strata energy, inc., ross in-situ recovery project january ...january -june 2016 semi-annual report...

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Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 August 26th, 2016 Deputy Director, Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-8F5, 11545 Rockville Pike Rockville, MD 20852-2738 Re: Strata Energy, Inc., Ross In Situ Recovery Project Source Materials License SUA-1601, Docket No. 040-09091 January - June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual Report for the period of January 1 5 \ 2016 through June 30th, 2016. This report satisfies the requirements of 10 CFR 40.65 and the applicable license conditions of Source Material License SUA-1601. Please contact me if you have any questions regarding this report. You can reach me at (307) 467-5995 or [email protected]. Sincerely, Strata Energy, Inc. . n in Vice President of Permitting, Regulatory and Environmental Compliance

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Page 1: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Document Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

August 26th, 2016

Deputy Director, Division of Decommissioning, Uranium Recovery and Waste Programs

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Mail Stop T-8F5, 11545 Rockville Pike

Rockville, MD 20852-2738

Re: Strata Energy, Inc., Ross In Situ Recovery Project

Source Materials License SUA-1601, Docket No. 040-09091

January - June 2016 Semi-Annual Report

To Whom It May Concern:

Strata Energy Inc. (Strata) hereby submits this Semi-Annual Report for the period of January 15\

2016 through June 30th, 2016. This report satisfies the requirements of 10 CFR 40.65 and the applicable license conditions of Source Material License SUA-1601.

Please contact me if you have any questions regarding this report. You can reach me at (307) 467-5995 or [email protected].

Sincerely,

Strata Energy, Inc .

. /}(/~~I'_ ~G(l_;Y-·

Micha~l n in

Vice President of Permitting, Regulatory and Environmental Compliance

Page 2: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Strata Energy, Inc.

Ross ISR Project

Source Material License Number SUA-1601

Docket Number 040-09091

Semi-Annual Effluent and Environmental Monitoring Report

January 1st - June 30th, 2016

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TABLE Of CONTENTS

1 INTRODUCTION ......................................................................................................................... 1

1.1 Activities Summary ....................................................................................................................... 1

2 LICENSE CONDITION 10.8(D)-QUARTERLY INSPECTION OF LINED RETENTION PONDS ................. 1

2.1 Inspection Summary ..................................................................................................................... 1

3 LICENSE CONDITION 10.8(E) -ANNUAL TECHNICAL INSPECTION OF LINED RETENTION PONDS .... 2

3.1 Inspection Summary ..................................................................................................................... 2

4 LICENSE CONDITION 11.l(C) - OPERATIONAL MONITORING ........................................................ 2

4.1 Status of Wellfields in Operation .................................................................................................. 2

4.2 Progress of Wellfields in Restoration ............................................................................................ 2

4.3 Status of Long Term Excursions .................................................................................................... 3

4.4 Summary of Mechanical Integrity Tests ....................................................................................... 3

4.4.1 FirstQuarter .......................................................................................................................... 3

4.4.2 Second Quarter ..................................................................................................................... 3

5 LICENSE CONDITION 11.l(D) - ENVIRONMENTAL MONITORING .................................................. 3

5.1 Air Particulates .............................................................................................................................. 4

5.2 Direct Radiation ............................................................................................................................ 5

5.3 Radon ............................................................................................................................................ 5

5.4 Soil ................................................................................................................................................. 5

5.5 Sediment ....................................................................................................................................... 6

5.6 Groundwater ................................................................................................................................. 6

5.6.1 Private Water Supply Wells ................................................................................................... 6

5.6.2 Industrial Wells ..................................................................................................................... 7

5.7 Surface water ................................................................................................................................ 7

6 LICENSE CONDITION 11.l(D) - OPERATIONAL EFFLUENT MONITORING ....................................... 8

6.1 Effluents due to Air Particulates ................................................................................................... 8

6.1.1 Plant ...................................................................................................................................... 8

6.1.2 Wellfield ................................................................................................................................ 9

6.2 Effluents due to Radon and Radon Progeny ............................................................................... 10

6.2.1 Plant .................................................................................................................................... 10

6.2.2 Wellfield .............................................................................................................................. 11

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6.2.3 Unplanned releases ............................................................................................................. 12

6.3 Background ................................................................................................................................. 12

6.4 Total Quantities Released ........................................................................................................... 13

6.4.1 Quantity of Air Particulate Effluent ..................................................................................... 13

6.4.2 Quantity of Radon and Radon Progeny Effluent ................................................................. 13

6.4.3 Conclusion ........................................................................................................................... 13

7 LICENSE CONDITION 11.2 -ANNUAL REVIEW OF RADIATION PROTECTION PROGRAM ............... 14

7.1 Annual Review of Radiation Protection Program ....................................................................... 14

7.2 Public Dose .................................. : ............................................................................................... 14

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1 INTRODUCTION

Pursuant to 10 CFR 40.65 and Source Material License SUA-1601, Strata Energy, Inc. (Strata) has prepared this Semi-Annual Report which summarizes the operational and environmental activities at the Ross Project. The report includes that information required by License Conditions 11.1 and 11.2, as applicable. This report covers the time period of January 1•t-June 30th, 2016.

1.1 ACTIVITIES SUMMARY

Strata commenced uranium recovery operations at the Ross Project on December 2"d, 2015. One wellfield, Mine Unit 1, has been approved by the appropriate regulatory agencies and the Strata Safety and Environmental Review Panel (SERP) and is currently in operations. No other wellfields are in either active or restoration status at the Ross Project.

Drilling, well construction, mechanical integrity testing, and hole plugging activities were continued in Mine Units 1 and 2 during the reporting period.

The monitoring for air particulates, direct radiation, and radon continued at the environmental monitoring stations. Surface water sampling continued at the three surface water monitoring stations and at applicable reservoirs. Groundwater monitoring continued for the wells specified in SUA-160l.

2 LICENSE CONDITION 10.8(0) RETENTION PONDS

2.1 INSPECTION SUMMARY

QUARTERLY INSPECTION OF LINED

There is currently one constructed lined retention pond at the Ross Project. This lined retention pond (Pond 1) is separated into three cells. There is currently byproduct material being stored in only one of the cells, Cell 3. Two quarterly inspections of Pond 1 occurred during the inspection period and are attached in Appendix B. The inspections occurred on 2/10/2016 and 5/18/2016. The results of the inspections indicate that all embankments are in good condition, there have been no leaks in the liner of Cell 3, and all systems and components are in good condition.

On April 25, 2016 a sample from Pond Monitor well Pl-C3 exceeded an action level (AL) by more than 20%. The chloride concentration in pond monitor well Pl-C3 was measured at 13.3 mg/L from the monthly sample obtained on April 25, 2016. Strata collected a verification sample on April 26, 2016, which had a concentration of 14.0 mg/L, confirming the action level was exceeded. The other indicator parameters were below their respective action levels and similar to previously measured concentrations. As required in the Groundwater Detection Monitoring Program (GWDMP), Strata has obtained weekly samples from all Pond 1 monitor wells since the exceedance in April. The results indicate that the elevated chloride level is likely due to natural seasonal variation in the groundwater quality. At the end of July, 2016, Strata will have one full year of data from the pond monitor wells and will evaluate the feasibility of updating background water quality and associated Als to account for the natural variation in the shallow groundwater quality. An initial report and a 60-day report were submitted to NRC as required by SUA-1601.

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Section 5.3.2.3 of the Technical Report {TR) of the approved License Application states that during the quarterly inspection the "Instrumentation and safety equipment will be tested to ensure proper operation. Recent readings of the instrumentation will be reviewed to detect unusual performance or distress of the embankment." Instrumentation for detecting unusual performance or distress of the embankment was not a part of the approved lined retention pond design and thus was not installed. Therefore this item was not available for inspection during the quarterly inspections. This commitment will be removed from the TR during the next revision if the Safety and Environmental Review Panel (SERP) determines that the revision does not need a license amendment.

Small erosion patterns discovered on the east embankment during the second quarter inspection were addressed on 6/16/2016 when an outside contractor performed minor earthwork on the embankment. The contractor filled and compacted the areas of concern. The erosion was minimal and due to surface water runoff, with the majority of the erosion being small channels roughly 2 inches wide by 2 inches deep. The main erosion pattern of concern was an estimated foot deep. Strata anticipates seeding or performing other erosion control techniques on the embankments of the ponds.

3 LICENSE CONDITION 10.S(E) - ANNUAL TECHNICAL INSPECTION OF UNED

RETENTION PONDS

3.1 INSPECTION SUMMARY

An annual technical inspection of the lined retention ponds was conducted on 5/26/2016 by the contractor WWC Engineering. The report of the inspection is included as Appendix C to this document.

4 LICENSE CONDITION 11.l{C) - OPERATIONAL MONITORING

4.1 STATUS OF WELLFIELDS IN OPERATION

There is currently one wellfield in operation, Mine Unit 1. There are currently four header houses in operation in Mine Unit 1 and the start dates for each are listed below.

• Header house 1- December 2"d, 2015 • Header house 2 - February 12th, 2016 • Header house 3 - May 161

h, 2016 • Header house 4 - June ih, 2016

The drilling of wells for Mine Unit 2 is currently being conducted.

4.2 PROGRESS OF WELLFIELDS IN RESTORATION

There are no wellfields in restoration at the Ross Project.

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4.3 STATUS OF LONG TERM EXCURSIONS

No excursions have occurred at the Ross Project.

4.4 SUMMARY OF MECHANICAL INTEGRITY TESTS

4.4.1 First Quarter

90 MUl wells located in Section 18 T53N R67W passed mechanical integrity test (MIT) during the period. Included in these 90 wells is OZ 209 which passed MIT in the first quarter, was damaged at the surface, repaired, and passed MIT again. Also included are OZ 190, 207, 208, 209, and 243 which were re-underreamed to enhance flow and passed a second MIT. OZ 224, 226, 283, 258, 294, and 269 failed the initial MIT, were repaired and passed the subsequent MIT.

6 MU2 monitor wells passed the MIT in the first quarter. 4 of the wells are located in Section 18 T53N R67W and 2 wells are located in Section 13 T53N R68W.

4.4.2 Second Quarter

30 MUl wells located in Section 18 T53N R67W passed mechanical integrity test (MIT) during the period. Included in these 30 wells is OZ 288 which failed the initial MIT but passed after resetting the bottom packer. Also included are OZ 81 and 281 which were worked over to enhance flow and passed a second MIT. OZ 318 was repaired and passed the subsequent MIT.

89 MU2 baseline/monitor wells passed the MIT in the second quarter. 37 of the wells are located in Section 18 T53N R67W, 28 wells are located in Section 13 T53N R68W, 13 wells are located in Section 07 T53N R67W, and 11 wells are located in Section 12 T53N R68W. Three wells (OW1B60-1, OW1B57-1, and OW1B58-1) were part of the Ross Regional Monitor wells. OW1B60-1 failed the initial test, was repaired and passed the subsequent test. Seven wells (DM 18, DM 7, OZ 21A, DM 10, DM 13, and DM 15) failed the initial test, were repaired, and passed the subsequent test. Five wells (OZ 10, DM 10, OZ 4, DM 4, and DM11) were re-tested as a check after the initial pump test. All wells passed the MIT again.

5 LICENSE CONDITION 11.l(D) - ENVIRONMENTAL MONITORING

Source Material License SUA-1601 License Condition 10.9 requires Strata to conduct an effluent and environmental monitoring program in accordance with the programs described in the approved license application. Sections 5.7.7 and 5.7.8 of the Technical Report (TR) of the approved License Application delineate the operational effluent and environmental monitoring which will occur at the Ross Project.

Strata currently has six environmental monitoring stations. The monitoring stations have a continuous air sampler for measuring the concentration of air particulates, a dosimeter to measure direct radiation, and a detector for measuring radon gas in air. The locations of the monitoring stations are consistent with the recommendation set forth in Regulatory Guide 4.14 and are discussed in detail in the TR Section 2.9.2.4.

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The environmental monitoring station names and descriptions are as follows:

• "Oshoto" - This location is Northeast and downwind of the facility. It is near a private residence; • "Met Station" - This location is Northwest of the facility and is located at the site of the

meteorological station; • "Southwest" - This location is Southwest and upwind of the facility. Per the TR Section 2.9.2.4,

this location is the designated "background location"; • "East" - This location is East of the facility; • "South" - This location is South and upwind of the facility; and • "North" - This location is North and downwind of the facility. The MILDOS-AREA computer

model results show that this location is the "maximally exposed member of the public".

5.1 AIR PARTICULATES

Strata conducts continuous air sampling to determine particulate concentrations in air. The air particulate sampling is conducted according to TR Section 5.7.7.1.1 and NRC Regulatory Guide 4.14 Section 2.1.2. The samples are collected weekly, or more often as required by dust loading, and composited for analysis on a quarterly basis. The samples are sent to an accredited contract laboratory for analysis for total uranium, Ra-226, Th-230, and Pb-210. The air sampling is currently conducted at the six environmental monitoring stations discussed above.

The operational air particulate sampling continued for all six sites during the reporting period. The results from the air particulate sampling are summarized in Appendix A, Table 1. The appropriate values from 10 CFR 20 Appendix B Effluent Concentration Limits for comparison and the appropriate Lower Limits of Detection (LLD) are also included in Appendix A, Table 1. The lower limits of detection are those specified in Regulatory Guide 4.14. The 10 CFR 20 Appendix B Table 2 values associated with class "W" were used for Natural Uranium and Th-230.

A review of the data indicates that the air particulate concentrations are consistent with concentrations obtained during the preoperational monitoring period and during 2015.

On 5/6/2016, the outside contract laboratory which performs the radiochemical analysis of the submitted composite air filters informed Strata that they had discovered an error in a calculation used in determining the activity concentrations on the filters for the 3rd and 4th quarters, 2015. The laboratory discovered the error during the analysis of the 1•t quarter, 2016 air filters. The air samplers used in Strata's environmental monitoring for air particulates display the total volume of air sampled during the sampling period. The volume displayed is the volume sampled if in an environment of standard temperature and pressure. Strata submits this volume to the laboratory with the air filters. The discovered error was in the calculation used to convert from the standard volumes to the actual volumes sampled by using the actual temperature and pressure data obtained from Strata's meteorological station. The laboratory stated that the error caused the reported volumes of air sampled to be overestimated, thus underestimating the activity concentration. The laboratory issued revised reports with the corrected volumes of air sampled and resulting activity concentrations on 5/16/2016.

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The error in the calculation resulted in a maximum percent difference of 12.5% between the activity concentration in the corrected report and what was reported previously. Additionally, all air particulate concentrations are at or near background levels with the highest revised activity concentration on the filters being 4.2% of the effluent concentration. An analysis on the difference in the initial report and the corrected report is contained in Appendix D. The revised concentrations for the 3'd and 4th quarters, 2015 are contained in Appendix E.

5.2 DIRECT RADIATION

Strata conducts a direct radiation monitoring program to monitor the direct radiation levels at the six environmental monitoring stations discussed above. The direct radiation levels are measured using environmental low level thermoluminescent dosimeters (TLDs). The TLDs are exchanged quarterly and sent to Landauer, a NVLAP-accredited company, for analysis. The direct radiation monitoring program is conducted according to the TR Section 5.7.7.1.1 and NRC Regulatory Guide 4.14 Section 2.1.6. The dosimeters were deployed from December 31st through March 31st for the first quarter and from March 31st through July gth for the second quarter.

A summary of the data obtained from the radiation monitoring program for the reporting period is included in Appendix A, Table 2. Data is presented as net readings as the reading from the control dosimeter has been subtracted. The values assigned to the control dosimeters for the first and second quarters are also included in Table 2 for informational purposes.

A review of the data indicates that the results are consistent with those obtained during 2015 and during the preoperational monitoring period.

5.3 RADON

Strata conducts continuous monitoring for radon gas in accordance with the TR Section 5.7.7.1.1 and NRC Regulatory Guide 4.14 Section 2.1.2. The radon gas is measured using Landauer's high sensitivity environmental radon Trak-Etch detectors. The detectors are exchanged quarterly and sent to Landauer for analysis. The detectors are placed at the six environmental monitoring stations described above. The detectors were deployed from December 31st through March 31st for the first quarter and from March 31st through July gth for the second quarter. A summary of the data obtained from the radon gas monitoring is included in Appendix A, Table 3. The 10 CFR 20 Appendix B Table 2 effluent concentration value of 1.00E-10 uCi/mL for radon with daughters present is also included in Table 3 for comparison.

A review of the data shows that the concentrations are consistent with those obtained during 2015 and during the preoperational monitoring period.

5.4 SOIL

Strata conducts soil sampling on an annual basis at the sites of the six environmental monitoring locations. The soil samples are collected according to the procedures outlined in the TR Section 5.7.7.1.2 and NRC Regulatory Guide 4.14 Section 2.1.5. The samples are analyzed for total uranium, Ra-226, Pb-

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210, and gross alpha. Soil samples were not taken during the reporting period and will be collected in the second half of 2016.

5.5 SEDIMENT

Strata conducts sediment sampling on an annual basis at the three surface water monitoring stations and at applicable reservoirs within the project area. The sediment samples are collected according to the procedures outlined in the TR Section 5.7.7.1.2 and NRC Regulatory Guide 4.14 Section 2.1.5. The samples are analyzed for total uranium, Th-230, Ra-226, Pb-210, and gross alpha. Sediment samples were not taken during the reporting period and will be collected in the second half of 2016.

5.6 GROUNDWATER

5.6.1 Private Water Supply Wells

Strata conducts monitoring of private water supply wells in accordance with the License Condition 11.1 D), the TR Section 5.7.8.2, and NRC Regulatory Guide 4.14 Section 2.1.3. All wells which are currently in use for domestic, agricultural and livestock purposes and within 2 kilometers of the monitor well ring for active mine units are sampled quarterly and sent to an accredited contract laboratory for analysis for dissolved and suspended uranium, Ra-226, Th-230, Pb-210, Po-210, gross alpha, and gross beta.

Nine private water supply wells were within 2 kilometers of the monitor well ring for MU1 during the reporting period. Sampling occurred on 2/12/2016 for the first quarter and 5/4 - 5/5/2016 for the second quarter.

One well, HBWELL05, was not sampled during the reporting period as the pump infrastructure has not been maintained to suitable standards for obtaining a sample. Sampling will resume at the well once the landowner upgrades the equipment. Two other wells, P50883W and TWWELL03, were not sampled during the first quarter of 2016 as the wells were shut-in for the winter. On 7 /20/2016, Strata self­identified a potential violation of a NRC license condition. It was determined that samples were not obtained from wells P50883W and TWWELL03 during the second quarter of 2016. A document outlining the self-identified violation and corrective actions is available for inspection. Results from six private water supply wells are contained in this report as samples were not obtained from the three wells discussed above.

A summary of the results from the monitoring for the reporting period are included in Appendix A, Table 4. The lower limits of detection and the 10 CFR 20 Appendix B Table 2 values for each radionuclide of interest are included in Appendix A, Table 7.

A review of the data indicates that all parameters are below the applicable effluent concentration limits and all but two results are consistent with results obtained during the 2015 reporting period and preoperational monitoring. The two exceptions are wells CSWELL01 and DWWELL01. Well CSWELL01

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yielded a Pb-210 (dissolved) concentration at 54% of the effluent concentration and DWWELLOl yielded a Pb-210 (suspended) concentration at 40% of the effluent concentrations. These two wells will be monitored in subsequent reporting periods for these concentrations.

5.6.2 Industrial Wells

Strata conducts monitoring of industrial wells used for oil field water flood purposes in accordance with License Condition 10.19 and the TR Section 5.7.8.2. The industrial wells are sampled on a monthly basis when those wells are near active wellfields in accordance with License Condition 10.19 and the samples are sent to an accredited contract laboratory for analysis for dissolved and suspended uranium, Ra-226, Th-230, Pb-210, Po-210, gross alpha, and gross beta. Two industrial wells were sampled during the reporting period, wells 19XX18 and 22X-19. A summary of the results from the monitoring for the reporting period are included in Appendix A, Table 5. The lower limits of detection and the 10 CFR 20 Appendix B Table 2 values for each radionuclide of interest are included in Appendix A, Table 7.

A sample was not collected for industrial well 22X-19 on 2/12/2016, 4/22/2016, and 5/4/2016 as there was no water in the well at the time of sampling. Samples were not obtained for either 22X-19 or 19XX18 during the month of June as there was no water in either well at the time of sampling.

A review of the results indicates that most concentration levels are similar to the results obtained during 2015. For industrial well 19XX18, the Ra-226 (dissolved) levels have remained consistently near 60% of the effluent concentration. The Pb-210 (dissolved) concentration levels have remained at the levels obtained from the second half of 2015, but the Pb-210 (suspended) concentration levels were found to be at 137% of the effluent concentration. This value is similar to the value found for Pb-210 (dissolved) in the first half of 2015. An additional parameter, Po-210 (suspended), was elevated this reporting period at 121.5% of the effluent concentration. Previous sampling has indicated Po-210 (suspended) concentrations at 33.8% (first half of 2015) and 42.8% (second half of 2015) of the effluent concentration. It is unclear as to the reason for the increase in concentration at this well. However, it is likely that it is fluctuation of natural background and not due to mining operations. Additionally, the Po-210 (dissolved) concentration is reported at 7.2% of the effluent concentration. All concentration levels in well 22X-19 are at similar levels to those obtained during previous reporting periods.

5.7 SURFACE WATER

Strata conducts monitoring of surface waters in accordance with the TR Section 5.7.8.2. All surface water features that lie within the license boundary and that may be impacted by operations are sampled and analyzed for dissolved and suspended uranium, Ra-226, Th-230, Pb-210, Po-210, gross alpha, and gross beta. The samples are collected quarterly, when available. For the reporting period, the site labeled "Oshoto Reservoir" was the only site which was potentially impacted by operations. A sample was collected on 5/4/2016. A sample was not collected during the first quarter of 2016 as no sample was able to be obtained due to the frozen lake. A summary of the results from the monitoring for the reporting period are included in Appendix A, Table 6. The lower limits of detection and the 10 CFR 20 Appendix B Table 2 values for each radionuclide of interest are included in Appendix A, Table 7.

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Strata additionally has three ISCO flowmeters/samplers located along waterways which collect samples of surface water when a pre-identified flow rate of the waterway is attained. The samplers are run from April through October. No samples were obtained from the ISCO samplers during the reporting period. However, Strata obtained grab water samples from these locations as recommended in Regulatory Guide 4.14. The samples were obtained on 5/4/2016, sent to an outside accredited laboratory, and analyzed for gross alpha, gross beta, and dissolved and suspended uranium, Ra-226, Th-230, Pb-210, and Po-210. A summary of the results are included in Appendix A, Table 6. The concentration of Pb-210 (suspended) at the site SW-2 is 42% of the effluent concentration limit; however, the Pb-210 (dissolved) value was found to be non-detect. The concentration of Pb-210 will be monitored at this location for an increasing trend.

6 LICENSE CONDITION 11.l(D) - OPERATIONAL EFFLUENT MONITORING

Strata's effluent monitoring program was approved by the NRC by verification letter dated November 19th, 2015 (ADAMS accession number: ML15302A405). As operations at the facility began on December 2"d, 2015, the quantity of effluent released during the month of December 2015 is also included in this report. It was not reported in the second half of 2015 as data required for determining the quantity of effluent released had not yet been received. This issue has continued over into this reporting period due to the large number of header houses placed into operation during the reporting period. As the track­etch devices require a placement of 3 months to meet the LLD and as the air particulate samples from each header house are composited and submitted semi-annually, header houses 2, 3, and 4 were in operation during the reporting period yet data is not yet available for them. It can be assumed that the quantity of effluent released from header houses 2, 3, and 4, and the wells associated with those header houses, will be similar to the data obtained for header house 1. The quantity of effluent released from header houses 2, 3, and 4 for this reporting period will be reported with the next semi-annual report when the data is available.

Strata will utilize the following method to address the issue of an average concentration for header houses when a header house is not in operation for the duration of the reporting period. If a header house is in operation for only a portion of the reporting period then that header house will be treated separately such that the concentrations found for that header house will be multiplied by the length of time the header house was in operation and then summed with the effluent emitted from those header houses in constant operation during the reporting period. The concentration will then be averaged with the concentrations of the other header houses in subsequent reports when that header house is in operation for the duration of the reporting period.

6.1 EFFLUENTS DUE TO AIR PARTICULATES

6.1.1 Plant

In order to measure the quantity of effluent released from the processing facility as air particulates, Strata submits quarterly composite samples obtained from periodic air sampling events at three locations within the processing facility to an outside accredited laboratory. The composite samples are

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analyzed for the radionuclides of concern, namely U-Nat, Th-230, Ra-226, and Pb-210. The three locations are the Ion Exchange Area, the Reverse Osmosis Area, and the Laboratory. The reported concentrations are averaged across the three locations and then multiplied by the design air ventilation rate of the processing facility and the length of time in the reporting period to determine the total quantity of effluent released in the form of air particulates from the processing facility.

The time periods for the two quarters are from December 2"d, 2015 to February 29th, 2016 and from March 1•t to May 31•t, 2016. This is a total time of 90 days for the first quarter and 92 days for the second quarter. Note that the times of the quarterly composites are not in congruence with the calendar quarters due to operations starting on December 2"d. In order to mitigate this problem, the samples for the third quarter will be extended to the end of September such that a calendar quarter schedule can be subsequently maintained. The design ventilation rate of the exhaust system is 40,000 CFM. A conversion factor of 1 cubic foot equaling 28,316.8 ml was used in estimating effluent released. An example of how the total effluent released was calculated will be for U-Nat for the first quarter. The net average concentration was found to be 7.9E-15 uCi/mL. This number was multiplied by the ventilation rate (40,000 CFM * 28,316.8 ml/cubic foot = 1.13E9 ml/minute) and the time (90 days * 1,440 minutes/day= 1.3E5 minutes) to yield the effluent released (7.9E-15 uCi/mL * 1.13E9 ml/minute * 1.3E5 minutes = 1.2E-6 Ci).

The results are displayed in Appendix A, Table 8. A review of the data shows that due to the minute concentrations of air particulates in the plant, the total quantity released is minimal.

6.1.2 'vVellfield

Wellheads are not considered sources of air particulates and Strata's deep disposal well building only contains a sealed wellhead and no ventilation system, thus the other point and diffuse sources of air particulates at the Ross Project are the header houses. Monthly air particulate samples are obtained from each header house and submitted as a composite sample to an outside accredited laboratory. The composite samples are submitted semi-annually and analyzed for U-Nat, Ra-226, Th-230, and Pb-210. The results are averaged to determine the average concentration of air particulates in the header houses. This average concentration is then multiplied by the design ventilation rate of the two ventilation fans in each header house, the time of the reporting period, and the number of header houses to determine the total quantity of effluent released in the form of air particulates due to operations in the wellfield.

Each ventilation fan in the header house is rated at 167 CFM (4.7E6 ml/minute). There are two ventilation fans in each header house. The period that the samples were composited over is December 2"d, 2015 to May 315

\ 2016, for a time of 182 days. As discussed above, in order to synchronize with the calendar semi-annual time period and to be consistent with the reporting period of the reports, the samples from header houses started during this reporting period will be composited until December 315

\ 2016. Subsequent composites will follow the calendar and reports semi-annual period.

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The results are displayed in Appendix A, Table 9. As header house 1 is the only header house to have been in operation during the duration of the reporting period, the effluent reported in Table 9 is not accurate of actual effluent released during the reporting period. However, as gross alpha analysis of monthly samples from each header house indicates that the concentrations in header houses 2, 3, and 4 are similar to header house 1, it can be assumed that the effluent from these header houses will be similar to those found for header house 1. The calculated effluent emitted from these three header houses will be submitted in the next semi-annual report as the results of the analysis on the composite samples will have been received at that time.

6.2 EFFLUENTS DUE TO RADON AND RADON PROGENY

The term radon progeny refers to the long lived decay products of Rn-222. Strata will assume equilibrium between radon and radon progeny.

6.2.1 Plant

To determine the quantity of effluent released from the plant as radon and radon progeny, Strata has committed to obtaining periodic samples of process fluid and analyzing the solution for the quantity of Rn-222. Samples are obtained from the recovery and injection solutions and sent to an outside accredited laboratory for analysis of the concentration of Rn-222. The concentration of Rn-222 is multiplied by the average process fluid flow for the time period to determine the quantity per unit time of Rn-222 which was in the processing facility on the recovery side and the quantity per unit time on the injection side. The quantity per unit time of Rn-222 from the injection portion is subtracted from the quantity per unit time of Rn-222 from the recovery portion and the resulting number is designated as the "loss term". This loss term is multiplied by the time period covered by the sampling to yield a total quantity released. Thus this method determines the effluent released by assuming that a drop in the concentration of Rn-222 from the recovery portion to the injection portion is being released inside the plant and subsequently exhausted to the outside.

In order to determine the average process fluid flow for a month, the daily flow rates for the injection and recovery solutions were averaged for the month. The daily flow rates were recorded as gallons per minute, thus the conversion factor of 1 gallon = 3,785 milliliters was used to convert to milliliters per minute (mLPM). The time used for calculating the effluent released was the number of days in the month. An example of how the quantity of effluent released was calculated will be for the month of June. The quantity per unit time of Rn-222 in the injection solution (5.3E-5 uCi/mL * 5.0E6 mLPM = 265 uCi/minute) was subtracted from the quantity per unit time of Rn-222 in the recovery solution (5.9E-5 uCi/mL * 5.0E6 mLPM = 295 uCi/minute) to yield a loss term of 31 uCi/minute. This number was multiplied by the total time (30 days * 24 hr/day * 60 minutes/hour = 43,200 minutes) to yield the effluent released of 1.4 Ci. Note that the displayed average flow is equivalent for the recovery and injection solutions due to only displaying one significant figure in scientific notation. The actual volumes of 5,029,330 mLPM for recovery and 4,979,036 mLPM for injection were used for the calculation.

A summary of the results for the monitoring period are displayed in Appendix A, Table 10. In determining the total quantity of effluent released during the reporting period, only the positive numbers were summed. For example, the months of February and April yielded negative numbers as

10

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,I

the concentration found in the injection solution was higher than in the recovery solution. These numbers were not used in the summation for total effluent released. Additionally, if multiple values for effluent released were obtained for a given month, the largest value obtained for that month was used. For example, four different values were obtained in the month of May due to duplicate samples per sampling event and multiple sampling events in that month. The largest value of 7.4 Ci was used.

A review of the data displayed in Appendix A, Table 10 indicates some inconsistencies. The first two samples were taken initially upon start up and then two weeks following start up. The concentrations from these samples are not considered to be accurate as low flows (approximately 300 gpm) of process fluid was flowing into the processing facility at this time. Thus the pipes were not completely filled and separation of gas and liquid would have occurred during this early stage of operations. The data then appears to stabilize for the next three months before once again becoming erratic. A second sampling event occurred in May to attempt to identify the source of the inconsistent data obtained during the -months of March to May. It was later determined that the erratic data obtained during these months can likely be attributed to the sampling method. Distance between the sampling port and the holding container allowed for the development of turbulence in the holding container, potentially releasing some of the radon gases in the solution. An immersion technique was implemented for the June sampling event such that a flexible hose was attached to the sampling port. The other end of the hose was placed at the bottom of the holding container. This ensures that minimal gas release occurs prior to obtaining the sample. The results from the June sampling event indicate that the new sampling protocol has yielded results which are thought to be more representative of the concentrations of Rn-222 in the recovery and injection solutions. Although not displayed in this report, the concentrations obtained for the months of July and August are also credible and consistent with results found for the month of June. The concentrations obtained from June to August are results which would be expected of a system which is completely pressurized with the process solution never contacting atmospheric pressure. Thus the obtained concentrations and subsequent effluent quantities calculated for this reporting period up to May 2016 are not thought to be accurate. The improved sampling method, as well as fully filled pipelines, has yielded more consistent, credible results that prove that this method is a viable method for determining the quantity of effluent released from the processing facility.

6.2.2 Wei/field

To determine the quantity of effluent released from the wellfield, track-etch devices were placed in each header house and in 10% of the recovery wellheads. Since injection wells have sealed wellheads, they are not significant sources of radon and radon progeny. The reported concentrations obtained from the header houses are averaged and this number is multiplied by the design ventilation rate, the time of the reporting period, and the number of header houses in operation. For the wellheads, the reported concentrations are averaged and the number is multiplied by a ventilation rate of 2 LPM, the time of the reporting period, and the total number of recovery wells in operation.

The track-etch devices were placed in Header house 1 and its' associated wells from 12/4/2016 to 4/1/2016 for the first quarter and from 4/1/2016 to 7/8/2016 for the second quarter, for a total time of 218 days. The devices were placed in Header house 2 and its' associated wells from 2/18/2016 to 7 /8/2016, for a total time of 142 days. The ventilation rate of the header houses is 9.SE6 mLPM (2 fans at 4.7E6 mLPM each).

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A summary of the results from the monitoring period are displayed in Appendix A, Table 11. The total effluent released is displayed in Appendix A, Table 12. A review of the data indicates that a minimal · amount of radon and radon progeny is released from the wellfield. As stated above, the results from header houses 3 and 4 are not included in this reporting period as the results have not yet been received.

6.2.3 Unplanned releases

Four unplanned releases of process fluid occurred at the Ross Project during the reporting period. Two of the four releases were reportable. A reportable release occurred on 3/3/2016 with an estimated 1200 gallons of fluid being released. The fluid was from Pond 1 Cell 3 which is comprised mainly of injection solution. A minor unreportable release occurred on 4/29/2016 and resulted in 60 gallons of recovery fluid being released. A minor unreportable release occurred on 5/28/2016 and resulted in 10 gallons of injection fluid being released. A reportable release occurred on 6/1/2016 with an estimated 600 gallons of recovery fluid being released. A summary of the estimated quantity of fluid released, the recovery or injection .Rn-222 concentration found for that month, and the calculated Rn-222 released from the event is displayed in Appendix A, Table 13. The conversion factor of 1 gallon= 3,785 milliliters was used. In the case when multiple data for Rn-222 concentration in fluid was available for a given month, the largest value reported was used to be conservative. For example, the May 28th spill used a concentration of 3.3E-5 uCi/mL Rn-222 in injection solution as it was the largest reported value of the four values.

6.3 BACKGROUND

The background concentration levels for radon and air particulates are the radon and air particulate concentration levels measured at the environmental monitoring station designated as the background location (the "Southwest" site).

6.3.1.1 Radon and Radon Progeny

As reported in Appendix A, Table 3, the value obtained from the background location is an average radon concentration of 9.0E-10 uCi/mL. This background value was not subtracted from the concentrations of effluent found in the processing facility as the concentrations obtained were from the

· process fluid, not the surrounding atmosphere. The method determines the effluent released by measuring a difference in concentrations in the process fluid and then assuming that difference is exhausted, thus a consideration of background would not be appropriate. A consideration of background in regards to unplanned releases is also not appropriate since the release is calculated based off of the concentration of Rn-222 in the process fluid released and not on the concentration of Rn-222 in the surrounding atmosphere. The background concentration was subtracted in regards to effluents in the wellfield as displayed by the net average concentrations in Appendix A, Table 12.

6.3.1.2 Air Particulates

As reported in Appendix A, Table 1, the background values for air particulates were 9.SE-15 uCi/mL for Pb-210 for the first quarter and 1.3E-14 uCi/mL for Pb-210 and 1.3E-16 uCi/mL for Th-230 for the second

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quarter. These values were subtracted from the obtained results in the processing facility as displayed by the net average concentrations in Appendix A, Table 8. The average of these results, l.lE-14 uCi/mL for Pb-210 and 6.5E-17 uCi/mL for Th-230, were used for the effluent attributed to the header house. This value was subtracted from the obtained results in the header house as displayed by the net average concentrations in Appendix A, Table 9.

6.4 TOTAL QUANTITIES RELEASED

The three sources of effluent at the Ross Project have been identified as the processing facility, the wellfield, and any unplanned releases of process fluids. Note that the quantities of effluent released include the month of December 2015. However, due to the timing of composite samples, the quantity of effluent for air particulates does not include the month of June. As discussed above, the timing of the composite samples will be submitted such that it will subsequently be consistent with the reporting period.

The deep disposal well building is not currently considered a source of effluent as the building only contains a sealed wellhead. All pumps associated with the system are contained in the processing facility. Additionally, the deep disposal well building does not contain a ventilation system.

6.4.1 Quantity of Air Particulate Effluent

The quantity of effluent released in the form of air particulates is summarized in Appendix A, Table 14. The quantity from the processing facility was calculated as 4.lE-5 Ci and the quantity from the wellfield was calculated as l.lE-7 Ci, for a total quantity released of 4.lE-5 Ci.

6.4.2 Quantity of Radon and Radon Progeny Effluent

The Rn-222 effluent released from the plant is calculated as 13.2 Ci. The Rn-222 effluent released from the wellfield is calculated as 0.028 Ci. The effluent released from unplanned releases is calculated as 3.5 E-4 Ci. The summation of the three sources of effluent yields a total quantity of Rn-222 effluent released of 13.2 Ci. As it is assumed that the radon progeny are in equilibrium with the radon, the total quantity of radon and radon progeny effluent released from December 2"d 2015 to June 30th 2016 is 26.4 Ci.

6.4.3 Conclusion

As stated in 10CFR40.65: "If quantities of radioactive materials released during the reporting period are significantly above the licensee's design objectives previously reviewed as part of the licensing action, the report shall cover this specifically." Strata previously estimated the quantity of effluent released in its' TR Section 7.3. Strata stated: "The Ross ISR project has the potential to produce radiological effluent in the form of Rn-222 that is dissolved in the production and restoration fluid and is present as a result of the uranium decay series. It is assumed there will be no particulate emissions during routine operations of this facility as the facility will use modern, low temperature vacuum driers, the particulate release of which is considered to be zero by the NRC as provided in NU REG 1910."

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The lack of effluent in the form of particulates is demonstrated in the near background levels obtained from periodic sampling events and a total effluent released of 4.1E-5 Ci.

In regards to the quantity of effluent from Rn-222, the TR Section 7.3.4.4 estimated the following: 122 Ci/yr from recovery wells in Mine Unit 1 and 71.2 Ci/yr from operations in the plant. The quantities of effluent found during this reporting period are not complete as several header houses in mine unit 1 were not operational during the duration of the reporting period and the results obtained from sampling for effluent from the processing facility are not thought to be accurate. The next reporting period will provide a more accurate quantity of effluent released from operations at the Ross Project. The results obtained from the processing facility are thought to be an overestimation as results obtained using a better sampling method have lowered the calculated effluent released. The current trend is that 1.4 Ci/month of Rn-222 is released from the processing facility as determined by the new sampling method. If subsequent sampling confirms this release level, it would result in a total of 33.6 Ci/yr of radon and radon progeny effluent from the processing facility. The quantity of effluent calculated to have been released due to operations in mine unit 1 are considerably lower than what was estimated during the licensing process. The effluent released from Header house 1 and its' associated recovery wells is estimated at 0.044 Ci/yr of radon and radon progeny. A mine unit has five header houses on average, such that a mine unit is estimated to release 0.22 Ci/yr. Thus both the effluent released from the processing facility and the wellfields have been determined to be below what was estimated in the licensing process.

7 LICENSE CONDITION 11.2 - ANNUAL REVIEW OF RADIATION PROTECTION

PROGRAM

7.1 ANNUAL REVIEW OF RADIATION PROTECTION PROGRAM

A review of the radiation protection program was conducted on March 15th and 16th, 2016, by a qualified auditor. The review did not find any major issues with the radiation protection program. As the review was conducted prior to a full year of operations and no meaningful exposure data could be reviewed, the review is not contained in this report. Another review of the radiation protection program for the monitoring period of December 2015 to December 2016 will occur and will be contained in a subsequent report.

7.2 PUBLIC DOSE

Per License Condition 11.2 and consistent with 10 CFR 20.1301 and 10 CFR 20.1302, an analysis of dose to individual members of the public will be conducted after a full year of operations has been completed.

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Appendix A

ENVIRONMENTAL MONITORING DATA January l 5t -June 30th, 2016

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.....

Table 1 - Environmental Air Particulates Monitoring, lQ and 2Q 2016

Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL) ±(uCi/mL) (uCi/mL)

Table 2 Values Concentration (uCi/mL) (%)

Oshoto

1st Quarter U-Nat 4.0E-16 N/A 1E-16 9E-13 0.0

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 l.2E-14 l.4E-15 2E-15 6E-13 2.0

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 1.4E-14 l.4E-15 2E-15 6E-13 2.3

North (maximally exposed member of the public)

1st Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 l.lE-14 1.4E-15 2E-15 6E-13 1.8

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 l.1E-14 l.2E-15 2E-15 6E-13 1.8

N/A =Not Applicable, ND= Non-Detect

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f'

Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL} ±(uCi/mL} (uCi/mL}

Table 2 Values Concentration (uCi/mL} (%}

Met Station

1st Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 1.lE-14 1.2E-15 2E-15 6E-13 1.8

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 1.4E-16 5.5E-17 1E-16 9E-13 0.0

Pb-210 1.0E-14 1.1E-15 2E-15 6E-13 1.7

Southwest (Background}

1st Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 9.5E-15 1.2E-15 2E-15 6E-13 1.6

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 1.3E-16 1.1E-16 1E-16 2E-14 0.7

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 1.3E-14 1.4E-15 2E-15 6E-13 2.2

N/A =Not Applicable, ND= Non-Detect

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Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL) ±(uCi/mL) (uCi/mL)

Table 2 Values Concentration (uCi/mL) (%)

East

1st Quarter U-Nat 1.2E-16 N/A 1E-16 9E-13 0.1

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 1.0E-14 l.5E-15 2E-15 6E-13 1.7

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 l.1E-14 1.1E-15 2E-15 6E-13 1.8

South

1st Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 1.1E-14 1.4E-15 2E-15 6E-13 1.8

2nd Quarter U-Nat ND N/A 1E-16 9E-13 N/A

Th-230 ND N/A 1E-16 2E-14 N/A

Ra-226 ND N/A 1E-16 9E-13 N/A

Pb-210 l.OE-14 l.OE-15 2E-15 6E-13 1.7

N/A =Not Applicable, ND= Non-Detect

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Table 2 - Environmental Direct Radiation Monitoring, lQ and 2Q 2016

1st Quarter 2nd Quarter Location Average Year to Date Total

Location Net Net mrem/quarter mrem/quarter

Net mrem/quarter Net mrem/quarter

Oshoto 5.9 8.6 7.3 14.5

North (maximally exposed 5.4 7.8 6.6 13.2

member of the public)

Met Station 9.1 7.9 8.5 17.0

Southwest (Background) 7.6 8.6 8.1 16.2

East 5.3 5.2 5.3 10.5

South 4.1 5.7 4.9 9.8

N/A =Not Applicable

I Control (mrem/quarterJ 26.8 29.6

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Table 3 - Environmental Radon in Air, lQ and 2Q 2016

1st Quarter Location

(uCi/mL)

Oshoto 5.0E-10

North (maximally exposed 6.0E-10

member ofthe public)

Met Station 8.0E-10

Southwest (Background) 8.0E-10

East 3.0E-10

South 4.0E-10

N/A =Not Applicable, ND= Non-Detect

LLD = 0.33 pCi/L based on 90 days

Uncertainty ±(uCi/mL)

4.0E-11

5.0E-11

6.0E-11

6.0E-11

3.0E-11

4.0E-11

2nd Uncertainty Location Average

Quarter (uCi/mL)

±(uCi/mL) (uCi/mL)

7.0E-10 5.0E-11 6.0E-10

6.0E-10 4.0E-11 6.0E-10

5.0E-10 4.0E-11 6.5E-10

l.OE-09 6.0E-11 9.0E-10

8.0E-10 5.0E-11 5.5E-10

4.0E-10 4.0E-11 4.0E-10

10CFR20 APP B Table 2 Value (uCi/mL)

lE-10

lE-10

lE-10

lE-10

lE-10

lE-10

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Table 4- Private Supply Wells Monitoring, lQ and 2Q 2016 Sample Location CSWELL01

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) 7.2E-09 N/A 2.4 5.8E-09

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) 7.0E-10 1.0E-10 1.2 3.0E-10

Ra-226 (suspended) 2.0E-10 1.0E-10 0.3 ND

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A 5.4E-09

Pb-210 (suspended) ND N/A N/A ND

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha 2.0E-08 4.8E-09 N/A 2.0E-08

Gross beta 1.5E-08 6.0E-09 N/A 1.8E-08

Sample Location DWWELL01

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) 3.9E-09 N/A 1.3 3.6E-09

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) 3.9E-09 2.0E-10 6.5 5.9E-09

Ra-226 (suspended) 2.2E-09 2.0E-10 3.7 2.2E-09

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A ND

Pb-210 (suspended) 3.0E-09 8.0E-10 30.0 4.0E-09

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha 2.6E-08 5.3E-09 N/A 2.7E-08

Gross beta 2.9E-08 6.6E-09 N/A 2.5E-08

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

Uncertainty (uCi/mL)

N/A

N/A

1.0E-10

N/A

N/A

N/A

5.0E-10

N/A

N/A

N/A

5.0E-09

7.4E-09

Uncertainty (uCi/mL)

N/A

N/A

3.0E-10

2.0E-10

N/A

N/A

N/A

5.0E-10

N/A

N/A

5.7E-09

7.8E-09

r

% Eff. Cone.*

1.9

N/A

0.5

N/A

N/A

N/A

54.0

N/A

N/A

N/A

N/A

N/A

% Eff. Cone.*

1.2

N/A

9.8

3.7

N/A

N/A

N/A

40.0

N/A

N/A

N/A

N/A

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Sample Location HBWELL03

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) 1.4E-09 N/A 0.5 1.1E-09

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) 5.0E-10 1.0E-10 0.8 5.0E-10

Ra-226(suspended) 3.0E-10 1.0E-10 0.5 ND

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A ND

Pb-210 (suspended) ND N/A N/A ND

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha 7.0E-09 3.0E-09 N/A 3.1E-09

Gross beta 2.0E-08 6.3E-09 N/A 2.2E-08

Sample Location HBWELL04

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) 1.7E-08 N/A 5.6 1.6E-08

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) 6.0E-10 1.0E-10 1.0 ND

Ra-226 (suspended) ND N/A N/A ND

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A ND

Pb-210 (suspended) l.lE-09 5.0E-10 11.0 ND

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha 1.6E-08 4.0E-09 N/A 1.8E-08

Gross beta 1.7E-08 5.6E-09 N/A 1.5E-08

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

Uncertainty (uCi/mL) % Eff. Cone.*

N/A 0.4

N/A N/A

1.0E-10 0.8

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

2.9E-09 N/A

7.SE-09 N/A

Uncertainty (uCi/mL) % Eff. Cone.*

N/A 5.2

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

4.7E-09 N/A

7.1E-09 N/A

Page 27: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Sample Location TWOl

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) ND N/A N/A ND

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) ND N/A N/A ND

Ra-226 (suspended) ND N/A N/A ND

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A ND

Pb-210 (suspended) ND N/A N/A ND

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha ND N/A N/A 1.2E-08

Gross beta 1.0E-08 5.5E-09 N/A 2.0E-08

Sample Location TW02

Parameter 1st Quarter (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.* 2nd Quarter (uCi/mL)

Uranium (dissolved) 5.0E-10 N/A 0.2 5.0E-10

Uranium (suspended) ND N/A N/A ND

Ra-226 (dissolved) 6.0E-10 1.0E-10 1.0 4.0E-10

Ra-226 (suspended) ND N/A N/A ND

Th-230 (dissolved) ND N/A N/A ND

Th-230 (suspended) ND N/A N/A ND

Pb-210 (dissolved) ND N/A N/A ND

Pb-210 (suspended) ND N/A N/A ND

Po-210 (dissolved) ND N/A N/A ND

Po-210 (suspended) ND N/A N/A ND

Gross alpha 3.4E-09 3.1E-09 N/A 9.6E-09

Gross beta 5.5E-09 5.6E-09 N/A 1.7E-08

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

Uncertainty (uCi/mL) % Eff. Cone.*

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

4.7E-09 N/A

7.6E-09 N/A

Uncertainty (uCi/mL) % Eff. Cone.*

N/A 0.2

N/A N/A

1.0E-10 0.7

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

3.9E-09 N/A

7.4E-09 N/A

Page 28: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Table 5 - Industrial Wells Monitoring, 1Q and 2Q 2016

Location: 19XX18

Sample 1/20/2016 2/12/2016 3/11/2016 4/22/2016 5/4/2016

Date

Parameter Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty

(uCi/mL) ±(uCi/mL) (uCi/mL) ±(uCi/mL) (uCi/ml) ±(uCi/ml) (uCi/mL) ±{uCi/mL) (uCi/ml) ±{uCi/ml)

Uranium 5.8E-08 N/A 5.4E-08 N/A

(dissolved) 4.4E-08 N/A 5.5E-08 N/A 4.8E-08 N/A

Uranium ND N/A ND N/A

(suspended) ND N/A ND N/A ND N/A

Ra-226 2.2E-08 5.0E-10 3.6E-08 7.0E-10

(dissolved) 4.0E-08 7.0E-10 3.9E-08 8.0E-10 3.8E-08 8.0E-10

Ra-226 .9.0E-10 1.0E-10 3.0E-10 1.0E-10

(suspended) 4.0E-10 1.0E-10 2.6E-09 2.0E-10 3.3E-09 2.0E-10

Th-230 ND N/A ND N/A

(dissolved) ND N/A ND N/A ND N/A

Th-230 ND N/A ND N/A ND N/A 1.2E-09 3.0E-10 1.5E-09 3.0E-10

(suspended)

Pb-210 7.lE-09 7.0E-10 7.2E-09 1.0E-09 6.lE-09 7.0E-10 3.0E-09 5.0E-10 2.0E-09 4.0E-10

(dissolved)

Pb-210 ND

(suspended) N/A 5.3E-09 7.0E-10 4.SE-09 6.0E-10 1.9E-08 1.0E-09 2.6E-08 1.2E-09

Po-210 1.3E-09 4.0E-10 5.9E-09 1.0E-09

(dissolved) 3.9E-09 8.0E-10 1.9E-09 5.0E-10 1.3E-09 6.0E-10

Po-210 1.8E-09 6.0E-10 4.8E-08 2.4E-09

(suspended) 4.3E-08 2.7E-09 6.4E-08 3.0E-09 8.6E-08 4.3E-09

Gross alpha 2.3E-07 1.SE-08 2.2E-07 l.4E-08 1.7E-07 1.3E-08 1.7E-07 1.3E-08 1.6E-07 1.3E-08

Gross beta 1.2E-07 9.3E-09 8.8E-08 8.0E-09 9.8E-08 8.3E-09 7.4E-08 7.9E-09 9.0E-08 1.0E-08

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

6/15/2016

Cone. Uncertainty

(uCi/ml) ±(uCi/ml)

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

Avg. Cone. % Eff.

(uCi/ml) Cone.

5.2E-08 17.2

N/A N/A

3.5E-08 58.3

1.SE-09 2.5

N/A N/A

1.4E-09 1.4

5.lE-09 50.8

1.4E-08 137.0

2.9E-09 7.2

4.9E-08 121.5

1.9E-07 N/A

9.4E-08 N/A

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I Location: 22X-19 I

Sample 1/20/2016 2/12/2016 3/11/2016 4/22/2016 5/4/2016

Date

Parameter Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty Cone. Uncertainty

(uCi/ml) ±(uCi/ml) (uCi/ml) ±(uCi/ml) (uCi/ml) ±(uCi/ml) (uCi/ml) ±(uCi/ml) (uCi/ml) ±(uCi/ml)

Uranium 1.4E-08 N/A N/A N/A 1.lE-08 N/A N/A N/A N/A N/A

(dissolved)

Uranium ND N/A N/A N/A ND N/A N/A N/A N/A N/A

(suspended)

Ra-226 2.8E-09 2.0E-10 N/A N/A 3.0E-09 2.0E-10 N/A N/A N/A N/A

(dissolved)

Ra-226 ND N/A N/A N/A ND N/A N/A N/A N/A N/A (suspended)

Th-230 ND N/A N/A N/A ND N/A N/A N/A N/A N/A (dissolved)

Th-230 ND N/A N/A N/A ND N/A N/A N/A N/A N/A (suspended)

Pb-210 ND N/A N/A N/A 1.lE-09 5.0E-10 N/A N/A N/A N/A (dissolved)

Pb-210 1.lE-09 4.0E-10 N/A N/A 1.3E-09 4.0E-10 N/A N/A N/A N/A

(suspended)

Po-210 ND N/A N/A N/A ND N/A N/A N/A N/A N/A

(dissolved)

Po-210 2.2E-08 1.9E-09 N/A N/A 1.lE-09 5.0E-10 N/A N/A N/A N/A

(suspended)

Gross alpha 3.6E-08 6.lE-09 N/A N/A 3.4E-08 5.9E-09 N/A N/A N/A N/A

Gross beta 1.4E-08 6.0E-09 N/A N/A 1.6E-08 5.8E-09 N/A N/A N/A N/A

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

6/15/2016

Cone. Uncertainty Avg. Cone. % Eff. (uCi/ml) ±(uCi/ml) (uCi/ml) Cone.

N/A N/A 1.3E-08 4.2

N/A N/A N/A N/A

N/A N/A 2.9E-09 4.8

N/A N/A N/A N/A

N/A N/A N/A N/A

N/A N/A N/A N/A

N/A N/A 1.lE-09 11.0

N/A N/A 1.2E-09 12.0

N/A N/A N/A N/A

N/A N/A 1.2E-08 29.0

N/A N/A 3.5E-08 N/A

N/A N/A 1.5E-08 N/A

Page 30: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Table 6 - Surface Water Monitoring: Reservoirs and Grab Samples from Waterways, lQ and 2Q 2016

Sample Location Oshoto Reservoir

Parameter 1st Quarter Uncertainty % Eff. 2nd Quarter Uncertainty % Eff.

(uCi/mL) (uCi/mL) Cone.* (uCi/mL) (uCi/mL) Cone.*

Uranium (dissolved) N/A N/A N/A 8.3E-09 N/A 2.8

Uranium (suspended) N/A N/A N/A ND N/A N/A

Ra-226 (dissolved) N/A N/A N/A ND N/A N/A

Ra-226 (suspended) N/A N/A N/A ND N/A N/A

Th-230 (dissolved) N/A N/A N/A ND N/A N/A

Th-230 (suspended) N/A N/A N/A ND N/A N/A

Pb-210 (dissolved) N/A N/A N/A ND N/A N/A

Pb-210 (suspended) N/A N/A N/A ND N/A N/A

Po-210 (dissolved) N/A N/A N/A ND N/A N/A

Po-210 (suspended) N/A N/A N/A ND N/A N/A

Gross alpha N/A N/A N/A 7.9E-09 3.2E-09 N/A

Gross beta N/A N/A N/A 1.4E-08 6.7E-09 N/A

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

Page 31: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Sample Location SW-1

Parameter Concentration (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.*

Uranium (dissolved) 5.4E-09 N/A 1.8

Uranium (suspended) ND N/A N/A Ra-226 (dissolved) ND N/A N/A Ra-226 (suspended) ND N/A N/A Th-230 (dissolved) ND N/A N/A Th-230 (suspended) ND N/A N/A Pb-210 (dissolved) ND N/A N/A Pb-210(suspended) ND N/A N/A Po-210 (dissolved) ND N/A N/A Po-210 (suspended) ND N/A N/A Gross alpha 7.lE-09 3.6E-09 N/A Gross beta l.3E-08 7.2E-09 N/A

Sample Location SW-2

Parameter Concentration (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.*

Uranium (dissolved) 8.4E-09 N/A 2.8

Uranium (suspended) 3.0E-10 N/A 0.1

Ra-226 (dissolved) 2.0E-10 l.OE-10 0.3

Ra-226 (suspended) 2.0E-10 l.OE-10 0.3

Th-230 (dissolved) ND N/A N/A Th-230 (suspended) ND N/A N/A Pb-210 (dissolved) ND N/A N/A Pb-210 (suspended) 4.2E-09 5.0E-10 42.0

Po-210 (dissolved) ND N/A N/A Po-210 (suspended) 3.2E-09 9.0E-10 8.0

Gross alpha 9.3E-09 3.8E-09 N/A Gross beta 1.3E-08 7.2E-09 N/A

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

Page 32: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Sample Location SW-3

Parameter Concentration (uCi/mL) Uncertainty (uCi/mL) % Eff. Cone.*

Uranium (dissolved) 9.0E-09 N/A

Uranium (suspended) ND N/A

Ra-226 (dissolved) ND N/A

Ra-226 (suspended) ND N/A

Th-230 (dissolved) ND N/A

Th-230 (suspended) ND N/A

Pb-210 (dissolved) ND N/A

Pb-210 (suspended) ND N/A

Po-210 (dissolved) ND N/A

Po-210 (suspended) ND N/A

Gross alpha 4.9E-09 3.3E-09

Gross beta 1.3E-08 7.lE-09

* Lower Limits of Detection and Effluent Concentration values from 10 CFR 20 Appendix B Table 2 are listed in Table 7

N/A =Not Applicable; ND= Non Detectable

0.5

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

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Table 7 - Water Sample Lower Limits of Detection and Effluent Concentration Values

10CFR20 APP B Table 2 Radionuclide LLD (uCi/mL) Effluent Cone. Water

(uCi/mL)

Natural Uranium 2E-10 3E-7

Thorium-230 2E-10 lE-7

Radium-226 2E-10 6E-8

Polonium-210 lE-9 4E-8

Lead-210 lE-9 lE-8

Page 34: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Table 8 - Processing Facility Air Particulates Effluent December 2015, lQ and 2Q, 2016

Sample Radio- Concentration Error Concentration Error Period nuclide (uCi/mL) ±(uCi/mL) (uCi/mL) ±(uCi/mL)

Ion Exchange Area Reverse Osmosis Area

1st U-Nat 9.2E-15 N/A 6.8E-15 N/A

Quarter

Th-230 8.3E-15 6.3E-15 ND N/A

Ra-226 7.7E-15 3.2E-15 7.7E-15 3.2E-15

Pb-210 2.2E-13 7.9E-14 8.lE-14 6.7E-14

2nd U-Nat ND N/A ND N/A

Quarter

Th-230 ND N/A 1.1E-14 1.1E-14

Ra-226 ND N/A ND N/A

Pb-210 1.1E-13 8.4E-14 8.0E-14 8.1E-14

N/A =Not Applicable; ND= Non-detect

*Backgrounds were listed as ND for all radionuclides except Pb-210 and Th-230

1st Quarter Background: Pb-210 = 9.5£-15 uCi/ml

2nd Quarter Background: Pb-210=1.3£-14 uCi/ml, Th-230=1.3£-16 uCi/ml

Concentration Error (uCi/mL) ±(uCi/mL)

Lab

7.7E-15 N/A

6.7E-15 6.3E-15

ND N/A

1.7E-13 7.6E-14

ND N/A

ND N/A

ND N/A

1.3E-13 7.3E-14

Average Cone.

(uCi/mL)

7.9E-15

7.5E-15

7.7E-15

1.6E-13

ND

1.1E-14

ND

1.1E-13

**The first quarter is from Dec. 2"d 2015 through February 29th, 2016. The second quarter is from March l't to May 31st, 2016.

Net Effluent

Average Released

Cone. (Ci)

(uCi/mL)

7.9E-15 1.2E-06

7.5E-15 1.1E-06

7.7E-15 1.1E-06

1.5E-13 2.2E-05

N/A N/A

1.1E-14 1.6E-06

N/A N/A

9.4E-14 1.4E-05

Page 35: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Table 9 - Wellfield Air Particulates Effluent December 2015, lQ and 2Q 2016

Concentration Error Location Sample Period Radionuclide

(uCi/mL) ±(uCi/mL)

Header house 1 Dec. '15 - May '16 U-Nat ND N/A Th-230 2.4E-15 1.2E-15

Ra-226 ND N/A

Pb-210 5.lE-14 2.6E-14

N/A =Not Applicable; ND= Non-Detect

*Backgrounds: Pb-210=1.lE-14 uCi/mL; Th-230 = 6.SE-17 uCi/mL

Net Effluent Concentration Released

(uCi/mL) (Ci)

N/A N/A

2.3E-15 5.8E-09

N/A N/A

4.0E-14 1.0E-07

Page 36: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Table 10 - Processing Facility Radon Effluent December 2015, lQ and 2Q 2016

Concentration Average

Concentration Average

Effluent Sample Date Recovery

Uncertainty Recovery Flow Injection

Uncertainty Injection Flow Loss Term Released

±(uCi/mL) Rate for the ±(uCi/mL) Rate for the (uCi/minute) (uCi/mL)

Month (mLPM) (uCi/mL)

Month (mLPM) (Ci)

12/1/2015 2.lE-05 4.2E-07 1.8E+06 1.0E-05 2.lE-07 1.8E+06 1.9E+Ol 0.8

12/21/2015 4.7E-05 9.4E-07 1.8E+06 1.4E-05 2.9E-07 1.8E+06 6.0E+Ol 2.7

12/21/2015 4.6E-05 9.2E-07 1.8E+06 1.4E-05 2.7E-07 1.8E+06 5.9E+Ol 2.6

(duplicates)

1/8/2016 4.lE-05 8.lE-07 1.5E+06 4.2E-05 8.4E-07 1.4E+06 -4.7E-01 0.0

2/8/2016 4.lE-05 8.3E-07 2.3E+06 4.9E-05 9.7E-07 2.3E+06 -1.4E+01 -0.6

3/15/2016 5.6E-05 1.lE-06 4.0E+06 4.7E-05 9.3E-07 3.9E+06 4.lE+Ol 1.8

4/11/2016 1.4E-05 2.8E-07 2.7E+06 4.8E-05 9.6E-07 2.6E+06 -9.0E+Ol -3.9

5/4/2016 5.0E-05 9.9E-07 4.7E+06 1.4E-05 2.9E-07 4.6E+06 1.7E+02 7.4

5/4/2016 5.2E-05 1.0E-06 4.7E+06 3.3E-05 6.6E-07 4.6E+06 9.0E+Ol 4.0

(duplicates)

5/25/2016 3.0E-05 6.0E-07 4.7E+06 8.6E-06 1.7E-07 4.6E+06 1.0E+02 4.5

5/25/2016 2.9E-05 5.9E-07 4.7E+06 8.9E-06 1.8E-07 4.6E+06 9.6E+01 4.3

(duplicates)

6/29/2016 5.9E-05 1.2E-06 5.0E+06 5.3E-05 1.lE-06 5.0E+06 3.lE+Ol 1.4

6/29/2016 5.4E-05 1.lE-06 5.0E+06 5.3E-05 1.lE-06 5.0E+06 1.0E+Ol 0.4

(duplicates)

Total (Ci): 13.2 * The loss Term = (Concentration Recovery *Avg. Flow Rate Recovery) - (Concentration Injection *Avg. Flow Rate Injection)

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Table 11- Radon Concentrations in the Wellfield December 2015, lQ and 2Q 2016

2nd Location

1st Quarter Uncertainty Quarter

Uncertainty

(uCi/mL) ±(uCi/mL) (uCi/mL)

±(uCi/mL)

Header house 1 2.lE-09 9.0E-11 6.9E-09 1.9E-10

OZ-005A 2.2E-09 9.0E-11 l.lE-08 2.5E-10

OZ-057 2.7E-09 1.0E-10 5.8E-09 l.8E-10

OZ-054 8.0E-10 5.0E-11 l.OE-09 6.0E-11

Header house 2 N/A N/A 9.9E-09 2.6E-10

OZ-018 N/A N/A 2.0E-09 l.lE-10

OZ-160 N/A N/A 2.3E-09 l.lE-10

OZ-170 N/A N/A 3.0E-09 l.3E-10

DDW 2.0E-10 2.0E-11 3.0E-10 3.0E-11

*N/A =Not Applicable

.. ·

Average Concentration

by Location

(uCi/mL)

4.5E-09

6.7E-09

4.3E-09

9.0E-10

9.9E-09

2.0E-09

2.3E-09

3.0E-09

2.5E-10

Page 38: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

Average

Table 12 - Wellfield Radon Effluents December 2015, lQ and 2Q 2016

Net Average Effluent

Location Concentration Concentration Released per

Location

Header house 1 Recover Wells

Header house 2 Recovery Wells

Header house 1

Header house 2

N/A =Not Applicable

*Background is 9.0E-10 uCi/mL

(uCi/mL}

3.9E-09

2.4E-09

4.5E-09

9.9E-09

(uCi/mL} (uCi}

3.0E-09 1.9E+OO

1.5E-09 6.3E-01

3.6E-09 1.1E+04

9.0E-09 1.7E+04

-:

,,

Effluent Number of

Released Recovery Wells

(Ci}

29 5.5E-05

30 1.9E-05

N/A 1.lE-02

N/A 1.7E-02

Total (Ci): 2.8E-02

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Spill Date

3/3/2016

4/29/2016

5/28/2016

6/1/2016

Table 13 - Unplanned Releases Radon Effluent

December 2015, lQ and 2Q 2016

Rn-222 Process Fluid Type Spill Volume (ml) Concentration

(uCi/mL)

Injection 4.5E+06 4.7E-05

Recovery 2.3E+05 1.4E-05

Injection 3.8E+04 3.3E-05

Recovery 2.3E+06 5.9E-05

Total (Ci):

Effluent Released (Ci)

2.lE-04

3.lE-06

1.3E-06

1.3E-04

3.SE-04

,,. •.

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!'

Table 14 - Total Air Particulate Effluent

Radionuclide Plant Effluent Wellfield Effluent Total Effluent

(Ci) (Ci) {Ci)

U-Nat 1.2E-06 None 1.2E-06

Th-230 2.7E-06 5.8E-09 2.7E-06

Ra-226 1.lE-06 None 1.lE-06

Pb-210 3.6E-05 1.0E-07 3.6E-05

Total (Ci): 4.lE-05

* "None" means no concentration detectable above background, thus no calculated effluent

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' "

Appendix B

QUARTERLY INSPECTIONS OF THE LINED RETENTION POND

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' IL .. _

Disposal Pond Quarterly Inspection

Inspection I Date: 2-/ / O /; {;

Inspector: a c.k

Disposal Pond Inspection Items

Item Completed Comments

Visual inspection of the embankment top, side E'.T"'b...nk.,.,,,nt :s• ~ ~

slopes, and toe for settlement, surface cracks, v f<> e. z,..x.r<. .S ~IN

erosion, and changes in alignment

There is no evidence of seepage in the v ~r>o/.AJ eover-e-downstream embankment toes and slopes

Instrumentation and safety equipment has been ~~l-~ t:-i· J. ,..s+-rum<-r>"f~t1ol'I is n .. .Y r~v?rer:J far

tested to ensure proper operation. Review of ~:S: p~n+·t e "? b ... n /.I. 1"1<.1"17-~ recent readings of the instrumentation has been $..., :}~ cP>J, ~

conducted to detect unusual performance or NIA fr- . distress of the embankment ir.:s~f~on

1..;.-ic.r i:s i'"l e.x,C£/l~f A detailed examination of the liner was conducted v GonJ..;f-;,,,,., ..,n.J -fw.rc to determine if degradation is occuring is n:> e.vi./;v1c= of

.,~;d-.=. .{).,.... l'-.o.f

h-1fc. t:1'1 1~·~r

**The results of the inspection will be reviewed by the VP-OPS (Production Supervisor) and the VP-PREC (Manager of Safety, Health, and Environmental Affairs). Inspection records will be kept on site and retained until termination of the project.

VP-PREC (Manager SHEA):

Date:

VP-OPS (Production Supervisor) ~~+-~,,_-T-"""'f-..,,.....-~......-~~~-

D ate:

Revision #: 1

d

RPP-FORM-019 Quarterly Disposal Pond Inspection 1of1 Approved by/Date: Nikolas Roche 2/10/2016_

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I (.._

Disposal Pond Quarterly Inspection

Inspection S/lS/2016 Date:

Inspector: Roche ~~~~~~~~~~~~~~~~~~

Disposal Pond Inspection Items

Item Completed

Visual inspection of the embankment top, side slopes, and toe for settlement, surface cracks, Yes erosion, and changes in alignment

Th.er~ is no evidence of seepage in the Yes

downstream embankment toes and slopes

Instrumentation and safety equipment has been tested to ensure proper operation. Review of recent readings of the instrumentation has been Yes conducted to detect unusual performance or distress of the embankment

A detailed examination of the liner was conducted Yes

to determine if degradation is occuring

Comments Small erosion patterns are forming on the east embankment due to runoff. The appropriate personnel have been notified and the issue will be addressed by using erosion control methods

Instrumentation is not required for monitoring embankment, thus this portion of the inspection is not applicable.

**The results of the inspection will be reviewed by the VP-OPS (Production Supervisor) and the VP-PREC (Manager of Safety, Health, and Environmental Affairs). Inspection records will be kept on site and retained until termination of the project.

"' VP-PREC (Manager SHEA):

Date:

VP-OPS (Production Supervisor) _-1-+---=--+-=-----)_f_/_.B/_,,/_(_ Date:

Revision #: 1 RPP-FORM-019 Quarterly Disposal Pond Inspection (6) 1of1 Approved by/Date: Nikolas Roche 2/10/2016_

Page 44: Strata Energy, Inc., Ross In-Situ Recovery Project January ...January -June 2016 Semi-Annual Report To Whom It May Concern: Strata Energy Inc. (Strata) hereby submits this Semi-Annual

( l I I

Appendix C

ANNUAL TECHNICAL INSPECTION OF THE LINED RETENTION POND

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\ . l I

IL.ff rro ed/ IR e terro ~ff orro Pr» rrndl A rrn lf!J M fEl ff ff m p<OJ M rrodf merro t ff rros pectff rro [{j} !Rep<OJ rl

INSPECTOR: Will Myers, P .E. __ _ TITLE: WWC Project Enoineer

INSPECTION DATE: __ 5~/2=6~/"""'"16 __ DATE LAST INSPECTION:_2=0=-=1-=-5 ___ _

PROJECT: Ross ISR Project IMPOUNDMENT: Lined Retention Pond 1

1. EMBANKMENT ST ABILITY

a. Outslope Embankment Cracks on crest (downstream None structural Conditions: side) .............................................

Cracks on the slope ..................... No

Bulging on slope ........................... No

Bulging at toe ............................... No

Shallow surface movement .......... No

b. lnslope Embankment Minor surface cracks at the liner Conditions: Cracks on crest (upstream side) ... anchor trench margin. Not concerning

Liner condition .............................. New, with some wrinkles near toe. Likely thermal expansion. Monitor

Bulging on slope above water No level .......... , ..................................

Bulging on slope at or beneath No water level ....................................

Shallow surface movement .......... No

c. Slope Erosion: Gullies on slope ............................ Yes, on northeast fill slope. Caused from ponding on crest low spot. Ofteldal to remediate.

Gullies on toe ............................... No

Gullies at abutment ...................... NA

Minor erosion ............................... Yes, due to lack of vegetation.

Page 1 of3 wwc

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I ) l

d. Seepage:

e. Foundation Movement:

f. Embankment Freeboard:

g. Visual survey of Embankment for settlement

a. Underdrain Pipes

At isolated points ..........................

At abutment. .................................

Over large areas ..........................

Boils .............................................

Horizontal movement away from slope ............................................

Bulging of downstream foundation materials ......................................

(Actual vs. Required) ....................

3. Piping System

Obstruction by vegetation .............

Obstruction by slough of slopes ...

Erosion of channel or sideslopes ..

Condition at discharge ..................

Manhole conditions ......................

Condition of pump ........................

CAV condition ..............................

Crushing or cracking of pipes .......

Page 2 of3

No

No

No

No

No

No

Cell 1 & 2 have 15' of FB

Cell 3 has 12' of FB

No indications of major settlement. There are a few low spots on the east fill slope.

No

No

No

Erosion control matting in place, but discharge channel doesn't drain well due to lack of grade.

Good, some water inside mostly due to rainwater. Manholes are constructed slightly below grade.

Appears in good condition

Appears in good condition

No

wwc

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' . ,_ \

Corrosion of pipes ........................ No

b. Leak Detection Pipe inlet ...................................... Can't see System:

Check for leak .............................. No leaks

Cracking, crushing, or corrosion No of pipe ..........................................

Deterioration of riprap or concrete NA

4. MONITORING

a. Water Level: Staff gage reading ........................ Cell 1 & 2 have 15' of FB

Cell 3 has 12' of FB

Abnormal increase in water level No without heavy rainfall. ...................

Abnormally long period of high No water after storm ..........................

Decrease in water level without No corresponding change in operations ....................................

Discharge reading ........................ Cell 3 1760 gal in 3 days

b. Sediment Level: Staff Gage Reading ...................... NA

c. Crest Survey: Elevations of Benchmarks ........... Based on Section 1, no survey is warranted at this time.

d. Daily/Monthly/Quarterly Yes Inspection/Review of Inspections:

Recommended Corrective Actions: Fill in low spots on embankment and fill erosion. Seed areas not

covered in gravel. Monitor wrinkles in liner, anchor trench, and signs of erosion until the pond slopes

are stabilized. Also continue to monitor the leak detection system, monitor wells, underdrain system

and freeboard levels.

Page 3 of3 wwc

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l ' .Ill 1,

Appendix D

ANALYSIS BETWEEN INITIALLY REPORTED AND REVISED AIR PARTICULATE DATA

July 1st - December 31st, 2015

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Environmental Air Particulates Monitoring Analysis Between Initially Reported and Revised Data for the 3rd and 4th Quarter, 2015

Initially Revised

Percent Initially Revised Percent

Location Sample

Radionuclide Reported

Concentration Difference - Reported

Error Difference -Period Concentration

(uCi/mL) Concentration Error

±(uCi/mL) Error(%) (uCi/mL) (%) ±(uCi/mL)

Oshoto

3rd Quarter U-Nat ND ND N/A N/A N/A N/A Th-230 ND ND N/A N/A N/A N/A Ra-226 ND ND N/A N/A N/A N/A Pb-210 1.3E-14 1.4E-14 7.4 9.6E-16 1.0E-15 4.1

4th Quarter U-Nat ND ND N/A N/A N/A N/A Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A Pb-210 2.3E-14 2.5E-14 8.3 1.3E-15 1.4E-15 7.4

North (maximally exposed member of the public)

3rd Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.5E-14 1.7E-14 12.5 1.2E-15 1.2E-15 0.0

4th Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.2E-14 1.3E-14 8.0 1.3E-15 1.4E-15 7.4

N/A =Not Applicable, ND= Non-Detect

J

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Initially Revised

Percent Initially Revised Percent

Location Sample

Radionuclide Reported

Concentration Difference - Reported

Error Difference -Period Concentration

(uCi/mL) Concentration Error

±(uCi/mL) Error(%) (uCi/mL) (%) ±(uCi/mL)

Met Station

3rd Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 2.lE-16 2.3E-16 9.1 7.3E-17 7.9E-17 7.9

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.8E-14 2.0E-14 10.5 1.2E-15 1.2E-15 0.0

4th Quarter U-Nat ND ND N/A N/A N/A N/A Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.3E-14 1.4E-14 7.4 1.2E-15 1.3E-15 8.0

Southwest (Background)

3rd Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 2.lE-14 2.3E-14 9.1 1.8E-15 2.0E-15 10.5

4th Quarter U-Nat 1.8E-16 1.9E-16 5.4 N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.2E-14 1.3E-14 8.0 1.lE-15 l.2E-15 8.7

N/A =Not Applicable, ND= Non-Detect

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.-...

Initially Revised

Percent Initially Revised Percent

Location Sample

Radionuclide Reported

Concentration Difference - Reported

Error Difference -Period Concentration

(uCi/mL) Concentration Error

±(uCi/mL) Error(%) (uCi/mL) (%) ±(uCi/mL)

East

3rd Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.2E-14 1.3E-14 8.0 1.lE-15 1.lE-15 0.0

4th Quarter U-Nat ND ND N/A N/A N/A N/A Th-230 ND ND N/A N/A N/A N/A Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.lE-14 1.2E-14 8.7 1.2E-15 1.3E-15 8.0

South

3rd Quarter U-Nat ND ND N/A N/A N/A N/A Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A Pb-210 1.9E-14 2.lE-14 10.0 1.4E-15 1.5E-15 6.9

4th Quarter U-Nat ND ND N/A N/A N/A N/A

Th-230 ND ND N/A N/A N/A N/A

Ra-226 ND ND N/A N/A N/A N/A

Pb-210 1.3E-14 1.4E-14 7.4 1.6E-15 1.7E-15 6.1

N/A =Not Applicable, ND= Non-Detect

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Appendix E

REVISED ENVIRONMENTAL AIR PARTICULATES MONITORING DATA

July l 5t - December 315

\ 2015

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Environmental Air Particulates Monitoring, 3Q and 4Q 2015 - REVISED

Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL) ±(uCi/mL) (uCi/mL)

Table 2 Values Concentration (uCi/mL) (%)

Oshoto

3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A Ra-226 ND N/A lE-16 9E-13 N/A Pb-210 1.4E-14 1.0E-15 2E-15 6E-13 2.3

4th Quarter U-Nat ND N/A lE-16 9E-13 N/A Th-230 ND N/A lE-16 2E-14 N/A Ra-226 ND N/A lE-16 9E-13 N/A Pb-210 2.SE-14 1.4E-15 2E-15 6E-13 4.2

North (maximally exposed member of the public)

3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.7E-14 1.2E-15 2E-15 6E-13 2.8

4th Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.3E-14 1.4E-15 2E-15 6E-13 2.2

N/A =Not Applicable, ND= Non-Detect

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Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL) ±(uCi/mL) (uCi/mL)

Table 2 Values Concentration (uCi/mL) (%)

Met Station

3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 2.3E-16 7.9E-17 lE-16 2E-14 1.2

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 2.0E-14 1.2E-15 2E-15 6E-13 3.3

4th Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.4E-14 1.3E-15 2E-15 6E-13 2.3

Southwest (Background)

3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 2.3E-14 2.0E-15 2E-15 6E-13 3.8

4th Quarter U-Nat 1.9E-16 N/A lE-16 9E-13 0.0

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.3E-14 1.2E-15 2E-15 6E-13 2.2

N/A =Not Applicable, ND= Non-Detect

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Concentration Error LLD 10CFR20 APP B Percent

Location Sample Period Radionuclide (uCi/mL) ±(uCi/mL) (uCi/mL)

Table 2 Values Concentration (uCi/mL) (%)

East

3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 l.3E-14 1.lE-15 2E-15 6E-13 2.2

4th Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.2E-14 1.3E-15 2E-15 6E-13 2.0

South 3rd Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 2.lE-14 1.5E-15 2E-15 6E-13 3.5

4th Quarter U-Nat ND N/A lE-16 9E-13 N/A

Th-230 ND N/A lE-16 2E-14 N/A

Ra-226 ND N/A lE-16 9E-13 N/A

Pb-210 1.4E-14 1.7E-15 2E-15 6E-13 2.3

N/A =Not Applicable, ND= Non-Detect