DRC-2014-002562 - 0901a0688041a9bb

r ENERGYFUELS
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
March 27 2014 DRC-2014-002562
Mr. Bryce Bird
Director, Utah Division of Air Quality
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT84116
Re: White Mesa Uranium Mill,
National Emissions Standards for Radon Emission from Operating Mill Tailings
Transmittal of February 2014 Monthly Radon Flux Monitoring Report for Cell 2
Dear Mr. Bird:
This letter transmits Energy Fuels Resources (USA) Inc's ("EFRI's") radon-222 flux monitoring report
for February 2014 (the "Monthly Report") consistent with 40 CFR 61.254(b), for Cell 2 at the White
Mesa Uranium Mill (the "Mill"). As discussed in our 2012 Annual Radon Flux Monitoring Report
submitted March 29, 2013, the radon flux from Cell 2 during 2012 was higher than the 20 pCi/(m2 -sec)
set out in 40 CFR 61.252(a). Although Cell 2 is no longer in operation, this Monthly Report is being
submitted consistent with the requirements of 40 CFR 261(b) applicable to operating tailings
impoundments.
Included with the Monthly Report is a Radon Flux Measurement Program Report, dated February 2014,
prepared by Tellco Environmental (the "Tellco February 2014 Monthly Report"). The Tellco February
2014 Monthly Report indicates that for the month of February 2014, the average radon flux from Cell 2
was 11.0 pCi/(m2 -sec), which is lower than the 20 pCi/(m2 -sec) set out in 40 CFR 61.252(a).
If you have any questions, please feel free to contact me at [phone].
Yours very truly,
Energy Fuels Resources (USA) Inc.
Jaime Massey
Regulatory Compliance Specialist
N:\WMM\Required Reports\NESHAPS Reports\2014 Monthly NESHAPs reports\February 2014\transmitall letter February
2014.doc
Letter to B. Bird
March 27, 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 FEBRUARY 2014
Submitted March 27, 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) Monthly Report
Although Cell 2 is no longer in operation, this Report is being submitted as a monthly report for the
Mill's Cell 2 for February 2014, consistent with 40 Code of Federal Regulations (CFR) 61.254(b)
applicable to operating tailings impoundments.
A summary of the events that gave rise to EFRI's decision to file this monthly report consistent with 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 February 2014 is set out in Section 5 of this Report.
The monthly monitoring data for February 2014, consistent with 40 CFR 61.254(b), is provided in
Attachment 1 to this Report, which contains the Radon Flux Measurement Program Report, dated
February 2014, prepared by Tellco Environmental (the "Tellco February 2014 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. 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.
Although Cell 2 is no longer in operation, EFRI is submitting this monthly compliance report consistent
with the standards in 40 CFR 61.254(b) applicable to operating tailings impoundments.
2
4) Background Information -- 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 evaporation 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 2013
indicate that water levels in Cell 2 have decreased approximately 3.98 feet (5600.56 to 5596.58 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 2013, reflecting improved dewatering for all of 2012 and 2013.
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 pQ7m2-s), which was higher than the 20
pCi/(m2 -sec) standard referred to in 40 CFR 61.252(a). 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. The
results of the 2013 Cell 3 radon-222 flux monitoring will be discussed in the 2013 Annual Radon Flux
Monitoring Report for Cell 3 due March 30, 2014.
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."
3
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,
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 was therefore higher than the standard
of 20 pCi/(m2 -sec) referred to in 40 CFR 61.252(a).
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 being submitted as a monthly report for February 2014 for Cell 2, consistent with the
requirements set out in 40 CFR 61.254(b). Monthly monitoring will continue until US EPA or DAQ
advises EFRI that such monthly monitoring need not be continued.
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 in 2013, 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 reduce radon flux to
levels lower than 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.
4
EFRI has evaluated these results and has concluded that the increase in radon-222 flux from Cell 2 in
excess of 20 pCi/(m2 -sec) 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 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 at levels at or
below 20 pCi/(m -sec), 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) February 2014 Results
Detailed results for February 2014 for Cell 2 are contained in the Tellco February 2014 Monthly Report.
As described in the Tellco February 2014 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 whether they exceeded 20 pCi/(m2-sec).
The average radon flux for Cell 2 in February 2014 was reported by Tellco to be 11.0 pCi/(m2 -sec).
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) states that in addition to all the information required for an Annual Report under 40
CFR 61.254(b), monthly reports provided under that section 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.
5
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,
EFRI has performed the following steps to ensure that radon emissions from Cell 2 are kept as low as
reasonably achievable and at or below 20 pCi/(m2-sec).
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 20 pCi/(m2-sec) or lower) 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.
6
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. See LB, U.STC. 1001.
David C. F/^nlrMd
Senior Vi/e President, General Counsel and Corporate Secretary
ATTACHMENT 1
National Emissions Standards for Hazardous Air Pollutants
2014 Radon Flux Measurement Program
February 2014 Sampling Results
National Emission Standards for Hazardous Air Pollutants
2014 Radon Flux Measurement Program
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
February 2014 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 4
5.4 Environmental Conditions 4
6. SAMPLE ANALYSIS 4
6.1 Apparatus 4
6.2 Sample Inspection and Documentation 5
6.3 Background and Sample Counting 5
7. QUALITY CONTROL (QC) AND DATA VALIDATION 5
7.1 Sensitivity 6
7.2 Precision 6
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)
i
1. INTRODUCTION
During February 22-23, 2014 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 to represent the year or making multiple
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 responded by making 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 only for Cell 2 for
February 2014; the results of other sampling events are presented in separate reports.
Beginning in June 2013, Energy Fuels has placed additional cover materials at selected sample
locations of Cell 2 in an attempt to reduce the radon flux levels. The approximate locations of the
additional material is depicted on the sample locations map, which is included as Figure 2 in
Appendix D. The thickness of the additional material varies from approximately 18-24 inches thick.
At the time of this writing, Energy Fuels is continuing to place additional cover material over portions
of Cell 2 and, upon completion of the current plan, over 51,000 cubic yards of additional material will
have been placed throughout an area of approximately 600,000 square feet.
Tellco was contracted to provide radon canisters, equipment, and canister-placement personnel as well
as lab analysis of samples collected. 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 is presently on a quarterly sampling frequency and was not sampled during
February 2014.
Cell 2, which has a total area of approximately 270,624 square meters (m2), has been filled and
covered with interim cover. This cell is comprised of one region, an interim soil cover of varying
thickness, which requires NESHAPs radon flux monitoring. There were no exposed tailings within
Cell 2 at during the February 2014 sampling.
l
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.
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 L The repaired Cell 4A, and newly constructed Cell 4B, were both constructed after December
15, 1989 and each was constructed with less than 40 acres surface area. Cell 4A and 4B comply
with the requirements of 40 CFR 61.252(b), therefore no radon flux measurements are required on
either Cell 4A or 4B.
4. SAMPLING METHODOLOGY
Radon emissions were measured using Large Area Activated Charcoal Canisters (canisters) in
conformance with 40 CFR, Part 61, Appendix B, Method 115, Restrictions to Radon Flux
Measurements, (EPA, 2012). These are passive gas adsorption sampling devices used to determine
the flux rate of radon-222 gas from a surface. The canisters were constructed using a 10-inch
diameter PVC end cap containing a bed of 180 grams of activated, granular charcoal. The prepared
charcoal was placed in the canisters on a support grid on top of a Vi inch thick layer of foam and
secured with a retaining ring under 1 lA 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 by Energy Fuels Radiation
Safety personnel for possible contamination resulting from fieldwork activities. All of the field
2
equipment used was subsequently released for unrestricted use. Tellco personnel maintained custody
of the samples from collection through analysis.
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 February 22, 2014, 100 sampling locations were spread out throughout the Cell 2 covered region.
The same sampling locations that were established for previous sampling of Cell 2 were used for this
February 2014 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., B01.. .B100). 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 couple of the sample locations had to be offset about 10 feet because of
muddy ground conditions at the actual location markers.
Five canisters (blanks) were similarly processed and the canisters were kept inside an airtight plastic
bag during the 24-hour testing period.
3
5.3 Sample Retrieval
On February 23, 2014 at the end of the 24-hour testing period, all canisters were retrieved,
disassembled and each charcoal sample was individually poured through a funnel into a container.
Identification numbers were transferred to the appropriate container, which was sealed and placed in a
box for 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 retrieved and containerized
during the retrieval and 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 27 degrees F, and the ground was not frozen at any of the
sample locations.
6. SAMPLE ANALYSIS
6.1 Apparatus
Apparatus used for the analysis:
• Single- or multi-channel pulse height analysis system, Ludlum Model 2200 with a
. Teledyne 3" x 3" sodium iodide, thallium-activated (Nal(Tl)) detector.
• Lead shielded counting well approximately 40 cm deep with 5-cm thick lead walls and a 7-
cm thick base and 5 cm thick top.
• National Institute of Standards and Technology (NIST) traceable aqueous solution radium-
226 absorbed onto 180 grams of activated charcoal.
• Ohaus Model C501 balance with 0.1-gram sensitivity.
4
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 ultimately verified as valid and no damaged or unsealed containers were observed.
6.3 Background and Sample Counting
The gamma ray counting system was checked daily, including background and radium-226 source
measurements prior to and after each counting session. Based on calibration statistics, using two
sources with known radium-226 content, background and source control limits were established for
each Ludlum/Teledyne counting system with shielded well (see Appendix A).
Gamma ray counting of exposed charcoal samples included the following steps:
• The length of count time was determined by the activity of the sample being analyzed,
according to a data quality objective of a minimum of 1,000 accrued counts for any given
sample.
• The sample container was centered on the Nal detector and the shielded well door was
closed.
• The sample was counted over a determined count length and then the mid-sample count
time, date, and gross counts were documented on the radon flux measurements data sheet
and used in the calculations.
• The above steps were repeated for each exposed charcoal sample.
• Approximately 10 percent of the containers counted were selected for recounting. These
containers were recounted 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, 2013) were
attained.
5
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 0.00 to 0.02 pCi/m2-s, with an
average of approximately 0.01 pCi/m2-s. The lower limit of detection (LLD) was approximately 0.03
pCi/m2-s.
7.2 Precision
Ten recount measurements, distributed throughout the sample set, were performed by replicating
analyses of individual field samples (see Appendix B). These recount measurements comprised
approximately 10 percent of the total number of samples analyzed. The precision of all recount
measurements, expressed as relative percent difference (RPD), ranged from less than 0.1 percent to
8.6 percent with an overall average precision of approximately 4.3 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 0.6 percent. The arithmetic average bias of the lab
control sample measurements was approximately -0.5 percent (see Appendix A).
7.4 Completeness
All 100 of the samples from the Cell 2 cover region were verified, representing 100 percent
completeness.
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 = [Xs*A*b*^ 5(^91.75^
6
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:
Gross Sample, cpm Background Sample,cpm +
Sample Count,t,min Background Count,t,min
Error,2cr = 2x x Sample Concentration
Net,cpm
Equation 8.3:
rjr>_ 2.71+(4.65VSK)
LLD~ [Ts*A*b*0.5(dM7
where: 2.71 = constant
4.65 = confidence interval factor
Sb = standard deviation of the background count rate
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi; values used:
0.1699, for M-01/D-21 and
0.1702, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
9. RESULTS
9.1 Mean Radon Flux
Referencing 40 CFR, Part 61, Subpart W, Appendix B, Method 115 - Monitoring for Radon-222
Emissions, Subsection 2.1.7 - Calculations, "the mean radon flux for each region of the pile and for
the total pile shall be calculated and reported as follows:
(a) The individual radon flux calculations shall be made as provided in Appendix A EPA
86(1). The mean radon flux for each region of the pile shall be calculated by summing all
individual flux measurements for the region and dividing by the total number of flux
measurements for the region.
(b) The mean radon flux for the total uranium mill tailings pile shall be calculated as follows:
J1A1 + ...J7A9 r+i...j;Ai
Js =
At
Where: Js = Mean flux for the total pile (pCi/m2-s)
Jj = Mean flux measured in region i (pCi/m2-s)
A; = Area of region i (m2)
At = Total area of the pile (m2)"
7
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."
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 = 11.0 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= 11.0pCi/m2-s
(11.0y270.624) = 11.0
270,624
As shown above, the arithmetic mean radon flux of the samples for Cell 2 at Energy Fuels White
Mesa milling facility is below the NRC and EPA standard of 20 pCi/m2-s. The February 2014
sampling results for Cell 2 are similar to last month's results.
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 2013.
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
htaiufte 1 .'4 i n. Vent Hale ! -in Tn e*.
> ScfufetnN Pad
S/2-i?. Thick
ikn&aei Pas
2-H1 Tine* C-'-arcua-
IS
all 41 "30 *
\
HJ-iii a a
pvc Ems cm
ncsfli 1 Larsr-Area Ra«9fl Collector
10
Appendix A
Charcoal Canister Analyses Support Documents
A
ACCURACY APPRAISAL TABLE
FEBRUARY 2014 SAMPLING
ENERGY FUELS RESOURCES
WHITE MESA MILL, BLANDING, UTAH
2014 NESHAPs RADON FLUX MEASUREMENTS
CELL 2
SAMPLING DATES: 2/22/14-2/23/14
SYSTEM
I.D.
DATE Bkg Counts (1 min. each)
#1 #2 #3
Source Counts (1 min. each)
#1 #2 #3
AVG NET
cpm
YIELD
cpm/pCi
FOUND
pCi
SOURCE
ID
KNOWN
pCi
% BIAS
M-01/D-21 2/24/2014 115 125 124 10192 10142 10319 10096 0.1699 59425 GS-04 59300 0.2%
M-01/D-21 2/24/2014 136 115 116 10221 10173 10379 10135 0.1699 59655 GS-04 59300 0.6%
M-01/D-21 2/25/2014 107 118 135 10339 10223 10148 10117 0.1699 59545 GS-04 59300 0.4%
M-01/D-21 2/25/2014 120 124 128 10215 10325 10225 10131 0.1699 59629 GS-04 59300 0.6%
M-01/D-21 2/24/2014 115 125 124 10235 10313 10145 10110 0.1699 59504 GS-05 59300 0.3%
M-01/D-21 2/24/2014 136 115 116 10165 10074 10192 10021 0.1699 58984 GS-05 59300 -0.5%
M-01/D-21 2/25/2014 107 118 135 10138 10216 10089 10028 0.1699 59021 GS-05 59300 -0.5%
M-01/D-21 2/25/2014 120 124 128 10189 10054 10241 10037 0.1699 59078 GS-05 59300 -0.4%
M-02/D-20 2/24/2014 135 138 129 10145 10093 10090 9975 0.1702 58609 GS-04 59300 •1.2%
M-02/D-20 2/24/2014 142 125 130 10201 10061 9970 9945 0.1702 58431 GS-04 59300 •1.5%
M-02/D-20 2/25/2014 116 102 112 10089 10129 10256 10048 0.1702 59036 GS-04 59300 -0.4%
M-02/D-20 2/25/2014 124 113 98 10088 10212 9966 9977 0.1702 58619 GS-04 59300 •1.1%
M-02/D-20 2/24/2014 135 138 129 10056 10164 10082 9967 0.1702 58559 GS-05 59300 -1.3%
M-02/D-20 2/24/2014 142 125 130 10242 10114 10048 10002 0.1702 58768 GS-05 59300 -0.9%
M-02/D-20 2/25/2014 116 102 112 10118 10146 10029 9988 0.1702 58682 GS-05 59300 -1.0%
M-02/D-20 2/25/2014 124 113 98 10039 10150 10070 9975 0.1702 58606 GS-05 59300 -1.2%
AVERAGE PERCENT BIAS FOR ALL ANALYTICAL SESSIONS: -0.5%
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION: ySl tirk fAlSft. NA^, B.^Ji ft^ U4^k
CLIENT:
System ID:
Scaler S/N: S / 51 ~2-
Calibration Check Log
Calibration Date: ^ Due Date:
Detector S/N: QUi S 33
High Voltage: V CP Window: 4.42 Thrshld: 2.20
Source ID/SN: Rq^/^tVSSource Activity: j>j j K P^'
Blank Canister Bkgd. Range, cpm: 2 o = *8 ^ to / S4 3 a = jgf) to I"? 1
Gross Source Range, cpm:
All counts times are one minute.
Pre
Date
_ #1
By Background Counts (1 min. each)
#2 «. #3 Avg^ #1
Source Counts (1 min. each)
#2 #3 Average
ok?
Y/N
1 QI73 LQ33 o-237
IX A2=i£
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; Vi KW< KVgS^ fA'.U f Bl^ctt/IA
CLIENT: &^€^y F^^S Re £PnjT£tf S (fU5/l^
Calibration Check Log
SystemlP: j^-Qv / Q - Z j Calibration Date: 0 / / J3 Due Date: ^ / / V / j f
Scaler S/N: 5 1 5 1 2- High Voltage: ( # 3*^? Window: 4.42 Thrshld: 2.20
Detector S/N: g M » S 3 3 Source ID/SN: fta7"'*>/SS -O b Source Activity: S^-^fiC
Blank Canister Bkgd. Range, cpm: 2 a = to I S H 3 a = 0°)
Gross Source Range, cpm: to
to L2 !
to toon
Technician:
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
J2L
X 'ate. ! Q7
7» 1 -> 134
\3T 1 go l Ox 1 L/ i O t H g>
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: VO K ] 4 < \K C$ (\ \j\\ \ \ , B \C\V\ A } <AA+S\
CLIENT:
Calibration Check Log
System ID: M - g 2> / D ~ Calibration Date: ^/ / 13 Due Date: fr/ / H / I *f
Scaler S/N: g[ lSL?3 High Voltage: t O 1 5T Window: 4.42 Thrshld: 2.20
Detector S/N: ^M-lg 3^- Source m/SN: (W^/G 6 ~ C? <f Source Activity: ^.^Kpl,
Blank Canister Bkgd. Range, cpm: 2o= "7 $ to 1 5" | 3 o = & 0 to j 7 CP
2g= c)^s^t0 .osz7 3q= • to L2kk3 Gross Source Range, cpm:
Technician: c^^/^-— C^O"^^
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
pre
3g> I2L±
a^o>61 ^x 132. 1 \QOU\ \Qoni
iP2
113 iooe(
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: ^ W\^C W &^*\ H , BU^VKg .1^^^
CLIENT: fcn-e^Ay PvAfVs R ^3*? u r C_<lS fi4£/r^
Calibration Check Log
System ID: •' ° ~ X Q Calibration Date: C?/W/ 1 ^ Due Date: U/i H j I *f
Scaler S/N: £L! &3 High Voltage: tQ 7^ Window: 4.42 Thrshld: 2.20
Detector S/N: Q *4 I 5 1> ^ Source ID/SN: ^T^^/G^ °S Source Activity: • 3 K, j> ^.
Blank Canister Bkgd. Range, cpm: 2 a = _ "7^ to iS) 3a= 0>O to QO
Gross Source Range, cpm:
Technician:
to
All counts times are one minute.
Pv^
Post-
Date By Background Counts (1 min. each)
#1 #2 #3 Avg.
Source Counts (1 min. each)
#1
\OOSL
#2 #3 Average
ok?
Y/N
139 134 1QI G?if 1 OC7g-2, y \30 Y
TOX US-oTTff \Q14 to OQ°>?>
ID ISO [PQ7C
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: OSACKKA^ ?OfT-Q c^fc*"0 SA) f 2 3o 1
Standard Weight (g): CZ. OO* Q ^
Date Pre-check (g)
2.00*0
^2-00 .0
Post-check (g)
-2LOO, O
~~2-00 - O
O.K. ± 0.1 % ? By
V5
-^5
Appendix B
Recount Data Analys*
B
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 14004.02
PILE: 2 BATCH: B SURFACE: SOIL
AREA: COVER DEPLOYED: 2 22 14 RETRIEVED: 2
FIELD TECHNICIANS: MC.DLC, CS COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN: 27°F
23 14 CHARCOAL BKG:
DATA ENTRY BY: DLC
WEATHER: CLEAR
149 cpm Wt.Out: 180.0 g.
TARE WEIGHT: 29.2 g.
RECOUNT CANISTER ANALYSIS:
GRID
LOCATION
BIO
RECOUNT
B2 0
RECOUNT
B3 0
RECOUNT
B4 0
RECOUNT
B50
RECOUNT
B60
RECOUNT
B70
RECOUNT
B80
RECOUNT
B90
RECOUNT
B100
RECOUNT
SAMPLE
BIO
BIO
B2 0
B20
B3 0
B3 0
B4 0
B4 0
B50
B50
B60
B60
B70
B70
B80
B80
B90
B90
B100
BlOO
RETRIV ANALYSIS MID-TIME CNT GROSS GROSS
8 11
11
30
30
12
12
1
1
50
50
37
37
49
49
18
18
24
24
28
28
8 40
40
55
55
41
41
27
27
4
4
58
58
5
5
14
14
17
17
21
21
2 24 14 9
2 25 14 10
2 24 14 9
2 25 14 10
24 14
25 14
2 24 14
2 25 14
2 24 14
2 25 14
10
9
10
10
10
2 24 14
2 25 14
10
10
2 24 14 10
2 25 14 10
24 14
25 14
24
25
14
14
10
10
10
10
33
34
41
34
49
35
58
36
10
38
2 24 14 10 17
2 25 14 10 38
24
39
34
40
42
42
54
42
12138
10505
13600
10887
8736
7888
1305
1172
3415
2948
3782
3272
1940
1600
1251
1148
1059
1836
217 . 8
217 . 8
212 . 8
212 . 8
216
216
209
209
213
213
8169 214.5
7085 214.5
218.5
218 . 5
212 . 5
212 . 5
210 .6
210 . 6
211. 1
211 . 1
RADON ± LLD PRECISION
pCi/m2s pCi/m2s pCi/m2s % RPD
20 .1
21 . 0
22 . 6
21 . 8
14
15
0
0
5
5
13 . 6
14 .1
6 . 2
6.4
1. 4
1.3
1. 90
2 . 07
1. 6
1. 6
2 . 0
2 .1
2.3
2.2
1. 4
1.4
0.6
0 . 6
0 .1
0 . 1
0 . 2
0.2
0.2
0 . 2
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
0 . 03
0 . 04
4 .4;
3 .6-
8.6!
0 . 0-
3 .6'-
3.6-
3.2-
7.4%
8.6!
0 . 0:
AVERAGE PERCENT PRECISION FOR THE CELL 2 COVER REGION: 4 .3%
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.: 14004.02
PILE: 2 BATCH: B SURFACE: SOIL
AREA: COVER DEPLOYED: 2 22 14 RETRIEVED: 2
FIELD TECHNICIANS: MC.DLC, CS COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21. M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN: 27°F
23 14 CHARCOAL BKG:
DATA ENTRY BY: DLC
WEATHER: CLEAR
149 cpm WtOut: 180.0 g.
TARE WEIGHT: 29.2 g.
GRID
LOCATION
B01
B02
B03
B04
B05
B06
B07
B08
B09
BIO
Bll
B12
B13
B14
B15
B16
B17
B18
B19
B2 0
B21
B22
B23
B24
B25
B26
B27
B28
B2 9
B3 0
B31
B32
B33
B34
B35
B36
B3 7
SAMPLE
I. D.
B01
B02
B03
B04
B05
B06
B07
B08
B09
BIO
Bll
B12
B13
B14
B15
B16
B17
B18
B19
B2 0
B21
B22
B23
B24
B25
B26
B27
B2 8
B29
B30
B31
B32
B33
B34
B35
B36
B37
DEPLOY RETRIV ANALYSIS
HR MIN HR MIN MO DA YR
MID-TIME CNT GROSS GROSS
WT IN
RADON + LLD
pCi/m2s pCi/m2s pCi/m2s COMMENTS:
11
13
14
16
18
20
22
24
26
28
30
30
28
26
24
22
20
18
16
14
12
10
9
8
7
6
5
4
8 27
28
3 0
31
32
34
35
37
39
40
41
43
44
46
47
49
50
52
53
55
55
53
52
5 0
49
47
46
44
43
41
4 0
39
37
35
34
32
31
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
25
25
27
27
29
29
32
32
33
33
35
35
36
36
38
38
39
39
41
41
42
42
44
44
45
46
48
48
49
49
51
51
52
52
54
54
55
1243
1282
1856
11425
1445
1222
1238
7064
1526
12138
3752
17846
8078
9296
3669
2606
2419
9126
16396
13600
4180
10004
5241
5318
4861
1638
11560
6369
8623
8736
16910
11252
2017
3915
10988
13879
9633
218
215
214
215
215
216
216
217
215
217
214
214
214
215
217
215
215
216 . 0
213 . 8
212 . 8
215 . 9
212 .3
209.4
217 . 0
203 .4
213
219
214
212
216
214
212
215
215
214 .4
217 . 5
216.2
1
1
2
18
1
0
1
11
2
20
6
15
5
4
3
15
27
22
6
16
29 . 7
13 .3
7
1
19
10
14
14
28
18
3
6.3
18.3
23 . 1
16 . 0
0. 7
1. 7
0 . 9
0 . 9
0 . 8
0 .1
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0.03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0. 03
Paae 1 of 3
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO: 14004.02
PILE: 2 BATCH: B SURFACE: SOIL
AREA: COVER DEPLOYED: 2 22 14 RETRIEVED: 2
FIELD TECHNICIANS: MC,DLC, CS COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN: 27°F
23 14 CHARCOALBKG:
DATA ENTRY BY: DLC
WEATHER: CLEAR
149 cpm WtOut: 180.0 g.
TARE WEIGHT: 29.2 g.
GRID
LOCATION
B38
B3 9
B40
B41
B42
B43
B44
B45
B46
B47
B4 8
B4 9
B50
B51
B52
B53
B54
B55
B56
B57
B58
B59
B60
B61
B62
B63
B64
B65
B66
B67
B68
B69
B70
B71
B72
B73
B74
SAMPLE DEPLOY RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON ± LLD
B38
B39
B4 0
B41
B42
B43
B44
B45
B46
B47
B48
B4 9
B50
B51
B52
B53
B54
B5B
B56
B57
B58
B59
B60
B61
B62
B63
B64
B65
B66
B67
B68
B69
B70
B71
B72
B73
B74
3
2
1
4
3
2
1
0
58
56
54
52
50
49
48
47
45
43
41
40
39
38
37
36
38
39
40
41
43
45
47
48
49
50
52
54
56
30
28
27
9
9
8
7
7
6
6
5
5
4
4
3
2
2
1
1
0
59
58
58
58
59
0
1
2
3
4
4
5
5
6
6
7
8
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
9
9
9
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
55
57
58
0
1
4
3
7
7
10
10
11
11
13
13
14
14
16
16
17
17
19
19
20
20
22
22
23
23
24
24
26
26
27
27
1188
11606
1305
1776
1532
1394
16616
42628
3064
15689
30807
5195
3415
6331
5912
2843
11297
1590
19193
12285
7860
4936
8169
3390
2252
2516
18160
6080
11549
19359
1914
2735
3782
14715
13735
8711
9095
216 .1
212 .4
209.3
213 .8
216 .8
215 . 7
217 . 7
214 . 8
216
218
220
213
213
213 . 0
215 . 3
215
219
213
215
216
215
214
214
215
216
214
214
211
215
217
221
219
218
213
219
217
219
1
19
0
2
1
0
28
72
5
26
52
8
5.
10
9
4
18
2
32
20
13
5
3
4
30
0 . 1
13 . 0
8 . 1
10 . 1
19 . 3
32 . 6
3 . 0
4.4
6.2
24 . 8
23 . 1
14
15
0 .1
2 . 8
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
03
03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
0 . 03
Page 2 of 3
CLIENT: ENERGY FUELS RESOURCES PROJECT: RADON FLUX MEASUREMENTS, WHITE MESA MILL PROJECT NO.: 14004.02
PILE: 2 BATCH: B SURFACE: SOIL
AREA: COVER DEPLOYED: 2 22 14 RETRIEVED: 2
FIELD TECHNICIANS: MC.DLC, CS COUNTED BY: DLC
COUNTING SYSTEM I.D.: M01/D21, M02/D20 CAL. DUE: 6/14/14
AIR TEMP MIN: 27°F
23 14 CHARCOAL BKG:
DATA ENTRY BY: DLC
WEATHER: CLEAR
149 cpm Wt.Out: 180.0 g.
TARE WEIGHT: 29.2 g.
ttmm SAMPLE DEPLOY RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON ± LLD
B75
B76
B77
B78
B79
B80
B81
B82
B83
B84
B85
B86
B87
B88
B89
B90
B91
B92
B93
B94
B95
B96
B97
B98
B99
BlOO
B75
B76
B77
B78
B79
B80
B81
B82
B83
B84
B85
B86
B87
B88
B89
B90
B91
B92
B93
B94
B95
B96
B97
B98
B99
BlOO
BLANK CANISTER ANALYSIS:
GRID
LOCATION
58
0
13
14
16
18
19
21
23
24
25
26
27
28
25
24
23
21
19
18
16
14
13
26
27
28
11
12
13
14
15
16
17
18
19
20
21
22
18
17
17
16
15
14
13
12
11
19
20
21
24 14
24 14
24
24
24
14
14
14
24 14
24 14
24 14
24 14
24
24
24
24
14
14
14
14
AVERAGE RADON
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
24 14 10
FLUX RATE
24 14
24 14
24 14
24 14
24 14
24 14
24 14
24 14
24 14
24 14
24 14
24 14
29
29
31
31
33
34
36
36
37
37
39
39
40
40
42
42
43
43
45
46
48
49
52
52
55
54
1 1656
1 1346
2 1041
2 1203
1 1355
2 1940
1 3462
1 8332
1 5221
1 1582
1 2334
1 3928
1 2335
1 7026
1 12372
1 1251
1 1377
1 3357
1 5794
2 1194
2 1561
3 1007
1 1378
1 1312
2 1156
1 1059
FOR THE CELL 2 COVER REGION
0 . 03 212
0 . 03 216
214 0 . 6 0 . 03
0 . 8 0 . 03 213
216 0 . 03
212 1 . 4 0 . 1 0 . 03
03 211
14 0 . 03 219
8 . 7 0 . 03 214
215 2 . 5 03
0 . 03 217
0 . 7 0 . 03
0 . 03
219
216
214 11 . 8 0 . 03
0 . 03 212 . 0 21
0 . 03
0 . 03
210
215 . 0
212 0 . 03
0 . 03 215
0 . 03
0 . 03
214 0 . 8
215 1.1
214 0 . 3
215
211 2 . 0
214 0 . 7
211
l/m 11. 0 pC
0.3
72.4 MAX
0 .03
0 . 03
0 . 03
0 . 03
0 . 03
SAMPLE RETRIV ANALYSIS MID-TIME CNT GROSS GROSS RADON ± LLD
B BLANK
B BLANK
B BLANK
B BLANK
B BLANK
B BLANK 1
B BLANK 2
B BLANK 3
B BLANK 4
B BLANK 5
23
23
23
23
23
8
8
48
48
48
48
48
24
24
24
24
24
14
14
14
14
14
8 47
47
58
58
10
10
10
10
10
10
1629
1492
1603
1516
1514
209 . 1
208 . 8
211 . 1
209.4
209.2
AVERAGE BLANK CANISTER ANALYSIS FOR THE CELL 2 COVER REGION:
mmsm
Page 3 of 3
0 . 02
0 .00
0 . 02
0 .00
0 . 00
0 . 01
0 . 02
0 . 02
0 . 02
0 . 02
0.02 _
pCi/m2 s
0. 03
0 . 03
0 . 03
0 . 03
0 . 03
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
Appendix D
Sample Locations Map (Figure
D
D. c=2
CELL 1
3h • -a
B25 B24 B27 ^ B26
B54 B55
; Fl l
WHITE MESA MILL
BLANDING. UTAH
NESHAPS 2014
FEBRUARY 2014
PREPARED FOR
ENERGY FUELS RESOURCES
o APPROXIMATE LOCATIONS WHERE OR ADDITIONAL COVER MATERIALS HAVE
BEEN PLACED THROUGH FEBRUARY 2014
FIGURE 2
N
t SCALE IN FEET
100 0 200 400
reueo ENVIRONMENTAL, LLC
THIS DRAWING ISTHE PROPERTY OF TELLCO ENVIRONMENTAL, LLC, AND IS NOT TO BE REPRODUCED, MODIFIED OR USED FOR ANY OTHER PROJECT OR EXTENSION OF THIS PROJECT EXCEPT BY AGREEMENT WITH TELLCO,