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5.0 COMPLIANCE MONITORING AND REPORTING <br />Radon-222 levels will be monitored at the ventilation exhaust points at the Whirlwind <br />Mine on a continual basis. Volumetric flow rates will be measured adjacent to the radon- <br />222 measurement locations on a periodic basis. Total radon-222 emissions from each <br />exhaust vent will be calculated for each calendar year. The COMPLY-R computer model <br />will be used to estimate the dose from radon-222 to the nearest receptor based on the <br />amount of radon-222 emitted from each vent and several other factors. The monitoring <br />data and model input and output will be summarized in an annual compliance report and <br />submitted to U.S. EPA by March 31 of the following year. <br />5.1 Radon-222 Monitoring <br />Radon-222 will be monitored at each emission point on a continuous basis. Energy Fuels <br />requests a conditional approval to use alpha track type radon-222 detectors (ATDs, <br />Method A-7). ATDs would be placed in each mine exhaust stream near the emission <br />point (e.g., vent shaft, portal) and changed out on a monthly basis. More frequent <br />change-outs may be necessary during changes in the ventilation system (e.g., the addition <br />of the Packrat ventilation drift). The approval for use of ATDs would be conditional <br />upon these types of detectors being proven as comparable to Method A-6 at similar mines <br />in the area. Energy Fuels feels the use of ATDs is appropriate given the anticipated <br />radon levels in regional mines, that it is the current method used in the industry and has <br />been previously used in Colorado for reporting purposes by Cotter Corporation at its <br />Schwartzwalder Mine and Denison Mines Corporation at its Sunday Mine complex. <br />Denison Mines is currently seeking approval to use these types of detectors at their U.S. <br />uranium mines. Energy Fuels anticipates that Denison Mines will be able to show that <br />Method A-7 produces comparable results to Method A-6 for similar regional uranium <br />mines (e.g., Sunday Mine Complex) with ore deposits in the same formation as the <br />Whirlwind Mine prior to mining of ore from the Whirlwind Mine. <br />If Denison Mines is unable to or does not show demonstrate the adequacy of Method A-7 <br />prior to Energy Fuels resuming production at the Whirlwind Mine, Energy Fuels would <br />collect radon concentrations by Methods A-6 and A-7, side-by-side for the initial three <br />months of mine production. Method A-6 involves collection using a continuous gas <br />monitor. Energy Fuels anticipates using a Pylon Electronics, Inc. model CRM-2 Area <br />Monitor, Environmental Instruments Canada model VS472 Radon Sniffer, or equivalent <br />device. These devices are scintillation cell-type continuous radon monitors. <br />18