DRC-2013-004486 - 0901a06880416f1f

10/10/13 State of Utah Mail - Public Questions on Energy Fuels Resources Dawn Mining Amendment Request: October 9, 2013, Salt Lake City, Utah, Hearing.
rad public <[e-mail]>
DRC-2013-004486
Public Questions on Energy Fuels Resources Dawn Mining Amendment
Request: October 9, 2013, Salt Lake City, Utah, Hearing.
1 message
[e-mail] <[e-mail]> Mon, Sep 30, 2013 at 3:09 PM
To: [e-mail]
Cc: Rusty Lundberg <[e-mail]>, John Weisheit <[e-mail]>
Dear Mr. Lundberg,
Attached please find cover letter, Questions for the October 9, 2013, hearing in Salt Lake
regarding
the amendment to the White Mesa Mill license, and one exhibit.
Please acknowledge the receipt of these documents.
Sincerely,
Sarah M. Fields
Program Director
Uranium Watch
PO Box 344
Moab, Utah 84532
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Uranium Watch
76 South Main Street, # 7 | P.O. Box 344
Moab, Utah 84532
435-259-9450
via electronic mail
September 30, 2013
Rusty Lundberg
Director
Division of Radiation Control
P.O. Box 144850
Salt Lake City, Utah 84114-4850
[e-mail]
RE: Public Questions on Energy Fuels Resources Dawn Mining Amendment Request: October 9,
2013, Salt Lake City, Utah, Hearing.
Dear Mr. Lundberg:
Attached please fine Questions for October 9, 2013 Hearing, Amendment to lle.(2) Byproduct
License UT 1900479, Energy Fuels Resources (USA) Inc. White Mesa Mill, San Juan County,
Utah. These comments are submitted on behalf of Uranium Watch, Living Rivers, and the Glen
Canyon Group of the Sierra Club. The Questions include one exhibit.
Sincerely,
Sarah Fields
Program Director
Uranium Watch
John Weisheit
Conservation Director
Living Rivers
Nuclear Issues Chair
Glen Canyon Group
Sierra Club
P.O. Box 622
Moab, Utah 84532
and P.O. Box 466
Moab, Utah 84532
Enclosures: As stated
URANIUM WATCH
QUESTIONS FOR OCTOBER 9, 2013, HEARING
Amendment to lle.(2) Byproduct License UT1900479
Energy Fuels Resources (USA) Inc.
White Mesa Mill
San Juan County, Utah
The following questions are submitted on behalf of Uranium Watch, Living
Rivers, and the Glen Canyon Group of the Sierra Club. These questions are submitted in
anticipation of a hearing before a Presiding Officer in Salt Lake City, Utah, on October 9,
2013. The hearing is being conducted to meet the requirements of 42 U.S.C. § 2021(o)
(3)(A)(i)(ii), with respect to the Energy Fuels Resources Inc. (EFRI) request for an
amendment to the White Mesa Uranium Mill Radioactive Materials License UT 1900479.
EFRI has requested authorization to process waste from another mineral processing
operation. The waste is sludge from a water treatment facility at the Dawn Mining
Company (DMC) Midnite Mine, Wellpinit, Washington. The application submitted to the
Utah Division of Radiation Control (DRC) was dated April 27, 2011, and supplemented
by documents dated December 5, 2012, and June 14 and August 7, 2013 (Application).
APPLICATION
1. The April 2011 Application states that the Midnite Mine materials are going to be
processed as "ore."
1.1. Are these materials "ore," as contemplated by the Atomic Energy Act of
1946, as subsequently amended by the AEA of 1954 and the Uranium Mill Tailings
Radiation Control Act of 1978? If so, what is the basis for the DRC's determination?
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1.2. Is EFRI required to submit a request for a license amendment to process ore
from a new source of uranium ore from a mine owned by EFRI or any other mine owner?
1.3. Why has EFRI submitted an Application for a license amendment to process
the Uranium Material from the Midnite Uranium Mine?
REGULATORY PROGRAMS
2. The Application for a license amendment for specific authorization to process the
waste from the Midnite Mine references the NRC Regulatory Issues Summary 2000-23:
"Interim Guidance on the Use of Uranium Feed Material Other Than Natural
Ores" (Interim Guidance), a Nuclear Regulatory Commission (NRC) guidance document
that has been adopted by the DRC.
2.1. Why must the DRC rely on the NRC Interim Guidance for the approval of
the proposed license amendment?
2.2. Why can't the DRC rely on the existing NRC regulations and Atomic
Energy Act statutes for the authorization of the processing of the Uranium Material?
2.3. What is the history of the NRC Interim Guidance? Did the NRC publish the
Interim Guidance in the Federal Register as a proposed policy guidance for public
comment? Did the NRC conduct an environmental analysis of the impacts related to the
changes to uranium mill operations that would result from implementation of the Interim
Guidance? Did the NRC publish a Federal Register Notice of the adoption of the 2000
Interim Guidance? Was the NRC Policy Guidance developed in accordance with the
requirements of the federal Administrative Procedure Act and the National Environmental
Policy Act?
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2.4. Why is the Interim Guidance "interim"? What other actions did the NRC
contemplate when they adopted this "interim" document?
2.5. Does the Interim Guidance have the force and effect of law, that is, statute or
regulation?
2.6. When did the Utah Radiation Control Board adopt the Interim Guidance?
Did the DRC notice the proposed adoption of the Interim Guidance and provide an
opportunity for the public to comment on its adoption? Was the adoption of the Interim
Guidance by the DRC a rulemaking under Utah rulemaking procedures?
2.7. The Interim Guidance uses the term "alternate feed material." Is this term a
euphemism, or is this term defined in the Atomic Energy Act, NRC, or Environmental
Protection Agency (EPA) regulation?
3. The Atomic Energy Act of 1954, as amended by the 1978 Uranium Mill Tailings
Radiation Control Act (UMTRCA), defines what is known as "lle.(2) byproduct
material" (42 U.S.C. 2014e.(2)): "(e) The term 'byproduct material' means—(2) the
tailings or wastes produced by the extraction or concentration of uranium or thorium
from any ore processed primarily for its source material content."
NRC regulation (10 C.F.R. 40.4) defines lie.(2) byproduct material: "Byproduct
Material means the tailings or wastes produced by the extraction or concentration of
uranium or thorium from any ore processed primarily for its source material content,
including discrete surface wastes resulting from uranium solution extraction processes.
Underground ore bodies depleted by such solution extraction operations do not constitute
'byproduct material' within this definition."
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White Mesa Mill Alternate Feed License Amendment (UT 1900479)
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3.1. Is the Interim Guidance use of the term "alternate feed material." a
clarification of the term "ore," in the definition of "byproduct material," or is it an
amendment to the definition of that term? What is the basis for this DRC determination?
3.2. What is the dictionary definition of the term "ore"? What is the mining
industry's use of the term "ore." How is the word "ore" used in other mining
terminology, such as ore-dressing or ore-pile?
3.3. Why is there no definition of the term "ore" in the Atomic Energy Act or
NRC or EPA regulation?
4. The Atomic Energy Act of 1954, as amended by the 1978 Uranium Mill Tailings
Radiation Control Act (UMTRCA), defines "source material" (42 U.S.C. 2014(z)): "The
term "source material" means (1) uranium, thorium, or any other material which is
determined by the Commission pursuant to the provisions of section 2091 of this title to
be source material; or (2) ores containing one or more of the foregoing materials, in such
concentration as the Commission may by regulation determine from time to time."
NRC regulation (10 C.F.R. 40.4) defines "source material": "Source Material
means: (1) Uranium or thorium, or any combination thereof, in any physical or chemical
form or (2) ores which contain by weight one-twentieth of one percent (0.05%) or more
of: (i) Uranium, (ii) thorium or (iii) any combination thereof. Source material does not
include special nuclear material." This definition includes two (2) definitions of source
material: the first is the uranium or thorium in any physical form, the second is "ores"
containing uranium or thorium. Under NRC regulation, any material containing more
than .05% source material is subject to regulation under the Atomic Energy Act and NRC
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implementing regulations. However, the NRC does not regulate ores containing uranium
or thorium, whether of not the ores contain .05% or more uranium and/or thorium by
weight.
The Application and the DRC documents are confusing with respect the definition
of the Uranium Material. The DRC Statement of Basis states: "The Washington
Department of Health (WDOH) issued a radioactive materials license (RML) in 1992 for
the uranium material generated from the Midnite Mine Water Treatment Plant (WTP),
which was constructed in 1988 and began treating water in 1992." This means that the
Uranium Material is waste from the processing of mine water from the Midnite Mine,
and the treatment facility and the waste were licensed by the State of Washington under a
source material license. Therefore, the uranium and thorium constituents of the Uranium
Material would fall under the first definition of "source material." The DRC Safety
Evaluation Report1 (SER, page 2) opines that the feed material, based on a policy
guidance, qualifies as "ore." Therefore, since the material is more than .05% uranium,
the DRC has transformed the Uranium Material from material that meets the first
definition of "source material" (uranium and/or thorium in any form) into material that
meets the second definition of "source material" (ore containing .05% or more uranium
and/or thorium, by weight).
4.1. Based on the Atomic Energy Act and NRC definitions of "source material,"
how is the Uranium Material transformed from a material that meets the first definition of
1 Safety Evaluation Report for the Amendment Request to Process an Alternate Feed Material at
White Mesa Mill from Dawn Mining Corporation Midnite Mine, Washington State; Energy Fuels
Resources (USA) Inc.; White Mesa Mill, San Juan County, Utah; August 9, 2013.
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source material (which is regulated under the Atomic Energy Act and NRC regulation)
into a material that meets the second definition (which is not regulated under the Atomic
Energy Act and NRC regulation)? How does this definitional transformation take place?
When, exactly, does this definitional transformation take place? When, exactly, does the
Uranium Material become ore?
4.2. What NRC Part 40 regulation (that have been incorporated into Utah rules by
reference) is the DRC relying on to change the regulatory definition of the Uranium
Material?
4.3. Where is the DRC authorized, by law, to change the regulatory definition of a
material under the provisions of the Atomic Energy Act and the implementing NRC and
EPA regulations?
5. The NRC regulations applicable to the White Mesa Mill, which the DRC administers
and enforces, are found in 10 C.F.R. Part 40, particularly in Appendix A.
5.1. Which of the Part 40 regulations applicable to 1 le.(2) byproduct material
were promulgated contemplating the processing of wastes from other mineral processing
operations at licensed conventional uranium mills?
5.2. Which generic or programatic Environmental Impacts Statements (EIS)
associated with the promulgation of NRC regulations applicable to the lle.(2) byproduct
material and uranium mills characterized and analyzed the impacts from processing
uranium-bearing wastes from other mineral processing operations and disposing of the
wastes in tailings impoundments at licensed uranium mills.
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5.3. How, exactly, do the NRC regulations for licensed uranium mills apply to the
processing of various approved alternate feeds at the White Mesa Mill?
5.4. Which alternate feeds that were approved by the NRC or the State of Utah
for processing at the White Mesa Mill included an environmental analysis under the
National Environmental Policy Act or DRC regulation and which did not? Please
reference the date and title of any environmental analyses.
6. The EPA has promulgated standards for lle.(2) byproduct material operations and
facilities, as required by UMTRCA at Subpart D of 40 C.F.R. Part 192. Part 192 provides
"Standards for Management of Uranium Byproduct Materials Pursuant to Section 84 of
the Atomic Energy Act of 1954, as Amended." These standards apply to the
"management uranium byproduct materials under section 84 of the Atomic Energy Act of
1954 (henceforth designated 'the Act'), as amended, during and following processing of
uranium ores, and to restoration of disposal sites following any use of such sites under
section 83(b)(1)(B) of the Act." Section 192.31(b) contains a definition of uranium
byproduct material: "Uranium byproduct material means the tailings or wastes produced
by the extraction or concentration of uranium from any ore processed primarily for its
source material content. Ore bodies depleted by uranium solution extraction operations
and which remain underground do not constitute 'byproduct material' for the purpose of
this subpart." This is the same definition of "byproduct material" as found in NRC 10
C.F.R. Part 40 regulations.
6.1. Has the EPA adopted the NRC's Interim Guidance with respect the
administration and enforcement of Part 192? If so, when and how?
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6.2. Were the EPA 40 C.F.R. Part 192 Subpart D Standards—for processing
operations and prior to the end of the closure period—promulgated in anticipation of the
processing of feed material other than natural ore (that is, "alternate feed material") at a
licensed uranium mill? If so, please cite the specific Federal Register Notice by page,
volume, and date.
6.3. Were the EPA 40 C.F.R. Part 192 Subpart D Standards—for application after
the closure period—promulgated in anticipation of the processing of feed material other
than natural ore (that is, "alternate feed material") at a licensed uranium mill? If so,
please cite the specific Federal Register Notice by page, volume, and date.
6.4. Did the NEPA analysis accompanying the EPA promulgation of Part 192
include an analysis of the the environmental impacts from the processing of what the
NRC refers to as "alternate feed"? If so, please refer to the page and section of the
NEPA document that accompanied the promulgation of Part 192, and any accompanying
background documents.
6.5. How, exactly, would the provisions of 40 C.F.R. Part 192 standards apply to
the processing of feed materials other than natural ores at licensed uranium mills? What
is the basis for that determination?
7. The EPA has promulgated National Emission Standards for Radon Emissions from
Operating Mill Tailings at 40 C.F.R. Part 61 Subpart W. The Subpart W Standards "apply
owners or operators of facilities licensed to manage uranium byproduct materials during
and following the processing of uranium ores, commonly referred to as uranium mills and
their associated tailings." Subpart W does not apply to the disposal of tailings. Section
UW Questions for October 9 Hearing
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61.251(g) defines uranium byproduct material: "Uranium byproduct material or tailings
means the waste produced by the extraction or concentration of uranium from any ore
processed primarily for its source material content. Ore bodies depleted by uranium
solution extraction and which remain underground do not constitute byproduct material
for the purposes of this subpart."
7.1. Has the EPA adopted the NRC's Interim Guidance with respect the
administration and enforcement of Part 61 Subpart W? If so, when and how?
7.2. Were the EPA 40 C.F.R. Part 61 Subpart W Standards for radon emissions
from operating uranium tailings promulgated in anticipation of the processing of feed
material other than natural ore (that is, "alternate feed material") at a licensed uranium
mill? If so, please cite the specific Federal Register Notice by page, volume, and date.
7.3. Did the NEPA analysis accompanying the EPA promulgation of Part 61
Subpart W include an analysis of the the environmental impacts from the processing of
what the NRC refers to as "alternate feed"? If so, please refer to the page and section of
the NEPA document that accompanied the promulgation of Part 61 Subpart W, and any
accompanying background documents.
7.4. How, exactly, would the provisions of 40 C.F.R. Part 61 Subpart W apply to
the radon emissions from uranium mills associated with the processing of feed materials
other than natural ores? What is the basis for that determination?
8. The EP A has promulgated regulations for Ore Mining and Dressing Point Source
Category for Uranium, Radium and Vanadium Ores Subcategory at 40 C.F.R. Part 440
Subpart C. Section 440.30 states with respect applicability: "The provisions of this
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subpart C are applicable to discharges from (a) mines either open-pit or underground,
from which uranium, radium and vanadium ores are produced; and (b) mills using the
acid leach, alkaline leach, or combined acid and alkaline leach process for the extraction
of uranium, radium and vanadium. Only vanadium byproduct production from uranium
ores is covered under this subpart."
8.1. Has the EPA adopted the NRC's Interim Guidance with respect the
administration and enforcement of Part 440 Subpart C? If so, when and how?
8.2. Were the EPA 40 C.F.R. Part 440 Subpart C standards for uranium, radium
and vanadium ores subcategory promulgated in anticipation of "uranium ores" being
defined as any material (feed material other than natural ores) that is processed at a
licensed uranium mill for its uranium content ("alternate feed material")? If so, please
cite the specific Federal Register Notice by page, volume, and date.
8.3. Did the NEPA analysis accompanying the EPA promulgation of Part 440
Subpart C include an analysis of the the environmental impacts from the discharge of
pollutants associated with the processing of feed materials other than natural ores? If so,
please refer to the page and section of the NEPA document that accompanied the
promulgation of Part 440 Subpart C, and any accompanying background documents.
8.4 How, exactly, would the provisions of 40 C.F.R. Part 440 Subpart C apply to
the discharges of pollutants from uranium mills associated with the processing of feed
materials other than natural ores? What is the basis for this determination?
ALTERNATE FEED PROCESSING AND DISPOSAL
9. Questions regarding the receipt, storage, processing, and disposal of alternate feed?
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9.1. How does the DRC monitor the shipments of "alternate feed" that are
received at the White Mesa Mill?
9.2. How does the DRC determine the amount of alternate feed that is being or
has been received at the White Mesa Mill from any one source?
9.3. How does the DRC determine whether the amount of material received and
processed at the Mill from a specific alternate feed source is less than or equal to the
amount of material that was approved for receipt and processing at the Mill from that
source.
9.4. How does the DRC determine that the material received at the Mill has the
same physical and chemical characteristics as the material that was approved by the NRC
or the DRC for receipt and processing? What type of verification is required? What kind
of sampling of the material is required?
9.5. What information is received by the DRC regarding 1) the amount of waste
from the processing of alternate feed from each source of material and 2) the physical and
chemical characteristics of the waste.
9.6. Does the DRC have data on the cumulative amount of radiological and
chemical constituents in the tailings as a result of the disposal of wastes from the
processing of alternate feed? If so, where is this information available?
9.7. Does the licensee keep track of where the tailings from the processing of
alternate feed material are disposed of.
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SAFETY EVALUATION REPORT
10. The SER, Section 1.5 (page 6). provides items that will be evaluated in the SER, in
accordance with Utah Code Annotated (UCA) R313-22-38 and R313-24-3. The SER
appears to limit the environmental analysis to the four listed items. The listed items
reflect, in part, the requirements for an environmental analysis for an Agreement State
lle.(2) byproduct material licensing action (42 U.S.C. § 2021(o)(3)(C)). However,
Section 2021(o)(3)(C) states that the environmental analysis shall include those four
items, it does not state that the environmental analysis should be limited to those items.
10.1. Does the DRC believe that the required environmental analysis should be
limited to the four items listed in the SER? If so, why? If not, what other environmental
analyses should be undertaken?
11. The SER at Table 1 (page 8) provides information regarding the Range of
Radionuclide Concentrations in the DMC Uranium Material. The amounts for Uranium
are given in milligrams per kilogram (mg/kg); the amounts for thorium-228, thorium-230,
thorium-232, lead- 210, radium total, and radium-226 are given in pico Curies per gram
(pCi/g).
11.1. Why does Table 1 provide the uranium concentrations in mg/kg and the
other radionuclides in pCi/g?
11.2. It is our understanding that, if the thorium decay chain is in equilibrium, the
amount of Thorium-228 would be about the same as the thorium-232. Why is the
maximum amount of thorium-232 14.27 times higher than the maximum thorium-228,
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where for the minimum levels of thorium-32 and thorium-2, the activity of thorium-228
is .41 times that of thorium-232?
11.3. Table 1 includes lead-210, the product of uranium-238 decay. Why does
Table 1 not include lead-208, the end of the thorium decay chain?
11.4. Table 1 fails to include the radon emissions from the Uranium Material.
Why is that?
11.5. Why does the SER fail to identify the other radium isotopes that are
included in "Total Radium."
11.6. Has the DRC evaluated and compared the radionuclides that will remain in
the Uranium Material and other alternate feeds after processing?
12. Table 3 provides information regarding the Concentrations of Total Uranium,
Radium 226 and Thorium-230 in the Uranium Material vs. Average Acid Leached Ore-
Derived Uranium Mill Tailings in Utah.
12.1. Table 3 only considers radium-226, but does not include the radium
concentrations from the decay of thorium (radium-228 and radium-224). Shouldn't Table
3 also include the radium concentrations form radium-228 and radium-224 and the total
concentrations from all radium isotopes in the comparison of the Uranium Material and
"Typical Utah Uranium Mill Tailings"?
12.2. Table 3 contains a comparison between the Uranium Material Constituents
and "Average Acid Leached Ore-Derived Uranium Mill Tailings in Utah." Why has the
DRC not included a comparison of the thorium-232 and thorium-228 concentrations for
the Uranium Material and the Average Acid Leach Ore in Utah?
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13. Table 5 is a Comparison of Radionuclide Activity Concentrations in Proposed
Uranium Material and Previous Alternate Feeds. Table 5 Summarizes the concentrations
of the Uranium Material as compared with Colorado Plateau Ores and Alternate Feed
Material. Table 5 relies to a great extent on the information in the W. R. Grace
Application. That application was submitted to the NRC in April 2000—over 13 years
ago.
13.1. Has the DRC reviewed the W. R. Grace Application of April 2000 and the
license amendment approval documents? If so, when did the DRC review that
application and approval documents?
13.2. Did the NRC conduct an environmental analysis of the receipt, processing,
and disposal of the W. R. Grace Material?
13.3. Has any of the W. R. Grace material been received at the White Mesa Mill
for processing?
13.4. Has the DRC received any documentation from EFRI or the generator and/
or regulator of the W.R. Grace facility regarding when, or if, the W. R. Grace Material
would ever be shipped to the White Mesa Mill?
13.5. Has the DRC reviewed the applications and approvals for the license
amendments and license conditions associated with the processing of alternate feed? If
so, which applications and approvals has the DRC reviewed and when did these reviews
take place?
13.6. What is the justification for comparing the Uranium Material with materials
that have not, and might not, ever be processed at the White Mesa Mill?
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14. Other Questions regarding the SER.
14.1. The SER (page 12) indicates the thorium-232 specific activity. However,
the total thorium activity (for the thorium decay chain) is usually the sum of the
thorium-232 and thorium-228 activity. Why did the DRC not include the thorium-228
activity?
14.2. What is the amount and activity of alternate feed materials containing
thorium-232 and its decay products from material that have actually been processed at
White Mesa?
14.3. Has the DRC reviewed the White Mesa Mill's Standard Operating
Procedures for High Thorium Content Ore Management? Has the DRC determined
whether the Uranium Material will trigger the use of this SOP? If not, why not?
14.4. The SER (page 12) states: "Demonstration that the uranium, radium, and
thorium activity concentrations of the Uranium Material are below the maximum range of
previously approved conventional ores and alternate feed materials indicates that radon
levels resulting from the processing of the Uranium Material are expected to be within
the range for which the existing approved controls and monitoring programs are currently
established and considered appropriate." Did the DRC also evaluate the range of
materials that have actually been processed at the mill, not just the previously approved
alternate feed?
14.5. The DRC refers to approved "conventional ores." Does the DRC approve
"conventional ores" for processing at the mill?
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14.6. The UCA and the Atomic Energy Act require the assessment of the
radiological impacts to the public health from the processing of the Uranium Material.
However, I am unable to find such an assessment. There is no discussion of how, exactly,
the processed material will be regulated under the applicable regulations, or now, exactly,
the radon and other radionuclides will be controlled over the life and long-term care of
processed Uranium Material. There is no discussion of the health risks from the radon
and other radionuclides associated with the transportation, storage, loading, processing,
disposal, and perpetual care of the Uranium Material and its processing wastes.
Where, exactly, in the SER does the DRC assess the radiological impacts to the
public health from the transportation, storage, loading, processing, disposal, and
perpetual care of the Uranium Material and its processing wastes?
14.7. The SER at Table 7 (page 13) provides information regarding Derived Air
Concentrations (DRCs) from Ores and Selected Alternate feed. Table 7 does not explain
what, exactly, the numbers in the table actually measure. Table 7 includes columns
identified as UF4, KF, Regen Material, and Calcined Material, but does not indicate the
source or nature of those materials.
Please explain what DAC means and what the numbers in Table 7 measure.
14.8. What is the source and nature of the UF4, KF, Regen Material, and
Calcined Material? How much of each of these materials has been processed at the Mill?
Please identify the date of the application(s), license amendment(s), and environmental
analysis or analyses associated with the processing and disposal of the UF4, KF, Regen
Material, and Calcined Material.
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14.9. The SER (page 14) states that the Concentrations of thorium-232 and its
decay products are negligible and its decay products are negligible and can be ignored.
What are the concentrations of thorium-232 and its decay products from the
Uranium Material and other feed material processed at the Mill? Compare the half-lives
and health impacts of the decay products of uranium with those of thorium decay
products. What is the basis for discounting the health risks from thorium-232 and its
decay products?
14.10. The SER (page 15) provides information re the external radiation
standards for transportation of the material and provides a standard of 200 mrem/hr at any
point on the outer surface of the vehicle.
How long would it take for a person next to a vehicle carrying radioactive
material receive the maximum dose of 100 mrem per year for off-site exposure from a
uranium mill?
14.11. Were the White Mesa Tailings Cells 4A and 4B designed contemplating
the disposal and perpetual storage of wastes from the processing of material other than
natural ores? If so, please identify the specific design elements in Cells 4A and 4B that
were developed in anticipation of the disposal of wastes from the processing of materials
other than natural ores from the Colorado Plateau?
14.12. Please identify and describe the specific design elements for the
construction of Cells 4A and 4B that would anticipate the disposal of the radiological and
chemical constituents found in the Uranium Material?
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14.13. How long after closure of the Cells 4A and 4B will it take to remove free
standing liquids from the Cells, such that the liquids will not longer provide a source of
leakage from the tailings impoundments into the surrounding soils and ground water?
14.14. Which radiological and chemical constituents present in the Uranium
Material have been found in excess of ground water standards in the monitoring wells at
the White Mesa Mill?
14.15. Has the DRC reviewed the amount and nature of contaminants in the
previously approved alternate feeds to determine whether Ground Water Discharge
Permit would need to be revised in order to detect the constituents in the alternate feed
that are not found in Colorado Plateau ores?
14.16. Has the DRC determined the chemical compatibility of the contaminants
in the previously approved alternate feeds to determine the types of chemical reactions
that would occur in the tailing cells as a result of disposing of the contaminants in the
tailings impoundments?
14.17. The SER states repeatedly that the radiological and chemical constituents
in the Uranium Material are similar to ores and alternate feed materials previously
processed at the Mill. However, the SER often compares the constituents with those in
alternate approved for processing, but not necessarily processed at the Mill. Why does
the SER not limit its similarity analysis to feed materials that have actually been
processed at White Mesa? What differences in constituent analyses would be apparent if
only processed materials were considered?
UW Questions for October 9 Hearing
White Mesa Mill Alternate Feed License Amendment (UT1900479)
September 30, 2013
19
14.18. The SER refers to Occupational Safety and Health Administration
regulations. Which OSHA regulations are applicable to the White Mesa Mill and how are
those regulations enforced?
15. The SER discusses Long Term Impacts and concludes that the DRC "does not
anticipate any significant impacts on the reclamation, decommissioning, and
decontamination of the White Mesa facility, if the Uranium Material is processed as an
alternate feed."
Currently White Mesa Mill Cell 2 was not in compliance with the emissions
limits in 40 C.F.R. Part 61 Subpart W, § 61.252(a), of 20 pico Curies per meter squared
for the calendar year 2012. Cell 2 no longer receives tailings, has an interim soil cover,
and is undergoing a process of dewatering. As a result of the non-compliance EFRI is
submitting monthly Subpart W compliance reports to the EPA and the Utah Division of
Air Quality, which administers and enforces Subpart W. The July 2013 Monthly Radon
Flux Monitoring Report for Cell 2 included an evaluation of possible causes of the
increases in radon flux from the impoundment. See Exhibit A. The July 2013 Report
states: "EFRI has identified the areas of elevated radon flux associated with known
sources of radiological contamination at or near the surface of the cell cover." EFRI
found that there were three specific locations associated with increase in radon
emissions: 1) the location associated with the former tailings discharge line, 2) the
perimeter area near the north of Cell 2 containing disturbed or windblown material, and
3) the location of specific alternate feed tailings disposal with elevated radionuclide
content.
UW Questions for October 9 Hearing 20
White Mesa Mill Alternate Feed License Amendment (UT 1900479)
September 30, 2013
This means that materials from the tailings have migrated off the pile and that the
wastes from the disposal wastes from the processing of alternate feed have elevated
radionuclide contents.
15.1. Has the DRC taken into consideration the fact that elevated levels of
radionuclides have been associated with the disposal of waste from the processing of
alternate feed material in a White Mesa tailings impoundment?
15.2. Has the DRC taken into consideration the fact of the dispersal of materials
from the tailings impoundments by wind and other natural forces?
15.3. What are the radiological constituents that will be disposed of in the tailings
impoundment from the processing of the Uranium Material that are different from the
radiological constituents that would be disposed of from the processing of the Colorado
Plateau ores at the Mill?
15.4. Do the EIS and Environmental Assessments (EAs) for the White Mesa Mill
operation evaluate the health, safety, and environmental impacts from the receipt, storage,
processing, disposal, and long-term storage related to the processing of alternate feed
materials? If so, please identify the documents and sections that contain such
evaluations.
15.5. Has the DRC conducted an evaluation of the cumulative impacts of the
receipt, storage, processing, disposal, and long-term storage related to the processing of
alternate feed materials at the White Mesa Mill?
16. NRC regulation (10 C.F.R. § 40.3) states: "A person subject to the regulations in this
part may not receive title to, own, receive, possess, use, transfer, provide for long-term
UW Questions for October 9 Hearing
White Mesa Mill Alternate Feed License Amendment (UT1900479)
September 30, 2013
21
care, deliver or dispose of byproduct material or residual radioactive material as defined
in this part or any source material after removal from its place of deposit in nature,
unless authorized in a specific or general license issued by the Commission under the
regulations in this part." Emphasis added.
16.1. Does the DMC have a general or specific license to transfer the Uranium
Material from the Midnite Mine to the White Mesa Mill?
Sarah Fields
Program Director
Uranium Watch
UTAH DEPARTMENT OF
ENVIRONMENTAL QUAUTY
AUG I 1 20* Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO. US, 80228
303 974 2140 ENERGYFUELS DIVISION OF AIR QUALITY
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
August 20, 2013
Mr. Bryce Bird
Director, Utah Division of Air Quality
State of Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT84116
Re: White Mesa Uranium Mill,
National Emissions Standards for Radon Emission from Operating Mill Tailings
Transmittal of July 2013 Monthly Radon Flux Monitoring Report for Cell 2
Dear Mr. Bird:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI's") radon-222 flux monitoring report
for July 2013 (the "Monthly Report") pursuant to 40 CFR 61.254(b), for Cell 2 at the White Mesa
Uranium Mill (the "Mill"). Cell 2, which was constructed and placed into operation prior to December
15, 1989 is subject to the requirements in 40 CFR 61.252(a). As discussed in our 2012 Annual Radon
Flux Monitoring Report submitted March 29, 2013, Cell 2 was not in compliance with the emissions
limits in 40 CFR 61.252(a) of 20 pCi/(m2 -sec) for the calendar year 2012. This Monthly Report is
submitted pursuant to 40 CFR 261(b) which requires monthly reporting of monitoring data collected
beginning the month immediately following the submittal of the annual report for the year in non-
compliance.
Included with the Monthly Report is a Radon Flux Measurement Program Report, dated July 2013,
prepared by Tellco Environmental (the "Tellco July 2013 Monthly Report"). The Tellco July 2013
Monthly Report indicates that for the month of July 2013, the average radon flux from Cell 2 of 24,3
pCi/(m -sec), did not comply with the standard in 40 CFR 61.252(a).
If you have any questions, please feel free to contact me at [phone].
Yours very truly,
Energy Fuels Resources (USA) Inc.
Jo Ann Tischler
Manager, Compliance and Licensing
N:\WMM\Required Reports\NESHAPS Reports\2013 Monthly NESHAPs\Cell 2 July 2013 Monthly NESHAPSNtransmtl
Cell 2 Radon Flux July 2013.doc
Letter to B. Bird
August 20, 2013
Page 2 of 2
cc: David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Rusty Lundberg, Utah DRC
Jay Morris, Utah DAQ
Harold R. Roberts
David E. Turk
Kathy Weinel
Director, Air and Toxics Technical Enforcement Program, Office of Enforcement, Compliance
and Environmental Justice, U. S. Environmental Protection Agency
Attachments
ENERGY FUELS RESOURCES (USA) INC.
40 CODE OF FEDERAL REGULATIONS 61 SUBPART W
WHITE MESA MILL
SAN JUAN COUNTY, UTAH
TAILINGS CELL 2 MONTHLY COMPLIANCE REPORT FOR JULY 2013
Submitted August 20,2013
by
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, Colorado 80228
[phone]
1) Name and Location of the Facility
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Mill (the "Mill"), located in
central San Juan County, Utah, approximately 6 miles (9.5 km) south of the city of Blanding. The Mill
can be reached by private road, approximately 0.5 miles west of Utah State Highway 191. Within San
Juan County, the Mill is located on fee land and mill site claims, covering approximately 5,415 acres,
encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of T37S, R22E, and Sections 4, 5, 6, 8,
9, and 16 of T38S, R22E, Salt Lake Base and Meridian.
All operations authorized by the Mill's State of Utah Radioactive Materials License are conducted within
the confines of the existing site boundary. The milling facility currently occupies approximately 50 acres
and the tailings disposal cells encompass another 275 acres.
2) Monthly Report
This Report is the monthly report for the Mill's Cell 2 for July 2013, required under 40 Code of Federal
Regulations (CFR) 61.254(b).
A summary of the events that gave rise to the requirement to file this monthly report under 40 CFR
61.254(b) is set out in Section 4 of this Report. A summary of the radon emissions from Cell 2 measured
in July 2013 is set out in Section 5 of this Report.
The monthly monitoring data for July 2013 required under 40 CFR 61.254(b) is provided in Attachment 1
to this Report, which contains the Radon Flux Measurement Program Report, dated July 2013, prepared
by Tellco Environmental (the 'Tellco July 2013 Monthly Report"). The results are summarized in
Section 5 of this Report.
3) Name of the Person Responsible for Operation and Preparer of Report
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, Colorado 80228
303.628.7798 (phone)
303.389.4125 (fax)
EFRI is the operator of the Mill and its tailings impoundments (Cells 2, 3, and 4A) and evaporation
impoundments (Cells 1 and 4B). The Mill is an operating conventional uranium mill, processing both
conventional ores and alternate feed materials. The "method of operations" at the Mill is phased disposal
of tailings. Compliance with the NESHAP standards at 40 CFR 61.252(a) is determined annually for
existing impoundments (i.e., Cells 2 and 3). The annual radon emissions for existing impoundments are
measured using Large Area Activated Charcoal Canisters in conformance with 40 CFR, Part 61,
Appendix B, Method 115, Restrictions to Radon Flux Measurements, (Environmental Protection Agency
["EPA"], 2008). These canisters are passive gas adsorption sampling devices used to determine the flux
rate of Radon-222 gas from the surface of the tailings material. For impoundments licensed for use after
December 15, 1989 (i.e., Cell 4A, and 4B), EFRI employs the work practice standard listed at 40 CFR
61.252(b)(1) in that all tailings impoundments constructed or licensed after that date are lined, are no
more than 40 acres in area, and no more than two impoundments are operated for tailings disposal at any
one time.
EFRI is submitting this monthly compliance report in conformance with the standards in 40 CFR
61.254(b).
2
4) Background Information - Summary of 2012 Annual Report
Facility History
Cells 2 and 3, which are 270,624 m2 (approximately 66 acres) and 288,858 m2 (approximately 71 acres),
respectively, were constructed prior to December 15, 1989 and are considered "existing impoundments"
as defined in 40 CFR 61.251. Radon flux from Cells 2 and 3 is monitored annually, as discussed below.
Cells 4A and 4B were constructed after December 15, 1989, and are subject to the work practice
standards in 40 CFR 61.252(b)(1), which require that the maximum surface area of each cell not exceed
40 acres. For this reason, Cells 4A and 4B are not required to undergo annual radon flux monitoring.
Cell 3, which is nearly filled, and Cell 4A, receives the Mill's tailings sands. Cells 1 and 4B, receive
solutions only, and are in operation as evaporative ponds. Cell 2 is filled with tailings, is covered with an
interim soil cover, and is no longer in operation.
Dewatering of Cell 2
The Utah Division of Water Quality issued Groundwater Discharge Permit ("GWDP') UGW-370004 in
2005. Under Part I.D.3 of the current GWDP, EFRI has been required to accelerate dewatering of the
solutions in the Cell 2 slimes drain. Dewatering of Cell 2 began in 2008. In mid-2011, changes were
made in the pumping procedures for slimes drain dewatering of Cell 2 that resulted in an acceleration of
dewatering since that time. As discussed in more detail below, studies performed by EFRI indicate that
the increase in radon flux from Cell 2 has likely been caused by these dewatering activities. No other
changes appear to have occurred in condition, use, or monitoring of Cell 2 that could have resulted in an
increase in radon flux from the cell.
The average water level in the Cell 2 slimes drain standpipe for each of the years 2008 through 2012
indicate that water levels in Cell 2 have decreased approximately 3.25 feet (5600.56 to 5597.31 fmsl)
since 2008. Of this decrease in water level, approximately 1 foot occurred between 2010 and 2011,
reflecting the improved dewatering that commenced part way through 2011, and approximately 2 feet
between 2011 and 2012, reflecting improved dewatering for all of 2012.
Radon Flux Monitoring of Cell 2
Tellco performed the 2012 radon flux sampling during the second quarter of 2012 in the month of June.
On June 25, 2012, Tellco advised EFRI that the average radon flux for Cell 2 from samples taken in June
2012 was 23.1 pCi/(m2 -sec) (referred to in the Tellco report as pCi/m2"s), which exceeded the Subpart W
requirement. The result of the 2012 radon-222 flux monitoring for Cell 3 was 18 pCi/(m2 -sec). Cell 3,
therefore, was in compliance with this standard for 2012.
40 CFR 61.253 provides that:
"When measurements are to be made over a one year period, EPA shall be provided with
a schedule of the measurement frequency to be used. The schedule may be submitted to
EPA prior to or after the first measurement period."
EFRI advised the Utah Division of Air Quality ("DAQ"), by notices submitted on August 3 and
September 14, 2012, that EFRI planned to collect additional samples from Cell 2 in the third and fourth
quarters of 2012. These samples were collected on September 9, October 21, and November 21, 2012,
3
respectively. As the June monitoring for Cell 3 indicated that it was in compliance with the standard,
further monitoring of Cell 3 was not performed.
The result of the 2012 radon-222 flux monitoring for Cell 2 was 25.9 pCi/(m2 -sec) (averaged over four
monitoring events). The measured radon flux from Cell 2 in 2012 therefore exceeded the standard in 40
CFR 61.252(a) of 20 pCi/(m2 -sec).
The Cell 2 and Cell 3 radon flux results were reported in EFRI's 2012 Annual Radon Flux Monitoring
Report (the "2012 Annual Report").
The provisions of 40 CFR 61.254(b) requires that:
"If the facility is not in compliance with the emission limits of paragraph 61.252 in the calendar
year covered by the report, then the facility must commence reporting to the Administrator on a
monthly basis the information listed in paragraph (a) of this section, for the preceding month.
These reports will start the month immediately following the submittal of the annual report for
the year in non-compliance and will be due 30 days following the end of each month."
This Report is the required monthly report for July 2013 for Cell 2. Monthly monitoring will continue
until US EPA or DAQ determines that it is no longer required.
Evaluation of Potential Factors Affecting Radon Flux
In an attempt to identify the cause of the increase in radon flux at Cell 2, EFRI conducted a number of
evaluations including:
• Excavation of a series of 10 test pits in the Cell 2 sands to collect additional information needed
to ascertain factors affecting radon flow path and flux,
• Evaluation of radon trends relative to slimes drain dewatering,
• Development of correlation factors relating dewatering rates to radon flux, and
• Estimation of the thickness of temporary cover that would be required to achieve compliance with
the radon flux standard of 20 pCi/(m2 -sec), during the dewatering process.
These studies and results are discussed in detail in EFRI's 2012 Annual Radon Flux Report and
summarized in the remainder of this section.
Slimes drain dewatering data indicate that a lowering of the water level in Cell 2 has resulted in an
increase in the average radon flux, and that an increase in water level has resulted in a decrease in the
average radon flux. Changes in radon flux have consistently been inversely proportional to changes in
water levels in Cell 2 since 2008. For the last three years the change in radon flux has been between 3
and 5 pCi/(m -sec) per each foot of change in water level. It is also noteworthy that the significant
increases in radon flux from Cell 2 which occurred between 2010 and 2011 and between 2011 and 2012
coincided with the periods of improved (accelerated) dewatering of Cell 2.
EFRI has evaluated these results and has concluded that the increase in radon-222 flux from Cell 2 that
has resulted in the exceedance of the 20 pCi/(m2 -sec) standard in 40 CFR 61.252 (a) in 2012 is most
likely the unavoidable result of Cell 2 dewatering activities mandated by the Mill's State of Utah GWDP.
This is due to the fact that saturated tailings sands attenuate radon flux more than dry tailings sands, and
4
the thickness of saturated tailings sands decrease as dewatering progresses. There appear to have been no
other changes in conditions at Cell 2 that could have caused this increase in radon flux from Cell 2.
These conclusions are supported by evaluations performed by SENES Consultants Limited ("SENES"),
who were retained by EFRI to assess the potential effects of dewatering on the radon flux from Cell 2 and
to provide calculations of the thickness of temporary cover required to achieve the radon flux standard
during the dewatering process.
SENES' evaluations were presented in a report provided as an attachment to EFRI's 2012 Annual Report.
SENES estimated a theoretical radon flux from the covered tailings at Cell 2 for various depths
(thicknesses) of dry tailings, and predicted future increases in radon flux as a function of decreases in
water levels.
In order to explore potential interim actions that could be taken to maintain radon flux within the 20
pCi/(m2-sec) standard, the SENES study also evaluated the extent to which radon emanations from the
cell can be reduced by increasing the thickness of the current interim cover on Cell 2.
5) July 2013 Results
Detailed results for July 2013 for Cell 2 are contained in the Tellco July 2013 Monthly Report. As
described in the Tellco July 2013 Monthly Report, monitoring was performed consistent with 40 CFR 61
Subpart W Appendix B, Method 115 radon emissions reporting requirements. The radon monitoring
consisted of 100 separate monitoring points at which individual radon flux measurements have been made
by collection on carbon canisters. The individual radon flux measurements were averaged to determine
compliance with 40 CFR Part 61.252.
The average radon flux for Cell 2 in July 2013 was reported by Tellco to be 24.3 pCi/(m2 -sec). This
radon flux value exceeds the 20 pCi/(m2-sec) standard in 40 CFR 61.252.
6) Other Information
Status of Proposed Updated Final Cover Design
As part of developing the Mill's final reclamation plan required to achieve the radon flux standard of 20
pCi/(m2-sec), a final engineered cover design was submitted by TITAN Environmental in 1996 and
approved by the US Nuclear Regulatory Commission ("NRC"). An updated final cover design for the
Mill's tailings system, submitted in November 2011, is under review by the Utah Division of Radiation
Control ("DRC"), and is not currently approved. DRC provided a second round of interrogatories on the
proposed cover design and associated Infiltration and Contaminant Transport Model ("ICTM") in
February 2013, for which EFRI and its consultant, MWH Inc. are preparing responses.
7) Additional Information Required for Monthly Reports
a) Controls or Other Changes in Operation of the Facility
40 CFR 61.254(b)(1) requires that in addition to all the information required for an Annual Report under
40 CFR 61.254(b), monthly reports shall also include a description of all controls or other changes in
operation of the facility that will be or are being installed to bring the facility into compliance.
Based on the evaluations described in Section 4, above, and as discussed during EFRI's March 27, 2013
meeting with DAQ and DRC staff, in addition to the monthly monitoring reported in this Monthly Report,
5
EFRI has proposed the following steps to ensure that radon emissions from Cell 2 are kept as low as
reasonably achievable and to bring the facility into compliance with the applicable standard:
Construction and Monitoring of Interim Cover Test Area, and Application of Additional Random
Fill
i. EFRI proposes to construct and monitor a test-scale application to confirm the effect of the
addition of one foot of additional soil cover. EFRI proposes to apply one foot of random fill at
90% compaction to a test area on Cell 2 of 100 feet by 100 feet. This test area would be
established on or before September 2013 subject to DRC confirmation as discussed below. The
radon flux in the test area would be measured both before and after placement of the additional
fill and periodically over a six month period. Design of the test soil cover area is underway.
ii. If the desired reduction (to within compliance levels) is achieved on the test area, EFRI will apply
one foot of additional random fill at 90% compaction, to the remainder of Cell 2, on or before
July 1, 2014. EFRI will perform the 2014 annual radon flux monitoring of Cell 2 after placement
of the fill over the entire Cell 2 area.
The foregoing proposed test and construction activities will be conditional upon DRC confirming that
such activities will not be prejudicial to or inconsistent with the final approved cover design currently
under review, and will be credited toward the final cover design. As of the date of this report, EFRI has
not received DRC's confirmation that the test and construction activities will not be prejudicial to or
inconsistent with the final approved cover design, or will be credited toward the final cover design.
Interim Corrective Action
EFRI has taken the following additional steps to provide interim mitigation of radon flux from Cell 2.
EFRI has identified the areas of elevated radon flux associated with known sources of radiological
contamination at or near the surface of the cell cover. Specifically:
• the location associated with the former tailings discharge line,
• the perimeter area near the north of Cell 2 containing disturbed or windblown material, and
• the location of specific alternate feed tailings disposal with elevated radionuclide content.
EFRI has implemented corrective measures, which began in June 2013 and are in progress at the time of
this monthly report. The corrective measures include the addition of cover material to the known source
areas, and/or the excavation and reburying of any amount of contaminated material that may be detected
at the surface of the source areas.
EFRI has completed an initial step of adding and compacting cover soil in a dry condition on Cell 2
during July 2013. This step has not affected the hot spots sufficiently to reduce the average flux to below
the limit of 20 pCi/(m2 -sec). During August 2013, the additional soil already added to Cell 2 will be
sprayed with water and re-compacted to improve (reduce) the permeability of the added cover. The Mill
will have the completed prior to the upcoming August sampling event, to quantify how much effect this
approach may have on the average flux.
a) Facility's Performance Under Terms of Judicial or Administrative Enforcement Decree
The Mill is not under a judicial or administrative enforcement decree.
6
8) Certification
I Certify under penalty of law that I have personally examined and am familiar with the information
submitted herein and based on my inquiry of those individuals immediately responsible for obtaining the
information, I believe that the submitted information is true, accurate and complete. I am aware that there
are significant penaltie^ for submitting false information including the possibility of fine and
imprisonment. SM18, p.S.C. 1001.
Signed: //,// /A Date:
David C./rrypenltind
Senior Vice President, General Counsel and Corporate Secretary
ATTACHMENT 1
National Emissions Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
July 2013 Sampling Results
National Emission Standards for Hazardous Air Pollutants
2013 Radon Flux Measurement Program
White Mesa Mill
6425 South Highway 191
Blanding, Utah 84511
July 2013 Sampling Results
Cell 2
Prepared for: Energy Fuels Resources (USA) Inc.
6425 S. Highway 191
P.O. Box 809
Blanding, Utah 84511
Prepared by: Tellco Environmental
P.O. Box 3987
Grand Junction, Colorado 81502
TABLE OF CONTENTS
Page
1. INTRODUCTION 1
2. SITE HISTORY AND DESCRIPTION 1
3. REGULATORY REQUIREMENTS FOR THE SITE 2
4. SAMPLING METHODOLOGY 2
5. FIELD OPERATIONS 3
5.1 Equipment Preparation 3
5.2 Sample Locations, Identification, and Placement 3
5.3 Sample Retrieval 3
5.4 Environmental Conditions 4
6. SAMPLE ANALYSIS 4
6.1 Apparatus 4
6.2 Sample Inspection and Documentation 4
6.3 Background and Sample Counting 5
7. QUALITY CONTROL (QC) AND DATA VALIDATION 5
7.1 Sensitivity 5
7.2 Precision 5
7.3 Accuracy 6
7.4 Completeness 6
8. CALCULATIONS 6
9. RESULTS 7
9.1 Mean Radon Flux 7
9.2 Site Results 8
References 9
Figure 1 10
Appendix A. Charcoal Canister Analyses Support Documents
Appendix B. Recount Data Analyses
Appendix C. Radon Flux Sample Laboratory Data, Including Blanks
Appendix D. Sample Locations Map (Figure 2)
1. INTRODUCTION
During July 22-23, 2013 Tellco Environmental, LLC (Tellco) of Grand Junction, Colorado, provided
support to Energy Fuels Resources (USA) Inc. (Energy Fuels) to conduct radon flux measurements
regarding the required National Emission Standards for Hazardous Air Pollutants (NESHAPs) Radon
Flux Measurements. These measurements are required of Energy Fuels to show compliance with
Federal Regulations (further discussed in Section 3 below). The standard is not an average per facility,
but is an average per radon source. The standard allows mill owners or operators the option of either
making a single set of measurements or making measurements over a one year period (e.g., weekly,
monthly, or quarterly intervals).
Energy Fuels is presently on a monthly radon flux sampling plan for Cell 2. This report presents the
radon flux measurements results for Cell 2 for July 2013; the results of each monthly sampling event
are presented in separate reports. Prior to 2012, Energy Fuels had chosen to make a single set of
measurements to represent the radon flux each year; however, as the radon flux levels in Cell 2 began
exceeding the regulatory standard of 20 picoCuries per square meter per second (pCi/m2-s) in 2012,
Energy Fuels decided to make the radon flux measurements on a more frequent basis.
During June and July 2013, Energy Fuels placed additional cover materials at selected sample
locations of Cell 2 in an attempt to reduce the radon flux levels. The additional material was
approximately 18-24 inches thick and approximately 100 feet in diameter, centered around selected
sample location points where previous sampling had identified radon flux greater than 40 pCi/m2-s.
Tellco was contracted to provide radon canisters, equipment, and canister placement personnel as well
as lab analysis of samples. Energy Fuels personnel provided support for loading and unloading
charcoal from the canisters. This report details the procedures employed by Energy Fuels and Tellco
to obtain the results presented in Section 9.0 of this report.
2. SITE DESCRIPTION
The White Mesa Mill facility is located in San Juan County in southeastern Utah, six miles south of
Blanding, Utah. The mill began operations in 1980 for the purpose of extracting uranium and
vanadium from feed stocks. Processing effluents from the operation are deposited in four lined cells,
which vary in depth. Cell 1, Cell 4A, and Cell 4B did not require radon flux sampling, as explained in
Section 3 below.
Cell 2, which has a total area of approximately 270,624 square meters (m2), has been filled and
covered with interim cover. This cell is comprised of one region; a soil cover of varying thickness,
which requires NESHAPs radon flux monitoring. The Cell 2 cover region is the same size in 2013 as
it was in 2012. There are no exposed tailings or standing liquid within Cell 2.
Cell 3, which has a total area of 288,858 m2, is nearly filled with tailings sand and is undergoing pre-
closure activities. This cell is comprised of two source regions that require NESHAPs radon
monitoring: a soil cover region of varying thickness and an exposed tailings "beaches" region. The
i
remaining area is covered by standing liquid in lower elevation areas. The sizes of the regions vary
due to the continuing advancement of interim cover materials and varying water levels.
3. REGULATORY REQUIREMENTS FOR THE SITE
Radon emissions from the uranium mill tailings at this site are regulated by the State of Utah's
Division of Radiation Control and administered by the Utah Division of Air Quality under generally
applicable standards set by the Environmental Protection Agency (EPA) for Operating Mills.
Applicable regulations are specified in 40 CFR Part 61, Subpart W, National Emission Standards for
Radon Emissions from Operating Mill Tailings, with technical procedures in Appendix B. At present,
there are no Subpart T uranium mill tailings at this site. These regulations are a subset of the
NESHAPs. According to subsection 61.252 Standard, (a) radon-222 emissions to ambient air from an
existing uranium mill tailings pile shall not exceed an average of 20 pCi/m2-s for each pile or region.
Subsection 61.253, Determining Compliance, states that: "Compliance with the emission standard in
this subpart shall be determined annually through the use of Method 115 of Appendix B." The
repaired Cell 4A, and newly constructed Cell 4B, were both constructed after December 15, 1989
and each was constructed with less than 40 acres surface area. Cell 4A and 4B comply with the
requirements of 40 CFR 61.252(b), therefore no radon flux measurements are required on either
Cell4A or 4B.
4. SAMPLING METHODOLOGY
Radon emissions were measured using Large Area Activated Charcoal Canisters (canisters) in
conformance with 40 CFR, Part 61, Appendix B, Method 115, Restrictions to Radon Flux
Measurements, (EPA, 2012). These are passive gas adsorption sampling devices used to determine
the flux rate of radon-222 gas from a surface. The canisters were constructed using a 10-inch
diameter PVC end cap containing a bed of 180 grams of activated, granular charcoal. The prepared
charcoal was placed in the canisters on a support grid on top of a Vi inch thick layer of foam and
secured with a retaining ring under 1 Vi inches of foam (see Figure 1, page 10).
One hundred sampling locations were distributed throughout Cell 2 (which consisted of one region) as
depicted on the Sample Locations Map (see Figure 2, Appendix D). Each charged canister was placed
directly onto the surface (open face down) and exposed to the surface for 24 hours. Radon gas
adsorbed onto the charcoal and the subsequent radioactive decay of the entrained radon resulted in
radioactive lead-214 and bismuth-214. These radon progeny isotopes emit characteristic gamma
photons that can be detected through gamma spectroscopy. The original total activity of the
adsorbed radon was calculated from these gamma ray measurements using calibration factors
derived from cross-calibration of standard sources containing known total activities of radium-226
with geometry identical to the counted samples and from the principles of radioactive decay.
After approximately 24 hours, the exposed charcoal was transferred to a sealed plastic sample
container (to prevent radon loss and/or further exposure during transport), identified and labeled, and
transported to the Tellco laboratory in Grand Junction, Colorado for analysis. Upon completion of on-
site activities, the field equipment was alpha and beta-gamma scanned for possible contamination
resulting from fieldwork activities. All field equipment was surveyed by Energy Fuels Radiation
Safety personnel and released for unrestricted use. Tellco personnel maintained custody of the
samples from collection through analysis.
2
5. FIELD OPERATIONS
5.1 Equipment Preparation
All charcoal was dried at 110°C before use in the field. Unused charcoal and recycled charcoal were
treated the same. 180-gram aliquots of dried charcoal were weighed and placed in sample containers.
Proper balance operation was verified daily by checking a standard weight. The balance readout
agreed with the known standard weight to within ± 0.1 percent.
After acceptable balance check, empty containers were individually placed on the balance and the
scale was re-zeroed with the container on the balance. Unexposed and dried charcoal was carefully
added to the container until the readout registered 180 grams. The lid was immediately placed on the
container and sealed with plastic tape. The balance was checked for readout drift between readings.
Sealed containers with unexposed charcoal were placed individually in the shielded counting well,
with the bottom of the container centered over the detector, and the background count rate was
documented. Three five-minute background counts were conducted on ten percent of the containers,
selected at random to represent the "batch". If the background counts were too high to achieve an
acceptable lower limit of detection (LLD), the entire charcoal batch was labeled non-conforming and
recycled through the heating/drying process.
5.2 Sample Locations, Identification, and Placement
On July 22, 2013, the sampling locations were spread out throughout the Cell 2 region. The same
sampling locations that were established for the previous sampling of Cell 2 were used for the July
2013 sampling, although the actual sample identification numbers (ID) are different. An individual
ID was assigned to each sample point, using a sequential alphanumeric system indicating the charcoal
batch and physical location within the region (e.g., G01 ...G100). This ID was written on an adhesive
label and affixed to the top of the canister. The sample ID, date, and time of placement were recorded
on the radon flux measurements data sheets for the set of one hundred measurements.
Prior to placing a canister at each sample location, the retaining ring, screen, and foam pad of each
canister were removed to expose the charcoal support grid. A pre-measured charcoal charge was
selected from a batch, opened and distributed evenly across the support grid. The canister was then
reassembled and placed face down on the surface at each sampling location. Care was exercised not
to push the device into the soil surface. The canister rim was "sealed" to the surface using a berm of
local borrow material.
Five canisters (blanks) were similarly processed and the canisters were kept inside an airtight plastic
bag during the 24-hour testing period.
5.3 Sample Retrieval
On July 23, 2013 at the end of the 24-hour testing period, all canisters were retrieved, disassembled
and each charcoal sample was individually poured through a funnel into a container. Identification
numbers were transferred to the appropriate container, which was sealed and placed in a box for
3
transport. Retrieval date and time were recorded on the same data sheets as the sample placement
information. The blank samples were similarly processed.
The charcoal samples from all 100 canisters were successfully containerized during the unloading
process.
5.4 Environmental Conditions
A rain gauge and thermometer were in place at the White Mesa Mill site to monitor rainfall and air
temperatures during sampling in order to ensure compliance with the regulatory measurement criteria.
In accordance with 40 CFR, Part 61, Appendix B, Method 115:
• Measurements were not initiated within 24 hours of rainfall.
• Approximately 0.01 inches of rainfall occurred after placement of the canisters, but all of
the canister seals remained intact and none of the canisters were surrounded by water.
• The minimum ambient air temperature during the sampling period was 66 degrees F.
6. SAMPLE ANALYSIS
6.1 Apparatus
Apparatus used for the analysis:
• Single- or multi-channel pulse height analysis system, Ludlum Model 2200 with a
Teledyne 3" x 3" sodium iodide, thallium-activated (Nal(Tl)) detector.
• Lead shielded counting well approximately 40 cm deep with 5-cm thick lead walls and a 7-
cm thick base and 5 cm thick top.
• National Institute of Standards and Technology (NIST) traceable aqueous solution radium-
226 absorbed onto 180 grams of activated charcoal.
• Ohaus Model C501 balance with 0.1 -gram sensitivity.
6.2 Sample Inspection and Documentation
Once in the laboratory, the integrity of each charcoal container was verified by visual inspection of the
plastic container. Laboratory personnel checked for damaged or unsealed containers and verified that
the data sheet was complete.
All of the 100 sample containers and 5 blank containers received and inspected at the Tellco analytical
laboratory were verified as valid and no damaged or unsealed containers were observed.
4
6.3 Background and Sample Counting
The gamma ray counting system was checked daily, including background and radium-226 source
measurements prior to and after each counting session. Based on calibration statistics, using two
sources with known radium-226 content, background and source control limits were established for
each Ludlum/Teledyne counting system with shielded well (see Appendix A).
Gamma ray counting of exposed charcoal samples included the following steps:
• The length of count time was determined by the activity of the sample being analyzed,
according to a data quality objective of a minimum of 1,000 accrued counts for any given
sample.
• The sample container was centered on the Nal detector and the shielded well door was
closed.
• The sample was counted over a determined count length and then the mid-sample count
time, date, and gross counts were documented on the radon flux measurements data sheet
and used in the calculations.
• The above steps were repeated for each exposed charcoal sample.
• Approximately 10 percent of the containers counted were selected for recounting. These
containers were recounted within a few days following the original count.
7. QUALITY CONTROL (QC) AND DATA VALIDATION
Charcoal flux measurement QC samples included the following intra-laboratory analytical frequency
objectives:
• Blanks, 5 percent, and
• Recounts, 10 percent
All sample data were subjected to validation protocols that included assessments of sensitivity,
precision, accuracy, and completeness. All method-required data quality objectives (EPA, 2012) were
attained.
7.1 Sensitivity
A total of five blanks were analyzed by measuring the radon progeny activity in samples subjected to
all aspects of the measurement process, excepting exposure to the source region. These blank sample
measurements comprised approximately 5 percent of the field measurements. The results of the blank
sample radon flux rates ranged from -0.02 to 0.01 pCi/m2-s, with an average of approximately 0.00
pCi/m2-s. The lower limit of detection (LLD) was approximately 0.03 pCi/m2-s.
7.2 Precision
Ten recount measurements, distributed throughout the sample set, were performed by replicating
analyses of individual field samples (see Appendix B). These recount measurements comprised
approximately 10 percent of the total number of samples analyzed. The precision of all recount
5
measurements, expressed as relative percent difference (RPD), ranged from less than 0.1 percent to
6.7 percent with an overall average precision of approximately 1.4 percent RPD.
7.3 Accuracy
Accuracy of field measurements was assessed daily by counting two laboratory control samples with
known Ra-226 content. Accuracy of these lab control sample measurements, expressed as percent
bias, ranged from approximately -3.0 percent to -0.5 percent. The arithmetic average bias of the lab
control sample measurements was approximately -1.5 percent (see Appendix A).
7.4 Completeness
One hundred samples from the Cell 2 Cover Region were verified, representing 100 percent
completeness for the July 2013 radon flux sampling.
8. CALCULATIONS
Radon flux rates were calculated for charcoal collection samples using calibration factors derived
from cross-calibration to sources with known total activity with identical geometry as the charcoal
containers. A yield efficiency factor was used to calculate the total activity of the sample charcoal
containers. Individual field sample result values presented were not reduced by the results of the field
blank analyses.
In practice, radon flux rates were calculated by a database computer program. The algorithms utilized
by the data base program were as follows:
Equation 8.1:
? N pCi Rn-222/m sec - [Ts*A*b»0-5<«Wi.W^
where: N = net sample count rate, cpm under 220-662 keV peak
Ts = sample duration, seconds
b = instrument calibration factor, cpm per pCi; values used:
0.1699, for M-01/D-21 and
0.1702, for M-02/D-20
d = decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
Equation 8.2:
Error, la = 2 x
Gross Sample, cpm Background Sample,cpm +
Sample Count,t,min Background Count,t,min
— x Sample Concentration Net,cpm
6
Equation 83:
2.71 +(4.65XS,J
LLD~ [Ts*A*b*0.5(d*T75)]
where: 2.71 = constant
4.65 = confidence interval factor
Sh • standard deviation of the background count rate
Ts - sample duration, seconds
b • instrument calibration factor, cpm per pCi; values used:
0.1699, for M-01/D-21 and
0.1702, for M-02/D-20
d • decay time, elapsed hours between sample mid-time and count mid-time
A = area of the canister, m2
9. RESULTS
9.1 Mean Radon Flux
Referencing 40 CFR, Part 61, Subpart W, Appendix B, Method 115 - Monitoring for Radon-222
Emissions, Subsection 2.1.7 - Calculations, "the mean radon flux for each region of the pile and for
the total pile shall be calculated and reported as follows:
(a) Trie individual radon flux calculations shall be made as provided in Appendix A EPA
86(1). The mean radon flux for each region of the pile shall be calculated by summing all
individual flux measurements for the region and dividing by the total number of flux
measurements for the region.
(b) The mean radon flux for the total uranium mill tailings pile shall be calculated as follows:
Ji Ai ± ... J2A? 1+1... JjAi
Js =
At
Where: Js = Mean flux for the total pile (pCi/m2-s)
Ji = Mean flux measured in region i (pCi/m2-s)
Aj = Area of region i (m2)
At = Total area of the pile (m2)"
40 CFR 61, Subpart W, Appendix B, Method 115, Subsection 2.1.8, Reporting states "The results of
individual flux measurements, the approximate locations on the pile, and the mean radon flux for each
region and the mean radon flux for the total stack [pile] shall be included in the emission test report. Any
condition or unusual event that occurred during the measurements that could significantly affect the results
should be reported."
7
9.2 Site Results
Site Specific Sample Results (reference Appendix C)
(a) The mean radon flux for the Cell 2 Cover Region at the site is as follows:
Cell 2 - Cover Region - 24.3 pCi/m2-s (based on 270,624 m2 area)
Note: Reference Appendix C of this report for the entire summary of individual measurement results,
(b) Using the data presented above, the calculated mean radon flux for Cell 2 is, as follows:
Cell 2 = 24.3 pCi/m2-s
(24.3¥270.624^ =24.3
270,624
As shown above, the arithmetic mean radon flux of the July 2013 samples for Cell 2 at Energy
Fuels White Mesa milling facility is above the NRC and EPA standard of 20 pCi/m2-s. The
extremely dry weather at the site for the past several years was especially severe during 2012 and is
continuing now in 2013. The result of this dry weather is likely a lowered water table in the
containment cell and reduced moisture content in surface soils, which could result in increased
radon flux rates at the site.
The additional cover material placed at the selected locations of Cell 2 (refer to the "comments"
column of the radon flux measurements spreadsheet in Appendix C) did not significantly reduce the
radon flux rates at those locations. The permeability of the additional cover material is likely a result
of low moisture content and partly because of the porosity of the materials used.
Appendix C presents the summary of individual measurement results, including blank sample
analysis.
Sample locations are depicted on Figure 2, which is included in Appendix D. The map was produced
by Tellco.
8
References
U. S. Environmental Protection Agency, Radon Flux Measurements on Gardinier and Royster
Phosphogypsum Piles Near Tampa and Mulberry, Florida, EPA 520/5-85-029, NTIS #PB86-
161874, January 1986.
U. S. Environmental Protection Agency, Title 40, Code of Federal Regulations, July 2012.
U. S. Nuclear Regulatory Commission, Radiological Effluent and Environmental Monitoring at
Uranium Mills, Regulatory Guide 4.14, April 1980.
U. S. Nuclear Regulatory Commission, Title 10, Code of Federal Regulations, Part 40, Appendix A,
January 2013.
9
Figure 1
Large Area Activated Charcoal Canisters Diagram
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10
Appendix A
Charcoal Canister Analyses Support Documents
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CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:^ Mg^gy hK\ [\ [ *g \Al/) A\^ } M T
CLIENT: ^v\-g>rjy tfraC Is I^SOUVT* *
Calibration Check Log
System ID: rVVO t / t> -Z ? Calibration Date: (* /1 *-} / ^ Due Date: klj-jjjjj
Scaler S/N: £SL23I Hi8h Voltagc: Window: 4.42 Thrshld: 2.20
Detector S/N: O 4 *S ^3 Source ID/SN: Ro^/fe^1/ Source Activity:
Blank Canister Bkgd. Range, cpm: 2 a = $(f to I 3a= (*P) to l"7 {
Gross Source Range, cpm: 2 a = ^923 to tO 3 a = g| l?*^ t0 fO"7^?»
Technician:
AH counts times are one minute.
Date
TV*
By Background Counts (1 min. each)
#1 #2 #3 #1
Source Counts (1 min. each)
#2 #3 Average
ok?
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Y/N: Y = average background and source cpm falls within the control limits.
N = average background and source cpm does not fall within the control limits.
The acceptable ranges were determined from prior background and source check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:
CLIENT: B^VC*^ y F&fcU RcSQUrCi^ ;
Calibration Check Log
SystemlD: jjj I / p> - 7- 1 Calibration Date: /'^ Due Date: I * ^ /1 f
Scaler S/N: ^Tl fS "7 High Voltage: IQl^ Window: 4.42 Thrshld: 2.20
Detector S/N: O H t-^ 3 3 Source ID/SN: Roj^V^^ ~ Source Activity: S^.3*p6«*
Blank Canister Bkgd. Range, cpm: 2o = _ Sjg to CS^H 3a- to t"7 I
Gross Source Range, cpm. 2o= 0)<%P)S to I OS*/ U> 3 a - jjg jfe to j
Technician:
All counts times are one minute.
Rat
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#2 #3
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#1 #2 #3 Average
ok?
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Y/N: Y - average background and source cpm falls within the control limits.
N = average background and source cpm does not fall within the control limits.
The acceptable ranges were determined from prior background and source check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION: V/j V\i4-g K } B W<^«J( KT^ ^ L^T
CLIENT: &*-f/^y F\A^ls r\^5Q mrc<S
Calibration Check Log
System ID: ^^^/r>-^Q Calibration ^ fr//4/0 Due Date: 4>/* <///</
Scaler S/N: t> JS*k 3 High Voltage: fc> g£ Window: 4.42 Thrshld: 2.20
Detector S/N: u Source ID/SN: Source Activity:
Blank Canister Bkgd. Range, cpm: 2a- _ to 17 O Jo.
Gross Source Range, cpm:
All counts times are one minute.
Date
Fb*f
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#1
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#1 #2 #3 Average
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Y/N: Y •» average background and source cpm falls within the control limits.
N = average background and source cpm does not fall within the control limits.
The acceptable ranges were determined from prior background and source check data.
CHARCOAL CANISTER ANALYSIS SYSTEM
SITE LOCATION:
CLIENT: £*-er^y Fuf.U 1^*6* P^HTCX?
Calibration Check Log
System ID: Calibration Date: Due Date:
Scaler S/N: vTlS"^3 High Voltage: fO^^S" Window: 4.42 Thrshld: 2.20
Detector S/N: & Hl53"2-> Source IP/SN:^22^ Source Activity: ^>K
Blank Canister Bkgd. Range, cpm: 2 o = _
"78 to tS"| 3g = C?C? to <7Q
Gross Source Range, cpm: 2o=9g^ to fOH-qft 3c = 3^63 to (OCC/
Technician:
All counts times are one minute.
Date By Background Counts (1 min. each)
#1 #2 #3 _Avg. #1
Source Counts (1 min. each)
#2 #3 Average
ok?
Y/N
Q2Ji:
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Y/N: Y = average background and source cpm falls within the control limits.
N = average background and source cpm does not fall within the control limits.
The acceptable ranges were determined from prior background and source check data.
BALANCE OPERATION DAILY CHECK
Balance Model: O Kaot^ Vor^ - Q ~ cT ^1 m
Standard Weight (g): *3-PQ • O g
Date Pre-check (g) Post-check (g) O.K. ± 0.1 % ?
yes
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Appendix B
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Radon Flux Sample Laboratory Data (including Blanks)
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