DRC-2016-005467 - 0901a06880619c9e

LLRW/U-Mill Document Scanning Form
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Document Date /6?
Document Title tf/frMMnJDoi": lufH?*rr/0*J &P
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Author(s) 'IpfiMW
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V'V- ......
State of Utah
GARY R. HERBERT
Governor
Spencer J. Cox
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
TO:
THROUGH:
FROM:
MEMORANDUM
DftC- ZO\U-00
File C-2016-36
Phil Goble, Section Manager
Russell J. Topham, P.E.
DATE: March 15,2016
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material March 10,
2016. Radioactive Materials License UT1900479 (License) - Energy Fuels Resources
(USA) Inc. (EFR) White Mesa Mill, Blanding, Utah
On March 10, 2016,1 traveled to the White Mesa Mill to perform an inspection of in-situ leach (ISL) waste
disposal operations on behalf of the Utah Division of Waste Management and Radiation Control
(DWMRC). This inspection responds to a 1 le.(2) Byproduct Receipt Notification from EFR, dated
February 23, 2016. EFR is allowed to dispose this byproduct material in Tailings Cell 3 only, which is
allowed by License Condition 10.5 of the EFR Radioactive Material License.
On February 23, 2016 the DWMRC received notice that EFR would receive three loads of 1 le.(2)
byproduct material, and intended to dispose of that waste in Cell 3 on March 10, 2016. The number of
loads expected was increased to four, but one load experienced delays in transit. Three loads were
ultimately received prior to the commencement of the burial activity.
I checked in at the White Mesa mill at 7:30 AM on March 10, 2016, and asked to see David Turk, Site
Manager for Environmental Health and Safety. Mr. Turk assigned Garrin Palmer to oversee the disposal
operation.
Prior to performing the disposal operation, while waiting for the field crew to assemble, 1 performed an
inspection of the Roberts Pond regrading, the biannual dam safety visual inspections, and a quick check for
standing water on the ore pad. The Roberts Pond and Dam Safety inspections are reported separately. The
ore pad was dry except for one 5’ by 5’ puddle near the east fence and two 1 ’ diameter spots near one of
the loads of ore.
At approximately 8:30 AM the crew assembled at the disposal area with the requisite equipment (a loader).
The three loads were disposed in two excavations. The field crew used the appropriate paperwork, i.e.
Revision 3.3 of Procedure PBL-10, to guide the operation.
195 North 1950 West • Salt Lake Citv, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D. D. [phone]
www.decf.utah.gov
Printed on 100% recycled paper
C-2015-54
Memorandum: Inspection of June 16, 2016
Page 2
Material disposed consisted of:
• Chipped pipe received at the plant March 9, 2016 from Cameco, Smith Ranch, in Douglas,
Wyoming, shipped by Greenfield Logistics, bearing Shipper Number 3/16-4. Upon receipt the
survey recorded a rate of 0.15 milirem per hour. And,
• Tote bags filled with miscellaneous decommissioning debris, along with pumps, wire, office
fixtures and vehicle seats received at the plant on February 22 and March 2, 2016 from Cameco,
Crow Butte, near Crawford, Nebraska, shipped by Greenfield Logistics, bearing Shipper Numbers
W-01-16 and W-02-16.
The bill of lading for each of these loads appears in the attachments to this report.
Mr. Palmer, with assistance from Tanner Holiday, surveyed the level at the bottom of each excavation prior
to waste placement. Using a front-end loader, the crew placed the waste in the excavations and tamped it
down. Mr. Palmer then surveyed the elevation of the top of the waste, and the crew filled the excavation to
the top with soil. As Photo 6 from the photo log shows, one of the excavations was only filled on one side
and covered, leaving the remaining portion of the hole open for receipt of the fourth expected load later
that day.
The crew wheel-walked the cover soil to provide compaction.
EFR appears compliant with Part 10.5.E.(2) of the RML with respect to the elevation of burial. It appeared
that all provisions of the approved disposal SOP were followed during placement and burial of the bulk
waste.
Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation.
Recommendation: I recommend closing out the inspection of March 10, 2016.
Attachments: Receipt Notification dated February 23, 2016, Bill of Lading and Disposal Documentation
for each load disposed on March 10, 2016, photos of the disposal operation.
3/1/2016 State of Utah Mail - White Mesa Mill 11e.(2) Byproduct Receipt Notification
i
3
Russell Topham <[e-mail]>
White Mesa Mill 11e.(2) Byproduct Receipt Notification
1 message
David Turk <[e-mail]> Tue, Feb 23, 2016 at 11:40 AM
To: "[e-mail]" <[e-mail]>
Cc: David Frydenlund <[e-mail]>, Kathy Weinel <[e-mail]>, Harold
Roberts <[e-mail]>, Phillip Goble <[e-mail]>, "[e-mail]"
<[e-mail]>, Logan Shumway <[e-mail]>
Mr. Anderson,
Attached you will find a pdf of the 1 le.(2) Byproduct Receipt Notification letter pursuant to
Radioactive Materials License (RML) UT1900479 condition 10.5.F. The original letter has been
shipped via UPS overnight delivery.
If there are any questions regarding this notification please contact me at the White Mesa Mill at
435.678.4113.
Regards,
David
OF Energy Fuels Resources (USA) Inc.
David Turk
Manager Environmental Health and Safety
t: 435-678-2221 x113 | c: 435-459-9786 | f: 435-678-2224
6425 S. Highway 191
Blanding, UT 84511
http://www.energyfuels.com
This e-mail is intended for the exclusive use 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 recipients).
https ://mail.google.com/mail/u/0/?ui=2&ik=3744873c9a&view=pt&search=inbox&th=1530f6ed910b66b9&siml=1530f6ed910b66b9 1/2
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
ENERGY FUELS
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
February 23, 2016
VIA Electronic Mail (PDF) and UPS
Mr. Scott Anderson
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Anderson,
Re: 1 le.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT 1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of three loads of 1 le.(2) byproduct material by March
10, 2016.
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 at 435.678.4113.
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: 3^1 16
Name of employee receiving the load: T/rry SttvrXd-
Generator of the Byproduct Material: fU
Shipper’s Manifest or Bill of Lading number: 311 h — M_
Was the State of Utah given notice to the receipt/disposal activities associated with this load? (fz§) or
No
Who gave and when was the notification given?
PbiXK I A \ L. 1~*~?~1A____________
Description of byproduct material disposal area/activities:
fft-ck glpLj,..fU.c pUffoJ frtJL__fzLdLh^______
Has each drum been inspected to identify the presence of any void spaces? /)/A________
Have all drums with void spaces been filled with tailings sands or soil? /1/A
Which tailings cell was the material placed in? (3-d_ 11 3.>
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill materia! or equipment disposed of in the cell?
_________________________________________________________________________________________________________________________________________________________________-_________________________—__________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
......... Y«
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014 ..............
Manifest or BOL #: S
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 12 of 13
I iilM
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer’s or
Environmental
Coordinator’s
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? fe ................................
Documentation of approval 44 tsr/qocy/?M
Was the ISL material segregated from disposed Mill material and other
ISL material? ...Ye$ ........
Refer to plat(s) used to confirm. <£*// 3 //>■ z. Are<t_____
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2
thick?
feet
Has 4 foot of tailings sands been maintained under each disposal
area?__jjrj
Refer to drawings used to confirm c'eti y /?„
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? j&j
Refer to drawings used to confirm. 3 Co^- .....
jt.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
A/o__
How was this confirmed (e.g., survey or review)
?i/c y------.........
g1
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
..J\ c <l.6\ s ,-i v-v. ^ ci.cJ, n’X (~Lv A\ laa^/’J-cr Ar i___1 <l a. \ i- ,y_.......tiyyycA 11
Were void spaces filled with tailings?
_______VeS „____
Was the shipment properly covered?
... y<J, S-c c rv kovc •_____
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: l le.(2) Byproduct Disposal
Page Oof 13
Manifest or BOL #: Z\U' H
Are additional settlement monitors required to be placed for this generator?
......asa......................................................................................................
If required, where were settlement markers were placed?
___AZ4____________________________________
Radiological receipt survey measurements:
.CxC..PXD.......Cl..................(a£_.
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or<tfo)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/* es^ or No
L, $
Energy Fuels Resources (USA) Corp
White4 lies a Hill
6485 S„ Highway 191
B1 and i ng U'T 84511
Ttansaet i on No
58628
Vehicle IDr
Trailer ID::
Account IDs
Order IDs
Owner IDs
Material IDs
Dost in., IDs
Date Time Sea I e
Ins 03/08/8(316 08::84 1
Out:: ©3/08/8016 09s 10 1
T3
Gross! 54560 lb <M>
11 <©)2 WYO SMITH RANCH Tare:: 43780 lb
Nets 10840 lb
11<e)8 Mat 11<e> 8 Material Receipt
BLANDING
Comments s R/Ott 18
Operator s 4
Si g nature::
Ch arge by Weight
..._ALsycl4^...
58688
T3
ll(e).2 WYO
11(e) 8 Mat;
03/08/8016 08s84 54560 lb <M>
03/08/8016 09s10 4378© lb
10840 lb
8 Tot ChgsNet Ch g ::0
Smith Ranch
Controled Elevation used (Cell 3)5612.27
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5605.83
Bottom of trench 5599.52
Initial shot used for material
Tod of material in trench 5603.95
4.93
11.37
17.68
4.93
13.25
Top of cell 3 Liner 5608.5
Feet below liner 4.55
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
(LZJJ-L q,u>T'go
(Nan#; of Carrier) /(SCAC)
Shipper Nog/(U"Y
Carrier No.
Date Silll 4___
on Collect on Delivery shipments, the letters COD must appear before consignee’s name or as otherwise
provided in Item 430, Sec 1
To: Energy Fuels_
Street 6425 South Hwv 191
City Blending State UT Zip Code 84511.
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd____________________
City Douglas . State Wv Zip Code 82633_
24 hr. Emergency Contact Tel. No: 905-885-8745
Route Vehicle
Number
No, of
units &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172 101, 172 202. 172 203
Total
Quantity
(Weight,volume,
Gallons, etc)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll
off
XX UN2913, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT
(SCO-1), CLASS 7
(36.4yd3)
27.8m3
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM; SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO^HjO
TOTAL ACTIVITY: 3.7E7Bq (0.001 Cl)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES : X NO □REMIT C.O.D. TO:
ADDRESS
Note-(t) Where the rale is dependant on value, shippers are required lo state specifically on
writing the agreed or declared value of the property, as follows The agreed or declared
value of the property is hereby specifically stated by the shipper lo be not
exceeding per
(2) Where the applicable tariff provisions specify a limitation of the carders liability absent a
release or a value declaration by the shipper and the shipper does not release the carrier's
liabrtity or declare a value, the carrier's Habitoy shall be limited to the extent provided by such
provisions See NMFL Item 172
(3) Commodities requiring special or additions! care or attention In handling or stowing must
be so marked end packaged as to ensure safe transportation See Section 2(e) of Item 300, Bills of Lading, Freight ants, and Statements ot Charges and Section 1(a) of the Contract
terms and conditions for a list of such articles
l hereby declare that the contents of this
consignment are fully and accurately described
above by the proper shipping name and are
classified, packaged, marked, and
labeled/Zplacard. and are in all respects in
proper condition for transport according to
applicable international and national
govammantal regulations.
F OF SHIPPER
SubkKt to Sector* 7 ol tto concstw* » uv» trapment«to be
delivered lo 8*e cer**$rtee wttwwt 'ecouree or* me consignor #v»
consignor sr*»t sign the fotaavtg ««emeru The terror ehel not make delivery <jt (Ms shipment wkhou paymerit
of freight tnti el other lawful chargee
(Signature at Consignor)
C O O FEE
PREPAID
COLLECT S
TOTAL
CHARGES
FREIGHT CHARGES
FREIGHT PREPAID Check tw« If cherge*
except vrtum u> at t<e to tx
right» checked coled
RECEIVED, subject to the classifications and tariffs in effect on the date of issue of this Bill of Lading the property described above in apparent good order, except as noted (contents and condition of contents of packages unknown), marked, consigned, and
destined as indicated above which said carrier (the word carrier being understood throughout this contract as meaning any person or corporation in possession of this property under the contract) agrees to carry to its usual place ol delivery at said destination
if on its route, otherwise to deliver to another carrier on the route to said destination » « mutually agreed as to each carrier of aii or any of said property over alt or any portion of said route to destination and as to each party at any time Interested in all or any
said property, that every service lo be performed hereunder shell be subject to eit the bill of lading terms and conditions in the governing classification on the date of the shipment
Shipper hereby certifies that he is faroiHar wrth al the lading tenns and conditions in the governing classification and the said terms and conditions are hereby agreed to by the shipper and accepted for htmself and his assigns
SHIPPER: CAMECO RESOURCES, INC.CARRIER: j Lkfnis'Hcs.
PER
3 h /!(*
PER
^ ^ - jTb
DATE DATE
Rev 3-Apr 02, 2015 (J
Page I of!
J:\4) Radiation Protection Program\WYO-RPP-0! (Volume IV-Health Physics)\WYO -RPP-Ot (Forms)\WYO -RPP-01.071 Bit! of Lading-By-Product-
SCO.doc
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(2)Byproduct Disposal
ATTACHMENT 2
Page 11 of 13
lle.m BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:___zl'islU
Name of employee receiving the load: j ,<s \ c^cXc,
Generator of the Byproduct Material: / -
Shipper’s Manifest or Bill of Lading number: ~ Q 1 ~~ 1 b
Was the State of Utah given notice to the receipt/disposal activities associated with this load?
No
Who gave and when was the notification given?
..........__________________________________________________________i_________< 17/"Zo16___________________________________________________________________________________________
?^fes\or
Description of byproduct material disposal area/activities:
..Xou>c Ew. He.iU, u>.Stx- f los <z*,A f f<-
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?__
Which tailings cell was the material placed in? _ ____..4..d..L_3___
//A
a/a
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
lAtvi (^Xr.r r iV Ch __4-L* 1 ho Hnl.
.......................................................................................................................................................................
Was the material segregated from any Mill material or equipment disposed of in the cell?
Vci ____ ____________ ___
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Yz5> ._______________________________________________________________________
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #: CO 'C> l ~ 1 b
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cel! approved by the executive Secretary
for ISL waste disposal? fet__________________
Documentation of approval ujtj££V7^ data Z_______
Was the ISL material segregated from disposed Mill material and other
ISL material? ■,_____________
Refer to plat(s) used to confirm. £'<// ? //£ z A-,™#/A s*-4
Engineer’s or
Environmental
Coordinator’s
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
Jhick?______________________ ______ __ ______ ________
Has 4 foot of tailings sands been maintained under each disposal
area? ^5 ___
Refer to drawings used to confirm te// 3
&
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? /rs_______
Refer to drawings used to confirm. ^V/ 3 ^atigagy*
jg-
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
__How was this confirmed (eg., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
At&a,_________c.o^c^cAe.f}'__uo> H-v __( cc^cUr ^ 4-__LajJ__H fP.U~__L;
Were void spaces filled with tailings?
_____Vki._____________
Was the shipment properly covered?
_____
Manifest or BOL #: {A ~Q
No.: PBL-10
Rev. No.: R-3.3
Date; November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
16
Are additional settlement monitors required to be placed for this generator?
. A/A_„___________„________________________
Page 13 of 13
If required, where were settlement markers were placed?
...A/Ar.......................................................................
Radiological receipt survey measurements:
in.**slL._................. d-o PiD.
Breathing Zone:
1,
2.
Was a Breathing Zone Sample collected? Yes
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?esfflr No
Generator of Byproduct material:Crow Butte
Controled Elevation used (Cell 3)5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
Top of material in trench
5608.35
5601.67
5606.25
4.93
9.62
16.3
4.93
11.72
Top of cell 3 Liner 5608.5
Feet below liner
&OL- rfc-
2.25
ll
e'S CtiSfi >.
hw*y 19i
T ransect
Date Ti we-
ili s 0E-/SS/£8J*S 07:1
Uut ■ T,? /BS/ B01 <1. US s
t. c J. # | D # T 3
Trailer fia ^ 6-iSS.e
■! ■'■’■■■ j ' ‘ ; c fit-- b CE;W#(£ BUT’ Tar’1?* 44380
1%.< 1:s :f7S0©
-ai Ittl 11 C e 1 £ Kirt' |51 |#i £l Wst;er ia‘i ITeceipt
3§i“t if?* I (i BLANDING
C O !)i T 3 I ' V:
0 p tf-ar or "i: 4 '
\ • <3* i
at *qe ,* 7 ■
.k'ki
SB: 511
BITS
i 1 c a: m;;!s| Q
6 l >
■ - 1 O?sea i "b-
T o t ijhg-1
iar? Mo«
5®1
Sc a 1 e
i 1
1 is f M
1U
1 b
e 6 PXt>
vz rwR. / Ur
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Shipper No.
Carrier No.
Page 1 of____1_Greenfield Logistics Date 02/24/16
(Name of Carrier) (SCAC)
on Collect on Delivery shipments, the letters COO must appear before consignee's name or as otherwise
provided in ttem 430, Sec 1.
To: Consignee_
Street________
Energy Fuels Resources (USA) Inc.
6425 S. Hwv 191________________
City Blandina . State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street:86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
24 hr. Emergency Contact Tel. No: [phone]
Route:Vehicle:
Nmber
No. of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,Identification Number {UN or NA), Packing Group, per 172.101,172202,172.203
Total Quantity
(Weight, Volume,
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carder
Use Only)
1 roll off XX RQ, UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-
1), CLASS T_________________________________________________________
25 cubic yards
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20
LABELS APPLIED: N/A
TRANSPORT INDEX: N/A per 49CFR172 JI08(d)(1)(k)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES, UNDER PROVISIONS OF 49 CFR 173.425 (b)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS: RADIOACTIVE 7
TRUCK SEAL NUMBER n/a
CBR Shipment #: W-01-16 CBR #2
PLACARDS TENDERED: YES : H NO: □REMIT COD. TO:
ADDRESS
Note-(l) Where the rate is dependant on value, shippers are required to state specifically
on writing the agreed or declared value of the property, as toBowk The agreed or declared
value of the property is hereby specifically staled try the shipper to be not
(2} Where the applicable tariff provisions specify a (imitation of the carrier's liability absent
a release or a value declaration by the shipper and the shipper does not retease the
carrier's totality or declare a value, the earner's liability shall be limited to the extent
provided by such provisions. See NMFL tern 172
(3) Commodities requiring special cv additional care or attention in handling or stowing must be so marked and packaged as to ensure safe transportation See Section 2(e) of
tern 340, Bills of Lading, Freight Bills, and Statements of Charges and Section 1(a) of the
Contract terms and conditions for a list of such articles.
i hereby declare that the contents at this
coralgnmem are futty and accurately dessibed
above by the proper shipping name and are
classified packaged, marked, end
labetedtfpiacard' and are in all respects in
proper condition for transport accorri-ng to
appfccahl© tntomationai and national
governmental regulations
ON JptALF OF SHIPPERSaLy__Signature 1
Step* t* Section 7 of *» cwd&xM • tN* tHpaicrt to »t» «te8wer«! la tfte amsagnoo wSfiat nxwurwo
contour *wi tign the tUUrwsC
Re earner tial m wata cSSwry otWi
at SchF* and *1 other Iraki Usurp**.
{Sigratur* at Comagnor)
COD FEE.
PREPAID 0
COLLECT 0 S
TOTAL
CHARGES
FREIGHT CHARGES
FREKSfTPftB’JYO C*cck om , e*e*pt«4wnbo*al 0 •rttotai
RECEIVED, subject to the classifications and tariffs in effect on the date of issue of this Bi8 of Lading, the property described above in apparent good order, incept as noted (contents and condition of contents of packages unknown), marked, consigned,
and destined as indicated above which said carrier (the word carrier being understood throughout this contract as meaning any person or corporation in possession of this property under the contract) agrees to carry to its usual place of delivery a* said
destination, if on its route, otherwise to deliver to another carrier on the route to said destination. & is mutually agreed as to each carrier of aO or any of. said property over all or any portion of said route to destination and as to each party at any time
interested in all or any said property, that every service to be performed hereunder shall be subject to ail the biff of lading terms and conditions in the goreming classification on the date of the shipment
Shipper hereby certifies that he Is familiar with ail the lading terms and conditions in the governing classification and the said terms and conditions are hereby agreed to by the shipper and accepted for himsdf and his assigns
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics
PER %PER
DATE VAX-lip
13
DATE
■EFK al2Mu
ue \y:ex
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle,(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: j>-2 - (6
Name of employee receiving the load: Tc-rry ________
Generator of the Byproduct Material: Ce***.*.<.o ~ Cr-ouj (Su-Hc
Shipper’s Manifest or Bill of Lading number: LO - tilL- \ 6
Was the State of Utah given notice to the receipt/disposal activities associated with this load?/Ye§) or
No
Who gave and when was the notification given?
bc-ufA X^fL^v ..........................__________________________________________
Description of byproduct material disposal area/activities:
...................................................................................................................... y** tgy 4 fc.
Has each drum been inspected to identify the presence of any void spaces?
Have all drams with void spaces been filled with tailings sands or soil? ___
_vdZA
Js/A..._
Which tailings cell was the material placed in? _ 3
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
_U'SO-S pl&,ccA >-v. V-U^.4- Ufel
Was the material segregated from any Mill material or equipment disposed of in the cell?
---------Yes.....................................................:-----------------------------------------------------
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Ye 5 __________________________________________________
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Manifest or BOL #: __lo - o^~ 16)
Page 12 of 13
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? #U7/
Documentation of approval ________&
Engineer’s or
Environmental
Coordinator’s
Initials
Was the ISL material segregated from disposed Mill material and other
ISL material? ________
Refer to plat(s) used to confirm. Ce// 3 //eZ A'rc>
Was the maximum lift thickness above tailings less than 4 feet thick?Q?
$%>....Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?&
Has 4 foot of tailings sands been maintained under each disposal
area?.....fes .......
Refer to drawings used to confirm 6*/t 3 ’J2JU
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? I4 S __
Refer to drawings used to confirm, c*// 3 &
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
_...........thisHow was
‘6tJr* * y
confirmed (e.g., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Arc.cUtvjs .1.,-w kU~ a...__La 4- ic.£k.s f....t-l f~t 1a^c^s ^cr_iiA V,
Were void spaces filled with tailings?
VeS
Was the shipment properly covered?
....... Vf j (..31.4.5'..._________________
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Manifest or BOL #: ! A T "dXr 16
Are additional settlement monitors required to be placed for this generator?
____A/A______________________________________
Page 13 of 13
If required, where were settlement markers were placed?
..........azA.......................................................................
Radiological receipt survey measurements:
---------......................................do........Rl_Cs_
Breathing Zone:
2.
Was a Breathing Zone Sample collected? Yes
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities^ Yeypr No
Generator of Byproduct material:Crow Butte
Controled Elevation used (Cell 3)5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
Top of material in trench
5608.35
5601.67
5606.25
4.93
9.62
16.3
4.93
11.72
Top of cell 3 Liner5608.5
Feet below liner 2.25
O.L #
UJ "
our're %5 1 LISP) €or(p.
i
Transact :i art
5£S6 1
Mo»
y6Hie It* ||3l
Trailer J'tis
PlCft cl y n t r 0 s
Or dtr IDs
Owner :‘H)j
Ms t s r i a 1 11>;
.. fc i i n 0
Dat s TI aie Seal's;
In: 03/01/2816, «:H t |
' ?03 /£0 IS l© : £13 ■
Ml3#}£ NEB CROWE BUTTE
Grose: SI 78# Tb CM)
T a r m s 4 3 4 - 1 to
Net; 18360 lb
ii ie I c' Plat 1,1 (t;) £ Mater ial Receipt
BLOMJ3 INS
C a ares n fc s
tit)era:; or
fi/O# GBl
+
f /
....._
by Useynl
/
V..-ana„,
52361
ITS
i } f, t- j 2 fvfflB
11 I o)2 Mat Net Chg| 8
6 17Bt .0 (fc; ■
*<,',420 lb
i8368 |b
Ton Cfctg :
~€kz3&.\v\ £L / K t~
<9,0 PHD
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Shipper No..
Carrier No.
Page 1 of 1 Greenfield Logistics
(Name of Carmr)(SCAC)
Date 02/26/16
on Collect on Delivery shipments, the letters COD must appear before consignee's name or as otherwise
provided in Item 430. Sec. 1.
To: Consignee_
Street________
Enerov Fuels Resources (USAl Inc.
6425 S. Hwv 191________________
City Blandina . State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street.86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
24 hr. Emergency Contact Tel. No: (3081665-1393
Route:Vehicle:
Nmber
No. of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202, 172.203
Total Quantity
(Weight Volume,
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Camer
Use Only)
1 roll off XX RQ, UN2912, RADIOACTIVE MATERIAL, Low Specific Activity
(LSA-1), CLASS 7_____________________________________
26 cubic yards
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H2O
LABELS APPLIED: N/A
TRANSPORT INDEX: N/A per 49CFR172208(d)(1)(k)
ACTIVITY OF SHIPMENT: _8.47x10r_Bq
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES, UNDER PROVISIONS OF 49 CFR 173.425 (b)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS: RADIOACTIVE 7
TRUCK SEAL NUMBER n/a
CBR Shipment»: W-01-16 CB #1
PLACARDS TENDERED: YES : E NO: □REMIT C O D TO;
ADDRESS
Nate-fl) Where the rate is dependant on value, shippers are required to state specrftcatiy an
writing the egfeed or (toefeeed vatoe d the property, eekttowe. The egreed or declared
value of the property is hereby apeoScaWy stated by the shipper to be not
wceedingper
(2) Where the applicable tariff provisions specify a imitation of the carrier’s iiahrfety absent a
release or s value declaration by fhe shipper and the shipper does not retease the carrier’s
Habiftty or declare a value, the carrier’s fiabfcty shall be Imitsd to the extent provided by such
provision* See NMFL item 172.
(3) Commodities requiring special or additional care or attention in handing or stowing must
be so marked and packaged as. to ensure safe transportation See Seebon 2(e) cf item 360.
Bits of Lading, Freight BAs, and Statements of Charges and Section 1(a) of the Contract
terms and conditions for a list of such articles.
I hereby dectare that the contents of &w
above by the p
ctasiafied. portaged, mariwd, and
labcJedft^tecard. and are in aO respects in
proper condition tor transport according to
applicable international and national
governmental regulations
QW BEHALF OF SHIPPER
Signature ^
M*m* to Swdon 7 sf On anftlm SB* •Nprrert * to to
riot carrier test rot mtea (Mtory of this tefcwnenl wfttoet poymeni
of f&t and Ml ether tevtui dargn.
($to«c«3f Consignor) ”
C O D. FEE
PREPAID D
COLLECT 0 S
TOTAL
CHARGES
FREIGHT CHARGES
FRBGHT PREPAID
RECEIVED, subjoct to the rSarasrftcations and tanfts in affect on the date of issue of this BS of Lading, (he properly described above in apparent good order, except as noted (contents and condition of contents of packages unknown), marked, consigned
and destined as indkafled above which saori carrier (the word carrier being understood throughout this contract os meaning any person or corporation in possession erf this property under the contratf} agrees to carry to its usual place of de&rery at said
destination, if on its fords, otherwise to de&ver to another camer on the route to said destination B is mutuafty agreed as to each earner of all or any of. said property over ail or any portion of said route to destination and as to each party at any time
interested m at or any said property, that every service to be performed hereunder shad be subject to al the Ml of lading terms and conditions m the governing classification on the date c# the shipment
Shipper hereby certifies dud he is famifcar vrith all the lodng terms and corxtitiorts in the governing dasodication and the said terms and condtocn* are hereby agreed to by the shipper and accepted far hansdl and h» assigns
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics
PER SSHS*PER &Z
DA-TE.gx/iuLlSJA.
-DATE
s-i-/<*
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r:; -i
1
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■ ' ■,*:, ' iif
Pfl
<• i'
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____v •■•■’-■.-',->'v *&*rKv;;; I
Photo 1: Excavation prepared for burial of chipped pipe from Cameco-Smith
Ranch. Photo taken March 10, 2016.
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urn
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p *'"V-.‘ .& •' v '•'■A V’'* 1 .- • -;. , * */ V '••■•_/•• W "‘.'r-:. 'V:. '. , ".. !• i,.,fs;,J.\ . ... *.i.i ____—:—' -
Photo 3: Placing waste in the excavation. Photo taken March 10, 2016.
=*•*
y3»«#«iS8|f **i.^-* : O
v\-"<K'
* „ • •; < ; -V _ "
:' "V :-.:v
. »•»*£: '.C*»
Photo 2: Chipped pipe from Cameco-Smith Ranch awaiting burial. Photo taken
March 10, 2016.
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Photo 4: Placing waste in the excavation. Photo taken March 10, 2016.
c&
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f V;I
Photo 5: Placing capping fill over the excavation. Photo taken March 10, 2016.
J
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sr
4-.-\. i ,fc<
■ %- ■ 1 -' - .. -■ ■ - ■
■ ■ ;:3' 5*
Photo 7: Decommissioning debris from Cameco-Crow Butte awaiting burial.
Photo taken March 10, 2016.
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V.,rs
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“5 re'V - -U* .• 'v?.^/ v„-,tSV/. V. ■
u‘
Photo 6: Finished fill placement. The crew part of left the excavation open to
receive another load of waste upon its arrival later in the day. Photo taken
March 10, 2016.
■■T3^
SI V
-sfr-
m
f /••• . . / . 7',', . 4 1 '
£___ILiajaL.______1
Photo 8: Decommissioning debris from Cameco-Crow Butte awaiting burial.
Photo taken March 10, 2016.
Iff
fh %,p
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r-**■ .~>ii8s
Photo 9: Placing waste in the excavation. Photo taken March 10, 2016.
B
ftjWSfer* 'JR
•V
•i.t-V:”*- _____________ .“v;i!ri Br*-»
' !
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;sSIS v- , ' ' ;m.
mK*-A C
v’>-
' ....
Photo 11: Surveying top of waste elevation. Photo taken March 10, 2016.
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n
-
4b -
wm
-v -
r*
^gg|isa#i *• *v r«H Hi ,
-a ,\2- *;
~ ■
W/if*.*'
<*, i ' vT| •, 1
- Sfe >4^!
- - ' ' • -..
tn*M; ■...
1 V b* -m
■vmil fc
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Photo 10
2016.
Placing capping fill over the excavation. Photo taken March 10,
—
4
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f, t m
V-!
W : PL# -
E... ,.• ' - j
SjgoU ■ ... <*•?/#■ f-‘.
in
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Photo 12: Wheel-walking soil cap to density the soil. Photo taken March 10,
2016.