DRC-2018-000568 - 0901a068807a3a81

State of Utah
GARY R HERBERT
Governor
SPENCER.! COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
Project File C-2016-94
Phil Goble, Uranium Mill Section Manager
Russell J. Topham, PE ------------------------
January 9, 2018
SUBJECT: Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
Observations from Site Visits of June 28, July 19 and August 10, 2017
Review of All Construction Quality Control Testing
Review of As-Built Report
Review of Radon Test Results (advance copy) Received August 23, 2017
Authority
Radioactive Materials License #UT1900479, Proposed UDRC Amendment 8 (Renewal), Condition 9.13:
“The Licensee shall perform all decommissioning and reclamation activities in conformance to
Reclamation Plan 5.1.”
10 CFR Part 40 Appendix A. Criterion 6A(1):
“For impoundments containing uranium byproduct materials, the final radon barrier must be completed
as expeditiously as practicable considering technological feasibility after the pile or impoundment ceases
operation in accordance with a written, [Director]-approved reclamation plan. (The term as
expeditiously as practicable considering technological feasibility as specifically defined in the
Introduction of this appendix includes factors beyond the control of the licensee.).”
Stipulation and Consent Agreement dated February 23, 2017, Agreement 1:
“The Director will approve Reclamation Plan 5.1 (the ‘Approved Reclamation Plan’) upon completion
of a public notice and comment period, and in conjunction with and conditional upon the execution and
delivery of this Agreement by EFR and the Director. This Agreement sets out the commitments and
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address P O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] 'TDD [phone]
uiwui.deq.iitnh.gov
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time frames for completing placement of reclamation cover on Cell 2 and performance assessment of the
cover system, in accordance with the Approved Reclamation Plan.’’
Reclamation Plan Revision 5. L p. 1-1:
“This plan presents [Energy Fuels’] plans and estimated costs for the reclamation of cells for the tailings
management system, and for decommissioning of the Mill and Mill site. This plan is an update to the
White Mesa Mill Reclamation Plan Revision 3.2b approved by the Utah Department of Environmental
Quality[,] Division of Radiation Control on January 26, 2011.”
Updated Tailings Cover Design Report (Appendix A to Reclamation Plan Revision 5.1), Appendix L,
Section L.4, Cover Performance Assessment:
“EFRI constructed a performance monitoring test section (Primary Test Section) within the Cell 2 cover
concurrently with the 2016 Phase 1 cover placement. The test section was constructed as a design-build
project using the guidelines provided in this appendix. The test section will be monitored to assess
perfonnance of the cover system for the tailings cells. The test section location is shown in the Drawings
(Attachment L.l [not included in this report]). Discussion on the test section design and plan is provided
in Section L.4.1 [not addressed in this report], and discussion on the test section monitoring program is
provided in Section L.4.2.”
Requirements
1. 10 CFR Part 40 Appendix A, Criterion 6(1):
“In disposing of waste byproduct material, licensees shall place an earthen cover (or approved
alternative) over tailings or wastes at the end of milling operations and shall close the waste disposal
area in accordance with a design which provides reasonable assurance of control of radiological hazards
to (i) be effective for 1,000 years, to the extent reasonably achievable, and, in any case, for at least 200
years, and (ii) limit releases of radon-222 from uranium byproduct materials, and radon-220 from
thorium byproduct materials, to the atmosphere so as not to exceed an average release rate of 20
picocuries per square meter per second (pCi/m2's) to the extent practicable throughout the effective
design life detennined pursuant to (l)(i) of this Criterion. In computing required tailings cover
thicknesses, moisture in soils in excess of amounts found normally in similar soils in similar
circumstances may not be considered. Direct gamma exposure from the tailings or wastes should be
reduced to background levels. The effects of any thin synthetic layer may not be taken into account in
determining the calculated radon exhalation level. If non-soil materials are proposed as cover materials,
it must be demonstrated that these materials will not crack or degrade by differential settlement,
weathering, or other mechanism, over long-term intervals.”
2. 10 CFR Part 40 Appendix A, Criterion 6(2):
“As soon as reasonably achievable after emplacement of the final cover to limit releases of radon-222
from uranium byproduct material and prior to placement of erosion protection barriers or other features
necessary for long-term control of the tailings, the licensee shall verify through appropriate testing and
analysis that the design and construction of the final radon barrier is effective in limiting releases of
radon-222 to a level not exceeding 20 pCi/m2-s averaged over the entire pile or impoundment using the
procedures described in 40 CFR part 61, appendix B, Method 115, or another method of verification
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 2
approved by the [Division] as being at least as effective in demonstrating the effectiveness of the final
radon barrier.”
3. ]() CFR Part 40 Appendix A, Criterion 6(3):
“When phased emplacement of the final radon barrier is included in the applicable reclamation plan, the
verification of radon-222 release rates required in paragraph (2) of this criterion must be conducted for
each portion of the pile or impoundment as the final radon barrier for that portion is emplaced.”
4. 10 CFR Part 40 Appendix A, Criterion 6(4):
“Within ninety days of the completion of all testing and analysis relevant to the required verification in
paragraphs (2) and (3) of this criterion, the uranium mill licensee shall report to the [Division] the results
detailing the actions taken to verify that levels of release of radon-222 do not exceed 20 pCi/m2-s when
averaged over the entire pile or impoundment. The licensee shall maintain records until termination of
the license documenting the source of input parameters including the results of all measurements on
which they are based, the calculations and/or analytical methods used to derive values for input
parameters, and the procedure used to determine compliance. These records shall be kept in a form
suitable for transfer to the custodial agency at the time of transfer of the site to DOE or a State for long­
term care if requested.”
5. 10 CFR Part 40 Appendix A, Criterion 6(5):
“Near surface cover materials (i.e., within the top three meters) may not include waste or rock that
contains elevated levels of radium; soils used for near surface cover must be essentially the same, as far
as radioactivity is concerned, as that of surrounding surface soils. This is to ensure that surface radon
exhalation is not significantly above background because of the cover material itself.”
6. Stipulation and Consent Agreement dated February 23, 2017, Agreement 1:
“EFR will complete Phase 1 cover construction in accordance with Sections L.l, L.2 and L.3 of
Appendix L (“Appendix L”) to the Updated Cover Design Report, which will include placement of: (1)
additional interim cover (Layer 1) to achieve design grades prior to placement of cover Layer 2; and (2)
the entirety of Layer 2.
“Instrumentation for monitoring Cell 2 after Phase 1 cover placement is described in Sections L.4.2 and
L.4.4 of Appendix L, and will include the existing settlement monuments and newly installed
piezometers.
“Cell 2 Phase 1 cover placement commenced in April 2016 and will be completed on or before August
31, 2017, or such later date as may be approved by the Director.
“An as-built report for Cell 2 Phase 1 cover placement will be provided to the Director within 90 days
after completion of construction, or such later date as may be approved by the Director.”
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 3
7. Stipulation and Consent Agreement dated February 23, 2017, Agreement 4:
“The cover design will be tested by monitoring as set out in [Agreement 3] and comparison of the results
to [specified] performance criteria.” Agreement 3 is being reviewed under another project, and so has
been omitted here, along with the associated requirements, to avoid redundant review.
8. Reclamation Plan Revision 5.1, Section 3.2.2. p. 3-4:
“Cell 2 final cover construction will take place before final cover construction on other cells at the
White Mesa Mill. Cell 2 final cover construction will occur in two phases and includes a performance
monitoring test section (Primary Test Section) containing a lysimeter constructed in the southeast
portion of Cell 2 concurrently with the Phase 1 cover placement. A Supplemental Test Section will be
constructed north of the tailings management cells relating to vegetative cover and erosion control. The
plan for implementing final cover placement on Cell 2 and performance assessment and monitoring is
presented in Appendix A. Cell 2 Phase 1 cover placement began in May 2016 and is expected to be
completed in two construction seasons. The Primary Test Section was constructed in the fall of 2016.
The Supplemental Test Section is proposed to be constructed in the fall of 2017”
9. Reclamation Plan Revision 5.1, Section 3.2.2.1, p. 3-4:
“The ET cover proposed and evaluated as described in the Updated Tailings Cover Design Report
(Appendix A) is designed as 9.5 feet thick for Cells 1, 4A, and 4B, 10 feet thick for Cell 3, and 10.5 feet
thick for Cell 2. The difference in cover thickensses is based on radon emanation analyses. The cover
system consists of the following materials outlined below by individual layers and thicknesses from top
to bottom:
• Layer 4 - 0.5 ft (15 cm) thick Erosion Protection Layer (gravel-admixture or topsoil)
• Layer 3 - 3.5 ft (107 cm) thick Growth Medium Layer acting as a Water
Storage/Biointrusion/Frost Protection/Secondary Radon Attenuation Layer (loam to sandy clay)
• Layer 2 - 3.0 to 4.0 ft (91 to 122 cm) thick Compacted Cover acting as the Primary Radon
Attenuation Layer (highly compacted loam to sandy clay)
• Layer 1 - 2.5 ft (76 cm) thick (minimum) Interim Fill Layer acting as a Secondary Radon
Attenuation and Grading Layer (loam to sandy clay)
“All the layers combined comprise the monolithic ET cover system. Layer 1 was placed in stages on
Cell 2 and the majority of Cell 3 as interim cover. Layer 1 will be placed on the remaining area of Cell
3, all of the Cell 1 Disposal Area, and Cells 4A and 4B. It is assumed that this material was or will be
dumped and minimally compacted by construction equipment to approximately 80 percent of standard
Proctor density. Layer 1 will provide the platform for the remaining cover system and act as a secondary
radon attenuation layer. Layer 2 will be compacted cover layer and act as the primary radon attenuation
layer. It will be 3 - 4 feet thick (3 feet for Cells 1,4A, and 4B, 3.5 feet for Cell 3, and 4 feet for Cell 2)
and compacted to 95 percent of standard Proctor density.” (The Reclamation Plan continues at this
point to describe installation of Layers 3 and 4, which were not part of this project.)
10. Reclamation Plan Revision 5.1, Section 3.2.2.1, p. 3-5:
“The key state and federal performance criteria for tailings cover design and reclamation include:
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 4
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 5
• Attenuate radon flux to a rate of 20 pCi/m2-s, averaged over each entire cell
• Minimize infiltration into the reclaimed tailings cells
• Maintain a design life of up to 1,000 years and at least 200 years
• Provide long-term isolation of the tailings, including slope stability and geomorphic durability to
withstand erosional forces of wind and runoff (up to the probable maximum precipitation event)
as well as design to accommodate seismic events (up to the peak ground acceleration from the
maximum credible earthquake)
• Designs to accommodate minimum reliance on active maintenance”
11. Reclamation Plan Revision 5.L Section 3.2.2.3, p. 3-6:
“Cell 2 has been filled with tailings and will be covered with the ET cover to a minimum cover
thickness of 10.5 feet. The final cover will drain at a slope of 0.5 to 1 percent to the north and south
as shown in the Drawings.
“The cover will be as described in Section 3.2.2.1 above and will consist of a 2.5 feet of interim fill,
followed by 4 feet of compacted cover, overlain by 3.5 feet of growth medium. Half a foot of topsoil
or gravel admixture will be utilized as armor against erosion at the surface of the cover. External side
slopes will be graded to a 5:1 slope and will have 6 inches of angular riprap on the cover surface for
erosion protection. A rock apron with dimensions as shown in the Drawings will be constructed at
the transition areas of the toes of the side slopes of Cell 2.”
12. Reclamation Plan Revision 5.1, Section 3.3.2, p. 3-8:
“Results of the analyses show that the proposed cover system can reduce the rate of radon-222
emanation to less than 20 pCi/m2-s, averaged over the entire area of each tailings cell.”
13. Reclamation Plan Revision 5.1, Section 3.3.5, p. 3-9:
“The components of erosion protection for the reclaimed tailings cells consist of the following:
• The cover on the top surface of Cells 1, 2, and 3, with slopes of 0.5 percent, would be
constructed as a vegetated slope, with 6 inches of topsoil.
• The portions of Cell 2 with a top surface of 1 percent slope, and the portions of Cells 4A and
4B with 0.8 percent slope, would be constructed as a vegetated slope with 6 inches of topsoil
mixed with 25 percent (by weight) gravel (maximum diameter of 1 inch).
• Erosion protection of external (5H:1V) side slopes would be provided by various sized
angular and rounded riprap with layer thicknesses ranging from 6 to 8 inches and median
particle sizes ranging from 1.7 to 5.3 inches. A 6-inch layer of filter material would be placed
between the erosional protection layer and underlying soil layer in locations with riprap
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9,2018
Page 6
greater than 1.7 inches. A narrow zone of this filter will also be placed at the interface
between the riprap (greater than 1.7 inches) on the external side slopes and the cover surface
erosion protection layer.
• The toe of embankment slopes will have erosional protection and scour protection on the
west and east sides of the cells provided by a rock apron measuring approximately 10 inches
deep and 5 feet wide, with a median particle size of 3.4 inches. On the south side of cells 4A
and 4B, and east side of Cell 4A, the rock apron would be approximately 3 feet in depth, 13
feet in width, and have a median particle size of 10.6 inches. On the north side slope of the
Cell 1 disposal area, the rock apron would be approximately 3 feet deep, 11 feet wide, and
have a median particle size of 9 inches.”
Observations
Russell J. Topham, P.E. of the Utah Division of Waste Management and Radiation Control (the
Division), performed site visits on June 29, July 19 and August 10 of 2017 to observe the placement of
Cell 2 primary radon barrier material and to review field notes of the construction crew. Mr. Topham
also reviewed construction quality control testing for the entire Radon barrier emplacement activity, the
As-Built Report for the cover construction dated July 18, 2017, and an advance copy of the radon flux
measurements taken for Cell 2 on March 21-22, 2017 received by email on August 23, 2017. The radon
flux measurements appear in the Semi-Annual Effluent Monitoring Reports, which are reviewed
separately, so the advanced copy was not entered into the electronic document database. The following
observations reflect the cited reviews and site visits.
As-Built Report for [Cell 2] Phase 1 Cover construction and Associated Quality Control Testing
The Division received the As-Built Report on July 18, 2017. The quality control testing appears as an
appendix to the report. The report fulfills a requirement of the SCA to document the construction
activities and results obtained for the Phase 1 cover construction. Phase 1 cover construction included
leveling of the platform fill layer and placement of the primary radon barrier. The As-Built Report
discussed the construction protocols, methods, and standards applied.
The As-Built Report provided sufficient data to evaluate the construction of the primary radon barrier.
Topics covered include a narrative summary of the construction, laboratory and field test analysis results
for the materials used and post-placement density. 28 figures, an appendix containing as-built
construction drawings and an appendix containing over 400 pages of quality control testing supplement
the text.
The advance copy of the radon flux measurements (taken prior to completion of all Phase 1
construction) provides a check against cover design assumptions and construction effectiveness.
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 7
3*3
Photo 1: Looking from southwest corner of Cell 2 across the surface of Cell 2 toward the northeast.
Photo taken June 29, 2017.
Photo 2: Looking from the center of the north edge of Cell 2 across the surface of Cell 2 toward the
southeast. Photo taken June 29, 2017.
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 8
The two photos above are representative of the photos taken during the inspections reported in this
memorandum.
Analysis
This section follows the same sequence and numbering convention used in the Requirements section
above.
1. 10 CFR Part 40 Appendix A, Criterion 6(1) provides seven requirements. Three are exclusively
design requirements, and are addressed in the review of Reclamation Plan Revision 5.1. The
remaining four are both design and performance requirements, and are outlined below for
evaluation.
a. “... licensees shall place an earthen cover (or approved alternative) over tailings or
wastes ...”
The As-Built Report documents that the materials placed were all soils. Field
observations on the dates mentioned substantiate that fact. The requirement to place an
earthen cover is met.
b. . licensees shall place ... cover ... in accordance with a design which provides
reasonable assurance of control of radiological hazards to (i) be effective for 1,000 years,
to the extent reasonably achievable, and, in any case, for at least 200 years ...”
The cover design follows Reclamation Plan Revision 5.1, which has been engineered to
meet the specified longevity requirements. The As-Build Report and field observations
indicate that the construction of the elements installed to date conform to the
requirements of Reclamation Plan Revision 5.1. This includes material selection,
placement thickness, and density achieved during placement. Specifically, the
installation to date consists of 2.5 feet of interim fill beneath 4 feet of primary radon
barrier, both layers meeting the gradation and density requirements of the reclamation
plan specifications. Since two layers of the cover system and the side-slope protection
remain to be installed, a final statement of compliant completion cannot be made at this
time. Energy Fuels has crews onsite capable of repairing erosion that may occur, and the
Division will include observations of cover erosion resistance in the routine inspection
regimen.
c. .. licensees shall place ... cover ... in accordance with a design which provides
reasonable assurance of control of radiological hazards to ... (ii) limit releases of radon-
222 from uranium byproduct materials, and radon-220 from thorium byproduct materials,
to the atmosphere so as not to exceed an average release rate of 20 picocuries per square
meter per second (pCi/m2's) to the extent practicable ....”
This standard applies once the radon barrier has been installed, but before the remaining
layers of the cover have been constructed. As discussed in Item 2 below, construction of
the cover system has reached the point where this requirement takes effect. The Division
received, and I have reviewed an advance copy of radon flux measurements taken July
15-16, 2017. These data will appear in the Semiannual Effluent Report the Division
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 9
expects to receive during March of 2018. Tests were also taken March 21-22, 2017
which appear in the Semiannual Effluent Monitoring Report received at Division offices
August 30, 2017. These data show a mean radon flux of 0.5 pCi/m2-s during the March
testing period and 0.9 pCi/m2-s during the July testing period. This averages 0.7 pCi/m2-
s. The seasonal variation observed is not surprising; nonetheless. The Division will
review the 2018 semiannual submittals to verify that emissions remain low. Energy
Fuels acquired the data using the protocol specified in 40 CFR Part 61, Appendix B,
Method 115. The data show that the newly-installed radon barrier is effective in reducing
radon flux to a point well below the 20 pCi/m2's requirement. The requirement to control
radon flux is met.
d. “Direct gamma exposure from the tailings or wastes should be reduced to background
levels.” This requirement applies once the full cover has been installed. Until then, the
Division will use the site boundary gamma measurements as an indicator. Those
measurements appear in the Semiannual Effluent Monitoring Reports.
2. 10 CFR Part 40 Appendix A, Criterion 6(2) addresses testing protocols to meet radon flux
requirements for the final cover. The requirement reads: “As soon as reasonably achievable
after emplacement of the final cover to limit releases of radon-222 from uranium
byproduct material and prior to placement of erosion protection barriers or other features
necessary for long-term control of the tailings, the licensee shall verify through appropriate
testing and analysis that the design and construction of the final radon barrier is effective in
limiting releases of radon-222 to a level not exceeding 20 pCi/m2-s averaged over the entire pile
or impoundment using the procedures described in 40 CFR part 61, appendix B, Method 115, or
another method of verification approved by the [Division] as being at least as effective in
demonstrating the effectiveness of the final radon barrier.” (emphasis added) Energy Fuels has
completed the cover to the point at which this requirement takes effect. As discussed in Item 1 .c
above, this requirement has been satisfied, both with respect to the method employed, and the
measured radon flux rate.
3. 10 CFR Part 40 Appendix A, Criterion 6(3) addresses phased implementation of cover
installation. This requirement states: “When phased emplacement of the final radon barrier is
included in the applicable reclamation plan, the verification of radon-222 release rates required
in paragraph (2) of this criterion must be conducted for each portion of the pile or impoundment
as the final radon barrier for that portion is emplaced.” As stated in Items 1 .c and 2 above, this
requirement has been satisfied.
4. 10 CFR 40 Appendix A, Criterion 6(4) requires: “Within ninety days of the completion of all
testing and analysis relevant to the required verification in paragraphs (2) and (3) of this
criterion, the uranium mill licensee shall report to the [Division] the results detailing the actions
.. taken to verify that levels of release of radon-222 do not exceed 20 pCi/m2-s when averaged
over the entire pile or impoundment.”
The testing reported in the Semiannual Effluent Monitoring Report for the first half of 2017
addresses the installation of the primary radon barrier. The testing occurred July 15-16, 2017,
and an advance copy of the results was submitted for Division review on August 23, 2017. The
official record copy of the results will appear in the Semiannual Effluent Monitoring Report due
to be submitted during March, 2018. For convenience, the advance copy, which also includes a
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 10
copy of the March 21-22, 2017 data report, is attached to this memorandum. The requirement
for timely submission of the data was met. Associated retention records will be checked during
future inspections.
5. 10 CFR Part 40 Appendix A, Criterion 6(5) sets a minimum cover thickness requirement: “Near
surface cover materials (i.e., within the top three meters) may not include waste or rock that
contains elevated levels of radium; soils used for near surface cover must be essentially the same,
as far as radioactivity is concerned, as that of surrounding surface soils. This is to ensure that
surface radon exhalation is not significantly above background because of the cover material
itself.”
To meet this criterion requires that plant-generated and imported 1 le.(2) decommissioning debris
must be placed at least 3 meters below the finished cover profile. The total cover thickness
presented in Reclamation Plan Revision 5.1 is 9.5 feet at its thinnest, which converts to 2.9
meters. However, Standard Operating Procedure PBL-10 (answering to License Condition 10.5)
requires that 1 le.(2) byproduct material be placed at the top of tailings, with at least one foot of
soil cover over the compacted byproduct material. This results in 10.5 feet (3.2 m) minimum
distance between the top of cover and the top of byproduct material that might contain radium
levels above native soil content. Since the top two layers of the cover system were not installed
during Phase 1 cover construction, it is premature to render a conclusion about this requirement;
however, the material thickness schedule indicates no need for adjustment of the layers already
installed.
6. Stipulation and Consent Agreement dated February 23, 2017, Agreement 1 has four
requirements:
a. “EFR will complete Phase 1 cover construction in accordance with Sections L.l, L.2 and
L.3 of Appendix L (“Appendix L”) to the Updated Cover Design Report, which will
include placement of: (1) additional interim cover (Layer 1) to achieve design grades
prior to placement of cover Layer 2; and (2) the entirety of Layer 2.” The cited portions
of Appendix L provide high-level requirements for scope (Section L.l), cover design
(Section L.2) and construction (Section L.3). Section L.3 directs the reader to detail
drawings (behind the “drawings” tab in the Reclamation Plan), specifications
(Attachment A to the Reclamation Plan) and Construction Quality Assurance/Quality
Control Plan (Attachment B to the Reclamation Plan). For brevity, the detailed analysis
of Energy Fuels’ performance is not presented here. The As-Built Report demonstrates
conclusively that the portions of the cover system installed on Cell 2 follow the plans and
specifications very closely, and that the quality control and quality assurance functions
were carried out strictly. My field observations revealed no material deviations from
these requirements.
The vegetative cover on the primary test section had not produced the density or diversity
of vegetation expected as of the August 10, 2017 site visit. Details of the primary test
section perfonnance are addressed in a separate memorandum, and will not be repeated
here. For the purposes of this review, the specifications were met.
b. “Instrumentation for monitoring Cell 2 after Phase 1 cover placement is described in
Sections L.4.2 and L.4.4 of Appendix L, and will include the existing settlement
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 11
monuments and newly installed piezometers.” All required instrumentation has been
installed (Primary Test Section instrumentation and piezometers) or extended (settlement
monitors) to meet the requirements. The Primary Test Section instrumentation is the
subject of a parallel effort to this one, and will not be detailed here. Monitoring of the
piezometers and settlement monitors are reported and reviewed separately from this
construction review. It is sufficient to state here that the instrumentation and monitoring
facilities were installed according to the specifications and are functioning as intended.
c. “Cell 2 Phase 1 cover placement commenced in April 2016 and wilTbe completed on or
before August 31,2017, or such later date as may be approved by the Director.” The
Phase 1 cover placement occurred between April 1,2016 and April 20, 2017, meeting the
requirement for timeliness of installation.
d. “An as-built report for Cell 2 Phase 1 cover placement will be provided to the Director
within 90 days after completion of construction, or such later date as may be approved by
the Director.” Phase 1 cover construction was completed April 20, 2017. Hard copies of
the As-Built Report arrived in the Director's office July 20, 2017, with an electronic copy
arriving on July 18. 2017. The electronic copy arrived 89 days following completion of
the construction, and the official hard copy and CD arrived on day 91 following
completion.
7. Stipulation and Consent Agreement dated February 23, 2017, Agreement 4 states: "The cover
design will be tested by monitoring as set out in [Agreement 3] and comparison of the results to
[specified] performance criteria." Agreement 3 is being reviewed under another project, and so
has been omitted here, along with the associated requirements, to avoid redundant review.
8. Reclamation Plan Revision 5.1, Section 3.2.2, p. 3-4 imposes several requirements:
a. “Cell 2 final cover construction will occur in two phases and includes a performance
monitoring test section (Primary Test Section) containing a lysimeter constructed in the
southeast portion of Cell 2 concurrently with the Phase 1 cover placement.” The Primary
Test Section is the subject of a parallel review effort, and so will not be detailed here. It
is sufficient here to state that the Primary Test Section is installed and functioning as
anticipated.
b. “A Supplemental Test Section will be constructed north of the tailings management cells
relating to vegetative cover and erosion control.” This feature has been constructed, but I
have not observed its condition as its construction occurred after my last visit to the site.
I will make this a focus of a future visit to the site.
c. “The plan for implementing final cover placement on Cell 2 and performance assessment
and monitoring is presented in Appendix A. Cell 2 Phase 1 cover placement began in
May 2016 and is expected to be completed in two construction seasons.” As noted in
Item 6 in this section, Phase 1 cover construction is complete and meets all specifications.
9. Reclamation Plan Revision 5.1, Section 3.2.2.1, p. 3-4 governs installation of the various layers
that make up the cover system. Inasmuch as only the first 2 layers of the Cell 2 are involved in
the current project, only requirements salient to those elements will be addressed here:
Reclamation Plan 5.1, Cell 2 Phase 1 Cover Construction
January 9, 2018
Page 12
a. “Layer 1 - 2.5 ft (76 cm) thick (minimum) Interim Fill Layer acting as a Secondary
Radon Attenuation and Grading Layer (loam to sandy clay).... It is assumed that this
material was or will be dumped and minimally compacted by construction equipment to
approximately 80 percent of standard Proctor density.” The As-built Report confirms
that the material selected, the placement of the material, the compaction of the material,
and the thickness of the layer all meet the stated specifications.
b. “Layer 2 - 3.0 to 4.0 ft (91 to 122 cm) thick Compacted Cover acting as the Primary
Radon Attenuation Layer (highly compacted loam to sandy clay).... Layer 2 will be
compacted cover layer and act as the primary radon attenuation layer. It will be 3 - 4 feet
thick (3 feet for Cells 1, 4A, and 4B, 3.5 feet for Cell 3, and 4 feet for Cell 2) and
compacted to 95 percent of standard Proctor density.” The As-built Report confirms that
the material selected, the placement of the material, the compaction of the material, and
the thickness of the layer all meet the stated specifications.
10. Reclamation Plan Revision 5.1, Section 3.2.2.1, p. 3-5 presents several criteria from 10 CF$ 40
Appendix A that have already been treated in the review of the reclamation plan and in previous
paragraphs in this section of this report. I have not repeated these requirements here. See
Paragraphs 1 through 5 above.
11. Reclamation Plan Revision 5.1, Section 3.2.2.3, p. 3-6 repeats design elements treated in earlier
paragraphs. I have not repeated the requirements here. See Paragraphs 6 and 9 above.
12. Reclamation Plan Revision 5.1, Section 3.3.5, p. 3-9 presents design considerations for the
finished contours of the project. The installation of the required cover elements to reach these
final grades will not occur until after the conclusion of the test period; therefore, I have not
presented a discussion of those elements here.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to construction of the first two layers of the cover system for Cell 2. As a result,
the milestones imposed by 10 CFR 40 Appendix A have been satisfied. The only remaining milestones
are related to completion of the study outlined in the Stipulation and consent Agreement governing the
two test sections and the future consideration for approval of the evapotranspirative cover.
During the series of inspections reported herein, the Secondary Test Section had not been completed.
The plant diversity and density for the Primary Test Section had not achieved expected levels. Both of
these elements are being followed through parallel efforts to this one, so no additional recommendations
are formulated here..
Attachments: Radon monitoring results for March and July, 2017.
8/23/2017 State of Utah Mail - Radon Flux measurements
Radon Flux measurements
1 message
Kathy Weinel <[e-mail]>
To: "Russell Topham ([e-mail])'1 <[e-mail]>
Here are the 2017 results
Russell Topham <[e-mail]>
Wed, Aug 23, 2017 at 7:48 AM
2 attachments
Q1 2017 Cell
1470K
2.pdf
Q3 2017 Cell 2.pdf^ 1366K
https://mail.google.com/mail/u/1/?ui=2&ik=3744873c9a&jsver=NQ90xUauj60.en.&view=pt&search=inbox&th=15e0f5a4832e93ac&siml=15e0f5a4832e... 1/1
Ceil 2
2017 Radon Flux Measurement Program
Second Half 2017 Sampling Results
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
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........................................................................1
4. SAMPLING METHODOLOGY...........................................................................................................1
5. FIELD OPERATIONS..........................................................................................................................2
5.1 Equipment Preparation............................................................................................................2
5.2 Sample Locations, Identification, and Placement................................................................2
5.3 Sample Retrieval.....................................................................................................................3
5.4 Environmental Conditions.....................................................................................................3
6. SAMPLE ANALYSIS...........................................................................................................................4
6.1 Apparatus..................................................................................................................................4
6.2 Sample Inspection and Documentation.................................................................................4
6.3 Background and Sample Counting........................................................................................4
7. QUALITY CONTROL (QC) AND DATA VALIDATION..............................................................5
7.1 Sensitivity.................................................................................................................................5
7.2 Precision....................................................................................................................................5
7.3 Accuracy...................................................................................................................................5
7.4 Completeness...........................................................................................................................5
8. CALCULATIONS..................................................................................................................................6
9. RESULTS...............................................................................................................................................7
9.1 Mean Radon Flux.....................................................................................................................7
9.2 Site Results................................................................................................................................8
References...................................................................................................................................................9
Figure 1......................................................................................................................................................10
Appendix A. Charcoal Canister Analyses Support Documents
Appendix B. Recount Data Analyses
Appendix C. Radon Flux Sample Laboratory Data, Including Blanks
Appendix D. Sample Locations Map (Figure 2)
1.INTRODUCTION
During July 15-16, 2017 Tellco Environmental, LLC (Tellco) of Grand Junction, Colorado, provided
support to Energy Fuels Resources (USA) Inc. (Energy Fuels) to conduct radon flux measurements on
Cell 2 at its White Mesa Mill site.
Pursuant to Utah Department of Environmental Quality (UDEQ) requirements, Energy Fuels conducts
radon flux measurements on a semiannual basis.
This report presents the radon flux measurements results for Cell 2 that represent the second half of
the year 2017. 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.
Cell 2, which has a total area of approximately 270,624 m2, has been filled and covered. This cell is
comprised of one region, a soil cover of varying thickness. There was no standing liquid and were no
exposed tailings within Cell 2 during this sampling.
3. REGULATORY REQUIREMENTS FOR CELL 2
Radon emissions from the uranium mill tailings at this site are regulated by the State of Utah’s
Division of Waste Management and Radiation Control (DWMRC). In accordance with DWMRC
requirements specified in correspondence dated July 23, 2014, Energy Fuels must measure the radon
flux on Cell 2 in accordance with 40 CFR 61, Appendix B, Method 115, "Monitoring for Radon-222
Emissions" semiannually. The average annual measured radon flux for Cell 2 shall not exceed a value
of 20 picoCuries per meter squared per second (pCi/m2-s).
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, 2017). 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 V2 inch thick layer of foam and
secured with a retaining ring under 1 Vi 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
1
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 sample loss and/or further exposure during transport), identified and labeled, and
transported to the Tellco laboratory in Grand Junction, Colorado for analysis. Tellco personnel
maintained custody of the samples from collection through lab 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 equipment used was subsequently released for unrestricted use.
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 (LTD), the entire charcoal batch was labeled non-conforming and
recycled through the heating/drying process.
5.2 Sample Locations, Identification, and Placement
On July 15, 2017, 100 sampling locations were spread out throughout the Cell 2 covered region. The
approximate sampling locations that were established for previous samplings of Cell 2 were used for
the placement of the canisters, 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., F01.. .F100). This ID was
written on an adhesive label and affixed to the top of the canister. The sample ID, date, and time of
2
placement were recorded on the radon flux measurements data sheets for the set of one hundred
measurements.
Prior to placing a canister at each sample location, the retaining ring, screen, and foam pad of each
canister were removed to expose the charcoal support grid. A pre-measured charcoal charge was
selected from a batch, opened and distributed evenly across the support grid. The canister was then
reassembled and placed face down on the surface at each sampling location. Care was exercised not
to push the device into the soil surface. The canister rim was “sealed” to the surface using a berm of
local borrow material.
Five canisters (blanks) were similarly processed and these canisters were kept inside an airtight plastic
bag during the 24-hour testing period.
5.3 Sample Retrieval
On July 16, 2017 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 of the charcoal samples from the Cell 2 covered region were successfully retrieved and
containerized during the retrieval and unloading process.
5.4 Environmental Conditions
A rain gauge and thermometer were placed at Cell 2 to monitor rainfall and air temperatures during
sampling; additionally. Energy Fuels maintains an onsite rain gauge.
In accordance with 40 CFR, Part 61, Appendix B, Method 115:
• Measurements were not initiated within 24 hours of rainfall at the site.
• There was no rainfall during the 24-hour sampling period.
• All canister seals remained intact during the 24-hour sampling period.
• The criteria regarding 35 degree F minimum ambient air temperature and unfrozen ground
do not apply when performing sampling at multiple times throughout the year; however,
the minimum air temperature during the 24-hour sampling period was 62 degrees F, and
the ground was not frozen.
3
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.
o Ohaus Port-O-Gram balance with 0.1 -gram sensitivity.
6.2 Sample Inspection and Documentation
Once in the laboratory, the integrity of each charcoal container was verified by visual inspection of the
plastic container. Laboratory personnel checked for damaged or unsealed containers and also checked
that the data sheet was complete.
All 100 of the sample containers and 5 blank containers inspected at the Tellco analytical laboratory
were ultimately verified as valid with no damaged or unsealed containers 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 system with shielded counting 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 gamma 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.
4
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, 2017) were
attained.
7.1 Sensitivity
A total of five blanks were analyzed by measuring the radon progeny activity in samples subjected to
all aspects of the measurement process, excepting exposure to the source region. These blank sample
measurements comprised approximately 5 percent of the field measurements. Analysis of the five
blank samples measured radon flux rates ranging from approximately 0.02 to 0.04 pCi/m2-s, with an
average of approximately 0.03 pCi/m2-s. The lower limit of detection (LED) was approximately 0.04
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 values of recount
measurements that were above 1 pCi/m2-sec, expressed as relative percent difference (RPD), ranged
from 3.2 to 5.1 percent RPD with an average RPD of approximately 4.2 percent.
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 -1.7 percent to +0.7 percent. The arithmetic average bias of the lab
control sample measurements was approximately -0.7 percent (see Appendix A).
7.4 Completeness
One hundred samples from the Cell 2 cover region were verified, representing 100 percent
completeness.
5
8. CALCULATIONS
Radon flux rates were calculated for charcoal collection samples using calibration factors derived
from cross-calibration to sources with known total activity with identical geometry as the charcoal
containers. A yield efficiency factor was used to calculate the total activity of the sample charcoal
containers. Individual field sample result values presented were not reduced by the results of the field
blank analyses.
In practice, radon flux rates were calculated by a database computer program. The algorithms utilized
by the data base program were as follows:
Equation 8.1:
2 NPCi Rn-222/m sec =
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:
0.1698, for M-01/D-21 and
0.1701, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
Equation 8.2:
Error, 2<r = 2 x
Gross Sample, cpm Background Sample,cpm
i SampleCount,t,min Background Count,t,min
Net,cpm
x Sample Concentration
Equation 8.2:
LLD =2-7L+(4.6518,1
[Ts*A*b*0.5c,WT'75)J
where: 2.71
4.65
Sb
Ts
b
d
A
= constant
= confidence interval factor
= standard deviation of the background count rate
= sample duration, seconds
= instrument calibration factor, cpm per pCi; values used:
0.1698, for M-01/D-21 and
0.1701, for M-02/D-20
= decay time, elapsed hours between sample mid-time and count mid-time
= area of the canister, m2
6
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:
Js
JiAi + ■ ■ ■ .NA, r+1 ■ ■ ■ J;A;
Ai
Where: Js = Mean flux for the total pile (pCi/m2-s)
Jj = Mean flux measured in region i (pCi/m2-s)
Aj = Area of region i (m2)
A, = Total area of the pile (m2)”
40 CFR 61, Subpart W, Appendix B, Method 115, Subsection 2.1.8, Reporting states “The results of
individual flux measurements, the approximate locations on the pile, and the mean radon flux for each
region and the mean radon flux for the total stack [pile] shall be included in the emission test report. Any
condition or unusual event that occurred during the measurements that could significantly affect the results
should be reported."
7
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 2017.
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 2017.
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
Handta
'2*h» Tine* C^arcOa* 5'ippt>«! Cr-I
r I GlA£. l Larje-Ar&a l^aaon Col led or
10
Appendix A
Charcoal Canister Analyses Support Documents
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CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION: 4-<- AU'l ) "B 1 to } Uffl U
CLIENT: £ ^.lA S ^_______________
Calibration Check Log
System ID: O V / X) ~ 1 Calibration Date: “T j i~l j v~) Due Date: I ^ j
Scaler S/N:________________________ High Voltage: U V/3 Window: 4.42 Thrshld: 2,20
Detector S/N: C> H 1 5^ 3_______ Source ID/SN: O H Source Activity: 5^ 3 C\
Blank Canister Bkgd. Range, cpm: 2 ct = 1 to ^ l 3 a = ^ 5~ to t ^3-
Gross Source Range, cpm:2g = to lc?4SB 3a = ^90-4 to
Technician:
All counts times are one minute.
Date By Background Counts (1 min. each)Source Counts (1 min. each) ok?
Y/N#1 #2 #3 Avg.#1 #2 #3 Average
7J‘0/n ilr2-»3^Ixi 12-6 l.0»4O rO-Z^D 10^34 107^6 V
lift foift^,101-70 io*s>i yTmfnmll^L\no /4l 1x5-IO\-73 v
ih^jn txo tn m 1740 »oi3u>IOI3C?r
sw
VoStf-
p¥e
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: \jOWYU > uuk
client: Ev^^y pv^eVc, ^^.<,0 kk/TA 9 C M,5A\
System ID: M-Qv /
Scaler S/N:__
Detector S/N: g> Hi
Blank Canister Bkgd. Range, cpm: 2 a =
Gross Source Range, cpm: 2 <j = ^
Calibration Check Loe
__ Calibration Date: 1~1 / f~?
High Voltage: \IU3 Window:
Source ID/SN: . Source Activity: 5^.~^ktpC;
1 to 1^3 ) 3 CT =______91^5 to 1(0*7-
Due Date: 'l I 1 ~7 / 1 8
4.42 Thrshld: 2.20
to tOH^S to t°SS~7
Technician:
All counts times are one minute.
Date By Background Counts (1 min. each)Source Counts (1 min. each)ok?
Y/N#1 #2 #3 Avg #1 #2 #3 Average
ikQjn ■pz7 \7-l yib ion^y
'ihefn iJJi 1 \fi icnLrO 10146 v
ri*fn )iO ih(\'zg lonc^iOLC?0)I007,<f>V
il \°>ln bZC.\JlO \wr \Tty t c9\«IOO-7C*7
vw.
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
SUE LOCATION:
CUENT: E.1A^-/~C|Y FvA-g-l^ V. <>
Calibration Check Log
System ID: ^A.^O"2_//T) -2_0 Calibration Date: } l~~) J t
Calibration Check Log
System ID: *p -2,0_______ Calibration Date: / l~l j /~7__ Due Date: ~7 / l7 ) tS
Scaler S/N:_____________________________ High Voltage: S0 ^ Window: 4.42 Thrshld: 2.20
Detector S/N: ___ Source ID/SN: fc^/frS- OH Source Activity:
Blank Canister Bkgd. Range, cpm: 2 a = t IQ______to ______ 3 c =_____^ R to _ _Lkf3____
Gross Source Range, cpm 2 o = to /O 3 a = ^ ft to iO (g
Technician:
All counts times are one minute.
Date By Background Counts (1 min. each)Source Counts (1 min. each)ok?
Y/N#1 #2 #3 Avg.#1 #2 #3 Average
ijmTT IT.©\^7-If?157 IOIS-7 loTi^T iOl^Co /
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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.
Calibration Check Log
System ID: KA.~Qj-*2_Q Calibration Date: j IT J ^~7 Due Date: 'l j 11 j IS
Scaler S/N:_______S V S (.a ________High Voltage: 060 Window: 4,42 Thrshld: 2.20
Detector S/N: 04^ !> ~2- Source ID/SN: -S^^^ource Activity:
Blank Canister Bkgd. Range, cpm: 2 o = \ lQ_______to _ tS~7 3 <?= to tG>8
Gross Source Range, cpm: 2 a= tyPil I to lOM 3 o = ^ to
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:. M;l\ jl^l flirt d.\ > u. "^v k.
CLIENT: f
Technician: _
All counts times are one minute.
Date By Background Counts (1 min. each)Source Counts (l min. each)ok?
Y/N#1 #2 #3 Avg.#1 #2 #3 Average
1 ia/17 PH-12ft /3“2-IS-I 137 tOl0)0)tovC(^lOI^Q V
7 m)n bJLc-tu.re; 4 13\1-34 /DI<VX loi-zrx 10 7-17
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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: 0 kgLkS ?^f ~ ^ ^ S^;/3.3Q7
Standard Weight (ate ^0o ^ -
Date Pre-check (g)Post-check (g)O.K. 10.1 % ?By
7/i8/n 3 00,0 2*P>P)
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f
Appendix B
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Appendix D
Sample Locations Map (Figure 2)
Cell 2
2017 Radon Flux Measurement Program
First Half 2017 Sampling Results
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
/
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......................................................................1
4. SAMPLING METHODOLOGY.......................................................................................................1
5. FIELD OPERATIONS......................................................................................................................2
5.1 Equipment Preparation.........................................................................................................2
5.2 Sample Locations, Identification, and Placement..............................................................2
5.3 Sample Retrieval.................................................................................................................3
5.4 Environmental Conditions..................................................................................................3
6. SAMPLE ANALYSIS.......................................................................................................................4
6.1 Apparatus.............................................................................................................................4
6.2 Sample Inspection and Documentation..............................................................................4
6.3 Background and Sample Counting.....................................................................................4
7. QUALITY CONTROL (QC) AND DATA VALIDATION............................................................5
7.1 Sensitivity.............................................................................................................................5
7.2 Precision................................................................................................................................5
7.3 Accuracy............................................................................................................. 5
7.4 Completeness........................................................................................................................5
8. CALCULATIONS.............................................................................................................................6
9. RESULTS...........................................................................................................................................7
9.1 Mean Radon Flux.................................................................................................................7
9.2 Site Results...........................................................................................................................8
References...............................................................................................................................................9
Figure 1.................................................................................................................................................10
Appendix A. Charcoal Canister Analyses Support Documents
Appendix B. Recount Data Analyses
Appendix C. Radon Flux Sample Laboratory Data, Including Blanks
Appendix D. Sample Locations Map (Figure 2)
1.INTRODUCTION
During March 21-22, 2017 Tellco Environmental, LLC (Tellco) of Grand Junction, Colorado,
provided support to Energy Fuels Resources (USA) Inc. (Energy Fuels) to conduct radon flux
measurements on Cell 2 at its White Mesa Mill site.
Pursuant to Utah Department of Environmental Quality (UDEQ) requirements, Energy Fuels conducts
radon flux measurements on a semiannual basis.
This report presents the radon flux measurements results for Cell 2 that represent the first half of the
year 2017. 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.
Cell 2, which has a total area of approximately 270,624 m2, has been filled and covered. This cell is
comprised of one region, a soil cover of varying thickness. There was no standing liquid and were no
exposed tailings within Cell 2 during this sampling.
3. REGULATORY REQUIREMENTS FOR CELL 2
Radon emissions from the uranium mill tailings at this site are regulated by the State of Utah’s
Division of Waste Management and Radiation Control (DWMRC). In accordance with DWMRC
requirements specified in correspondence dated July 23, 2014, Energy Fuels must measure the radon
flux on Cell 2 in accordance with 40 CFR 61, Appendix B, Method 115, "Monitoring for Radon-222
Emissions" (2013) semiannually. The average annual measured radon flux for Cell 2 shall not exceed
a value of 20 picoCuries per meter squared per second (pCi/m2-s).
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, 2016). 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 V2 inch thick layer of foam and
secured with a retaining ring under 1 ‘A 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
1
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 sample loss and/or further exposure during transport), identified and labeled, and
transported to the Tellco laboratory in Grand Junction, Colorado for analysis. Tellco personnel
maintained custody of the samples from collection through lab 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 equipment used was subsequently released for unrestricted use.
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 March 21, 2017, 100 sampling locations were spread out throughout the Cell 2 covered region.
The approximate sampling locations that were established for previous samplings of Cell 2 were used
for the placement of the canisters, 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
2
time of placement were recorded on the radon flux measurements data sheets for the set of one
hundred measurements.
Prior to placing a canister at each sample location, the retaining ring, screen, and foam pad of each
canister were removed to expose the charcoal support grid. A pre-measured charcoal charge was
selected from a batch, opened and distributed evenly across the support grid. The canister was then
reassembled and placed face down on the surface at each sampling location. Care was exercised not
to push the device into the soil surface. The canister rim was “sealed” to the surface using a berm of
local borrow material.
Five canisters (blanks) were similarly processed and these canisters were kept inside an airtight plastic
bag during the 24-hour testing period.
5.3 Sample Retrieval
On March 22, 2017 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.
The charcoal from one of the samples (B20) was spilled during the canister retrieval process. The
remaining charcoal samples from the Cell 2 covered region were successfully retrieved and
containerized during the retrieval and unloading process.
5.4 Environmental Conditions
A rain gauge and thermometer were placed at Cell 2 to monitor rainfall and air temperatures during
sampling; additionally, Energy Fuels maintains an onsite rain gauge.
In accordance with 40 CFR, Part 61, Appendix B, Method 115:
• Measurements were not initiated within 24 hours of rainfall at the site.
• There was no rainfall during the 24-hour sampling period.
• All canister seals remained intact during the 24-hour sampling period.
® The criteria regarding 35 degree F minimum ambient air temperature and unfrozen ground
do not apply when performing sampling at multiple times throughout the year; however,
the minimum air temperature during the 24-hour sampling period was 44 degrees F, and
the ground was not frozen.
3
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 Port-O-Gram balance with 0.1-gram sensitivity.
6.2 Sample Inspection and Documentation
Once in the laboratory, the integrity of each charcoal container was verified by visual inspection of the
plastic container. Laboratoiy personnel checked for damaged or unsealed containers and also checked
that the data sheet was complete. One container (for sample B20) was nearly empty because most of
the charcoal from that sample was spilled during retrieval, as previously mentioned.
The remaining 99 sample containers and 5 blank containers inspected at the Tellco analytical
laboratory were ultimately verified as valid with no damaged or unsealed containers 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 system with shielded counting 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 gamma 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.
4
• 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, 2016) were
attained.
7.1 Sensitivity
A total of five blanks were analyzed by measuring the radon progeny activity in samples subjected to
all aspects of the measurement process, excepting exposure to the source region. These blank sample
measurements comprised approximately 5 percent of the field measurements. Analysis of the five
blank samples measured radon flux rates ranging from approximately 0.00 to 0.02 pCi/m2-s, with an
average of approximately 0.01 pCi/m2-s. The lower limit of detection (LLD) was approximately 0.04
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 values of recount
measurements, expressed as relative percent difference (RPD), were all less than 0.1 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 -1.7 percent to +1.3 percent. The arithmetic average bias of the lab
control sample measurements was approximately -0.4 percent (see Appendix A).
7.4 Completeness
Ninety-nine out of the total 100 samples from the Cell 2 cover region were verified, representing 99
percent completeness.
5
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 = '[js*A*b*o.5»w[^j
where:N = net sample count rate, cpm under 220-662 keV peak
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi; values used:
0.1698, for M-01/D-21 and
0.1697, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
Equation 8.2:
Error,2o- = 2x
Gross Sample, cpm Background Sample,cpm
Sample Count, t,min Background Count,t,min
Net,cpm
X Sample Concentration
Equation 8.3:
LLD =2.71 + (4.651(Sul
where: 2.71
4.65
Sb
Ts
b
d
A
constant
confidence interval factor
standard deviation of the background count rate
sample duration, seconds
instrument calibration factor, cpm per pCi; values used:
0.1698, for M-01/D-21 and
0.1697, forM-02/D-20
decay time, elapsed hours between sample mid-time and count mid-time
area of the canister, m2
6
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:
Js
1^ + ... JtA? 1+1... JjA;
A,
Where: Js = Mean flux for the total pile (pCi/m2-s)
Ji = Mean flux measured in region i (pCi/m2-s)
Af = Area of region i (m2)
At = Total area of the pile (m2)”
40 CFR 61, Subpart W, Appendix B, Method 115, Subsection 2.1.8, Reporting states “The results of
individual flux measurements, the approximate locations on the pile, and the mean radon flux for each
region and the mean radon flux for the total stack [pile] shall be included in the emission test report. Any
condition or unusual event that occurred during the measurements that could significantly affect the results
should be reported."
7
9.2 Site Results
Site Specific Sample Results (reference Appendix C)
(a) The mean radon flux for the Cell 2 region at the site is as follows:
Cell 2 - Cover Region = 0.5 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 = 0.5 pCi/m2-s
t0.5¥270.624^ = 0.5
270,624
As shown above, the arithmetic mean of the radon flux rate measurements representing the first half
of the year 2017 for Cell 2 at Energy Fuels' White Mesa milling facility is well below the U.S.
Nuclear Regulatory Commission and EPA regulatory standard of 20 pCi/m2-s.
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 2016.
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 2017.
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
1 '2*in Tinc« Ctio'cuo-
Suppixl
tO-lfl Dr) PVC End Op
MCtflE 1 lirse-Arei R«»on r.ollsclor
10
Appendix A
Charcoal Canister Analyses Support Documents
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CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:.
CLIENT: PaeU I^e5gurcf^ Cu$^)
Calibration Check Log
System ID: M ' 0* / IP" ____________ Calibration Date: W / / C' Due Date: ^ ! 1 ~7
Sealer S/N: _S I S X
Detector S/N: O M I 5 3 3
High Voltage: I 1 ^°) Window:____i42____ Thrshld: 2.20
Source ID/SN: *■**»/<*- Source Activity: S^»3 K
Blank CanisterBkgd. Range, cpm: 2 O = ‘ P 8______to ^ ^ I 3 G= ^ M____________to t ~7 H
Gross Source Range, cpm: 2 o = ^ to I 045$ 3 0 = ^ ^1 to I
Technician: tZC
All counts times are one minute.
Date By BackKround Counts (1 min. each)Source Counts (1 min. each)ok?
Y/N#1 #2 #3 Avg.#1 #2 #3 Average
3/^/n IXCh ‘7>o 17-y ICTMV 10 2-0 3
p/ZC l7_8 To^IT-I ico<?)4 lOo<V7 10(^6 ld?( -J-C?
VZS//-7 73c7~1 ‘^l |3|lDOat2-3^183 10072./
3/2-S-/, 7 l4^17 |2-°|iDlc?"?l«93o^,0 3-2-6 V
?rc
fr*
Posf
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.
Calibration Check Log
System ID: l'vA'^l /V--*) _ Calibration Date: Due Date: ~^ / I ^ * "7
Scaler S/N: b I ^______________High voltage; \ | (p°) Window: 4.42 Thishld: 2.20
jDetector S/N: OHl53^ _ Source ID/SN: OS Source Activity: 5^-3
Blank Canister Bkgd. Range, cpm: 2 a =____[ Q g to 1^1 3q= to
Gross Source Range, cpm: 2 a = qqoq 3„. loloo-^g
Technician: _ 17A
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION: (A (A t K
CLIENT: y p <A ^ <? »A iTc--g $ C^J^-^ ________
All counts times are one minute.
Date By Background Counts (1 min. each)Source Counts (1 min. each)ok?
Y/N#1 #2 . #3 Avg.#1 #2 #3 Average
(7^1 ,33 iT-V (.0.0 77 fO/X 1 l°.(? \\Ot oo i3/W/7 VPC-1^</I2_^i loF 'V 100^i Oloif 10(05 i
3/-2.S/ r7 VU-<H(/115-131 l-OZuLf Wb-T-i o is-o y
’bf'Zsfn 140 12-1 l 17 1^°1 \ o 1 (OlOH (0(87-1 Ol4U y
?os>+
pc>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.
Calibration Check Log
System ID: M ^ H / ^ ~ _____ Calibration Date: ^ /1 C» Due Date: "7 /^ ^ / 1 ~7 __
Scaler S/N: S1 S 3High Voltage: Window: 4.42 Thrshld: 2.20
Detector S/N: O M <53^._______ Source ID/SN: 4 Source Activity: 5^ 3
Blank Canister Bkgd. Range, cpm: 2 0= l O 3- to I ^3 30= ^~7to I ~7 ^
Gross Source Range, cpm: 2 0 = ^ "5 & to j QMS 3 3 0= to I 7 &
Technician: _
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:. k
CLIENT: l < <f^OL\CC^$ 0-4 SA)
All counts times are one minute.
Date By Back^ound Counts {J min. each)Source Counts (1 min. each)ok?
Y/N#i #2 #3 Avg.#1 #2 #3 Average
3/*H/n ro^lT-3 10173 iOtsB y
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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 kl 4^ /A £*><* /A\W} . U i
CLIENT: E.^€.rt^^ R CM
System ID
Scaler S/N:
Calibration Check Loe
: ° ^ ^ Calibration Date: 7/ /c/ / /V Due Date: 7//^/f7
I g Q>3High Voltage: Window: 4.42 Thrshld: 2.20
Source ID/SN: KP+ks-oS . Source Activity: S°i' 3 1
Blank Canister Bkgd. Range, cpm: 2 a= * ^ ^ to 1 1/ 3_____3 a = 8*7to ' 7 3
Gross Source Range, cpm: 2 o = ^ ^ to * 5 I 3 c= ^B0"? to I OS B O
Technician:______------------------------------
Detector S/N: O H 1 3 3 2-
All counts times are one minute.
P°>t
Pre
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Date By Background Counts (1 min. each) Source Counts 0 min. each)ok?
Y/N#1 #2 #3 Avg.#1 #2 #3 Average
viMin 104 n*)i^-3 1 0 10L>cm s l C? e> t &/rs^r 1 \ I 0 102.03 i oi^-z-V
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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 Mode!: Q h S ?0<-+0Ser.* 15-3^7
Standard Weight (g): 30&* O
Date Pre-check (g)Post-check (g)O.K. ± 0.1 % ?By
y/7-^/n l>oo,o
3/ZS/17 300. o 3^0. O
Appendix B
Recount Data Analyses
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Radon Flux Sample Laboratory Data (including Blanks)
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Sample Locations Map (Figure 2)