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Mr. H. Bruce Humphries September 12, 1996 Page 2 of WDEQ/LQD Guideline No. 3, Radiological Survey, is enclosed. The United States Nucleaz Regulatory Commission ("NRC") has published a Manual for Conductine Radiological Survey in Support of License Termination (NUREG/CR-58 ORAV-93/C57, 1992), which describes processes for conducting radiological surveys during decommissioning to demonstrate that residual radioactivity satisfies the criteria established by the NRC for termination of a license. Although the approaches detailed in NUREG/CR-58 aze designed for substantially rnore complex situations involving NRGlicensed material, the general concept of a survey approach is valid and technically sound. A copy of NUREG/CR-58 is enclosed. The Texas Regulations for Control of Radiation ("TRCR") were adopted by the Texas Boazd of Health in accordance vr;th the Texas Radiation Control Act (Chapter 401, Health and Safety Code, as amended by Chaprters 172, 840, 913, and 930, Acts of the 71st Legislative, Regulaz Session, 1989). These rules ar-e compatible with those of the U.S. NRC and of other states (such as Colorado) who have entered into a contractual agreement with the Commission. Part 43 applies to licensing of uranium recovery operations (i.e., mills or in-situ mining operations). Section 43.3, Expiration and Termination of License specifies requirements for radiation survey(s) in support of license termination at 43.32(d)(iii). A copy of TRCR Part 43 is attached. Please note [hat the survey we propose to perform is consistent with the more simple methods described by WDEQ/I.QD for mine properties, and will involve measurement equipment appropriate for the type of material being surveyed. A description entitled Use of Probes for the Determination of Uranium Grade is enclosed. As the method described is the one that EFN has used for some 30 years, and the one that we plan to use when we start back up to m:ilce economic and business decisions, we believe it will be more than adequate to determine the average uranium content of rocks present at the Sunday and West Sunday Mines. As discussed in our meeting, EFN intends to implement the field program described above on Tuesday, September 24. Provided that analytical results can be obtained in a timely manner, we anticipate submitting a report to the Division on or azound November 1, 1996. I can be reached at (303) 899-5647. Sincerely, r!~/~ c /~'~C-tom/ /':c.. Michelle R. Rebmann Environmental Manager MRR/pl cc: Hazold R. Roberts Rick A. Van Horn Rich A. Munson