DRC-2014-007461 - 0901a068804d8afa

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
GARY R. HERBERT
Governor
Rusty Lundberg
Director
SPENCER J. COX
Lieutenant Governor
December 29, 2014 DRC-2014-007365
Kathy Weinel DRC-2014-007461
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Compliance—Radioactive Material License No. UT 1900479
2014 Radiation Protection Inspection, Module RADMOD-Alternate Feed-2014
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on December 4, 2014 by a representative of the Division of Radiation Control (DRC), Utah Department of
Environmental Quality.
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to the management of Alternate
Feed Materials were found to be in compliance with relevant requirements.
Additionally, this acknowledges the receipt of your letter dated December 19, 2014. The DRC concurs
with the manner in which the FMRI/Fan Steel alternate feed material is to be stored.
The inspection is considered closed. A copy of the Inspection Report is enclosed.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
Rusty Lundberg, Director
RL/BMI:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^1097 • T.D.D. [phone]
www. deq. utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-AF-2014: Alternate Feed Management
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): December 4, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Harold Roberts, Terry Slade, David Turk, Kathy Weinel (Energy Fuels
Resources)
Consulted With: Phil Goble, Ryan Johnson, Russ Topham (Utah Division of Radiation
Control)
Inspection Summary
The inspection was opened on December 4, 2014 with a meeting with D. Turk.
Areas/Topics inspected included:
• Alternate Feed Material Inventory
• Maximum Quantity of Feed Material Stored on the Mill Site
• Tailings Cell Capacity
• FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
• Dawn Mining Alternate Feed Material Management
• Visible Dust Assessment
The inspector held a closeout meeting on December 4, 2014 with D. Turk of Energy Fuels
Resources to review the inspection activities, observations, and conclusions.
Findings
One questionable practice was observed during the inspection. There was some uncertainty
regarding the appropriateness of the manner in which the FMRI/Fan Steel feedstock was being
stored.
Inspection Items
Alternate Feed Material Inventory
D. Turk conducted a tour of the feed materials stored at the mill site. Materials stored at the site
include:
• Cabot Performance Materials which is stored on the ore pad in a pile with a 6"-8" soil cover.
• FMRI/Fan Steel feedstock where material received earlier is stored on the ore pad in a pile
Page 1 of 4
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2014\lnspectionReportRev0.doc
with an approximately one foot soil cover. More recently received material is stored
adjacent to the pile but are stored in the synthetic sacks/bags in which it was shipped.
Material continues to be received and stored in the synthetic bags.
• Dawn Mining Uranium Material is stored on a concrete pad in multi-layered synthetic sacks.
• Polydrums overpacked in yellow outer polydrums contain material from Cameco
Corporation and are stored on a concrete pad.
In addition to the above alternate feed material uranium ore continues to be stored in a pile on the
ore pad and material cleaned from the SAG mill is stored in a pile for future uranium recovery
processing.
A review of shipping documents showed that manifested material corresponded with the records
maintained at the mill site. Shipment dates, manifest numbers, material weights (both shipper and
Licensee measurements) were verified with mill records and tracking documents.
Maximum Quantity of Feed Material Stored on the Mill Site
The mill site maintains records of the quantities of feed material that is received at the site and also
the amount of product that is exported from the site. The corporate office tracks the feed material
to ensure that the quantity limits are not exceeded. A Utah Division of Radiation Control (DRC)
engineer verifies that quantities specified in the surety are not exceeded.
Tailings Cell Capacity
It was reported that as of December 13, 2013 the remaining capacity in the tailings system was
3,286,533 dry tons. With limited processing having taken place during 2014, it is concluded that
excess^capaeity^x4sts for nevv^and in the near future. ^
The licensee cannot receive any feed materials that would cause the facility to exceed the tailings
cell disposal capacity. Except for a very small fraction (the percentage of uranium found in feed
material, <1%), essentially all the material by volume/mass will be placed in the tailings disposal
cell. Therefore, it can easily be determined whether or not additional feed material can be accepted
for processing based on the cell capacity.
FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
The FMRI/Fan Steel material stored at the mill is currently made up of two "piles." One pile is
comprised of material from the first round of shipments. As described by the Licensee, the material
arrived in synthetic sacks but due to exposure to the elements the sacks began to deteriorate so the
decision was made to remove the material from the sacks and consolidate the material into a large
pile, and to prevent the material from becoming dispersed an approximately one foot earthen cover
was placed over the pile.
The second pile is being created with the second round of shipments. The plan was to duplicate the
process of removing the material from the sacks and to place over the resulting pile an earthen
cover. A shipment of sacks had just been received by the mill indicating that the second pile is not
yet completed.
A review of License Condition 10.20 and the referenced amendment request raised the concern that
Page 2 of 4
U:\MON_WAST\Biraai\wp\Inspections\Energy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2014\lnspectionReportRev0.doc
the Fan Steel material was not being stored properly. The amendment request stipulates that:
"The Uranium Material will not be unloaded from the shipping bags until just prior to being
introduced into the Mill processing circuit. Leaving the material in the shipping bags will
eliminate the need for additional dust control measures during storage."
The manner the material is stored does not conform to this requirement.
It is acknowledged that the sacks/bags are susceptible to weathering and deterioration and if left
without remedial actions could result in exposed contaminated material and a dispersal problem.
Dawn Mining Alternate Feed Material Management
License Condition 10.20.A(1) requires that:
"Dawn Mining Uranium Material stored (stockpiled) at the Mill Site longer than 14 days
shall be covered with a durable geomembrane cover resistant to damage by ultraviolet (UV)
radiation and sufficient ballast shall be place over the cover to prevent wind uplift of the
cover during peak wind conditions at the site."
This material has been in storage longer than 14 days. Initially, it was planned to transport the
material in bulk form thus the need for a cover to prevent the material from being dispersed. Before
the first shipment it was decided to contain the material in synthetic sacks for transport and storage.
Although this does not strictly adhere to the specifications of the license condition, the practice
satisfies the intent of the requirement as deemed by other DRC representatives. The sacks have
three inner layers of containment and will inhibit dispersal of any of the material provided the
integrity of the sacks has not been compromised. Visual inspection of the sacks verified that they
are intact and in good condition. Upon request, the Licensee provided specifications for the sacks'
synthetic outer layers which indicate a resistance to UV rays.
Visible Dust Assessment
An unusual rain storm was taking place during the day ofthe inspection so dust was not of concern
at that time and could not be assessed further.
Closeout Meeting
The inspector held a closeout meeting with D. Turk of Energy Fuels Resources (USA) on December
4, 2014. The observations made during the inspection were summarized during the meeting.
The storage of the FMRI/Fan Steel material was discussed. The inspector pointed out that the
manner the material was being stored was not in accordance with the commitments made in the
license and in the amendment request. The Licensee indicated that the material was being "staged
for processing." The inspector recognized the dilemma created by the specific storage requirement;
strict compliance could cause undesirable consequences with respect to release and spread of
contamination.
The inspector suggested that further discussion with the DRC management would be required to
determine the extent and severity of the irregularities regarding the material storage; therefore, the
inspection would remain open.
Post Inspection Action
Internal DRC discussions concluded that, notwithstanding the license requirements, the FMRI/Fan
Page 3 of 4
U:\MON_WAST\Bimai\wp\Inspections\Energy Fuel, Blanding, L)T\2014\RADMOD-ALT FEED-
2014\InspectionReportRev0.doc
Steel material must be contained while in storage. A mutually (Licensee and DRC) agreed upon
approach to resolve the dilemma would be required.
On December 10, 2014 a conference call between the Licensee (H. Roberts, D. Turk, and K.
Weinel) and the DRC (P. Goble, B. Imai, and R. Johnson) was held to discuss the FMRI/Fan Steel
material storage issue.
It was concluded that the practice of removing the material from the sacks/bags and placing the
earthen cover over the material was an acceptable resolution to the issue; provided that once the
cover was placed it would be inspected regularly to ensure that the cover has not been compromised
in any manner during the duration ofthe storage. It was agreed that this resolution could be
documented in formal correspondence(s) between the Licensee and DRC and that a license
amendment would not be required.
Once the resolution is finalized the Licensee is expected to take whatever internal actions are
necessary to ensure satisfactory implementation.
On December 19, 2014 the DRC received the Licensee's letter specifying the actions to be taken
regarding the FMRI material storage and "dust mitigation strategy." With this information the
inspection will be able to be closed.
Conclusion
With the resolution of the material storage concern, and based on the items inspected, it is
concluded that the Licensee is in compliance with the management of alternate feed material.
Recommendations for the Licensee
It is recommended that the Licensee use its discretion and manage the stored FMRI/Fan Steel
material in the most efficient manner. It is not necessary to wait for the sacks/bags to fail before the
feed material is separated and covered.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai December 24, 2014
(Name) ^(Signature) (Date)
Page 4 of 4
U:\MON_WAST\Bimai\wp\InspectionsVEnergy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2014\inspectionReportRev0.doc
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
ENERGY FUELS 303 974 2140
201 4—007324 www.energvfuels.com
December 19, 2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") December 4, 2014 Alternate
Feed Inspection at the White Mesa Mill, and teleconference of December 10, 2014
between DRC and Energy Fuels Resources (USA) Inc. ("EFRI"), regarding storage of
Fan Steel Feed Materials, Radioactive Materials License ("RML") 1900479
Dear Mr. Lundberg:
This letter responds to the above referenced teleconference of December 10, 2014, regarding
the DRC alternate feed inspection conducted at the White Mesa Mill (the "Mill") on December
4, 2014.
The DRC noted during the December 4, 2014 inspection, that the FMRI material staged on the
Ore Storage Pad, was covered with clean soil prior to processing. EFRI placed the clean soil
cover as a dust control measure during storage. DRC noted that EFRFs actions in using a clean
soil cover were adequate and appropriate and provided sufficient dust mitigation. However,
DRC noted that in the RML amendment application, EFRI planned to keep the FMRI material in
the shipping bags until the material was readied for processing. The RML amendment
application stated that the shipping bags were the planned dust mitigation measure.
EFRI added the clean soil cover as an added dust mitigation measure when it was noted during
weekly inspections that the shipping bags were not sturdy enough for long term storage. The
shipping bags began to show wear and began tearing a few months after delivery. To provide
continuous dust mitigation, EFRI added the clean soil cover.
During the December 10, 2014 teleconference, DRC requested that EFRI provide documentation
of the change in dust mitigation strategy. This letter serves as the documentation of the change
in dust mitigation methods that are currently employed for the FMRI materials housed at the
Mill.
;
Letter to Rusty Lundberg
December 19, 2014
Page 2 of 2
As previously noted, all ores or feeds are inspected weekly as required by the DRC-approved
Discharge Minimization Technology Plan ("DMT"). Any inconsistencies in the dust
minimization for the FMRI material will be addressed as a result of the weekly inspections.
Further, any new FMRI materials received at the Mill will be subject to the same dust
minimization strategy that is currently used. The FMRI material will be maintained in the
shipping bags, as long as the shipping bags provide adequate dust minimization and are
maintaining their integrity. Should the shipping bags show signs of wear or disintegration, the
material from the worn or broken bags will be segregated, then covered with clean soil as the
dust minimization and control. Soil cover will be placed within 2 weeks of the inspection noting
shipping bag damage.
As previously noted, the soil cover is sufficiently protective and provides adequate dust
minimization and this letter serves as the documentation of the change.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Harold R. Roberts
David E. Turk
Dan Hillsten
Scott Bakken
2
Alternate feed Material
inspection Report
INSPECTION REPORT
Inspection Module: RADMOD-AF-2014: Alternate Feed Management
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): December 4, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Harold Roberts, Terry Slade, David Turk, Kathy Weinel (Energy Fuels
Resources)
Consulted With: Phil Goble, Ryan Johnson, Russ Topham (Utah Division of Radiation
Control)
Inspection Summary
The inspection was opened on December 4, 2014 with a meeting with D. Turk.
Areas/Topics inspected included:
• Alternate Feed Material Inventory
• Maximum Quantity of Feed Material Stored on the Mill Site
• Tailings Cell Capacity
• FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
• Dawn Mining Alternate Feed Material Management
• Visible Dust Assessment
The inspector held a closeout meeting on December 4, 2014 with D. Turk of Energy Fuels
Resources to review the inspection activities, observations, and conclusions.
Findings
One questionable practice was observed during the inspection. There was some uncertainty
regarding the appropriateness of the manner in which the FMRI/Fan Steel feedstock was being
stored.
Inspection Items
Alternate Feed Material Inventory
D. Turk conducted a tour of the feed materials stored at the mill site. Materials stored at the site
include:
• Cabot Performance Materials which is stored on the ore pad in a pile with a 6"-8" soil cover.
• FMRI/Fan Steel feedstock where material received earlier is stored on the ore pad in a pile
Page 1 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2014\RAD]VIOD-ALT FEED-
2014\InspectionReportRev0.doc
with an approximately one foot soil cover. More recently received material is stored
adjacent to the pile but are stored in the synthetic sacks/bags in which it was shipped.
Material continues to be received and stored in the synthetic bags.
• Dawn Mining Uranium Material is stored on a concrete pad in multi-layered synthetic sacks.
• Polydrums overpacked in yellow outer polydrums contain material from Cameco
Corporation and are stored on a concrete pad.
In addition to the above alternate feed material uranium ore continues to be stored in a pile on the
ore pad and material cleaned from the SAG mill is stored in a pile for future uranium recovery
processing.
A review of shipping documents showed that manifested material corresponded with the records
maintained at the mill site. Shipment dates, manifest numbers, material weights (both shipper and
Licensee measurements) were verified with mill records and tracking documents.
Maximum Quantity of Feed Material Stored on the Mill Site
The mill site maintains records of the quantities of feed material that is received at the site and also
the amount of product that is exported from the site. The corporate office tracks the feed material
to ensure that the quantity limits are not exceeded. A Utah Division of Radiation Control (DRC)
engineer verifies that quantities specified in the surety are not exceeded.
Tailings Cell Capacity
It was reported that as of December 13, 2013 the remaining capacity in the tailings system was
3,286,533 dry tons. With limited processing having taken place during 2014, it is concluded that
excess capacity exists for now and in the near future.
The licensee cannot receive any feed materials that would cause the facility to exceed the tailings
cell disposal capacity. Except for a very small fraction (the percentage of uranium found in feed
material, <1%), essentially all the material by volume/mass will be placed in the tailings disposal
cell. Therefore, it can easily be determined whether or not additional feed material can be accepted
for processing based on the cell capacity.
FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
The FMRI/Fan Steel material stored at the mill is currently made up of two "piles." One pile is
comprised of material from the first round of shipments. As described by the Licensee, the material
arrived in synthetic sacks but due to exposure to the elements the sacks began to deteriorate so the
decision was made to remove the material from the sacks and consolidate the material into a large
pile, and to prevent the material from becoming dispersed an approximately one foot earthen cover
was placed over the pile.
The second pile is being created with the second round of shipments. The plan was to duplicate the
process of removing the material from the sacks and to place over the resulting pile an earthen
cover. A shipment of sacks had just been received by the mill indicating that the second pile is not
yet completed.
A review of License Condition 10.20 and the referenced amendment request raised the concern that
Page 2 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2014\InspectionReportRev0.do/*
the Fan Steel material was not being stored properly. The amendment request stipulates that:
"The Uranium Material will not be unloaded from the shipping bags until just prior to being
introduced into the Mill processing circuit. Leaving the material in the shipping bags will
eliminate the need for additional dust control measures during storage."
The manner the material is stored does not conform to this requirement.
It is acknowledged that the sacks/bags are susceptible to weathering and deterioration and if left
without remedial actions could result in exposed contaminated material and a dispersal problem.
Dawn Mining Alternate Feed Material Management
License Condition 10.20.A(1) requires that:
"Dawn Mining Uranium Material stored (stockpiled) at the Mill Site longer than 14 days
shall be covered with a durable geomembrane cover resistant to damage by ultraviolet (UV)
radiation and sufficient ballast shall be place over the cover to prevent wind uplift of the
cover during peak wind conditions at the site."
This material has been in storage longer than 14 days. Initially, it was planned to transport the
material in bulk form thus the need for a cover to prevent the material from being dispersed. Before
the first shipment it was decided to contain the material in synthetic sacks for transport and storage.
Although this does not strictly adhere to the specifications of the license condition, the practice
satisfies the intent ofthe requirement as deemed by other DRC representatives. The sacks have
three inner layers of containment and will inhibit dispersal of any of the material provided the
integrity of the sacks has not been compromised. Visual inspection of the sacks verified that they
are intact and in good condition. Upon request, the Licensee provided specifications for the sacks'
synthetic outer layers which indicate a resistance to UV rays.
Visible Dust Assessment
An unusual rain storm was taking place during the day of the inspection so dust was not of concern
at that time and could not be assessed further.
Closeout Meeting
The inspector held a closeout meeting with D. Turk of Energy Fuels Resources (USA) on December
4, 2014. The observations made during the inspection were summarized during the meeting.
The storage of the FMRI/Fan Steel material was discussed. The inspector pointed out that the
manner the material was being stored was not in accordance with the commitments made in the
license and in the amendment request. The Licensee indicated that the material was being "staged
for processing." The inspector recognized the dilemma created by the specific storage requirement;
strict compliance could cause undesirable consequences with respect to release and spread of
contamination.
The inspector suggested that further discussion with the DRC management would be required to
determine the extent and severity of the irregularities regarding the material storage; therefore, the
inspection would remain open.
Post Inspection Action
Internal DRC discussions concluded that, notwithstanding the license requirements, the FMRI/Fan
Page 3 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2014\InspectionReportRev0.doc
Steel material must be contained while in storage. A mutually (Licensee and DRC) agreed upon
approach to resolve the dilemma would be required.
On December 10, 2014 a conference call between the Licensee (H. Roberts, D. Turk, and K.
Weinel) and the DRC (P. Goble, B. Imai, and R. Johnson) was held to discuss the FMRI/Fan Steel
material storage issue.
It was concluded that the practice of removing the material from the sacks/bags and placing the
earthen cover over the material was an acceptable resolution to the issue; provided that once the
cover was placed it would be inspected regularly to ensure that the cover has not been compromised
in any manner during the duration of the storage. It was agreed that this resolution could be
documented in formal correspondence(s) between the Licensee and DRC and that a license
amendment would not be required.
Once the resolution is finalized the Licensee is expected to take whatever internal actions are
necessary to ensure satisfactory implementation.
On December 19, 2014 the DRC received the Licensee's letter specifying the actions to be taken
regarding the FMRI material storage and "dust mitigation strategy." With this information the
inspection will be able to be closed.
Conclusion
With the resolution of the material storage concern, and based on the items inspected, it is
concluded that the Licensee is in compliance with the management of alternate feed material.
Recommendations for the Licensee
It is recommended that the Licensee use its discretion and manage the stored FMRI/Fan Steel
material in the most efficient manner. It is not necessary to wait for the sacks/bags to fail before the
feed material is separated and covered.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By: Boyd M. Imai
_ T^JA/^Jh^^ December 24,2014
(Name) ^^gnature) (Date)
Page 4 of 4
U:\MON_WAST\Bimai\wp\lnspections\Energy Fuel, Blanding, UT\2014\RADMOD-ALT FEED-
2ul4\InspectionReportRev0.d" -
Energy fuels Submittal
FMRI/Fan steel Storage
si V Boyd Imai <[e-mail]>
White Mesa Mill Inspection Response
Fri, Dec 19, 2014 at 2:24 PM Kathy Weinel <[e-mail]>
To: Rusty Lundberg <[e-mail]>
Cc: Phillip Goble <[e-mail]>, Thomas Rushing <[e-mail]>, "[e-mail]"
<[e-mail]>, Harold Roberts <[e-mail]>, Jaime Massey <[e-mail]>,
David Turk <[e-mail]>, Dan Hillsten <[e-mail]>
Mr. Lundberg,
Attached please find the documentation requested by DRC Staff on December 10, 2014 resulting from a DRC
inspection of the White Mesa Mill on December 4, 2014.
A hard copy has been sent via express carrier for your convenience.
Please contact me if you have any questions on this submittal.
Kathy Weinel
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assuiauve Maruigei
t: 303-389^134 | f: 303-389-4125
225 Union Blvd., Suite 600
Lakewood, CO, US, 80228
http://www.energyfuels.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you are not the
intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or copy
this message if you are not the intended recipient(s).
«Q Response to 12.04.14 lnsptn.pdf
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.enerpvfuels.com
December 19,2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") December 4, 2014 Alternate
Feed Inspection at the White Mesa Mill, and teleconference of December 10, 2014
between DRC and Energy Fuels Resources (USA) Inc. ("EFRI"), regarding storage of
Fan Steel Feed Materials, Radioactive Materials License ("RML") 1900479
Dear Mr. Lundberg:
This letter responds to the above referenced teleconference of December 10, 2014, regarding
the DRC alternate feed inspection conducted at the White Mesa Mill (the "Mill") on December
4, 2014.
The DRC noted during the December 4, 2014 inspection, that the FMRI material staged on the
Ore Storage Pad, was covered with clean soil prior to processing. EFRI placed the clean soil
cover as a dust control measure during storage. DRC noted that EFRI's actions in using a clean
soil cover were adequate and appropriate and provided sufficient dust mitigation. However,
DRC noted that in the RML amendment application, EFRI planned to keep the FMRI material in
the shipping bags until the material was readied for processing. The RML amendment
application stated that the shipping bags were the planned dust mitigation measure.
EFRI added the clean soil cover as an added dust mitigation measure when it was noted during
weekly inspections that the shipping bags were not sturdy enough for long term storage. The
shipping bags began to show wear and began tearing a few months after delivery. To provide
continuous dust mitigation, EFRI added the clean soil cover.
During the December 10, 2014 teleconference, DRC requested that EFRI provide documentation
of the change in dust mitigation strategy. This letter serves as the documentation of the change
in dust mitigation methods that are currently employed for the FMRI materials housed at the
Mill.
Letter to Rusty Lundberg
December 19, 2014
Page 2 of 2
As previously noted, all ores or feeds are inspected weekly as required by the DRC-approved
Discharge Minimization Technology Plan ("DMT")- Any inconsistencies in the dust
minimization for the FMRI material will be addressed as a result of the weekly inspections.
Further, any new FMRI materials received at the Mill will be subject to the same dust
minimization strategy that is currently used. The FMRI material will be maintained in the
shipping bags, as long as the shipping bags provide adequate dust minimization and are
maintaining their integrity. Should the shipping bags show signs of wear or disintegration, the
material from the worn or broken bags will be segregated, then covered with clean soil as the
dust minimization and control. Soil cover will be placed within 2 weeks of the inspection noting
shipping bag damage.
As previously noted, the soil cover is sufficiently protective and provides adequate dust
minimization and this letter serves as the documentation of the change.
Please contact me if you have any questions or require any further information.
Yours very truly.
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Harold R. Roberts
David E. Turk
Dan Hillsten
Scott Bakken
2
Alternate Feed
ALTERNATIVE FEED
w. Dawn Mining
RIS-
Oate Received
WMM
Energy Fuels Dawn Dawn WMM Dawn % WMM% Dry
Scale house Weight lbs Tons Tons moisture moisture Tons Bill of lading # Discription
WMM
%U
WMM Est.
lbs. U
Dawn
IbsU
Dawn wet
mg/kg U
7/14/2014
7/16/2014
7/23/2014
7/23/2014
7/30/2014
7/30/2014
8/6/2014
8/20/2014
8/20/2014
8/27/2014
8/27/2014
9/4/2014
9/4/2014
9/10/2014
9/17/2014
9/18/2014
9/29/2014
10/3/2014
10/8/2014
10/9/2014
10/15/2014
10/22/2014
10/24/2014
10/29/2014
10/29/2014
11/4/2014
11/7/2014
11/13/2014
46,160
46,760 '
44,900 '
44,740 •
46,440 '
46,240
46,840
44,140'
43,860 '
46,200 ^.
43,720 •
45,180^
46,600 "
43,740 -
43,720,-
37,220 "
46,000 '
46,300 "
44,800
43,500 '
45,740 '
44,940 -•
46,460 '
45,060 '
44,120^
45,500 "
45,160^
26,680 '
46,172^
46,672 '
46,355 '
44,726^'
46,014 -
46,162 "
46,826
43,990 '
43,516
45,928'
43,674 S
45,108 '
46,558 '
43,580 "
44,324
36,942 '
45,680 ^
46,076 '
44,744
43,306 -
45,332 '
44,462 -'
46,230-'
44,618
43,686'
45,090.'
44,560'
26,458'
23 1
23 3
23 2
22 4
23 0
23 1
23 4
22 0
21.8
23 0
21 8
22 6
23 3
218
22 2
18 5
22 8
23 0
22 4
21 7
22 7
22 2
23 1
22 3
21 8
22 5
22.3
13 2
23 1
23 4
22 5
22 4
23 2
23 1
23 4
22 1
21 9
23.1
21 9
22 6
23 3
21 9
219
18 6
23 0
23.2
22 4
21 8
22 9
22 5
23 2
22.5
22 1
22 8
22.6
13.3
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69 0
69.0
69 0
69 0
69 0
69 0
69 0
69 0
69.0
69 0
69 0
69 0
69 0
69.0
69 0
69 0
69 0
62.5
61.7
65 6
60 8
61 2
60 8
63 2
62 5
612
64 2
65 7
67 3
66 5
69.6
69 5
67 9
69 3
67 0
67 9
68 5
66 6
66 5
66 8
69 2
68 1
68.6
69 3
68 2
8 66
8 96
7 72
8 77
9 01
9 06
8 62
8.28
8.51
8 27
7 49
7 39
7 81
6 65
6.67
5 97
7 06
7 64
7 19
6 85
7 64
7 53
7 71
6 94
7 04
7 14
6 93
4 24
14-DMC-06 •'
14-DMC-07 '
14-DMC-09
14-DMC-08--
14-DMC-ll
14-DMC-10 "
14-DMC-12 *"
14-DMC-13'
14-DMC-14-
14-DMC-15 -
14-DMC-16
14-DMC-17*.
14-DMC-18*?
14-DMC-19 "
14-DMC-20 -
14-DMC-21-'
14-DMC-22 -~
14-DMC-23 -•
14-DMC-24 -
14-DMC-25 -
14-DMC-26 "
14-DMC-28 -
14-DMC-27
14-DMC-30 '
14-DMC-29 -
14-DMC-32 '
14-DMC-31-"
14-DMC-33 -
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
Super Sacks
SuperSacks
SuperSacks
SuperSacks
SuperSacks
SuperSacks
SuperSacks
SuperSacks
SuperSacks
Super Sacks
Super Sacks
102
0 98
102
102
1.02
0 94
103
0.88
0 84
103
102
0 99
0 89
0 91
102
0 95
0 10
0 11
103
1 12
0 99
101
107
1 21
1 20
104
1 14
1 19
176 16
176 54
160 28
175 88
179 26
167 43
174 82
142 91
139 94
166 03
150 18
151 30
129 56
119 70
135 46
110 38
131 64
159 71
144 92
150 89
147 09
148 99
161 74
163 48
164 18
145 54
152 98
98 23
188 94
190 98
189 68
183 02
188 29
188 89
190 79
180 01
178 07
187.94
178.71
190.52
184 58
178 33
181.37
151 17
186.92
188 54
183 09
177 21
182 79
179 23
186 47
179 87
176 05
181 8
179 63
106 72
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
4,095
Totals-1,240,720 1,236,789 618 620 69.0 0 66 2117 192 SuperSacks 100 4,225 2 5,039 6 4,095
ALTERNATE FEED
FNRI (Fan Steel)
RIS: N/A
Date
Received
FMRI
Weight Weight
(kgs) (lbs)
White
Weight
(kgs)
Mesa
Weight
(lbs) Tons
% DRY # of
Moisture TONS Units Container Bil1 of Lading Description
Est. Est. lbs.
U308
Est.
lbs. U
2/7/2014
2/11/2014
- 2/12/2014
2/13/2014
2/13/2014
2/14/2014
2/17/2014
3/17/2014
4/10/2014
4/11/2014
• 4/14/2014
4/15/2014
4/16/2014
4/16/2014
4/16/2014
5/12/2014
5/28/2014
5/29/2014
- 5/30/2014
6/2/2014
6/2/2014
6/3/2014
6/3/2014
8/26/2014
9/26/2014
10/6/2014
10/7/2014
10/8/2014
10/13/2014
10/14/2014
10/15/2014
11/14/2014
16,630
16,694
16,496
17,233
16,391
16,741
16,405
15,656
19,047
19,048
18,928
18,417
18,118
18,416
18,412
15,484
17,884
18,292
18,325
17,927
18,303
17,879
18,316
19,860
18,197
18,143
21,546
21,676
18,350
18,259
18,383
18,821
36,662
36,803
36,367--
37,992
36,136
36,908
36,166
34,516
41,992
41,993
41,728-'
40,602
39,942
40,600
40,590
34,135
39,426
40,326
40,400-'
39,522
40,350
39,416
40,380
43,784
40,117
39,998
47,500^
47,788
40,455
40,254
40,528
41,492
16,565
15,577
17,463
16,756
16,366
16,656
16,366
15,622
19,006
19,024
18,915
18,389
18,080
18,416
18,198
15,450
17,817
18,280
18,289
20,294
18,244
17,845
18,244
19,614
18,117
18,180
18,126
18,316
18,489
18,216
18,289
19,995
36,520
34,340
38,500
36,940
36,080
36,720
36,080
34,440
41,900
41,940
41,700
40,540
39,860
40,600
40,120
34,060
39,280
40,300
40,320
44,740
40,220
39,340
40,220
43,240
39,940
40,080
39,960-
40,380
40,760
40,160
40,320
44,080
18.3
17.2
19.3
18.5
18.0
18.4
18.0
17.2
21.0
21.0
20.9
20.3
19.9
20.3
20.1
17.0
19.6
20.2
20.2
22.4
20.1
19.7
20.1
21.6
20.0
20.0
20.0
20.2
20.4
20.1
20.2
22.0
40.72
43.82
37.04
41.60
41.15
42.56
41.15
48.30
40.77
47.28
60.36
30.85
36.55
43.00
36.60
38.68
45.11
44.90
24.52
46.08
42.93
52.70
40.14
49.94
46.32
43.22
48.61
43.22
42.16
41.48
44.35
42.90
10.82
9.65
12.12
10.79
10.62
10.55
10.62
8.90
12.41
11.06
8.26
14.02
12.65
11.57
12.72
10.44
10.78
11.10
15.22
12.06
11.48
9.30
12.04
10.82
10.72
11.38
10.27
11.46
11.79
11.75
11.22
12.58
GFLU000369
GFLU001193
GFLU001054
GFLU002183
GFLU001143
GFLU002193
GFLU002023
GFLU000369
GFLU002072
GFLU001136
GFLU002010
GFLU001114
GFLU001071
GFLU001001
GFLU001121
GFLU001191
GFLU002169
GFLU002193
GFLU002023
GFLU002183
GFLU001143
GFLU001193
GFLU001054
GFLU001324
GFLU001114
GFLU001001
GFLU001102
GFLU001071
GFLU002010
GFLU001136
GFLU002072
GFLU002010
FM-0689
FM-0693
FM-0692 -
FM-0690
FM-0687
FM-0694
FM-0691
FM-0702
FM-0695
FM-0696
FM-0698-
FM-0699
FM-0701
FM-0697
FM-0700
FM-0710
FM-0707
FM-0708
FM-0709
FM-0703
FM-0705
FM-0704
FM-0706
FM-0718
FM-0716
FM-0713
FM-0712^
FM-0717
FM-0711
FM-0715
FM-0714
FM-0726
Super sacks
Super sacks
Super sacks
Supersacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Supersacks
Super sacks
Supersacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
Super sacks
0.141
0.073
0.081
0.086
0.08
0.029
0.083
0.111
0.076
0.117
0.141
0.054
0.052
0.075
0.071
0.025
0.075
0.089
0.058
0.054
0.063
0.098
0.03
0.069
0.104
0.05
0.07
0.048
0.111
0.054
0.053
0.089
30.53
14.08
19.63
18.55
16.99
6.12
17.62
19.76
18.86
25.87
23.31
15.14
13.15
17.36
18.06
5.22
16.17
19.76
17.65
13.03
14.46
18.24
7.22
14.94
22.30
11.38
14.37
11.01
26.17
12.69
11.89
22.40
25.89
11.94
16.65
15.73
14.40
5.19
14.94
16.76
15.99
21.94
19.76
12.84
11.15
14.72
15.31
4.43
13.71
16.76
14.97
11.05
12.26
15.46
6.12
12.67
18.91
9.65
12.19
9.33
22.19
10.76
10.08
19.00
Totals: 578,276 1,274,868 573,201 1,263,680
/ 1
631.8 42.84 361.16
* i)
32 0.074 533.93 452.76
URANIUM OXIDE
Yellow Cake
Date Shipped Lot # Grade % Net (lbs) U308(lbs) As U (lbs) Tons Unitsff Transactions Comments
2/11/2014
2/14/2014
2/18/2014
2/21/2014
5/14/2014
5/21/2014
5/28/2014
7/10/2014
7/16/2014
7/21/2014
8/11/2014
8/14/2014
11/4/2014
11/7/2014
11/11/2014
119
120
121
122
123
124
125
131
132
133
126
128
127
129
130
0.8208
0.8219
0.8217
0.8237
0.8215
0.8199
0.8045
0.8184
0.8222
0.8247
0.8187
0.8203
0.8008
0.8188
0.8187
40,849
40,849
40,252
37,583
37,588
37,583
37,584
38,690
38,693
38,694
37,584
37,549
37,537
37,582
37,429
39,539
39,592
39,004
36,506
36,414
36,338
35,656
37,340
37,516
37,631
36,286
36,323
35,448
36,288
36,136
33,529
33,574
33,075
30,957
30,879
30,814
30,236
31,664
31,813
31,911
30,770
30,801
30,060
30,772
30,643
20.4
20.4
20.1
18.8
18.8
18.8
18.8
19.3
19.3
19.3
18.8
18.8
18.8
18.8
18.7
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
669
670
671
672
673
674
675
676
677
678
679
680
681
682
683
ft?
15,208 kg of Canadian Obligated
15,228 kg of Canadian Obligated
15,003 kg of Canadian Obligated
14,043 kg of Canaidan Obligated
14,007 kg of Canadian Obligated
13,978 kg of Canadian Obligated
13,715 kg of Canadian Obligated
14,363 kg of United States Obligated
14,431 kg of United States Obligated
12,124 kg of United States and 2,350 kg of Canadian Obligated
13,958 kg of Canadian Obligated
13,971 kg of Canadian Obligated
13,634 kg of Canadian Obligated A'
13,958 kg of Canadian Obligated
13,903 kg of Canadian Obligated
LC-
Total 576,046 556,014 471,499 288.0 645
ALTERNATTVE FEED
GtoteUMvanced Metals Material c*y>DV
RIS - YFB
Date Received
Energy Fuels
Scale house
Cabot
Weight lbs
Cabot
Tons
WMM
Tons
%
moisture
Dry
Tons Bill of lading # Container # Comments
Est.
«U308
Est. lbs.
U30,
Est.
lbs. U
4/15/2014
4/17/2014
4/17/2014
4/18/2014
4/22/2014
4/23/2014
4/23/2014
4/24/2014
4/24/2014
4/25/2014
4/28/2014
4/28/2014
4/28/2014
4/29/2014
4/30/2014
4/30/2014
4/30/2014
5/1/2014
5/1/2014
5/2/2014
5/5/2014
Total
42,780 -
43,000
43,220
43,080
42,680
42,460
42,760
42,720 '
42,420 -
42,520 -
42,700 '
42,660 '
42,600 1
42,440 •
42,400 •
42,680
42,920
42,540 •
43,480
42,740
42,920
40,020
40,000
40,000
40,380
40,000
40,020
40,020
40,020
40,140
40,000
40,000
40,140
40,020
40,000
40,020
40,020
40,000
40,000
40,000
39,960
40,020"
897,720 840,780
20 0
20 0
20 0
20 2
20 0
20 0
20 0
20 0
201
20 0
20 0
201
20 0
20 0
20 0
20 0
20 0
20 0
20 0
20 0
20 0
420
21 4
21 5
216
21 5
21 3
21 2
21 4
21 4
21 2
213
21 4
21 3
21 3
21 2
21 2
21 3
21 5
21 3
21 7
21 4
21 5
449
21 1
27 9
41 0
29 1
28 2
34 3
32 3
315
34 1
50 9
32 8
31 0
33 8
31 3
32 4
29 7
27 8
32 7
34 8
33 4
31 1
27 8
16
15 5"
12 8
15 3
15 3
14 0
14 5
14 6
14 0
10 4
14 3
14 7
14 1
14 6
14 3
15 0^-
15 5
14 3
14 2
14 2
14 8
303 3
\
1173
2087
2092
1276
1177
1131
2099
1262
1198
1043
1199
1226
1126
1159
1279
1277
1013
1034
2198
348
1265 "
GLFU1173
GFLU2087
GFLU2092
GFLU1276
GFLU1177
GFLU1131
G FLU 2099
GFLU1262
GFLU1198
GFLU1043
GFLU1199
GFLU1226
GFLU1126
GFLU1159
GFLU1279
GFLU1277
GFLU1013
GFLU1034
GFLU2198
GFLU0348
GFLU1265
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Dirt
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
in bags
on plas
on plas
on plas
on plas'
on plas'
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plasi
on plas
on plas
on plas
itlC
;tic
;tic
itlC
tic
tic
tic
tic
tic
tic
tic
tic
;tic
;tic
tic
ItlC
;tic
;tic
tie
ItlC
ItlC
-KM
0 747
0 468
0 567
0 707
0 588
0 538
0 681
0 498
0 623
0 653
0 688
0 686
0 443
0 426
0 613
0 400
0 431
0 531
0 599
0 622
0 709
0 582
252 30
145 07
144 63
216 01
180 16
150 20
197 26
145 65
174 18
136 41
197 45
202 07
124 93
124 13
175 70
119 95
133 60
152 11
169 94
176 97
209 63
3,528
213 95
123 02
122 65
183 17
152 78
127 36
167 27
123 51
147 71
115 68
167 43
171 36
105 94
105 26
148 99
101 71
113 29
128 99
144 11
150 07
177 77
2,992
fc
Inventory Status location Summary Location
Mined Ore Stoi Arizona Strip Arizona 1
Pinenut
Pinenut Pad
Arizona Strip Total _
Mined Ore Stockpiled Total _
Alternate feed Alternate feed Can CaF2- Honeywell
UF4- Cameco
Regen- Cameco
FanSteel- FMRI
WTP- Dawn Mining
Alternate feed Cameco Total
Alternate feed - Re Cameco- Receivable
Alternate feed - Receivable - Billed Total
Alternate feed Cabot
Alternate feed Total _ _ _
Alternatejfeed Total
In Mill from on In Mill from ore In Mill from Ore
In Mill from ore Total
In Mill from ore Total
In Mill from alt In Mill from Altern In Mill from Alternate Feed
In Mill from Alternate Feed Total
In Mill from alternate feed Total
Finished Goods Cameco Cameco- Received
Cameco- In transit
Cameco Total
Mill FG Mill FG
Mill FG Total
Metal payable Metal payable CaF2
Metal payable Total
Converdyn Converdyn- Received
Converdyn- In transit
Converdyn Total
Comurex Comurex- Received
Comurex- In transit
Comurex Total
Drum Shred Payab Drum Shred
Drum Shred Payable Total
In Transit In Transit
In Transit Total^ _
Finished Goods Total
Grand Total
Uranium Ore Statement of Change September
12/4/2014
Values
Contained Pounds U308 Recoverable Pounds U308
9,125 96,553 91,726
7,597 80,193 76,183
16,722 176,746 167,909
16,722 176,746
0 2,418 " 1,886
0 62,878 59,734
0 4,601 3,681
83 132 99
83 70,028 65,399
319,247 303,284
319,247 303,284
83 389,275 _368>684
.__ ^
0
0
100,772 95,733
100,772 _??<Z?3_
iq0>72 ~" 95,733
201,940
0
201,940
222,393
222,393
0 -298
0 -298
23,877
0
23,877
2,741
0
2,741
0 450,653
16,805 666,794 1,082,979
Shipping Documents
FflNSTEE!..
- t ~yJ -
Page 1: Bill of Lading
STRAIGHT BILL OF LADING - SHORT FORM - Original - Not Negotiable
Carrier 1: Greenfield Logistics
Carrier 2: BNSF Railroad
Carrier 3 Greenfield Logistics
Received, subject to the classification and tariffs Ln effect on the date of this Bill of Lading:
BOL# - FM-0695
Shipper's No. 091613 550 008VX
date: ? from Muskogee, Oklahoma At
The property described below, in apparent good order, except as noted (contents and conditions of packages unknown) marked,
consigned, and destine as indicated below, which said carrier (the word carrier being understood throughout this contract as meaning
any persons or corporation Ln possession of the property under this contract) agrees to carry to its place of delivery at said destination,
if on its own water line, otherwise to deliver to another carrier on the route to said destination, and as to each party at any time
interested in all or any of said property, that every service to be performed shall be subject to all the conditions not prohibited by law,
whether printed or written, herein contained, (as specified in Uniform Domestic Straight Bill of Lading set forth Ln Uniform Freight
Classification in effect on the date hereof) which are hereby agreed to by the shipper and himself and his assigns.
(Mail or street address of consignee - for notification)
TO: Energy Fuels, Inc.
White Mesa Mill
6425 South Highway 191
Blanding, UT 84511
FROM: FMRI, Inc.
10 Tantalum Place
Muskogee, OK 74403
Route. Muskogee, OK to Port of Catoosa OK to Salt Lake City UT to Blanding, UT
l5' Tractor #-lsl Trailer £
2nd Trailer #
DOT #919061
2na Tractor # DOT # 919061
No of
Packages
Description of Package Weight (Subject to Correction)
Gross Net
Exclusive Use Shipment
UN29I2
Radioactive matenal, low specific activity (LSA-I)
7
RQ
Th(nat) and U (nat)
solid, fluoride
0.005TBq
Container # GFLU 2072
49498 lbs 41998 lbs
Emergency Contact Chemtrec 1800-424-9300 Labels: Excepted - 49CFR 173^427 (a) (6) (vi).
Placards: Not required - 49-6fR JV72.504, Table 1, footnote 1.
Carrier 1
Per Date
Per: Date:
This is to certify that the above-named materials are properly
classified, described, packaged, marked and labeled, and are in
proper condition for transportation according to the applicable
regulations of the Department of Transportation.
Shipper: FMRI, Inc
Per: Dale:
Carrier 3:
Per: Date:
Energy Fuels Facility Owner or Operator: Certification of Receipt of material covered by this manifest
Ua^- Fd^— Da'e:
RADIOLOGICAL SURVEY FORM
Phase I Transportation
Survey Type: Release of IMC for transport
Inst S/N /^f)^/^ Model No. Cal Due Dale
Inst S/N ^2^>9r<9^> Model No. <S<f? ^ Ca! Due Date
ntermodal Survey
Sample #
1
Door
Front
Top
Bottom
Exposure
Rate
Contact
mrem/h
,3GO
Removable
alpha
dpm/cm'
0
I
beta/gamma
dpm/cm3
XL
J±
IL
0
9
From
INTERMODAL
CONTAINER
Exposure Rate
Cab: 0.00^
mrem/hr
2 meter- £^C%£>
mrem/hr
3 meter- £>.
mrem/hr
Limits:
1. Exposure Rate
a. No reading > 1 rem/hr at 3 meters from surface of intermodal [49CFRI73 427(a)(l i|
b. No readings >200 mrem/hr on surface of intermodal [49CFR173.441(a)], oi else
i. No readings >200 mrem/h at any point on the vertical planes, upper sui fact oi luau. and lower surface of vehicle [49CFR173.441(b)(2)], and
ii. No readings > 10 mrem/h at any point 2m from vertical planes proiecied by on'a., edge of vehicle (excluding top and underside) [49CFR173.441(b)(3)], and
iii. No readings > 2 mrem/h in any normally occupied space [49CFR173 441(b)!4 ;|
2. Removable
a. No reading > 200 dpm/ 300cm2 alpha or 1000 dpm/ 300cm2 beta/gamma [a consei vaiive application of License Condition 33].
Bill of Lading # FM- L06>^S
Performed by / Date /^^~
Intermodal No. 7^?
Reviewed^by \
Transportation Plan
Phase I Remediation
FMRI, Inc
C-4
25 September 2013
INSTRUCTIONS TO THE DRIVER
FOR THE EXCLUSIVE USE SHIPMENT OF
BILL OF LADING # FM-0695
radioactive material, low specific activity (LSA-I), 7,2912, RQ
1. This shipment contains bulk quantities of radioactive uranium and thorium bearing material and
is being shipped as exclusive use in accord with 49 CFR 173.427.
2. The driver shall maintain all seals, labels and markings while in transit.
3. The vehicle and intermodal container configuration shall not be altered in such a manner as to
change radiation levels measured outside the vehicle or container.
4. The driver will not enter the sealed container under any circumstances.
5. The driver will not stop to load or unload cargo from sealed container during transit.
6. In the event of an emergency such as fire, leak, accident or loss of material, the driver will
immediately telephone-
24 Hour Emergency Telephone: Chemtrec 1-800-424-9300
I have read and understand the instructions given above.
Carrier 3:
Driver Signature
Date:
Carrier 2:
Driver Signature:
Date:
DftWH HlMtH DAUN MINIM
,3 i \ ^Ti>
m
3K
• •
I*
P.O. Box 38
Richland, WA 99352
[phone]
[phone] - fax
LOGISTICS, LLC
SAVAGE LOAD #
th
DATE --, . ,
?-? h /If
PO#
Consignor Consignee _ );
Shipped From Shipped To
Address p Address
City/State/Zip City/State/Zip ,
No. Pieces Proper Shipping Name, Kind of Package, Description of Articles, Special Marks and Exception:
See Shipper's BOL/Manifest*
Driver Notes:
Equipment Numbers
Loading Start ,
Equipment Numbers
Unloading Start
DnW's Signature* /
Finish
r^fe Sig^ture- / ./ Dri
Bill To
Finish _
Address
City/StateZip
If total value of load is in excess of $100,000 and/or additional protection for
shipping is needed other than that provided by shipper, it must be noted below.
* Shipper/Agent \
Signature. Date.
LOAD SHIPPED IN GOOD ORDER AND CONDITION EXCEPT AS NOTED
t ^Cdn&ignee/ Agent
Signature Date
LOAD SHIPPED IN GOOD ORDER AND CONDITION EXCEPT AS NOTED
* TERMS: Payable within 15 days. Service Charge of 1.5% per month. In the
event of suit for collection, costs will be paid by the Debtor. Jurisdiction and
venue will be in Benton County, Washington.
In Event of Emergency call 911 and
See Shippers Bill of Lading for
ergency Response
ERG #
Your Business Is Appreciated - Thank You
Input Spreadsheet
Bag#
7-2014-16
7-2014-17
7-2014-18
7-2014-19
7-2014-20
7-2014-21
7-2014-22
Ship Date
Manifest
Shipment #
CuFt
128
128
128
128
128
128
128
896
7/21/2014
14-DMC-09
14-DMC-09
Sorb
Gross wt (Ib) Gross wt (Kg) (kg)
6130 2783.0
7140 3241.6
7626 34622
6840
6698
5575
6346
46355
U mg/kg (dry) moisture content U mg/kg (wet)
13209 0.690 4095
3105.4
3040.9
2531.1
2881.1
21045.3
Net wt (kg) pCI/g U-Nat
45.0 2738.0 2907
45.0 3196.6 2907
45.0 _3417.2_ 2907
45.0 3060.4 " 2907
45.0 2995.9 2907
45.0 2486.1 2907
45.0 2836 1 2907
315 I" 20730.3
pCi/g U-Nat
2907
mCi U-nat Mbq U-nat
7.959
9.293
9.934
8.897
" 8.709
7.227
8.245
60.264
294.48
343.84
367.56'
329.19
322.23'
267.40
305.07
2229.77
Kg Source
11.210
13.089
13.992
12.531
12.266
10.179
11.613
84.88
Month Start Bag Number
20
22
Page 1
ORGANIZATION
Dawn Mining Company
2 IS THIS A\ "EXCLUSIVE USE" SHIPMENT7
DOES EPA REGULATED
rVASTE REQUiR NG A MAN FE5T
*CCOMPANV THIS SH PMENT''
If 'Yes* provide Manifest Number
RADIOACTIVE MATERIAL
MANIFEST
SHIPPING PAPER
5 SHIPPER- NAME AND FACILITY
Dawn Mining Company*
PO Box 250
Ford, WA 99013-0250
1 EMERGENCY TELEPHONE NUMBER (.Include Area Code)
509-258-4511 (7AM-3PM) • 509-936-5272 (after hours) CONTACT
Bob Nelson
6 CARRIER NAME AND ADDRESS
[ ] YES
[ X ] NO
[ ]YES
[X] NO
3 TOTAL NUMBER OF
PACKAGES IDENTIFIED
ON THIS MANIFEST =====>
7
Bags
EPA MANIFEST NUMBER
NA
CONTACT
Tom Savage
ickrowlecgirg waste receip* SIGNATJK-Ai.i'aoiaa QUA
USER PERMIT NUMBER
NA
SHIPMENT #
14-DMC-09
Savage Logistics
P.O. Box 38
Richland, WA 99352
SHIPPER ID #
NA
COLLECTOR
PROCESSOR
GENERATOR TYPE (SPECIFY)
NA
TELEPHONE #(indude area code)
509-258-4511
9 CONSIGNEE-NAME AND FACILITY ADDRESS
Energy Fuels - White Mesa Facilty
6425 South Highway 191
Blanding, UT 84511
EPA ID NUMBER
NA
SHIPPING DATE
7/21/2014
TELEPHONE #(mdiide area code)
509-375-6222
PAGE 1 OF 1 PAGE(S)
SIGNATURE-Authonzed consignee acknowledging waste reciept nee acknovfl
I Manifest Number
(Use this number on all continuation pages)
14-DMC-09
Contact
Harold Roberts
Telephone Number (Include Area Code)
303-974-2140
Date
10. Certification
This is 'o ccn'y tt*iT Te hefwr-rameo rna'ar lala we property dasaiflec Describee packaged markea arc labeled mro are Ir proper corailor 'or irarspon'ior accoralrg
:o The applicable regijla'ton of 'fe Deparmer* o' Trars porta'ior
AWTnORIiED SIGNAT TITLE
Shipper /Consultant
DATE
11 US DEPARTMENT OF TRANSPORTATION DESCRIPTION
(Including proper shipping name, hazard class, UN ID number
and any additional information)
12
DOT LABEL
'RADIOACTIVE-
13
TRANSPORT
INDEX
14
PHYSICAL AND
CHEMICAL FORM
15
INDIVIDUAL
RADIONUCLIDES
16 TOTAL
PACKAGE ACTIVITY
MBq / mCi
17
LSA/SCO
CLASS
18 TOTAL WEIGHT
OR VOLUME
19 IDENT
NUMBER OF
PACKAGE
UN 2910, Radioactive material, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 294.48
7.959
NA 128 ft3
6130 lb
7-2014-16
UN 2910, Radioactive matenal, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 343.84
9.293
NA 128 ft3
7140 Ib
7-2014-17
UN 2910, Radioactive matenal, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 367.56
9.934
NA 128 ft3
7626 Ib
7-2014-18
UN 2910, Radioactive matenal, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 329.19
8.897
NA 128 ft3
6840 Ib
7-2014-19
UN 2910, Radioactive material, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 322.23
8.709
NA 128 ft3
6698 lb
7-2014-20
UN 2910, Radioactive material, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 267.40
7.227
NA 128 ft3
5575 lb
7-2014-21
UN 2910, Radioactive material, excepted package - limited
quantity of material, 7 Filter cake
N/A N/A Solid / Oxides U-Nat 305.07
8.245
NA 128 ft3
6346 Ib
7-2014-22
* Shipped from Dawn Mining Company
in Wellpinit, WA
FOR CONSIGNEE USE ONLY
CONSIGNEE ORIGINAL (MUST ACCOMPANY WASTE IN TRANSIT)
4 I X
Tt
si
J'I. '..
>
J
A
Page 1: Bill of Lading for LSA-I
STRAIGHT BILL OF LADING -SHORT FORM- Original - Not Negotiable
Carrier 1: US Environmental/Horwith
Carrier 2: -epSPy-Truskjog /"S p
Received, subject
Shipper's No.
Carrier's No.
1277
1277
the classification and tariffs in effect on the date of this Bill of Lading:
ai 7:00 AM date: 3/11/2014 from Bovertown, PA
the property described below, in apparent good order, except as noted (contents and conditions of packages unknown), marked, consigned, and destined as
indicated below, which said carrier (the word carrier being understood throughout this contract as meaning any persons or corporation in possession
of the property under this contract) agrees to carry to its place of delivery at said destination, if on its own water line, otherwise to deliver to another carrier
on the route to said destination, and as to each party at any time interested in all or any of said property, that every service tobe performed shall be
subject to all the conditions not prohibited by law, whether printed or written, herein contained, (as specified in Uniform Domestic Straight Bill of Lading
set forth in Uniform Freight Classification in effect on the date hereof) which are hereby agreed to by the shipper and himself and his assigns.
(Mail or street address of consignee - for notification)
TO:
Energy Fuels Resources
6425 South Highway 191
Blanding.UT 84511
FROM:
Global Advanced Metals
650 County Line Road
Boyertown, PA 19512
Route:
1st Tractor* 1st Trailer Number Horwith. DOT Hazmat Registration No. PAD146714878
1 st Tractor # 1st Trailer Number US Env. DOT Hazmat Registration No. PADR000524041
2nd Tractor # 2nd Trailer Number Horwith DOT Hazmat Registration No 0678065500990N
NO, of
Packages Ull
nwi
Desription of Articles, Special Marks Hazard
ID No. PG
Weight (Subject
to Correcfloo .. Required
Radioactive Material, LSA-I, n.o.s.
(80.92% U, nat and 19.08% Th, nat)
2717 MBq
73.4 mCi
UN 2912 47,220
Ib. Gross
40,020
Ib. Net
Bulk
Cargo
2912
Emergency Response Telephone Number:
National Response Center
800-424-8802
Monitored at all times the Hazardous Material is in transportation including
storage incidental to transportation (172.604)
PLACARDS
REQUIRED''
NO
PLACARDS
SUPPLIED7
None required per
49CFR 173.427 (a)(6) (v)
This is to certify that the above-named materials are properly classified,
described, packaged, marked and labeled, and are in proper condition for
transportation according to the applicable regulations of the Department of
Transportation.
Shipper: Global Advanced Metals
Transporter 1:
Per: <^y// ^
US Environmental/Horwith
Transported 2:
Date: 3/11/2014
Per: Date: 3/11/2014
;overed by this manifest \J
Date 4/31/H
Energy Fgejy Resources Facility Owner or Operator: Certification of Receipt of material covered by
Signature (S*-i*s\_^S^> (<:^#/C'VA
Date
Page 2: LSA-I Survey Form
CONTAINER / BILL OF LADING #
CONVEYANCE SURVEY FORM
DATE: 3/11/14
Front
INTERMODAL
CONTAINER
Door
RADIATION LEVELS IN
mR/hr
Surface 6.6 feet
1
2
3
4
5
6
09
1 5
08
1 0
1 6
09
02
02
02
02
02
02
Instrument Data:
Make Bicron
SN C565E
Calibration Due
Tech JB
02/17/15
Requirements for Exclusive Use Shipment per 49 CFR 173.441 and 427:
1 No readings > 200 mR/hr (2 mSv/hr) on surface of intermodal or surface plane of truck
2 Readings in cab must be less than or equal to 2 mR/hr (0 02 mSv/hr)
3 No readings > 10 mR/hr (0 1 mSv/hr) at 6 6 feet (2 meters) from surface of intermodal
4 Container must be marked "Radioactive-LSA" per 173 427 (a) (vi)
This survey document is an attachment to Bill of Lading # 0 1277
1277
Page 3: Driver's Instructions
BILL OF LADING # 1277
INSTRUCTIONS TO THE DRIVER
FOR THE EXCLUCIVE USE SHIPMENT OF
RADIOACTIVE MATERIAL
1. This shipment contains bulk quantities of radioactive uranium and thorium bearing ores and is being shipped
in accord with 49 CFR 173.425.
2. The driver shall maintain all seals, labels and markings while in transit.
3. The vehicle configuration shall not be altered in such a manner as to change radiation levels measured
outside the vehicle.
4. The driver will not enter the sealed container under any circumstances.
5. The driver will not stop to load or unload cargo from sealed container during transit.
6. In the event of an emergency such as fire, leak, accident or loss of material, the driver will immediately telephone:
24 Hour Emergency Telephone: [phone]
I have read and understand the insytuctions given above.
Transporter 2:
Driver Signature:
Date:
Super Sack
SnecmcationSheet
Boyd Imai <[e-mail]>
FW: Outer Specs
David Turk <[e-mail]> Thu, Dec 4, 2014 at 3:23 PM
To: "[e-mail]" <[e-mail]>
Sir,
Attached is the spec sheet for the outer most liner. As we discussed at the site, there are two bags plus two
plastic bags inside for a total of four different layers.
Let me know if there is anything else you need.
t: 435-678-2221 x113 | c: 435-459-9786 | f: 435-678-2224
6425 S. Highway 191 PO Box 809
Blanding, UT, US, 84511
http://www.energyfuels.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you are not the
intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or copy
this message if you are not the intended recipient(s).
David
Energy Fuels Resources (USA) Inc.
David Turk
Manager Environmental Health and Safety
From: Chuck Crochet [mailto:[e-mail]]
Sent: Thursday, December 04, 2014 2:33 PM
To: David Turk
Subject: Outer Specs
David,
Please find the specs for the outer most liner of the Lift Pac. If you require any additional information please let
me know.
Thanks,
Chuck Crochet
Direct: 949-610-5929
7_5_oz_coated_woven_polypropylene.pdf
61K
PACTEC
P.O. Box 8069 Clinton, LA 70722 [phone] www.pactecinc.com
I1 7.5 oz Coated Woven Polypropylene
Specifications
Weight
Thickness
UV Resistance
Tensile Strength
(Warp)
Tensile Strength
(Weft)
Trap Tear
(Warp)
Trap Tear
(Weft)
TongueTear
(Warp)
Tongue Tear
(Weft)
7.5 oz
Coated Woven
Polypropylene
7.5 oz/yd2
(254.2 g/m2)
20 mil
(.5 mm)
70% @ 1200 hrs
370 lbs
(1,646 N)
370 lbs
(1,646 N)
170 lbs
(756 N)
160 lbs
(711 N)
90 lbs
(400 N)
125 lbs
(556 N)
The information contained herein is typical and to the best of our knowledge accurate and indicative ofthe results that can be obtained
by testing in an accredited laboratory. The buyer or user of these products is solely responsible for determining whether these products
are suitable for any intended use and for its proper installation and use.
Other Supporting
Documentation
DRC-03
Page 13 of 21
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #UT1900479
Amendment # 07
Prior to the licensee receiving materials from the Maywood site, the licensee must require
that the generator of the material certify that the material does not contain listed hazardous
waste as defined under the Resource Conservation and Recovery Act (RCRA) per a
Radioactive Material Profile Record.
[Applicable NRC Amendment: 22]
(\\Q. 19./The licensee is authorized to receive and process source material from Ponds 2 and 3 ofthe
FMRl's Muskogee Facility located in Muskogee, Oklahoma, in accordance with statements,
representations, and commitments contained in the amendment requests and submittals to
the Director dated March 7, 2005, June 22, 2005, and April 28, 2006.
/Applicable UDRC Amendment: 2]
10.2(/The licensee is authorized to receive and process source material from Dawn Mining
-— Company's Midnite Mine site in Wellpinit, Washington, in accordance with statements,
representations, and commitments contained in the Amendment Request submitted to the
Director, Utah Division of Radiation Control (Director) dated April 27, 2011 and submittals
to the Director dated December 5, 2012, June 14, 2013, August 7, 2013. The Licensee is
authorized to receive no more than 1,000 tons per year and a total limit of 4,500 tons (dry
weight) under this license condition without prior approval from the Director.
A. (1) Dawn Mining Uranium Material stored (stockpiled) at the Mill Site longer than
14 days shall be covered with a durable geomembrane cover resistant to
damage by ultraviolet (UV) radiation and sufficient ballast shall be placed over
the cover to prevent wind uplift ofthe cover during peak wind conditions at the
site; and
(2) If at any time, visible dust is observed to be originating from Uranium Material
stored on site, the BFRI RSO or his or her authorized representative shall take
actions within 30 minutes to stop the generation of visible dust."
[Applicable UDRC Amendment: 7]
SECTION 11: MONITORING, RECORDING, AND BOOKKEEPING REQUIREMENTS
11.1 fhe results of sampling, analyses, surveys and monitoring, the results of calibration of
equipment, reports on audits and inspections, all meetings and training courses required by
this license and any subsequent reviews, investigations, and corrective actions, shall be
documented. Unless otherwise specified in the State of Utah regulations all such
documentation shall be maintained for a period of at least five (5) years.
\ *4
4.3. Storage
4.3.1. Manner of Storage
^ fix
Containers arriving at the Mill site will be received according to existing Mill procedures. The
shipping bags will be unloaded from the IMCs and placed in a designated area for storage until
the material is scheduled for processing."-The Uranium Material will not be unloaded from the
shipping bags until just prior to being introduced into the Mill processing circuit. Leaving the
material in the shipping bags will eliminate the need for additional dust control measures during
storage.
4.3.2. Environmental Impacts Associated With Storage
Because the Uranium Material will be contained in fabric bags, there will be no pathways for
exposure of Uranium Material to the environment while in storage. Gamma radiation and radon
emanation from the bagged material will be minimal and within the levels associated with other
ores and alternate feed materials handled at the Mill on a routine basis.
4.4. Process
The Uranium Material will be added to the Mill circuit in a manner similar to that used for the
normal processing of conventional ore, either alone or in combination with other approved
alternate feed materials. The Uranium Material will be introduced to the process circuit either
through the conventional ore grinding circuit or by use of the existing trommel screen to remove
non-uranium bearing oversize material prior to processing. The material will be processed
through the existing acid leach, CCD and solvent extraction circuits for the recovery of uranium
values. The leaching process will begin in Pulp Storage with the addition of sulfuric acid. The
solution will be advanced through the remainder of the Mill circuit with no significant
modifications to either the circuit or the recovery process anticipated. Since no significant
physical changes to the Mill circuit will be necessary to process this Uranium Material, no
significant construction impacts beyond those previously assessed will be involved.
Recovery of additional contained metals is not anticipated at this time. Should IUSA decide to
recover tantalum or other metals from the Uranium Materials, such recovery will be
accomplished in a manner similar to the recovery of vanadium, tantalum and other metals at the
Mill in the past.
As mentioned above, the Uranium Material is very similar to the Cabot Materials, which
contained comparable levels of similar metals in their oxide and salt forms. The Cabot Materials
were successfully processed at the Mill during 1997-1998 for the recovery of uranium and
tantalum, under a previous amendment to the Mill's license, without any unforeseen or adverse
process impacts.
The effects of introducing the Uranium Material into the Mill's process and tailings were
reviewed by Jo Ann Tischler, an independent chemical expert. Ms. Tischler's report is included
as Attachment 5. Table 2 to Ms. Tischler's report compares the concentrations of all known
12
- d^erw^) "^xV-^ c^vv^o^vcl O_0iLwJ-«Q W cV^J
4
dp
^-gei^iL^^^ po^^^J^
0/2-c r«^^
SWA f M (tt
-U(
(D
UO/^L~ (f-u^ ugsy (-^A^
"? e.
D
No PBL 11
Rev No R 0
Date October 3
2011
DENISON MINES (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title FMRI and Cabot Processing
Page 2 of 2
G vibrating
Gnzzly and
Apron
Feeder
Feeder
Pulp
Storage
Tank
Semi
Autogenous
Gnnding Mill
Operating Instructions
The FMRI or Cabot matenal that has been prepared for feeding to uranium recovery
processing will be sitting in a pile on the ore pad Before handling these materials
appropriate precautions should be taken to protect operators from inhaling airborne dusts
of these materials Operators can then proceed with the gnnding step as follows
• Make sure you are familiar with the MSDS for the FMRI or Cabot matenal
whichever you will be handling
• Make a safety inspection of all lines and equipment
o Inspect lines for leaks or seeps
o Inspect safety showers and eyewash fountains
o Inspect operator s cabs of mobile equipment to be used to assure doors
and all other openings through which dust might enter can be tightly
sealed
• Start up the gnnd circuit according to standard operating procedures Begin
feeding the prepared FMRI or Cabot matenal to the gnzzly and continue feeding
and processing through the gnnd circuit stonng the ground pulp in the pulp
storage tanks according to standard operating procedures for the gnnd circuit
David Turk
From:
Sent:
To:
Subject:
Jaime Massey
Thursday, December 04, 2014 9:40 AM
David Turk
FW: Remaining capacity in tailings system
OF Energy Fuels Resources (USA) Inc.
Jaime Massey
t 303-389-4167
225 Union Blvd , Suite 600
Lakewood, CO, US, 80228
http //www enerqyfuels com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s) This message and any attached files with it are confidential and may
contain privileged or proprietary information If you are not the intended recipient(s) please delete this message and notify the sender You may not use, distribute
print or copy this message if you are not the intended recipient(s)
From: Jo Ann Tischler
Sent: Monday, December 23, 2013 2:01 PM
To: Kevin Carney <[e-mail]> ([e-mail])
Cc: Phillip Goble ([e-mail])
Subject: Remaining capacity in tailings system
In response to your phone request a week ago, Harold his Civil Engineer, Ryan Ellis, have confirmed that the remaining
capacity in the tailings system is
3,286,533 dry tons
As of December 1, 2013.
Please contact me if you need anything else.
Happy Holidays,
Jo Ann Tischler
Kevin,
l