DRC-2014-001882 - 0901a068804081c2

ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www energyfuels com
Mr. Rusty Lundberg
Director
Division of Radiation Control
February 19,2014
VIA OVERNIGHT DELIVERY DRC-201 4-001 882
Utah Department of Environmental Quality
195 North 1950 West
RO. Box 144850
Salt Lake City, UT 84114-4820
Re: Submittal of Radiological Characterization of Sewage at White Mesa Mill
Notice of Violation - Radioactive Materials License Number UT1900479
Dear Mr. Lundberg:
This letter provides Energy Fuels Resources (USA) Inc.'s ("EFRI's") follow-up to our letter of September
20, 2013 regarding a Notice of Violation received as a result of Utah Division of Radiation Control's
("DRC's") June 13,2013 inspection at the White Mesa Mill.
Utah DRC performed an inspection of the White Mesa Mill (the "Mill") on June 13, 2013. The inspection
resulted in DRC's issuance of a Notice of Violation ("NOV") which was received by EFRI on July 8,2013.
The NOV listed two violations of the Utah Radiation Control Rules. Violation 1, regarding documentation
of delivery driver training, was fully addressed in EFRI's letter of August 6, 2013. DRC confirmed in a
letter dated August 22, 2013, that EFRI's response to Violation 1 was satisfactory. Correspondence related
to Violation 2 is discussed and surnmarized below.
During the June 13, 2013 inspection, DRC's inspector reviewed documentation indicating that a vacuum
truck collected sewage from the Office Building Sewage Vault (the "admin Vault") on March 1, 2013 for
off-site release to the Blanding municipal sewage plant. The Admin Vault receives wastes from the main
office area which is outside the Mill's restricted area boundary; however, the vault itself is within the
restricted area boundary. The March 1, 2013 event was the first time in the history of the Mill that the
Admin Vault had been pumped out. The records reviewed by the inspector stated that the sewage truck was
surveyed for dose rate prior to release for off-site transfer of the material; however the sewage material was
not sampled for radiological characterization.
EFRI initially requested, in the letter of August 6, 2013, that Violation 2 be rescinded. The letter provided
technical rationale why the Admin Vault would not contain radionuclides of concern at levels above the
permissible limit for releases of uranium to sewers Usted in 10 CFR 20 Appendix B, Table 3. Mr. Phil
Goble and Mr. Kevin Carney of DRC discussed the letter with EFRI during a telephone conference on
August 19, 2013. As a result of that telephone conversation, EFRI withdrew its contention that Violation 2
should be rescinded, and agreed to provide sampling and analysis of the radionuclide content of the Admin
Background
•
Letter to R. Lundberg
February 19, 2014
Page 2 of 4
Vault to confirm that the vault contents complied with the limits in 10 CFR 20 Appendix B Table 3 for the
radionuclides of concern at the Mill.
Subsequent to the phone call, DRC provided a letter on August 22, 2013, requiring EFRI to prepare a
written response including the root cause analysis and description and timing of the agreed-upon corrective
actions to address Violation 2. EFRI provided this response in a letter of September 20, 2013, which
committed to three corrective steps to address the non-compliance and prevent a recurrence, as follows:
1. Addition of language to the Mill's Radiation Protection Manual, Section 2.7, requiring that prior to
off-site shipment of any sewage or recyclable fluids from the Mill, samples will be collected and
analyzed for radionuclide content.
2. Sampling of all four sewage vaults on site and storage of current radiological characterization data
for sewage at the Mill, in the event that any sewage vault needs to be pumped out in the future. The
sampling of the Admin Vault would confirm that the sewage released off site on March 1, 2013
complied with the requirements of 10 CFR 20. Sampling of the other vaults would provide data
necessary to determine whether the contents of these vaults, if they were to be pumped out, could
be shipped off site or would need to be managed and disposed on site.
3. Re-education of the Mill Manager, Environmental Manager, RSO, and radiation technicians,
regarding the need for radiological characterization of materials leaving the Mill's restricted area.
As discussed in EFRI's letter of September 20, 2013, corrective steps 1 and 3, above, were completed
during September of 2013. The remainder of this letter demonstrates that since the submittal of the
September 20 2013 letter, EFRI has completed corrective step 2, and has confirmed that that the material
released on March 1, 2013 was in compliance with the limits in 10 CFR 20 Appendix B Table 3 for the four
radionuclides of concern at the Mill.
Field Sampling Program
On October 3, 2013, the Mill conducted sampling of the following sources of sewage that could potentially
be released from the Mill site:
Sample Number Sample Location
001 Admin Vault
002 CCR Vault
003 Change Room Vault
004 Scale House Vault
To sample each of the four sewage vaults, Mill personnel entered each vault and stirred the contents to
produce a homogenous sample. Mill personnel then collected a sample from the vault by use of a specially
rigged dipper.
One method blank, one sample duplicate (of the Admin Vault) and one laboratory control sample were
prepared and analyzed by the contract laboratory. Sample handling followed the same chain of custody
procedures used for other types of sampling conducted pursuant to the Mill's Radioactive Materials
License.
2
Letter to R. Lundberg
February 19, 2014
Page 3 of4
Analytical Methodology
Soil samples were analyzed by a third party contract laboratory, GEL Laboratories LLC ("GEL").
As discussed with Kevin Carney of DRC on September 16, 2013, EFRI agreed to have samples analyzed
for the same four radionuclides of concern as monitored and reported in the Mill's Semi-Annual Effluent
Report, specifically:
• Pb-210
• Ra-226
• Th-230
• U-nat
The laboratory was required to provide limits of detection equal to or lower than the limits for each
radionuclide as listed in 10 CFR 20 Appendix B Table 3. Table 3 specifies monthly average concentration
limits for releases to sewers.
Results and Conclusions
Attachment 1 of this letter provides a comparison of the laboratory analytical to the limits in 10 CFR 20
Appendix B Table 3. Analytical data package from GEL is provided in Attachment 2. The results are
summarized and discussed below.
Admin Vault
Each of the four radionuclides of concern was below its respective detection limit in the Admin Vault
sample. Assuming that the sample collected on October 3, 2013 is representative of the sewage that was
collected in the Admin Vault from the Mill's inception until the vacuum truck emptied it for the first time
on March 1, 2013, these results confirm that the material released from the Mill on March 1, 2013 complied
with the limits in 10 CFR 20 Appendix B.
CCR Vault
Pb-210 and Ra-226 in the CCR Vault sample each exceeded their respective limits in 10 CFR 20 Appendix
B. All other radionuclides analyzed were below their respective detection limits.
Change Room Vault
Pb-210 and Th-230 in the Change Room Vault sample each exceeded its respective limit in 10 CFR 20
Appendix B. All other radionuclides analyzed were below their respective detection limits.
Scale House Vault
Each of the four radionuclides of concern was below its respective detection limit in the Scale House Vault
sample. Theoretically, if this vault needed to be pumped out, its contents could be released for off-site
transfer to the Blanding sewage plant.
3
Letter to R. Lundberg
February 19,2014
Page 4 of 4
Proposed Management of Analyzed Materials
Based on the analytical results discussed above, the contents of both the Admin Vault, which were released to
the municipal sewage plant on March 1, 2013 and the Scale House Vault, which were not released and do not
require release at this time, comply with the requirements in 10 CFR 20 Appendix B to be released to municipal
sewer systems. As discussed above, the contents of the CCR Vault and Change Room Vault exceeded the
acceptable limits for discharge to municipal sewers at this time, based on the October 2013 sampling event. The
contents of these two vaults have never been pumped for release off site and do not require removal at this time.
EFRI proposes to manage sewage vault contents as follows. The Mill will sample and analyze sewage vault
contents for radionuclide concentrations once every two years or prior to pumping of a sewage vault as needed.
The resulting radiological characterization data will be used to determine whether the pumped material will be
managed on site in the Mill's tailings system or released to the municipal sewage plant. Current
characterization data will be maintained at the Mill for DRC review.
If a sewage vault requires pumping or removal of its contents, EFRI will evaluate the most current data for that
vault. If each of the four radionuclides of concern is present at levels below the limit in 10 CFR 20 Appendix B
for sewer discharge, EFRI may choose to ship the material off site to the Blanding municipal sewage plant. If
any of the four radionuclides of concern exceeds its limit in 10 CFR 20 Appendix B, the sewage vault materials
will be managed on site. The sewage materials will be transferred into steel or plastic drums, which will be
sealed and transferred to the tailings system for on-site disposal. Sewage will be disposed in the tailings cell or
cells currently approved for disposal of Mill waste. Drums of sewage will be disposed consistent with the
currently approved version of the Mill Waste Disposal SOP, PBL-7, to ensure protection of the liner of the cell
in which it is placed.
In addition, prior to any off-site shipment of recyclable fluids from the Mill, appropriate surveys and/or analysis
will be performed to assure that applicable release standards are met.
Achievement of Full Compliance Relative to the NOV
As discussed with DRC on the phone call of August 19, 2013 and in a subsequent meeting on November
12, 2013, submittal of the analytical characterization data accompanying this letter completes the corrective
action steps required to achieve full compliance with requirements applicable to the sewage release.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
cc: Kevin Carney, Utah DRC
David C. Frydenlund
Philip Goble, Utah DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Attachments
4
ATTACHMENT 1
SUMMARY OF SEWAGE SAMPLE RESULTS
AND
RELEASE LIMITS
10 CFR 20 Appendix B
Release Limits
Appendix B Table 3 Monthly Average Concentration Limits for Releases to Sewers
Isotope
Release Limit
(uCi/ml)
Sample 01 Admin
Vault (uCi/ml)
Sample 02 CCR Vault
(uCi/ml)
Sample 03 Change
Room Vault
(uCi/ml)
Sample 04 Scale
House Vault
(uCi/ml)
Pb-210 1.0E-07 ND 4.80E-07+/-3.73E-08 1.09E-06+/-3.95E-08 ND
Ra-226 6.0E-07 ND 6.22E-07+/-1.06E-07 ND ND
Th-230
U-235/236
U-238
1.0E-06
3.0E-06
3.0E-06
ND
ND
ND
ND
ND
ND
1.30E-06+/-4.51E-08
ND
ND
ND
ND
ND
NOTE:
ND indicated that the analyte was not detected at the required reporting limit.
Entries on this page flagged as "ND" were flagged with the data qualifier "U" in the data package
from GEL Laboratories.
ATTACHMENT 2
GEL ANALYTICAL DATA PACKAGE
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www gel com
Certificate of Analysis Report Date: February 18,2014
Company
Address :
Contact:
Project:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Admin Vault
335208001
Misc Liquid
03-OCT-13 09:25
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
Parameter Qualifier Result Uncertainty MDC RL Units DF Analyst Date Time Batch Method
lad Alpha Spec Analysis
Mphaspec Th, Liquid "As Received"
rhonum-230 U -7 01E-10 +/-3.16E-09 1 45E-08
Mphaspec U, Liquid "As Received"
Jramum-235/236 U -3 98E-10 75E-09
Jramum-238 U 1 72E-09 +/-2 41E-09
lad Gas Flow Proportional Counting
3FPC, Pb210, Liquid "As Received"
xad-210 U 8 83E-08 +/-2 94E-08
lad Radium-226
^ucas Cell, Ra226, liquid "As Received"
ladium-226 U 2 44E-07 +/-9 55E-08
The following Analytical Methods were performed:
7 95E-09
8 19E-09
9.02E-08
2 82E-07
1 00E-06
3 00E-06
3.00E-06
1.00E-07
6 00E-07
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
JXH2 10/25/13 1101 1338432 1
JXH2 10/24/13 1014 1338429 2
KDF1 11/06/13 0955 1338156 3
KSD1 10/28/13 2035 1338764 4
Method Description Analyst Comments
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903 1 Modified
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
rhonum-229 Tracer
Jramum-232 Tracer
^ead Carrier
Alphaspec Th, Liquid "As Received"
Alphaspec U, Liquid "As Received"
GFPC, Pb210, Liquid "As Received"
84 6
108
92 5
(15%-125%)
(15%-125%)
(25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
5RL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
lie greater of either the adjusted MDL or the CRDL.
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www.gel com
Certificate of Analysis ReportDate: February 18,2014
Company
Address:
Contact:
Project:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
CCR Vault
335208002
Misc Liquid
03-OCT-13 09:45
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
Parameter Qualifier Result Uncertainty MDC RL Units DF Analyst Date Time Batch Method
lad Alpha Spec Analysis
Mphaspec Th, Liquid "As Received"
rhonum-230 U 4 80E-07 +1-2 90E-08
Alphaspec U, Liquid "As Received"
Jramum-235/236 U 8.84E-08 15E-08
Jraruum-238 U 1 69E-06 +/-4 48E-08
lad Gas Flow Proportional Counting
JFPC, Pb210, Liquid "As Received"
.ead-210 4 80E-07 +/-3 73E-08
lad Radium-226
^ucas Cell, Ra226, liquid "As Received"
tadium-226 6 22E-07 06E-07
The following Analytical Methods were performed:
1 15E-08
8 09E-09
8 74E-09
5 32E-08
2 19E-07
1 00E-06
3 00E-06
3 00E-06
1 00E-07
6.00E-07
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
JXH2 10/25/13
JXH2 10/24/13
1101 1338432 1
1014 1338429 2
KDF1 11/06/13 0934 1338156
KSD1 10/28/13 1400 1338764
Vlethod Description Analyst Comments
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903 1 Modified
Jurrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
rhonum-229 Tracer
Jramum-232 Tracer
^ead Carrier
Alphaspec Th, Liquid "As Received"
Alphaspec U, Liquid "As Received"
GFPC, Pb210, Liquid "As Received"
84 1
97 3
98 5
(15%-125%)
(15%-125%)
(25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
SRL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
lie greater of either the adjusted MDL or the CRDL.
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www gel com
Certificate of Analysis Report Date: February 18,2014
Company:
Address:
Contact:
Project:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Change room Vault
335208003
Misc Liquid
03-OCT-13 09:55
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
Parameter Qualifier Result Uncertainty MDC RL Units DF Analyst Date Time Batch Method
1 84E-08
8 40E-09
7.33E-09
lad Alpha Spec Analysis
Alphaspec Th, Liquid "As Received"
rhonuro-230 1 30E-06 +/-4 51E-08
Mphaspec U, Liquid "As Received"
Jramum-235/236 U 6 78E-08 +/-9.85E-09
Jranium-238 U 140E-06 +/-3.95E-08
lad Gas Flow Proportional Counting
3FPC, Pb210, Liquid "As Received"
.ead-210 1.09E-06 +/-5 46E-08 619E-08
lad Radium-226
.ucas Cell, Ra226, liquid "As Received"
ladium-226 U 5 60E-07 +/-1.19E-07
The following Analytical Methods were performed:
1 00E-06
3 00E-06
3 00E-06
1 OOE-07
2 60E-07 6 OOE-07
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
JXH2 10/25/13
JXH2 10/24/13
1102 1338432 1
1014 1338429 2
KDF1 11/06/13 0935 1338156
KSD1 10/28/13 1400 1338764
Method Description Analyst Comments
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903.1 Modified
surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
rhonum-229 Tracer
Jramum-232 Tracer
.ead Carrier
Alphaspec Th, Liquid "As Received"
Alphaspec U, Liquid "As Received"
GFPC, Pb210, Liquid "As Received"
95 9
103
99 8
(15%-125%)
(15%-125%)
(25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
SRL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
he greater of either the adjusted MDL or the CRDL.
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www gel.com
Certificate of Analysis Report Date: February 18, 2014
Company:
Address:
Contact:
Project:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado 80228
Ms. Kathy Weinel
Sewage Sample Analysis
Client Sample ID:
Sample ID:
Matrix:
Collect Date:
Receive Date:
Collector:
Scale house Vault
335208004
Misc Liquid
03-OCT-13 10:15
09-OCT-13
Client
Project:
Client ID:
DNMI00108
DNMI001
Parameter Qualifier Result Uncertainty MDC RL Units DF Analyst Date Time Batch Method
lad Alpha Spec Analysis
\lphaspec Th, Liquid "As Received"
rhonum-230 U 1.17E-08 +/-5 00E-09
Vlphaspec U, Liquid "As Received"
Jranium-23 5/236 U 7 20E-10 +/-2 04E-09
Jraruum-238 U 1 48E-09 +1-2 37E-09
lad Gas Flow Proportional Counting
3FPC, Pb210, Liquid "As Received"
.ead-210 U 3 10E-08 +1-2 01E-08
lad Radium-226
^ucas Cell, Ra226, liquid "As Received"
ladium-226 U 3 26E-07 +/-1.10E-07
The following Analytical Methods were performed:
1 13E-08
7 67E-09
8 68E-09
6 68E-08
1 00E-06
3 00E-06
3 00E-06
1 OOE-07
3 09E-07 6 OOE-07
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
JXH2 10/25/13
JXH2 10/24/13
1102 1338432 1
1014 1338429 2
KDF1 11/06/13 0936 1338156
KSD1 10/28/13 1400 1338764 4
Method Description Analyst Comments
DOE EML HASL-300, Th-01-RC Modified
DOE EML HASL-300, U-02-RC Modified
DOE RP280 Modified
EPA 903.1 Modified
surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
rhonum-229 Tracer
Jranium-232 Tracer
^ead Carrier
Alphaspec Th, Liquid "As Received"
Alphaspec U, Liquid "As Received"
GFPC, Pb210, Liquid "As Received"
91 2
97 7
102
(15%-125%)
(15%-125%)
(25%-125%)
Votes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma).
SRL = Sample Reporting Limit. For metals analysis only. When the sample is U qualified and ND, the SRL column reports the value which is
lie greater of either the adjusted MDL or the CRDL.
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www gel com
Contact:
Workorder:
Energy Fuels Resources (USA), Inc.
225 Union Boulevard
Suite 600
Lakewood, Colorado
Ms. Kathy Weinel
335208
QC Summary Report Date: February 18,2014
Page 1 of
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Pate Time
Rad Alpha Spec
3atch 1338429
QC 1202966026 335208001 DUP
Uranium-235/236
Uranium-238
QC 1202966027 LCS
Uranium-235/236
Uranium-238
QC 1202966025 MB
Uranium-235/236
Uranium-238
3atch 1338432
QC1202966029 335208001 DUP
Thonum-230
QC1202966030 LCS
Thonum-230
QC 1202966028 MB
Thorium-230
Rad Gas Flow
Batch 1338156
QC1202965399 335208001 DUP
Lead-210
QC 1202965400 LCS
Lead-210
QC 1202965398 MB
Lead-210
Rad Ra-226
Batch 1338764
QC 1202966807 335208001 DUP
Radium-226
QC 1202966809 LCS
U -3 98E-10 U 2 37E-09
Uncertainty +/-1.75E-09 +1-2 77E-09
U 1 72E-09 U 4.43E-09
Uncertainty +/-2.41E-09 +/-2.86E-09
Uncertainty
5.41E-07
Uncertainty
Uncertainty
Uncertainty
U 1 36E-08
+/-4 93E-09
U 6.27E-07
+1-2 81E-08
U 8 98E-10
+/-2.96E-09
U 6.54E-09
+/-3.50E-09
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
uCi/mL
N/A
N/A
N/A JXH2 10/24/13 10 1
N/A
10/24/13 10.1
116 (75%-125%)
10/24/13 10:1
U -7.01E-10 U 3.74E-09
Uncertainty +/-3.16E-09 +/-3.39E-09
4.28E-07
Uncertainty
Uncertainty
U 4.58E-07
+/-2.73E-08
U 1.92E-09
+/-3 61E-09
uCi/mL N/A
uCi/mL
N/A JXH2 10/25/13 11 C
107 (75%-125%)
uCi/mL
10/25/13 11 :C
10/25/13 1 l.C
U 8.83E-08 U 3.95E-08
Uncertainty +/-2.94E-08 +/-1.67E-08
0.000297
Uncertainty
Uncertainty
0.000268
+1-6 72E-07
U 5.11E-09
+/-9.09E-09
uCi/mL N/A
uCi/mL
N/A KDF1 11/06/13 09.2
90.3 (75%-125%)
uCi/mL
11/06/13 09:f
11/06/13 09.:
U 2.44E-07 U 2.12E-07
Uncertainty +/-9 55E-08 +1-9 34E-08
uCi/mL N/A N/A KSD1 10/28/13 21-1
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www gel.com
Workorder: 335208
QC Summary
Page 2 of
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Pate Time
Rad Ra-226
3atch
Radium-226
1338764
QC 1202966806
Radium-226
MB
QC 1202966808 335208001 MS
Radium-226
1.76E-06
Uncertainty
Uncertainty
1.23E-05 U 2.44E-07
Uncertainty +/-9.55E-08
U
1.60E-06
+1-6 01E-08
2.18E-08
+/-1.21E-08
1 13E-05
+/-4 35E-07
uCi/mL
uCi/mL
uCi/mL
90 5 (75%-125%)
91 9 (75%-125%)
10/28/13 14 3
KSD1 10/28/13 14:0
10/28/13 14.3
Notes:
Counting Uncertainty is calculated at the 68% confidence level (1-sigma)
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
Result is less than value reported
Result is greater than value reported
The TIC is a suspected aldol-condensation product
For General Chemistry and Organic analysis the target analyte was detected in the associated blank.
Results are either below the MDC or tracer recovery is low
Analyte has been confirmed by GC/MS analysis
Results are reported from a diluted aliquot of the sample
Estimated Value
Analytical holding time was exceeded
Analyte present Reported value may be biased high. Actual value is expected to be lower
Analyte present Reported value may be biased low. Actual value is expected to be higher.
M if above MDC and less than LLD
Matrix Related Failure
N/A RPD or %Recovery limits do not apply.
Nl See case narrative
Analyte concentration is not detected above the detection limit
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
One or more quality control cntena have not been met. Refer to the applicable narrative or DER.
Sample results are rejected
Analyte was analyzed for, but not detected above the CRDL.
Gamma Spectroscopy-Uncertain identification
Gamma Spectroscopy-Uncertain identification
Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.
Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier
QC Samples were not spiked with this compound
<
>
A
B
BD
C
D
F
H
K
L
M
M
ND
NJ
Q
R
U
UI
UJ
UL
X
Y
GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407 - [phone] - www.gel.com
QC Summary
Workorder: 335208 Page 3 of
Parmname NOM Sample Qual Units RPD% REC% Range Anlst Date Time
A RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL Qualifier Not Applicable for Radiochemistry
h Preparation or preservation holdmg time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike cone by a factor of 4 or more.
A The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance cntena when the sample is greater than
five times (5X) the contract required detection limit (RL) In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/- the
RL is used to evaluate the DUP result.
* Indicates that a Quality Control parameter was not within specifications.
For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.
Where the analytical method has been performed under NELAP certification, the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Energy Fuels Resources (USA), Inc.
Sewage Sample Analysis
SDG: 335208
This data package was revised to report sample "used oil storage" under a separate SDG.
Receipt Narrative
for
Energy Fuels Resources (USA), Inc.
SDG: 335208
February 18,2014
Laboratory Identification:
GEL Laboratories LLC
2040 Savage Road
Charleston, South Carolina 29407
[phone]
Summary:
Sample receipt: The samples arrived at GEL Laboratories LLC, Charleston, South Carolina on October 09,
2013 for analysis. The samples were delivered with proper chain of custody documentation and signatures. All
sample containers arrived without any visible signs of tampering or breakage. There are no additional comments
concerning sample receipt.
Sample Identification: The laboratory received the following samples:
Case Narrative:
Sample analyses were conducted using methodology as outlined in GEL's Standard Operating Procedures. Any
technical or administrative problems during analysis, data review, and reduction are contained in the analytical
case narratives in the enclosed data package.
The enclosed data package contains the following sections: Case Narrative, Chain of Custody, Cooler Receipt
Checklist, Data Package Qualifier Definitions and data from the following fractions: Radiochemistry.
335208001
335208002
335208003
335208004
Laboratory ID Client ID
Admin Vault
CCR Vault
Change room Vault
Scale house Vault
Heather Shaffer
Project Manager
Page
Project*:
GEL Quote # _
COC Number*0
PO Number
of
GEL Chain of Custody and Analytical Request
GEL Work Order Number; -?3^^L6cf
GEL Laboratories, LLC
2040 Savage Road
Charleston, SC 29407
Phone [phone]
Fax [phone]
Client Name-Phone# M?$-&7b-2ZZI Sampie Analysis Requested (5) (Fill in the number of containers for each test)
Project/Site Name U 5e^ipW^ Fax#: 1/3$ 'GslQ-Zzz^
Address 0Q
Should this
sample be
considered*
Collected by. Send Results To ty^fr lU-lc / \jj2^\
Sample ID
* For composites - indicate start and stop date/time
•Date Collected
(mm-dd-yy)
•Time
Collected
(Military)
(hhmm)
QC Code Held
Filtered (J)
Sample
Matrix w
•4-3
— Preservative Type (6)
Comments
Note- extra sample is
required for sample
specific QC
y y y
3/w
^7
/
^CCvV^ Kov^g /
TAT Requested. Normal Rush: Specify- (Subject to Surcharge) Fax Results1 Yes / No Circle Deliverable C of A / QC Summary / Level 1 / Level 2 / (teveT^1 / Level 4
Remarks: Are there any known hazards applicable to these samples9 If so, please list the hazards Sample Collection Time~Zone
Eastern Pacific
Central Other _
(^Mountain*""-
Chain of Custody Signatures Sample Shipping and Delivery Details
Rehnodtehed By (Signed) Date Time
iidO
Received by (signed) Date Time GEL PM
Method of Shipment Date Shipped
Airbill ti
Airbill U
1 ) Chain of Custody Number = Client Determined
2 ) QC Codes N = Normal Sample.TB = Trip Blank, FD = Field Duplicate, EB = equipment Blank. MS = Matrix Spike Sample, MSD = Matrix Spike Duplicate Sample, C = Grab, C •= Composite
3 ) Field Filtered For liquid matrices, indicate with a - Y - lor yes the sample was field filtered or - N - tor sample was not field filtered
4 ) Matrix Codes DW=Dnnking Water, CW=Groundwater, SW=Surface Water. WW=Waste Water. W=Water, SO=Soil, SD=Sedimeiv. SL=Sludge. SS=Solid Waste. OOil F=Filter, P=Wipe. U=Unne. F=Fecal N=Nasal
5 ) Sample Analysis Requested Analytical method requested (i e 8260B. 6010B/7470A) and number of containers provided for each (i e 8260B - 3. 60I0B/7470A -1)
6 ) Preservative Type HA = Hydrochloric Acid. Nl = Nunc Acid, SH = Sodium Hydroxide, SA = Sulfuric Acid. AA = Ascorbic Acid, HX = Hexane, ST = Sodium Thiosulfatc, If no preservative is added = leave field blank
. WHITE • LABORATORY YELLOW = FILE PINK = CLIENT
For Lab Receiving Use Only
Custody Seal Intact7
YES NO
Cooler Temp
C
GEL Laboratories LLC SAMPLE RECEIPT & REVIEW FORM
Client: SDG/AR/COC/Work Order: t&frflJL X
Received By; C^P Date Received: \f\ -C^j - f ^
Suspected Hazard Information
, Maximum Net Counts Observed* (Observed Counts - Area Background Counts): £f) Vfj
fyes Were swipes taken of sample contadners < action levels? I
"'If Net Counts > lOOcpm on samples not marked "radioactive", contact the Radiation Safety Group for further
investigation.
COC/SampIes marked as radioactive?
Classified Radioactive II or III by RSO?
COC/Samples marked containing PCBs?
Package, COC, and/or Samples marked as
beryllium or asbestos containing? [f yes, samples are to be segregeated as Safety Controlled Samples, and opened by the GEL Safety Group.
Shipped as a DOT Hazardous? Hazard Class Shipped: UN#:
Samples identified as Foreign Soil?
Sample Receipt Criteria Comments/Qualifiers (Required for Non-Conforming Items)
Shipping containers received intact
and sealed?
Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
Preservation Method: Ice bags Blue ice Dry ice / None J Other (describe)
*all temperatures are recorded in Cfetstmr Samples requiring cold preservation
within (0< 6 deg. C)7»
2a Daily check performed and passed on
IR temperature gun?
Temperature Device Serial #: 12 A^CO^HLP \
Secondary Temperature Device Seri^^fApplicaWe):
Chain of custody documents included
with shipment?
Sample containers intact and sealed?
Circle Applicable:
Seals broken Damaged container Leaking container Other (describe)
Samples requiring chemical
preservation at proper pH?
Sample ID's, containers affected and observed pH:
If Preservation added. Lot#:
VOA vials free of headspace (defined
as < 6mm bubble)?
Sample ID's and containers affected:
Are Encore containers present?
£Jf yes, i immediately deliver to Volatiles laboratory)
Samples received within holding
time?
ID's and tests affected:
Sample ID's on COC match ID's on
bottles?
Sample ID's and containers affected:
10 Date & time on COC match date &
time on bottles?
Sample ID's affected:
11 Number of containers received match
number indicated on COC?
Sample ID's affected:
12 Are sample containers identifiable as
GEL provided?
13 COC form is properly signed in
relinquished/received sections?
Circle Applicable:
FedEx Air FedEx Ground f UPS J Field Services Courier Other
14 Carrier and tracking number.
Comments (Use Continuation Form if needed):
PM (or PMA) review: Initials Date /0-4f-/3 Page (_of I
GEL Laboratories LLC - Login Review Report
GEL Work Order/SDG: 335208
Client SDG:
Project Manager:
Project Name:
Purchase Order:
Package Level:
EDD Format:
335208
Heather Shaffer
DNMI00108 Sewage Sample Analysis
DW16138
LEVEL3
EIM DNMI
Work Order Due Date: 07-NOV-13
Package Due Date:
EDD Due Date:
Due Date:
HXS1
04-NOV-13
07-NOV-13
07-NOV-13
Report Date:18-FEB-14
Work Order: 335208
Page 1 of 4
Collector: C
Prelogin #: 20131009001
Project Workdef ID: 1330620
SDG Status: Closed
Logged by:
GEL ID Client Sample ID Client Sample Desc.
Collect
Date & Time
Receive Time # of
Date & Time Zone Cont.
Lab Fax Days to Prelog Lab Field
Matrix Due Date Process CofC # Group QC QC
335208001 Admin Vault
335208002 CCR Vault
335208003 Change room Vault
335208004 Scale house Vault
335208005 used oil storage
03-OCT-13 09 25 09-OCT-13 09 05 -2 2 MISC LIQUID
03-OCT-13 09 45 09-OCT-13 09 05 -2 2 MISC LIQUID
03-OCT-13 09 55 09-OCT-13 09-05 -2 2 MISC LIQUID
03-OCT-131015 09-OCT-13 09 05 -2 2 MISC LIQUID
03-OCT-1310 25 09-OCT-13 09 05 -2 1 MISC LIQUID
21
21
21
21
21
Client Sample ID Status Tests/Methods
Product
Reference Fax Date PM Comments Aux Data
Receive
Codes
-001 Admin Vault
-002 CCR Vault
-003 Change room Vault
-004 Scale house Vault
-005 used oil storage
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Sewage Solid
REVW Alphaspec U, Liquid Sewage Solid
REVW GFPC, Pb210, Liquid Sewage Solid
REVW Lucas Cell, Ra226, liquid Sewage Solid
REVW Alphaspec Th, Liquid Waste Oil
REVW Alphaspec U, Liquid Waste Oil
REVW GFPC, Pb210, Liquid Waste Oil
REVW Lucas Cell, Ra226, liquid Waste Oil
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
limited volume; must run as
liquids and meet client DLs
Cooler Seal Undisturbed y
Temperature (C) 18
Cooler Seal Undisturbed y
Temperature (C) 18
Cooler Seal Undisturbed y
Temperature (C) 18
Cooler Seal Undisturbed y
Temperature (C) 18
Cooler Seal Undisturbed y
Temperature (C) 18
GEL Laboratories LLC - Login Review Report
Product: ASP_THL WorkdefID: 1331646 In Product Group? No
Method: DOE EML HASL-300, Th-01 -RC Modified
Product Description: Alphaspec Th, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Group Name:
Client RDL or
PQL & Unit
Group Reference:
Report Date:18-FEB-14
Work Order: 335208
Page 2 of 4
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received-
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
14269-63-7 Thonum-230 .0000001 uCi/mL REG No
Product: ASP_UUL WorkdefID: 1331647 In Product Group? No
Method: DOE EML HASL-300, U-02-RC Modified
Product Description: Alphaspec U, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Group Name:
Client RDL or
PQL & Unit
Reporting
Units
Group Reference:
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? in QC? List?
15117-96-1/13982- Uranium-235/236
7440-61-1 Uranium-238
.0000003
.0000003
uCi/mL
uCi/mL
REG
REG
No
Product: GFC PBL WorkdefID: 1331648
Method: DOE RP280 Modified
Product Description: GFPC, Pb210, Liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS# Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Reporting
Units
Group Reference:
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? in QC? List?
14255-04-0 Lead-210 .00000001 uCi/mL REG No
Product: LUC26RAL WorkdefID: 1331649
Method: EPA 903 1 Modified
Product Description: Lucas Cell, Ra226, liquid
Samples: 005
Parmname Check: All parmnames scheduled properly
CAS # Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Reporting
Units
Group Reference:
Path: Standard
Product Reference: Waste Oil
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? inQC? List?
13982-63-3 Radium-226 .00000006 uCi/mL REG No
i.
GEL Laboratories LLC - Login Review Report
Product: ASP THL
Method:
Product Description:
Samples:
Parmname Check:
CAS#
Workdef ID: 1331642 In Product Group? No
DOE EML HASL-300, Th-01-RC Modified
Alphaspec Th, Liquid
001,002, 003, 004
All parmnames scheduled properly
Parmname
Group Name:
Client RDL or
PQL & Unit
Group Reference:
Report Date- 18-FEB-14
Work Order: 335208
Page 3 of 4
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
14269-63-7 Thorium-230 .000001 uCi/mL REG Yes
Product: ASP UUL WorkdefID: 1331643 In Product Group? No Group Name:
Method: DOE EML HASL-300, U-02-RC Modified
Product Description: Alphaspec U, Liquid
Samples: 001, 002, 003, 004
Parmname Check: All parmnames scheduled properly
CAS# Parmname
Client RDL or
PQL & Unit Reporting
Units
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? in QC? List?
15117-96-1/13982- Uranium-235/236
7440-61-1 Uranium-238
000003
000003
uCi/mL
uCi/mL
REG
REG
Yes
Product: GFC PBL WorkdefID: 1331644
Method: DOE RP280 Modified
Product Description: GFPC, Pb210, Liquid
Samples: 001, 002, 003, 004
Parmname Check: All parmnames scheduled properly
CAS# Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Reporting
Units
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Parm Included Included Custom
Function in Sample? in QC? List?
14255-04-0 Lead-210 .0000001 uCi/mL REG Yes
Product: LUC26RAL
Method:
Product Description:
Samples:
Parmname Check:
CAS#
WorkdefID: 1331645
EPA 903.1 Modified
Lucas Cell, Ra226, liquid
001,002, 003, 004
All parmnames scheduled properly
Parmname
In Product Group? No Group Name:
Client RDL or
PQL & Unit
Group Reference:
Path: Standard
Product Reference: Sewage Solid
Moisture Correction: "As Received"
Reporting Parm Included Included Custom
Units Function in Sample? in QC? List?
13982-63-3 Radium-226 0000006 uCi/mL REG Yes
c
GEL Laboratories LLC - Login Review Report
Action Product Name Description Samples
Contingent
Tests
Login Requirements:
Requirement Include? Comments
Peer Review by: Work Order (SDG#), PO# Checked? C of C signed in receiver location?
Report Date:18-FEB-14
Work Order 335208
Page 4 of 4
Radiochemistry Case Narrative
Energy Fuels Resources (DNMI)
SDG 335208
Method/Analysis Information
Product: Alphaspec U, Liquid
Analytical Method: DOE EML HASL-300, U-02-RC Modified
Analytical Batch Number: 1338429
Sample ID Client ID
335208001 Admin Vault
335208002 CCR Vault
335208003 Change room Vault
335208004 Scale house Vault
1202966025 Method Blank (MB)
1202966026 335208001 (Admin Vault) Sample Duplicate (DUP)
1202966027 Laboratory Control Sample (LCS)
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed m this narrative has been analyzed in accordance with
GL-RAD-A-011 REV# 24.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
None of the samples m this sample set required reprep or reanalysis.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Manual Integration
No manual integrations were performed on data in this batch.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Method/Analysis Information
Product: Alphaspec Th, Liquid
Analytical Method: DOE EML HASL-300, Th-01 -RC Modified
Analytical Batch Number: 1338432
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Sample ID
335208001
335208002
335208003
335208004
1202966028
1202966029
1202966030
Change room Vault
Scale house Vault
Method Blank (MB)
335208001(Admin Vault) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
Client ID
Admin Vault
CCR Vault
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-038 REV# 16.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QO Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
None of the samples in this sample set required reprep or reanalysis.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Manual Integration
No manual integrations were performed on data in this batch.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required. Method/Analysis Information
Product: GFPC, Pb210, Liquid
Analytical Method: DOE RP280 Modified
Analytical Batch Number: 1338156
Sample ID
335208001
335208002
335208003
335208004
1202965398
1202965399
1202965400
Client ID
Admin Vault
CCR Vault
Change room Vault
Scale house Vault
Method Blank (MB)
335208001 (Admin Vault) Sample Duplicate (DUP)
Laboratory Control Sample (LCS)
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-018 REV# 13.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (QC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples meet the required acceptance limits with the following exceptions: The blank,
1202965398 (MB), did not meet the detection limit due to keeping the blank volume consistent with the other
sample aliquots. All other samples met the detection limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
Samples were refoiled and recounted due to a suspected blank false positive. The recounts are reported.
Chemical Recoveries
All chemical recoveries meet the required acceptance limits for this sample set.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Method/Analysis Information
Product:
Analytical Method:
Analytical Batch Number:
Lucas Cell, Ra226, liquid
EPA 903.1 Modified
1338764
Sample ID Client ID
335208001 Admin Vault
335208002 CCR Vault
335208003 Change room Vault
335208004 Scale house Vault
1202966806 Method Blank (MB)
1202966807 335208001(Admin Vault) Sample Duplicate (DUP)
1202966808 335208001 (Admin Vault) Matrix Spike (MS)
1202966809 Laboratory Control Sample (LCS)
The samples in this SDG were analyzed on an "as received" basis.
SOP Reference
Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as
Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with
GL-RAD-A-008 REV# 14.
Calibration Information:
Calibration Information
All initial and continuing calibration requirements have been met.
Standards Information
Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used
before the expiration dates.
Sample Geometry
All counting sources were prepared in the same geometry as the calibration standards.
Quality Control (OC) Information:
Blank Information
The blank volume is representative of the sample volume in this batch.
Designated QC
The following sample was used for QC: 335208001 (Admin Vault).
QC Information
All of the QC samples met the required acceptance limits.
Technical Information:
Holding Time
All sample procedures for this sample set were performed within the required holding time.
Sample Re-prep/Re-analysis
Samples 1202966807 (Admin Vault) and 335208001 (Admin Vault) were recounted due to high relative percent
difference/relative error ratio. The recounts are reported. Samples were degassed and recounted due to a
suspected blank false positive and low recovery. Recounts are reported.
Miscellaneous Information:
Data Exception (DER) Documentation
Data exception reports are generated to document any procedural anomalies that may deviate from referenced
SOP or contractual documents. A data exception report (DER) was not generated for this SDG.
Sample-Specific MDA/MDC
The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.
Additional Comments
Additional comments were not required for this sample set.
Qualifier Information
Manual qualifiers were not required.
Certification Statement
Where the analytical method has been performed under NELAP certification, the analysis has met all ofthe
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] - www gel.com
Qualifier Definition Report
for
DNMI001 Energy Fuels Resources (USA), Inc.
Client SDG: 335208 GEL Work Order: 335208
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a surrogate compound
U Analyte was analyzed for, but not detected above the CRDL.
Review/Validation
GEL requires all analytical data to be venfied by a qualified data reviewer. In addition, all CLP-like deliverables
receive a third level review of the fractional data package.
The following data validator verified the information presented in this data report:
Signature: Name Theresa Austin
Date: 18 FEB 2014 Title: Group Leader