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HomeMy WebLinkAboutDRC-2016-008005 - 0901a06880641dffJune 16, 2016 Sent VIA OVERNIGHT DELIVERY Mr. Scott Anderson Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4820 Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com Div of Waste Management and Radiation Control JUN 2 0 2016 Vl2b-Z0/0-aJ&XJ5 Re: Transmittal of Revised Standard Operating Procedures ("SOPs") for Annual Soil Sampling and Radon Measurement for White Mesa Uranium Mill Dear Mr. Anderson: This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI' s") proposed revisions to the White Mesa Mill SOPs for annual soil sampling and radon measurement. These revisions include changes made to: 1. Incorporate changes requested by the Division of Waste Management and Radiation Control ("DWMRC") personnel during an inspection. 2. Incorporate changes to the radon SOP to address detector changes by the manufacturer. 3. Correct typographical errors. For ease of review we have provided both redline/strikeout (text only) and clean versions (text and figures) of each document. If you should have any questions regarding these plans please contact me. Yours very truly, fnifXr~ ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager CC: David C. Frydenlund Harold R. Roberts David E. Turk Logan Shumway Scott Bakken REDLINE . I' White Mesa Mill-Standard Operating Procedures Book# 11, Environmental Protection Manual, Section 4.1 Date: -l+A406/16 Revision: EFR-42 Page 1 of 42 SURFACE SOIL MONITORING PART I SOIL MONITORING PLAN 1.0 SOIL MONITORING Surface soils are sampled at the eight air monitoring sites and at spaced intervals around the perimeter boundary of the Mill property. The sampling locations are shown in Figure 1. Soil samples from the northern Mill boundary and the north half ofthe eastern boundary (adjacent to Sections 22, 27 and 34) are collected approximately every 1000 feet. The remainder ofthe perimeter boundary soil samples are collected every 2500 feet. Soil samples are taken once per year during August or as soon as possible thereafter, but no later than September 30 of the year. Each soil sampling location will be marked with an aluminum tag with the sample location identification etched or painted on the tag. The tags will be attached to a metal stake driven approximately 18 inches into the ground. The sampling locations will be placed on the inside of the Mill's perimeter fence to prevent tampering and vandalism. The locations will be sited approximately one foot from the inside of the perimeter fence to prevent inadvertent disturbance by truck or vehicle traffic. The location markers will be designed and installed with as low a profile as possible, while still maintaining visibility for ease of location during the annual sampling program. In addition, a soil sample could be taken from Westwater Creek, in the place of a water sample. However, a sediment (soil) sample would only be taken at Westwater Creek if water was not available. In the event that a soil sample is collected in place of a water sample for Westwater Creek, the sample should be analyzed for the same parameters as those called for in this SOP (Radium-226, Pb-210, Th-232, and U-nat). Refer to SOP No. PBL-EP-3 for details regarding collection of a water sample from Westwater Creek. 2.0 SAMPLING AND ANALYTICAL QUALITY ASSURANCE The sample bags are marked for location identification and are submitted to the analytical laboratory accompanied by Chain-of-Custody forms. (Attachment A) Analytical quality assurance for soil monitoring is based on the contract laboratory's quality controls such as blanks, duplicates, and standard percentage recovery. The laboratory is committed to meet the LLD values for radionuclides contained in U.S. NRC Regulatory Guides 4.14 and 4.15 and will perform re-runs on all samples not meeting these limits. Appropriate laboratory control and quality assurance data will be provided by the contract laboratory, or equivalent, including LLD information. 3.0 ANALYTICAL REQUIREMENTS All soil samples will be analyzed, on a dry basis for the following radionuclides: Ra-226 Th- 232, Pb-210, and U-Nat. Analytical results will be reported in appropriate radiological units such as pica curies per gram or micro curies per kilogram. I · White Mesa Mill -Standard Operating Procedures Book# II, Environmental Protection Manual, Section 4. I Date: +-I-A406!16 Revision: EFR-4~ Page 2 of 4~ PART II SOIL MONITORING STANDARD OPERATING PROCEDURES 1.0 SURF ACE SOIL SAMPLING 1.1 Equipment Equipment used for soil sampling is as follows: 1. Tape measure or measuring stick calibrated to 1 foot and to one centimeter. 2. Clean trowel or shovel. 3. Clean sample containers. 1.2 Soil Sampling Procedure Soil samples are collected using a clean trowel or shovel to excavate a soil sample evenly across a one square foot area at a depth of ooe-five centimeter~. The ooe-five centimeter excavation depth is maintained by using the tape measure or other suitable calibrated measuring stick. As the soil is being collected, it is placed directly into the sample container. -The sample container is then identified with a label (see Section 2.1 below). 1.3 Decontamination Procedure Equipment such as trowels or shovels used for sampling is decontaminated between sampling locations. Equipment is decontaminated by spraying with deionized water and wiping with clean paper toweling. Decontamination will continue until all visible dirt and debris is removed from the equipment. 2.0 SAMPLING QUALITY ASSURANCE 2.1 Sample Duplicates Soil sample duplicates will be collected at a frequency of 1 duplicate per 20 samples. The duplicates will be submitted blind to the laboratory and will be named as follows: N1D where: N = Northern boundary 1 = Sequential number of the northern boundary sample D =Duplicate of sample N1 Duplicate precision will be discussed in the Semi-Annual Effluent Report. Duplicate precision will be assessed as follows: I . White Mesa Mill-Standard Operating Procedures Book #11 , Environmental Protection Manual, Section 4.1 Date: -l-1-1-l-406/16 Revision: EFR-4~ Page 3 of 4~ a) Relative Percent Difference. RPDs will be calculated in comparisons of duplicate and original field sample results. Section 3.3 will apply when the RPD > 35%, unless the measured concentrations are less than 5 times the required detection limit (Standard Methods, 1998) (EPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, February 1994, 9240.1-05-01, p. 25). 2.2 Sample Labeling 2.2 Each sample must be labeled and all sample labels must be filled out in ink and numbered. The following information must be contained on the label: 1. Project and facility. 2. Company name 3. Date and time of sample collection. 4. Sampler's initials. 5. Sample location. 6. Requested Analytical Parameters Sample Chain-of-Custody During sampling activities, traceability of the sample must be maintained upon sample collection until the laboratory data is issued. Information on the custody, handling, transfer, and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The sampler is responsible for filling out the COC form. The COC form will be signed by the sampler when the sampler relinquishes the samples to anyone else. A COC form is to be completed for each set of samples placed in a sample shipping container and is to include the following: 1. Sampler's name. 2. Date and time of collection. 3. Sample location. 4. Sample type. 5. Analysis requested. I ' White Mesa Mill -Standard Operating Procedures Book #11, Environmental Protection Manual, Section 4.1 6. Signatures of persons releasing custody. Date: -l-l-A406/16 Revision: EFR-4~ Page 4 of 4~ 7. Signatures of persons accepting custody, dates, and times. Copies of the COC forms and all custody documentation when received will be retained in appropriate files at the Mill. The original COC form remains with the samples until disposal of the samples. 2.3 Sample Handling and Shipping Samples will be placed in shipping containers and transported to the contract laboratory. COC forms will be placed inside a resealable bag and placed inside the sample shipping container. 2.4 Record Keeping All laboratory and field soil sample data are retained in the files-at the Mill and the Corporate Offices.and when analytical results are available the results are entered into a computer file and retained in the files. Laboratory analytical data are stored in the soil files after the data has been entered on a computer file . 3.0 ANALYTICAL QUALITY ASSURANCE 3.1 Data Validation and Quality Control Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in results noted and investigated. Appropriate measures to confirm or disaffirm results will be pursued, such as laboratory conversation, analytical sample rerun, or trend analysis. 3.2 Quality Assurance and Data Validation The contract laboratory will prepare and retain a copy of all analytical and quality control documentation. The laboratory will provide hard copy information in each data package submitted in accordance with quality assurance objectives for the surface soil quality assurance project plan that is: COC forms, cover sheets with comments, narratives, samples analyzed, reporting limits and LLD values for analytes, and analytical results of quality control samples. The data reduction and laboratory review 'Nill be documented,package will be signed, and dated by the analyst a laboratory representative. 3.3 Corrective Action Corrective action will be taken for any deficiencies or deviations noted in the procedures or anomalous results, such as but not limited to additional sample collection, sample re-run, laboratory inquires, or other actions as appropriate. . 'I White Mesa Mill -Standard Operating Procedures Book #11, Environmental Protection Manual, Section 4.1 Date: +!-1+406/16 Revision: EFR-4~ Page 5 of 4~ Corrective actions for duplicate deviations shall first determine if the deviation is indicative of a systematic issue. If the deviation is limited in scope and nature, the QA Manager will: 1. Notify the laboratory, a. Request the laboratory review all analytical results for transcription and calculation errors, and b. If the samples are still within holding time, the QA Manager may request the laboratory re-analyze the affected samples. 1-White Mesa Mill-Standard Operating Procedures Date: -l-1R406/16 Revision: EFR-~ Book # 11, Environmental Protection Manual, Section 1.2 Page 1 of 4 AIR MONITORING --RADON 1. RADON MONITORING PLAN 1.1 Locations and Frequency of Samples Radon samples are taken at the following locations: BHV-1 BHV-2 BHV-2A (Duplicate ofBHV-2) BHV-3 (Background location for use in assessment of background concentrations) BHV-4 BHV-5 BHV-6 BHV-7 BHV-8 BHV -70 (Blank Transit Control sample(_8 for use in assessment of effects due to sample shipment. Previously numbered as BHV-7) See Attachment A to Section 1.1 of this Environmental Protection Manual for the locations of these monitoring stations. Samples are collected on a quarterly basis using Landauer RadtrakRapidos® High Sensitivity Outdoor Environmental detector(Trac Etch) Outdoor Air Radon Detector, (Landauer Part Number DR.~M) or equivalent. One or more than one Radtrak@ tHac- Ete-hj Outdoor Air Radon Detector will be placed at each of the locations noted above (except BHV-70). If more than one Rapidos® High Sensitivity Outdoor Environmental detector is placed at a location, one of the Rapidos® High Sensitivity Outdoor Environmental detectors will be designated as the primary detector. The number of detectors to be placed at each location shall be as determined by the Radiation Safety Officer ("RSO"). If multiple Radtrak@ Rapidos® High Sensitivity Outdoor Environmental detectordetectors are placed at one location, either the results from the primary detector or the numeric average of the results for that location will be calculated and reported as the radon value for the quarter. Rapidos® High Sensitivity Outdoor Environmental detector Radtrak@ (Trac Etch) detector results will be reported in the Semi-Annual Effluent Report. 1.2 Quality Assurance Quality assurance of the samples is met by collecting samples in accordance with the conditions and guidelines set forth in Section 2 of this procedure. In addition, the following steps will be followed: 1· White Mesa Mill-Standard Operating Procedures Date: ++A-406116 Revision: EFR-~ Book #11, Environmental Protection Manual, Section 1.2 Page 2 of 4 1.3 a) One duplicate sample or set of duplicate samples will be collected each quarter by placing samples at the same location as the routine sample(s), at the same height as the routine sample(s), and as close to the routine sample(s) as reasonably achievable; b) A field blanktransit control sample will be collected analyzed each quarter to assess any concentrations resulting from shipment of the detectors; c) Detector locations will be monitored periodically to ensure the detectors have not been lost; d) Detector shipments will be inspected to ensure that all detectors are present when receiving or shipping detectors; and e) Monitoring data will be reviewed for consistency and data transportation issues/ detections. Analytical Requirements Each quarterly sample will be analyzed for Radon-222. Results will be expressed in pCi/L. 2. STANDARD OPERATING PROCEDURES 2.1 Equipment Samples will be collected using the Radtrak® (Trac Etch) Rapidos® High Sensitivity Outdoor Environmental detector Outdoor Air Radon Detector (Landauer Part Number DRNM) or equivalent. The Rapidos® High Sensitivity Outdoor Environmental detectordetectors will be returned to the supplier/manufacturer for processing and analysis. Detectors are analyzed using ~the--"high sensitivity" methodology, which provides a lower limit of detection. The lower limit of 6.0 pCi!L days ef-detection is based on the number of days the detector is deployed. 2.2 Monitoring Methodology The following monitoring procedures will be followed: a) Remove detector from package-The Outdoor Air Radon DetectorRadtrak@ radon detectors are supplied in aluminum bags which prevent radon exposure. Open the aluminum bag and remove the Rapidos® High Sensitivity Outdoor Environmental detector. Assemble the clear plastic cup ·.vhich has a Radtrak®mounting assembly for the detector fastened to the bottom. Rapidos® High Sensitivity Outdoor Environmental detectors as specified in the manufacturer's instructions. -Note that the Rapidos® High Sensitivity Outdoor Environmental detectors,Detectors, before, during or after exposure should not be j" White Mesa Mill-Standard Operating Procedures Date: +l-A406/16 Revision: EFR-~ Book #11, Environmental Protection Manual, Section 1.2 Page 3 of 4 3. in locations which exceed a temperature of 160°F (70°C). There is no low temperature. b) Fill in the enclosed Detector and Commission Information SheetDetector Log 8fieet with the serial number on the Rapidos® High Sensitivity Outdoor Environmental detectordetector label. Also fill in the date installed and the location information in the location/comments area. c) Attach a--fieklthe protective canister assembly to a post or other location using the metal bracket with the open mouth of the canister facing down. The protective canister assembly may be placed at any desired height (typically 3-6 feet) and preferably in a location minimizing animal damage or tampering. Remove the clear acrylic retaining ring from the canister by removing the wing nuts. Install the Rapidos® High Sensitivity Outdoor Environmental detectorassembled cup inside the protective canister and replace the retaining ring and-wing nuts in order to hold the 6l:l)rRapidos® High Sensitivity Outdoor Environmental detector in place in the protective canister. d) Leave the detectors undisturbed for the duration of the three month monitoring period. e) At the end of the monitoring period, remove the Rapidos® High Sensitivity Outdoor Environmental detector Radtrak@ detector from the plastic cupprotective canister. Peel off the gold seal provided with the shipment and cover all the holes on the top of the detector. This stops the monitoring period. Record the ending date on the Detector and Commission Information SheetDetector Log Sheet. f) After all of the detectors have been collected and sealed, but prior to final packaging and shipment, place the transit control detector(s) in the shipping container.open a new detector and immediately cover all the holes on the top of the detector with one of the gold seals provided vlith the shipment. Label this This detector will be reported as as--BHV -70 on the Detector Log Sheet. Use the same exposure time/days for BHV 70 as the eight sample detectors when listing BHV 70 on the Detector Log Sheet. g) Return the detectors along with a copy of the Detector Log SheetDetector and Commission Information Sheet using the laboratory provided label for shipment back to the supplying organization. RECORD KEEPING Data maintained in record form for environmental radon is: a) Sample period; b) Sample location; and c) Radon levels. 1· White Mesa Mill-Standard Operating Procedures Date: +!+!406/16 Revision: EFR-~ Book #11, Environmental Protection Manual, Section 1.2 Page 4 of 4 CLEAN ' White Mesa Mill-Standard Operating Procedures Book #11 , Environmental Protection Manual, Section 4.1 SURFACE SOIL MONITORING PART I SOIL MONITORING PLAN 1.0 SOIL MONITORING Date: 06/16 Revision: EFR-5 Page 1 of5 Surface soils are sampled at the eight air monitoring sites and at spaced intervals around the perimeter boundary of the Mill property. The sampling locations are shown in Figure 1. Soil samples from the northern Mill boundary and the north half of the eastern boundary (adjacent to Sections 22, 27 and 34) are collected approximately every 1000 feet. The remainder of the perimeter boundary soil samples are collected every 2500 feet. Soil samples are taken once per year during August or as soon as possible thereafter, but no later than September 30 of the year. Each soil sampling location will be marked with an aluminum tag with the sample location identification etched or painted on the tag. The tags will be attached to a metal stake driven approximately 18 inches into the ground. The sampling locations will be placed on the inside of the Mill's perimeter fence to prevent tampering and vandalism. The locations will be sited approximately one foot from the inside of the perimeter fence to prevent inadvertent disturbance by truck or vehicle traffic. The location markers will be designed and installed with as low a profile as possible, while still maintaining visibility for ease of location during the annual sampling program. In addition, a soil sample could be taken from Westwater Creek, in the place of a water sample. However, a sediment (soil) sample would only be taken at Westwater Creek if water was not available. In the event that a soil sample is collected in place of a water sample for Westwater Creek, the sample should be analyzed for the same parameters as those called for in this SOP (Radium-226, Pb-210, Th-232, and U-nat). Refer to SOP No. PBL-EP-3 for details regarding collection of a water sample from Westwater Creek. 2.0 SAMPLING AND ANALYTICAL QUALITY ASSURANCE The sample bags are marked for location identification and are submitted to the analytical laboratory accompanied by Chain-of-Custody forms. (Attachment A) Analytical quality assurance for soil monitoring is based on the contract laboratory's quality controls such as blanks, duplicates, and standard percentage recovery. The laboratory is committed to meet the LLD values for radionuclides contained in U.S. NRC Regulatory Guides 4.14 and 4.15 and will perform re-runs on all samples not meeting these limits. Appropriate laboratory control and quality assurance data will be provided by the contract laboratory, or equivalent, including LLD information. 3.0 ANALYTICAL REQUIREMENTS All soil samples will be analyzed, on a dry basis for the following radionuclides: Ra-226 Th- 232, Pb-210, and U-Nat. Analytical results will be reported in appropriate radiological units such as pico curies per gram or micro curies per kilogram. White Mesa Mill-Standard Operating Procedures Book #11, Environmental Protection Manual, Section 4.1 Date: 06/16 Revision: EFR-5 Page 2 of 5 PART II SOIL MONITORING STANDARD OPERATING PROCEDURES 1.0 SURFACE SOIL SAMPLING 1.1 Equipment Equipment used for soil sampling is as follows: 1. Tape measure or measuring stick calibrated to 1 foot and to one centimeter. 2. Clean trowel or shovel. 3. Clean sample containers. 1.2 Soil Sampling Procedure Soil samples are collected using a clean trowel or shovel to excavate a soil sample evenly across a one square foot area at a depth of five centimeters. The five centimeter excavation depth is maintained by using the tape measure or other suitable calibrated measuring stick. As the soil is being collected, it is placed directly into the sample container. The sample container is then identified with a label (see Section 2.1 below). 1.3 Decontamination Procedure Equipment such as trowels or shovels used for sampling is decontaminated between sampling locations. Equipment is decontaminated by spraying with deionized water and wiping with clean paper toweling. Decontamination will continue until all visible dirt and debris is removed from the equipment. 2.0 SAMPLING QUALITY ASSURANCE 2.1 Sample Duplicates Soil sample duplicates will be collected at a frequency of 1 duplicate per 20 samples. The duplicates will be submitted blind to the laboratory and will be named as follows: N1D where: N =Northern boundary 1 = Sequential number of the northern boundary sample D =Duplicate of sample Nl Duplicate precision will be discussed in the Semi-Annual Effluent Report. Duplicate precision will be assessed as follows: White Mesa Mill -Standard Operating Procedures Date: 06116 Revision: EFR-5 Page 3 of5 Book #11, Environmental Protection Manual, Section 4.1 a) Relative Percent Difference. RPDs will be calculated in comparisons of duplicate and original field sample results. Section 3.3 will apply when the RPD > 35%, unless the measured concentrations are less than 5 times the required detection limit (Standard Methods, 1998) (EPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, February 1994, 9240.1-05-01, p. 25). 2.2 Sample Labeling 2.2 Each sample must be labeled and all sample labels must be filled out in ink and numbered. The following information must be contained on the label: 1. Project and facility. 2. Company name 3. Date and time of sample collection. 4. Sampler's initials. 5. Sample location. 6. Requested Analytical Parameters Sample Chain-of-Custody During sampling activities, traceability of the sample must be maintained upon sample collection until the laboratory data is issued. Information on the custody, handling, transfer, and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The sampler is responsible for filling out the COC form. The COC form will be signed by the sampler when the sampler relinquishes the samples to anyone else. A COC form is to be completed for each set of samples placed in a sample shipping container and is to include the following: 1. Sampler's name. 2. Date and time of collection. 3. Sample location. 4. Sample type. 5. Analysis requested. White Mesa Mill-Standard Operating Procedures Book #11 , Environmental Protection Manual, Section 4.1 6. Signatures of persons releasing custody. Date: 06116 Revision: EFR-5 Page 4 of5 7. Signatures of persons accepting custody, dates, and times. Copies of the COC forms and all custody documentation when received will be retained in appropriate files at the Mill. The original COC form remains with the samples until disposal of the samples. 2.3 Sample Handling and Shipping Samples will be placed in shipping containers and transported to the contract laboratory. COC forms will be placed inside a resealable bag and placed inside the sample shipping container. 2.4 Record Keeping All laboratory and field soil sample data are retained in the filesat the Mill and the Corporate Offices .. 3.0 ANALYTICAL QUALITY ASSURANCE 3.1 Data Validation and Quality Control Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in results noted and investigated. Appropriate measures to confirm or disaffirm results will be pursued, such as laboratory conversation, analytical sample rerun, or trend analysis. 3.2 Quality Assurance and Data Validation The contract laboratory will prepare and retain a copy of all analytical and quality control documentation. The laboratory will provide hard copy information in each data package submitted in accordance with quality assurance objectives for the surface soil quality assurance project plan that is: COC forms, cover sheets with comments, narratives, samples analyzed, reporting limits and LLD values for analytes, and analytical results of quality control samples. The data package will be signed, and dated by a laboratory representative. 3.3 Corrective Action Corrective action will be taken for any deficiencies or deviations noted in the procedures or anomalous results, such as but not limited to additional sample collection, sample re-run, laboratory inquires, or other actions as appropriate. Corrective actions for duplicate deviations shall first determine if the deviation is indicative of a systematic issue. If the deviation is limited in scope and nature, the QA Manager will: 1. Notify the laboratory, ----···-·-------------------------------------------- White Mesa Mill-Standard Operating Procedures Book #11, Environmental Protection Manual, Section 4.1 Date: 06/16 Revision: EFR-5 Page 5 of5 a. Request the laboratory review all analytical results for transcription and calculation errors, and b. If the samples are still within holding time, the QA Manager may request the laboratory re-analyze the affected samples. ~- 1 ~ E--1 z ril ::E :::r:: u ~ E--1 ~ • __ .,. ·--• •'>••• • I .... 1-YI..,._ --···--·· 1111-1111-W-1 1 --..... ---·-·-· I ,_1_1 .. _ ..,_,, __ t'_ll-111::::111 II_ .. __ -II·-·-·---·--· Company Name: Project Name, Pws #, Permit#, Etc.: Report Mail Address: Contact Name, Phone, Fax, E-mail: Sampler Name if other than Contact: Invoice Address: Invoice Contact & Phone #: Purchase Order#: Ell Quote#: Report Required For: POTWIWWTPO owo c A ~~ L'\1 Sl ~ F EC ~u l:S irE D Notify Ell prior to RUSH Shipped by: 0 Other !!!os sample submittal for additional CI)IDCD .E > 5l' ... charges and scheduling Cooler ID(s) Special Report Formats -Ell must be notified prior to sCI)>I~ c §;::EO! Comments: sample submittal for the following: u<s>. w ~ ~ Receipt Temp NELACD A2LAD LeveiiVD -a; Iii :g :r:: c c 0 c.._"' u -c oc ... ~0 111 c: § Other _8Ql(J)I.Q ~ e Custody Seal Y N EO...!! CCI Cll e EDD/EDT 0 Format :::1 E 111 E Cll Intact YN z~;:! < .= ~ ~ w iii Signature YN SAMPLE IDENTIFICATION Collection Collection ~ J: Match w (/) (Name, Location, Interval, etc.) Date lime MATRIX en ~ LabiD 1 ~ 2 ~ 3 -w 4 ~ 5 >- 6 ~ 7 ~ 8 9: 9 m 10 ~ Custody Relinquished by (print): Daternme: Signature: Received by (print): Datefllme: Slgnatura: Record Relinquished by (print): Date/rome: Slgnatura: Received by (print): Datamme: Signature: MUST be Signed LABORATORY USE ONLY Sample Disposal: Return to client: Lab Disposal: Sample Type: # of fracUons lr --,rtaln circumstances, samples submiHed to Energy Laboratories, Inc. may be ~··bcontracted to other certified laboratories In order to complete the analysis req,.--,ed. This serves as notice of this possibility. All sub-c\ 1<:t data will be clearly notated on your analytical report. Visit our web site at www.eneravlab.com for additionarmformation. downloadabla fee schedule_ forms_ & links_ ------------------------------------, White Mesa Mill-Standard Operating Procedures Date: 06116 Revision: EFR-4 Page 1 of 3 Book #11, Environmental Protection Manual, Section 1.2 AIR MONITORING --RADON 1. RADON MONITORING PLAN 1.1 Locations and Frequency of Samples Radon samples are taken at the following locations: BHV-1 BHV-2 BHV-2A (Duplicate ofBHV-2) BHV-3 (Background location for use in assessment of background concentrations) BHV-4 BHV-5 BHV-6 BHV-7 BHV-8 BHV-70 (Transit Control sample(s) for use m assessment of effects due to sample shipment. Previously numbered as BHV-7) See Attachment A to Section 1.1 of this Environmental Protection Manual for the locations of these monitoring stations. Samples are collected on a quarterly basis using Landauer Rapidos® High Sensitivity Outdoor Environmental detector, or equivalent. One or more than one Outdoor Air Radon Detector will be placed at each of the locations noted above (except BHV -70). If more than one Rapidos® High Sensitivity Outdoor Environmental detector is placed at a location, one of the Rapidos® High Sensitivity Outdoor Environmental detectors will be designated as the primary detector. The number of detectors to be placed at each location shall be as determined by the Radiation Safety Officer ("RSO"). If multiple Rapidos® High Sensitivity Outdoor Environmental detector are placed at one location, either the results from the primary detector or the numeric average of the results for that location will be calculated and reported as the radon value for the quarter. Rapidos® High Sensitivity Outdoor Environmental detector results will be reported in the Semi-Annual Effluent Report. 1.2 Quality Assurance Quality assurance of the samples is met by collecting samples in accordance with the conditions and guidelines set forth in Section 2 of this procedure. In addition, the following steps will be followed: a) One duplicate sample or set of duplicate samples will be collected each quarter by placing samples at the same location as the routine sample(s), at the White Mesa Mill-Standard Operating Procedures Date: 06116 Revision: EFR-4 Page 2 of 3 Book #11, Environmental Protection Manual, Section 1.2 1.3 same height as the routine sample(s), and as close to the routine sample(s) as reasonably achievable; b) A transit control sample will be analyzed each quarter to assess any concentrations resulting from shipment of the detectors; c) Detector locations will be monitored periodically to ensure the detectors have not been lost; d) Detector shipments will be inspected to ensure that all detectors are present when receiving or shipping detectors; and e) Monitoring data will be reviewed for consistency and data transportation issues/detections. Analytical Requirements Each quarterly sample will be analyzed for Radon-222. Results will be expressed in pCi/L. 2. STANDARD OPERATING PROCEDURES 2.1 Equipment Samples will be collected using the Rapidos® High Sensitivity Outdoor Environmental detector or equivalent. The Rapidos® High Sensitivity Outdoor Environmental detector will be returned to the supplier/manufacturer for processing and analysis. Detectors are analyzed using a "high sensitivity" methodology, which provides a lower limit of detection. The lower limit of detection is based on the number of days the detector is deployed. 2.2 Monitoring Methodology The following monitoring procedures will be followed: a) Remove detector from package -The Outdoor Air Radon Detector are supplied in aluminum bags which prevent radon exposure. Open the aluminum bag and remove the Rapidos® High Sensitivity Outdoor Environmental detector. Assemble the mounting assembly for the Rapidos® High Sensitivity Outdoor Environmental detectors as specified in the manufacturer's instructions. Note that the Rapidos® High Sensitivity Outdoor Environmental detectors, before, during or after exposure should not be in locations which exceed a temperature of 160°F (70°C). There is no low temperature. b) Fill in the enclosed Detector and Commission Information Sheet with the serial number on the Rapidos® High Sensitivity Outdoor Environmental detector White Mesa Mill -Standard Operating Procedures Date: 06/16 Revision: EFR-4 Page 3 of 3 Book #11, Environmental Protection Manual, Section 1.2 3. label. Also fill in the date installed and the location information in the location/comments area. c) Attach the protective canister assembly to a post or other location using the metal bracket with the open mouth of the canister facing down. The protective canister assembly may be placed at any desired height (typically 3-6 feet) and preferably in a location minimizing animal damage or tampering. Install the Rapidos® High Sensitivity Outdoor Environmental detector inside the protective canister and replace the wing nuts in order to hold the Rapidos® High Sensitivity Outdoor Environmental detector in place in the protective canister. d) Leave the detectors undisturbed for the duration of the three month monitoring period. e) At the end of the monitoring period, remove the Rapidos® High Sensitivity Outdoor Environmental detector from the protective canister. Peel off the gold seal provided with the shipment and cover all the holes on the top of the detector. This stops the monitoring period. Record the ending date on the Detector and Commission Information Sheet. f) After all of the detectors have been collected and sealed, but prior to final packaging and shipment, place the transit control detector(s) in the shipping container. This detector will be reported as BHV -70. g) Return the detectors along with a copy of the Detector and Commission Information Sheet. RECORD KEEPING Data maintained in record form for environmental radon is: a) Sample period; b) Sample location; and c) Radon levels.