ENVIRONMENTAL RADIOLOGICAL MONITORING: AIR … · 2019-07-12 · The purpose of this Standard Operating Procedure (SOP) is to detail the program for air sampling associated with environmental

UR-ENERGY USA, INC. LOST CREEK ISR, LLC

STANDARD OPERATING PROCEDURE

ENVIRONMENTAL RADIOLOGICAL MONITORING: AIR PARTICULATES

Edition: 10Jul2013 Rev1 SOP Number: SOP_LC_ENV-004 Author: MDG/CJP

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Reviewed By: CJP 10/29/2012; CTK 10/25/2012; MDG 2/14/2013; JWC 3/12/2013; MDG 7/3/2013; JWC 7/7/2013 Final Approval:

1.0 PURPOSE

The purpose of this Standard Operating Procedure (SOP) is to detail the program for air sampling associated with environmental radiological air particulate monitoring at the Lost Creek ISR (LC-ISR) Project site. Air sampler units are placed at monitoring stations for the purpose of monitoring ambient site air and sampling potential airborne radiological particulates at the site. Air monitoring is intended to demonstrate that potential exposures to members of the public at the boundary of the unrestricted project area do not exceed regulatory limits. Monitoring of the air is part of the radiological effluent and environmental monitoring program pursuant to NRC Regulatory Guide 4.14 (RG 4.14) to comply with dose limits for members of the public set forth in 20.1301 and 20.1302 and for the reporting requirements pursuant to 10 CFR 40.65. A demonstration of ALARA as set forth in 10 CFR 20.1101 should be achieved with the air monitoring results.

Because of meagerness of vegetation at the Lost Creek Project location, vegetation, livestock and game are not considered significant pathways for radiological exposure to man, and these will not be routinely sampled (TR5.7.7.1). LC-ISR TR MILDOS analysis demonstrated that AP2 Monitor and PR-5 (see attached figure and table in Section 6.0) detectors have the greatest likelihood of levels of radon progeny elevated above ECLs. LC-ISR does not anticipate that radon progeny levels in soil or in vegetation will exceed Pre-Operational levels. Using Pre-Operational air particulate and radon monitoring sampling results, LC-ISR has established radon and Pb-210 background levels for all monitoring stations (see attached table.) Results from Pre-Operational soil sampling have been tabulated in SOP_LC_ENV-008_Operational Soil Monitoring. LC-ISR will compare Operational radon, air particulate and soil monitoring results of downwind samplers with the ECLs and established background and upwind results. If the comparisons do indicate elevation of radon and radon progeny in the air above ECLs or elevated soil levels, then LC-ISR will establish and implement a plan for vegetation and cattle tissue radiological analysis to demonstrate compliance with public exposure limits. The results of the Operational/Pre-Operational comparisons will be reported in the Annual Radiation Protection Program/ALARA (RPP) Report and in the Semi-Annual Effluent and Environmental Monitoring Reports for Commission review.





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2.0 RESPONSIBILITIES/AUTHORITY

The Radiation Safety Officer (RSO) and EHS Department is responsible for: • Ensuring the operation and maintenance of the air sampler units; • Oversight of air sampler unit maintenance and operation; • Ensuring filters are changed according to schedule; • Ensuring that filters are composited properly and submitted for laboratory

analysis; • Maintaining records of acquired field and analytical data; • Analyzing data for determining compliance with public dose limits.

3.0 PREREQUISITES AND TRAINING

Instruments used for air sampling should be properly maintained and calibrated and capable of sampling a volume of air to meet the analytical detection limits (Section 6.5).

Training includes reading and understanding this procedure and familiarization with applicable regulations, guidance, and policy including NRC License Technical Report (TR) Section 2.9.3.7, TR Section 5.7.7.1, 10 CFR 20, 10 CFR 40, NRC Regulatory Guide 4.14, and the ALARA program described in EHS-MS Volume II: Radiation Protection Program.

4.0 DEFINITIONS

CDE (Committed Dose Equivalent): The dose equivalent to organs or tissues of reference (T) that will be received from an intake of radioactive material by an individual during the 50-year period following the intake.

CEDE (Committed Effective Dose Equivalent): The sum of the products of the weighting factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues.

Effluent Concentration Limit (ECL): The 10 CFR 20, Appendix B, Table 2, ECL values are equivalent to the radionuclide concentrations which, if inhaled or ingested continuously over the course of a year, would produce a total effective dose equivalent of 0.05 rem (50 millirem or 0.5 millisieverts)





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Effective dose equivalent (EDE or HE): the sum of the products of the dose equivalent to the organ or tissue (HT) and the weighting factors (wT) applicable to each of the body organs or tissues that are irradiated (HE= Σ wTHT).

Total Effective Dose Equivalent (TEDE)

5.0 HAZARD ASSESSMENT AND PPE

: The sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).

Refer to SOP_LC_ENV-005: Air Sampler Filter Changes for hazards associated with air sampler operation and maintenance.

6.0 PROCEDURE

Air sampling is conducted pre-operationally and during operations of the LC-ISR facility consistent with RG 4.14 as described in NRC TR Section 2.9.3.7 and TR Section 5.7.7.1.

6.1 Pre-Operational Monitoring

Pre-operational baseline characterization sampling has been conducted as described in TR Section 2.9. The air monitoring for determination of background levels was conducted at five air monitoring stations as shown in TR Figure 2.9-25 (Appendix A) during 2007-2008. TR Figure 2.9-27 is included to show monitoring location proximities to the CPP. Pre-operational monitoring has been continued through facility construction and completion of the LC-ISR Central Processing Plant (CPP) until 01 July 2013 to allow for a better statistical evaluation of the Pre-operational data. Pre-Operational monitoring results have been used for statistical evaluation of background levels. Since dose limits for members of the public are exclusive of background, the background values will be used for subtraction from operational results.

6.2 Operational Monitoring

Air particulate samples are collected continuously at the permanent air monitoring stations during operation of the Plant.

Sample locations are summarized on the following table and shown on the attached maps:





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Sample Station ID

Corresponding Air Monitoring Station ID Area Comments

PR-1 AP-1* Lost Creek Nearest Residence, Bairoil, WY PR-2 AP-3 Lost Creek SW Boundary of LC, Upwind of CPP PR-3 AP-5 Lost Creek NW Boundary of LC, Upwind of CPP PR-4 - - Lost Creek N of CPP, 100m PR-5 AP-2 Lost Creek E Adjacent to CPP; Highest Expected PR-6 - - Lost Creek NE Boundary of LC, Downwind CPP PR-7 - - Lost Creek W Boundary of LC, Upwind of CPP PR-8 - - Lost Creek S Boundary of LC, Upwind of CPP PR-9 - - Lost Creek In Mine Unit, S of CPP

PR-10 AP-4 Lost Creek E Boundary of LC, Downwind of CPP Duplicate sample located here

PR-11 - - Lost Creek S Boundary of LC, Upwind of CPP PR-12 - - Lost Creek SSE Boundary LC, Over Ore Trend

PR-13 AP-6 Lost Creek East

Added Oct 1, 2012 for permitting process. Located in SE corner of

Section 2 T25N R92E.

*Note that the LC-ISR air particulate monitors are not technically “high-volume” monitors, as they are operating at approximately 30 Lpm. They have been re-designated as “AP” rather than “HP”

Filters should normally be changed on a weekly basis or as soon as possible thereafter depending upon site access conditions. Flow rates and volumes from the air samplers should be reviewed weekly to determine if there are any anomalies or falloff in flow due to dust loading if filters are not changed within a week (see Section 6.5 for QA/QC). Filters will be changed and field data will be collected as detailed in SOP_LC_ENV-005: Air Sampler Filter Changes.

Filters will be composited by location on a quarterly basis and submitted to an approved laboratory for analysis. Requested analysis includes U-nat, Ra-226, Th-230, and Pb-210 in air and analysis should meet detection limits listed in Section 6.5. Results will be tabulated and included in the Semi-Annual Effluent and Environmental Monitoring Report. An example table of results from the final two Quarters of Pre-Operational monitoring is included at the end of this SOP.

6.3 Data Analysis

The results of the filter analysis will be evaluated to determine if there is contamination by comparing the concentrations of the downwind monitoring stations (AP2 and AP4) with the upwind monitoring stations (AP 3 and AP 5). The upwind monitoring stations will





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be averaged to create the current quarter’s background (Nbkgrd). The following equation can be used to determine if there is contamination present. If the sample value is above the Critical Limit (Lc) then the sample may have contamination on it, and the results will be potentially be used to determine dose, as necessary. The LC will be 2 standard deviations of the current quarter’s baseline data (σb) above the current quarter’s background.

𝐿𝑐 = 2𝜎𝑏 +𝑁𝑏𝑘𝑔𝑟𝑑

Air particulate concentrations determine if levels could contribute to exposures to members of the public above regulatory limits.

Pursuant to 10 CFR 20.1302, LC-ISR shall demonstrate that the public shall not receive doses greater than 50 mrem/yr by:

• Comparing analyzed filter effluent concentrations with 10 CFR 20, Appendix B, Table 2 ECLs;

• Demonstrating that annual average concentrations do not exceed ECLs; • If analyzed values exceed Table 2 ECLS, calculating doses from the measured

concentrations of U-nat, Ra-226, Th-230, and Pb-210, as well as Rn-222, to show that they do not contribute to doses in excess of the established limits as described in SOP_LC_HP-016: Radiation Dose Determination;

• I.e. demonstrating that the theoretical continuous presence of a member of the public would not receive a dose in excess of 2 mrem/hr or 50 mrem/yr.

The following table shows the “10 CFR 20, Appendix B, Table 2” values detailing the concentrations that will give members of the public their annual dose limit:

Radionuclide Table 2 Effluent

Concentration Limit for Public (µCi/mL)

Solubility Class

Pb-210 6.0 x 10-13 N/A

Ra-226 9.0 x 10-13 N/A

Th-230 2.0 x 10-14 W (more restrictive)

U-nat - 9.0 x 10-13 W (TR 5.7.4)





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6.4 ALARA

Pursuant to 10 CFR 20.1301, the public shall not receive a dose greater than 100 mrem/yr for all routes of exposure. However, the practice of ALARA should render concentrations of effluent to practicable levels below that standard.

ALARA dose constraints are set forth in 20.1101(d) such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 mrem (0.1 mSv) per year from air emissions excluding Rn-222.

To compare the radionuclide concentrations in air to the ALARA limit, the values will be compared to 1/5th (20%) of the Effluent Concentration Limit (ECL) since the ECL limit is based on 50 mrem/yr. The data should be evaluated on a quarterly basis to determine if the ALARA limit is exceeded. If the ALARA limit is exceeded, a report shall be filed to NRC in accordance with 10_CFR 20.2203. The results will be summarized and discussed in the annual ALARA report.

6.5 Quality Assurance/Quality Control

The air sampler will be maintained and calibrated according to SOP_LC_ENV-006: Air Sampler Maintenance and Calibration.

Dust loading on filters may cause a decrease in flow rates. If a reduction in flow rates of more than 10% is observed, the flow data will be compared to flow rates following a filter change to determine if dust loading was the cause. If flow rates are still reduced by greater than 10% at the time of the next filter change, the air sampling unit will be removed from service for maintenance (See SOP_LC_ENV-006).

Analysis of the filters should meet the following detection limits:

Analyte Detection Limit (µCi/mL) U-nat 1x10-16

Ra-226 1x10-16 Th-230 1x10-16 Pb-210 1x10-15





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If the analysis does not meet the detection limits:

• The laboratory should be contacted to determine if the detection limit can be met through reanalysis

• If the detection limits cannot be met, the laboratory should provide a case narrative to include in the analytical report

7.0 DOCUMENTS AND RECORDS

Records associated with the air effluent monitoring program include:

• Field data gathered from the air monitors:

Master HiVol Data Analysis.xlsx

• Analytical data from analytical laboratory which will be kept on file either electronically or hardcopy or both:

HiVol LabResults and Reports

• Calibration data from each air sampling device:

Calibration Records

8.0 REFERENCES

Code of Federal Regulations Title 10 Part 20.1101(d)

Code of Federal Regulations Title 10 Part 20.1302

Code of Federal Regulations Title 10 Part 40.65

NRC License Application Technical Report for the Lost Creek Project, Section 2.9.3.7: Radiological Air Particulate (High-Vol) Sampling, April 2010

NRC License Application Technical Report for the Lost Creek Project, Attachment 2.9-9: Technical Memorandum: Radiological Air Particulate Sampling, January 2009

NRC License Application Technical Report for the Lost Creek Project, Section 5.7.7.1: Operational Radiation Monitoring, April 2010





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NRC Regulatory Guide 4.14: Radiological Effluent and Environmental Monitoring at Uranium Mills, April 1980

NRC Regulatory Guide 8.37: ALARA Levels for Effluents from Materials Facilities, July 1993

SOP_LC_ENV-005: Air Sampler Filter Changes

SOP_LC_ENV-006: Air Sampler Maintenance and Calibration





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Appendix A: Monitoring Locations





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EXAMPLE TABLE X

LOST CREEK AIR SAMPLING DATA AIR PARTICULATE & PASSIVE RADON LOCATIONS

1st and 2nd Quarters 2013

SAMPLE LOCATION SAMPLE PERIOD RADIONUCLIDE

MEASURED CONC.

(uCi/ml)

ERROR EST. +/-

(uCi/ml)

BACKGROUND (BKGD) (uCi/ml)

CALCULATED CONC.

(uCi/ml) L.L.D.

*(uCi/ml)

EFF. CONC. LIMIT

(uCi/ml)

% EFF.CONC.

LIMIT %

AP1/PR1 1st Qtr U-Nat 1.06E-16 N/A

1.00E-16 9.00E-13 0.01 Nearest Residence

Th-230 1.07E-16 1.20E-16

1.00E-16 3.00E-14 0.36

Bairoil, WY

Ra-226 3.32E-17 7.89E-17

1.00E-16 9.00E-13 0.00

Pb-210 1.88E-14 1.75E-15

2.00E-15 6.00E-13 3.13

PR-1

Rn-222 w/ prgny 9.00E-10 9.00E-11 5.00E-10 4.00E-10 3.30E-10 1.00E-10 400.00

2nd Qtr U-Nat

Th-230

Ra-226

Pb-210 PR-1

Rn-222 w/ prgny


1.00E-16 9.00E-13 0.03

Highest Expected

Th-230 1.48E-16 1.55E-16

1.00E-16 3.00E-14 0.49 Adjacent to CPP, East

Ra-226 1.25E-16 1.27E-16

1.00E-16 9.00E-13 0.01

Downwind of CPP

Pb-210 2.00E-16 1.86E-15

2.00E-15 6.00E-13 0.03 PR-5

Rn-222 w/ prgny 2.20E-09 1.50E-10 2.08E-09 1.20E-10 3.30E-10 1.00E-10 120.00

Rn-222 w/o prgny 2.20E-09 1.50E-10 2.08E-09 1.20E-10 3.30E-10 1.00E-08 1.20

2nd Qtr U-Nat

Th-230

Ra-226

Pb-210 PR-5

Rn-222 w/ prgny

Rn-222 w/o prgny


1.00E-16 9.00E-13 0.01 Upwind of CPP

Th-230 2.35E-16 1.37E-16

1.00E-16 3.00E-14 0.78

SW Boundary of LC

Ra-226 7.40E-17 7.53E-17

1.00E-16 9.00E-13 0.01

Pb-210 2.11E-14 1.53E-15

2.00E-15 6.00E-13 3.52

PR-2

Rn-222 w/ prgny 2.20E-09 1.50E-10 2.08E-09 1.20E-10 3.30E-10 1.00E-10 120.00

2nd Qtr U-Nat

Th-230

Ra-226

Pb-210 PR-2

Rn-222 w/ prgny

AP4/PR-10 1st Qtr U-Nat 1.00E-16 N/A

1.00E-16 9.00E-13 0.01

Downwind of CPP

Th-230 1.95E-16 1.74E-16

1.00E-16 3.00E-14 0.65 E Boundary of LC

Ra-226 -1.78E-17 1.08E-16

1.00E-16 9.00E-13 0.00

Pb-210 1.48E-14 1.89E-15

2.00E-15 6.00E-13 2.47

PR-10

Rn-222 w/ prgny 1.00E-09 9.00E-11 2.08E-09 -1.08E-09 3.30E-10 1.00E-10 < bkgd

Rn-222 w/o prgny 1.00E-09 9.00E-11 2.08E-09 -1.08E-09 3.30E-10 1.00E-08 < bkgd

PR-10DUP

Rn-222 w/ prgny 1.40E-09 1.10E-10 2.08E-09 -6.80E-10 3.30E-10 1.00E-10 < bkgd PR10&DUP RPD= 33.3% Rn-222 w/o prgny 1.40E-09 1.10E-10 2.08E-09 -6.80E-10 3.30E-10 1.00E-08 < bkgd

2nd Qtr U-Nat

Th-230

Ra-226

Pb-210 PR-10

Rn-222 w/ prgny

Rn-222 w/o prgny PR-10DUP

Rn-222 w/ prgny

PR10&DUP RPD= #DIV/0! Rn-222 w/o prgny

SAMPLE LOCATION SAMPLE PERIOD RADIONUCLIDE

MEASURED CONC.

(uCi/ml)

ERROR EST. +/-

(uCi/ml)

BACKGROUND (BKGD) (uCi/ml)

CALCULATED CONC.

(uCi/ml) L.L.D.

*(uCi/ml)

EFF. CONC. LIMIT

(uCi/ml)

% EFF.CONC.

LIMIT % AP5/PR-3 1st Qtr U-Nat 1.26E-16 N/A

1.00E-16 9.00E-13 0.01

Upwind of CPP

Th-230 1.61E-16 1.37E-16

1.00E-16 3.00E-14 0.54 NW Boundary of LC

Ra-226 1.18E-16 8.96E-17

1.00E-16 9.00E-13 0.01

Pb-210 2.07E-14 1.74E-15

2.00E-15 6.00E-13 3.45

PR-3

Rn-222 w/ prgny 2.00E-09 1.40E-10 2.08E-09 -8.00E-11 3.30E-10 1.00E-10 < bkgd

2nd Qtr U-Nat

Th-230

Ra-226

Pb-210 PR-3

Rn-222 w/ prgny

PR-4 1st Qtr Rn-222 w/ prgny 2.10E-09 1.40E-10 2.08E-09 2.00E-11 3.30E-10 1.00E-10 20.00 N of CPP, 100m


2nd Qtr Rn-222 w/ prgny

Rn-222 w/o prgny

PR-6 1st Qtr Rn-222 w/ prgny 1.80E-09 1.30E-10 2.08E-09 -2.80E-10 3.30E-10 1.00E-10 < bkgd NE Boundary of LC


Downwind of CPP 2nd Qtr Rn-222 w/ prgny

Rn-222 w/o prgny

PR-7 1st Qtr Rn-222 w/ prgny 2.00E-09 1.40E-10 2.08E-09 -8.00E-11 3.30E-10 1.00E-10 < bkgd W Boundary of LC 2nd Qtr Rn-222 w/ prgny

Upwind of CPP

PR-8 1st Qtr Rn-222 w/ prgny 1.90E-09 1.40E-10 2.08E-09 -1.80E-10 3.30E-10 1.00E-10 < bkgd S Boundary of LC 2nd Qtr Rn-222 w/ prgny

Upwind of CPP

PR-9 1st Qtr Rn-222 w/ prgny 2.30E-09 1.50E-10 2.08E-09 2.20E-10 3.30E-10 1.00E-10 220.00 In Mine Unit


S of CPP 2nd Qtr Rn-222 w/ prgny

Rn-222 w/o prgny

PR-11 1st Qtr Rn-222 w/ prgny 2.30E-09 1.50E-10 2.08E-09 2.20E-10 3.30E-10 1.00E-10 220.00 S Boundary of LC 2nd Qtr Rn-222 w/ prgny

Upwind of CPP

PR-12 1st Qtr Rn-222 w/ prgny 1.90E-09 1.40E-10 2.08E-09 -1.80E-10 3.30E-10 1.00E-10 < bkgd SSE Boundary of LC


Over Ore Trend 2nd Qtr Rn-222 w/ prgny

Rn-222 w/o prgny

*LLD for radon is based on a 90 day sample collection time

Documents

ENVIRONMENTAL RADIOLOGICAL MONITORING: AIR … · 2019-07-12 · The purpose of this Standard Operating Procedure (SOP) is to detail the program for air sampling associated with environmental