberg
August 6,2013
Page 7 of 7
A copy of the NOV has been posted in the Administration Building, in accordance with R313-18-
1 l(l)(d). EFRI therefore requests that Violation 2 be rescinded.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Kevin Carney, Utah DRC
Ronnie Nieves
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
Attachment 1
Estimate of Radioactivity of Sewage Vault
Assumptions:
1 to 2 liters per 24 hour day (assume 0.67 L per 8 hours)
150 humans using office bathrooms
365 days/yr
33 yrs
no radiaoctive decay of any isotope (all activity conserved)
1500 gallon vac truck (5700 L)
action limit of 15ug/L Unat in urine
1 sample in 150 per month have detectable Unat in urinalysis (>0).
is 7.5 ug/L (0.0075ug/ml)- halfway between ND and action level
Estimated maximum Unat in sewage if all radionuclides in 33 years were hauled in one truckload
670 ml/person-day x 1 *personx 365 days/yr x 33 yrsx 0.0075 **ug/ml Unat
* One person per 150 who have any detectable uranium in the bioassay
** The majority of persons who have detectable Unat in urinalysis have results near the detection level,
or have retest results near the detection level, indicating the elevated sample was incorrect.
For conservatism, it has been assumed that every detection was halfway to the action level,
instead of near the detection level.
60,526 ug Unat total removed in one 5700 L truck volume
11 ug/L concentration in 5700 L truckload
0.011 ug/ml
Basis: per World Information Service on Energy ("WISE") U data updated 20 Sep. 2012
25,280 Bq in 1 g Unat (total activity U234+U235+U238)
lg = 25,280 Bq x 0.00027 uCi per Bq =
6.83 uCi Unat perg Unat
0.00000683 uCi/ug U nat
Estimated maximum activity concentration of truck contents:
0.011 ug Unat/ml x 6.830E-06 uCi/ug Unat = 7.25E-08 uCi/ml
6/19/13 State of Utah Mail - RE: DRC Inspection SS: Fl
RE: DRC Inspection SSS-01 RFI
To: Kevin Carney <[e-mail]>
Cc: Phillip Goble <[e-mail]>
I spoke with the Country Comfort people and they stated that the material was taken directly to the sewer
lagoons. The material was pumped into the ponds. They are tied up with the Summer Camp until next
week, so a written letter would come after that point. Let me know if there are any questions.
From: Kevin Carney [mailto:[e-mail]]
Sent: Monday, June 17, 2013 4:11 PM
To: David Turk
Cc: Phillip Goble
Subject: DRC Inspection SSS-01 RFI
I'm following up on the issue of the sewer sludge that was released on 3-1-13. I would like to find out where the
waste was taken and what was done with it. Whether it was treated or disposed of in some other manner. It
would be best to have something in writing from the Country Comfort folks.
If you have any questions, feel free to give me a buzz. Thanks.
David Turk <DTurk©energyfuels.com> Wed, Jun 19, 2013 at 8:09 AM
Sir,
David
Dave
| (Kevin J Carney, RRPT
Utah Division of Radiation Control
https://mai I .g cog le.coirrt^
6/19/13 State of Utah Mail - RE: DRC Inspection SSS-^^FI
195 North 1950 West
Salt Lake City, UT 84116
Phone: I HO I) ,KR>-008 I
Fax: [phone]-i097
kcaruey@ utah.tfov
Energy Fuels Resources (USA) hie.
David Turk
t: 435-678-2221 x113 | c: 435-459 9786 | f: 435-678-2224
6425 S. Highway 191 PO Box 809
Blanding, UT, US, 84511
http://www energyfuels.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you are not the
intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or copy
this message if you are not the intended recipient(s).
https ://mai I .g cog le. conVmai l/u/0/?ui=2&i k=4909a65a88&view= pt&search=i nbox&th= 13f5cc292f289d 19
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE
RADMOD-SSS-01 Rev 2
SURVEYS/SOURCES/SECURITY
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT 1900479
Inspector(s): Kevin Carney
Inspection Dates: Start: June 13.2013 End: June 14.2013
Requirements, Procedures, Policies, Standards:
o Radioactive Materials License UT 1900479
o NRC Regulatory Guide 8.30
o NRC Regulatory Guide 8.31
o License Renewal Application Appendices E and I
o Utah Administrative Code R313 -15
o Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use, May 1987
Personnel Contacted: Ron Nieves
Dan Hillsten
Dave Turk
SURVEYS
Release Surveys
License Renewal Application Appendix E Section 2.6.4 states:
Upon notification that materials are requested for release, the Radiation Safety department shall inspect
and survey the material. Surveys include fixed and removable alpha surveys and beta-gamma surveys. An
equipment inspection and release form is to be prepared and signed by the RSO or his designee. Any
material released from the mill will be accompanied with the appropriate release form. If contamination
exceeds levels found in NRC guidance "Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use", dated May, 1987, then decontamination must proceed at the direction of the RSO. If the
material cannot be decontaminated, then it will not be released.
Page 1 of 7
1) Were all observed equipment and/or materials released from the Mill surveyed for fixed and removable
alpha and beta-gamma?
Yes • No |3 N/A •
Comments: All except one, which was sewage from the Admin Bldg. tank located inside the Mill's
Restricted Area. The material was vacuumed into a truck and only an external survey of the truck was
performed. No sample of the material was taken and analyzed.
License Renewal Application Appendix E Section 2.6.2 release limits:
Limits for Alpha emissions for U-Nat and its daughter products are:
Average 5,000 dpm/100cm
Maximum 15,000 dpm/100cm2
Removable 1,000 dpm/100cm
Limits for Beta-gamma emissions (measured at a distance of one centimeter) for
Beta/Gamma emitting radioisotopes are:
Average 0.2 mr/hr or 5,000 dpm/100cm2
Maximum 1.0 mr/hr or 15,000 dpm/100cm2
2) Have all observed equipment and/or materials released from the Mill met the release limits required in
Appendix E Section 2.6.2 (incorporated by reference to NRC Guidance Document, Decontamination of
Facilities and Equipment Prior to Release for Unrestricted Use, May 1987)
Yes g| No • N/A [
Comments: All equipment and material was properly surveyed with the exception of the material
referenced in Item L
3) Was an equipment inspection and release form prepared and signed by the RSO or his designee for all
observed equipment and/or materials released from the Mill?
Yes |3 No • N/A •
Comments:
Page 2 of 7
4) Did an equipment inspection and release form accompany observed materials released from the Mill?
Yes E| No • N/A •
Comments: A log book containing the required documentation for the items inspected is kept in the
Radiation Safety Office. There is no log showing that a copy of the document accompanied the released
item although the RSO informs the inspector that no items are released without a copy of the form. The Mill
needs to document that this requirement is being met.
License Renewal Application Appendix E Section 2.7.3 states: All barrels are fixed alpha and gamma
scanned prior to shipment. A minimum of 25 percent of the barrels consigned are also wipe tested.
License Renewal Application Appendix E Section 2.7.5 (3) states: Perform a fixed alpha survey of each
barrel. The release limits for fixed alpha radiation contamination is an average of 5,000 dpm/100cm2
and a maximum of 15,000 dpm/100cm2. Any barrel that exceeds 1,000 dpm/100cm2 fixed alpha
contamination requires a removable alpha smear/wipe test to be performed.
Perform a removable alpha survey of each barrel exceeding 1,000 dpm/100cm2 fixed alpha contamination.
The release limit for removable alpha radiation contamination is 1,000 dpm/100cm2. Perform a smear/wipe
test and analyze filters for removable alpha on 25% of the barrels at a minimum, and perform a smear/wipe
test and analyze the filters for removable alpha on any barrels that exceed 1,000 dpm/100cm2 total alpha
contamination.
5) For observed uranium concentrate product barrels, have all barrels been surveyed for fixed alpha?
Yes EJ No • N/A •
Comments: Survey results documented in logbook. Log was reviewed from January. 2013.
6) For observed uranium concentrate product barrels, have at least 25% of all barrels been surveyed for
removable alpha?
Yes g] No • N/A •
Comments: Survey results documented in logbook. Log was reviewed from January. 2013.
Page 3 of 7
7) Were any uranium concentrate product barrels found to have > 1,000 dpm/100cm2 total alpha
contamination?
Yes • No 03 N/A •
Comments: Survey results documented in logbook. Log was reviewed from January. 2013.
8) If yes to 7) above, were those barrels surveyed for removable alpha contamination?
Yes • No • N/A g
Comments:
Personnel Exit Monitoring
License Renewal Application Appendix E Section 1.2.3 states, in part:
The monitoring procedure includes the following steps:
1. The alarm rate meter is adjusted within the range of 500 to 750 dpm/100cm2 to ensure a margin of 250
dpm/100cm2 due to the low efficiency of this instrumentation.
2. An individual monitors himself by slowly passing the detector over their hands, clothing and shoes,
including the shoe bottoms, at a distance from the surface of approximately 'A inch. An area that is
suspected of possessing any contamination (i.e. hands, boots, visible spotting/stain on clothing etc.) should
be carefully monitored by placing the detector directly on the surface and note the measurement.
3. Should an alarm be set off indicating the presence of contamination, the individual should:
a. Resurvey themself to verify the contamination.
b. If contamination is present the individual must wash the affected area and again survey themself
to ensure the contamination has been removed.
6. Individual surveys are to be logged and initialed.
9) Did all observed personnel monitor themselves by slowly passing the detector over their hands, clothing
and shoes, including the shoe bottoms, at a distance from the surface of approximately lA inch?
Yes El No • N/A •
Comments: Personnel observed at East Door. Guard Shack and Lab exit points. All observed personnel
properly surveyed.
Page 4 of 7
SOURCES
10) Does the mill possess any non-exempt sealed sources under UT 1900479?
Yes • No ^
Comments: No non-exempt sources have been acquired since the last time this inspection was conducted.
Note: exempt sources are those sealed sources that meet the criteria in R313-15-1401(2) (a) through (e).
11) If yes to 10) above, have the sources been leak tested in accordance with R313-15-1401(l) (a) through
(g)?
Yes • No • N/A g
Comments:
12) If yes to 11) above, was the leak test performed by persons specifically authorized by the Executive
Secretary, an Agreement State, a Licensing State, or the USNRC?
Yes • No • N/A [g
Comments:
13) If yes to 11) above, were any sealed sources found to show evidence of leaking?
Yes • No • N/A g
Comments:
Page 5 of 7
The following inspection items refer to the White Mesa Mill Security Program and are followed by the
referenced section.
SECURITY
14) Were all observed perimeter gates found to be secured or guarded? (Section 1.5)
Yes |3 No • N/A •
Comments:
15) Was the Yellow Cake Storage Area found to be secured or guarded? (Section 1.3)
Yes • No El N/A •
Comments: Both gates to the YC Storage Area were found open. There was ongoing work being
performed inside, but no personnel were present at the time the inspector entered to the area.
16) Was the key for the Yellow Cake Storage Area found to be under Mill Management personnel's
control? (Section 1.3)
Yes [3 No • N/A •
Comments: Key is kept in the RSO office.
17) Was the Yellow Cake Storage Area found to be under video surveillance? (Section 1.3)
Yes El No • N/A •
Comments: Video monitors are located in the Mill Manager's office.
Page 6 of 7
Randomly select driver's names from the gate logs and verify training with RSO.
18) Have all reviewed drivers hauling reagent and/or uranium ore received site safety and radiation
protection training prior to entry into the Restricted Area? (Section 1.4)
Yes • No El N/A •
Comments: Four (4) ore truck drivers had been on site on the day of the inspection (June 13). One driver
(Ethan Hammond) had no training documentation on file at the Mill.
19) Are "Authorized Access Only" signs posted at all observed access gates? (Section 1.5)
Yes §NoQ N/A •
Comments:
20) Are "Caution-Radioactive Material" signs posted on the perimeter restricted area fence at intervals
allowing for direct visibility of signs for all observed access points to the fenceline? (Section 1.5)
Yes El No • N/A [
Comments:
Additional Comments: An NOV for the observations made in Items 2 and 18 of this inspection is
recommended.
Page 7 of 7
INSPECTION REPORT
Inspection Module:
Inspection Location:
RADMOD SSS-01
White Mesa Mill, Blanding Utah
RM License: UT1900479
Inspection Items:
Inspection Date:
Inspectors:
Surveys/Sources/Security
June 13, 2013
Kevin Carney, Utah Division of Radiation Control (DRC)
Personnel Contacted: David Turk, Ron Nieves and Dan Hillsten.
Governing Documents:
• Radioactive Material License UT1900479
• NRC Regulatory Guide 8.30
• License Renewal Application Dated February 28, 2007
• White Mesa Mill Radiation Protection Manual, Section 1
• White Mesa Mill Security Program, Section 1.4
• White Mesa Mill Training Manual, Sections 2 and 3
• Utah Administrative Code R313-15
• 10CFR20
Inspection Summary
The inspection was a verification of compliance with Utah Rules, 10CFR20, NRC Regulatory Guide
8.30 and White Mesa Mill (the Mill) procedures as they pertain to radiological release surveys,
security and sealed sources at the Mill. The inspection consisted of a review of records, site
observations and interviews with the Radiation Protection Staff as well as other personnel on site.
Discrepancies
Several discrepancies were noted during the inspection and are discussed below.
Inspection Items
The inspection was divided into four main sections:
• Surveys
• Security
• Sources
The inspection outlines are noted below according to section:
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Surveys
The inspection consisted of a review of records of equipment and materials released from the Mill's
Radiologically Restricted Area including product drums. One discrepancy was noted during the
survey and is described below.
Security
The inspection examined the Mill's procedural requirements for management of the Yellow Cake
Storage Area as well as Restricted Area perimeter fences and gates. The inspection also examined
ore and reagent truck drivers' access to the Mill. Two separate discrepancies were noted during the
inspection and are described below.
Sources
The inspection examined the Mill's management of sealed sources. The Mill has not acquired any
new non-exempt sources since the last time this inspection was performed. All sources used at the
Mill are exempt quantity sources with the exception of their fixed gauge monitors. These monitors
are administered under the Mill's General License. No discrepancies were noted during the
inspection.
Findings
Several findings were identified during the inspection.
Surveys
During a review of the Mill's release records, it was discovered that on March 1st, 2013, a contractor
(Country Comfort), entered the Restricted Area (RA) to pump out the Office Building's Sewage
Vault. Although the vault's contents are from the rest rooms located outside of the RA, the vault
itself resides inside of the RA. A review of the release form for this event entitled the 'Radiation
Survey of Equipment Released for Unrestricted Use' shows that the contents that were removed from
the vault and pumped into the contractor's truck were only surveyed for dose rate. The release form
contains a comment that reads, "Material was wet, did not take an alpha reading." The inspector
agrees that since the material was volumetric in nature, (i.e., liquid, sludge and/or soil-like material),
an alpha scan or swipe sample would not be an appropriate survey method. However, this type of
material would necessitate sampling and analysis to determine its isotopic concentrations.
The truck was released with an external alpha survey and documented on the form entitled 'Daily
Vehicle Scan for Vehicles Leaving the Restricted Area'. Although process knowledge would assume
that the material inside the truck was radiologically releasable, radioanalysis of the material was not
conducted to confirm this prior to it being released from the RA for unrestricted use.
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As a follow up, I asked Dave Turk of Energy Fuels to contact Country Comfort to determine where
the material was taken. Via email on June 19th, 2013, Mr. Turk informed me that the material was
taken, "directly to the sewer lagoons." This would confirm that the material was released to sanitary
sewerage which is defined by 10CFR20.1003 as, "a system of public sewers for carrying off waste
water and refuse, but excluding sewage treatment facilities, septic tanks, and leach fields owned or
operated by the licensee."
10CFR20 Appendix B, Radionuclide Table lists the Effluent Concentration Limit, Annual Limit
of Intake and Derived Air Concentration for radionuclides. Each radionuclide listed includes
three (3) tables: Table 1, Occupational Values; Table 2, Effluent Concentrations (air and water);
and Table 3, Releases to Sewers.
Utah Rule R313-15-1003, "Disposal by Release into Sanitary Sewerage" states, in part: "(1)A
licensee or registrant may discharge licensed or registered material into sanitary sewerage if
each of the following conditions is satisfied:
(a) The material is readily soluble, or is readily dispersible biological material, in water; and
(b) The quantity of licensed or registered radioactive material that the licensee or registrant
releases into the sewer in one month divided by the average monthly volume of water released
into the sewer by the licensee or registrant does not exceed the concentration listed in Table III
of Appendix B of 10 CFR 20.1001 to 20.2402, (2010), which is incorporated by reference"
Utah Rule R313-15-501. Surveys and Monitoring - General states, in part:
"(1) Each licensee or registrant shall make, or cause to be made, surveys that:
(a) Are necessary for the licensee or registrant to comply with Rule R313-15; and
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(ii) Concentrations or quantities of radioactive material; and
(Hi) The potential radiological hazards."
Security
During the inspection, a tour of the facility was made. At approximately 0830, the inspector observed
that the Yellow Cake Storage Area was unlocked and unattended with both access gates wide open.
Work was ongoing inside the area but no workers were present at the time.
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The White Mesa Mill Security Program (Book #15), Section 1.3, Yellow Cake Product Storage,
states:
"Yellowcake product is stored within a locked fenced enclosure. Access to the enclosure is restricted
by limiting key access only to Mill management personnel. Employees working within the enclosure
require the authorization of such personnel prior to access. These crews will also be monitored
through the use of a closed circuit video surveillance system."
As was discussed at the inspection's Closeout Meeting with the Mill's staff, there is confusion in the
language of the Mill Security Program, Section 1.3. Although the procedure requires a locked
enclosure, restricted key access, access authorization and video monitoring, it does not specifically
state that the enclosure be locked or guarded when not occupied. It is logical to assume that, given
the other specific requirements, the intention would be to have the gates locked or guarded at all
times to restrict unauthorized access to the area. The recommendation to the Mill's staff was to
revise the language in the procedure to clarify the requirement. This will be reiterated in the
inspection letter to Energy Fuels.
Another finding was noted concerning delivery truck driver access. During the inspection, the Scale
House Operator gave the inspector the names of four (4) ore truck drivers who had been on site that
day. The driver's names were then compared to the log book containing the ore and reagent drivers'
appropriate facility training documents. No training documentation existed for one of the ore truck
drivers.
The Mill's Security Program, Section 1.4, Reagent and Ore Carriers, states:
"Truck drivers hauling reagent and ore into the restricted area of the facility are to receive
documented site safety and radiation protection training prior to access to the site. Access is limited
by controlling and documenting gate access. Safety and radiation training consists of appropriate
training for the activity involved."
This same finding was noted in an earlier SSS-01 inspection conducted on December 15-16, 2011.
That finding was cited as a Severity Level IV Notice of Violation with no civil penalty assessed.
Conclusions and Recommendations
Surveys
The release of the sewer material on March 1st, 2013 is in violation of R313-15-501. The Mill failed
to make, or cause to be made, the appropriate surveys for release of the material from the Mill's
Restricted Area.
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The release of the sewer material on March 1st, 2013 is also in violation of R313-15-1003. The
material was released to Sanitary Sewerage without any analytical data showing that it met the
requirements of 10CFR20 Appendix B, Table 3 for Releases to Sewers for any radionuclide of
concern associated with Mill operations.
It is recommended that this violation be cited as a Severity Level IV NOV with a Civil Penalty of
$750.00.
Ore truck drivers inside the Restricted Area of the Mill without proper training is an ongoing issue. It
is recommended that this violation be cited as a Severity Level IV NOV with a Civil Penalty of
$750.00.
In regard to the Yellow Cake Storage Area being unattended, an NOV is not recommended.
Recommendation for Next Inspection
1. Follow up on training for truck drivers.
2. Ensure proper exit monitoring by Mill personnel.
3. Review Security Plan to verify changes to language requiring the YC Storage Area to
Security
be locked or guarded.
Prepared By:
Reviewed By: Phillip Goble
Kevin Carney June 26 , 2013
June 26 . 2013
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%\ rlr fx \\\(Jr
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ZLM,/^I ^ / HIM1^
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Energy Fuels Resources (USA) Inc.
White Mesa Mill
Radiation Survey of Equipment Released for Unrestricted Use
All equipment or material released from the White Mesa Mill to an unrestricted area must be surveyed for release in
accordance with the following procedure.
1. Monitor for Gross alpha contamination with the appropriate survey meter.
2. If calculated assay exceeds 1,000 dpm/lOOcm2, then perform swipe analysis at applicable points.
3. Decontaminate if a removable alpha exceeds 1,000 dpm/100cm2 or fixed alpha exceeds 5,000 dpm/100cm2.
4. Release equipment or material if alpha contamination and Beta-Gamma levels are below the following
limit:
Removable alpha - 1,000 dpm/100cm2
Fixed alpha- 5,000 dpm/100cm2 average
15,000 dpm/100cm2 maximum
Beta-Gamma- 0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1cm maximum
Released from White Mesa Mill to
Date: _S Released by z4
Beta/Gamma mr/hr List of Equipment Removable Alpha otal Alpha dpm/100cm
dpm/100cm
Oi»T
Instrument Function checks
Alpha Meter:
Inst. Model
Th-230 Source SN
dpm cpm
Efficiency Factory
Cal. Date:
Bkg
MDA
SN
eff
Beta-Gamma Meter:
Inst. Model SN i&m
Cs-l37 Source SN
Inst. Response XSr^r\t\t
Cal. Date: l|x$TiV
Removable Alpha
Inst. Model AJ
Th-230 Source SN
dpm cpm
Efficiency Facto
Cal. Date:
SN
eff
Comments:
• * «
*
f.
2
1
1 as
Date: gj~H*
Daily Vehicle Scan for Vehicles Leaving the Restricted Area
7*
License/
Container #
Operator
Total Alpha
dpm/1 OOcnr
Truck/Tires
Rem. Alpha
dpm/100cm2
Beta/Gamma
p7y
mr/hr Done By
mi XT
fr:Mt5 X1M
1SL
3&
aft t^MMgft
^6 -O i
<0.67
Removable alpha • 1000 dpm/100cm2
Fixed alpha - 5000 dpm/100cm2 average
15000 dpm/100cm2 maximum
Beta-Gamma - 0.2 mr/hr @ 1 cm average
1.0 mr/hr @ 1 cm maximum
Alpha Meter
Model #3
SN
Cal. Date \H UL 13.
Cpm: H£gg
T?}-230 @ 33000 dpm
Efficiency:_J
Factor.
Bka: 2o
MDA: olhb
Beta-Gamma
Model #1
SN
Cal Datejf{J^L£L__
Cs-137 #2
Reading IS
Bkg Mfc//J£
Comments:
m i PUnt
in
ii
§
i I < I / V"-.:
fit*. rWNT-3
V Precip
i SB™ Mmi l a'j & V?05 Pracip SO
f8!
Ammonia Tanks p]
W4 1 m TWN-1
Chlorat* Tanks f9) \ A ft
TW4 SMMM VMM f^l 24
si
Uaeh
TW4-1S*
fW4i.20
- -
14]
"-'.'/jr. 'If
TO.
1 I
. -
ft ' i
16 f
TO4 !W4i13
V",
ai
1£
M
•
Leach ftetd (curreniiy sn operation)
Sampliirtg Method to be Determined
Potential Mill Site Source -
Geoprobe Bering
I Other Potential Nitrate ami
• Man
A Spririg/Sssp
Owner POMRBK mm ana
ChlorkJe Sowrce - Geoprobe Boring • *unac8 wa.er
4" Nstnate MortikwiJig VYGSI •Inaccessible Potential Milt Site Source - * CWoroform Monitoring Weft
Ha Geoprobe Boring
is.
SourceW: Aerial - Utah G!S Porta) wttttit*. dated 200«,
Walls - HGC, Ine-, May 2008 report.
Figure 2
Phase 1B Nitrate Source Areas:
Geoprobe Boring
Nitrate Investigation Revised
Phase 1 Work Plan
s iKRMiewatc wr-ei no- t.v
6725/13 10 CFR 20.1003 Definitions.
resulting from activities under the^rensee's control. This includes radioacfS^ from all licensed and unlicensed
sources used by the licensee, but excludes background radiation. It also includes radioactive materials remaining
at the site as a result of routine or accidental releases of radioactive material at the site and previous burials at the
site, even if those burials were made in accordance with the provisions of 10 CFR part 20.
Respiratory protective device means an apparatus, such as a respirator, used to reduce the individual's intake
of airborne radioactive materials.
Restricted area means an area, access to which is limited by the licensee for the purpose of protecting
individuals against undue risks from exposure to radiation and radioactive materials. Restricted area does not
include areas used as residential quarters, but separate rooms in a residential building may be set apart as a
restricted area.
Sanitary sewerage means a system of public sewers for carrying off waste water and refuse, but excluding
sewage treatment facilities, septic tanks, and leach fields owned or operated by the licensee.
Self-contained breathing apparatus (SCBA) means an atmosphere-supplying respirator for which the
breathing air source is designed to be carried by the user.
Shallow-dose equivalent (Hs), which applies to the external exposure of the skin of the whole body or the skin
of an extremity, is taken as the dose equivalent at a tissue depth of0.007 centimeter (7 mg^cm2).
Sievert(SeQ § 20.1004).
Site boundary means that line beyond which the land or property is not owned, leased, or otherwise controlled
by the licensee.
Source material means—
(1) Uranium or thorium or any combination of urariium and thorium in any physical or chemical form; or
(2) Ores that contain, by weight, one-twentieth of 1 percent (0.05 percent), or more, of urariium, thorium, or any
combination of urariium and thorium Source material does not include special nuclear material
Special nuclear material means—
(1) Pfotomrm, urariium-233, uranium enriched in the isotope 233 or in the isotope 235, and any other material
that the Commission, pursuant to the provisions of section 51 of the Act, determines to be special nuclear
material, but does not inckide source material; or
(2) Any material artificially enriched by any of the foregoing but does not include source material.
Stochastic effects means health effects that occur randomly and for which the probability of the effect occurring,
rather than its severity, is assumed to be a linear function of dose without threshold. Hereditary elfects and
cancer incidence are examples of stochastic elfects.
Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplying respirator for which the
source of breathing air is not designed to be carried by the user.
file:///C:/Documents and Setrjngs/rcarney.UTAH/MyDocunnents/References/Federal/Title 10/part020/part020-1003.html 8/10
6/17/13 ^plmin CodeR313-15 Standards for Protection Against^pition. May 1, 2013
R313-15-1003. Disposal by Release into Sanitary Sewerage.
(1) A licensee or registrant may discharge licensed or registered material into sanitary
sewerage if each of the following conditions is satisfied:
(a) The material is readily soluble, or is readily dispersible biological material, in
water; and
(b) The quantity of licensed or registered radioactive material that the licensee or
registrant releases into the sewer in one month divided by the average monthly volume
of water released into the sewer by the licensee or registrant does not exceed the
concentration listed in Table III of Appendix B of 10 CFR 20.1001 to 20.2402, (2010),
which is incorporated by reference; and
(c) If more than one radionuclide is released, the following conditions shall also be
satisfied:
(1) The licensee or registrant shall determine the fraction of the limit in Table III of
Appendix B of 10 CFR 20.1001 to 20.2402, (2010), which is incorporated by reference,
represented by discharges into sanitary sewerage by dividing the actual monthly average
concentration of each radionuclide released by the licensee or registrant into the sewer
by the concentration of that radionuclide listed in Table III of Appendix B of 10 CFR
20.1001 to 20.2402, (2010), which is incorporated by reference; and
(ii) The sum of the fractions for each radionuclide required by Subsection R313-15-
I003(i)(c)(i) does not exceed unity; and
(d) The total quantity of licensed or registered radioactive material that the licensee or
registrant releases into the sanitary sewerage system in a year does not exceed 185 GBq
(five Ci) of hydrogen-3, 37 GBq (one Ci) of carbon-14, and 37 GBq (one Ci) of all other
radioactive materials combined.
(2) Excreta from individuals undergoing medical diagnosis or therapy with radioactive
material are not subject to the limitations contained in Subsection R3i3-i5-i003(i).
www.rules.utah.gov/publicat7ccde/r313/r313-015.htrn#T41 1/1
6/17/13
Uranium- natural
10 CFR Part 20 - Appendix B - Radionuclide Table - Ucaniurn-natural
Uranium-natural
Atomic
No. Radionuclide Class
Table 1
Occupational Values
Col. 1
Oral
Ingestion
ALT
(uCi)
Col. 2 Col. 3
Inhalation
ALI
(uCi)
DAC
(uCi/ml)
Table 2
Effluent
Concentrations
Col. 1
Air
(uCi/ml)
Col. 2
Table 3
Releases to
Sewers
Water
(^Ci/ml)
Monthly
Average
Concentration
(u€i/ml)
92 Uranium-
natural
D, see
230TJ
iE+1
Bone Surf
1E+0
Bone
Surf
5E-10
(2E+1) (2E+0) 3E-12 3E-7 3E-6
W, see
230TJ 8E-1 3E-10 9E-13
Y, see 230
U 5E-2 2E-11 9E-14
file:///C:/Documents and Settings/kcarney.UTAH/My Documents/References/Federal/Title 10/part020/appb/Uranium-natural.html 1/1
6/17/13
Lead-210
10 CFR Part 20- Appendix B - Radionuclide Table-Lead-210
Lead-210
Atomic
No. Radionuclide Class
Table 1
Occupational Values
Col. 1
Oral
Ingestion
ALI
(uCi)
Col. 2 Col. 3
Inhalation
ALI
(uCi)
DAC
(uCi/ml)
Table 2
Effluent
Concentrations
Col. 1
Air
(juCi/ml)
Col. 2
Table 3
Releases to
Sewers
Water
(u€i/ml)
Monthly
Average
Concentration
(uCi/ml)
82 Lead-210 D,all
compounds
6E-1
Bone surf
(1E+0)
2E-1
Bone
surf
(4E-1)
IE-10
6E-13 1E-8 1E-7
file:///C:/Documents and Settings/kcarney.UTAH/My Documents/References/Federal/Title 10/part020/appb/Lead-210.html 1/1
6/17/13
Radium-226
10 CFR Part 20 - Appendix B - Radionuclide Table - Radium-226
Radium-226
Atomic
No. Radionuclide Class
Table 1
Occupational Values
Col. 1
Oral
Ingestion
ALI
(uCi)
Col.
2 Col. 3
Inhalation
ALI
(uCi)
DAC
(uCi/ml)
Table 2
Effluent
Concentrations
Col. 1
Air
(uCi/ml)
Col. 2
Table 3
Releases to
Sewers
Water
(uCi/ml)
Monthly
Average
Concentration
(uCi/ml)
88 Radium-226 W, all
compounds
2E+0
Bone Surf
(5E+0)
6E-1 3E-10 9E-13
6E-8 6E-7
fi I e:///C ./Documents and Settings/kcarney.UTAH/My Documents/References/Federal/Title 10/part020/appb/Radium-226.html 1/1
6/17/13
Thorium-230
10 CFR Part 20 - Appendix B - Radionuclide Table -^jorium-230
Thorium-230
Atomic
No. Radionuclide Class
Table 1
Occupational Values
Col. 1
Oral
Ingestion
ALI
(uCi)
Col. 2 Col. 3
Inhalation
ALI
(uCi)
DAC
(uCi/ml)
Table 2
Effluent
Concentrations
Col. 1
Air
(u€i/ml)
Col. 2
Table 3
Releases to
Sewers
Water
(^Ci/ml)
Monthly
Average
Concentration
(u£i/ml)
90 Thorium-230 W, see
226Th
4E+0
Bone Surf
6E-3
Bone
Surf
3E-12
(9E+0) (2E-2) 2E-14 1E-7 1E-6
Y, see
226Th
2E-2
Bone
Surf
(2E-2)
6E-12
3E-14
file:///C:/Documents and Setting s/kcamey.UTAH/My Documents/References/Federal/Title 10/part020/appb/Thorium-230.html 1/1
GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT
PRIOR TC RELEASE FOR UNRESTRICTED USE
OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE,
OR SPECIAL NUCLEAR MATERIAL
U.S. Nuclear Regulatory Commission
Division of Industrial and
Medical Nuclear Safety
Washington, DC 20555
August 1987
6-s-
The instructions in this guide, in conjunction with Table 1, specify the
radionuclides and radiation exposure rate limits which should be used in
decontamination and survey of surfaces or premises and equipment prior to
abandonment or release for unrestricted use. The limits in Table 1 do not
apply to premises, equipment, or scrap containing induced radioactivity for
which the radiological considerations pertinent to their use may be different.
The release of such facilities or items from regulatory control is considered
on a case-by-case basis.
1. The licensee shall make a reasonable effort to eliminate residual
contamination.
2. Radioactivity on equipment or surfaces shall not be covered by paint,
plating, or other covering material unless contamination levels, es
determined by a survey and documented, are below the limits specified
in Table 1 prior to the application of the covering. A reasonable effort
must be made to minimize the contamination prior to use of any covering.
3. The radioactivity on the interior surfaces of pipes, drain lines, or
ductwork shall be determined by making measurements at all traps, and
other appropriate access points, provided that contamination at these
locations is likely to be representative of contamination on the interior
of the pipes, drain lines, or ductwork. Surfaces of premises, equipment,
or scrap which are likely to be contaminated but are of such size,
construction, or location as to make the surface inaccessible for purposes
of measurement shall be presumed to be contaminated in excess of the limits.
4. Upon request, the Commission may authorize a licensee to relinquish
possession or control of premises, equipment, or scrap having surfaces
contaminated with materials in excess of the limits specified. This may
include, but would not be limited to, special circumstances such as razing
of buildings, transfer of premises to another organization continuing work
with radioactive materials, or conversion of facilities to a long-term
storage or standby status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, radioactive contaminants, and the nature, extent,
and degree of residual surface contamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amounts of materials on surface areas, together with other
considerations such as prospective use of the premises, equipment, or
scrap, are unlikely to result in an unreasonable risk to the health and
safety of the public.
Prior to release of premises for unrestricted use, the licensee shall
make a comprehensive radiation survey which establishes that contamination
is within the limits specified in Table 1. A copy of the survey report
shall be filed with the Division cf Industrial and Medical Nuclear Safety,
U. S. Nuclear Regulatory Commission, Washington, DC 20555, and also the
Administrator of the NRC Regional Office having jurisdiction. The report
should be filed at least 30 days prior to the planned date of abandonment.
The survey report shall:
a. Identify the premises.
b. Show that reasonable effort has been made to eliminate residual
contamination.
c. Describe the scope of the survey and general procedures followed.
d. State the findings of the survey in units specified in the
instruction.
Following review of the report, the NPC will consider visiting the
facilities to confirm the survey.
NUCLIDES3
TABLE 1
ACCEPTABLE SURFACE CONTAMINATION LEVELS
AVERAGE5 c f MAXIMUM5 d f REMOVABLE5 e f
U-nat, U-235, U-238, and
associated decay products
Transuranics. Ra-226, Ra-228,
Th-230, Th-228, Pa-231,
Ac-227, 1-125, 1-129
Th-nat, Th-232. Sr-90,
Ra-223, Ra-224, U-232, 1-126.
1-131, 1-133
Geta-ganma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and
others noted above.
5,000 dpm a/100 cm*
100 dpm/100 cm2
1000 dpm/100 cm<
5000 dpm By/lOO cm1
15,000 dpm a/100 cm2
300 dpm/100 cm'
3000 dpm/100 cm2
15,000 dpm Oy/100 cm2
1 ,000 dpm a/100 cm2
20 dpm/100 cm2
200 dpm/100 cm2
1000 dpm fly/100 cm2
aVJhere surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting
nuclides should apply independently.
5As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the
counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average
should be derived for each such object.
dThe maximum contamination level applies to an area of not more than 100 cm2.
eThe amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with dry filter or soft
absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of
known efficiency. When removable contamination on objects of less surface area 1s determined, the pertinent levels should be reduced
proportionally and the entire surface should be wiped.
*The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed
0.2 mrad/hr at 1 cm and 1.0 mrad/hr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeter of
total absorber.
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
?)l
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
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LAKEWOOD CO 80228
PS Form 3800, June 2002 See Reverse for Instructions
RE: Inspection conducted June 13,
Number UT 1900479
2013; Notice of Violation: Radioactive Material License
Dear Ms. Tischler:
On June 13, 2013, an inspection was conducted at the White Mesa Uranium Mill by a representative
of the Division of Radiation Control (DRC) of the Utah Department of Environmental Quality. Results
of the inspection were discussed with management at the conclusion of the inspection.
The inspection was an examination of the activities conducted at your facility as they relate to
compliance with the Utah Radiation Control Rules and the conditions of your Radioactive Materials
License. The inspection consisted of selective examinations of procedures and representative records,
interviews of personnel, independent measurements, and observations by the inspector.
It was noted that not all of your activities were conducted in compliance with State requirements. A
Notice of Violation and Proposed Imposition of Civil Penalty is enclosed. The particular violations are
described in the enclosed Notice.
Please contact Phil Goble at 80
Sincerely,
SENDER: COMPLETE THIS SECTION
Rusty Lundberg, Director 1. Article Addressed to:
Complete items 1,2, and 3. Also complete
item 4 if Restricted Delivery is desired.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
cc: Ron Nieves, Radiation Safe
RL/KJC:kc
Enclosure
JO ANN TISCHLER nov 7/2/13 kc
COMPLIANCE DIRECTOR
ENERGY FUELS RESOURCES (USA) INC
225 UNION BLVD SUITE 600
LAKEWOOD CO 80228
Mailing Addre.
Telephone (801) 5.
COMPLETE THIS SECTION ON DELIVERY
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811, February 2004
7DD3 EBbO DDD3 £353 "EDUO
Domestic Return Receipt 102595-02-M-1540
J
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UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Colorado 80228
STATUTORY AUTHORITY
This Notice of Violation and Proposed Imposition of Civil Penalty (NOV PICP) is issued by the
Director of the Utah Division of Radiation Control (Director) under the Utah Radiation Control
Act, as amended, Utah Code Ann. Sections 19-3-101 to 19-3-113 (the Act), including Utah Code
Ann. Sections 19-3-103.5, 19-3-108, and 19-3-109. This NOV PICP is also issued in accordance
with the Utah Administrative Procedures Act, Utah Code Ann. Sections 63G-4-101 through
63G-4-601 and Administrative Procedure Rules, Utah Admin. Code R305-7. The Director is
authorized to issue such NOV PICPs in accordance with Section 19-3-108 of the Utah Code.
VIOLATIONS
While conducting a routine inspection on June 13, 2013, an inspector with the Utah Division of
Radiation Control (DRC) identified noncompliance issues at the White Mesa Uranium Mill. A
representative of Energy Fuels accompanied the DRC inspector during the inspection. The DRC
has determined that violations of the Utah Radiation Control Rules have occurred. The Director
of the DRC proposes civil penalties. The proposed penalties are in accordance with R313-14 of
the Utah Radiation Control Rules. The particular violations and the associated proposed civil
penalties are set forth below:
Violation 1
The Mill's Security Program, Section 1.4, Reagent and Ore Carriers, states:
"Truck drivers hauling reagent and ore into the restricted area of the facility are to receive
documented site safety and radiation protection training prior to access to the site. Access is
limited by controlling and documenting gate access. Safety and radiation training consists of
appropriate training for the activity involved. "
Contrary to the above requirement, the DRC inspector found that an ore delivery driver inside of
the Mill's Restricted Area was present without the proper site safety and radiation protection
training. An identical violation was identified during a previous inspection on December 15,
2011 and a Severity Level IV Notice of Violation was issued on January 25, 2012.
The violation of the Mill's Security Program identified during the June 13, 2013 inspection has
been characterized as Severity Level IV. The base penalty for this Severity Level is $750. Level
IV Violations are of more than a minor concern; however, if left uncorrected, could lead to a
more serious concern. In this case, drivers have continued to be allowed access to the Restricted
Area without awareness of the potential radiological and safety hazards. Therefore, a civil
penalty of $750 is proposed.
Page 1 of 5
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Colorado 80228
Violation 2
10 CFR 20 Appendix B, Radionuclide Table lists the Effluent Concentration Limit, Annual
Limit of Intake and Derived Air Concentration for radionuclides. Each radionuclide listed
includes three (3) tables: Table 1, Occupational Values; Table 2, Effluent Concentrations (air and
water); and Table 3, Releases to Sewers.
Utah Rule R313-15-1003, Disposal by Release into Sanitary Sewerage states, in part:
*'(!) A licensee or registrant may discharge licensed or registered material into sanitary
sewerage if each of the following conditions is satisfied:
(a) The material is readily soluble, or is readily dispersible biological material, in water;
and
(b) The quantity of licensed or registered radioactive material that the licensee or
registrant releases into the sewer in one month divided by the average monthly
volume of water released into the sewer by the licensee or registrant does not exceed
the concentration listed in Table III of Appendix B of 10 CFR 20.1001 to 20.2402,
(2010), which is incorporated by reference "
Utah Rule R313-15-501. Surveys and Monitoring - General states, in part:
"(1) Each licensee or registrant shall make, or cause to be made, surveys that:
(a) Are necessary for the licensee or registrant to comply with Rule R313-15; and
(b) Are necessary under the circumstances to evaluate:
(i) The magnitude and the extent of radiation levels; and
(ii) Concentrations or quantities of radioactive material; and
(Hi) The potential radiological hazards. "
Page 2 of 5
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Colorado 80228
Contrary to the above requirements, the DRC inspector found, based on a records review, that on
March 1, 2013, a contractor had entered the Mill's Restricted Area (RA) to pump out the Office
Building's Sewage Vault. Although the vault's contents are from the rest rooms located outside
of the RA, the vault itself resides inside of the RA. A review of the release form for this event
entitled the 'Radiation Survey of Equipment Released for Unrestricted Use' shows that the
contents that were removed from the vault and pumped into the contractor's truck were only
surveyed for dose rate. The release form contains a comment that reads, "Material was wet, did
not take an alpha reading." The inspector agrees that since the material was volumetric in
nature, (i.e., liquid, sludge and/or soil-like material), an alpha scan or swipe sample would not be
an appropriate survey method. However, this type of material would necessitate bulk sampling
and analysis to determine its isotopic concentrations.
The truck was released with an external alpha survey and documented on the form entitled
'Daily Vehicle Scan for Vehicles Leaving the Restricted Area'. Although process knowledge
would assume that the material inside the truck was radiologically releasable, radioanalysis of
the material was not conducted to confirm this prior to it being released from the RA for
unrestricted use.
As a follow up, I asked a member of Energy Fuels' staff to contact the contractor to determine
where the material was taken. Via email from the Energy Fuels' staff member on June 19, 2013,
the DRC was informed that the material was taken, "directly to the sewer lagoons." This would
confirm that the material was released to sanitary sewerage which is defined by 10 CFR 20.1003
as, "a system of public sewers for carrying off waste water and refuse, but excluding sewage
treatment facilities, septic tanks, and leach fields owned or operated by the licensee. "
The violations of Utah Rule R313-15-501, Utah Rule R313-15-1003 and 10 CFR 20 Appendix B
identified during the June 13, 2013 inspection have been characterized as Severity Level IV. The
base penalty for this Severity Level is $750. Level IV Violations are of more than a minor
concern; however, if left uncorrected, could lead to a more serious concern. In this case, the DRC
does not believe that radioactive material had been released for unrestricted use. However, the
Mill made no effort to verify that the material was suitable for release. If left uncorrected, similar
materials that contain significant radioactive concentrations may unknowingly be released to the
general public.
Page 3 of 5
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600 License Number UT1900479
Lakewood, Colorado 80228
A written response is required within 30 days after receipt of this Notice. The following
information is required: (1) The corrective actions which have been taken and the results
achieved; (2) the corrective steps which have been taken to prevent recurrence; and (3) the date
full compliance will be achieved.
Any response or written answer to this Notice of Violation should be addressed to Rusty
Lundberg, Director, Utah Division of Radiation Control, 195 North 1950 West, P.O. Box
144850, Salt Lake City, Utah 84114-4850.
NOTICE
Compliance with the provisions of this NOV-PICP is mandatory. Under UAC R313-14-15, the
Licensee's good faith efforts to comply with the NOV-PICP may impact the monetary penalty
that would apply in a settlement. Providing false information may subject the Licensee to further
civil penalties.
Utah Code Ann. Section 19-3-109 provides that a violation of the Act or related order may be
subject to a civil penalty of up to $5,000 per violation.
Any reply to this NOV-PICP should include, for each violation: (1) the corrective steps which
have been taken and the results achieved; (2) the corrective steps which have been taken to
prevent recurrence; and (3) the date full compliance will be achieved. A response protesting the
NOV-PICP shall include: (1) an admission or denial of the item of non-compliance; (2) a
demonstration of extenuating circumstances; (3) a showing of error in the NOV-PICP; or (4)
other reasons why the penalty should not be imposed.
CIVIL PENALTY
The licensee must pay the civil penalty or Respond to this Notice of Agency Action imposing the
civil penalties by filing a written answer. Utah Code Ann. Section 63G-4-201(2)(a)(vi). If the
licensee chooses to pay the civil penalty, payment shall be made within 30 calendar days of
the date of this NOV-PICP. Utah Administrative Code R313-14-15(2). An extension may be
given when extenuating circumstances are shown to exist. Payment shall be made by check,
payable to the Division of Radiation Control and mailed to the Division at the address below.
If the Licensee chooses not to pay the civil penalties, it must follow the procedures for
contesting the NOV-PICP described below.
Page 4 of 5
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
License Number UT1900479
CONTESTING THIS NOV-PICP
This Notice of Violation (NOV) is effective immediately. You may contest this NOV by
submitting a Request for Agency Action in writing as specified in Utah Administrative Code
R305-7-303. Filing a request for a hearing or a general statement of disagreement is not
sufficient under Utah Code Section 63G-4-201(3)(a) of the Utah Administrative Procedures Act
to preserve your right to challenge this NOV. A Request for Agency Action must include the
information specified in R3 05-7-3 03.
A Request for Agency Action must be received by the Executive Secretary within 30 calendar
days of the date of the NOV or the NOV shall become final. Failure to file a Request for Agency
Action within the period provided waives any right of administrative contest, reconsideration,
review, or judicial appeal. An extension is only available under R305-7-205.
Any response or written answer to this NOV-PICP should be addressed to Rusty Lundberg,
Division Director, Utah Division of Radiation Control, 195 North 1950 West, P.O. Box 144850,
Salt Lake City, Utah 84114-4850.
Upon failure to pay any civil penalty due which has been subsequently determined in accordance
with the applicable provisions of UCA 19-3-109 and R313-14, the matter may be referred to the
Attorney General, and the civil penalty may be collected by civil action pursuant to UCA
19-3-109(5).
Dated at Salt Lake City, Utah
This 2^ day of July, 2013
Utah Division of Radiation Control
Rusty Lundberg, Director
RI7KJC:kc
Page 5 of 5
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
August 22, 2013
CERTIFIED MAIL
RETURN RECEIPT REQUIRED
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
HI ru
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U.S. Postal ServiceTM
CERTIFIED MAILM RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided^
For delivery information visit our website at www.usps
Certified Fee
Return Reciept Fee
(Endorsement Require'
Restricted r>" jt&&P,*
1
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City, Si
PS Form 3500, June 2002 See Reverse for Instructions
RE: Inspection conducted June 13, 2013; Notice of Violation: Radioactive Material License
Number UT1900479
Dear Ms. Tischler:
The Division of Radiation Control (DRC) of the Utah Department of Environmental Quality has
reviewed your August 6, 2013 letter regarding the Notice of Violation (NOV) dated July 2, 2013.
Your response to Violation 1 of the NOV was satisfactory and the DRC is awaiting payment of the
civil penalty associated with this violation.
As was discussed in the phone conversation between yourself, Phil Goble and Kevin Carney of the
DRC, your response to Violation 2 of the NOV was not accepted. Subsequently, you withdrew your
contention that there has been no non-compliance situation. Violation 2 of the NOV dated July 2, 2013
remains applicable and the DRC requests your response with regard to (1) the corrective steps which
have been taken and the results achieved; (2) the corrective steps which have been taken to prevent
recurrence; and (3) the date full compliance will be achieved.
Please contact Phil Goble at 801-536-4250 if you have any questions.
Sincerely,
Rusty Lundberg, Director
cc: Ron Nieves, Radiation Safety Officer
RI7KJC:kc
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www. deq. utah. gov
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