DRC-2014-006782 - 0901a068804bafaf

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC-2014-006782 www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
November 18, 2014
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Energy Fuels Resources (USA) Inc. Response to Division of Radiation Control ("DRC")
Request for Information letter dated October 14, 2014 and e-mail Request for Revision
dated October 20, 2014 for the Environmental Protection Manual ("EPM"),White Mesa
Uranium Mill - RML UT1900479
Dear Mr. Lundberg:
This letter responds to the Division of Radiation Control's ("DRC's") Request for Information ("RFI")
dated October 14, 2014 and the DRC's Request for Revision dated October 20, 2014, regarding Energy
Fuels Resources (USA) Inc.'s. ("EFRI's") September 8, 2014 Environmental Protection Manual
revisions submitted as required by License Condition 11.9. This letter addresses the comments from the
RFI and Request for Revision. For ease of review, each of DRC's comments is provided verbatim
below in italics, followed by EFRI's response.
The White Mesa Mill EPM is comprised of fifteen separate Standard Operating Procedures ("SOPs")
or Plans, housed in one binder. Only those SOPs which require revision are attached to this response
letter in Attachment A. It is important to note that additional changes to correct typographical errors
or to update procedures are also included for completeness purposes only, and were not made to
respond to the RFI and Request for Revision. The redline strikeout changes from the September 8,
2014 submission have been accepted for incorporation. The changes resulting from the October 14,
2014 RFI and from the October 20, 2014 Request for Revision are shown in redline text for your
convenience.
Implementation of the changes described in these SOPs will commence on the next routine sample
period after the receipt of DRC approval of the EPM, that is, on the next routinely scheduled quarterly or
annual sampling event unless DRC specifies otherwise.
Letter to Rusty Lundberg
November 18,2014
Page 2 of 7
Comments from DRC RFI dated October 14, 2014
DRC Comment:
EFRI Standard Operating Procedure (SOP): Air Monitoring-P articulate Radionuclides
Part II Standard Operating Procedures
1.0 Equipment
It states; "Particulates are trapped on an 8 X 10-inch glass micro fiber filter... "
RFI Question # I:
What is the micron size of the filters used for air particulate monitoring?
EFRI Response:
EFRI is currently using the Whatman EPM 2000, with a pore size of the filters is 2.5 iim ("microns")
and with a >99.95% efficiency for 0.3um-size particles. The EPM 2000 has been selected by U.S. EPA
as standard filter used in nationwide high-volume air sampler network. EPA requires a "Collection
efficiency: 99 percent minimum as measured by the DOP test (ASTM-2986) for particles of 0.3 urn
diameter.
These specifications have not been added to the SOP as it is not necessary for the completion of field
activities.
The SOP has been modified to remove the EPM 1000 filter because it is no longer manufactured and has
been replaced with the EPM 2000.
DRC Comment:
EFRI Standard Operating Procedure (SOP): Air Monitoring-P articulate Radionuclides
Part 11 Standard Operating Procedures
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?
EFRI Response:
The EPA methods used for orifice calibrations are as specified in 40CFR Part 50, Appendix B, Section
9.2.17. Specifically, the methods delineated in EPA-600/4-77-027a, The Quality Assurance Handbook
for Air Pollution Measurement Systems, Volume II - Ambient Air Specific Methods. Copies of the
pertinent pages have been included as Attachment B to this response.
Letter to Rusty Lundberg
November 18, 2014
Page 3 of 7
The SOP has been modified to include the appropriate reference to the EPA method.
DRC Comment:
EFRI SOP: Surface Soil Monitoring
1.0 Soil Monitoring
lt 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 500feet along the northern mill
boundary. Please correct the inconsistency.
EFRI Response:
The soil samples from the northern Mill boundary and the north half of the eastern boundary (adjacent to
section 22, 27 and 34) will be collected approximately every 1000 feet. The EFRI response referenced
in the comment was incorrect. Since the SOP is correct, no changes to the SOP are required.
DRC Comment:
EFRI SOP: Surface Soil Monitoring
1.0 Soil Monitoring
RFI Question #3:
How will the soil sample locations be marked?
EFRI Response:
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 marking procedure noted above has been added to the SOP.
DRC Comment:
EFRI SOP: Surface Soil Monitoring
1.0 Soil Monitoring
RFI Question #4:
Please describe how the soil sampling locations will be protected to keep the sampling area
undisturbed?
Letter to Rusty Lundberg
November 18, 2014
Page 4 of 7
EFRI Response:
The sampling locations will be placed on the inside of the Mill's perimeter fence to reduce the chances
of 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.
It is important to note that the Mill's perimeter fence was recently replaced and there are no immediate
plans for construction or maintenance activities of the fence thus limiting the potential for disturbance
from Mill Staff.
DRC Comment:
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.
EFRI Response.
While not required by NRC Regulatory Guideline 4.14, Th-232 and Pb-210 have been added to the
analytical suite for the annual soil sampling program. The SOP has been modified as requested.
DRC Comment:
Vegetation Sampling RFI Questions
RFI Question #6
Explain the rational of only having three areas for vegetation sampling?
EFRI Response:
The current program is appropriate for assessing impacts from Mill activities because the locations
currently sampled are on the property boundaries or just outside of the property boundaries which
represent the areas of potential impact from Mill activities. Because the current sample locations are on
or within the Mill boundaries, they will indicate whether any contamination has left the property
boundary.
The three locations for vegetation sampling represent the areas most likely to be impacted by Mill
activities based on prevailing wind directions. The predominant wind direction during the 2004 - 2013
period were from the north-northwest through north-northeast approximately 35% of the time. The
southwest vegetation sampling location was placed to assess impacts in this area. The secondary wind
Letter to Rusty Lundberg
November 18, 2014
Page 5 of 7
direction pattern from the south through the south-southwest occurred 18.2% of the time. The northwest
and northeast vegetation sampling locations were placed to assess impacts in this direction. The three
vegetation sampling areas are sited such that impacts from Mill activities would be detected in these
locations and would indicate if any contamination has left the property. The vegetation sampling
locations are close to the Mill process areas by design to assess Mill impacts. It is important to note that
all three locations are sampled three times per year resulting in nine data points annually.
In addition, a large volume of vegetation is required to complete the analyses specified; approximately
20 kilograms of vegetation is collected for each sample at each location. The vegetation volume for
each location fills a large 39-gallon trash bag. Vegetation in the area is sparse due to the dessert-like
ecosystem and recent drought conditions have worsened the vegetation conditions. Collecting more
locations on the same schedule would have an adverse impact on the ecosystem and overall environment
in the area.
DRC Comment:
Vegetation Sampling RFI Questions
RFI Question #7
Explain what type of vegetation is sampled?
EFRI Response:
As previously stated, vegetation in the area is sparse due to the dessert-like ecosystem. Primarily,
vegetation samples are composed of sage brush, rabbit brush, native grasses and cactus. Some
variability in the sample composition is based on the time of year the sampling is conducted. The three
sampling events are conducted in early spring, late spring and late fall. The time of year impacts what
plants are available for collection with less grass available during the fall sampling event.
DRC Comment:
Vegetation Sampling RFI Questions
RFI Question #8
Please add U-Nat and Th-232, to the analytical requirements [for vegetation] based on receipt and
processing of alternate feeds.
EFRI Response:
While not required by NRC Regulatory Guideline 4.14, Th-232 and U-Nat have been added to the
analytical suite for the vegetation sampling program. The SOP has been modified as requested.
Letter to Rusty Lundberg
November 18, 2014
Page 6 of 7
DRC Comment:
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 [Effluent] report.
EFRI Response:
The SOP has been modified as requested.
Comments from DRC Request for Revision dated October 20, 2014
DRC Comment:
A revised Table 7 Stack Sampling Requirements is provided below for your convenience. Please revise
section 5.0, Stack Sampling; tab 1.4 of the Environmental Monitoring Plan to address stack sampling
deficiencies.
Table 7 - Stack Sampling Requirements
Frequency
Feed Stack
(Grizzly
Baghouse) Stack
Stack for North
and/or South
Yellowcake
Dryer Stacks
Yellowcake
Packaging
(Yellowcake
Baghouse Stack)
Vanadium Circuit
Stack
Quarterly If operating, U-
nat, Th-230, Ra-
226, Pb-210. Th-
232, Ra-228, and
Th-228.Nene
If operating, U-
nat. Th-230. Ra-
226. Pb-210, Th-
232. Ra-228. and
Th-228.
If operating, U-
nat. Th-230, Ra-
226. Pb-210, Th-
232. Ra-228. and
Th-228.
[f operating, U-nat,
Th-230. Ra-226.
Pb-210, Th-232,
Ra-228, and Th-
228.
If operating, U
nat,Th 230, Th
232, Ra 226, Pb
240
Semi annually If operating, U
nat, Th 230, Th
232-
If operating, U
nat,Th 230, Th
232,Ra 226, Pb
240
Note: Grizzly baghouse stack and Vanadium Circuit stack samples shall be representative and adequate
for the determination of the release rates and concentrations of radionuclides listed in Table 7 above, and
do not need to be collected in an isokinetic state.
EFRI Response:
Table 5-1 [7], section 5.0, Stack Sampling; tab 1.4 of the Environmental Monitoring Plan has been
modified as requested.
Letter to Rusty Lundberg
November 18, 2014
Page 7 of 7
If you have any questions, please contact me at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Scott Bakken
Attachments
ATTACHMENT A
REDLINE
White Mesa Mill - Standard Operating Procedures I
Book #11, Environmental Protection Manual, Section 1.2
Date: G4JL1/14 Revision: EFR-32-
l Page 1 of 3
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 of BHV-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 sample 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 Radtrak® (Trac-Etch) Outdoor Air
| Radon Detector, (Landauer Part Number DRNM) or equivalent. One or more than 4one
Radtrak® (Trac-Etch) Outdoor Air Radon Detector will be placed at each of the locations
noted above (except BHV-70). The number of detectors to be placed at each location
| shall be as determined by the Radiation ASafety Officer ("RSO"). If multiple Radtrak®
detectors are placed at one location, the numeric average of the results for that location
will be calculated and reported as the radon value for the quarter.
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:
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;
I White Mesa Mill - Standard Operating Procedures Date: 0411/14 Revision: EFR-32-
Book #11, Environmental Protection Manual, Section 1.2 Page 2 of 3
b) A field blank sample will be collected 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.
1.3 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) Outdoor Air Radon Detector
(Landauer Part Number DRNM) or equivalent. The detectors 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 of 6.0 pCi/L-
days.
2.2 Monitoring Methodology
The following monitoring procedures will be followed:
a) Remove detector from package - The Radtrak® radon detectors are supplied
in aluminum bags which prevent radon exposure. Open the aluminum bag and
remove the clear plastic cup which has a Radtrak® detector fastened to the
bottom. 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 Log Sheet with the serial number on the detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach a field canister to a post or other location using the metal bracket with
the open mouth of the canister facing down. The canister 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 assembled cup inside the canister and
replace the retaining ring and wing nuts in order to hold the cup in place.
I White Mesa Mill - Standard Operating Procedures Date: 04U./14 Revision: EFR-32-
Book #11, Environmental Protection Manual, Section 1.2 Page 3 of 3
d) Leave the detectors undisturbed for the duration of the three month
monitoring period.
e) At the end of the monitoring period, remove the Radtrak® detector from the
plastic cup. 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 Log Sheet.
f) After all of the detectors have been collected and sealed, but prior to final
packaging and shipment, open a new detector and immediately cover all the holes
on the top of the detector with one of the gold seals provided with the shipment.
Label this detector 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 Sheet using the
laboratory provided label for shipment back to the supplying organization.
3. RECORD KEEPING
Data maintained in record form for environmental radon is:
a) Sample period;
b) Sample location; and
c) Radon levels.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
Page 1 of 6
STACK EMISSION MONITORING PROCEDURES
WHITE MESA GAS STACK EMISSIONS
1.0 INTRODUCTION
White Mesa, or it's contracted service providers, uses scientifically approved
reference methods to determine gas stack emissions release concentration for
radionuclide particulates. These methods conform to principles that apply to
obtaining valid samples of airborne radioactive materials, using prescribed
acceptable methods and materials for gas and particulate sampling. See American
Standard Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
ANSI N13.1-1969. These sampling methods are also consistent with guidance
contained in the U.S. Nuclear Regulatory Commission's Regulatory Guide 4.14,
"Radiological Effluent and Environmental Monitoring at Uranium Mills."
2.0 SAMPLING METHODOLOGIES
The sampling methods for airborne radionuclide particulates, from the yellowcake
dryer and other mill effluent control stacks, are identical to methods published in
the EPA's manual, Gas Stream Sampling Reference Methods for New Source
Performance Standards; they are found in the EPA Manual in Appendix No. 5.
"Determination of Particulate Emissions from Stationary Sources" ("EPA Method
#5") and Appendix No. 17, "Determination of Particulate Emissions from
Stationary Sources (In-Stack Filtration Method)" ("EPA Method #17). Copies of
EPA Method #5 and #17 are attached to this SOP. Sampling is performed as per
the methods, to ensure that the sampling and results are: (1) isokinetic; (2)
representative; and (3) adequate for determination of the release rates and
concentrations of U-Nat, Th-230, Ra-226 and Pb-210.
2.1 Sampling Equipment
Sampling equipment used to collect airborne radionuclide particulates from point
source emission stacks at the Mill consists of equipment manufactured by
Research Appliance Company (RAC), (or other equivalent apparatuses), as
follows:
1. RAC Model 201009 Model 2414 stack sampler.
2. Two each, RAC Model 201044 modular sample cases. One heater box and
one glassware box.
3. One each, RAC Model 201019 umbilical cord.
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Book #11: Environmental Protection Manual, Section 1.4
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4. Three each, RAC Model 201013 - 100mm diameter filter holders.
5. One each, RAC Model 201005 standard pilot tube, three feet length,
stainless steel/S-type probe.
6. Barometer.
7. Psychrometer.
8. Satorius Model 2432 balance or equivalent.
9. Triple beam balance.
Equipment instruction and operating manual(s) provided by the manufacturer(s)
are retained at the Mill and used for specific guidance and reference.
2.2 Sample Collection
Gas stack samples are collected from emission control systems used in Uranium
Recovery Operations at the Mill. These samples are collected from process stacks
when the emission control systems are operating. They are sampled for
radionuclide particulate concentrations at a frequency in accordance with Table 5-
1. Sample collection methods are described in detail in EPA Method #5 and EPA
Method #17, Determination of Particulate Matter Emissions From Stationary
Sources. It is necessary to read and understand all procedures described in the
methods and in the equipment manual. The operation of the equipment requires
"hands-on" instruction from the Environment Departmental Staff from individuals
who are experienced in using sample collection equipment and applying sample
collection methods. The following steps are described for stack sample
collection.
1. Check equipment listed in Section 2.1 of this SOP. Consult the
manufacturers equipment operations manual for details.
2. Assemble equipment as described in the operations manual for sample
collection EPA Method #17.
3. Follow the calibration procedure listed in the manual. If the
calibration measurements are not obtained, consult the trouble
shooting section of the manual for corrective instruction. Once the
collection apparatus is calibrated, proceed to the next step.
4. Weigh a new glass fiber filter, record the weight, and place in the
filter holder assembly.
5. Check the sample collection system for leaks.
6. Cap ends of sample probes to prevent contamination and transport
sample unit to the sample location.
7. Uncap sample end and insert 3/8-diameter sample probe into the stack
in the midsection of the exhaust stream.
8. Turn sample apparatus on and observe unit operation to insure a
sample is being collected and the apparatus is functioning properly.
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Book#l 1: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
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9. Collect the stack sample for at least one hour during periods of routine
process operation. Note the collection time.
10. Record the information described in the manufacture's operations
manual. This information is also described in the EPA Methods #5
and #17 for point source particulate emissions.
11. After sample collection is complete, turn off unit. Obtain sample
filter from filter housing and place in a new plastic petri dish. Send to
outside laboratory for radionuclide analysis in accordance with Table
5-1.
2.3 Sample Handling and Shipping
1. During preparation and assembly on the sampling train, keep all
openings where contamination can occur covered until just prior to
assembly or until sampling is about to begin.
2. Using a tweezer or clean disposable surgical gloves, place a labeled
(identified) and weighed filter in the filter holder. Be sure that the
filter is properly centered and the gasket properly placed so as to
prevent the sample gas stream from circumventing the filter. Check
the filter for tears after assembly is completed.
3. Before moving the sampling train to the cleanup site, remove the
probe from the sample train, wipe off the silicone grease, and cap the
open outlet of the probe. Be careful not to lose any condensate that
might be present. Wipe off the silicone grease from the filter inlet
where the probe was fastened, and cap it. Remove the umbilical cord
from the last impinger, and cap the impinger. If a flexible line is used
between the first impinger or condenser and the filter holder,
disconnect the line at the filter holder, and let any condensed water or
liquid drain into the impingers or condenser. After wiping off the
silicone grease, cap off the filter holder outlet and impinger inlet.
Either ground-glass stoppers, plastic caps, or serum caps may be used
to close these openings.
4. Transfer the probe and filter-impinger assembly to the cleanup area.
This area should be clean and protected from the wind so that the
chances of contaminating or losing the sample will be minimized.
5. Save a portion of the acetone used for cleanup as a blank. Take 200
ml of this acetone directly from the wash bottle being used, and place
it in a glass sample container labeled "acetone blank."
6. Carefully remove the filter from the filter holder, and place it in its
identified petri dish container. Use a pair of tweezers and/or clean
disposable surgical gloves to handle the filter. If it is necessary to fold
the filter, do so such that the PM cake is inside the fold. Using a dry
Nylon bristle brush and/or a sharp-edged blade, carefully transfer to
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Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
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the petri dish and PM and/or filter fibers that adhere to the filter
holder gasket. Seal the container.
7. Send to the laboratory for radionuclide analysis.
3.0 RECORD KEEPING
Records of gas stack effluent sampling events and results of analysis are retained
at the Mill. The following information is recorded:
1. Stack and Run ID
2. Date and Sampler
3. Sampled Air Volume at standard conditions
4. Sampled Water Volume at standard conditions
5. Moisture Content (volume basis)
6. Stack Gas Molecular Weight (wet basis)
7. Stack Gas Velocity
8. Stack Gas Volumetric Flow Rate (dry basis, at standard conditions)
9. Particulate Concentration
10. Percent Isokinetics
11. Emission Rates for Particulates U-Nat, Th-230, Ra-226, and Pb-210.
The data are used to calculate emission rates in pounds and pico curies per hour
for radionuclide particulate concentrations.
4.0 MONITORING LOCATION AND FREQUENCY
Stack sampling must be performed during any quarter or semi-annual period that
the stacks operate in accordance with the schedule in Table 5-1. During non-
operational periods, stack sampling is not performed.
4.1 Yellowcake Stacks
The exhaust stack for the drying and packaging equipment associated with the
yellowcake calciner is sampled on a quarterly basis during operations. The
sample ports are located on the roof of the main Mill building.
4.2 Feed Stacks
The grizzly feed stack is located on the north end of the grizzly structure. This
stack is accessible from a stack platform and is sampled on a semi annualquarterly
basis if this system is operating.
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4.3 Vanadium Stacks
The exhaust stack for the drying and packaging equipment associated with the
vanadium circuit is sampled on a quarterly basis during operations. The sample
ports are located on the roof of the vanadiuin annex portion of the building.
5.0 ANALYSIS REQUIREMENTS
All gas stack samples are collected at the Mill according to the calendar year
schedule shown below in Table 5-1. The samples will be sent to an off-site
laboratory for the analysis detailed below.
TABLE 5-1
Sampling Frequency and Analysis
Feed Stack Stuck for Y.C. Dryer and Packaging
Quarterly: None Quarterly: If operating, U nat
Semi Annual: If operating, U nat, Th 230—Semi Annual: If operating, U nat
Th 230, Ra 226,
Pb 210
Frequency
Grizzly
Baghouse
Stack
North and/or
South
Yellowcake
Dryer Stacks
Yellowcake
Packaging
Baghouse
Stack
Vanadium
Dryer Stack
Vanadiuin
Packaging
Stack
Quarterly If operating.
U-nat. Th-230.
Ra-226. Pb-
210. Th-232.
Ra-228. and
Th-228.
If operating,
U-nat. Th-230.
Ra-226. Pb-
210. Th-232.
Ra-228. and
Th-228.
If operating, U-
nat. Th-230.
Ra-226. Pb-
210. Th-232.
Ra-228. and
Th-228.
If operating, U-If operating, U-
nat. Th-230.
Ra-226. Pb-
210. Th-232,
Ra-228. and
Th-228.
nat. Th-230.
Ra-226. Pb-
210. Th-232,
Ra-228. and
Th-228.
Note: Grizzly baghouse stack and Vanadium Circuit stack samples shall be representative
and adequate (based on EFRTs operational knowledge and operational conditions at the
time of the sampling event) for the determination of the release rates and concentrations
of radionuclides listed in Table 5-1 above, and do not need to be collected in an isokinetic
state.
6.0 QUALITY ASSURANCE METHODOLOGY
6.1 Equipment Operation
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Prior to performing an emission point sampling run, the sampling equipment is
subjected to a dry run test to determine leakages or equipment malfunction.
Calibration of equipment is checked on a periodic basis. Probe tips are protected
by a protective cap while not in use to protect accuracy determinations. During
transport of equipment, all openings are sealed to prevent contamination.
Calculations utilized during runs to maintain isokinetic conditions are reviewed
and dry run tested prior to the actual run. All containers and probes are washed
prior to each usage.
Malfunction of sampling equipment, excessive malfunctions of normal operations
being monitored, or percent isokinetic sampling rates greater than ± 10% error,
indicate mandatory voiding of the run or data involved.
6.2 Operations
If samples are collected from the operation of any unit which appears, in the
judgment of the sampler, to be functioning in a manner not consistent with normal
operations, then the sample will be voided and the system will be resampled.
6.3 Chemical Sample Control
Analyses on each period's sample shall include blanks for the filters, impinger
solutions, and the rinse solutions. A field logbook shall be maintained listing data
generated, determinations of volumes measured, and net gain weights of filters to
provide a back up to summary data records. Filters are transmitted within plastic
enclosed petri dishes. Handling of filters is only done using tweezers.
6.4 Calculations
All calculations will be retained at the Mill in both a hard copy and computer
files.
The gas stack effluent concentrations (C) are calculated as follows:
Lab Result uCi (A) / Volume Sampled (V) = Effluent Concentration (C)
where
Volume Sampled (V) = Flow rate (Q) * Time of sample collection in minutes (t)
and
Lab Result uCi (A) = Radioisotopic activity, in uCi on air filter
N:\WMM\SOPs and Procedures\EPM - November 2014 Revision\Section 1.4 Stack MonitoringVAppendix E-Section
1.4 Stack Emission 4 - Nov 2014.docF:\Mill SOP Master CopyVBook 11 Environmental Procodurcs\07 License
Renewal\EFR\Appendix E Section 1.4 Stack Emission 3.doc
I White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
i
Date: 43/43-JJ/14Revision: EFR-43
Page 7 of 6
N:\WMM\SOPs and Procedures\EPM - November 2014 RevisiorASection 1.4 Stack MonitorineVAppendix E-Section
1.4 Stack Emission 4 - Nov 2014.docF:\Mill SOP Master CopyVBook 11 Environmental Procedures\07 License
Rencwal\EFR\Appendix E Section 1.4 Stack Emission 3.doc
BHV-2
*
V I
J
v? BHV-8 BHV-1
BHV-7 Is
BHV-5
r
it BHVio BHV-4
Actual Location of BHV-3
is 34,500 Feet Due Wej \ ! / Energy Fuels Resources (USA) Inc.
J 191
9—^ —
Tentative location based on DRC
correspondence dated June 12, 2014.
Final locatons will be surveyed after
installation. Installation will be performed
after DRC approval of The Environmental
Protection Manual.
_
1 IN = 6 000 F
0.5 1
Mi lies
Legend
* Existing Air Monitoring Station
Q Tentative Air Monitoring Station**
Canyon Rim
Drainage
Road
| r^3 property Boundary
I iTailings Cell
^^jTownship and Range
I I Section
Pond
Coordinate System: NAD
1983 StatePlane Utah
South FIPS 4303 Feet
CF
m ENE
ENERGY FUELS
REVISIONS
By:
Project: WHITE MESA MILL
County: San Juan State: Utah
Location: -
ATTACHMENT A
PARTICULATE MONITORING STATIONS
Author:mhenington Date:8/22/2014 Drafted By: mhenington
PLEASE PRINT (Provide as much information as possible.)
Page. of
Company Name-Project Name, PWS, Permit, Etc. Sample Origin
State:
EPA/State Compliance:
Yes • No •
Report Mail Address: Contact Name: Phone/Fax Email: Sampler: (Please Print)
Invoice Address: Invoice Contact & Phone: Purchase Order: Quote/Bottle Order
"ShTppSdTjyT Special Report/Formats:
• DW
• POTWAA/WTP
• State:
• Other:
• EDD/EDT(Eleclromc Data)
Format:
• LEVEL IV
• NELAC
Q
E: ro
CO
CD
r-2
Ul 5 x o
<:
SAMPLE IDENTIFICATION
(Name, Location, Interval, ate)
Collection
Date
Collection
Time MATRIX
D
LU
X o <
v—
SE
UJ UJ CO
I-<
h-
TO TD c
CO <J5
R
U
S
H
Contact ELI prior to
RUSH sample submittal
for charges and
scheduling - See
Instruction Page
Cooler ID(»):
Comments: Receipt Tamp
On let: Y N
J Custody Seal
On Bottle
On Cooler
J Intact
3 Signature
I Match
fe
Custody
Record
MUST be
Signed
Relinquished by (print) Dato/Timo. Signature:
Relinquished by (pnnt) Date/Time Signature
Received by (pnnt)' Datemme Signature-
Received by (pnnt) Datemme
TllaSvedTyTSESrSlofy^ Uate/T
Signature'
"SigTaTureT
Sample Disposal: Return to Client-Lab Disposal:.
In certain circumstances, samples submitted to Energy Laboratories, Inc may be subcontracted to other certified laboratories in order to complete the analysis requested
This serves as notice of this possibility. All sub-co t data will be clearly notated on your analytical report.
Visit our web site at www.enerovlab.corn for additioi' ormation, downloadable fee schedule, forms, and links.
ATTACHMENT C
MONTHLY CALIBRATION AND WEEKLY FLOW CHECK WORKSHEET
Site:
Date of Calibration:
Temperature (Ta): °C/ K
Orifice Plate No.: _
Calibrator's Name:
Pressure (Pa): _mmHg (25.4 x inches)
Monthly Calibration for the Month of:
(i)
Initial
Manometer
(AH) (in. H2Q)
Actual Flow
(m3/min)
Vs
Standard Flow
(nrVmin)
Standard Flow
(ft3/min)
Adjusted
Manometer(5)
(in. H2Q)
Adjusted
Qs
A3A5)
(ftVmin)
Weekly Flow Check
Starting
Manometer
(in. H20)
Stopping
Manometer
(in. H20)
Start
Date
Start Stop Stop
Time Week Filter Number Time Date
Orifice Information
Orifice S/N
Qa Slope (m)
Qa Intercept (b)
Calibration Date
Orifice Notes: Information to left found on the
latest certification worksheet delivered with a
newly certified orifice. Orifice should be
calibrated annually. Slope and intercept values
should come from Qa portion of the calibration.
Monthly Calculations:
1) Connect the U-tube manometer to the orifice plate then read and record the initial pressure drop.
2) Use the manometer reading to calculate the actual flow rate using the Qa equation below, which
uses actual temperature and pressure as well as specific orifice values filled out above.
3) Convert actual flow rate to standard flow rate using the Qs equation below.
4) Convert the standard flow rate from (m3/min) to (ft3/min).
5) If necessary, adjust the control screw so that the final flow rate is between 32-40 ft3/min.
(2) Qa =Mm
(3) a = a
AH
f r. \
-b
(4) Qs(fi7j= 35.315x2,ten)
Where:
Qa = Actual flow rate at field conditions (m3/min)
Qs = Standard flow rate at standard conditions (m3/min)
m = Slope value from Qa portion of orifice calibration
b = Intercept value from Qa portion of orifice calibration
AH = Manometer reading (in. H20)
Ta = Actual temperature (273 + °C = K)
Pa = Actual atmospheric pressure (mmHg)
Ts = Standard temperature = 298 K
Ps = Standard atmospheric pressure = 760 mmHg
ATTACHMENT D
TISCH O
Environment a)
TSCH ENVIRONMENTAL, toe,
145 SOUTH MIAMI AVE
V8AASE OF CLEVES, OH
513.467.9000
877.263.7610 TOLL FREE
513.467.9009 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5025A
Date - Jul 10, 2014 Rootsmeter S/.N 0438320
Operator Tisch Orifice I.D. - 8091779
Ta (K)
Pa (mm)
296
754.38
PLATE
OR
Run #
VOLUME
START
(m3)
VOLUME
STOP
{m3)
DI FF
VOLUME
Cm3)
DIFF
TIME
(min)
METES
DIFF
Hg •
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1. 00
1.00
1.00
1.00
1. 00
1.3390
0.9370
0.8770
0.8370
0.6900
3.3
6 .4
8 .1
9 . 0
12 . 9
2.00
4 .00
5.00
5.50
8 . 00
DATA TABULATION
Vstd
(x axis)
Qstd
(y axis)
Va
(x axis)
Qa
!y axis)
0.9949
0.9907
0.9885
0.9874
0.9822
0.7163
1.0038
1.1271
1.1797
1.4235
1.4137
1.9993
2.2353
2.3444
2.8275
0.9956
0,9914
0.9892
0.9881
0.9829
0.7168
1.0045
1.1279
1.1805
1.4245
0.8859
1.2528
1.4007
1.4690
1.7717
Qstd slope (m)
intercept (b) =
coefficient (r) =
1.99700
-0.01294
0.99992
Qa slope (m) = 1.25049
intercept (b) = -0.00811
coefficient (r) = 0.99992
y axis = SQRT[H20(Pa/760) (298/Ta)] y axis = SQRT[H20(Ta/Pa)
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff. Hg)/760](298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{[SQRT(H20(Pa/760)(298/Ta))]- b}
Qa = l/m{[SQRT H20(Ta/Pa)3- b}
Environmental
ATTACHMENT D
TISCH O
TJSCH EmnmntmrniM., INC,
145 SOUTH MMMI AVE
VILLAGE OF CLEVES, OH
45DD2
513.457.9000
877.263.7610 Tou FREE
513.467.9009 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5025A
Date - Jul 21, 2 014 Rootsmeter S/N
Operator Tisch Orifice I.D. -
0438320
5-76-02
Ta (K)
Pa (mm)
299
754.38
PLATE
OR
Run #
VOLUME
START
Cm3)
VOLUME
STOP
(m3)
DIFF
VOLUME
Cm3)
DIFF
TIME
(min)
METER
DIFF
Hg
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.00
1. 00
1. 00
1.00
1.00
1.3950
0.9800
0.8780
0.8370
0.6860
3.2
6.4
8 . 1
8 . 9
12 .9
2 . 00
4 . 00
5 . 00
5.50
8.00
DATA TABULATION
Vstd
(x axis)
Qstd
(y axis)
Va
(x axis)
Qa
(y axis)
0.9851
0.9808
0.9786
0.9776
0.9723
0.7061
1.0008
1.1146
1.1680
1.4174
1.4066
1.9893
2.2241
2.3326
2.8132
0
0
0
0
9957
9914
9892
9882
0.9829
0
1
1
1
1
7138
0116
1266
1806
4328
0.8903
1.2591
1.4077
1.4765
1.7807
Qstd slope (m) = 1.98285
intercept (b) = 0.00883
coefficient (r) = 0.99986
Qa slope (m) = 1.24163
intercept (b) = 0.00559
coefficient (r) = 0.99986
y axis = SQRT[H20(Pa/760)(298/Ta)] y axis = SQRT[H20(Ta/Pa) ]
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff. Hg)/760](298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{ [SQRT(H2O(Pa/760) (298/Ta))]- b)
Qa = l/m{[SQRT H20(Ta/Pa)]- b}
BHV-1
Energey Fuels Resources - White Mesa Mill
Period: July 1, 2014 - September 30, 2014
Calibration Date: 7/10/2014
Calibration Slope & Intercept:
Orifice S/N: 8091779
m= 1.25049 b= -0.0081 Updated: 8/22/14
Week
#
Filter
Number
Start
Date
Stop
Date
Start
Time
Stop
Time
Total
Time
(min)
AH
Starting
Manometer
(in. H20)
AH
Stopping
Manometer
(in. H20)
AH
Average
Manometer
(in. H,0)
Ta
Wkly. Avg,
Temp.
CC)
Ta
Wkly. Avg.
Temp.
CO
Pa
Wkly. Avg.
Pressure
(mmHg)
Qa
Act. Flow
(mVmin)
Qs
Std. Flow
(mVmin)
Qs
Std. Flow
(SCFM)
(ftVmin)
Tolal
Std.
Volume
(in')
Tare
Weight
(8)
Gross
Weight
(g>
Net
Weight
(mg)
Loading
0ug/m')
Percent
Onstream
(%)
7130505 7/7/2014 7/14/2014 7278.3 17366.2 10087.9 4.1) 4.0 4.0 19.0 292.2 621.03 1.10 0.92 32.48 9278.3 4.4442 4.4905 46.3 0.0050 100.1
7123199 17366.2 27408.8 10042.6 3.5 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 4.5221 4.5319 0.0011 99.6
7129193 27408.8 37640.7 10231.9 4.0 3.5 20.0 293.2 621.03 1.07 31.40 9098.0 4.5172 4.5218 0.0005 101.5
7129187 37640.7 47869.5 10228.8 3.0 3.9 3.5 20.0 293.2 621.03 1.03 0.85 30.13 8726.1 4.5303 4.5360 5.7 0.0007 101.5
47869.5 57734 9864.5 3.5 4.0 20.0 293.2 621.03 1.07 0.89 31.40 8771.3 4.5295 4.5380 97.9
57734 67754.2 4.0 20.0 293.2 621.03 1.09 0.91 32.02 9085.1 4.5402 4.5464 0.0007 99.4
rn
67754.2 77803.4 1004').2 3.6 3.9 3.8 20.0 293.2 621.03 1.07 0.89 31.40 8935.5 4.5359 4.5435 7.6 0.0009 99.7
77803.4 83387.6 5584.2 3.7 3.6 3.7 20.0 293.2 621.03 1.06 30.98 4899.1 4.5610 0.0015 55.4
83387.6 93412.4 10024.8 4.0 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9089.3 4.5542 4.5605 6.3 0.0007 99.5
10 93412.4 103434.8 10022.4 4.0 4.0 20.0 293.2 621.03 0.92 32.42 9202.2 4.5613 4.6928 131.5 0.0143 99.4
103434.8 1 13555.1 10120.3 3.5 3.6 3.6 20.0 293.2 621.03 0.87 30.56 8757.0 4.5489 4.5543 5.4 0.0006 100.4
12 17921.6 27945.! 10024.2 3.6 3.7 20.0 293.2 621.03 1.06 31.19 8854.0 4.5355 4.5454 9.9 0.0011 99.4
13 27945.6 38066.3 10120.7 4.0 3.9 20.0 293.2 621.03 1.08 0.90 31.81 9117.6 4.5355 4.5454 9.9 0.0011 100.4
Totals 126421.7 13.92 11.56 408.38 112503.2 58.908 59.168 259.1 0.0291
Averages 9724.7 3.7 3.8 3.8 19.9 293. 621.03 .07 0.89 8654.1 4.531 4.551 19.9 0.0022 96.5
Comments:
Insert weekly flow check values in yellow columns
Blue column values are calculated
Green columns are calculated averages from the met station
jlnsert tiller weight values into orange columns.
I White Mesa Mill - Standard Operating Procedures I
Book #11, Environmental Protection Manual, Section 1.2
Date: 0411/14 Revision: EFR-32-
l Page 1 of 3
AIR MONITORING ~ RADON
l. 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 of BHV-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 sample 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 Radtrak® (Trac-Etch) Outdoor Air
| Radon Detector, (Landauer Part Number DRNM) or equivalent. One or more than 4one
Radtrak® (Trac-Etch) Outdoor Air Radon Detector will be placed at each of the locations
noted above (except BHV-70). The number of detectors to be placed at each location
| shall be as determined by the Radiation ASafety Officer ("RSO"). If multiple Radtrak®
detectors are placed at one location, the numeric average of the results for that location
will be calculated and reported as the radon value for the quarter.
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:
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;
White Mesa Mill - Standard Operating Procedures Date: 0411714 Revision: EFR-32
Book #11, Environmental Protection Manual, Section 1.2 Page 2 of 3
b) A field blank sample will be collected 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.
1.3 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) Outdoor Air Radon Detector
(Landauer Part Number DRNM) or equivalent. The detectors 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 of 6.0 pCi/L-
days.
2.2 Monitoring Methodology
The following monitoring procedures will be followed:
a) Remove detector from package - The Radtrak® radon detectors are supplied
in aluminum bags which prevent radon exposure. Open the aluminum bag and
remove the clear plastic cup which has a Radtrak® detector fastened to the
bottom. 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 Log Sheet with the serial number on the detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach a field canister to a post or other location using the metal bracket with
the open mouth of the canister facing down. The canister 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 assembled cup inside the canister and
replace the retaining ring and wing nuts in order to hold the cup in place.
I White Mesa Mill - Standard Operating Procedures I
Book #11, Environmental Protection Manual, Section 1.2
Date: 04JJ./14 Revision: EFR-32-
> Page 3 of 3
d) Leave the detectors undisturbed for the duration of the three month
monitoring period.
e) At the end of the monitoring period, remove the Radtrak® detector from the
plastic cup. 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 Log Sheet.
f) After all of the detectors have been collected and sealed, but prior to final
packaging and shipment, open a new detector and immediately cover all the holes
on the top of the detector with one of the gold seals provided with the shipment.
Label this detector 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 Sheet using the
laboratory provided label for shipment back to the supplying organization.
3. RECORD KEEPING
Data maintained in record form for environmental radon is:
a) Sample period;
b) Sample location; and
c) Radon levels.
I White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43A3-1 l/14Revision: EFR-43
Page 1 of 6
STACK EMISSION MONITORING PROCEDURES
WHITE MESA GAS STACK EMISSIONS
1.0 INTRODUCTION
White Mesa, or it's contracted service providers, uses scientifically approved
reference methods to determine gas stack emissions release concentration for
radionuclide particulates. These methods conform to principles that apply to
obtaining valid samples of airborne radioactive materials, using prescribed
acceptable methods and materials for gas and particulate sampling. See American
Standard Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
ANSI N13.1-1969. These sampling methods are also consistent with guidance
contained in the U.S. Nuclear Regulatory Commission's Regulatory Guide 4.14,
"Radiological Effluent and Environmental Monitoring at Uranium Mills."
2.0 SAMPLING METHODOLOGIES
The sampling methods for airborne radionuclide particulates, from the yellowcake
dryer and other mill effluent control stacks, are identical to methods published in
the EPA's manual, Gas Stream Sampling Reference Methods for New Source
Performance Standards; they are found in the EPA Manual in Appendix No. 5,
"Determination of Particulate Emissions from Stationary Sources" ("EPA Method
#5") and Appendix No. 17, "Determination of Particulate Emissions from
Stationary Sources (In-Stack Filtration Method)" ("EPA Method #17). Copies of
EPA Method #5 and #17 are attached to this SOP. Sampling is performed as per
the methods, to ensure that the sampling and results are: (1) isokinetic; (2)
representative; and (3) adequate for determination of the release rates and
concentrations of U-Nat, Th-230, Ra-226 and Pb-210.
2.1 Sampling Equipment
Sampling equipment used to collect airborne radionuclide particulates from point
source emission stacks at the Mill consists of equipment manufactured by
Research Appliance Company (RAC), (or other equivalent apparatuses), as
follows:
1. RAC Model 201009 Model 2414 stack sampler.
2. Two each, RAC Model 201044 modular sample cases. One heater box and
one glassware box.
3. One each, RAC Model 201019 umbilical cord.
N:\WMM\SOPs and ProceduresVEPM - November 2014 Revision\Section 1.4 Stack MonitoringVAppendix E-Section
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Renewal\EFR\Appendix E Section 1.4 Stack Emission 3.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
Page 2 of 6
4. Three each, RAC Model 201013 - 100mm diameter filter holders.
5. One each, RAC Model 201005 standard pilot tube, three feet length,
stainless steel/S-type probe.
6. Barometer.
7. Psychrometer.
8. Satorius Model 2432 balance or equivalent.
9. Triple beam balance.
Equipment instruction and operating manual(s) provided by the manufacturer(s)
are retained at the Mill and used for specific guidance and reference.
2.2 Sample Collection
Gas stack samples are collected from emission control systems used in Uranium
Recovery Operations at the Mill. These samples are collected from process stacks
when the emission control systems are operating. They are sampled for
radionuclide particulate concentrations at a frequency in accordance with Table 5-
1. Sample collection methods are described in detail in EPA Method #5 and EPA
Method #17, Determination of Particulate Matter Emissions From Stationary
Sources. It is necessary to read and understand all procedures described in the
methods and in the equipment manual. The operation of the equipment requires
"hands-on" instruction from the Environment Departmental Staff from individuals
who are experienced in using sample collection equipment and applying sample
collection methods. The following steps are described for stack sample
collection.
1. Check equipment listed in Section 2.1 of this SOP. Consult the
manufacturers equipment operations manual for details.
2. Assemble equipment as described in the operations manual for sample
collection EPA Method #17.
3. Follow the calibration procedure listed in the manual. If the
calibration measurements are not obtained, consult the trouble
shooting section of the manual for corrective instruction. Once the
collection apparatus is calibrated, proceed to the next step.
4. Weigh a new glass fiber filter, record the weight, and place in the
filter holder assembly.
5. Check the sample collection system for leaks.
6. Cap ends of sample probes to prevent contamination and transport
sample unit to the sample location.
7. Uncap sample end and insert 3/8-diameter sample probe into the stack
in the midsection of the exhaust stream.
8. Turn sample apparatus on and observe unit operation to insure a
sample is being collected and the apparatus is functioning properly.
N:\WMM\SOPs and Procedures\EPM - November 2014 Revision\Section 1.4 Stack MonitoringVAppendix E-Section
1.4 Stack Emission 4 - Nov 2014.docF:\Mill SOP Mooter Copv\Book 11 Environmental Proceduroo\07 License
Ronowal\EFR\Appondix E Section 1.4 Stack Emission 3.doc
White Mesa Mill - Standard Operating Procedures
Book#l 1: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
Page 3 of 6
9. Collect the stack sample for at least one hour during periods of routine
process operation. Note the collection time.
10. Record the information described in the manufacture's operations
manual. This information is also described in the EPA Methods #5
and #17 for point source particulate emissions.
11. After sample collection is complete, turn off unit. Obtain sample
filter from filter housing and place in a new plastic petri dish. Send to
outside laboratory for radionuclide analysis in accordance with Table
5-1.
2.3 Sample Handling and Shipping
1. During preparation and assembly on the sampling train, keep all
openings where contamination can occur covered until just prior to
assembly or until sampling is about to begin.
2. Using a tweezer or clean disposable surgical gloves, place a labeled
(identified) and weighed filter in the filter holder. Be sure that the
filter is properly centered and the gasket properly placed so as to
prevent the sample gas stream from circumventing the filter. Check
the filter for tears after assembly is completed.
3. Before moving the sampling train to the cleanup site, remove the
probe from the sample train, wipe off the silicone grease, and cap the
open outlet of the probe. Be careful not to lose any condensate that
might be present. Wipe off the silicone grease from the filter inlet
where the probe was fastened, and cap it. Remove the umbilical cord
from the last impinger, and cap the impinger. If a flexible line is used
between the first impinger or condenser and the filter holder,
disconnect the line at the filter holder, and let any condensed water or
liquid drain into the impingers or condenser. After wiping off the
silicone grease, cap off the filter holder outlet and impinger inlet.
Either ground-glass stoppers, plastic caps, or serum caps may be used
to close these openings.
4. Transfer the probe and filter-impinger assembly to the cleanup area.
This area should be clean and protected from the wind so that the
chances of contaminating or losing the sample will be minimized.
5. Save a portion of the acetone used for cleanup as a blank. Take 200
ml of this acetone directly from the wash bottle being used, and place
it in a glass sample container labeled "acetone blank."
6. Carefully remove the filter from the filter holder, and place it in its
identified petri dish container. Use a pair of tweezers and/or clean
disposable surgical gloves to handle the filter. If it is necessary to fold
the filter, do so such that the PM cake is inside the fold. Using a dry
Nylon bristle brush and/or a sharp-edged blade, carefully transfer to
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-11/14Revision: EFR-44
Page 4 of 6
the petri dish and PM and/or filter fibers that adhere to the filter
holder gasket. Seal the container.
7. Send to the laboratory for radionuclide analysis.
3.0 RECORD KEEPING
Records of gas stack effluent sampling events and results of analysis are retained
at the Mill. The following information is recorded:
1. Stack and Run ID
2. Date and Sampler
3. Sampled Air Volume at standard conditions
4. Sampled Water Volume at standard conditions
5. Moisture Content (volume basis)
6. Stack Gas Molecular Weight (wet basis)
7. Stack Gas Velocity
8. Stack Gas Volumetric Flow Rate (dry basis, at standard conditions)
9. Particulate Concentration
10. Percent Isokinetics
11. Emission Rates for Particulates U-Nat, Th-230, Ra-226, and Pb-210.
The data are used to calculate emission rates in pounds and pico curies per hour
for radionuclide particulate concentrations.
4.0 MONITORING LOCATION AND FREQUENCY
Stack sampling must be performed during any quarter or semi-annual period that
the stacks operate in accordance with the schedule in Table 5-1. During non-
operational periods, stack sampling is not performed.
4.1 Yellowcake Stacks
The exhaust stack for the drying and packaging equipment associated with the
yellowcake calciner is sampled on a quarterly basis during operations. The
sample ports are located on the roof of the main Mill building.
4.2 Feed Stacks
The grizzly feed stack is located on the north end of the grizzly structure. This
stack is accessible from a stack platform and is sampled on a semi annualquarterly
basis if this system is operating.
N:\WMM\SOPs and ProceduresVEPM - November 2014 RevisionVSection 1.4 Stack MonitoringVAppendix E-Section
1.4 Stack Emission 4 - Nov 2014.docF:\Mill SOP Master CopvVBook 11 Environmental Procedure5\07 License
Rcnowal\EFR\Appendix E Section 1.1 Stack Emission 3.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-1 l/14Revision: EFR-43
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4.3 Vanadium Stacks
The exhaust stack for the drying and packaging equipment associated with the
vanadium circuit is sampled on a quarterly basis during operations. The sample
ports are located on the roof of the vanadium annex portion of the building.
5.0 ANALYSIS REQUIREMENTS
All gas stack samples are collected at the Mill according to the calendar year
schedule shown below in Table 5-1. The samples will be sent to an off-site
laboratory for the analysis detailed below.
TABLE 5-1
Sampling Frequency and Analysis
Feed Stack Stack for Y.C. Dryer and Packaging
Quarterly: None Quarterly: If operating, U nat
Semi Annual: If operating, U nat, Th 230—Semi Annual: If operating, U nat
Th 230, Ra 226,
Pb 210
Frequency
Grizzly
Baghouse
Stack
North and/or
South
Yellowcake
Dryer Stacks
Yellowcake
Packaging
Baghouse
Stack
Vanadium
Dryer Stack
Vanadium
Packaging
Stack
Quarterly If operating,
U-nat, Th-230.
Ra-226. Pb-
210. Th-232.
Ra-228. and
Th-228.
If operating,
U-nat. Th-230,
Ra-226. Pb-
210. Th-232,
Ra-228, and
Th-228.
If operating, U-
nat, Th-230,
Ra-226. Pb-
210, Th-232,
Ra-228, and
Th-228.
If operating, U-If operating, U-
nat, Th-230,
Ra-226. Pb-
210, Th-232.
Ra-228, and
Th-228.
nat, Th-230,
Ra-226. Pb-
210. Th-232.
Ra-228. and
Th-228.
Note: Grizzly baghouse stack and Vanadium Circuit stack samples shall be representative
and adequate (based on EFRI's operational knowledge and operational conditions at the
time of the sampling event) for the determination of the release rates and concentrations
of radionuclides listed in Table 5-1 above, and do not need to be collected in an isokinetic
state.
6.0 QUALITY ASSURANCE METHODOLOGY
6.1 Equipment Operation
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 43/43-11/14Revision: EFR-43
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Prior to performing an emission point sampling run, the sampling equipment is
subjected to a dry run test to determine leakages or equipment malfunction.
Calibration of equipment is checked on a periodic basis. Probe tips are protected
by a protective cap while not in use to protect accuracy determinations. During
transport of equipment, all openings are sealed to prevent contamination.
Calculations utilized during runs to maintain isokinetic conditions are reviewed
and dry run tested prior to the actual run. All containers and probes are washed
prior to each usage.
Malfunction of sampling equipment, excessive malfunctions of normal operations
being monitored, or percent isokinetic sampling rates greater than ± 10% error,
indicate mandatory voiding of the run or data involved.
6.2 Operations
If samples are collected from the operation of any unit which appears, in the
judgment of the sampler, to be functioning in a manner not consistent with normal
operations, then the sample will be voided and the system will be resampled.
6.3 Chemical Sample Control
Analyses on each period's sample shall include blanks for the filters, impinger
solutions, and the rinse solutions. A field logbook shall be maintained listing data
generated, determinations of volumes measured, and net gain weights of filters to
provide a back up to summary data records. Filters are transmitted within plastic
enclosed petri dishes. Handling of filters is only done using tweezers.
6.4 Calculations
All calculations will be retained at the Mill in both a hard copy and computer
files.
The gas stack effluent concentrations (C) are calculated as follows:
Lab Result u,Ci (A) / Volume Sampled (V) = Effluent Concentration (C)
where
Volume Sampled (V) = Flow rate (Q) * Time of sample collection in minutes (t)
and
Lab Result uCi (A) = Radioisotopic activity, in jiCi on air filter
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1.4 Stack Emission 4 - Nov 2014.docF:VMill SOP Master CopyVBook 11 Environmental ProcodurosV07 License
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White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 0411/14 Revision: EFR-34
Page 1 of 4
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 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 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.
I White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual. Section 4.1
Date: ©4JJ./14 Revision: EFR-34
Page 2 of 4
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 one centimeter. The one 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).
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:
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).
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 9411/14 Revision: EFR-34
Page 3 of 4
2.2 Sample Labeling
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
2.2 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.
6. Signatures of persons releasing custody.
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.
I White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 94JJ/14 Revision: EFR-34
Page 4 of 4
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 soil sample data are retained in the files 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 will be documented, signed, and
dated by the analyst.
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,
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.
Chain of Custody and Analytical Request Record Page.
PLEASE PRINT, provide as much information as possible. Refer to corresponding notes on reverse side,
project Name. PWS #. Permit #, Etc.:
Of.
Company Name:
Report Mail Address: Contact Name. Phone, Fax, E-mail: Sampler Name if other than Contact:
Invoice Address: Invoice Contact & Phone #: Purchase Order #: ELI Quote #:
Report Required For POTW/WWTP • DW •
Other
Special Report Formats - ELI must be notified prior to
sample submittal for the following:
NELAC • A2LAG Level IV •
Other
EDD/EDT • Format
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Date
Collection
Time
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sample submittal for additional j
charges and scheduling | Cooler ID(s)
Comments:
Receipt Temp
Custody Seal Y
Intact Y
Signature Y
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MUST be
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Relinquished by (pnnt) Signature
Relinquished by (print) Signature
Sample Disposal: Return to client: Lab Disposal:
Received by (pnnl) Signature
Recewed by (print). Dale/time Signature.
Sample Type:. LABORATORY USE ONLY # of fractions
Ir -=rtaln circumstances, samples submitted to Energy Laboratories, Inc. may be "•^contracted to other certified laboratories In order to complete the analysis req>'
This serves as notice of this possibility. All sub-c ;t data will be clearly notated on your analytical report
Visit our web site at wvw.eneroyfaD.com Ibr additional information, downloadable fee schedule, forms, & links.
-<ed.
BHV-2
BHV-1
tt
BHV Mr
BHV-7
BHV-5
» , t» ll..—4-
T37S
T38S BHV-4 BHV-6 Actual location of BHV-^s
is 34,500 feet due west tt
' ' Energy Fuels Resources (USA) Inc. - -
I k A ii 1
1 191
tt
1 IN = 6.000 FT
3,750 7,500 11,250 15,000
=HH Feet
Legend
Program
* 1,000 Feet
* 2,500 Feet
* Existing Air Monitoring Station
* Tentative Air Monitoring Station
1 'Property Boundary
Road
CJT°wnship and Range Coordinate System: NAD
J Section 1983 StatePlane Utah
South FIPS 4303 Feet
V
ENERGYFUELS
By:
Project: WHITE MESA MILL
County: San Juan State: Utah
FIGURE 1
SOIL MONITORING LOCATIONS
Author: mhenington Date: 9/5/2014 Drafted By: mhenington
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 42/4211/14 Revision: EFR-33
Page 1 of 4
VEGETATION MONITORING
PART I VEGETATION MONITORING PLAN
1.0 VEGETATION MONITORING PLAN
Vegetation is sampled in early spring, late spring, and late fall at three locations around the
Mill. These locations are: Northeast Area (near BHV-1), Northwest Area (V2 mile west of
BHV-1) and the Southwest Area (West of BHV-4 and south off Cell 3).
2.0 QUALITY ASSURANCE
Quality assurance for vegetation monitoring is based on the contract laboratory's quality
controls such as duplicates, blanks, standard percent recovery, and spike percent recovery.
The laboratory will also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides
4.14 and 4.15 when analyzing the vegetation samples. The laboratory is committed to meet
the LLD values for radionuclides addressed in these guidelines and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each vegetation sample will be analyzed for Ra-226, U-Nat, Th-232, and Pb-210
radionuclide concentrations. Results will be expressed in units of picocuries per gram (pCi/g)
or micro curies per kilogram (uxi/kg), on a wet basis.
PART II VEGETATION MONITORING STANDARD OPERATING PROCEDURES
1.0 VEGETATION SAMPLING
1.1 Equipment
Equipment used for vegetation sampling is as follows:
1. Scissors
2. Large plastic sample bags
1.2 Vegetation Sampling Procedure
Vegetation samples are collected and removed at the surface with scissors at each sampling
location. The vegetation sample is enclosed in a large plastic bag. Each sample will be
weighed upon return to the office and must weigh at least three kilograms in order for the
I White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 42/42-11/14 Revision: EFR-32
Page 2 of 4
laboratory to meet the required LLD values outlined in U.S. NRC Regulatory Guide 4.14. In
addition, as vegetation samples are collected efforts will be made to minimize the amount of
soil in the samples. The sample bag is then labeled (see Section 2.1).
2.0 SAMPLING QUALITY ASSURANCE
2.1 Sample Labeling
All sample labels must be filled out in waterproof ink and numbered. The date, time,
sampler's initials, and the sample location will be completed at the time the sample is
collected. The following information will be included on the label:
1. Project and facility.
2. Sampler's company affiliation.
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Weight of sample.
7. Requested analytical parameters.
2.2 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 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 4.2
Date: 42/4211/14 Revision: EFR-32
Page 3 of 4
6. Signatures of persons releasing custody.
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 analysis of the
samples. After sample analysis, the COC form will be sent to the Environmental Department along
with the analyses.
2.3 Sample Handling and Shipping
Sample bags will be packaged in large shipping boxes and transported to the contract
laboratory. COC forms will be placed inside a sealed bag and placed inside the shipping
box.
2.4 Record Keeping
All vegetation sampling data will be retained in a file. When analytical data becomes
available, the data is entered into a computer file and retained in the files. All laboratory
analytical data is stored in the vegetation files after the data has been entered into the
computer file.
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and QC Review
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 a copy of and retain all analytical and QC
documentation. The laboratory will provide the Mill with paper copies of the following in
each data package, in accordance with QA objectives for the Surface Soil QA Project Plan:
1.
2.
3.
4.
5.
6.
COC forms
Cover sheets with comments
Narrative
Samples analyzed
Reporting limits and LLD values for analytes
Analytical results of QC samples
The data reduction and laboratory review will be documented, signed, and dated by the
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 42/4211/14 Revision: EFR-32
Page 4 of 4
contract laboratory analyst.
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.
CLEAN
White Mesa Mill - Standard Operating Procedures
Book #11. Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 1 of 7
AIR MONITORING - PARTICULATE RADIONUCLIDES
PART I AIR MONITORING PLAN
1.0 PARTICULATE RADIONUCLIDE AIR MONITORING
Air samples for monitoring particulate radionuclides are taken at the following locations:
(See Attachment A)
BHV-1 Northeast of the Mill at the meteorological station.
BHV-2 Approximately 2.5 miles north of the Mill.
BHV-4 Approximately 400 yards south of Cell No. 4.
BHV-5 Approximately 100 yards south of the intersection of Highway 191 and the
Mill access road.
BHV-6 Approximately 0.5 miles south of BHV-5 along Highway 191.
BHV-7 Approximately 0.8 miles south of BHV-1 along Highway 191.
BHV-8 Approximately 0.6 miles west of BHV-1.
Air samples are collected on a weekly basis. A composite of 13 weekly samples from
each of the above locations is prepared to form a quarterly sample for each location.
2.0 QUALITY ASSURANCE
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in this SOP (Section 6.0).
Quality assurance of the analytical results is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percent recovery. The laboratory will
also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides 4.14 and 4.15
when analyzing the air filter samples. The laboratory is cornmitted to meet the LLD
values for radionuclides listed in these guidance documents, and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each quarterly sample will be analyzed for U-Nat, Ra-226, Th-230, Pb-210 and Th-232.
Results will be expressed in picocuries per milliliter (pCi/mL).
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 2 of 7
PART II STANDARD OPERATING PROCEDURES
1.0 EQUIPMENT
The equipment used in monitoring levels of particulate radionuclides consists of high
volume air samplers equipped with mass flow controllers and vacuum switch controlled
timers. The samplers are capable of collecting air through the sample filter at a
volumetric flow rate of approximately 40 standard cubic feet per minute (scfm). The
mass flow controller varies the actual air flow rate as dictated by changing temperature,
filter loading, and barometric pressure to maintain a constant standard air flow rate. The
actual rate is read directly from the analog gauge located on the front panel. The timer is
turned off when no vacuum exists in the system, i.e., when the motor/blower assembly is
disconnected or otherwise malfunctions.
Particulates are trapped on an 8 x 10-inch glass microfiber filter such as one of the
following, or equivalent:
1. Whatman EPM 2000
2. Schliecher & Schuell #1 HV.
2.0 MONITORING METHODOLOGY
The air samplers are mounted on towers approximately 2 meters above ground plane.
The samplers run continuously except for calibration, mechanical or electrical failure, and
maintenance down time. Target flow rate will be 36 scfm.
Air filters are replaced weekly due to particulate loadings. Maximum filter use duration
will be weekly unless weather conditions prohibit safe access to one or more of the air
monitoring station locations.
Each filter is stamped by the manufacturer with a unique number. The blank filters are
weighed to the nearest 0.0001 gram using a Sartorius Model 2432 analytical balance or
equivalent. The filters are kept in manila folders inside resealable plastic bags for support
during transportation to the site. The tare weight is then recorded on each filter folder
along with the location, filter number, start date, and start time. This information is then
input into an analytical data file on the computer. When the sampled filters are collected
in the field, the stop dates and times are entered on the folder. On return from the field,
the filters are again weighed and the gross weights are recorded on the folders. The
weights, stop dates, and stop times are then recorded into the analytical data file that is
printed off and sent to the contract laboratory.
Samples are collected continuously for approximately one week. The "loaded" filters are
removed from the shut down samplers, folded, and placed in the folders in the plastic
bags. If any part of the filter remains on the seal gasket, it is removed and added to the
folder. The new filters are removed from their folders and placed on the vacuum head
White Mesa Mill - Standard Operating Procedures
Book#l 1, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 3 of 7
with the filter holder frame tightened enough to seal, but not tight enough to rupture the
filters. The samplers are then turned on.
Each station's filters are composited on a quarterly basis (13 weeks) by the environmental
staff. The samples are forwarded, along with an analytical sheet and Chain of Custody
(COC) form (provided by the contract laboratory), to the contract laboratory in sealed
plastic bags.
3.0 CALIBRATION
3.1 Orifice Plate
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 will do the
calibration. Calibrations will be completed in accordance with EPA-600/4-77-027a, The
Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II -
Ambient Air Specific Methods. Calibration records are kept in the environmental files.
3.2 Sampler
Calibration of the equipment occurs during the first Monday of each month. If a non-
scheduled motor replacement is necessary, the sampler is re-calibrated.
An orifice plate assembly and U-tube manometer are used for monthly calibrations.
The sampler flow rate is regulated to a standard air volume that is recorded on the field
calibration sheet using 20°C. (298 K) and 29.2 inches (760 mm) of mercury as standard
conditions. The top portion of the Monthly Calibration and Weekly Flow Check
Worksheet (Attachment C) is completed for each air sampling station and retained in the
files.
The monthly calibration task involves the following:
1. Before visiting each monitoring location, the air temperature and barometric
pressure are recorded.
2. The motors are replaced as required. The replacement motors are prepared at the
Mill office.
3. A filter is placed within the orifice plate, and the orifice plate is secured on top of
the vacuum head.
4. The orifice plate is connected to the U-tube manometer and the initial inches H20
is recorded and a flow rate calculated using the current field temperature and
pressure.
5. The control screw is adjusted as necessary to advance or slow the vacuum motor
to reach the desired flow rate. The final flow rate must be at least 32 scfm on the
analog meter and reach 75% onstream time for the quarter to meet the required
LLD for the radionuclide parameters.
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 4 of 7
4.0 CALCULATIONS
Using inches of water from the U-tube, refer to the following subsections to perform the
calculation of flow rate. Section 4.1 provides the equation used to compute the flow rate
at field conditions, and (the "actual" flow rate [Qa]), in cubic meters per minute. Actual
flow rate must be corrected to standard flow rate (Qs) using the flow rate equation in
Section 4.2. The standard flow rate is then converted to standard cubic feet with the
conversion equation in Section 4.3.
4.1 Orifice Equation
Using the inches of water
measurement, determined from the U-tube, the following equation is used to calculate the
flow rate at field conditions:
Where:
Qa = Actual flow rate at field conditions (mVmin)
m = Slope value from Qa portion of orifice calibration
AH = Manometer reading (in. H20)
Ta = Actual temperature (273 + °C = K) [from the meteorological station data
(temperature readings) that are downloaded weekly]
Pa = Actual atmospheric pressure (mmHg) [from the meteorological station data
(barometric pressure readings) that are downloaded weekly]
b = Intercept value from Qa portion of orifice calibration
The constants m and b in the above equation are provided by the calibration laboratory
for each specific calibrated orifice (Attachment D). Each orifice will have unique
performance properties that relate to design; those measured performance properties are
incorporated into the flow equation as specific constants. The flow equation
demonstrates the relationship between measured vacuum pressure in inches of water to
actual flow rate utilizing this device.
White Mesa Mill - Standard Operating Procedures
Book#l 1, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 5 of 7
4.2 Standard Conditions Flow Rate Equation
The flow rate at standard conditions is calculated by adjusting the field condition flow
rate, calculated above, by the following equation:
f r> ^
Qs = Qa T
Where:
Qs = Standard flow rate at standard conditions (mVmin)
Qa = Actual flow rate at field conditions (mVmin)
Ta = Actual temperature (273 + °C = K)
Pa = Actual atmospheric pressure (mmHg)
Ts = Standard temperature = 298 K
Ps = Standard atmospheric pressure = 760 mmHg
4.3 Correction Equation
To convert the standard flowrate, from cubic meters per minute to standard cubic feet per
minute, use the following equation:
a(*%J=35.315x0>;/J
5.0 RECORD KEEPING
The records are kept on the filter folders and the field worksheets, which are retained in
the environmental files in the environmental office and are also entered into the analytical
data file on the computer after the data have been reviewed. The following information
will be entered into the computer data file (see Attachment E):
• Filter number
• Start date
• Stop date
• Start time
• Stop time
• Starting manometer reading (AH) (in. H2O)
• Stopping manometer reading (AH) (in. H20)
• Weekly average temperature (Ta) (°C)
• Weekly average pressure (Pa) (mmHg)
• Tare filter weight (g)
• Gross filter weight (g)
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date 11/14 Revision: EFR-5
Page 6 of 7
The following information will be calculated by the computer file (see Attachment E):
• Total time (min)
• Average manometer reading (AH) (in. H^O)
• Weekly average temperature (K)
• Actual flow rate (Qa) (m3/min)
• Standard flow rate (Qs) (m3/min)
• Standard flow rate (Qs) (ft3/min)
• Total standard volume (m3)
• Net weight (mg)
• Loading (mg/m3)
• Percent onstream
6.0 QUALITY ASSURANCE
6.1 Installation and Removal of Filters
Field methods to assure quality of air sample collection include the following:
1. Inspection of all new filters for aberrations and discarding damaged ones.
2. Maintaining seals on equipment connections.
3. Careful installation and removal of filters, retaining all abraded filter media.
4. Proper sequential handling of all filters.
5. Filters are inspected for fingerprint contamination by visual observation.
6.2 Sample Duration
Maintenance of sample duration is assured by:
1. Installation of a vacuum-actuated timer which operates the timer only when
the motor is running and pulling the minimum allowable vacuum.
2. Weekly monitoring of stations and inspecting wear on the motors and proper
change-out at appropriate intervals (monthly).
6.3 Sample Flow Rate
Quality assurance of each sampler's flow rate is accomplished by weekly readings of the
sampler's flow characteristics using a manometer. Sampler pressure drop readings are
measured on a weekly basis using a manometer and going through the monthly
calibration steps. This value, along with average weekly temperature and pressure values
from the site meteorological station, are used to determine weekly flow rate values.
Monthly checks of flow controller operation and documentation thereof also provide
quality assurance. Samplers are calibrated and checked at motor rotation intervals
(monthly).
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.1
Date: 11/14 Revision: EFR-5
Page 7 of 7
6.4 Calculations
Calculations are checked on a random basis for inconsistencies, and such checks are
documented.
Upon retrieval of the data analytical sheet from the contract laboratory, the date of receipt
is noted, along with the date of transcription is noted on the sample station log sheet with
the transcriber's initials. The transcription of data is reviewed by another person in the
Environmental Department to minimize transposition of numerical values. Calculation
and data storage is by computer program.
6.5 Sampler Performance
A record of sampler operation time versus total possible duration time is maintained as a
flag against excessive equipment downtime. Sampler performance is reviewed monthly.
6.6 Quality Control Methodology
Blanks are weighed each week and submitted alongside the actual filters. The filters and
blanks are recorded on an analytical sheet which is sent to the vendor, and this sheet is
returned with the results.
BHV-2
—
1
1 •< ^ - /
! V? BHV-8 BHV-1
—
_J
BHV-7
BHV-5
• BHV-6 -BHV-4
Actual Location of BHV-3
is 34,500'Feet Due Wes
Energy Fuels Resources (USA) Inc
<>
91
f b
N Tentative location based on DRC
correspondence dated June 12, 2014.
Final locatons will be surveyed after
installation. Installation will be performed
after DRC approval of The Environmental
Protection Manual.
r~A IN = 6
0.5 1
000 F
_ lies
Legend
# Existing Air Monitoring Station
Q Tentative Air Monitoring Station*
Canyon Rim
Drainage
Road
|C3property Boundary
I I Tailings Cell
djTownship and Range
] Section
Pond
Coordinate System: NAD
1983 StatePlane Utah
South FIPS 4303 Feet
ENERGY FUELS
REVISIONS
Date: By
Project: WHITE MESA MILL
County: San Juan State: Utah
Location: -
ATTACHMENTA
PARTICULATE MONITORING STATIONS
Author: mhenington Date: 8/22/2014 Drafted By: mhenington
Ul M—\t BUI
PLEASE PRINT (Provide as much information as possible,
Page. of
Company Name: Project Name, PWS, Permit, Etc. Sample Origin
State:
EPA/State Compliance:
Yes • No •
Report Mail Address: Contact Name: Phone/Fax-Email: Sampler: (Please Print)
Invoice Address: Invoice Contact & Phone: Purchase Order: Quote/Bottle Order-
Contact ELI prior to |3hipP«iby;
RUSH sample submittal
for charges and
scheduling - See
Instruction Page
Special Report/Formats:
• DW
• POTW/WWTP
• State:
• Other:
• EDD/EDT(Electronic Data)
Format:
• LEVEL IV
• NELAC
QJ
, _ V/.J
a. ro,.g O |S5r8 •
CD
CD
r-Z UJ
S
X o <
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Date
Collection
Time MATRIX
R
U
S
H
Comments:
Cooler ID(*r:
RuceiptTomp
On lea: Y N
5 Custody Seal
On Bottle
On Cooler
i Intact
Y N
Y N
Custody
Record
MUST be
Signed
Relinquished by (pnnt). Dato/Time Signature'
Relinquished by (pnnt). Signature
Sample Disposal. Return to Client:. Lab Disposal..
Received by (pnnt) DBta/Tlma Signature'
Received by (pnnt) Date/Time
TlocoTvea'^^aB5raTr!^?,™M"m"™TJaTefflma™
Signature'
"SgnalureT
In certain circumstances, samples submitted to Energy Laboratories, Inc. may be subcontracted to other certified laboratories in order to complete the analysis requested.
This serves as notice of this possibility. All sub-co t data will be clearly notated on your analytical report.
Visit our web site at www.eneravlab.com for additioi. ormation, downloadable fee schedule, forms, and links.
ATTACHMENT C
MONTHLY CALIBRATION AND WEEKLY FLOW CHECK WORKSHEET
Site:
Date of Calibration:
Temperature (Ta): K
Orifice Plate No.: _
Calibrator's Name:
Pressure (Pa): _rnmHg (25.4 x inches)
Monthly Calibration for the Month of: r Initial
Manometer
(AH) (in. H2Q)
(i)
(2) Qa
Actual Flow
(m3/min)
W
Standard Flow
(m /min)
Standard Flow
(ft3/min)
Adjusted
Manometer(5)
(in. H20)
Adjusted
Qs <2'3'4'5>
(ft3/min)
Weekly Flow Check
Week Filter Number
Start
Date
Start
Time
Starting
Manometer
(in. H2Q)
Stop
Date
Stop
Time
Stopping
Manometer
(in. H20)
4
Orifice Information
Orifice S/N
Qa Slope (m)
Qa Intercept (b)
Calibration Date
Orifice Notes: Information to left found on the
latest certification worksheet delivered with a
newly certified orifice. Orifice should be
calibrated annually. Slope and intercept values
should come from Qa portion of the calibration.
Monthly Calculations:
1) Connect the U-tube manometer to the orifice plate then read and record the initial pressure drop.
2) Use the manometer reading to calculate the actual flow rate using the Qa equation below, which
uses actual temperature and pressure as well as specific orifice values filled out above.
3) Convert actual flow rate to standard flow rate using the Qs equation below.
4) Convert the standard flow rate from (m3/min) to (ft3/min).
5) If necessary, adjust the control screw so that the final flow rate is between 32-40 ft3/min.
(2) Qa =l/m AH
(3) Q,=Qa\f
jyja J
(4) a(/'>i)=35.315x«2j(m%Bn)
Where:
Qa = Actual flow rate at field conditions (m3/min)
Qs = Standard flow rate at standard conditions (m /min)
m = Slope value from Qa portion of orifice calibration
b = Intercept value from Qa portion of orifice calibration
AH = Manometer reading (in. H20)
Ta = Actual temperature (273 + °C = K)
Pa = Actual atmospheric pressure (mmHg)
Ts = Standard temperature = 298 K
Ps = Standard atmospheric pressure = 760 mmHg
ATTACHMENT D
Environmental
145 SOUTH MIAJ* AVE
VILLAGE Of CLIVES, OH
45005
513.4*7.9000
877.263.7610 Tou. FRI I
513.467.9G09 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5G25A
Date - Jul 10,, 2014 Rootsmeter S/N 0438320 Ta (K> - 296
Operator Tisch Orifice I.D. - 8091779 Pa (nun) ~ 754.33
PLATE
OR
Run #
VOLUME
START
(m3)
VOLUME
STOP
<m3)
DIFF
VOLUME
(m3)
DIFF
TIME
(min)
METER
DIFF
Hg
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.00
1.00
1.00
1. 00
1. 00
1.3390
0.9870
0.8770
0.8370
0.6900
3 . 3
S .4
8 . 1
9.0
12 . 9
2.00
4.00
5.00
5.50
8.00
DATA TABULATION
Vstd
(x axis]
Qstd
(y axis)
va
[x axis;
Qa
(y axis)
0.9949
0.9907
0.9885
0.9874
0.9822
0.7163
1.0038
1.1271
1.1797
1.4235
1.4137
1.9993
2.2353
2.3444
2.8275
0.9956
0,9914
0.9892
0.9881
0.9829
0.7168
1.0045
1.1279
1.1805
1.4245
0
1
1
1
1
8859
2528
4007
4690
7717
Qstd slope (m) = 1.99700
intercept (b) = -0.01294
coefficient (r) = 0.99992
Qa slope (m)
intercept (b)
coefficient (r)
1.25049
•0.00811
0.99992
y axis = SQRT[H20(Pa/760) (298/Ta)3 y axis = SQRT[H20(Ta/Pa) ]
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff. Hg)/760](298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{[SQRT(H20(Pa/760)(298/Ta))]- b}
Qa = l/m{[SQRT H20(Ta/Pa)3- b)
Environmental
ATTACHMENT D
TISCH ftt
7»CH EfflffRCNMEHTAL,
145 SOUTH MIAMI AYE
VILLAGE CLEVES, OH
45002
513.457.9000
877.263.761 D7ou FREE
513.467.9009 FAX
ORIFICE TRANSFER STANDARD CERTIFICATION WORKSHEET TE-5025A
Date - Jul 21, 2014 Rootsmeter S/N 043S320 Ta CK) - 299
Operator Tisch Orifice I.D. - 5-76-02 Pa (mm) - 754.38
PLATE
OR
Run #
VOLUME
START
(m3)
VOLUME
STOP
(m3)
DIFF
VOLUME
(m3)
DIFF
TIME
(min)
METER
DIFF
Hg
(mm)
ORFICE
DIFF
H20
(in.)
1
2
3
4
5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.00
1.00
1.00
1.00
1.00
1
0
0
0
3950
9800
8780
8370
6860
3
S
8
8
12
2 . 00
4 . 00
5 . 00
5.50
8 . 00
DATA TABULATION
Vstd
(x axis)
Qstd
(y axis)
Va
(x axis)
Qa
(y axis]
0.9851
0.9808
0.9786
0.9776
0.9723
0.7061
1.0008
1.1146
1.1680
1.4174
1.4066
1.9893
2.2241
2.3326
2.8132
0.9957
0.9914
0.9892
0.9882
0.9829
0.7138
1.0116
1.1266
1.1806
1.4328
0
1
1
1
1
8903
2591
4077
4765
7807
Qstd slope (m) = 1.98285
intercept (b) = 0.00883
coefficient (r) = 0.99986
Qa slope (m) = 1.24163
intercept (b) = 0.00559
coefficient (r) = 0.99986
y axis = SQRT[H20(Pa/760)(298/Ta)} y axis = SQRT[H20(Ta/Pa) ]
CALCULATIONS
Vstd = Diff. Vol[(Pa-Diff. Hg)/760] (298/Ta)
Qstd = Vstd/Time
Va = Diff Vol [(Pa-Diff Hg)/Pa]
Qa = Va/Time
For subsequent flow rate calculations:
Qstd = l/m{[SQRT(H20(Pa/760)(298/Ta))]- b}
Qa = l/m{[SQRT H20(Ta/Pa)]- b)
BHV-1
Energey Fuels Resources - White Mesa Mill
Period: July 1, 2014 - September 30, 2014
Calibration Date: 7/10/2014
Calibration Slope & Intercept:
Orifice S/N: 8091779
m= 1.25049 b= -0.0081 Updated: 8/22/14
Week
#
Filter
Number
Start
Date
Stop
Date
Start
Time
Stop
Time
Total
Time
(min)
AH
Starting
Manometer
(in. H20)
AH
Stopping
Manometer
(in. H20)
AH
Aveiage
Manometer
(in. H20)
Wkly. Avg
Temp.
CO
Ta
Wkly. Avg.
Temp.
(K)
Pa
Wkly. Avg
Pressure
(mmHg)
Qa
Act. Flow
(mVmin)
Qs
Std. Flow
(in '/mini
Qs
Std. Flow
(SCFM)
(t't'/min)
Total
Std.
Volume
(m*)
Tare
Weight
(g)
Gross
Weight
(g)
Net
Weight
(mg)
Loading
(mg/nv')
Percent
Onstream
(%)
7130505 7/7/2014 7/14/2014 7278.3 17366.2 10087.9 4.0 4.0 4.0 19.0 292.2 621.03 1.10 0.92 32.48 9278.3 4.4442 4.4905 46.3 0.0050 100.1
7123199 17366.2 27408.8 10042.6 3.5 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8689.7 4.5221 4.5319 0.0011 99.6
7129193 27408.8 37640.7 10231.9 4.0 3.5 20.0 293.2 621.03 1.07 31.40 9098.0 4.5172 4.5218 0.0005 101.5
7129187 37640.7 47869.5 10228.8 3.0 3.9 3.5 20.0 293.2 621.03 1.03 0.85 30.13 8726.1 4.5303 4.5360 5.7 0.0007 101.5
47869.5 9864.5 3.5 4.0 20.0 293.2 621.03 1.07 0.89 31.40 8771.3 4.5295 4.5380 8.5 0.0010 97.9
57734 67754.2 10020.2 4.0 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9085.1 4.5402 4.5464 6.2 0.0007
67754.2 77803.4 10049.2 3.6 3.9 3.8 20.0 293.2 621.03 1.07 tl.K'J 31.40 8935.5 4.5359 4.5435 0.0009 99.7
77803.4 83387.6 5584.2 3.7 3.6 3.7 20.0 293.2 621.03 1.06 4899.1 4.5610 55.4
83387.6 93412.4 10024.8 4.0 3.9 20.0 293.2 621.03 1.09 0.91 32.02 9089.3 4.5605 6.3 0.0007 99.5
10 93412.4 103434.8 10022.4 4.0 4.0 4.0 20.0 293.2 621.03 n.<>2 32.42 9202.2 4.5613 4.6928 131.5 0.0143 99.4
103434.8 113555.1 10120.3 3.5 3.6 3.6 20.0 293.2 621.03 1.04 0.87 30.56 8757.0 4.5489 4.5543 5.4 0.0006 100.4
12 17921.6 27945.8 10024.2 3.6 3.7 20.0 293.2 621.03 1.06 31.19 8854.0 4.5355 4.5454 9.9 0.0011 99.4
13 27945.6 38066.3 10120.7 3.9 20.0 293.2 0.90 31.81 9117.6 4.5355 9.9 100.4
Totals 126421.7 13.92 58.908 59.168
Averages 3.7 3.8 1».9 293.1 621.03 31.41 8654.1 4.531 4.551 10 0 0.0022 96.5
Comments:
Insert weekly flow check values in yellow columns.
Blue column values are calculated.
Green columns are calculated averages from the met station.
Insert filter weight values into orange columns.
ii
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.2
Date: 11/14 Revision: EFR-3
Page 1 of 3
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 of BHV-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 sample 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 Radtrak® (Trac-Etch) Outdoor Air
Radon Detector, (Landauer Part Number DRNM) or equivalent. One or more than one
Radtrak® (Trac-Etch) Outdoor Air Radon Detector will be placed at each of the locations
noted above (except BHV-70). The number of detectors to be placed at each location
shall be as determined by the Radiation Safety Officer ("RSO"). If multiple Radtrak®
detectors are placed at one location, the numeric average of the results for that location
will be calculated and reported as the radon value for the quarter.
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:
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;
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.2
Date: 11/14 Revision: EFR-3
Page 2 of 3
b) A field blank sample will be collected 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.
1.3 Analytical Requirements
Each quarterly sample will be analyzed for Radon-222. Results will be expressed in
Samples will be collected using the Radtrak® (Trac-Etch) Outdoor Air Radon Detector
(Landauer Part Number DRNM) or equivalent. The detectors 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 of 6.0 pCi/L-
days.
2.2 Monitoring Methodology
The following monitoring procedures will be followed:
a) Remove detector from package - The Radtrak® radon detectors are supplied
in aluminum bags which prevent radon exposure. Open the aluminum bag and
remove the clear plastic cup which has a Radtrak® detector fastened to the
bottom. 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 Log Sheet with the serial number on the detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach a field canister to a post or other location using the metal bracket with
the open mouth of the canister facing down. The canister 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 assembled cup inside the canister and
replace the retaining ring and wing nuts in order to hold the cup in place.
pCi/L.
2. STANDARD OPERATING PROCEDURES
2.1 Equipment
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 1.2
Date: 11/14 Revision: EFR-3
Page 3 of 3
d) Leave the detectors undisturbed for the duration of the three month
monitoring period.
e) At the end of the monitoring period, remove the Radtrak® detector from the
plastic cup. 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 Log Sheet.
f) After all of the detectors have been collected and sealed, but prior to final
packaging and shipment, open a new detector and immediately cover all the holes
on the top of the detector with one of the gold seals provided with the shipment.
Label this detector 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 Sheet using the
laboratory provided label for shipment back to the supplying organization.
3. RECORD KEEPING
Data maintained in record form for environmental radon is:
a) Sample period;
b) Sample location; and
c) Radon levels.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 1 l/14Revision: EFR-4
Page 1 of 6
STACK EMISSION MONITORING PROCEDURES
WHITE MESA GAS STACK EMISSIONS
1.0 INTRODUCTION
White Mesa, or it's contracted service providers, uses scientifically approved
reference methods to determine gas stack emissions release concentration for
radionuclide particulates. These methods conform to principles that apply to
obtaining valid samples of airborne radioactive materials, using prescribed
acceptable methods and materials for gas and particulate sampling. See American
Standard Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities
ANSI N13.1-1969. These sampling methods are also consistent with guidance
contained in the U.S. Nuclear Regulatory Commission's Regulatory Guide 4.14,
"Radiological Effluent and Environmental Monitoring at Uranium Mills."
2.0 SAMPLING METHODOLOGIES
The sampling methods for airborne radionuclide particulates, from the yellowcake
dryer and other mill effluent control stacks, are identical to methods published in
the EPA's manual, Gas Stream Sampling Reference Methods for New Source
Performance Standards; they are found in the EPA Manual in Appendix No. 5,
"Determination of Particulate Emissions from Stationary Sources" ("EPA Method
#5") and Appendix No. 17, "Determination of Particulate Emissions from
Stationary Sources (In-Stack Filtration Method)" ("EPA Method #17). Copies of
EPA Method #5 and #17 are attached to this SOP. Sampling is performed as per
the methods, to ensure that the sampling and results are: (1) isokinetic; (2)
representative; and (3) adequate for determination of the release rates and
concentrations of U-Nat, Th-230, Ra-226 and Pb-210.
2.1 Sampling Equipment
Sampling equipment used to collect airborne radionuclide particulates from point
source emission stacks at the Mill consists of equipment manufactured by
Research Appliance Company (RAC), (or other equivalent apparatuses), as
follows:
1. RAC Model 201009 Model 2414 stack sampler.
2. Two each, RAC Model 201044 modular sample cases. One heater box and
one glassware box.
3. One each, RAC Model 201019 umbilical cord.
N:\WMM\SOPs and ProceduresXEPM - November 2014 Revision\Section 1.4 Stack MonitoringVAppendix E-Section
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White Mesa Mill - Standard Operating Procedures
Book#l 1: Environmental Protection Manual, Section 1 4
Date: 1 l/14Revision: EFR-4
Page 2 of 6
4. Three each, RAC Model 201013 - 100mm diameter filter holders.
5. One each, RAC Model 201005 standard pilot tube, three feet length,
stainless steel/S-type probe.
6. Barometer.
7. Psychrometer.
8. Satorius Model 2432 balance or equivalent.
9. Triple beam balance.
Equipment instruction and operating manual(s) provided by the manufacturer(s)
are retained at the Mill and used for specific guidance and reference.
2.2 Sample Collection
Gas stack samples are collected from emission control systems used in Recovery
Operations at the Mill. These samples are collected from process stacks when the
emission control systems are operating. They are sampled for radionuclide
particulate concentrations at a frequency in accordance with Table 5-1. Sample
collection methods are described in detail in EPA Method #5 and EPA Method
#17, Determination of Particulate Matter Emissions From Stationary Sources. It
is necessary to read and understand all procedures described in the methods and in
the equipment manual. The operation of the equipment requires "hands-on"
instruction from the Environment Departmental Staff from individuals who are
experienced in using sample collection equipment and applying sample collection
methods. The following steps are described for stack sample collection.
1. Check equipment listed in Section 2.1 of this SOP. Consult the
manufacturers equipment operations manual for details.
2. Assemble equipment as described in the operations manual for sample
collection EPA Method #17.
3. Follow the calibration procedure listed in the manual. If the
calibration measurements are not obtained, consult the trouble
shooting section of the manual for corrective instruction. Once the
collection apparatus is calibrated, proceed to the next step.
4. Weigh a new glass fiber filter, record the weight, and place in the
filter holder assembly.
5. Check the sample collection system for leaks.
6. Cap ends of sample probes to prevent contamination and transport
sample unit to the sample location.
7. Uncap sample end and insert 3/8-diameter sample probe into the stack
in the midsection of the exhaust stream.
8. Turn sample apparatus on and observe unit operation to insure a
sample is being collected and the apparatus is functioning properly.
9. Collect the stack sample for at least one hour during periods of routine
process operation. Note the collection time.
N:\WMM\SOPs and ProceduresVEPM - November 2014 Revision\Section 1.4 Stack MonitoringVAppendix E-Section
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 1.4
Date: 1 l/14Revision: EFR-4
Page 3 of 6
10. Record the information described in the manufacture's operations
manual. This information is also described in the EPA Methods #5
and #17 for point source particulate emissions.
11. After sample collection is complete, turn off unit. Obtain sample
filter from filter housing and place in a new plastic petri dish. Send to
outside laboratory for radionuclide analysis in accordance with Table
5-1.
2.3 Sample Handling and Shipping
1. During preparation and assembly on the sampling train, keep all
openings where contamination can occur covered until just prior to
assembly or until sampling is about to begin.
2. Using a tweezer or clean disposable surgical gloves, place a labeled
(identified) and weighed filter in the filter holder. Be sure that the
filter is properly centered and the gasket properly placed so as to
prevent the sample gas stream from circumventing the filter. Check
the filter for tears after assembly is completed.
3. Before moving the sampling train to the cleanup site, remove the
probe from the sample train, wipe off the silicone grease, and cap the
open outlet of the probe. Be careful not to lose any condensate that
might be present. Wipe off the silicone grease from the filter inlet
where the probe was fastened, and cap it. Remove the umbilical cord
from the last impinger, and cap the impinger. If a flexible line is used
between the first impinger or condenser and the filter holder,
disconnect the line at the filter holder, and let any condensed water or
liquid drain into the impingers or condenser. After wiping off the
silicone grease, cap off the filter holder outlet and impinger inlet.
Either ground-glass stoppers, plastic caps, or serum caps may be used
to close these openings.
4. Transfer the probe and filter-impinger assembly to the cleanup area.
This area should be clean and protected from the wind so that the
chances of contaminating or losing the sample will be minimized.
5. Save a portion of the acetone used for cleanup as a blank. Take 200
ml of this acetone directly from the wash bottle being used, and place
it in a glass sample container labeled "acetone blank."
6. Carefully remove the filter from the filter holder, and place it in its
identified petri dish container. Use a pair of tweezers and/or clean
disposable surgical gloves to handle the filter. If it is necessary to fold
the filter, do so such that the PM cake is inside the fold. Using a dry
Nylon bristle brush and/or a sharp-edged blade, carefully transfer to
the petri dish and PM and/or filter fibers that adhere to the filter
holder gasket. Seal the container.
7. Send to the laboratory for radionuclide analysis.
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Book #11: Environmental Protection Manual, Section 1.4
Date: 1 l/14Revision: EFR-4
Page 4 of 6
3.0 RECORD KEEPING
Records of gas stack effluent sampling events and results of analysis are retained
at the Mill. The following information is recorded:
1. Stack and Run ID
2. Date and Sampler
3. Sampled Air Volume at standard conditions
4. Sampled Water Volume at standard conditions
5. Moisture Content (volume basis)
6. Stack Gas Molecular Weight (wet basis)
7. Stack Gas Velocity
8. Stack Gas Volumetric Flow Rate (dry basis, at standard conditions)
9. Particulate Concentration
10. Percent Isokinetics
11. Emission Rates for Particulates U-Nat, Th-230, Ra-226, and Pb-210.
The data are used to calculate emission rates in pounds and pico curies per hour
for radionuclide particulate concentrations.
Stack sampling must be performed during any quarter or semi-annual period that
the stacks operate in accordance with the schedule in Table 5-1. During non-
operational periods, stack sampling is not performed.
4.1 Yellowcake Stacks
The exhaust stack for the drying and packaging equipment associated with the
yellowcake calciner is sampled on a quarterly basis during operations. The
sample ports are located on the roof of the main Mill building.
4.2 Feed Stacks
The grizzly feed stack is located on the north end of the grizzly structure. This
stack is accessible from a stack platform and is sampled quarterly if this system is
operating.
4.3 Vanadium Stacks
The exhaust stack for the drying and packaging equipment associated with the
vanadium circuit is sampled on a quarterly basis during operations. The sample
ports are located on the roof of the vanadium annex portion of the building.
N:\WMM\SOPs and ProceduresXEPM - November 2014 RevisionASection 1 4 Stack MonitoringXAppendix E-Section
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4.0 MONITORING LOCATION AND FREQUENCY
White Mesa Mill - Standard Operating Procedures
Book#l 1: Environmental Protection Manual, Section 1.4
Date: 1 l/14Revision: EFR-4
Page 5 of 6
5.0 ANALYSIS REQUIREMENTS
All gas stack samples are collected at the Mill according to the calendar year
schedule shown below in Table 5-1. The samples will be sent to an off-site
laboratory for the analysis detailed below.
TABLE 5-1
Sampling Frequency and Analysis
Frequency
Quarterly
Grizzly
Baghouse
Stack
If operating,
U-nat, Th-230,
Ra-226, Pb-
210, Th-232,
Ra-228, and
Th-228.
North and/or
South
Yellowcake
Dryer Stacks
If operating,
U-nat, Th-230,
Ra-226, Pb-
210, Th-232,
Ra-228, and
Th-228.
Yellowcake
Packaging
Baghouse
Stack
If operating, U-
nat, Th-230,
Ra-226, Pb-
210, Th-232,
Ra-228, and
Th-228.
Vanadium
Dryer Stack
If operating, U-
nat, Th-230,
Ra-226, Pb-
210, Th-232,
Ra-228, and
Th-228.
Vanadium
Packaging
Stack
If operating, U-
nat, Th-230,
Ra-226, Pb-
210, Th-232,
Ra-228, and
Th-228.
Note: Grizzly baghouse stack and Vanadium Circuit stack samples shall be representative
and adequate (based on EFRI's operational knowledge and operational conditions at the
time of the sampling event) for the determination of the release rates and concentrations
of radionuclides listed in Table 5-1 above, and do not need to be collected in an isokinetic
state.
6.0 QUALITY ASSURANCE METHODOLOGY
6.1 Equipment Operation
Prior to performing an emission point sampling run, the sampling equipment is
subjected to a dry run test to determine leakages or equipment malfunction.
Calibration of equipment is checked on a periodic basis. Probe tips are protected
by a protective cap while not in use to protect accuracy determinations. During
transport of equipment, all openings are sealed to prevent contamination.
Calculations utilized during runs to maintain isokinetic conditions are reviewed
and dry run tested prior to the actual run. All containers and probes are washed
prior to each usage.
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White Mesa Mill - Standard Operating Procedures
Book#l 1: Environmental Protection Manual, Section 1.4
Date: 1 l/14Revision: EFR-4
Page 6 of 6
Malfunction of sampling equipment, excessive malfunctions of normal operations
being monitored, or percent isokinetic sampling rates greater than ± 10% error,
indicate mandatory voiding of the run or data involved.
6.2 Operations
If samples are collected from the operation of any unit which appears, in the
judgment of the sampler, to be functioning in a manner not consistent with normal
operations, then the sample will be voided and the system will be resampled.
6.3 Chemical Sample Control
Analyses on each period's sample shall include blanks for the filters, impinger
solutions, and the rinse solutions. A field logbook shall be maintained listing data
generated, determinations of volumes measured, and net gain weights of filters to
provide a back up to summary data records. Filters are transmitted within plastic
enclosed petri dishes. Handling of filters is only done using tweezers.
6.4 Calculations
All calculations will be retained at the Mill in both a hard copy and computer
files.
The gas stack effluent concentrations (C) are calculated as follows:
Lab Result uCi (A) / Volume Sampled (V) = Effluent Concentration (C)
where
Volume Sampled (V) = Flow rate (Q) * Time of sample collection in minutes (t)
and
Lab Result uCi (A) = Radioisotopic activity, in pCi on air filter
N:\WMM\SOPs and ProceduresVEPM - November 2014 RevisionVSection 1.4 Stack MonitoringVAppendix E-Section
1.4 Stack Emission 4 - Nov 2014 - clean.doc
White Mesa Mill - Standard Operating Procedures
Book#l 1, Environmental Protection Manual, Section 4.1
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 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 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.
Date: 11/14 Revision: EFR-4
Page 1 of 4
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 11/14 Revision: EFR-4
Page 2 of 4
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 one centimeter. The one 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).
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:
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).
White Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 11/14 Revision: EFR-4
Page 3 of 4
2.2 Sample Labeling
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
2.2 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.
6. Signatures of persons releasing custody.
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 fdes at the Mill. The original COC form remains with the samples until disposal
of the samples.
While Mesa Mill - Standard Operating Procedures
Book #11, Environmental Protection Manual, Section 4.1
Date: 11/14 Revision: EFR-4
Page 4 of 4
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 soil sample data are retained in the files 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 will be documented, signed, and
dated by the analyst.
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. Ifthe 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.
Chain of Custody and Analytical Request Record Page of.
PLEASE PRINT, provide as much information as possible. Refer to corresponding notes on reverse side.
I Project Name, PWS #. Permit #, Etc Company Name:
Report Mail Address: Contact Name, Phone, Fax, E-mail: Sampler Name tf other than Contact:
Invoice Address: Invoice Contact & Phone #: Purchase Order #: ELI Quote #:
Report Required For POTW/WWTP • DW •
Other
Special Report Formats - ELI must be notified prior to
sample submittal for the following:
NELAC • A2LAQ Level IV •
Other
EDD/EDT • Format
SAMPLE IDENTIFICATION
(Name, Location, Interval, etc.)
Collection
Oate
Collection
Time
12 o § o a s
= > S
S cn >i «
O < o >,
° e-2 8
Jj; £• o n
E ?3
3 £ n,
MATRIX
F EQU ES TED Notify ELI prior to RUSH
sample submittal for additional
charges and scheduling
| Shipped by:
Cooler ID(s)
Comments:
| Receipt Temp
° C
Custody Seal Y
Intact Y
Signature Y
Match
Lab ID
CO
6
7
8
9 G-
OQ
Custody
Record
MUST be
Signed
Relinquished by (print) Osto/nme Signature.
Relinquished by (print). Signature
Sample Disposal: Return to client: Lab Disposal:
Racwvod by (pnm) SigfiktufB
Received by (print): Data/Time Signature.
Sample Type:_
LABORATORY USE ONLY
# of fractions
Ir -*rtaln circumstances, samples submitted to Energy Laboratories, Inc. may be -"^contracted to other certified laboratories in order to complete the analysis reqi-
This serves as notice of this possibility. All sub-o ;t data will be clearly notatod on your analytical report.
Visit our web site at www.energylab.com for additkxiar information, downloadable fee schedule, forms, & links.
Med.
^* cc cc
BHV-2
13
1-
BHV-1
2J
3HV-
ft
BHV-7
BHV-5
O-i—4 T37S
T38S BHV-4 BHV-6 Actual location of BHV-3
is 34.500 feet due west
' Energy Fuels Resources (USA) Inc. •
I A A ,r ^
191
1 IN = 6,
3,750 7,500
6.000 FT
11.250 15,000 •• Feet
Legend
Program
• 1,000 Feet
• 2,500 Feet
* Existing Air Monitoring Station
• Tentative Air Monitoring Station
1 'Property Boundary
Road
|_JTownship and Range Coordinate System: NAD
Section 1983 StatePlane Utah
South FIPS 4303 Feet
ENERGY FUELS
Date: By:
Project: WHITE MESA MILL
County: San Juan State: Utah
FIGURE 1
SOIL MONITORING LOCATIONS
Author: mhenington Date: 9/5/2014 Drafted By: mhenington
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 11/14 Revision: EFR-3
Page 1 of 4
VEGETATION MONITORING
PART I VEGETATION MONITORING PLAN
1.0 VEGETATION MONITORING PLAN
Vegetation is sampled in early spring, late spring, and late fall at three locations around the
Mill. These locations are: Northeast Area (near BHV-1), Northwest Area (V2 mile west of
BHV-1) and the Southwest Area (West of BHV-4 and south off Cell 3).
2.0 QUALITY ASSURANCE
Quality assurance for vegetation monitoring is based on the contract laboratory's quality
controls such as duplicates, blanks, standard percent recovery, and spike percent recovery.
The laboratory will also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides
4.14 and 4.15 when analyzing the vegetation samples. The laboratory is coiriiriitted to meet
the LLD values for radionuclides addressed in these guidelines and will perform re-runs on
all samples not meeting these limits.
3.0 ANALYTICAL REQUIREMENTS
Each vegetation sample will be analyzed for Ra-226, U-Nat, Th-232, and Pb-210
radionuclide concentrations. Results will be expressed in units of picocuries per gram (pCi/g)
or micro curies per kilogram (uxi/kg), on a wet basis.
PART II VEGETATION MONITORING STANDARD OPERATING PROCEDURES
1.0 VEGETATION SAMPLING
1.1 Equipment
Equipment used for vegetation sampling is as follows:
1. Scissors
2. Large plastic sample bags
1.2 Vegetation Sampling Procedure
Vegetation samples are collected and removed at the surface with scissors at each sampling
location. The vegetation sample is enclosed in a large plastic bag. Each sample will be
weighed upon return to the office and must weigh at least three kilograms in order for the
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 11/14 Revision: EFR-3
Page 2 of 4
laboratory to meet the required LLD values outlined in U.S. NRC Regulatory Guide 4.14. In
addition, as vegetation samples are collected efforts will be made to minimize the amount of
soil in the samples. The sample bag is then labeled (see Section 2.1).
2.0 SAMPLING QUALITY ASSURANCE
2.1 Sample Labeling
All sample labels must be filled out in waterproof ink and numbered. The date, time,
sampler's initials, and the sample location will be completed at the time the sample is
collected. The following information will be included on the label:
1. Project and facility.
2. Sampler's company affiliation.
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Weight of sample.
7. Requested analytical parameters.
2.2 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 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. #1 T Environmental Protection Manual, Section 4.2
Date: 11/14 Revision: EFR-3
Page 3 of 4
6. Signatures of persons releasing custody.
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 analysis of the
samples. After sample analysis, the COC form will be sent to the Environmental Department along
with the analyses.
2.3 Sample Handling and Shipping
Sample bags will be packaged in large shipping boxes and transported to the contract
laboratory. COC forms will be placed inside a sealed bag and placed inside the shipping
box.
2.4 Record Keeping
All vegetation sampling data will be retained in a file. When analytical data becomes
available, the data is entered into a computer file and retained in the files. All laboratory
analytical data is stored in the vegetation files after the data has been entered into the
computer file.
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and QC Review
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 a copy of and retain all analytical and QC
documentation. The laboratory will provide the Mill with paper copies of the following in
each data package, in accordance with QA objectives for the Surface Soil QA Project Plan:
The data reduction and laboratory review will be documented, signed, and dated by the
1.
2.
3.
4.
5.
6.
COC forms
Cover sheets with comments
Narrative
Samples analyzed
Reporting limits and LLD values for analytes
Analytical results of QC samples
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, Section 4.2
Date: 11/14 Revision: EFR-3
Page 4 of 4
contract laboratory analyst.
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.
ATTACHMENT B
Protection of
Environment
40
PARTS 50 TO 51
Revised as of July 1,1998
CONTAINING
A CODIFICATION OF DOCUMENTS
OF GENERAL APPLICABILITY
AND FUTURE EFFECT
AS OF JULY 1, 1998
With Ancillaries
Published by
the Office of the Federal Register
National Archives and Records
Administration
as a Special Edition of
the Federal Register
Pt. 50, App. B 40 CFR Ch. I (7-1-98 Edition)
flow rate interval (1.1 to 1.7 m3/min [39-60 ft3/
min]), are required.
9.2.6 Measure and record the certification
data OTX a form similar to the one illustrated
in Figure 4 according to the following steps.
9.2.7 Observe the barometric pressure and
record as Pi (item 8 in Figure 4).
9.2.8 Read the ambient temperature in the
vicinity of the standard, volume meter and
record it as Ti (item 9 in Figure 4).
9.2.9 Start the blower motor, adjust the
flow, and allow the system to run for at least
1 min for a constant motor speed to be at-
tained.
9.2.10 Observe the standard volume meter
reading and simultaneously start a stop-
watch. Record the initial meter reading (V,)
in column 1 of Figure 4.
9.2.11 Maintain this constant flow rate
until at least 3 m3 of air have passed through
the standard volume meter. Record the
standard volume meter inlet pressure ma-
nometer reading as AP (column 5 in Figure
4), and the orifice manometer reading as AH
(column 7 in Figure 4). Be sure to indicate
the correct units of measurement.
9.2.12 After at least 3 m3 of air have passed
through the system, observe the standard
volume meter reading while simultaneously
stopping the stopwatch. Record the final
meter reading (Vf) in column 2 and the
elapsed time (t) in column 3 of Figure 4.
9.2.13 Calculate the volume measured by
the standard volume meter at meter condi-
tions of temperature and pressures as
Vm=Vf-Vi. Record in column 4 of Figure 4.
9.2.14 Correct this volume to standard vol-
ume (std m3) as follows:
V . =V
std m
P, - AP T sid
P T std M
where:
v«d = standard volume, std m3;
Vm - actual volume measured by the stand-
ard volume meter;
Pj = barometric pressure during calibration,
mm Hg or kPa;
AP = differential pressure at inlet to volume
meter, mm Hg or kPa;
P.ui = 760 mm Hg or 101 kPa;
TIld = 298 K;
Ti = ambient temperature during calibra-
tion, K.
Calculate the standard flow rate (std m3/min)
as follows:
Qstd = _Vs.d
t
where:
QUui = standard volumetric flow rate, std m3/
min
t = elapsed time, minutes.
Record Qstd to the nearest 0.01 std m3/min
in column 6 of Figure 4.
9.2.15 Repeat steps 9.2.9 through 9.2.14 for
at least four additional constant flow rates,
evenly spaced over the approximate range of
1.0 to 1.8 std m-Vmin (35-64 ft3/min).
9.2.16 For each flow, compute
•AAH (Pi/P8td)(298/T1)
(column 7a of Figure 4) and plot these value
against Q.W as shown in Figure 3a. Be sure to
use consistent units (mm Hg or kPa) for bar-
ometric pressure. Draw the orifice transfer
standard certification curve or calculate the
linear least squares slope (m) and intercept
(b) of the certification curve:
•AAH (P1/P8td)(298/T1)
=mQ«d+b. See Figures 3 and 4. A certification
ffC^fe.iibo^^be„rea^ble.to, 0.02 std^m^n^ld.,
9.2.17 Recalibrate the transfer standard an-
nually or as required by applicable quality
_control procedujes.jf(See Reference 2.)jL
'"^^SiBfaiiondTso^t^TtSw tnSieafor'.
NOTE: For samplers equipped with a flow
controlling device, the flow controller must
be disabled to allow flow changes during
calibration of the sampler's flow indicator,
or the alternate calibration of the flow con-
troller given in 9.4 may be used. For sam-
plers using an orifice-type flow indicator
downstream of the motor, do not vary the
flow rate by adjusting the voltage or power
supplied to the sampler.
9.3.1 A form similar to the one illustrated
in Figure 5 should be used to record the cali-
bration data.
9.3.2 Connect the transfer standard to the
inlet of the sampler. Connect the orifice ma-
nometer to the orifice pressure tap, as illus-
trated in Figure 3b. Make sure there are no
leaks between the orifice unit and the sam-
pler.
9.3.3 Operate the sampler for at. least 5
minutes to establish thermal equilibrium
prior to the calibration.
9.3.4 Measure and record the ambient tem-
perature, T2. and the barometric pressure, P2.
during calibration.
9.3.5 Adjust the variable resistance or, if
applicable, insert the appropriate resistance
plate (or no plate) to achieve the desired
flow rate.
9.3.6 Let the sampler run for. at least 2 min
to re-establish the run-temperature condi-
tions. Read and record the pressure drop
across the orifice (AH) and the sampler flow
rate indication (I) in the appropriate col-
umns of Figure 5.
9.3.7 Calculate •AAH(P2rJ?«d)(298/T2) and de-
termine the flow rate at standard conditions
(Q»td) either graphically from the certifi-
cation curve or by calculating Q»t<i from the
least square slope and intercept of the trans-
fer standard's transposed certification curve:
Q8td=l/m •AH(P3/PBtd)(298/T2)-b. Reeord the
value of Q„t<i on Figure 5.
on
ITS? = concentration at standard conditions,
isg/std m3;
= average barometric pressure during
sampling period, mm Hg;
= 760 mn Hg (or 101 kPa);
Tj = average ambient temperature during
sampling period, K.
11.0 References.
I. Quality Assurance Handbook for Air Pol-
;ction Measurement Systems, Volume 1,
Principles. EPA-600/9-76-005, U.S. Environ-
mental Protection Agency, Research Tri-
ple Park,_NC 27711,1976. _
2 Quality Assurance Handbook for Air Pol-
tetion Measurement Systems, Volume H,
Ambient Air Specific Methods. EPA-600/4-77-
|2?a, U.S. Environmental Protection Agency,
Research Triangle Park. NC 27711, 1977.
3. Wedding", JT B./AfR. "McFariand, and j"'
E. Cernak. Large Particle Collection Charac-
i^ristics of Ambient Aerosol Samplers. Envi-
ron. Sci. Technol. iJ:387-390, 1977.
4. McKee, H. C, et al. Collaborative Test-
ing of Methods to Measure Air Pollutants, I.
The High-Volume Method for Suspended Par-
ticulate Matter. J. Air Poll. Cont. Assoc., 22
<342), 1972
5. Clement, R. E., and F. W. Karasek. Sam-
ple Composition Changes in Sampling and
Analysis of Organic Compounds in Aerosols.
The Intern. J. Environ. Anal. Chem., 7:109,
1S79.
6. Lee, R. E., Jr., and J. Wagman. A Sam-
pling Anomaly in the Determination of At-
mospheric Sulfuric Concentration. Am. Ind.
Hygiene Assoc. J., 27:266, 1966.
7 Appel, B. R., et al. Interference Effects
ir. Sampling Particulate Nitrate in Ambient
Air. Atmospheric Environment, 13:319, 1979.
8. Tierney, G. P., and W. D. Conner. Hygro-
scopic Effects on Weight Determinations of
Particulates Collected on Glass-Fiber Fil-
ters. Am. Ind. Hygiene Assoc. J., 28:363. 1967,
9. Chahal, H. S., and D. J. Romano.- High-
Volume Sampling Effect of WIndborne Par-
ticulate Matter Deposited During Idle Peri-
ods. J. Air Poll. Cont. Assoc , Vol. 26 (885),
1976.
10. Patterson, R. K. Aerosol Contamination
from High-Volume Sampler Exhaust. J. Air
Poll. Cont. ASBOC, Vol. 30 (169), 1980.
11. EPA Test Procedures for Determining
pH and Integrity of High-Volume Air Filters.
QAD/M-80.01. Available from the Methods
Standardization Branch, Quality Assurance
Division, Environmental Monitoring Sys-
tems Laboratory (MD-77), U.S. Environ-
mental Protection Agency, Research Tri-
angle Park, NC 27711. 1980.
12. Smith, F., P. S. Wohlschlegel, R. S. C.
Rogers, and D. J. Mulligan. Investigation of
Flow Rate Calibration Procedures Associ-
ated with the High-Volume Method for De-
termination of Suspended Particulates.
EPA-600/4-78-047, U.S. Environmental Pro-
tection Agency, Research Triangle Park, NC,
June 1978.
?5* r.
Figure 1. High-volume ampler in thalttr.
33
EPA-600/4-77-027a
May 1977
QUALITY ASSURANCE HANDBOOK
FOR
AIR POLLUTION MEASUREMENT SYSTEMS
Volume II — Ambient Air Specific Methods
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Environmental Monitoring and Support Laboratory
Research Triangle Park, North Carolina 27711
/
Section No. 2.2.2
Revision No. 0
Date May i, 1977
Page 4 of 25
6. Allow the system to operate for the 2 4-hour test
period and determine the elapsed time from the elapsed time
meter.
a. If the elapsed time is 24 hours + 15
minutes, the timer is acceptable for
field use.
b. If the elapsed time is not 24 hours
+ 15 minutes, adjust the tripper
switches and repeat the test.
Indicator lamp
ON-OFF Timer
(± 15 min/24 hours)
Elapsed time meter
(+ 2 min/24 hours)
Figure 2.2 Diagram of a timer calibration system
2.5 Orifice Calibration Unit
„The.orifice calibration unit should be calibrated _against_a,_.. ,
secondary standard, for example a Rootsmeter, upon receipt and at
one-year intervals thereafter. The manufacturer's average calibration
curve can be used unless the calibration deviates from it by more
than ± 4 percent at any one point along the curve. When deviations
from the manufacturer's curve are larger than + 4 percent and
there are no visible signs of damage to the orifice, the cali-
bration should be repeated by another operator. If the large
deviations persist (after the secondary standard has been checked