HomeMy WebLinkAboutDRC-2024-004545Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
State of Utah
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
SPENCER J. COX
Governor Douglas J. Hansen
Director
DEIDRE HENDERSON
Lieutenant Governot
MEMORANDUM
TO: Project File C-2024-32
THROUGH: Phil Goble, RAM Section Manager PlzurthtL 0212112024
FROM:
DATE:
0212r12024
SUBJECT:January 3l,2024Inspection of the Disposal of l1e.(2) Decommissioning Debris from In
Situ Leach Facilities at the White Mesa Uranium Mill. Energy Fuels Resources
Radioactive Material License No. UT 1900479, Amendment 10.
Authority
Radioactive Materials License #UTL900479 Amendment 10, Condition 10.5: "In accordance with the
licensee's submittal to the NRC dated May 20,1993, the licensee is hereby authorized to dispose of l1e.(2)
byproduct material generated at licensed in-situ recovery (ISR) [previously known as in-situ leach (ISL)]
facilities as per 10 CFR 40 Appendix A, Criterion2 andfrom other uranium recovery facilities, subject to the
following conditions:" (Conditions are included below in the Requirements bnd Compliance
Determination section.)
R313-12-3 (quoting t0 CFR 40.4): o'Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes."l
t0 CFR Part 40 Appendix A, Criterion 2:o'Toavoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal
' This definition amends the language given in Section lle.(2) of the Atomic Energy Act as amended in 1954 to include ISL
facilities on the same footing as conventional uranium mills. This is done by referencing "solution extraction" in the
definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10'
DRC-2024-O70648 195 North 1950 West' Salt Lake City, UT
Mailing Address: P.O. Box 144880 ' Salt Lake City, UT 84114-4880
Telephone (801 ) 536-0200' Fax (80 1 ) s36-0222' T.D.D. (80 1 ) 5364284
waxn.deq.utah.goa
Printed on 100olo recycled paper
Heather Mickelson, PE, PG /,a-7,e,La.*
February 2I,2024
First Quarter 2024ISL Decommissioning Debris Disposal Inspection Report
February 21,2024
Page2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Observations
Heather Mickelson, PE, PG and Phil Goble, Uranium Mill Section Manager of the Utah Division of
Waste Management and Radiation Control (Division) observed the burial of two (2) loads of l1e.(2)
byproduct material on January 31,2024 at the White Mesa Uranium Mill (Mill). The Mill is owned and
operated by Energy Fuels Resources (Licensee). The Division received notice (DRC-2024-004217 and,
DRC-2024-004060) of the disposal electronically on January 10, 2024 and January 16,2024.
Operating Procedures and Records
The Standard Operating Procedure (SOP) PBL-10, dated August23,2023, governs the disposal of
11e.(2) byproduct material from ISL facilities, The Mill's staff were most recently trained on this SOp
on January 9,2024. The inspector obtained a copy of the latest version of the SOP from the Licensee
during the inspection.
The Licensee maintains hard copies of the buried lle.(z) material records onsite. Records are moved
from the Mill's office building to an onsite storage container within the restricted area when file space
inside the office building becomes limited. The storage area was confirmed by visual observation
during this inspection.
Copies of the data packets for each load are attached to this report.
l1e.(2) Byproduct Material Disposal Activities and Description
Prior to January 31,2024, the disposal pit location was determined, located by survey, and excavated by
the Licensee. The bottom of the excavation extended into the tailings sand. The lle.(2) byproduct
material was placed near the burial pit for burial (Photos 1).
During the January 37,2024 inspection, the Division observed the final disposal activities. The
excavation depth was surveyed (Photo 2). The 1le.(2) byproduct material was moved into the
excavation (Photo 3) and the top of the material was surveyed. Clean cover was then placed over the
l1e.(2) byproduct material and then compacted to further minimize void spaces (Photos 4 and 5). The
vertical extent of the burial was below the top of the tailings and above the bottom liner.
Steel pipe segments that were approximately l0 inches in diameter and four feet in length were
separated (Photo 6). The Licensee was unable to crush these pipes with the track on the bulldozer.
These pipes were filled with sand and buried at a separate time. The addition of sand packed within the
pipes was done to reduce potential void spaces within Tailings Cell 3 and is in accordance with SOp
PBL-I0, Section 7.0 (4) and Radioactive Material License No. UT 1900479, Amendment 10, Condition
10.58.
The disposal activities were for one load of 11e.(2) byproduct material from Strata Energy, Inc Ross
Project in Wyoming and one load from Encore Alta Mesa LLC in Texas. The material consisted of
dishwashers, air sampling cabinets, a desk, and crushable and non-crushable metal pipes, pVC and ABS
pipes, fiberglass pipes, and wiring. The inspector verified the Licensee performed the observedl le.(2)
byproduct material disposal operations in accordance with the current Sop.
First Quarter 2024ISL Decommissioning Debris Disposal Inspection Report
February 21,2024
Page 3
Upon leaving the restricted area, all personnel scanned themselves and no individual had a measurable
reading above site release limits.
Close Out Meeting
A preliminary inspection findings meeting was held with Mill management on January 31,2024 and
observations made during the inspection were discussed. This meeting included: Heather Mickelson,
Phil Goble, Terry Slade and Tanner Holliday (Environmental Lead). During this meeting, the Licensee
committed to submitting requested information (data packets). This information was received on
February 20,2024 and the inspection was finalized on February 20,2024. This date is considered the
closeout date for the inspection.
Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.58: "All ISR contaminated equipment shall
be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the banels crushed. Barrels containing soil or sludges
shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled with
tailings or soil prior to disposal. "
The activities observed and information gathered during this inspection support the conclusion that the
Licensee is complying with this license condition. The licensee confirmed that all materials were
crushed by rolling over them with the bulldozer prior to being placed in the excavation. The pipes were
crushed as they were placed into the excavation pit and compacted. Pipes that were not crushable were
filled with sand during disposal.
Radioactive Materials License #UT1900479, Condition 10.5C: "All ISR byproduct material shall be
buried in Impoundment No. 3 unless prior written approval is obtained from the Director for alternate burial
locations."
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. All 1le.(2) byproduct material was buried in Tailings
Cell No. 3.
Radioactive Materials License #1171900479, Condition 10.5D: "All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include all items required by
this License."
The activities observed and information gathered during this inspection support the conclusion that the
Licensee is complying with this license condition. The Licensee maintains records of the lle.(2)
byproduct material disposed of onsite. These records document the nature of each load of material
received, where it is buried, and how it was handled, including all measureg taken to comply with all of
License Condition 10.5.
Radioactive Materials License #UT1900479, Condition 10.5E: "Disposal Requirements for l1e.(2)
byproduct material: the licensee shall perform byproduct material disposal activities in accordance with the
current Standard Operating Procedure (SOP) for I le.(2) byproduct material disposal. Said plan includes the
following minimum provisions:
First Quarter 2024ISL Decommissioning Debris Disposal Inspection Report
February 21,2024
Page 4
(l) The material disposal area must be located on a tailings beach area of the conventional
impoundment or on an area of the impoundment that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the conventional impoundment;
(3) (Reserved)
(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
a. There are at least 4 feet oftailings sands under the bottom ofeach disposal area; and
b. The bottom ofeach disposal area is located at least 12feetfrom the sides or dikes ofthe
impoundment."
The activities observed and information gathered during this inspection support the conclusion that the
Licensee is complying with this license condition. The Licensee met the requirement to submit the
procedure with the initial version of SOP PBL-10, and now uses Revision R-4.0, dated August23,2023.
Revision R-4.0 addresses all of the items specified in License Condition 10.5. The original version and
every subsequent revision of this procedure were submitted to the Division for review and approval
prior to implementation.
Further, the Licensee is complying with the SOP, such as, minimizing void space, and placing the waste
in the tailing sands with at least four feet of sands below it and at least 12 feet from the side or dike of
the cell.
Radioactive Moterials License #aT1900479, Condition 10.5F: "The Licensee shall notify the Director in
writing at least 7 calendar days prior to the proposed scheduled date for disposal of any I le.(2) byproduct
material in the conventional impoundments.
An annual summary of the amounts of l le.(2) byproduct material disposed of from off-site generators shall
be included in the Annual Technical Evaluation Report rbquired in License Condition 12.2.'
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Division received notice (DRC-2024 -004217
and DRC-2024-004060) of the disposal electronically on January 10,2024, and January 16,2024.
These notifications comply with the 7 days advance notice requirement.
The annual summary submittal will be evaluated by DWMRC separately from this inspection.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements, the applicable SOp,
and license conditions with respect to disposal of 11e.(2) byproduct material generated as
decommissioning debris from ISL uranium recovery facilities.
Attachments: 1 1e.(2) Disposal Photolog
lle.Q) byproduct receipt notification dated and received on January 10,2024
I 1 e.(2) byproduct receipt notification dated and received on January 16, 2024. Document packet for Strata l le.(2) byproduct material bearing Bill of Lading# 23-047#l and#2
Document packet for Alta Mesa (2) byproduct material bearing Bill of Lading # l8l
Photo 1. I 1e.(2) byproduct material to be buried. Photo taken on January 31,
2024.
Photo 3. Energy Fuels Resources moving I Ie.(2) byproduct material into the
excavation pit. Photo taken on January 31,2024.
Photo 2. Energy Fuels Resources surveying the
Photo taken on January 31,2024.
excavation pit.
Photo 4. Energy Fuels Resources placing fill over the 1 1 e.(2) byproduct
material and compacting with a bulldozer. Photo taken on January 31,2024.
fi
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Photo 6. Final compacted area of the lle.(2) byproduct material burial
location. Photo taken on January 31, 2024
Photo 6. Pipe segments segregated for further compaction. Photo taken on
January 31,2024.
ENERGYFUELS
Energy Fuels Resources (USA) lnc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax 435 678 2224
www.energyfuels.com
Mr. Doug Hansen
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
January 16,2024
VIA Electronic Mail (PDF) and UPS
RECEIVED
By Divtsion of wasae lranagement and Radlatlon Conl/r/ .l 1:U p,1n, Jaa tA, m2l
Dear Mr. Hansen DRC -2024-004060
Re: 11e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifuing the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of one load by January 31st,2024.
If there are any questions regarding these shipments or the scheduling of the disposal activities, feel free to
contact me at the White Mesa Mill at435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
ENERGYFUELS
Energy Fuels Resources (USA) lnc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, tax 435 678 2224
www.energyfuels.com
January 10,2024
VIA Electronic Mail (PDF) and UPS
Mr. Doug Hansen
State of Utah Department of Environmental Quality
195 Nonh 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Hansen
Re: l1e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notiflzing the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of one load by January 24th,2024.
If there are any questions regarding these shipments or the scheduling of the disposal activities, feel free to
contact me at the White Mesa Mill at435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
Heather Mickelson <hmickelson@utah.gov>
11e-2 Documents
Garrin Palmer <GPalmer@energyfuels.com>
To: Heather Mickelson <hmickelson@utah.gov>
Tue, Feb 20,2024 at 12:53 PM
HiHeather,
Thanks for your patience. Please see the attached 11e-2. Have a good one
Disclaimer
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4 attachments
fi\ Encore.pdfE tsgx
m Strata (2).pdfE rctx
m Strata (f ).pdfumx
6 Strata (2).pdfs 167K
w2
Rev. No.: R-3.S
t0No.:FTJEI.S INC.STANDARD OPERATNG PROGDI.'RES Page lOof t2
vate: Jinl zolq
Namc of employee recciving the load:
Gercrator of thc Blproduct Material:
Shipper's Manifest orBill of Ladingnu)nber: @
$fl *" Statc of Utah given notice to the reccipUdicposal activitics associated with this foad? @
Who gave and wbcri wj$givcn?
2
Description of b;product material disposal area/activities:
Has each dnrm been inspccted to identify the presonoe of any void spaces?
Havc all drums with void sprccs becn fillcd with tqilings sands or soil? ,vn
lVhich tailinge cell was the material plrced in?(ll -1
WCI thcnaerial
bytailings sands?
plaa{ on a tailings bcach arca of thp cell or on an arra of tbo ceII tha was underlain
Page 11 of 12
STAT.IDASD OPERATTI-'IGRev. No.:R'3.5
Nri.:
'{
ManifestorBol,#: aj-nq7 4l tia
Irave the thickness and placement messuremcirts been verified and documentod for the disposal area by
the engineer, sPecificallY:
How was the area comPacied? TYas each lift compacted by heavy equipmcnt (such as a Cat D-O at least
sor
Environme'ntal
Coordinator's
for ISLin aoell approvod by thethe
wastc disPosal?
than 4 feetlesstailingsabovemaximutnlift thlckness
Wasthe fcetlifr
satrds undcr each disposalHas 4 farot of
c
sides ordikPsfectftomthedtea 6t least 12ofoachIe the bottom
of thc tailings
uppermost flexiblethis confirmed
Will the
elevatign
How
orthoexceedplanctheoftheoflinuhourbranetheof review)orsurvey(c.S.,
4 times placenrcnt of
Were void spaces filled with
lifts?
?
Was the properly covered?
Manifest or BoL#: a3-o17 s I fa
Are additional settlement monitors reguired to be placed?
No.: PBLI0
Rev.No.lR-3.5
Datr: Ausust 4.Nzt
"11EX6yFUELS
RESOURCES (USA) rNC.
STANDARD OPERAUNG PROCBDT,'RBS
Title: lie{2) ByrpdrrctDeporal
Page12of 12
If rgquired, where were the settlement mar-ters placed?
.&a
Radiological reccip survey measure,meots:
o
Breathing Zohe:
l. Was aBrcathing Zone Sample collectctt? Vcs o@
2. If yes, what wens the results of the sampling?
-Uh
.
Was a phoograph takcn during the rmtoading activities{h or No
No.: PBLI0
Rov. No.: R-3.5
Date: Ausust4.W2l
EI.IERGYFtE
STANDARD OPERATIIYG PRO(tsDT..IRES
Title: ilo.(2) Brsodrrr pispord
PagelOof t2
Date:t/c/
Nane of employec receiving the
Gsprator of ths Blryroduct Material:
Shippcr's Mtmife.storBitl oftradingnulnber: ri-O{7 t I, *t ?.
lVas the State of Utah given notice to the receipt/disposal rctivities associated with this toad? (,Q,
No
IVho gave and whri wa$givcn?
2
Description of blryroduct materid disposal area/activities:
Has each drum been inspected to identif-y thc presence of any void spaces?
rfavc all drums with void sprccs becn filled with tailings sands or soil?
Which tailinge ccll was the matcrial placed in?
Was thc materialplaa{
bytailings sands?
on a tailings bcach arca of tbc ccll or on an arGa of the cell tha was underlain
Page 11 of 12STAT.IDA8D OPERATN-{GRev. No.: R-3.5
Nd.:
:. I
Manifest or EOL #: , 2-j-Dq7 4 I # a
Have the thickness and placement measurements been verified and documentod for the digposal arca by
the engincer, sPecifi callY:
How was tlre area comp4cted? Was each lift compacted by heavy equipment (such as a Cat D-6) at least
lifts?
or
Environmental
Coordinator's
for ISLby thein aeell ap'provedthe
waste disposal?
tailings less than 4 feetmaximurn lift tblckness
fcctWasthemaxfunurnlift
uudcr disposalsandsHas 4 fbot of
area?*/c < -
least 12 feptfrom thp sides ordikPsrtdlcaoachoftheIsbottom
cthcoftailings
this conflrmed (c.9.' survey
grade o{ the
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ortheoxcecdmatorialplanctheofthewiutheoflincrflexiblefnembranetheofelcvationuppeimost
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\Fy'ere void spaces frlled with
Was the properly coverod?
Manifest or BOL#: a3-O{7 $ I f:.
Are additional scftIement monitors required to bc placed?
rolsx6y FUELS RESOURCES (USA) INC.
STANDARD OPERATING PRWEDI,'RBS
Tltle: l1e.{2) BvprqductDoposal
Page 12of 12
2g2t
l0
Rev. No.: R-3.5
Dato:
If requircd, where were tlre settlementmarkers placed?
rqA
Radiological receipt survey measunements:
t.o
Breathing Zone:
l. Was aBrcathing Zonesample oollectcd? Ye.s o@
2. If yes, what werc the results of tbe sampling?
lVas a pbotograph takcn during the untoading activities{fr or No
Energy Fuels Resources (USA) Corp"White Mesa M1II
6425 S. Highway 191Blanding UT 84511
Date
01/0912024
01/09 /2024
Transacti-on No.
s1 996
Time
14:07
l-5:36
fn:
Out:
l-eSca
t_
1Vehicle ID:
Trailer ID:
Account ID:Order ID:
Owner ID:
Material ID:Destin. fD:
Comments:
Operator:
15 011
STRATA ENE STRATA ENERGY
11 (e) 2 Mat 11 (e) 2 Material Receipt
BLAND]NG
Gross:
Tare:
Net:
61140
46840
14300
1b (M)
1b
1b
Fe \#'BOL#23-0 47 #2 TRL3838 BrN1, BrN24 Charge by Weight
Signature:
BILL.()FIADIT.IG & UCENCE MATERIAI. SHIPPING FORM
Shipment #: 23-U7 AL
Carr'ler Name: MP Envkonmental Services
Carrier HazMat Registration #: 05301955O1168D
HazMatCompany lD: 4665
To:
Facility: White Mesa Mill
Ucense #: UT 190047
Address:6425 S. Hwy191, Blandl#h, 84511
Contact Person: GaJrin Palmer
Phone #: 435-67&4114
'l hereby declare that the contents of this consignment are fully and accuratev described above bythe proper shipping name,
and are classi{ied, packaged marked and labeled/placarded, and are in all respects in proper condition for transport
according to applicable international and national governmental re8ulations."
Shipper's Si$ature:
Response Number: 3O7 -467 -9392
Date: l/LltaLq
24 Hr Emeryency
From:
Facility:Strata Energv, lnc, Ross ProieEt
License #: WYSUA16O1
Address: 2929 New tbyen Rd., oshoto, wY, 82721
Contact Person: John Durand
Phone: !X)7467.5995
Proper Shipping Name: UN 3321, Radioactive material, low specific activitv (tSA-lD, 7
Radionuclides Present
Radionuclide
U lnatl
Ra-226
Th-230
Pb-210
Po210
Radionuclides Present Natural Uranium, Ra-226, Th-230
Physical Form: Surface contamination on processing wastes
Chemical Form: UO"RaCO3, ThSOa
Package: roll-offconteiner which meets the rcquirementg of 49 CFR 173.410
Volume of Material: 22 Yd^3
Ci = 3.7E10
Total Activity 5.748+08 Bq ( 1.5sE-02 Ci)?"-.er,6Jl4b te.?,!
Exduslve Use ShiDment
L22e+O7
3.80E+07
Quantiw (Bol
4.50E+O8
S.60E+07
1.828+07
BITL-OF.IADING & L]CENCE MATERIAT SHIPPIN6 FORM
Shipmeni#:23547 #2
Carrier Name: MP Environmental Services
Carrier HazMat Registration #: 05 3O9550116BD
HazMat Company lD: 4665
"l hereby declare that the contents of this consignment are fully and accurately described above by the p.oper shipping name,
and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport
according to applicable international and national gov€rnmental regulations,"
Shipper's Signature:lLn^/;*
24 Hr Emergency Response Number: 307-467-9392
Date:t / z/ tazq
To:
Facility:Whire Mesa Mill
License s: UT 190047
Address: 6425 S. Hwy191, BlandinB, Utah,84511
Contact Person: Garrin Palmer
Phone #: 435-67&41L4
Facility:Strata Enersv. lnc. Ross Proiect
License f: WYSUA-15O1
Address: 2929 New Haven Rd., oshoto, wy,82721
Contact Person: John Durand
Phone: 307-467-5995
lD: 174549
Shipping Name: UN 3321, Radioactive material, low specific activity (tsA-tr), 7
Radionuclides Present
Radionuclide
U (nirt)
Ra-226
Th-230
Pb-210
Po-210
Radionuclides Present: Natural Uranium, Ra-226 Th-230
Physical Form: Surface contamination on processing wastes
{1 Ci = 3.7E10
Form: UO4. RaCOI ThSO4
Package: roll-offcontainerwhich meets the requirementsof 49 CFR 173.410 1..\{rr*tl(l&of Material:8 Yd^3
Activity:3.27E+OB Bq ( 8.85E-03 ci)l.q.2tluse
Quantity (Bql
2.82E+08
1.35E+07
1.86E+O7
5.04E+05
7.21E+06
Controled Elevation used (Cell 3)
BOL #
Area
lnitial shot for trench
Top of trench
Bottom of trench
lnitialshot used for material
Top of material in trench
Top of cell 3 liner
Feet below liner
23-047 #L#2
Elevation
s613.5
Transit Shot
1.9
7.8
11.5
5607.5
5603.9
5606.41
5608.5
2.O9
1.9
8.99
Rev. No.: R-3.5
Dste:
STANDARD OPERATtr{G
INC.
PROCEDTJRES Page I0 of 12
Date:tlrel t-'l
Naineofemploycereceivingtheload: fi .^(l t a.H,^-n*.,
Generato,roffh.e BypoductMaterial: E,ar"t e,- ^ t+ ^ *t.sn (Aes*^J
Shippcr's Manifest or Bill of Iading nulnbcr:
*o* *" staoe of utah given notice to the receipt/di$posal activities associated with rhis LaddD,
Who gave and wheri ryas the given?
Poseription of byproduct mat€rial area/activities:
Has each dnm been inspected to idcntif-y the preenoe of nny vgid spaces ? I , I
Have all drums with void cpees becn fiIled with taitings sands or soil? rU&
lVhich tailings ccll was the marerial ptaced in? Lr-lt 3
Was the material plaed on a
by taitings sands?
AilingS bcach area of tho ccll or on an area of the cell rtrat was underlain
Page t1 of12
t
STANDARD OPERATINGRev, No,: R-3.5
Nti.:
r{
Manifest or BOI. #:9t
Have the thiokness and pracernent nreasurements been verified and documented for the disposal area by
the engineer, sPecifi callY:
How was the area compacted? Wao erch lift compacted by heavy equiplhent (such as a Cdt D6) at least
Environmental
Coordinator's
sor
for ISL
a r
by thein a eell approved
wastre disposal?
the
4 fentless thanabove tailingsmarjmurnlift ttrickness
2ofsubsequentlift'Wasthe
underbeensandsof4HasfootHilings
$ea?JL t-
C
ordike-sfromthp sidesar-ea at least 12festIsthebottomofoach
of thc tailiags
uppcimost flexible
this conflrmed
theoforggadetheplaneexceedtheofelevationthewill.U-2celltheofInermenrbranetheofelevatign r€vlew)orsurvey(c.9.wasHow
4 pnor to placement of lifts?
Were void spaces filled with
Was the shiPment covered?
Nir.: PBLIO
Rev. No,l R-3.5
Date: Aucust 4,W21
ENBRCYFIJETJ RESOURCES (USA) rNC.
STANDARD OPERAfl NG PRQCEDURES
Titlei I le.(2) Brpodua Djrpooal
Page12of 12
Manifcsror'Bol"#: lGt
Are additional settlement monitors requircd to be placed?.
If rqquired, *Yy" the settlementmarkers placed?
Radiological survey measurements:
Breathing Zclner
l. Was aBrcathing Zone Samplepollectcd? Yes or$
2, If yes, what wcre the rc,sults of the sampling? (/
tr//,
lVas a photograph taken during the unloading aotivities? 4prN.
BILL OF LADING
SHIPMENT ID# 181
SHIPPER (From):
Encore ALTA MESA LLC
AI}DRESS:
755 Co. Rd. 3 I 5 Encino, TX 78353
Driver's Signature: *
SHIPMENT DATE:I-12-24
CONSIGNEE (To):
Enerry Fuels Resources (USA) Inc
6425 South Highway 191
uT 8451 I
ADDRESS:
P. O. Box uT 8451 I
SHIPPER LTCENSE NO.: RO536O TELEPHONE NO,
(43s) 678-222t
SHIPPER NO.:CARRIER NAME AND ADDRESS:
Environmental Evolutions
P.O. Box 709
Robstown, TX 78380
36 l-387-9400
CARRIER HAZMAT REG. NO.:
Trailer #Container# GFLU001145 Seal #Seal
CLASSIFICA,TION
Objects
30,000 lbs.(SCO) waste material and soils
Exclusive use shipment
Net ouantiw:fiilE'applied
I - / 6'7/Y
CERTIFICATION: These is to certifu that the above named articles are properly classified,
described, packaged, marked and labeled, and are in proper condition for transportation,
according to the applicable regulations of the Deparhnent of Transportation.
Shippers Signature Date:l- I /- tq
T
pkg1
RQ (net)
l- tr"21
SIIIPPER USDOT NO.:CONSIGNEE
LICENSE NO.:
ur- 1900479
SIIIPPER TELEPHONE
NQ.:361-568-3549
CARRIERUSDOT
Cubic feet
or
MATERIALAT'ID
Objects (SCO-l) and soil, non-fissile, Class 7
Dry l1 (E).2 By-Product material. Natural uranium and
daughters.
Activity: illrFWilIryA
EMERGENCY CONTACT:
A.J. Rodri guez 361-701 -8042
UN29l3, Radioactive Surface Contaminated