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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 :i ,:. H '!: fr I' ) 'n'- 1-- i!;'a., 't. ,/ 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 The information contained in this communication from the sender is confidential, It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information ls strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast, a leader in email security and cyber resilience. Mimecast integrates email defenses with brand protection, security awareness training., web security, compliance and other essential capabilities. Mimecast helps protect large and small organizations from malicious activity, human error and technology failure; and to lead the movement toward building a more resilient world. To find out more, visit our website, 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$givcn? 2 Description of blryroduct materid disposal area/activities: Has each drum been inspected to identif-y thc presence of any void spaces? rfavc all drums with void sprccs becn filled with tailings sands or soil? Which tailinge ccll was the matcrial placed in? Was thc materialplaa{ bytailings sands? on a tailings bcach arca of tbc ccll or on an arGa of the cell tha was underlain Page 11 of 12STAT.IDA8D OPERATN-{GRev. No.: R-3.5 Nd.: :. I Manifest or EOL #: , 2-j-Dq7 4 I # a Have the thickness and placement measurements been verified and documentod for the digposal arca by the engincer, sPecifi callY: How was tlre area comp4cted? Was each lift compacted by heavy equipment (such as a Cat D-6) at least lifts? or Environmental Coordinator's for ISLby thein aeell ap'provedthe waste disposal? tailings less than 4 feetmaximurn lift tblckness fcctWasthemaxfunurnlift uudcr disposalsandsHas 4 fbot of area?*/c < - least 12 feptfrom thp sides ordikPsrtdlcaoachoftheIsbottom cthcoftailings this conflrmed (c.9.' survey grade o{ the cEll? ilo or rcview) ortheoxcecdmatorialplanctheofthewiutheoflincrflexiblefnembranetheofelcvationuppeimost How wa$ 4 tim€s placenrcnt of \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