DRC-2013-002511 - 0901a068803927e9

Energy Fuels Resources (USA) Inc.
^ p' Wmmml 225 Union Blvd. Suite 600
QjpJppy Lakewood, CO, US, 80228
Ml ENERGY FUELS 303 974 2140
www. energyfuels. com
VIA EMAIL AND OVERNIGHT DELIVERY "DRC-2013-002511"
June 20,2013 / Rece/Ved
JUN 2013
Mr. Bryce Bird ^vision of
Director, Utah Division of Air Quality \h, Nation Control
State of Utah Department of Environmental Quality ^ 0
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 May 2013 Monthly Radon Flux Monitoring Report for Cell 2
iv 1
Dear Mr. Bird:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI's") radon-222 flux monitoring report
for May 2013 (the "Monthly Repoit") pursuant to 40 CFR 61.254(b), for Cell 2 at the White Mesa
Uranium Mill (the "Mill"). Cell 2, which was constructed and placed into operation prior to December
15, 1989 is subject to the requirements in 40 CFR 61.252(a). As discussed in our 2012 Annual Radon
Flux Monitoring Report submitted March 29, 2013, Cell 2 was not in compliance with the emissions
limits in 40 CFR 61.252(a) of 20 pCi/(m2 sec) for the calendar year 2012. This Monthly Report is
submitted pursuant to 40 CFR 261(b) which requires monthly reporting of monitoring data collected
beginning the month immediately following the submittal of the annual repoit for the year in non-
compliance.
Included with the Monthly Report is a Radon Flux Measurement Program Repoit, dated May 2013,
prepared by Tellco Environmental (the "Tellco May 2013 Monthly Report"). The Tellco May 2013
Monthly Report indicates that for the month of May 2013, the average radon flux from Cell 2 of 22.6
pCi/(m sec), did not comply with the standard in 40 CFR 61.252(a).
If you have any questions, please feel free to contact me at [phone].
Yours very truly,
Energy Fuels Resources (USA) Inc.
Jo Ann Tischler
Manager, Compliance and Licensing
N:\WMM\Required Reports\NESHAPS Reports\2013 Monthly NESHAPs\Cell 2 May 2013 Monthly NESHAPS\transmtl
Cell 2 Radon Flux May 2013.doc
Letter to B. Bird
May 29, 2013
Page 2 of 2
cc: David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Rusty Lundberg, Utah DRC
Jay Morris, Utah DAQ
Harold R. Roberts
David E. Turk
Kathy Weinel
Director, Air and Toxics Technical Enforcement Program, Office of Enforcement, Compliance
and Environmental Justice, U. S. Environmental Protection Agency
Attachments
ENERGY FUELS RESOURCES (USA) INC.
40 CODE OF FEDERAL REGULATIONS 61 SUBPART W
WHITE MESA MILL
SAN JUAN COUNTY, UTAH
MONTHLY COMPLIANCE REPORT FOR MAY 2013
Submitted June 20,2013
by
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
[phone]
1) Name and Location of the Facility
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Mill (the "Mill"),
located in central San Juari County, Utah, approximately 6 miles (9.5 km) south of the city of
Blanding. The Mill can be reached by private road, approximately 0.5 miles west of Utah
State Highway 191. Within San Juan County, the Mill is located on fee land and mill site
claims, covering approximately 5,415 acres, encompassing all or part of Sections 21, 22, 27,
28, 29, 32, and 33 of T37S, R22E, and Sections 4, 5, 6, 8, 9, and 16 of T38S, R22E, Salt Lake
Base and Meridian.
All operations authorized by the Mill's State of Utah Radioactive Materials License are
conducted within the confines of the existing site boundary. The milling facility currently
occupies approximately 50 acres and the tailings disposal cells encompass another 275 acres.
2) Monthly Report
This Repoit is the monthly report for the Mill's Cell 2 for May 2013, required under 40 Code
of Federal Regulations (CFR) 61.254(b).
A summary of the events that gave rise to the requirement to file this monthly report under 40
CFR 61.254(b) is set out in Section 4 of this Report. A summary of the radon emissions from
Cell 2 measured in May 2013 is set out in Section 5 of this Report.
The monthly monitoring data for May 2013 required under 40 CFR 61.254(b) is provided in
Attachment 1 to this Report, which contains the Radon Flux Measurement Program Report,
dated May 2013, prepared by Tellco Environmental (the "Tellco May 2013 Monthly
Report"). The results are summarized in Section 5 of this Repoit.
3) Name of the Person Responsible for Operation and Preparer of Report
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, Colorado 80228
303.628.7798 (phone)
303.389.4125 (fax)
EFRI is the operator of the Mill and its tailings impoundments (Cells 2, 3, and 4A) and
evaporation impoundments (Cells 1 and 4B). The Mill is an operating conventional uranium
mill, processing both conventional ores and alternate feed materials. The "method of
operations" at the Mill is phased disposal of tailings. Compliance with the NESHAP
standards at 40 CFR 61.252(a) is determined annually for existing impoundments (i.e., Cells
2 and 3). The annual Radon emissions for existing impoundments are measured using Large
Area Activated Charcoal Canisters in conformance with 40 CFR, Part 61, Appendix B,
Method 115, Restrictions to Radon Flux Measurements, (Environmental Protection Agency
["EPA"], 2008). These canisters are passive gas adsorption sampling devices used to
determine the flux rate of Radon-222 gas from the surface of the tailings material. For
impoundments licensed for use after December 15, 1989 (i.e., Cell 4A, and 4B), EFRI
employs the work practice standard listed at 40 CFR 61.252(b)(1) in that all tailings
impoundments constructed or licensed after that date are lined, are no more than 40 acres in
area, and no more than two impoundments are operated for tailings disposal at any one time.
2
EFRI is submitting this monthly compliance report in conformance with the standards in 40
CFR 61.254(b).
4) Background Information - Summary of 2012 Annual Report
Facility History
Cells 2 and 3, which are 270,624 m2 (approximately 66 acres) and 288,858 m2 (approximately
71 acres), respectively, were constructed prior to December 15, 1989 and are considered
"existing impoundments" as defined in 40 CFR 61.251. Radon flux from Cells 2 and 3 is
monitored annually, as discussed below.
Cells 4A and 4B were constructed after December 15, 1989, and are subject to the work
practice standards in 40 CFR 61.252(b)(1), which require that the maximum surface area of
each cell not exceed 40 acres. For this reason, Cells 4A and 4B are not required to undergo
annual radon flux monitoring.
Cell 3, which is nearly filled, and Cell 4A, receives the Mill's tailings sands. Cells 1 and 4B,
receive solutions only, and are in operation as evaporative ponds. Cell 2 is filled with
tailings, is covered with an interim soil cover, and is no longer in operation.
Dewatering of Cell 2
The Utah Division of Water Quality issued Groundwater Discharge Permit ("GWDP') UGW-
370004 in 2005. Under Part I.D.3 of the current GWDP, EFRI has been required to
accelerate dewatering of the solutions in the Cell 2 slimes drain. Dewatering of Cell 2 began
in 2008. In mid-2011, changes were made in the pumping procedures for slimes drain
dewatering of Cell 2 that resulted in an acceleration of dewatering since that time. As
discussed in more detail below, studies performed by EFRI indicate that the increase in radon
flux from Cell 2 has likely been caused by these dewatering activities. No other changes
appear to have occurred in condition, use, or monitoring of Cell 2 that could have resulted in
an increase in radon flux from the cell.
The average water level in the Cell 2 slimes drain standpipe for each of the years 2008
through 2012 indicate that water levels in Cell 2 have decreased approximately 3.25 feet
(5600.56 to 5597.31 fmsl) since 2008. Of this decrease in water level, approximately 1 foot
occurred between 2010 and 2011, reflecting the improved dewatering that commenced part
way through 2011, and approximately 2 feet between 2011 and 2012, reflecting improved
dewatering for all of 2012.
Radon Flux Monitoring of Cell 2
Tellco performed the 2012 radon flux sampling during the second quarter of 2012 in the
month of June. On June 25 2012, Tellco advised EFRI that the average radon flux for Cell 2
from samples taken in June 2012 was 23.1 pCi/(m2 sec) (referred to in the Tellco report as
pCi/m2"s), which exceeded the Subpart W requirement. The result of the 2012 radon-222 flux
monitoring for Cell 3 was 18 pCi/(m2 sec). Cell 3, therefore, was in compliance with this
standard for 2012.
3
40 CFR 61.253 provides that:
"When measurements are to be made over a one year period, EPA shall be
provided with a schedule of the measurement frequency to be used. The
schedule may be submitted to EPA prior to or after the first measurement
period."
EFRI advised the Utah Division of Air Quality ("DAQ"), by notices submitted on August 3
and September 14, 2012, that EFRI planned to collect additional samples from Cell 2 in the
third and fourth quarters of 2012. These samples were collected on September 9, October 21,
and November 21, 2012, respectively. As the June monitoring for Cell 3 indicated that it was
in compliance with the standard, further monitoring of Cell 3 was not performed.
The result of the 2012 radon-222 flux monitoring for Cell 2 was 25.9 pCi/(m2"sec) (averaged
over four monitoring events). The measured radon flux from Cell 2 in 2012 therefore
exceeded the standard in 40 CFR 61.252(a) of 20 pCi/(m2 "sec).
The Cell 2 and Cell 3 radon flux results were reported in EFRI's 2012 Annual Radon Flux
Monitoring Report (the "2012 Annual Report").
The provisions of 40 CFR 61.254(b) requires that:
"If the facility is not in compliance with the emission limits of paragraph 61.252 in
the calendar year covered by the report, then the facility must commence reporting to
the Administrator on a monthly basis the information listed in paragraph (a) of this
section, for the preceding month. These reports will start the month immediately
following the submittal of the annual report for the year in non-compliance and will
be due 30 days following the end of each month."
This Report is the required monthly report for May 2013 for Cell 2. Monthly monitoring will
continue until US EPA or DAQ determines that it is no longer required.
Evaluation of Potential Factors Affecting Radon Flux
In an attempt to identify the cause of the increase in radon flux at Cell 2, EFRI conducted a
number of evaluations including:
• Excavation of a series of 10 test pits in the Cell 2 sands to collect additional
information needed to ascertain factors affecting radon flow path and flux,
• Evaluation of radon trends relative to slimes drain dewatering,
• Development of correlation factors relating dewatering rates to radon flux, and
• Estimation of the thickness of temporary cover that would be required to achieve
compliance with the radon flux standard of 20 pCi/(m2 sec), during the dewatering
process.
These studies and results are discussed in detail in EFRI's 2012 Annual Radon Flux Report
and summarized in the remainder of this section.
4
Slimes drain dewatering data indicate that a lowering of the water level in Cell 2 has resulted
in an increase in the average radon flux, and that an increase in water level has resulted in a
decrease in the average radon flux. Changes in radon flux have consistently been inversely
proportional to changes in water levels in Cell 2 since 2008. For the last three years the
change in radon flux has been between 3 and 5 pCi/(m2 sec) per each foot of change in
water level. It is also noteworthy that the significant increases in radon flux from Cell 2
which occurred between 2010 and 2011 and between 2011 and 2012 coincided with the
periods of improved (accelerated) dewatering of Cell 2.
EFRI has evaluated these results and has concluded that the increase in radon-222 flux from
Cell 2 that has resulted in the exceedance of the 20 pCi/(m2 sec) standard in 40 CFR 61.252
(a) in 2012 is most likely the unavoidable result of Cell 2 dewatering activities mandated by
the Mill's State of Utah GWDP. This is due to the fact that saturated tailings sands attenuate
radon flux more than dry tailings sands, and 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 EFRFs 2012
Annual Report. SENES estimated a theoretical radon flux from the covered tailings at Cell 2
for various depths (thicknesses) of dry tailings, and predicted future increases in radon flux as
a function of decreases in water levels.
In order to explore potential interim actions that could be taken to maintain radon flux within
the 20 pCi/(m2 sec) standard, the SENES study also evaluated the extent to which radon
emanations from the cell can be reduced by increasing the thickness of the current interim
cover on Cell 2.
5) May 2013 Results
Detailed results for May 2013 for Cell 2 are contained in the Tellco May 2013 Monthly
Report. As described in the Tellco May 2013 Monthly Report, monitoring was performed
consistent with 40 CFR 61 Subpart W Appendix B, Method 115 radon emissions reporting
requirements. The radon monitoring consisted of 100 separate monitoring points at which
individual radon flux measurements have been made by collection on carbon canisters. The
individual radon flux measurements were averaged to determine compliance with 40 CFR
Part 61.252.
The average radon flux for Cell 2 in May 2013 was reported by Tellco to be 22.6 pCi/(m2"
sec). This radon flux value exceeds the 20 pCi/(m2"sec) standard in 40 CFR 61.252.
6) Other Information
Status of Proposed Updated Final Cover Design
As part of developing the Mill's final reclamation plan required to achieve the radon flux
standard of 20 pCi/(m2 sec), a final engineered cover design was submitted by TITAN
Environmental in 1996 and approved by the US Nuclear Regulatory Commission ("NRC").
5
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 Facilitv
40 CFR 61.254(b)(1) requires that in addition to all the information required for an Annual
Report under 40 CFR 61.254(b), monthly reports shall also include a description of all
controls or other changes in operation of the facility that will be or are being installed to bring
the facility into compliance.
Based on the evaluations described in Section 4, above, and as discussed during EFRI's
March 27, 2013 meeting with DAQ and DRC staff, in addition to the monthly monitoring
reported in this Monthly Report, EFRI has proposed the following steps to ensure that radon
emissions from Cell 2 are kept as low as reasonably achievable and to bring the facility into
compliance with the applicable standard:
Construction and Monitoring of Interim Cover Test Area, and Application of
Additional Random Fill
i. EFRI proposes to construct and monitor a test-scale application to confirm the effect
of the addition of one foot of additional soil cover. EFRI proposes to apply one foot
of random fill at 90% compaction to a test area on Cell 2 of 100 feet by 100 feet.
This test area would be established on or before September 2013. The radon flux in
the test area would be measured both before and after placement of the additional fill
and periodically over a six month period. Design of the test soil cover area is
underway.
ii. If the desired reduction (to within compliance levels) is achieved on the test area,
EFRI will apply one foot of additional random fill at 90% compaction, to the
remainder of Cell 2, on or before July 1, 2014. EFRI will perform the 2014 annual
radon flux monitoring of Cell 2 after placement of the fill over the entire Cell 2 area.
The foregoing proposed test and construction activities will be conditional upon DRC
confirming that such activities will not be prejudicial to or inconsistent with the final
approved cover design currently under review, and will be credited toward the final cover
design. As of the date of this report, EFRI has not received DRC's confirmation that the test
and construction activities will not be prejudicial to or inconsistent with the final approved
cover design, or will be credited toward the final cover design.
a) Facility's Perfonnance 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. Iam aware that there are significant penalties for submitting false
information includUg the possibility of fine and imprisonment. See 18, U.S.C. 1001.
Signed: // /y^ v—• Date:
Senior Vice President, General Counsel and Corporate Secretary
ATTACHMENT 1
National Emissions Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
May 2013 Sampling Results
National Emission Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
May 2013 Sampling Results
Prepared for* Energy Fuels Resources (USA) Inc
6425 S Highway 191
P O Box 809
Blanding, Utah 84511
Prepared by Tellco Environmental
P O Box 3987
Grand Junction, Colorado 81502
TABLE OF CONTENTS
Page
1 INTRODUCTION . 1
2 SITE HISTORY AND DESCRIPTION . 1
3 REGULATORY REQUIREMENTS FOR THE SITE 2
4 SAMPLING METHODOLOGY 2
5 FIELD OPERATIONS . . 3
5 1 Equipment Preparation. 3
5 2 Sample Locations, Identification, and Placement. . 3
5 3 Sample Retrieval . 3
5 4 Environmental Conditions . 4
6 SAMPLE ANALYSIS . . 4
6 1 Apparatus . 4
6 2 Sample Inspection and Documentation . 4
6 3 Background and Sample Counting ... 4
7 QUALITY CONTROL (QC) AND DATA VALIDATION . 5
71 Sensitivity . .. ... 5
7 2 Precision ... 5
7 3 Accuracy. . 6
7 4 Completeness . . 6
8 CALCULATIONS . . 6
9 RESULTS . . 7
9 1 Mean Radon Flux 7
9 2 Site Results 8
References ... 9
Figure 1 ... . . 10
Appendix A Charcoal Canister Analyses Support Documents
Appendix B Recount Data Analyses
Appendix C Radon Flux Sample Laboratory Data, Including Blanks
Appendix D Sample Locations Map (Figure 2)
i
1. INTRODUCTION
During May 20-21, 2013, Tellco Environmental, LLC (Tellco) of Grand Junction, Colorado, provided
support to Energy Fuels Resources (USA) Inc (Energy Fuels) to conduct radon flux measurements
regarding the required National Emission Standards for Hazardous Air Pollutants (NESHAPs) Radon
Flux Measurements These measurements are required of Energy Fuels to show compliance with
Federal Regulations (further discussed in Section 3 below) The standard is not an average per facility,
but is an average per radon source The standard allows mill owners or operators the option of either
making a single set of measurements or making measurements over a one year penod (e g , weekly,
monthly, or quarterly intervals)
Previously during 2012, Energy Fuels with support from Tellco, conducted radon flux measurements
in June 2012 on Cell 2 and Cell 3 with the intention of performing a single set of measurements to
represent the year 2012 The arithmetic average radon flux rate of the June 2012 sampling for Cell 3
was below the regulatory standard of 20 picoCunes per square meter per second (pCi/m2-s), however,
the radon flux measurements for Cell 2 exceeded the standard and in response, Energy Fuels
conducted additional radon flux measurements for Cell 2 in September, October, and November 2012
No additional sampling of Cell 3 was performed in 2012 because the average radon flux rate
measured by the June 2012 sampling was below the regulatory standard
Energy Fuels is presently on a monthly radon flux sampling plan for Cell 2 beginning in April 2013,
this report presents the radon flux measurements results for May 2013 Tellco was contracted to
provide radon canisters, equipment, and canister placement personnel as well as lab analysis of
samples Energy Fuels personnel provided support for loading and unloading charcoal from the
canisters This report details the procedures employed by Energy Fuels and Tellco to obtain the
results presented in Section 9 0 of this report
2. SITE DESCRIPTION
The White Mesa Mill facility is located m San Juan County in southeastern Utah, six miles south of
Blanding, Utah The mill began operations in 1980 for the purpose of extracting uranium and
vanadium from feed stocks Processing effluents from the operation are deposited in four lined cells,
which vary in depth Cell 1, Cell 4A, and Cell 4B did not require radon flux sampling, as explained in
Section 3 below
Cell 2, which has a total area of approximately 270,624 square meters (m2), has been filled and
covered with interim cover This cell is comprised of one region, a soil cover of varying thickness,
which requires NESHAPs radon flux monitoring The Cell 2 cover region is the same size in 2013 as
it was in 2012 There are no exposed tailings or standing liquid within Cell 2
Cell 3, which has a total area of 288,858 m2, is nearly filled with tailings sand and is undergoing pre-
closure activities This cell is comprised of two source regions that require NESHAPs radon
monitoring at the time of the June 2012 radon sampling, approximately 219,054 m2 of the cell had a
soil cover of varying thickness and approximately 36,233 m2 of exposed tailings "beaches" The
remaining approximately 33,571 m2 was covered by standing liquid in lower elevation areas
l
3. REGULATORY REQUIREMENTS FOR THE SITE
Radon emissions from the uranium mill tailings at this site are regulated by the State of Utah's
Division of Radiation Control and administered by the Utah Division of Air Quality under generally
applicable standards set by the Environmental Protection Agency (EPA) for Operating Mills
Applicable regulations are specified in 40 CFR Part 61, Subpart W, National Emission Standards for
Radon Emissions from Operating Mill Tailings, with technical procedures in Appendix B At present,
there are no Subpart T uranium mill tailings at this site These regulations are a subset of the
NESHAPs According to subsection 61 252 Standard, (a) radon-222 emissions to ambient air from an
existing uranium mill tailings pile shall not exceed an average of 20 pCi/m2-s for each pile or region
Subsection 61 253, Determining Compliance, states that "Compliance with the emission standard in
this subpart shall be determined annually through the use of Method 115 of Appendix B " The
repaired Cell 4A, and newly constructed Cell 4B, were both constructed after December 15, 1989
and each was constructed with less than 40 acres surface area Cell 4A and 4B comply with the
requirements of 40 CFR 61 252(b), therefore no radon flux measurements are required on either
Cell 4A or 4B
4. SAMPLING METHODOLOGY
Radon emissions were measured using Large Area Activated Charcoal Canisters (canisters) in
conformance with 40 CFR, Part 61, Appendix B, Method 115, Restrictions to Radon Flux
Measurements, (EPA, 2012) These are passive gas adsorption sampling devices used to determine
the flux rate of radon-222 gas from a surface The canisters were constructed using a 10-inch
diameter PVC end cap containing a bed of 180 grams of activated, granular charcoal The prepared
charcoal was placed in the canisters on a support grid on top of a Vi inch thick layer of foam and
secured with a retaining ring under 1 !/2 inches of foam (see Figure 1, page 11)
One hundred sampling locations were distributed throughout Cell 2 (which consisted of one region) as
depicted on the Sample Locations Map (see Figure 2, Appendix D). Each charged canister was placed
directly onto the surface (open face down) and exposed to the surface for 24 hours. Radon gas
adsorbed onto the charcoal and the subsequent radioactive decay of the entrained radon resulted in
radioactive lead-214 and bismuth-214 These radon progeny isotopes emit characteristic gamma
photons that can be detected through gamma spectroscopy The original total activity of the
adsorbed radon was calculated from these gamma ray measurements using calibration factors
derived from cross-calibration of standard sources containing known total activities of radium-226
with geometry identical to the counted samples and from the principles of radioactive decay
After approximately 24 hours, the exposed charcoal was transferred to a sealed plastic sample
container (to prevent radon loss and/or further exposure during transport), identified and labeled, and
transported to the Tellco laboratory in Grand Junction, Colorado for analysis Upon completion of on-
site activities, the field equipment was alpha and beta-gamma scanned for possible contamination
resulting from fieldwork activities All field equipment was surveyed by Energy Fuels Radiation
Safety personnel and released for unrestricted use Tellco personnel maintained custody of the
samples from collection through analysis
2
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 May 20, 2013, the sampling locations were spread out throughout the Cell 2 region The same
sampling locations that were established for the April 2013 sampling of Cell 2 were used for the May
2013 sampling, although the sample identification numbers are different A sample identification
number (ID) was assigned to every sample point, using a sequential alphanumeric system indicating
the charcoal batch and physical location within the region (e g, C01 C100) This ID was written on
an adhesive label and affixed to the top of the canister. The sample ID, date, and time of placement
were recorded on the radon flux measurements data sheets for the set of one hundred measurements
Prior to placing a canister at each sample location, the retaining ring, screen, and foam pad of each
canister were removed to expose the charcoal support grid A pre-measured charcoal charge was
selected from a batch, opened and distributed evenly across the support grid The canister was then
reassembled and placed face down on the surface at each sampling location Care was exercised not
to push the device into the soil surface The canister rim was "sealed" to the surface using a berm of
local borrow material.
Five canisters (blanks) were similarly processed and the canisters were kept inside an airtight plastic
bag during the 24-hour testing period
5.3 Sample Retrieval
On May 21, 2013 at the end of the 24-hour testing period, all canisters were retrieved, disassembled
and each charcoal sample was individually poured through a funnel into a container Identification
numbers were transferred to the appropriate container, which was sealed and placed in a box for
3
transport Retrieval date and time were recorded on the same data sheets as the sample placement
information The blank samples were similarly processed
The charcoal samples from all 100 canisters were successfully containerized during the unloading
process
5.4 Environmental Conditions
A rain gauge and thermometer were in place at the White Mesa Mill site to monitor rainfall and air
temperatures dunng 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
• No rainfall occurred during the sampling period
• The minimum ambient air temperature during the sampling period was 40 degrees F
6. SAMPLE ANALYSIS
6.1 Apparatus
Apparatus used for the analysis
• Single- or multi-channel pulse height analysis system, Ludlum Model 2200 with a
Teledyne 3" x 3" sodium iodide, thallium-activated (Nal(Tl)) detector
• Lead shielded counting well approximately 40 cm deep with 5-cm thick lead walls and a 7-
cm thick base and 5 cm thick top
• National Institute of Standards and Technology (NIST) traceable aqueous solution radium-
226 absorbed onto 180 grams of activated charcoal
• Ohaus Model C501 balance with 0 1-gram sensitivity
6.2 Sample Inspection and Documentation
Once in the laboratory, the integrity of each charcoal container was verified by visual inspection of the
plastic container Laboratory personnel checked for damaged or unsealed containers and verified that
the data sheet was complete
All ofthe 100 sample containers and 5 blank containers received and inspected at the Tellco analytical
laboratory were verified as valid and no damaged or unsealed containers were observed
6.3 Background and Sample Counting
The gamma ray counting system was checked daily, including background and radium-226 source
measurements prior to and after each counting session Based on calibration statistics, using two
4
sources with known radium-226 content, background and source control limits were established for
each Ludlum/Teledyne counting system with shielded well (see Appendix A)
Gamma ray counting of exposed charcoal samples included the following steps
• The length of count time was determined by the activity of the sample being analyzed,
according to a data quality objective of a minimum of 1,000 accrued counts for any given
sample
• The sample container was centered on the Nal detector and the shielded well door was
closed
• The sample was counted over a determined count length and then the mid-sample count
time, date, and gross counts were documented on the radon flux measurements data sheet
and used in the calculations
• The above steps were repeated for each exposed charcoal sample
• Approximately 10 percent of the containers counted were selected for recounting These
containers were recounted within a few days following the original count
7. QUALITY CONTROL (QC) AND DATA VALIDATION
Charcoal flux measurement QC samples included the fo
objectives
• Blanks, 5 percent, and
• Recounts, 10 percent
lowing intra-Iaboratory analytical frequency
All sample data were subjected to validation protocols that included assessments of sensitivity,
precision, accuracy, and completeness All method-required data quality objectives (EPA, 2012) were
attained
7.1 Sensitivity
A total of five blanks were analyzed by measuring the radon progeny activity in samples subjected to
all aspects of the measurement process, excepting exposure to the source region These blank sample
measurements comprised approximately 5 percent of the field measurements The results ofthe blank
sample radon flux rates ranged from -0 01 to 0 01 pCi/m2-s, with an average of approximately 0 00
pCi/m2-s The lower limit of detection (LLD) was approximately 0 03 pCi/m2-s.
7.2 Precision
Ten recount measurements, distributed throughout the sample set, were performed by replicating
analyses of individual field samples (see Appendix B)i 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
6 5 percent with an overall average precision of approximately 2 5 percent RPD
5
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 -2 8 percent to +0 5 percent The arithmetic average bias ofthe lab
control sample measurements was approximately -0 9 percent (see Appendix A)
7.4 Completeness
One hundred samples from the Cell 2 Cover Region were verified, representing 100 percent
completeness for the May 2013 radon flux sampling
8. CALCULATIONS
Radon flux rates were calculated for charcoal collection samples using calibration factors derived
from cross-calibration to sources with known total activity with identical geometry as the charcoal
containers A yield efficiency factor was used to calculate the total activity of the sample charcoal
containers Individual field sample result values presented were not reduced by the results ofthe field
blank analyses
In practice, radon flux rates were calculated by a database computer program The algorithms utilized
by the data base program were as follows
Equation 8.1
pCi Rn-222/m2sec [Ts*A*b*0 5(d/9175)]
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 1708, for M-01/D-2 land
0 1727, 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, la = 2x
Gross Sample, cpm Background Sample, cpm +
Sample Count,t,min Background Count,t,min
x Sample Concentration Net,cpm
6
Equation 8.3
TTn_ 2 71 +(4 65VSK>
LLU" [Ts*A->'b*0 5(d/9T75)]
where 2 71 = constant
4 65 = confidence interval factor
Sb = standard deviation of the background count rate
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi, values used
0 1708, for M-01/D-21 and
0 1727, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
9. RESULTS
9.1 Mean Radon Flux
Referencing 40 CFR, Part 61, Subpart W, Appendix B, Method 115 - Monitoring for Radon-222
Emissions, Subsection 2 1 7 - Calculations, "the mean radon flux for each region of the pile and for
the total pile shall be calculated and reported as follows
(a) The individual radon flux calculations shall be made as provided in Appendix A EPA
86(1) The mean radon flux for each region of the pile shall be calculated by summing all
individual flux measurements for the region and dividing by the total number of flux
measurements for the region
(b) The mean radon flux for the total uranium mill tailings pile shall be calculated as follows
JiAi+ J2Az r+i J'A<
Js =
At
Where Js = Mean flux for the total pile (pCi/m2-s)
J, = Mean flux measured in region l (pCi/m2-s)
A, = Area of region I (m2)
At = Total area of the pile (m2)"
40 CFR 61, Subpart W, Appendix B, Method 115, Subsection 2 1 8, Reporting states "The results of
individual flux measurements, the approximate locations on the pile, and the mean radon flux for each
region and the mean radon flux for the total stack [pile] shall be included in the emission test report Any
condition or unusual event that occurred during the measurements that could significantly affect the results
should be reported "
7
9.2 Site Results
Site Specific Sample Results (reference Appendix C)
(a) The mean radon flux for each region within the site as follows
Cell 2 - Cover Area = 22 6 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 = 22 6 pCi/m2-s
(22.6X270.624) =22 6
270,624
As shown above, the arithmetic mean radon flux of the May 2013 samples for Cell 2 at Energy
Fuels White Mesa milling facility is above the NRC and EPA standard of 20 pCi/m2-s The
extremely dry weather at the site for the past several years was especially severe during 2012 and
seems to be continuing now in 2013 The result of this dry weather is likely a lowered water table in
the containment cell and reduced moisture content in surface soils, which could result in increased
radon flux rates at the site
Appendix C is a 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 qf Federal Regulations, July 2012
U S Nuclear Regulatory Commission, Radiological Effluent and Environmental Monitoring at
Uranium Mills, Regulatory Guide 4 14, April 1980
U S Nuclear Regulatory Commission, Title 10, Code of Federal Regulations, Part 40, Appendix A,
January 2013
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
1 '4 m Vent Hole
I '1 Hi TlMCii Ojrc^a
I in Tiuck,
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5 2 if Thick
5^rut3<-M Pas
TV*
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\
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Flfltfll. . 1 Largt-Arfta Raoon Collector
10
Appendix A
Charcoal Canister Analyses Support Documents
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13
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION \fJ U < ^t> N\ e<>^\ MHl; B / gttA d ' <^ ,
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CLIP NT £v\-g/^ KA^W ^-g^P^^S tO^^A^ T-^-C Calibration Check Log;
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__ Source ID/SN Source Activity ^ ^
Blank Canister Bkgd Range, cpm 2 a - 1 \°) to 13
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System ID
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ok?
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Y/N Y = average backgiound and source cpm falls withm the control limits
N = average background and source cpm does not fall withm the control limits
The acceptable ranges were determined from prior background and souice check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION R €S^\ K\ U } B rj ' ^ > Q( T
Calibration Check Log
Cahbi ation Date Due Date 6/^9 Ji3
_ High Voltage I Window 4 42 Thrshld 2_20
Source ID/SN jGrSrO^ Souice Activity £T^'3<d'P^
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System ID M -O I / p^l
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Tlie acceptable ranges were determined from prior background and source check data
CHARCOAL CANISTER ANALYSIS SYSTEM
SITh LOCATION \)0 vuVC R<?^ j ) I*d M*j } iji _
CLIFNT ^HA-c/^y FU*; (S ^ e 5>Ovxrcx5> (^S/Q TTtAd.
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The acceptable ranges were determined from prior background and source check data
CHARCOAL CANISTER ANALYSIS SYSTEM
SfTF LOCATION
CLIENI Fu€l* K^w^s Q>t£^ JW..
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Cahbranon Date ... , Gleg!>?-
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r S/N PH^^1, Source ID/SN fe^^V GS'O^ Source Activity S^-3£p 6'
t^X 3q- IH to Lg?
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pre?
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Date By Background Counts (1 mm each)
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Y/N Y = average background and source cpm falls within the control limits
N = average background and source cpm docs not fall withm the control limits
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Appendix B
Recount Data Analysi
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oooooooooooooooooooooooooo
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o o o o o
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co
CO
>-
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LU
z < o
z
CO
J hi hi J hi
o o o o o
Di pi Di Di H E-t E-i H H 53 55 53 53 £ O O CJ CJ CJ CJ CJ
ro ro ro ro ro o o o o o
o o o o o
CN CN CN CN CN O O O O O
O O O O O
O O H
OOO
O CN CN H CN
co r- co co cn
O O O O o
CN CN CN CN CN
m in o VD co
VD VO VO CN <tf in <^ in in vo
rH rH H rH H
o o o o o
rH rH rH rH rH
rH rH ^ <tf l>
CN CN ro ro ^
r- r- o i> i>
rH rH rH rH rH
ro ro ro ro ro
rl H H H H
rH H rH rH H
CN CN CN CN CN
in in in in in
in in in in in
^* ^*
CO CO CO CO CO
in tn in in in
CN CN CN CN CN
CO CO CO 00 00
rH CN ro ^ in
^ ^ ^
OQ CQ PQ CQ PQ
CJ CJ CJ CJ CJ
rH CN ro ^ m
^ ^ ^ fc^
CQ CQ PQ CQ PQ
CJ U CJ CJ CJ
Appendix D
Sample Locations Map (Figure 2)
iS 85 Hi
g ^2
CZD