DRC-2022-021027 - 0901a068810e66b3

D;v of Waste M2.nag8mt: nt
and Rad,at1on Control
SEP 1 6 2�22
September 13, 2022
Sent VIA EXPEDITED DELIVERY
Ms. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www .energyfuels.com
Re: Request for Division of Waste Management and Radiation Control ("DWMRC")
Interpretation of Stack Sampling Frequency Specifications in NRC Regulatory
Guide 4.14, White Mesa Uranium Mill
Dear Mr. Hansen:
Energy Fuels Resources (USA) Inc. ("EFRI") is requesting that the Division of Waste
Management and Radiation Control ("DWMRC") provide an interpretation of the quarterly stack
sampling frequency specified in Nuclear Regulatory Commission ("NRC") Regulatory Guide
4.14, Section 2.1.1 as it pertains to stack sampling at the White Mesa Mill (the "Mill").
The Mill's Radioactive Materials License ("RML") Section 11.2 states "The licensee shall
implement an effluent and environmental monitoring program as described in Sections 2 through
7 of the NRC Regulatory Guide 4.14 Radiological Effluent and Environmental Monitoring at
Uranium Mills, ... ". Section 2.1.1 of the NRC Regulatory Guide 4.14 states "Effluents from the
yellowcake dryer and packaging stack should be sampled quarterly during normal operations."
The NRC Regulatory Guide 4.14 assumes that "normal operations" are continuous throughout
the calendar year and thus has set the sampling frequency at quarterly, which, is taken to mean
once each calendar quarter. EFRI operates the Mill on a "campaign" basis to maximize the
efficiency of the operations. Longer campaigns which have spanned more than one calendar
quarter have been sampled once during each calendar quarter of operations. Previously, shorter campaigns have been rescheduled or delayed to accommodate the Regulatory Guide 4.14
sampling frequency. To allow the Mill to operate at maximum efficiency, EFRI is requesting
interpretation for campaigns that do not extend beyond 92 days of run time regardless of whether
those run times are in a single calendar quarter or multiple calendar quarters. Ninety-two days is
considered equivalent to a calendar quarter because the third calendar quarter of each year is 92
days. EFRI is proposing that for campaigns that do not extend beyond 92 days regardless of the
number of calendar quarters in the campaign, that stack sampling be completed once during the
92 day run period. This request does not lessen frequency of sampling or provide EFRI with any
relief from its current requirements. This interpretation allows for more efficient scheduling of
DRC-2022-021027