DRC-2014-006141 - 0901a068804a1b99

I H •) b u'
State of Utah
GARY R HERBERT
Governor
SPENCERJ COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-006141
October 14, 2014
Kathy Weinel, Quality Assurance Manger
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Radioactive Material License Number UT 1900479: Request for Information (RFI)
Environmental Monitoring Manual submitted September 8, 2014
Dear Ms. Weinel:
On September 8, 2014 Energy Fuels Resources (USA) Inc. (EFRI) submitted a revised
Environmental Protection Manual (EPM) as required in License Condition 11.9. The revised EPM
was required to include 2 additional air monitoring stations and a revised soil sampling program.
The License Condition also required that air particulate sample analysis to include Thorium 232
and every air monitoring station will also monitor for radon (Rn222) and gamma detection devices
on a quarterly basis. In addition, the licensee was required to analyze whether a revised
vegetation sampling program is appropriate. The DRC has reviewed the submitted information
and revised EMP and requests the following information:
EFRI Standard Operating Procedure (SOP): Air Monitoring-Particulate Radionuclides
Part II Standard Operating Procedures
1.0 Equipment
It states; "Particulates are trapped on an 8 X 10-inch glass microfiber filter.
RFI Question #1:
What is the micron size of the filters used for air particulate monitoring?
3.1 Orifice Plate
It states; "The orifice plates shall be calibrated every year as recommended by the EPA. A
certified calibration laboratory that will use the EPA or an EPA-approved method ..."
RFI Question #2:
What is the EPA or approved EPA method used to calibrate the orifice plate?
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD (801) 536-44)4
www duq Utah gov
Printed on 100% recycled paper
Page 2
EFRI SOP: Surface Soil Monitoring
1.0 Soil Monitoring
It states; "Soil samples from the northern Mill boundary and the north half of the eastern boundary
(adjacent to section 22, 27 and 34) are collected approximately every 1000 feet. The remainder of
the perimeter boundary soil samples are collected every 2500 feet." However, on page 2 EFRI
Response: states: The additional samples will be collected at a frequency of every 500 feet along
the northern mill boundary. Please correct the inconsistency.
RFI Question #3:
How will the soil sample locations be marked?
RFI Question #4:
Please describe how the soil sampling locations will be protected to keep the sampling area
undisturbed?
3.0 Analytical Requirements
RFI Question #5
Please add Th-232 and Pb-210 to the analytical requirements for soil samples based on receipt and
processing of alternate feeds.
Vegetation Sampling RFI Questions
RFI Question #6
Explain the rational of only having three areas for vegetation sampling?
RFI Question #7
Explain what type of vegetation is sampled?
RFI Question #8
Please add U-Nat and Th-232, to the analytical requirements based on receipt and processing of
alternate feeds.
Air Monitoring - Radon Monitoring Plan
Please add at the end of section 1.1 that all detector results will be provided in the Semi-annual
environmental report.
If you have any questions concerning this letter, please contact me or Ryan Johnson at 801-536-
4250.
Division of Radiation Control