DRC-2014-001181 - 0901a068803f7f4f

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-2014-001181
January 15, 2014 UTAH DEPARTMENT OF
ENVIRONMENTAL QUALITY
Mr. Bryce Bird JAN 1 7 2014
Director, Utah Division of Air Quality
State of Utah Department of Environmental Quality DIVISION OF AIR QUALITY
195 North 1950 West
Salt Lake City, UT 84116
Re: White Mesa Uranium Mill,
National Emissions Standards for Radon Emission from Operating Mill Tailings
Transmittal of December 2013 Monthly Radon Flux Monitoring Report for Cell 2
Dear Mr. Bird:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRFs") radon-222 flux monitoring report
for December 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-
compliance.
Included with the Monthly Report is a Radon Flux Measurement Program Report, dated December
2013, prepared by Tellco Environmental (the "Tellco December 2013 Monthly Report"). The Tellco
December 2013 Monthly Report indicates that for the month of December 2013, the average radon flux
from Cell 2 of 10.0 pCi/(m2 -sec), complied 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,
Energy FujjVResources (USA) Inc.
Jaime Massey
Regulatory Compliance Specialist
N:\WMM\Required Reports\NESHAPS Reports\2013 Monthly NESHAPs\Cell 2 December 2013 Monthly
NESHAPs\transmtl Cell 2 Radon Flux December 2013.doc
Letter to B. Bird
January 15, 2014
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 DECEMBER 2013
Submitted January 15,2014
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) Montlily Report
This Report is the monthly report for the Mill's Cell 2 for December 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 December 2013 is set out in Section 5 of this Report.
The monthly monitoring data for December 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
December 2013, prepared by Tellco Environmental (the "Tellco December 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"], 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 Infonnation - Summary of 2012 Annual Report
Facility History
Cells 2 and 3, which have surface areas of 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, receive 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 2012 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 report for
the year in non-compliance and will be due 30 days following the end of each month."
This Report is the required monthly report for December 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 Report 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 Report.
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) December 2013 Results
Detailed results for December 2013 for Cell 2 are contained in the Tellco December 2013 Monthly
Report. As described in the Tellco December 2013 Monthly Report, 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 December 2013 was reported by Tellco to be 10.0 pCi/(m2 -sec).
This radon flux value complies with 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 performed 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 constructed 12 test areas on Cell 2 to assess the effect of the addition of one foot of
additional soil cover. EFR applied one foot of random fill moistened and compacted by a dozer
to 12 circular test areas of approximately 100 to 120 feet in diameter. The total tested area is
larger than the single 100 foot by 100 foot area proposed in previous Cell 2 monthly radon flux
monitoring reports. Installation of 12 test areas containing the additional 1 foot of compacted soil
was completed by August 2, 2013. Wetting and re-compaction of all 12 areas was completed
prior to the start of the September 21, 2013 monthly flux monitoring event.
ii. The radon flux has been monitored monthly at 100 locations on Cell 2, including the 12 test
areas, since April 2013.
iii. The effectiveness of the additional compacted cover at the 12 test areas will be evaluated over the
next several months. If the desired reduction (to within compliance levels) is achieved on the test
areas, EFRI will apply additional random fill at 90% compaction, to the remainder of Cell 2, on
or before July 1, 2014.
Based on discussions with DRC, EFRI will proceed with the application of cover and will provide a letter
to DRC with information demonstrating that the application of soil cover is consistent with the design and
QC requirements of the proposed Reclamation Plan, currently under revision, on the understanding that
the application of cover 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:
• Windblown tailings from Cell 3 which have been deposited on Cell 2 as Cell 3 is being closed
have been removed and re-buried in Cell 3. A berm approximately five feet high, extending the
length of the Cell 3 beach has been constructed at the edge of Cell 2, to prevent further carryover
of sands from Cell 3 onto the Cell 2 cover prior to closure of Cell 3.
• Any contaminated material near the surface of Cell 2 has been reburied.
• Additional cover material has been added to each of 12 identified areas of elevated flux on Cell 2.
• Monthly radon flux monitoring to assess the effectiveness of the above actions is ongoing.
b) 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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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 penalties # for submitting false information including the possibility of fine and
imprisonment. Set/8, UiB.C. 1001.
Signed: //if I Jr Date:
David C. FrycjenlvAid \7
Senior Vice President, General Counsel and Corporate Secretary
ATTACHMENT 1
National Emissions Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
December 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
December 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 December 02-03, 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).
Prior to 2012, Energy Fuels had opted 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. 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
December 2013; the results of each monthly sampling event are presented in separate reports.
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 3 sampling results are presented in separate reports.
Cell 2, which has a total area of approximately 270,624 square meters (m2), has been filled and
covered with interim cover. The Cell 2 cover region is the same size in 2013 as it was in 2012. This
cell is comprised of one region, a soil cover of varying thickness, which requires NESHAPs radon
flux monitoring. There were no exposed tailings within Cell 2 at during the December 2013 sampling.
Cell 3, which has a total area of approximately 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.
l
The 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." Cell 1 is
completely covered with standing liquid and therefore no radon flux measurements are required on
Cell 1. 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 Vz inch thick layer of foam and
secured with a retaining ring under 1V2 inches of foam (see Figure 1, page 10).
One hundred sampling locations were distributed throughout Cell 2 (consisting 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 December 02, 2013 100 sampling locations were spread out throughout the Cell 2 covered region.
The same sampling locations that were established for the previous sampling of Cell 2 were used for
this December 2013 sampling, although the actual sample identification numbers (IDs) 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., Q01.. .Q100). 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. A few of the samples had to be offset several feet because of standing water at
the actual location markers, due to previous rainstorms.
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 December 03, 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.
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Identification numbers were transferred to the appropriate container, which was sealed and placed in a
box for transport. Retrieval date and time were recorded on the same data sheets as the sample
placement information. The blank samples were similarly processed.
All 100 charcoal samples from Cell 2 covered region were successfully containerized during the
unloading process.
Tellco personnel maintained custody of the samples from collection through lab analysis.
5.4 Environmental Conditions
A rain gauge and thermometer were placed within Cell 2 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.
• There was no rainfall after the placement of the canisters.
• The criteria regarding minimum ambient air temperature and frozen ground do not apply
when performing sampling on a monthly basis; however, the minimum air temperature
during the sampling period was 32 degrees F, and the ground was not frozen.
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 (NaI(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.
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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 on the next day 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. Analysis of the five
blank samples measured radon flux rates ranging from approximately -0.01 to 0.02 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
5
approximately 10 percent of the total number of samples analyzed. The precision of all recount
measurements, expressed as relative percent difference (RPD), ranged from less than 0.1 percent to
9.3 percent with an overall average precision of approximately 2.9 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 -1.5 percent to 0.0 percent. The arithmetic average bias of the lab
control sample measurements was approximately -0.9 percent (see Appendix A).
7.4 Completeness
All 100 of the samples from the Cell 2 cover region were verified, representing 100 percent
completeness for the December 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:
pCi Rn-222/m2sec = [Ts*A*b*^5<dA>i ^
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, 2a = 2x
Gross Sample, cpm Background Sample, cpm +
Sample Count, t, mm Background Count, t, min
x Sample Concentration Net,cpm
6
Equation 8.3:
1Tn_ 2.71+(4.65XSt)
LLD" [Ts*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:
JiAi+ ... J2A2r+l... JA
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 region at the site is as follows:
Cell 2 - Cover Region = 10.0 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= 10.0pCi/m2-s
(10.0X270.624) =10.0
270,624
As shown above, the arithmetic mean radon flux of the December 2013 samples for Cell 2 at
Energy Fuels White Mesa milling facility is below the NRC and EPA standard of 20 pCi/m2-s.
For the past several years, the site has been experiencing drought conditions, which were especially
severe during 2012 and the first half of 2013. The result of this dry weather is likely a lowering of
the moisture levels in the buried tailings and cover materials, leading to increased radon flux rates at
the site. There were a few intense storms in September 2013, which produced very heavy rain
downpours and flash flooding at Cell 2, with water running off or standing on the surface cover
material. There were several small areas with standing water on the surface of the Cell 2 cover
during the December 2013 sampling. The December 2013 sampling results for Cell 2 are
substantially lower than any of the other radon flux testing performed during the prior months of
2013. It is likely that the rain storms during the latter part of 2013 are increasing the moisture
content in the cover material of Cell 2, as well as the tailings sands beneath, which is improving the
radon attenuation properties of the cover material.
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, Title 10, Code of Federal Regulations, Part 40, Appendix A,
January 2013.
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
Handle
ff tf^X
1/4 in. VcntHalo I-in Tn»cK
1 Scriibbat Pad
Strutter PaJ
1 '2 HI 71 ne* Cl'4'COa
Spring
\
PVC End Cap
fIGtfflE 1 Large-Ares Ratfen Cplltcter
10
Appendix A
Charcoal Canister Analyses Support Documents
A
ACCURACY APPRAISAL TABLE
DECEMBER 2013 SAMPLING
ENERGY FUELS RESOURCES
WHITE MESA MILL, BLANDING, UTAH
2013 NESHAPs RADON FLUX MEASUREMENTS
CELL 2
SAMPLING DATES: 12/02/13-12/03/13
SYSTEM
I D.
DATE Bkg Counts
#1
(1 min.
#2
each)
#3
Source Counts (1 min. each)
#1 #2 #3
AVG NET
cpm
YIELD
cpm/pCi
FOUND
pCi
SOURCE
ID
KNOWN
pCi
M-01/D-21 12/5/2013 141 142 125 10158 10117 10228 10032 0 1699 59045 GS-04 59300
M-01/D-21 12/5/2013 128 131 121 10151 9983 10161 9972 0.1699 58691 GS-04 59300
M-01/D-21 12/6/2013 129 116 113 9982 10290 9923 9946 0 1699 58538 GS-04 59300
M-01/D-21 12/6/2013 143 120 140 10050 10187 10037 9957 0.1699 58605 GS-04 59300
M-01/D-21 12/5/2013 141 142 125 10196 10101 10325 10071 0.1699 59278 GS-05 59300
M-01/D-21 12/5/2013 128 131 121 10340 10182 10069 10070 0.1699 59272 GS-05 59300
M-01/D-21 12/6/2013 129 116 113 10040 10127 10047 9952 0.1699 58576 GS-05 59300
M-01/D-21 12/6/2013 143 120 140 10063 10042 10154 9952 0.1699 58576 GS-05 59300
M-02/D-20 12/5/2013 116 108 114 10106 10104 10223 10032 0.1702 58940 GS-04 59300
M-02/D-20 12/5/2013 129 139 138 10036 10204 10132 9989 0.1702 58688 GS-04 59300
M-02/D-20 12/6/2013 131 119 108 10066 9996 10122 9942 0.1702 58414 GS-04 59300
M-02/D-20 12/6/2013 125 145 126 9985 10234 10114 9979 0 1702 58631 GS-04 59300
M-02/D-20 12/5/2013 116 108 114 10071 10160 10051 9981 0.1702 58645 GS-05 59300
M-02/D-20 12/5/2013 129 139 138 10025 10054 10172 9948 0.1702 58451 GS-05 59300
M-02/D-20 12/6/2013 131 119 108 10167 10117 9996 9974 0.1702 58602 GS-05 59300
M-02/D-20 12/6/2013 125 145 126 10224 10248 10110 10062 0.1702 59119 GS-05 59300
AVERAGE PERCENT BIAS FOR ALL ANALYTICAL SESSIONS. -0.9%
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION: K<*A Mill 1>I^J^ }uCT
CLIENT: &W£»*}y ^Jirt I $ ^65P \AjTCtS
Calibration Check Log
System ID: M-Oz/p-2() Calibration Date: Due Date: fr/'?/iCf
Scaler S/N: S~l^(f 3 High Voltage: I OlS Window: 4.42 Thrshld: 2.20
Detector S/N: €> 4* 5B>*2-. Source ID/SN: ource Activity:
Blank Canister Bkgd. Range, cpm: 2o= to tS" ) 3 0 = to t "7 0
Gross Source Range, cpm: 2«=_?5^3_to ios^n 30= to \o<*(f)
Technician: ^ Gyt^^
All counts times are one minute.
Date By
#1 I #2 I #3
Background Counts (1 min. each)
Avg.
Source Counts (1 min. each)
#1
r?6
#2
010 a
#3 Average
taw
10111
ok?
Y/N
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
SITE LOCATION: \k\ V\,\<Lc \k*J$Q\ NMovjj % lotlA^n^ , OfT
CLIENT: £-"4*^^ ^U>*As ^eSo%\^6t5 (jj
Calibration Check Log
System ID: ^'O^/h Calibration Date: 3 Due Date: b/lj'/lf
Scaler S/N: ( 3 High Voltage: \01^ Window: 4.42 Thrshld: 2.20
Detector S/N: O 4 I £3*2- Source ID/SN: /&S~C>S Source Activity: $>°l'^ *pC
to 1^1 3o = to no Blank Canister Bkgd. Range, cpm: 2 o = &
Gross Source Range, cpm: 2q= 364 fc> to LQ4^€> 3q= ^kfe"^ to tOfcUl
Technician: ^P/- ^ft^v—
All counts times are one minute.
Date By Background Counts (1 min. each)
#1 #2 #3 Avg. #1
Source Counts (1 min. each)
#2 #3 Average
ok?
Y/N
ioe> ii toon \ g>$7i i oo
HI 1LSL
Oa JL4S XXT2M&
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
SITE LOCATION:
CLIENT; £*v-€»Q^y Fn.<i-S ^•^SQHYiflt.S
Calibration Check Log
System ID: lA-Pi/p-^ I Calibration Date: C>/ / V /' 3 Due Date: 6 / N / I V
Scaler S/N: 5~l S~7 ^- Hign Voltage: I^^S Window: 4.42 Thrshld: 2.20
Detector S/N: OH iS 33 Source ID/SN: ^A^^/GS" Source Activity: 3 K p£/
Blank Canister Bkgd. Range, cpm: 2 o = to l^H 3 a = 6°) to t~7 [
Gross Source Range, cpm: 2 o = °) ^^3 to [0 5H"7 3 G = to I O
Technician:
All counts times are one minute.
Date By Background Counts (1 min
#1 #2 #3
each)
Avg. #1
Source Counts (1 min. each)
#2 #3 Average
ok?
Y/N
i± i3V cot r7
13) TTv7
1-2-0
J2=±
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
LOCATION: vJ Wt\** IV B/^ctv^ jKJ^T
CLIENT: y FvV<l5 ^gUW lO^S/fr)
SITE
Calibration Check Log
Calibration Date: fr/ M /13 Due Date: fe/ N / / <j*
Scaler S/N: fl57^ High Voltage: 10%% Window:
SvstemID: tW^'/p^l
4.42 Thrshld: 2.20
Detector S/N: 0 *r I *5 33 Source ID/SN: Source Activity:
Blank Canister Bkgd. Range, cpm: 2 <J = _ to n
Gross Source Range, cpm: 2o= °I^P)S to tOCl U 3 o = 97*4Q to I
Technician:
All counts times are one minute.
Pre
Date
5gH
By Background Counts (1 min,
#1
1
#2
if
#3
each)
Avg.
3(g
#i
Source Counts (l min. each)
#2
IPIP
#3 Average
ok?
Y/N
Otfl*2-o5 8 ± tOO<4
l«43 3ii look7*
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.
BALANCE OPERATION DAILY CHECK
Balance Model: OHA^> ~Q £M« l"2^ ° 7
Standard Weight (g): ^QO'O ^.
Date Pre-check (g)
-7.00,0
Post-check (g) O.K.±0.1 %? By
Appendix B
Recount Data Analy:
B
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 13004.09
PILE: 2 BATCH: Q SURFACE: SOIL AIR TEMP MIN: 32°F WEATHER: NO RAIN
AREA: COVER DEPLOYED: 12 2 13 RETRIEVED: 12 3 13 CHARCOAL BKG: 147 cpm Wt. Out: 180.0 g.
FIELD TECHNICIANS: CS.DLC.TE COUNTED BY: DLC DATA ENTRY BY DLC TARE WEIGHT: 29.2 g.
COUNTING SYSTEM l.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
RECOUNT CANISTER ANALYSIS:
RETRIV ANALYSIS MID-TIME GROSS GROSS
LOCATION
QIO
RECOUNT
Q20
RECOUNT
[ Q30"
! RECOUNT
Q40
RECOUNT
j Q50 "
!_ RECOUNT
Q60
RECOUNT
; Q70
: RECOUNT
Q80
RECOUNT
RECOUNT
QIO
QIO
Q20
Q20
Q3Q
Q30
Q40
Q40
Q50"
Q60
Q60
"Q70
Q70_
Q80
Q80
Q9Q'
Q90
HR MIN HR MIN MO DA YR HR MIN (MIN) COUNTS WT IN pCi/m-'s pCi/m-'s pCi/m;s
Q100
RECOUNT
Q100
Q100
12
12
25
25
34
34
44
44
57
57
8
8
17
17
32
32
44
44
52
52
14 12 5
14 12 6
24 12 5
24 12 6
34" 12 5
34 12 6
44 12 5
44 12 6
54 12 "5
54 12 6
12 5
12 6
14 12 5
14 12 6
36 12 5
36 12 6
9 46 12 5
9 46 12 6
13 16 21
13 9 20
13 16
13 9
13 16
13 9
13 17
13 9
13 17
13 9
29
20
13 16 37
13 9 21
46
21
13 17 2
13 9 23
9
23
13 17 20
13 9 25
30
26
13 17 40
13 9 30
56 12 5
56 12 6
13
13
17
9
53
30
5730
5297
10327
9272
"93 91
8536
23413
20917
3660
__3256_
3317
2994
1141'
1014
1224
1167
1624
1581
1878
1804
221,5
221.5
219.5
219.5
"218.9
218 .9
219.8
219.8
217/9
217.9
221.4
221.4
219.4
219.4
219.8
219.8
215". 7
215.7
221.9
221.9
12.1
12 ,7
22 .0
22 .4
"20 VO
20 .0
50.3
50 .9
7.6
_7 .6
6 . 9
7.0
" 2 .2
_2.1
0.6
0.6
1.43"
JL .57
1.7
1.8
1.2
1_.3
2.2
2.2
2T0
2,0
5.0
5.1
0.8
0.8
0.7
0.7
0.2
0.2
0.1
0.2
0.2
0.2
0.04
0 .04
0 . 04
0 .04
"o". 04"
0.04
0 . 04
0 .04
0.04
0 .04
0.04
0 .04
0 .04
0^04
0.04
0 .04
0~ 04"
Q.Q4
0 . 04
0 .04
PRECISION
4.8%
1. 8%
0.0%
1.2%
Q,J}%
1.4%
4.7%
0.0%
9.3%
5.7%
AVERAGE PERCENT PRECISION FOR THE CELL 2 COVER REGION: 2.9%
Page 1 of 1
Appendix C
Radon Flux Sample Laboratory Data (including Blanks)
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 13004.09
PILE: 2 BATCH: Q SURFACE: SOIL AIR TEMP MIN: 32°F
AREA: COVER DEPLOYED: 12 2 13 RETRIEVED: 12 3 13 CHARCOAL BKG:
FIELD TECHNICIANS: CS.DLC, TE COUNTED BY: DLC DATA ENTRY BY: DLC
COUNTING SYSTEM I D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
WEATHER: NO RAIN
147 cpm WtOut: 180.0 g.
TARE WEIGHT: 29.2 g.
GRID
LOCATION
QOl
QC2
Q03
Q04
Q05
Q06
Q07
Q08
Q09
QIO
Qll
Q12
013
Q14
Q15
Q16_
~Q17
Q18
Q19
Q20
Q21
DEPLOY RETRIV ANALYSIS MID-TIME
HR MIN HR MIN MO DA YR HR MIN
GROSS GROSS RADON + LLD
COUNTS WT IN pCi/m2s pCi/m2s pCi/m2s COMMENTS
Q23
Q24
Q25
Q26
Q27
Q28
Q29
Q30
Q31
Q32
Q33"
Q34
Q35
Q36
Q37
QOl
Q°2_
Q03
Q04
Q05
Q06
Q07
Q08
Q09
QIO
Qll
Q12
Q13
Q14
Q15
Q16
Q17
Q18
Q19
Q20
Q21
Q22
Q23
Q24
Q25
Q26
Q27
Q28
Q29
Q30
Q31
Q32
Q33
Q34
Q35
Q36
Q37
58
0
2
4
6~"
8
~9~
10
"11
12
13
15
16
17
19
21
22~
22
24
25
26
27_
28
29
30
31
32
33
34
34
36
37
38
39
39
40
41
5
6
- ?
8
9
10
11
12
13
14
15
16
17~
18
19"
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
12 5
12 5
12 5~
12 5
12 5
12
12
12
12
12
12
12
12
12
12
12
"12
12
12"
12
12
12
12"
12
12
12
12
12
12
12
12
12
12
12
12
12
12
13 16
13 16
13 16
13 16
13 16
13 16
13 16"
13_ 16
13 16 ~
13 16
"13"" 16
13 16
13 16
13 16_
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16"
13 16
13" 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
10
10
13
13
17"
16
19
19
2l'
21
23
23
25"
25
26
26
28
28
29
29
"31
31
32
32
34
34
35
35
37
37
38
38
41
40
42
42
44
3
3
1
1
3
2
T
1
1
1
2
1
1
1
1
1
1
1
"1
1
1'
1
1
1
1
1
1
1
1"
1
1
1
3
1
1
1
1
1422
1332
1761"
5323
1050'
1282
1000
3051
" 1081
5730
1381
15514
244Q
6049
1845
2511
"4194
9184
10895"
10327
3081
6785
" 2103
1546
14688
1414
6470
4031
29505
9391
8482
4963
1001
2772
6581
3890
7641
223
219
222
221
220
222
219.0
222 .2
221'.4'
221.5
217.7
219.6
226.0
220,7
218 .0
222.2
218.8"
22Q.5
"220.6
219 .5
221.7"
221.8
222 ,
219
222
220
218
221.4
218 .3
218 .9
219.5
223.0
222.5
222.3
217.9
220.8
226.0
0
0
3"
11
O"
1
1.
6,
2
12
1,
33
"" 5^
12 .8
3.7
5.1
"~8".8
19.5
23 .3"
22 .0
" 6.4
14 .4
4.2
3
31
2
13
8
0
5
7
7
4
63.6
20.0
18.1
10 .4
0.4
5.7
13 . 9
8.1
16.2
0.1
0.1
673
1.1
0.5
1.3
0.4
°:5
079~
2.3
1.4
0.8
6.4
0.04
0.04
0.04
0 . 04
0,04
0.04
0". 04
0 . 04
0". 04
0 . 04
0 . 04"
04
04
04
04~
04
04"
04
0 .04
0.04
0~04"
0.Q4
0 . 04
0 . 04
0 ,"6 4
0 . 04
0.04
0 . 04
0 . 04
0.04
0.04
0 . 04
0.04
0,04
0 . 04
0 . 04
0 . 04
Page 1 of 3
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 13004.09
PILE: 2 BATCH: Q SURFACE: SOIL AIR TEMP MIN: 32°F
AREA: COVER DEPLOYED: 12 2 13 RETRIEVED: 12 3 13 CHARCOAL BKG:
FIELD TECHNICIANS: CS.DLC, TE COUNTED BY: DLC DATA ENTRY BY: DLC
COUNTING SYSTEM l.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
WEATHER NO RAIN
147 cpm WLOut 180.0 g.
TARE WEIGHT: 29.2 g.
LOCATION
SAMPLE DEPLOY RETRIV ANALYSIS
I. D. HR MIN HR MIN MO DA YR
MID-TIME
L .. Q38
Q39
Q40
Q41
Q42
Q43
Q44
Q45
Q46
Q47
Q48
Q49
Q5Q
Q51
Q52
Q53
Q54
Q55
Q56
Q57
Q58
Q59
Q60
Q61
Q62
Q63
Q64
Q65
Q66
Q67
Q68
Q69
Q70
Q71
Q72
073
Q74
Q38
Q39
Q4 0
Q41
Q42
Q43
Q44
Q45
Q4 6
Q47
Q48
Q49
Q5Q
Q51
Q52
Q53
Q54
Q55
Q56
Q57
Q58
Q59
Q60
Q61
Q62
Q63
Q64
Q65
Q66
Q67
Q68
Q69
Q70
Q71
Q72
Q73
Q74
42
43
44
46
48
50
51
52
53
54
55
56
57
58
59
0
1
2
4
5 "
6
7
8
8
9
10
11
12
13
14
15
17
17
18
19
20
20
42
43
44
45
46
4 7
48
49
50
51
52
53"
54
55
56
57
58
59
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12"
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
13 16
13 16"
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 16
13 17
13 17
13" 17
13 17
13 17
13 17
13" 17
13 17
13" 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
44
46
46
49
49
52"
51
56
56
59
58
2
2
3
3
~5
5
6
6
8
8
9
9
11
11
12
14
17
16
18
18
20
20
21
21
23
23
1
2
1
2
2
4
1
1
1
4
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
4
1
1
1
1
1
1
1
1
1
1
GROSS
COUNTS
8075
1209
23413
1284
1406
1203"
4062
32893
1788
1002
13267
" 4311
3660
" 4 614
1948
1Q00
1193
5525
24092
3922
7QQ4
3678
3317
2679
1567
1655
1281
7691
6384
19643
1369
2798
1141
10886
6618
5878
7173
GROSS RADON
220,
221.
220 ,
218,
223,
220 ,
221.
219
220.3
223.9
212 .6
220 .3
219.7
216 . 5
217 .4
216,3
219.4
218 .4
219 .2
224.0
221.7
0 . 04
0.04
0.04
0.04
WT IN pCi/m2s pCi/m2s pCi/m-'8 COMMENTS
218.6
214 .5
219.8
217.7
220.8
229.0
220.0
219.7
214.7
210.6
220.8
221.7
217.9
219.1
217.3
220 .8
17.1
1.0
50.3
1.1
1.2
"O.i"
8.5
71,1
3,
0
28
9"
7
9.7
3.9
" 1,9
2.3
11.7
51. 9
8,2"
14 .9
7
6
5
3
3
0
16 .4
13 .5
42 . 3
2 ,
5,
2
23
14
0.8
7.1
0.8
0.8
1.5
0.8
0.7
0.5
0.3
0.3
0.0
1.6
12 .4
15 .2
1.2
1.5
04
04
04
.04
0 .04
0.04
0.04
0 . 04
0,04
0.04
0.04
0.04
0.04
0.04
0 .04
0.04
0 .04
0 . 04
0.04
0 . 04
0.04
0.04
0 .04
0 ,04
Q . 04
0 . 04
0 .04
0,04
0.04
0.04
0.04
0.04
0.04
Page 2 of 3
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 13004.09
PILE: 2 BATCH: Q SURFACE: SOIL
AREA: COVER DEPLOYED: 12 2 13 RETRIEVED:
FIELD TECHNICIANS- CS.DLC, TE COUNTED BY: DLC
COUNTING SYSTEM l.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN:32°F
12 3 13 CHARCOAL BKG:
DATA ENTRY BY: DLC
WEATHER: NO RAIN
147 cpm WtOut: 180.0 g.
TARE WEIGHT: 29.2 g.
LOCATION
Q75
Q76
Q77
Q78_
Q79
Q80
Q81 "
Q82
Q83
Q84
Q8 5
Q86
Q87
Q88
"Q89
Q90
Q91
Q92
Q93
Q94
Q95
Q96
Q91
Q98
Q99
QlOO
DEPLOY RETRIV ANALYSIS MID-TIME
HR MIN HR MIN MO DA YR HR MIN COUNTS WT IN pCi/m2s pCi/m2s pCi/m2s COMMENTS
Q75
Q76
Q77
Q78
Q79
Q80
Q81
Q82
Q83
Q84
Q85
Q86
Q87
Q88
Q89 ~
Q9Q
Q91
Q92
Q93
Q94
Q95
Q96
Q97
Q98
Q99
QlOO
21
23
27
28
29
32
35
36
37
38
39
40
41
42
43"
44
45
46
47
47
4 8
49
50
51
52
52
19
20
33
34
3 5
36
"37"
38
3 9
40
41
42
43
44
45
46
47
48
~49
50
51
52
53
54
55
56
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 17
13 "lY
13 17
13 17
13 17
13 17
13 17
13" 17
13 17
13 17
13 17
13 17
13 17
24
24
27"
27
29"
30
33
33
34
34
36
36
37
37
39
40
42
42
43
44
46
47
50
50
54
53
1 1251
1 1015
3 "" 1147
3 1433
1 " 1013
3 1224
1 2126
1 6947
1 " 3337
1 1203
1 " 1782
1 2522
1 1957
1 _JS068
1 11784
2 1624
1 1065
1 3506
1 1834
2 1677
2 " 1112
4 1002
1 1082
2 1475
4 1168
2 1878
219.2
220.7
223.4
224.8
219.5
219 .8
220 .3
218.9
217.8
223 .7
22Q
215
218
221
218.2
215.7
222 .7
218 . 9
220 .4
221.8
221.9
221
222
223
220
221
2
1
0
0
" 1
0
4
14
6
2
3
5
3
12.8
25.1
1.4
2.0
1.3
2.5
0 . 04
0 . 04
0 . 04
0 , 04
0 . 04
0^04
0 . 04
0.04
0.04
0.04
0 .04
0 .04
0.04
0.04
6.04
0.04
0~04
0.04
04
04 20' W
0.2
0.1
0.0
0.2
0.04
0.04
0.04
0.04
0 . 04
0 . 04
AVERAGE RADON FLUX RATE FOR THE CELL 2 COVER REGION: 10 . 0 pCi/m2 s
"MIKI
BLANK CANISTER ANALYSIS'
LOCATION
Q BLANK 1
Q BLANK 2
Q" BLANK 3
Q BLANK 4
Q BLANK. 5
SAMPLE
Q BLANK 1
Q BLANK 2
Q BLANK 3
Q BLANK 4
Q BLANK 5
RETRIV ANALYSIS MID-TIME
HR MIN HR MIN MO DA YR
51
51
51
51
51
32
32
33
33
33
12
12
12
12
12
13
13
13
13
13
14
14
14
14
14
28
28
40
40
52
10
10
10
10
10
GROSS
COUNTS
1478
1395
1529
1454
1588
GROSS
210.9
208.1
212.9
209.9
210.2
71.1 MAX
RADON
pCi/m2s pCi/m2s pCi/m2s COMMENTS
0 .00
-0.01
0 .01
0 .00
0.02
0,03
0.03
0 .03
0 .03
0.03
0,04
0.04
0 . 04
0 . 04
0.04
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
AVERAGE BLANK CANISTER ANALYSIS FOR THE CELL 2 COVER REGION;
Page 3 of 3
0.00 pCi/m2s
Appendix D
Sample Locations Map (Figure
D
0 D. -CELLI
7-
Q17 oi
Q25 Q2« Q27 Q26 •37 Q36
Q54 Q55 044 045
3 069 Q6B
~CELL3~
-CELL4B-
-CELL4A
WHITE MESA MILL
BLANDING. UTAH
NESHAPS 2013
DECEMBER 2013
PREPARED FOR
ENERGY FUELS RESOURCES
FIGURE 2
N
t SCALE IN FEET
200 100 0 200 400
nuco
ENVIRONMENTAL, LLC
THIS DRAWING IS THE PROPERTY OF TELLCO ENVIRONMENTAL, LLC AND IS NOT TO BE REPRODUCED MODIFIED OR USED FOR ANY OTHER PROJECT OR EXTENSION OFTHIS PROJECT EXCEPT BY AGREEMENT WITH TELLCO