DRC-2013-002932 - 0901a068803afc59

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 "DRC-2013-002932
August 20, 2013
Mr. Bryce Bird
Director, Utah Division of Air Quality
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT84116
Re: White Mesa Uranium Mill,
National Emissions Standards for Radon Emission from Operating Mill Tailings
Transmittal of July 2013 Monthly Radon Flux Monitoring Report for Cell 2
Dear Mr. Bird:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI's") radon-222 flux monitoring report
for July 2013 (the "Monthly Report") pursuant to 40 CFR 61.254(b), for Cell 2 at the White Mesa
Uranium Mill (the "Mill"). Cell 2, which was constructed and placed into operation prior to December
15, 1989 is subject to the requirements in 40 CFR 61.252(a). As discussed in our 2012 Annual Radon
Flux Monitoring Report submitted March 29, 2013, Cell 2 was not in compliance with the emissions
limits in 40 CFR 61.252(a) of 20 pCi/(m2 -sec) for the calendar year 2012. This Monthly Report is
submitted pursuant to 40 CFR 261(b) which requires monthly reporting of monitoring data collected
beginning the month immediately following the submittal of the annual report for the year in non-
Included with the Monthly Report is a Radon Flux Measurement Program Report, dated July 2013,
prepared by Tellco Environmental (the "Tellco July 2013 Monthly Report"). The Tellco July 2013
Monthly Report indicates that for the month of July 2013, the average radon flux from Cell 2 of 24.3
pCi/(m -sec), did not comply with the standard in 40 CFR 61.252(a).
If you have any questions, please feel free to contact me at [phone].
Yours very truly,
compliance.
Energy Fuels Resources (USA) Inc.
Jo Ann Tischler
Manager, Compliance and Licensing
N:\WMM\Required Reports\NESHAPS Reports\2013 Monthly NESHAPs\Cell 2 July 2013 Monthly NESHAPS\transmtl
Cell 2 Radon Flux July 2013.doc
Letter to B. Bird
August 20, 2013
Page 2 of 2
cc: David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Rusty Lundberg, Utah DRC
Jay Morris, Utah DAQ
Harold R. Roberts
David E. Turk
Kathy Weinel
Director, Air and Toxics Technical Enforcement Program, Office of Enforcement, Compliance
and Environmental Justice, U. S. Environmental Protection Agency
Attachments
ENERGY FUELS RESOURCES (USA) INC.
40 CODE OF FEDERAL REGULATIONS 61 SUBPART W
WHITE MESA MILL
SAN JUAN COUNTY, UTAH
TAILINGS CELL 2 MONTHLY COMPLIANCE REPORT FOR JULY 2013
Submitted August 20, 2013
by
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
[phone]
1) Name and Location of the Facility
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Mill (the "Mill"), located in
central San Juan County, Utah, approximately 6 miles (9.5 km) south of the city of Blanding. The Mill
can be reached by private road, approximately 0.5 miles west of Utah State Highway 191. Within San
Juan County, the Mill is located on fee land and mill site claims, covering approximately 5,415 acres,
encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of T37S, R22E, and Sections 4, 5,6, 8,
9, and 16 of T38S, R22E, Salt Lake Base and Meridian.
All operations authorized by the Mill's State of Utah Radioactive Materials License are conducted within
the confines of the existing site boundary. The milling facility currently occupies approximately 50 acres
and the tailings disposal cells encompass another 275 acres.
2) Monthly Report
This Repoit is the monthly report for the Mill's Cell 2 for July 2013, required under 40 Code of Federal
Regulations (CFR) 61.254(b).
A summary of the events that gave rise to the requirement to file this monthly report under 40 CFR
61.254(b) is set out in Section 4 of this Report. A summary of the radon emissions from Cell 2 measured
in July 2013 is set out in Section 5 of this Report.
The monthly monitoring data for July 2013 required under 40 CFR 61.254(b) is provided in Attachment 1
to this Report, which contains the Radon Flux Measurement Program Report, dated July 2013, prepared
by Tellco Environmental (the "Tellco July 2013 Monthly Report"). The results are summarized in
Section 5 of this Report.
3) Name of the Person Responsible for Operation and Preparer of Report
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, Colorado 80228
303.628.7798 (phone)
303.389.4125 (fax)
EFRI is the operator of the Mill and its tailings impoundments (Cells 2, 3, and 4A) and evaporation
impoundments (Cells 1 and 4B). The Mill is an operating conventional uranium mill, processing both
conventional ores and alternate feed materials. The "method of operations" at the Mill is phased disposal
of tailings. Compliance with the NESHAP standards at 40 CFR 61.252(a) is determined annually for
existing impoundments (i.e., Cells 2 and 3). The annual radon emissions for existing impoundments are
measured using Large Area Activated Charcoal Canisters in conformance with 40 CFR, Part 61,
Appendix B, Method 115, Restrictions to Radon Flux Measurements, (Environmental Protection Agency
["EPA"1, 2008). These canisters are passive gas adsorption sampling devices used to determine the flux
rate of Radon-222 gas from the surface of the tailings material. For impoundments licensed for use after
December 15, 1989 (i.e., Cell 4A, and 4B), EFRI employs the work practice standard listed at 40 CFR
61.252(b)(1) in that all tailings impoundments constructed or licensed after that date are lined, are no
more than 40 acres in area, and no more than two impoundments are operated for tailings disposal at any
one time.
EFRI is submitting this monthly compliance report in conformance with the standards in 40 CFR
61.254(b).
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4) Background Information -- Summary of 2012 Annual Report
Facility History
Cells 2 and 3, which are 270,624 m2 (approximately 66 acres) and 288,858 m2 (approximately 71 acres),
respectively, were constructed prior to December 15, 1989 and are considered "existing impoundments"
as defined in 40 CFR 61.251. Radon flux from Cells 2 and 3 is monitored annually, as discussed below.
Cells 4A and 4B were constructed after December 15, 1989, and are subject to the work practice
standards in 40 CFR 61.252(b)(1), which require that the maximum surface area of each cell not exceed
40 acres. For this reason, Cells 4A and 4B are not required to undergo annual radon flux monitoring.
Cell 3, which is nearly filled, and Cell 4A, receives the Mill's tailings sands. Cells 1 and 4B, receive
solutions only, and are in operation as evaporative ponds. Cell 2 is filled with tailings, is covered with an
interim soil cover, and is no longer in operation.
Dewatering of Cell 2
The Utah Division of Water Quality issued Groundwater Discharge Permit ("GWDP') UGW-370004 in
2005. Under Part I.D.3 of the current GWDP, EFRI has been required to accelerate dewatering of the
solutions in the Cell 2 slimes drain. Dewatering of Cell 2 began in 2008. In mid-2011, changes were
made in the pumping procedures for slimes drain dewatering of Cell 2 that resulted in an acceleration of
dewatering since that time. As discussed in more detail below, studies performed by EFRI indicate that
the increase in radon flux from Cell 2 has likely been caused by these dewatering activities. No other
changes appear to have occurred in condition, use, or monitoring of Cell 2 that could have resulted in an
increase in radon flux from the cell.
The average water level in the Cell 2 slimes drain standpipe for each of the years 2008 through 2012
indicate that water levels in Cell 2 have decreased approximately 3.25 feet (5600.56 to 5597.31 fmsl)
since 2008. Of this decrease in water level, approximately 1 foot occurred between 2010 and 2011,
reflecting the improved dewatering that commenced part way through 2011, and approximately 2 feet
between 2011 and 2012, reflecting improved dewatering for all of 2012.
Radon Flux Monitoring of Cell 2
Tellco performed the 2012 radon flux sampling during the second quarter of 2012 in the month of June.
On June 25, 2012, Tellco advised EFRI that the average radon flux for Cell 2 from samples taken in June
2012 was 23.1 pCi/(m2 -sec) (referred to in the Tellco report as pCi/m2"s), which exceeded the Subpart W
requirement. The result of the 2012 radon-222 flux monitoring for Cell 3 was 18 pCi/(m2 -sec). Cell 3,
therefore, was in compliance with this standard for 2012.
40 CFR 61.253 provides that:
"When measurements are to be made over a one year period, EPA shall be provided with
a schedule of the measurement frequency to be used. The schedule may be submitted to
EPA prior to or after the first measurement period."
EFRI advised the Utah Division of Air Quality ("DAQ"), by notices submitted on August 3 and
September 14, 2012, that EFRI planned to collect additional samples from Cell 2 in the third and fourth
quarters of 2012. These samples were collected on September 9, October 21, and November 21, 2012,
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respectively. As the June monitoring for Cell 3 indicated that it was in compliance with the standard,
further monitoring of Cell 3 was not performed.
The result of the 2012 radon-222 flux monitoring for Cell 2 was 25.9 pCi/(m2 -sec) (averaged over four
monitoring events). The measured radon flux from Cell 2 in 2012 therefore exceeded the standard in 40
CFR 61.252(a) of 20 pCi/(m2 -sec).
The Cell 2 and Cell 3 radon flux results were reported in EFRI's 2012 Annual Radon Flux Monitoring
Report (the "2012 Annual Report").
The provisions of 40 CFR 61.254(b) requires that:
"If the facility is not in compliance with the emission limits of paragraph 61.252 in the calendar
year covered by the report, then the facility must commence reporting to the Administrator on a
monthly basis the information listed in paragraph (a) of this section, for the preceding month.
These reports will start the month immediately following the submittal of the annual repoit for
the year in non-compliance and will be due 30 days following the end of each month."
This Report is the required monthly repoit for July 2013 for Cell 2. Monthly monitoring will continue
until US EPA or DAQ determines that it is no longer required.
Evaluation of Potential Factors Affecting Radon Flux
In an attempt to identify the cause of the increase in radon flux at Cell 2, EFRI conducted a number of
evaluations including:
• Excavation of a series of 10 test pits in the Cell 2 sands to collect additional information needed
to ascertain factors affecting radon flow path and flux,
• Evaluation of radon trends relative to slimes drain dewatering,
• Development of correlation factors relating dewatering rates to radon flux, and
• Estimation of the thickness of temporary cover that would be required to achieve compliance with
the radon flux standard of 20 pCi/(m2 -sec), during the dewatering process.
These studies and results are discussed in detail in EFRI's 2012 Annual Radon Flux Repoit and
summarized in the remainder of this section.
Slimes drain dewatering data indicate that a lowering of the water level in Cell 2 has resulted in an
increase in the average radon flux, and that an increase in water level has resulted in a decrease in the
average radon flux. Changes in radon flux have consistently been inversely proportional to changes in
water levels in Cell 2 since 2008. For the last three years the change in radon flux has been between 3
and 5 pCi/(m2-sec) per each foot of change in water level. It is also noteworthy that the significant
increases in radon flux from Cell 2 which occurred between 2010 and 2011 and between 2011 and 2012
coincided with the periods of improved (accelerated) dewatering of Cell 2.
EFRI has evaluated these results and has concluded that the increase in radon-222 flux from Cell 2 that
has resulted in the exceedance of the 20 pCi/(m2 -sec) standard in 40 CFR 61.252 (a) in 2012 is most
likely the unavoidable result of Cell 2 dewatering activities mandated by the Mill's State of Utah GWDP.
This is due to the fact that saturated tailings sands attenuate radon flux more than dry tailings sands, and
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the thickness of saturated tailings sands decrease as dewatering progresses. There appear to have been no
other changes in conditions at Cell 2 that could have caused this increase in radon flux from Cell 2.
These conclusions are supported by evaluations performed by SENES Consultants Limited ("SENES"),
who were retained by EFRI to assess the potential effects of dewatering on the radon flux from Cell 2 and
to provide calculations of the thickness of temporary cover required to achieve the radon flux standard
during the dewatering process.
SENES' evaluations were presented in a report provided as an attachment to EFRI's 2012 Annual Repoit.
SENES estimated a theoretical radon flux from the covered tailings at Cell 2 for various depths
(thicknesses) of dry tailings, and predicted future increases in radon flux as a function of decreases in
water levels.
In order to explore potential interim actions that could be taken to maintain radon flux within the 20
pCi/(m2-sec) standard, the SENES study also evaluated the extent to which radon emanations from the
cell can be reduced by increasing the thickness of the current interim cover on Cell 2.
5) July 2013 Results
Detailed results for July 2013 for Cell 2 are contained in the Tellco July 2013 Monthly Repoit. As
described in the Tellco July 2013 Monthly Repoit, monitoring was performed consistent with 40 CFR 61
Subpart W Appendix B, Method 115 radon emissions reporting requirements. The radon monitoring
consisted of 100 separate monitoring points at which individual radon flux measurements have been made
by collection on carbon canisters. The individual radon flux measurements were averaged to determine
compliance with 40 CFR Part 61.252.
The average radon flux for Cell 2 in July 2013 was reported by Tellco to be 24.3 pCi/(m2 -sec). This
radon flux value exceeds the 20 pCi/(m2 -sec) standard in 40 CFR 61.252.
6) Other Information
Status of Proposed Updated Final Cover Design
As part of developing the Mill's final reclamation plan required to achieve the radon flux standard of 20
pCi/(m2-sec), a final engineered cover design was submitted by TITAN Environmental in 1996 and
approved by the US Nuclear Regulatory Commission ("NRC"). An updated final cover design for the
Mill's tailings system, submitted in November 2011, is under review by the Utah Division of Radiation
Control ("DRC"), and is not currently approved. DRC provided a second round of interrogatories on the
proposed cover design and associated Infiltration and Contaminant Transport Model ("ICTM") in
February 2013, for which EFRI and its consultant, MWH Inc. are preparing responses.
7) Additional Information Required for Monthly Reports
a) Controls or Other Changes in Operation of the Facility
40 CFR 61.254(b)(1) requires that in addition to all the information required for an Annual Report under
40 CFR 61.254(b), monthly reports shall also include a description of all controls or other changes in
operation of the facility that will be or are being installed to bring the facility into compliance.
Based on the evaluations described in Section 4, above, and as discussed during EFRI's March 27, 2013
meeting with DAQ and DRC staff, in addition to the monthly monitoring reported in this Monthly Report,
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EFRI has proposed the following steps to ensure that radon emissions from Cell 2 are kept as low as
reasonably achievable and to bring the facility into compliance with the applicable standard:
Construction and Monitoring of Interim Cover Test Area, and Application of Additional Random
Fill
i. EFRI proposes to construct and monitor a test-scale application to confirm the effect of the
addition of one foot of additional soil cover. EFRI proposes to apply one foot of random fill at
90% compaction to a test area on Cell 2 of 100 feet by 100 feet. This test area would be
established on or before September 2013 subject to DRC confirmation as discussed below. The
radon flux in the test area would be measured both before and after placement of the additional
fill and periodically over a six month period. Design of the test soil cover area is underway.
ii. If the desired reduction (to within compliance levels) is achieved on the test area, EFRI will apply
one foot of additional random fill at 90% compaction, to the remainder of Cell 2, on or before
July 1, 2014. EFRI will perform the 2014 annual radon flux monitoring of Cell 2 after placement
of the fill over the entire Cell 2 area.
The foregoing proposed test and construction activities will be conditional upon DRC confirming that
such activities will not be prejudicial to or inconsistent with the final approved cover design currently
under review, and will be credited toward the final cover design. As of the date of this report, EFRI has
not received DRC's confirmation that the test and construction activities will not be prejudicial to or
inconsistent with the final approved cover design, or will be credited toward the final cover design.
Interim Corrective Action
EFRI has taken the following additional steps to provide interim mitigation of radon flux from Cell 2.
EFRI has identified the areas of elevated radon flux associated with known sources of radiological
contamination at or near the surface of the cell cover. Specifically:
• the location associated with the former tailings discharge line,
• the perimeter area near the north of Cell 2 containing disturbed or windblown material, and
• the location of specific alternate feed tailings disposal with elevated radionuclide content.
EFRI has implemented corrective measures, which began in June 2013 and are in progress at the time of
this monthly report. The corrective measures include the addition of cover material to the known source
areas, and/or the excavation and reburying of any amount of contaminated material that may be detected
at the surface of the source areas.
EFRI has completed an initial step of adding and compacting cover soil in a dry condition on Cell 2
during July 2013. This step has not affected the hot spots sufficiently to reduce the average flux to below
the limit of 20 pCi/(m2 -sec). During August 2013, the additional soil already added to Cell 2 will be
sprayed with water and re-compacted to improve (reduce) the permeability of the added cover. The Mill
will have the completed prior to the upcoming August sampling event, to quantify how much effect this
approach may have on the average flux.
a) Facility's Performance Under Terms of Judicial or Administrative Enforcement Decree
The Mill is not under a judicial or administrative enforcement decree.
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r
8) Certification
I Certify under penalty of law that I have personally examined and am familiar with the information
submitted herein and based on my inquiry of those individuals immediately responsible for obtaining the
information, I believe that the submitted information is true, accurate and complete. I am aware that there
are significant penaltie^ for submitting false information including the possibility of fine and
imprisonment. Spi 18, W.S.C. 1001.
Signed: //// SA ' Date: _
David C. Frypenlpnd
Senior Vice President, General Counsel and Corporate Secretary
ATTACHMENT 1
National Emissions Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
July 2013 Sampling Results
National Emission Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
July 2013 Sampling Results
Cell 2
Prepared for: Energy Fuels Resources (USA) Inc.
6425 S. Highway 191
P.O. Box 809
Blanding, Utah 84511
Prepared by: Tellco Environmental
P.O. Box 3987
Grand Junction, Colorado 81502
TABLE OF CONTENTS
Page
1. INTRODUCTION 1
2. SITE HISTORY AND DESCRIPTION 1
3. REGULATORY REQUIREMENTS FOR THE SITE 2
4. SAMPLING METHODOLOGY 2
5. FIELD OPERATIONS 3
5.1 Equipment Preparation 3
5.2 Sample Locations, Identification, and Placement 3
5.3 Sample Retrieval 3
5.4 Environmental Conditions 4
6. SAMPLE ANALYSIS 4
6.1 Apparatus 4
6.2 Sample Inspection and Documentation 4
6.3 Background and Sample Counting 5
7. QUALITY CONTROL (QC) AND DATA VALIDATION 5
7.1 Sensitivity 5
7.2 Precision 5
7.3 Accuracy 6
7.4 Completeness 6
8. CALCULATIONS 6
9. RESULTS 7
9.1 Mean Radon Flux 7
9.2 Site Results 8
References 9
Figure 1 10
Appendix A. Charcoal Canister Analyses Support Documents
Appendix B. Recount Data Analyses
Appendix C. Radon Flux Sample Laboratory Data, Including Blanks
Appendix D. Sample Locations Map (Figure 2)
1. INTRODUCTION
During July 22-23, 2013 Tellco Environmental, LLC (Tellco) of Grand Junction, Colorado, provided
support to Energy Fuels Resources (USA) Inc. (Energy Fuels) to conduct radon flux measurements
regarding the required National Emission Standards for Hazardous Air Pollutants (NESHAPs) Radon
Flux Measurements. These measurements are required of Energy Fuels to show compliance with
Federal Regulations (further discussed in Section 3 below). The standard is not an average per facility,
but is an average per radon source. The standard allows mill owners or operators the option of either
making a single set of measurements or making measurements over a one year period (e.g., weekly,
monthly, or quarterly intervals).
Energy Fuels is presently on a monthly radon flux sampling plan for Cell 2. This report presents the
radon flux measurements results for Cell 2 for July 2013; the results of each monthly sampling event
are presented in separate reports. Prior to 2012, Energy Fuels had chosen to make a single set of
measurements to represent the radon flux each year; however, as the radon flux levels in Cell 2 began
exceeding the regulatory standard of 20 picoCuries per square meter per second (pCi/m2-s) in 2012,
Energy Fuels decided to make the radon flux measurements on a more frequent basis.
During June and July 2013, Energy Fuels placed additional cover materials at selected sample
locations of Cell 2 in an attempt to reduce the radon flux levels. The additional material was
approximately 18-24 inches thick and approximately 100 feet in diameter, centered around selected
sample location points where previous sampling had identified radon flux greater than 40 pCi/m2-s.
Tellco was contracted to provide radon canisters, equipment, and canister placement personnel as well
as lab analysis of samples. Energy Fuels personnel provided support for loading and unloading
charcoal from the canisters. This report details the procedures employed by Energy Fuels and Tellco
to obtain the results presented in Section 9.0 of this report.
2. SITE DESCRIPTION
The White Mesa Mill facility is located in San Juan County in southeastern Utah, six miles south of
Blanding, Utah. The mill began operations in 1980 for the purpose of extracting uranium and
vanadium from feed stocks. Processing effluents from the operation are deposited in four lined cells,
which vary in depth. Cell 1, Cell 4A, and Cell 4B did not require radon flux sampling, as explained in
Section 3 below.
Cell 2, which has a total area of approximately 270,624 square meters (m2), has been filled and
covered with interim cover. This cell is comprised of one region; a soil cover of varying thickness,
which requires NESHAPs radon flux monitoring. The Cell 2 cover region is the same size in 2013 as
it was in 2012. There are no exposed tailings or standing liquid within Cell 2.
Cell 3, which has a total area of 288,858 m2, is nearly filled with tailings sand and is undergoing pre-
closure activities. This cell is comprised of two source regions that require NESHAPs radon
monitoring: a soil cover region of varying thickness and an exposed tailings "beaches" region. The
l
remaining area is covered by standing liquid in lower elevation areas. The sizes of the regions vary
due to the continuing advancement of interim cover materials and varying water levels.
3. REGULATORY REQUIREMENTS FOR THE SITE
Radon emissions from the uranium mill tailings at this site are regulated by the State of Utah's
Division of Radiation Control and administered by the Utah Division of Air Quality under generally
applicable standards set by the Environmental Protection Agency (EPA) for Operating Mills.
Applicable regulations are specified in 40 CFR Part 61, Subpart W, National Emission Standards for
Radon Emissions from Operating Mill Tailings, with technical procedures in Appendix B. At present,
there are no Subpart T uranium mill tailings at this site. These regulations are a subset of the
NESHAPs. According to subsection 61.252 Standard, (a) radon-222 emissions to ambient air from an
existing uranium mill tailings pile shall not exceed an average of 20 pCi/m2-s for each pile or region.
Subsection 61.253, Determining Compliance, states that: "Compliance with the emission standard in
this subpart shall be determined annually through the use of Method 115 of Appendix B." The
repaired Cell 4A, and newly constructed Cell 4B, were both constructed after December 15, 1989
and each was constructed with less than 40 acres surface area. Cell 4A and 4B comply with the
requirements of 40 CFR 61.252(b), therefore no radon flux measurements are required on either
Cell 4A or 4B.
4. SAMPLING METHODOLOGY
Radon emissions were measured using Large Area Activated Charcoal Canisters (canisters) in
conformance with 40 CFR, Part 61, Appendix B, Method 115, Restrictions to Radon Flux
Measurements, (EPA, 2012). These are passive gas adsorption sampling devices used to determine
the flux rate of radon-222 gas from a surface. The canisters were constructed using a 10-inch
diameter PVC end cap containing a bed of 180 grams of activated, granular charcoal. The prepared
charcoal was placed in the canisters on a support grid on top of a Vi inch thick layer of foam and
secured with a retaining ring under 1XA inches of foam (see Figure 1, page 10).
One hundred sampling locations were distributed throughout Cell 2 (which consisted of one region) as
depicted on the Sample Locations Map (see Figure 2, Appendix D). Each charged canister was placed
directly onto the surface (open face down) and exposed to the surface for 24 hours. Radon gas
adsorbed onto the charcoal and the subsequent radioactive decay of the entrained radon resulted in
radioactive lead-214 and bismuth-214. These radon progeny isotopes emit characteristic gamma
photons that can be detected through gamma spectroscopy. The original total activity of the
adsorbed radon was calculated from these gamma ray measurements using calibration factors
derived from cross-calibration of standard sources containing known total activities of radium-226
with geometry identical to the counted samples and from the principles of radioactive decay.
After approximately 24 hours, the exposed charcoal was transferred to a sealed plastic sample
container (to prevent radon loss and/or further exposure during transport), identified and labeled, and
transported to the Tellco laboratory in Grand Junction, Colorado for analysis. Upon completion of on-
site activities, the field equipment was alpha and beta-gamma scanned for possible contamination
resulting from fieldwork activities. All field equipment was surveyed by Energy Fuels Radiation
Safety personnel and released for unrestricted use. Tellco personnel maintained custody of the
samples from collection through analysis.
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5. FIELD OPERATIONS
5.1 Equipment Preparation
All charcoal was dried at 110°C before use in the field. Unused charcoal and recycled charcoal were
treated the same. 180-gram aliquots of dried charcoal were weighed and placed in sample containers.
Proper balance operation was verified daily by checking a standard weight. The balance readout
agreed with the known standard weight to within ± 0.1 percent.
After acceptable balance check, empty containers were individually placed on the balance and the
scale was re-zeroed with the container on the balance. Unexposed and dried charcoal was carefully
added to the container until the readout registered 180 grams. The lid was immediately placed on the
container and sealed with plastic tape. The balance was checked for readout drift between readings.
Sealed containers with unexposed charcoal were placed individually in the shielded counting well,
with the bottom of the container centered over the detector, and the background count rate was
documented. Three five-minute background counts were conducted on ten percent of the containers,
selected at random to represent the "batch". If the background counts were too high to achieve an
acceptable lower limit of detection (LLD), the entire charcoal batch was labeled non-conforming and
recycled through the heating/drying process.
5.2 Sample Locations, Identification, and Placement
On July 22, 2013, the sampling locations were spread out throughout the Cell 2 region. The same
sampling locations that were established for the previous sampling of Cell 2 were used for the July
2013 sampling, although the actual sample identification numbers (ID) are different. An individual
ID was assigned to each sample point, using a sequential alphanumeric system indicating the charcoal
batch and physical location within the region (e.g., G01 ...G100). This ID was written on an adhesive
label and affixed to the top of the canister. The sample ID, date, and time of placement were recorded
on the radon flux measurements data sheets for the set of one hundred measurements.
Prior to placing a canister at each sample location, the retaining ring, screen, and foam pad of each
canister were removed to expose the charcoal support grid. A pre-measured charcoal charge was
selected from a batch, opened and distributed evenly across the support grid. The canister was then
reassembled and placed face down on the surface at each sampling location. Care was exercised not
to push the device into the soil surface. The canister rim was "sealed" to the surface using a berm of
local borrow material.
Five canisters (blanks) were similarly processed and the canisters were kept inside an airtight plastic
bag during the 24-hour testing period.
5.3 Sample Retrieval
On July 23, 2013 at the end of the 24-hour testing period, all canisters were retrieved, disassembled
and each charcoal sample was individually poured through a funnel into a container. Identification
numbers were transferred to the appropriate container, which was sealed and placed in a box for
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transport. Retrieval date and time were recorded on the same data sheets as the sample placement
information. The blank samples were similarly processed.
The charcoal samples from all 100 canisters were successfully containerized during the unloading
process.
5.4 Environmental Conditions
A rain gauge and thermometer were in place at the White Mesa Mill site to monitor rainfall and air
temperatures during sampling in order to ensure compliance with the regulatory measurement criteria.
In accordance with 40 CFR, Part 61, Appendix B, Method 115:
• Measurements were not initiated within 24 hours of rainfall.
• Approximately 0.01 inches of rainfall occurred after placement of the canisters, but all of
the canister seals remained intact and none of the canisters were surrounded by water.
• The minimum ambient air temperature during the sampling period was 66 degrees F.
6. SAMPLE ANALYSIS
6.1 Apparatus
Apparatus used for the analysis:
• Single- or multi-channel pulse height analysis system, Ludlum Model 2200 with a
Teledyne 3" x 3" sodium iodide, thallium-activated (Nal(Tl)) detector.
• Lead shielded counting well approximately 40 cm deep with 5-cm thick lead walls and a 7-
cm thick base and 5 cm thick top.
• National Institute of Standards and Technology (NIST) traceable aqueous solution radium-
226 absorbed onto 180 grams of activated charcoal.
• Ohaus Model C501 balance with 0.1 -gram sensitivity.
6.2 Sample Inspection and Documentation
Once in the laboratory, the integrity of each charcoal container was verified by visual inspection of the
plastic container. Laboratory personnel checked for damaged or unsealed containers and verified that
the data sheet was complete.
All of the 100 sample containers and 5 blank containers received and inspected at the Tellco analytical
laboratory were verified as valid and no damaged or unsealed containers were observed.
6.3 Background and Sample Counting
The gamma ray counting system was checked daily, including background and radium-226 source
measurements prior to and after each counting session. Based on calibration statistics, using two
sources with known radium-226 content, background and source control limits were established for
each Ludlum/Teledyne counting system with shielded well (see Appendix A).
Gamma ray counting of exposed charcoal samples included the following steps:
• The length of count time was determined by the activity of the sample being analyzed,
according to a data quality objective of a minimum of 1,000 accrued counts for any given
sample.
• The sample container was centered on the Nal detector and the shielded well door was
closed.
• The sample was counted over a determined count length and then the mid-sample count
time, date, and gross counts were documented on the radon flux measurements data sheet
and used in the calculations.
• The above steps were repeated for each exposed charcoal sample.
• Approximately 10 percent of the containers counted were selected for recounting. These
containers were recounted within a few days following the original count.
7. QUALITY CONTROL (QC) AND DATA VALIDATION
Charcoal flux measurement QC samples included the following intra-laboratory analytical frequency
objectives:
• Blanks, 5 percent, and
• Recounts, 10 percent
All sample data were subjected to validation protocols that included assessments of sensitivity,
precision, accuracy, and completeness. All method-required data quality objectives (EPA, 2012) were
attained.
7.1 Sensitivity
A total of five blanks were analyzed by measuring the radon progeny activity in samples subjected to
all aspects of the measurement process, excepting exposure to the source region. These blank sample
measurements comprised approximately 5 percent of the field measurements. The results of the blank
sample radon flux rates ranged from -0.02 to 0.01 pCi/m2-s, with an average of approximately 0.00
pCi/m2-s. The lower limit of detection (LLD) was approximately 0.03 pCi/m2-s.
7.2 Precision
Ten recount measurements, distributed throughout the sample set, were performed by replicating
analyses of individual field samples (see Appendix B). These recount measurements comprised
approximately 10 percent of the total number of samples analyzed. The precision of all recount
5
measurements, expressed as relative percent difference (RPD), ranged from less than 0.1 percent to
6.7 percent with an overall average precision of approximately 1.4 percent RPD.
7.3 Accuracy
Accuracy of field measurements was assessed daily by counting two laboratory control samples with
known Ra-226 content. Accuracy of these lab control sample measurements, expressed as percent
bias, ranged from approximately -3.0 percent to -0.5 percent. The arithmetic average bias of the lab
control sample measurements was approximately -1.5 percent (see Appendix A).
7.4 Completeness
One hundred samples from the Cell 2 Cover Region were verified, representing 100 percent
completeness for the July 2013 radon flux sampling.
8. CALCULATIONS
Radon flux rates were calculated for charcoal collection samples using calibration factors derived
from cross-calibration to sources with known total activity with identical geometry as the charcoal
containers. A yield efficiency factor was used to calculate the total activity of the sample charcoal
containers. Individual field sample result values presented were not reduced by the results of the field
blank analyses.
In practice, radon flux rates were calculated by a database computer program. The algorithms utilized
by the data base program were as follows:
Equation 8.1:
2 N
pCi Rn-222/m sec = rrs*A*b*0 5(d/9i 75)j
where: N = net sample count rate, cpm under 220-662 keV peak
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi; values used:
0.1699, for M-01/D-21 and
0.1702, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
Equation 8.2:
Error, 2cr = 2 x
Gross Sample, cpm Background Sample, cpm +
Sample Count, t, min Background Count,t,mm
x Sample Concentration Net,cpm
6
Equation 8.3:
2.71+(4.65K&.)
LLD- rrs*A*b*0.5(d/9T75)]
where: 2.71 = constant
4.65 = confidence interval factor
Sb = standard deviation of the background count rate
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi; values used:
0.1699, for M-01/D-21 and
0.1702, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
9. RESULTS
9.1 Mean Radon Flux
Referencing 40 CFR, Part 61, Subpart W, Appendix B, Method 115 - Monitoring for Radon-222
Emissions, Subsection 2.1.7 - Calculations, "the mean radon flux for each region of the pile and for
the total pile shall be calculated and reported as follows:
(a) The individual radon flux calculations shall be made as provided in Appendix A EPA
86(1). The mean radon flux for each region of the pile shall be calculated by summing all
individual flux measurements for the region and dividing by the total number of flux
measurements for the region.
(b) The mean radon flux for the total uranium mill tailings pile shall be calculated as follows:
J1A1. + ... J7A2H .. • J,A,
Js =
At
Where: Js = Mean flux for the total pile (pCi/m2-s)
J, = Mean flux measured in region i (pCi/m2-s)
A, = Area of region i (m2)
At = Total area of the pile (m2)"
40 CFR 61, Subpart W, Appendix B, Method 115, Subsection 2.1.8, Reporting states "The results of
individual flux measurements, the approximate locations on the pile, and the mean radon flux for each
region and the mean radon flux for the total stack [pile] shall be included in the emission test report. Any
condition or unusual event that occurred during the measurements that could significantly affect the results
should be reported."
7
9.2 Site Results
Site Specific Sample Results (reference Appendix C)
(a) The mean radon flux for the Cell 2 Cover Region at the site is as follows:
Cell 2 - Cover Region = 24.3 pCi/m2-s (based on 270,624 m2 area)
Note: Reference Appendix C of this report for the entire summary of individual measurement results,
(b) Using the data presented above, the calculated mean radon flux for Cell 2 is, as follows:
Cell 2 = 24.3 pCi/m2-s
(24.3V270.624) =24.3
270,624
As shown above, the arithmetic mean radon flux of the July 2013 samples for Cell 2 at Energy
Fuels White Mesa milling facility is above the NRC and EPA standard of 20 pCi/m2-s. The
extremely dry weather at the site for the past several years was especially severe during 2012 and is
continuing now in 2013. The result of this dry weather is likely a lowered water table in the
containment cell and reduced moisture content in surface soils, which could result in increased
radon flux rates at the site.
The additional cover material placed at the selected locations of Cell 2 (refer to the "comments"
column of the radon flux measurements spreadsheet in Appendix C) did not significantly reduce the
radon flux rates at those locations. The permeability of the additional cover material is likely a result
of low moisture content and partly because of the porosity of the materials used.
Appendix C presents the summary of individual measurement results, including blank sample
analysis.
Sample locations are depicted on Figure 2, which is included in Appendix D. The map was produced
by Tellco.
8
References
U. S. Environmental Protection Agency, Radon Flux Measurements on Gardinier and Royster
Phosphogypsum Piles Near Tampa and Mulberry, Florida, EPA 520/5-85-029, NTIS #PB86-
161874, January 1986.
U. S. Environmental Protection Agency, Title 40, Code of Federal Regulations, July 2012.
U. S. Nuclear Regulatory Commission, Radiological Effluent and Environmental Monitoring at
Uranium Mills, Regulatory Guide 4.14, April 1980.
U. S. Nuclear Regulatory Commission, Title10, Code of Federal Regulations, Part 40, Appendix A,
January 2013.
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
12 HI Tlncx Ciid'coa
L-in Tn»cd 1/4 in Vent Ho e Scrubbm Pad
S,2ir reick
&crub3i!i Pa a
1 8»
Spnnp ft 25
\ tO-iii »a
PVC End C»p
FlGtWE l Large-Ar&a Ratfon Collector
10
Appendix A
Charcoal Canister Analyses Support Documents
A
ACCURACY APPRAISAL TABLE
JULY 2013 SAMPLING
ENERGY FUELS RESOURCES
WHITE MESA MILL, BLANDING, UTAH
2013 NESHAPs RADON FLUX MEASUREMENTS
CELL 2
SAMPLING DATES- 07/22/13-07/23/13
SYSTEM
I D
DATE Bkg Counts (1 mm. each)
#1 #2 #3
Source Counts (1 mm each)
#1 #2 #3
AVG NET
cpm
YIELD
cpm/pCi
FOUND
pCi
SOURCE
ID
KNOWN
pCi
M-01/D-21 7/23/2013 129 127 141 10101 10119 10337 10053 0 1708 58860 GS-04 59300
M-01/D-21 7/23/2013 126 127 132 10287 10124 10121 10049 0 1708 58835 GS-04 59300
M-01/D-21 7/24/2013 121 125 132 10249 10138 10216 10075 0 1708 58987 GS-04 59300
M-01/D-21 7/24/2013 133 114 141 10075 10107 10105 9966 0 1708 58351 GS-04 59300
M-01/D-21 7/23/2013 129 127 141 10156 10071 10124 9985 0.1708 58458 GS-05 59300
M-01/D-21 7/23/2013 126 127 132 10230 10152 10179 10059 0 1708 58891 GS-05 59300
M-01/D-21 7/24/2013 121 125 132 10049 9956 10028 9885 0 1708 57875 GS-05 59300
M-01/D-21 7/24/2013 133 114 141 10056 10264 10181 10038 0 1708 58769 GS-05 59300
M-02/D-20 7/23/2013 114 136 122 10135 10248 10290 10100 0.1727 58485 GS-04 59300
M-02/D-20 7/23/2013 128 137 119 10106 10133 10158 10004 0.1727 57929 GS-04 59300
M-02/D-20 7/24/2013 112 125 137 10250 10276 10189 10114 0 1727 58562 GS-04 59300
M-02/D-20 7/24/2013 126 131 112 10236 10199 10226 10097 0 1727 58467 GS-04 59300
M-02/D-20 7/23/2013 114 136 122 10214 10270 10023 10045 0.1727 58164 GS-05 59300
M-02/D-20 7/23/2013 128 137 119 10368 10029 10076 10030 0 1727 58076 GS-05 59300
M-02/D-20 7/24/2013 112 125 137 9967 10295 9911 9933 0.1727 57516 GS-05 59300
M-02/D-20 7/24/2013 126 131 112 10144 10120 10212 10036 0 1727 58110 GS-05 59300
AVERAGE PERCENT BIAS FOR ALL ANALYTICAL SESSIONS -1 5%
CHARCOAL CANISTER ANALYSIS SYSTEM
SITELOCAnoN^kVV^ Hec^ U ^ ^\^A\vy^ J g T
CLIENT- w-g^si r~u t \ S ^•^si?uvT.-g £
Calibration Check Log
System ID- NAwO t / -2. ) Calibration Date Due Date. fr/W//^ _
Scaler S/N ^~l9^~2- High Voltage Window 4 42 Thrshld _ 2 20
Detector S/N- O 4<b ^3 Source ID/SN. ^IJ^^^G^'O \f Source Activity £^3£p£»
Blank Canister Bkgd Range, cpm: 2o = _
Gross Source Range, cpnr
.to.
to
to
Technician-JP —
All counts times are one minute.
Fbsf
Date By Background Counts (1 min each)
#1 #2 #3 #1
Source Counts (1 mm each)
#2 #3 Average
ok'f
Y/N
J2a JL*L \<=>[Q \
iDon< !
Y/N Y = average background and source cpm falls within the control limits.
N = average background and source cpm docs not fall within the control limits.
The acceptable ranges were determined from pnor background and source check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:
CT IENT £*ygr^y FVJL-CU Res purees
System ID
Scaler S/N:
^
Calibration Check Log
:M-oi /r>
— *Z> I Cahbrahon Date Due Dale
gT> ^ 7 ^ High Voltage: J^A_?_ Window: 4,42 Thrshld- 2.20
Detector S/N Q H i^33 Source 1D/SN: ^oP'^/^ " Source Activity. ^« p£«
Blank Canister Bkgd Range, cpm: 2 cr - t0 tS 3 a (tP) to (~7 [
Gross Souicc Range, cpm 2 a = tyfo^S _ to lOS*l U 3 a = °)~7 to 10C?7 /
Technician*
All counts times arc one minute
Date
Posi-
By Background Counts (1 min each)
#2 #3 Avg. '1
Source Counts (1 nun, each)
#2 #3 Average
ok''
Y/N
IS • 3
\ 7,7 IQ2.3Q toil
Y/N- Y = average background and source cpm falls within the control limits.
N - average background and source cpm does not fall within the control limits.
The acceptable ranges were determined from prior background and source check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SIT E LOCATION.
CLIENT £-^-cW^ y Fl/l^ts U(TC<5
System ID rV<? ^/D~ 2X>
Scalci S/N S"' 3
Detector S/N
Calibration Check Log
_ Calibration Date fr/*4/l3 Due Date </ _
High Voltage- |P3-£~ Window. 4 42 Thrshld 2 20
Source ID/SN. Source Activity
"78 to tS"l 3<T= UO to L70 Blank Canister Bkgd Range, cpm 2 a =
2a- q^Sq to iOS~-2T7 3a- 3 9 '7 to fiUA Gross Source Range, cpm
Technician-
Alt counts times are one minute
Fbsf
rb^T~[7/a^//?"
Dale By Background Counts (1 tnin each)
#1 #2 #3 Avg. #1
Source Counts (1 mm each)
#2 #3 Average
ok1'
Y/N
lite. I-2--Z-10-2.2,^
J3a 113 IQi3X
IfX. iX5"
13. LL2=, »23
Y'N Y = average background and source cpm falls within the control limits
N = average background and source cpm docs not fall within the control limits.
The acceptable ranges were determined from prior background and source check data
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION.
CLIEN'I
Calibration Check Lop
System ID |^"P%/7)-2-0 Calibration Date £/ /M7 * 3
Scaler S/N:
Detector S/N ^HlS^^-
Blank Canister Bkgd Range, cpm: 2 o =
Gross Source Range, cpm
DueDatc- /iH
High Voltage. jO'ZS' Window 4 42 Thrshld _. 2 20.
Source ID/SN Source Activity' .-*>K fQ
to IS^( 3a= GC? to <7Q
2a-
Technician:
qg^k to io- ^^63 to ioU,/
All counts times are one minute
Date By Background Counts (1 min each)
#2 tf3 Avg.
Source Counts (I mm. each)
#1 #2 #3 Average
ok°
Y'N
iQ2J' ioxio 12-:
-LVX IPOS'?) 5 L^
Y/N: Y = average background and source cpm falls within the control limits.
N = average background and source cpm docs not fall within the control limits.
The acceptable ranges were determined Gom prior background and source check data.
BALANCE OPERATION DAILY CHECK
Balance Model: O hqut^, Vor^ ~ O ~ <g m Wi
Standard Weight (g): Q-OQ • Q ^
Date Pre-check (g)
TOO, O
Post-check (g) O.K. ± 0.1 % ?
y^s
By
Appendix B
Recount Data Analyses
B
CLIENT- ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 13004 00
PILE. 2 BATCH: G SURFACE" SOIL AIR TEMP MIN: 66°F WEATHER. RAINED 0.01 in. AFTER PLACEMENT
AREA-COVER DEPLOYED. 7 22 13 RETRIEVED: 7 23 13 CHARCOAL BKG. 148 cpm Wt. Out. 180.0 g.
FIELD TECHNICIANS: TE.DLC COUNTED BY: DLC DATA ENTRY BY: DLC TARE WEIGHT 29.2 g.
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL DUE: 6/14/14
GRID SAMPLE RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON + LLD PRECISION
LOCATION I. D. HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS WT IN pCi/m2s pCi/m2s pCi/m2s % RPD
G10
RECOUNT
G20
RECOUNT
G3 0
RECOUNT
G40
RECOUNT
G50
RECOUNT
G60
RECOUNT
G70
RECOUNT
G80
RECOUNT
G90
RECOUNT
GlOO
RECOUNT
G10
G10
G20
G20
G3 0
G30
G4 0
G40
G50
G50
G60
G60
G70
G70
G80
G80
G90
G90
GlOO
GlOO
8
8
8
8
8
8
9
9
9
9
10
10
10
10
10
10
11
11
15
15
32
32
52
52
20
20
40
40
1
1
10 15
10 15
33
33
54
54
12
12
8
8
8
8
8
8
8
8
9
9
9
9
9
9
9
9
9
9
10
10
24
24
36
36
46
46
55
55
0
0
11
11
19
19
33
33
57
57
19
19
7 23 13 20
7 24 13 7
7 23 13 20
7 24 13 7
23 13
24 13
7 23 13
7 24 13
23 13
24 13
20
7
20
7
7 23 13 20
7 24 13 7
23 13 20
24 13 7
7 23 13 20
7 24 13 7
20
7
7 23 13 21
7 24 13 7
23
24
13
13
21
7
2
7
10
7
17
8
25
8
34
10
41
10
49
11
59
12
8
16
16
16
33392
31264
17493
15848
12394
11688
1500
1371
34097
32075
28247
26092
5590
5501
1560
1478
1072
1006
1835
1719
226 .1
226 .1
222 .3
222 .3
223 .5
223 .5
223 .1
223 .1
226.5
226 .5
220 . 9
220 . 9
224 .7
224 .7
224 .5
224 .5
220.8
220 .8
225.5
225 .5
51.1
52 . 0
26.7
26.3
19.0
19 .4
53.8
54 . 8
44.8
44 . 8
1.0
1.0
0.6
0.6
1.2
1.2
5.1
5.2
2.7
2 . 6
1 . 9
1.9
0.2
0.2
5.4
5.5
4.5
4 . 5
0.9
0.9
0 .1
0.1
0.1
0.1
0.1
0.1
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0.03
0. 03
0.03
0.03
0.03
0.03
0.03
0.03
1.7*
1.5s
2 .1%
0.0'-
1. 8%
0. 0s
6 . 7!
0 . 0%
0 . 0%
0 . 0!
AVERAGE PERCENT PRECISION FOR THE CELL 2 COVER REGION: 1.4%
Page 1 of 1
Appendix C
Radon Flux Sample Laboratory Data (including Blanks)
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL
PILE: 2 BATCH: G SURFACE: SOIL
AREA: COVER DEPLOYED: 7 22 13 RETRIEVED: 7
FIELD TECHNICIANS: TE.DLC COUNTED BY. DLC
COUNTING SYSTEM ID.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN:66°F
23 13 CHARCOAL BKG:
DATA ENTRY BY: DLC
GRID
LOCATION
G01
G02
G03
G04
G05
G06
G07
G08
G09
GIO
Gil
G12
G13
G14
G15
G16
G17
G18
G19
G20
G21
G22
G23
G24
G25
G26
G27
G28
G29
G30
G31
G32
G33
G34
G35
G36
G37
SAMPLE DEPLOY RETRIV ANALYSIS MID-TIME CNT GROSS
I. D. HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS
G01
G02
G03
G04
G05
G06
GO 7
G08
G09
GIO
Gil
G12
G13
G14
G15
G16
G17
G18
G19
G20
G21
G22
G23
G24
G25
G26
G27
G28
G29
G30
G31
G32
G33
G34
G35
G36
G37
3
4
5
7
8
9
11
12
13
15
16
17
19
20
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52
55
6
9
11
13
15
16
20
20
21
21
22
22
22
23
23
24
24
25
25
26
26
32
33
34
35
36
37
38
38
39
39
43
44
45
46
46
47
48
49
50
52
53
53
23
23
23
7. 23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
13 19
13 19
13 19
13 19
13 19
13 19
13 20
13 20
13
13
20
20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
55
55
56
56
59
59
1
1
2
2
4
4
5
5
7
7
8
8
10
10
11
11
13
13
14
14
16
16
17
17
19
19
20
20
22
22
23
2223
17910
1594
25307
1451
1156
3364
17178
2259
33392
15520
44760
18072
14898
6841
5042
30632
26242
23532
17493
31494
26093
20297
20330
34547
1572
22155
14091
65936
12394
22913
19664
28965
3496
17863
27663
17349
Page 1 of 3
PROJECT NO 13004.00
WEATHER: RAINED 0.01 in. AFTER PLACEMENT
148 cpm WtOut 180.0 g
TARE WEIGHT- 29.2 g.
WT IN pCi/m2s pCi/m2s pCi/m2s COMMENTS:
219 .0
220.5
221.9
227 .2
222 .2
220 . 8
224
225
229
226
221
226
224
227
222 .6
223 .4
224
220
222
222
231
226
223
225
220
223
230
222 . 0
216 .0
223
235
227
221
225
223
220
227
3
27
2
38
0
1
4
26
3.2
51.1
23 . 7
68 .6
27.7
22 .7
10
7
47
40
36
26
48
40
31
31
53
2.2
34.1
21.6
102 . 0
19.0
35.4
30.5
45.1
5.2
27.8
43 .1
27 . 0
0.3
2.7
0.2
3.9
0.1
0.2
0.5
2.6
0.
5 .
2 .
6 .
2 .
2 .
1.
0.
4 .
4 .
3 .
2 .
4 .
4 .
3 .
3
5,
0
3
2 ,
10
1
3
3
4
0
2
4
2
0.03
0.03
0.03
0.03
0 . 03
0.03
0.03
0 . 03
0 .03
0.03
0 . 03
0.03
0.03
0. 03
03
03
0.03
0.03
0 . 03
0.03
0.03
0.03
0.03
0.03
0. 03
0 . 03
0 . 03
0.03
0.03
0.03
0 . 03
0 . 03
0.03
0 . 03
0.03
0.03
0.03
NEW COVER
NEW COVER
NEW COVER
NEW COVER
NEW COVER
NEW COVER
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO 13004.00
PILE: 2 BATCH. G SURFACE. SOIL
AREA: COVER DEPLOYED. 7 22 13 RETRIEVED: 7
FIELD TECHNICIANS: TE.DLC COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN:66°F
23 13 CHARCOAL BKG:
DATA ENTRY BY- DLC
WEATHER: RAINED 0.01 in. AFTER PLACEMENT
148 cpm WtOut. 180 0 g.
TARE WEIGHT: 29.2 g
GRID
LOCATION
G38
G39
G40
G41
G42
G43
G44
G45
G46
G47
G48
G4 9
G50
G51
G52
G53
G54
G55
G56
G57
G58
G59
G60
G61
G62
G63
G64
G65
G66
G67
G68
G69
G70
G71
G72
G73
G74
SAMPLE
I . D.
G38
G39
G40
G41
G42
G43
G44
G45
G46
G47
G48
G49
G50
G51
G52
G53
G54
G55
G56
G57
G58
G59
G60
G61
G62
G63
G64
G65
G66
G67
G68
G69
G70
G71
G72
G73
G74
DEPLOY RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON + LLD
HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS WT IN pCi/m2S pCi/m2S pCi/m2 s COMMENTS:
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
17
19
20
22
25
27
30
32
33
35
37
38
40
41
42
44
46
49
52
55
57
59
1
2
4
5
7
8
10
12
13
14
15
17
18
20
21
54
54
55
55
55
56
56
57
57
59
59
0
0
1
1
2
2
3
8
9
10
10
11
12
12
13
13
14
14
16
17
18
19
20
20
21
22
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
13 20
23
25
25
26
27
29
29
31
31
32
32
34
34
35
35
37
37
38
38
40
40
41
41
43
43
44
44
46
46
47
47
49
49
50
50
52
52
1151
33840
1500
5006
1803
1580
43887
129362
5075
35586
51920
10681
34097
9463
19139
2790
19755
3371
72076
28670
10767
8930
28247
5399
5409
2815
22450
16807
31945
22125
2928
4927
5590
22122
21712
20576
12875
224 .3
223 .4
223 .1
225 .3
222 .8
225.9
225 . 0
227.4
220 .1
223 .8
227 . 8
224
226 .
221.
221,
222
216
227
224 ,
222 .4
223 .1
221.6
220.9
222 . 8
222 .5
223 .
223 .
221 .
217.
221.
225 .
223 .
224 .
225 .
220.8
229.8
226.5
1.6
53.0
2.1
7.6
1.2
0.2
5.3
0.2
0.8
1
69
204
7
56
81
16
30
4
31
5
114
45
16
14
44
8
8
4
35
26
50
35
4
53.8
14 . 8
1
2
2
1
2
4
9
0
8
4
4
3
7
,7
.9
,2
,5
7.7
8.7
35.3
34 .6
32 .8
20.4
0
0
6 ,
20
0
5
8 .
1
5
1
3
0.4
3.1
0
11,
4 ,
1 ,
1
4
0
0.8
0.8
0.03
0.03
0.03
0.03
0.03
0 . 03
0.03
0 .03
0.03
0.03
0.03
0.03
0.03
0.03
0 . 03
0.03
0 . 03
0.03
0.03
0 . 03
0. 03
0 . 03
0 . 03
0 . 03
0.03
0.03
0.03
0 .03
0 . 03
0 . 03
0.03
0 . 03
0 . 03
0.03
0.03
0.03
0.03
NEW COVER
NEW COVER
NEW COVER
NEW COVER
NEW COVER
NEW COVER
NEW COVER
Page 2 of 3
CLIENT". ENERGY FUELS RESOURCES PROJECT. RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO: 13004.00
PILE: 2 BATCH. G SURFACE: SOIL
AREA. COVER DEPLOYED: 7 22 13 RETRIEVED. 7
FIELD TECHNICIANS: TE.DLC COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN: 66°F
23 13 CHARCOAL BKG.
DATA ENTRY BY: DLC
WEATHER: RAINED 0.01 in AFTER PLACEMENT
148 cpm Wt.Out: 180.0 g.
TARE WEIGHT: 29.2 g
LOCATION
G75
G76
G77
G78
G79
G80
G81
G82
G83
G84
G85
G86
G87
G88
G89
G90
G91
G92
G93
G94
G95
G96
G97
G98
G99
GlOO
SAMPLE DEPLOY RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON + LLD
I. D. HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS WT IN pCi/m2 s pCi/m2 s pCi/m2 s COMMENTS:
G75
G76
G77
G78
G79
G80
G81
G82
G83
G84
G85
G86
G87
G88
G89
G90
G91
G92
G93
G94
G95
G96
G97
G98
G99
GlOO
10 23
10 24
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
11
11
11
11
11
11
11
27
29
31
33
35
37
39
40
42
44
10 46
10 47
52
54
56
58
59
1
3
5
7
10
11
12
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
10
10
10
10
10
10
10
10
10
23
24
25
27
30
33
35
38
40
42
44
46
47
48
55
57
59
2
4
6
8
10
12
13
17
19
23 13
23
20
23 13
23 13
13 20
20
23 13
23 13
23 13
23 13
20
20
20
21
21
13 21 23
23 13 21
23 13 21
23 13 21
23 13 21
23 13 21
21 23 13
23 13
23
23
23 13
23 13
23
23 13
23 13
23 13
23 13
23 13
21
13 21
13 21
21
21
13 21
21
21
21
21
21
53
53
56
56
58
59
1
2
3
3
5
5
6
6
8
8
10
10
11
11
13
13
14
14
15
16
1276
1329
1039
1693
3081
1560
6511
11302
15451
1971
3945
8880
3373
5095
10504
1072
1448
1876
6725
2873
1528
1585
14785
2721
1327
1835
223
227
230
227
220 . 0
224 .5
226.9
221.7
222 .6
222 .8
226 .4
223 .2
223 .6
222.1
218 .6
220 . 8
227 .1
223
209
230
226
220
229
221
230
225
1
1
0
2
4
1
10
17 .9
24 .6
14 . 0
5.2
7,
16,
0,
2 ,
2.8
10.5
4.3
2
2
23,
4
1
1
0.8
1.7
0.4
0.2
0.1
0.03
0.03
0.03
0 . 03
0 . 03
0.03
0.03
0.03
0.03
0.03
0 . 03
0.03
0.03
0 . 03
0 . 03
0.03
0.03
0 . 03
0 . 03
0 . 03
0.03
0 . 03
0.03
0.03
0.03
0.03
AVERAGE RADON FLUX RATE FOR THE CELL 2 COVER REGION: 24.3 pCi/m2s
BLANK CANISTER ANALYSIS"
LOCATION
G BLANK 1
G BLANK 2
G BLANK 3
G BLANK 4
G BLANK 5
SAMPLE
G BLANK 1
G BLANK 2
G BLANK 3
G BLANK 4
G BLANK 5
RETRIV ANALYSIS MID-TIME
HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS WT IN pCi/m2 s pCi/m2 s pCi/m2 s COMMENTS
20
20
20
20
20
15
15
15
15
15
23
23
23
23
23
13
13
13
13
13
21
21
21
21
21
25
25
36
36
47
10
10
10
10
10
1533
1451
1489
1378
1501
213.6
209.9
208 . 9
207 . 9
209.6
0. 01
0.00
0 . 00
-0 . 02
0.00
0.02
0.02
0 . 02
0 . 02
0 . 02
0.03
0.03
0.03
0.03
0 . 03
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
AVERAGE BLANK CANISTER ANALYSIS FOR THE CELL 2 COVER REGION: 0.00 pCi/m2s
Page 3 of 3
Appendix D
Sample Locations Map (Figure
D
EE -CELLI
Pb WHITE MESA MILL
BLANDING, UTAH
NESHAPS 2013
1?
(=9 SAMPLE LOCATIONS MAP
JULY 2013 -CELL
3
PREPARED FOR
ENERGY FUELS RESOURCES
LEGEND
GOI O SAMPLE LOCATION ON
FIGURE 2
-CELL4B
-CELL4A
reueo ENVIRONMENTAL, LLC