DRC-2017-009523 - 0901a06880784a62

State of Utah
GARY R HERBERT
Governor
SPENCERJ COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director
'pfzcrzon-o&fcz-i}
MEMORANDUM
TO:Project File C-2017-17
THROUGH: Phil Goble, Uranium Mill Section Manager
HeatherMickelson, PE tv
November 20, 2017 K
FROM:
DATE:
SUBJECT: 2017 Engineering Module 73, Inspection of disposal of 1 le.(2) decommissioning debris
from in situ leach facilities
Authority
Radioactive Materials License #UT1900479, Condition 10.5: “In accordance with the Licensee's
submittal to the NRG dated May 20, 1993, the Licensee is hereby authorized to dispose of byproduct
material generated at licensed in situ leach (ISL) facilities, subject to [...] conditions.” (Conditions are
included below in the Requirements section.)
R313-12-3 (quoting 10 CFR 40.4): “Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes.”1
10 CFR Part 40 Appendix A, Criterion 2: “To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations.”
1 This definition amends the language given in Section 11 e.(2) of the Atomic Energy Act as amended in 1954 to include ISL
facilities on the same footing as conventional uranium mills. This is done by referencing “solution extraction” in the
definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10.
DRC-20 195 North 1950 West • Salt Lake Citv, UT
Mailing Address PO Box 144880 • Salt Lake City, UT 84114-4880
' Telephone [phone] • Fax [phone] "TDD [phone]
www.deq.iitnh.gov
Printed on 100% recycled paper
Observations
Heather Mickelson, PE of the Utah Division of Waste Management and Radiation Control (the
Division), observed disposal of six loads of 1 le.(2) byproduct material on November 1, 2017 at the
White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (the Licensee).
Notifications of the disposals were sent by the Licensee on September 18, 2017 and October 20, 2017
and were received by the Division on September 19, 2017 and October 24, 2017, respectively.
This inspection was specific to the Licensee’s implementation of Standard Operating Procedure SOP
PBL-10, which governs disposal of 1 le.(2) byproduct material from ISL facilities.
The 1 le.(2) byproduct material for disposal was from three generators. Two loads were received from
Cameco Resources/Crow Butte Resources, Inc. - Crow Butte in Crawford, Nebraska; one load was
received from South Texas Mining Venture LLP - UEC/La Palangana in Benavides, Texas; and three
loads were received from Cameco Resources - Cameco-Smith Ranch in Douglas, Wyoming.
The Licensee maintains a map of Tailings Cell 3 in the mill office that shows the dedicated disposal
location for each 1 le.(2) byproduct material generator. The generator disposal areas are marked within
the tailing cell.
A photo log is attached and shows disposal activities for each of the generators.
Lateral disposal pit locations were determined and located in the field by survey prior to excavation and
prior to DWMRC arrival. The bottom of the excavations extended into the tailings sand, and the depth
was surveyed prior to placement of material into the excavation (Photo 2). Once the 1 le.(2) byproduct
material was placed in the excavation and compressed, the top of the material was surveyed (Photo 5).
Clean cover was then placed over the 1 le.(2) byproduct material and then compacted (Photos 3, 6, and
9). The lateral extent of the burial is below the top of the tailings and above the bottom liner.
The Crow Butte 1 le.(2) byproduct material consisted of trash and filters in tote bags (Photo 1). The La
Palangana 1 le.(2) byproduct material consisted of pipe, barrels, and trash (Photo 4). Prior to November
3, 2017, the barrels were crushed to allow the clean cover material to fill the void spaces of the
compacted 1 le.(2) byproduct material. The Cameco-Smith Ranch 1 le.(2) byproduct material was trash,
wires, pipe, and chip pipe (Photos 7 and 8).
A close out meeting to discuss observations during the inspection included with Heather Mickelson,
David Turk, Garrin Palmer, and Tanner Holiday.
Copies of paperwork obtained from field crews show that the Licensee used revision R-3.3 of SOP PBL-
10, dated November 13, 2014 for the operations observed. Revision R-3.3 is the most recent version of
the procedure. A copy of the data packet for each load is attached to this report.
Fourth Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report
November 20, 2017
Page 2
Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.5B: “All ISL contaminated equipment shall
be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges
shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal.”
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. The 1 le.(2) byproduct material from the La
Palangana load included barrels contained that were crushed to minimize void spaces.
Fourth Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report
November 20, 2017
Page 3
Radioactive Materials License #UT1900479, Condition 10.5C: “All ISL waste shall be buried in Cell
No. 3 unless prior written approval is obtained from the Executive Secretary [now Director] for alternate
burial locations.”
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. All 1 le.(2) byproduct material was buried in Tailings
Cell 3.
Radioactive Materials License #UT1900479, Condition 10.5D: “All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include descriptions of the
ISL waste and the disposal locations, as well as all actions required by this License condition.”
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. The Licensee maintains records of the 1 le.(2)
byproduct material disposed of onsite. These records include document the nature of each load of
material received, where it is buried, and how it was handled, including all measures taken to comply
with all of License Condition 10.5.
Radioactive Materials License #UT1900479, Condition 10.5E: “The Licensee shall also submit for
Executive Secretary [now Director] approval a revised written Standard Operating Procedure (SOP) for
ISL disposal on or before December 1, 2010. The revised SOP shall describe the documentation
required for ISL disposal, which shall include but is not limited to the following:”
(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an
area of the cell that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the tailings cell; 3
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed
of in the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in
situ leach source will be segregated from the byproduct material from all other in situ leach
sources;
Fourth Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report
November 20, 2017
Page 4
(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the
tailings cell.
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. The Licensee met the requirement to submit the
procedure with the initial version of SOP PBL-10, and now uses Revision R-3.3, dated November 13,
2014. Revision R-3.3 addresses all of the items specified in License Condition 10.5. The original
version and every subsequent revision of this procedure were submitted to the Division for review and
approval prior to implementation.
Further, the Licensee is complying with the SOP, such as segregating generator 1 le.(2) byproduct
material streams, minimizing void space, and placing the waste in the tailing sands with at least four feet
of sands below it and at least 12 feet from the side or dike of the cell.
Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the Executive
Secretary [now Director] in writing at least 7 calendar days prior to the proposed scheduled date for
disposal of any byproduct material generated at ISL facilities in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators shall be sent to the
Executive Secretary [now Director] on or before November 1 of each calendar year.
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Division received notice of the disposal on
September 19, 2017 and October 24, 2017 and, which are greater than 7 days in advance of burial on
November 3, 2017. The annual summary submittal will be evaluated by DWMRC separately from this
inspection.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 1 le.(2) byproduct material generated as decommissioning debris
from ISL uranium recovery facilities.
No new recommendations were identified during this inspection.
Attachments: 1 le.(2) Byproduct Receipt Notifications dated September 18, 2017
1 le.(2) Byproduct Receipt Notifications dated October 20, 2017
Document packet for Crow Butte byproduct material bearing Bill of Lading Number W-01-17 CB1
Fourth Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report
November 20, 2017
Page 5
Document packet for Crow Butte byproduct material bearing Bill of Lading Number W-02-17 CB2
Document packet for UEC La Palangana byproduct material bearing Bill of Lading number LP-026
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2017-SRI-
0007
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 20I7-SAT3-
006
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2017-CPP-
008
Photo 3. Compacting clean cover and Crow Butte 1 le.(2) byproduct material. Photo
taken on November 3, 2017.
Photo 2. Measuring the elevation of the bottom of burial pit for Crow Butte 1 le.(2)
byproduct material. Photo taken on November 3, 2017.
Photo 4. La Palangana 1 le.(2) byproduct material to be buried. Photo taken on
November 3, 2017.
Photo 5. Surveying the top of the La Palangana 1 le.(2) byproduct material prior to
covering with clean cover. Photo taken on November 3, 2017.
Photo 7. Cameco-Smith Ranch 1 le.(2) byproduct material to be buried. Photo taken
on August 10, 2017.
Photo 6. Compacting the La Palangana 1 le.(2) byproduct material and clean cover with
a bull dozer and the arrival of additional clean cover. Photo taken on November 3, 2017.
Photo 9. Compacting Cameco-Smith Ranch 1 le.(2) byproduct material and clean
cover with a bulldozer. Photo taken on November 3, 2017.
c>
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
September 18, 2017
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
POBox 144880
Salt Lake City, UT 84114-4880
Dear Mr. Anderson,
Re: 1 le.(2) Byproduct Receipt Notification
Div of Waste Management
and Radiation Control
SEP 1S 2017
’WsWn-OOlObZ-
Pursuant to Radioactive Materials License (RML) UT1900479 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 another load by October 3, 2017.
If there are any questions regarding this shipment or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4113.
Regards,
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Div oi vu’uj.c: ivijnagement
and Radiation Control
October 20, 2017
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: 11 e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 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 one load by November 3, 2017.
If there are any questions regarding this shipment or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4113.
OCT 2 4 2017
Tm&xhmm
Regards,
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. !
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES ■ Page 11 of 13
Date: November 13,Title: lte.(2) Byproduct Disposal I
2014 !i
!
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: iojioin_______
Name of employee receiving the load: ___
Generator of the Byproduct Material: - u.
Shipper’s Manifest or Bill of Lading number:LP-ozc? _____________
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(Yes)>r
No
Who gave and when was the notification given?
’Qa-a t i- k.iofiel'T- _______________
Description of byproduct material disposal area/activities:
Set. C---A. [AfltfV__________:______________
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? Y&J.
Which tailings cell was the material placed in? ll 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?
AAt^.4 cr=\cA £LLc*£t.(L __...................................~l~o 4~tvt-i-
Was the material segregated from any Mill material or equipment disposed of in the cell?
.Y^r,..............................................................................................................-_________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: lle.(2) Byproduct Disposal
Manifest or BOL #: LV-oi
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 JSL waste disposal? Ha
Documentation of approval ft Art* 7 J?
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm. 3 /h-Z fi-rcu.&
Was the maximum lift thickness above tailings less than 4 feet thick?
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?
Refer to drawings used to confirm £(K 3 &
Is the bottom of each disposal area at least 12 feet from'the sides or
dikes of the tailings cell? krt
Refer to drawings used to confirm, tw/ 3 Ce.^h
Will the elevation of the material exceed the plane or'grade of the
elevation of the uppermost flexible membrane liner of the cell?
A/a
How was this confirmed (e.g., survey or review)
vtiAXstr*?!
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?
yA fft'C.—WnVv-S f Cvt- ( t __<hr- O' ___1 ^
^ fjr' tr-C-H, _______ _ __________________________________
Were void spaces filled with tailings?
H<A_______________________________________________________________
Was the shipment properly covered?
V&vstt. __
: No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES , Page 13 of 13
Date: November 13,; Title: 1 le.(2) Bjproduct Disposal |
j 2014 i1..-. - - ...........- ■ . 1 .J
Manifest or BOL #: L
Are additional settlement monitors required to be placed for this generator?
__. a/a..
If required, where were settlement markers were placed?
,/i/A_________________________________________
Radiological receipt surv'ey measurements:
_fTt? - tz.o Lo t, _________
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes oiCKa^
2. If yes, what were the results of the sampling?
r\
Was a photograph taken during the unloading activities^Yggtor No
LP-OZZ,
Shipment Number
BILL OF LADING - LICENSED MATERIAL SHIPPING FORM
24-HOUR EMERGENCY CONTACT NUMBER/PROVIDER & CONTRACT NAME OR No.
[phone] Kevin Dziuk (Radiation Safety Officer)
CONSIGNOR (Shipper/From): Company Name and Site
South Texas Mining Venture LLP - Benavides, Texas
ADDRESS: 5781 FM 3196 Benavides, TX 78341
SHIPPER TELEPHONE No.: [phone]
CONSIGNEE (Receiver/To): Company Name and Site
Energy Fuels - Blanding, Utah
ADDRESS: 6425 S Highway 19 Blanding, UT 84511
CONSIGNEE TELEPHONE No.: [phone]
SHIPPER/TRANSPORTER INFORMATION
SHIPPER NRC/STATE LICENSE No.: R06062 CONSIGNEE NRC/STATE LICENSE No.: UT 1900479
SHIPPER USDOT No.: 148604 SHIPPER PHMSA REGISTRATION,No.: 071111550027TV
CARRIER NAME: Cosby Trucking CARRIER ADDRESS: 601 S 200 E Blanding, UT 84511
CARRIER USDOT No.: 298957 CARRIER PHMSA REGISTRATION No.: 071113550019V
NUMBER
OF UNITS HM
DESCRIPTION OF MATERIAL, ARTICLES, SPECIAL MARKS, EXCEPTIONS
UN PSN CLASS
GROSS
WEIGHT
; KG (LBS)
1
TRAILER
. UN 2912
1
i.
RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1)
(Solid Byproduct Material)
Activity 37 Mba ( CiL
Curie x 3.7E4 = 1 Megabecquerel
Volume 287 cubic feet
7
i
Estimated
11,339
(25,000)
****EXCLUSIVE USE SHIPMENT****
’ CATEGORY OF LABEL(S) APPLIED TO PACKAGE - RADIOACTIVE LSA,
EMERGENCY RESPONSE DOCUMENT ATTACHED - 2016 ERG Section 162
This is to certify that the above-named articles are properly classified, described; packaged, marked, and labeled, arid are in proper condition
for transportation accordinjyto the applicate i^ulationj of the Department of Transportation.
SHIPPER'S SIGNATURE
DRIVER'S SIGNATURE^
DESTINATION SIGNATURE OF
DATE -/0 //7 /p
DATE_ lo/nln
DATE LO -ZiD " 1 7
INDICATION OF LEAKAGE YES, EXPLAIN
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at 10/20/17 11:15:10 **
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
815 COSBY TRUCKING
UEC MNT LU UEC LA PALANGANA
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
In:
Out
Comments: TRL # 5
Operator: 4 Charge by Weight
Signature:_r L -A x A:r . \
C_J
Transaction No.
53261
Date Time Scale
10/20/2017 10:53 1
10/20/2017 11:14 1
Gross: 66700 lb (M)
Tare: 33260 lb
Net: 33440 lb
Controled Elevation used (Cell 3)
UEC La-Palangana
5612.6
Area Elevation Transit Shot
Initial shot for trench 4.98
Top of trench 5607.18 10.40
Bottom of trench 5601.19 16.39
Initial shot used for material 4.98
Tod of material in trench 5605.86 11.72
Top of cell 3 Liner 5608.5
Feet below liner 2.64
L5>- 6
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. |
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES j Page 11 of 13
Date: November 13, Title: 11 e.(2) Byproduct Disposal 12014 i !
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:___fSa-oUL TUr H
Generator of the Byproduct Material: _ r. J2><j 1-4 <-
Shipper’s Manifest or Bill of Lading number: -O ( - t~7 C9\
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(^s>pr
No
Who gave and when was the notification given?
....TlwiiC.*____5./Lila :
Description of byproduct material disposal area/activities:
T~ rc«. s L jv A Cr|tf-T-< x To ft- S pUohpS £K^\:tk piaffe—
Has each dmm 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? ^________
■AS A
jsA
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-S -p _ la_____i\T r.A-C-^V. _ 4g
Was the material segregated from any Mill material or equipment disposed of in the cell?
lei
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
------------.!c.J------- .. . ............ ...................................... - -----------------------------------------------------
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
Manifest orBOL #. LaJ> -Of- t 7 ' d-Q>l
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? fa
Documentation of approval ft HT/ite'iT'f &-***. ~?
Was the ISL material segregated from disposed Mill material and other
ISL material? jk*
Refer to plat(s) used to confinn. ^W/ 7 f/r-.7 &
Was the maximum lift thickness above tailings less than 4 feet thick?&
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?
Refer to drawings used to confirm £ej/ 3 &
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? ies
Refer to drawings used to confirm. {c/( 3 Dfa &
Will the elevation of the material exceed the plane or gradW of the
elevation of the uppermost flexible membrane liner of the cell?
AJe
How was this 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? *,4—-4-ceo
— fij----—Ar.^r-Cty\JtaS—fefZAW cAr.jA—£*M—\ e^ i i H(5e_r~
Were void spaces filled with tailings?
__________________________________:___________________—________
Was the shipment properly covered?
__yc3+-^jtx._HiJaeJcS________
No.: PEL-10
Rev. No.: R-3.3
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
1
! Page 13 of 13
Date: November 13,
2014
Title: 1 le.(2) Bjproduct Disposal
Manifest or BOL #: LJ> -o / -t~7 6 (
Are additional settlement monitors required to be placed for this generator?
J/A
If required, where were settlement markers were placed?
.J/A
Radiological receipt survey measurements:
pro
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes oi(£jo^
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?(YesJk No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Page 1 of__1_Greenfield Logistics. LLC Date 9/11/17
(Name of Carrier!(SCACj
on Collect on Delivery shipments, the letters COD must appear before consisnee's name or as otherwise
provided in Item 430, Sec. 1
To: Consignee Energy Fuels Resources (USA) Inc.
Street 6425 S.Hwv 191
City Blandinq . 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, 172 202,172.203
Total Quantity
(Weight, Volume,
Gallons, etc.)
Weight
(Subject to
Correcbon)
RATE Charges
(For Carrier
Use Only)
1 roll off XX UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-1),
CLASS/
30 cubic yards
Natural Uranium, Thorium-230 and Radium-226
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H2O
LABELS APPLIED: N/A per 49 CFR 172.203 (d)(4)
TRANSPORT INDEX: N/A per 49 CFR 172.203(d)(5)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
EXCLUSIVE USE SHIPMENT
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
INCLUDING EXEMPTION FROM MARKING AND LABELING
REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
CBR SHIPMENT #:W-01-17 CB 1
Note-(l) VUiere the rate Is dependant on valua, shippers are required to stale specifically on
writing the agreed or declared value of tha property, as follows- The agreed or declared
value of the property Is herePy speofcalty stated try the shipper to be not
exceeding___________per____________________________.
(2) Where the applicable tariff provisions specify a imitation of the earner's liability absent a
release or a value declaration by the shipper and the shipper does not release the camel's
liability or declare a veins, the earner’s lability shafl be Kmrted to the aident provided by such
provisions. See NMFL item 172
(3) Commodities requiring special or addtlonal care or attention in handling or stowing must
be so marked and packaged as to ensure sata transportation. See Section 2(e) of item 360,
Bills of Lading. Freight Bills, and Statements of Charges and Section 1 (a) of the Contract
terms and condtions for e list of seen articles
I hereby declare that the contents of this
consignment are hilly and accurately described
above by the proper shipping name and are
classified, packaged, marked, and
labeled/Spiacard, and are in all respects in
proper condition for transport according to
applicable International and national
governmental regulations
ON BEHALF OF SHIPPER
Signature ' i
Sutytcl to Sodlon 7 ef lha eendiiont i ihn aHpnwt * to t»
ddlwM to th* e«wi0i« artthout raeourM on tfta conalpxx, tha unaignor anal aisn ina Mowing aHarrwnc The carter ahail not aiake deitvery cl tha ahlpmart wthoul pwynMnl
of freight and al other lawful Ohargaa
(SlgoauWConUgnor)
C O D FEE
PREPAID C
COLLECT h $
TOTAL
CHARGES
FREIGHT CHARGES
FREIGHT PREPAID Ctmtk bn if chai^a
except whan oc* at C aiatob*
rtgrt la cneclcad coSect
RECEIVED, subject to the classifications and tariffs in effect on the date of issue of this Bill of Lading, the property desenbed above in apparent good order, except as noted (contents and condition of contents ©f packages unknown), marked, consigned,
and destined as indicated above which said earner (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 rts usual place of del very at said
destination, if on its route, otherwise to delwerto another carrier on the route to said destination tt is mutually agreed as to each earner of all or any of. said property overafl 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 aD the biQ ol lading terms and conditions In the governing classification on the date of the shipment.
Shipper hereby certifies that he is familiar with all 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 himself and his assigns.
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics, LLC
PE*PER: ^. L-----------
____aUto-l___________DATE. *, / !))}?.
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Transaction No.
53231
Date Time Scale
In:09/12/2017 11:14 1
Out:09/12/2017 11:54 1
Vehicle ID:1002
Trailer ID:Gross:51060 lb (M)
Account ID:11(e)2 NEB CROWE BUTTE Tare:42680 lb
Order ID:Net:8380 lb
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDING
Comments: CONTAINER # CB1
Operator: 4 Charge by Weight
Signature:
io-ot'ii £E(
Generator of Byproduct material:Crow Butte
Controled Elevation used (Cell 3)
Area Elevation
5613.04
Transit Shot
Initial shot for trench 4.98
Top of trench 5609.88 8.14
Bottom of trench 5601.38 16.64
Initial shot used for material 4.98
Too of material in trench 5607.52 10.5
Top of cell 3 Liner 5608.5
Feet below liner 0.98
UJ> 1
r? CB
'.No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
ENERGY FUELS RESOURCES (USA) INC.l_/X 1 I^jLYVJ X X X\J-rvJW WXYV-/XJ.O I
STANDARD OPERATING PROCEDURES Page 11 of 13 j
Title: 1 le.(2) Byproduct Disposal
2014
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ^ I i<j iy
Name of employee receiving the load: .-Tg.fr. y-
Generator of the Byproduct Material: Crtu*)
Shipper’s Manifest or Bill of Lading number: Lp ~QZ^~ I T C-R
Was the State of Utah given notice to the receipt/disposal activities associated with this load?/YesY)r
No
Who gave and when was the notification given?
b.^rA ...____Mu.ill_____________________________________________
Description of byproduct material disposal area/activities:
. re., -5^-^crA-l•____________Sg.g, ________
Has each drum been inspected to identify the presence of any void spaces? l)k________
Have all drums with void spaces been filled with tailings sands or soil?______A/k__________
Which tailings cell was the material placed in? dS-g_l( 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?
MfrTfcWfrd uio^S f ^__fU-eT- f a f U<l
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: 11 e.(2) Byproduct Disposal
Manifest or BOL #: tt-7-O Z ~L l 8 *2-
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?.,
. Documentation of approval 7 &
Was the ISL material segregated from disposed Mill material and other
ISL material? («-•>
Refer to plat(s) used to confirm. 3 iU. z, .^o***/ /fos*.g?
Was the maximum lift thickness above tailings less than 4 feet thick?&
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? ^
Refer to drawings used to confirm £ct( 3 <*
Is the bottom of each disposal area at least 12 feet from ftie sides dr
dikes of the tailings cell? /<?. ->
Refer to drawings used to confinn. Oil 3
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
AJ,
How was this 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?
/Are-^ yicH* rkr> cK~.rk It?/* __fei-__H__________if
I?, ^ ______________________________
Were void spaces filled with tailings?
.to___________________________________________________________________________
Was the shipment properly covered?
I; No.: PBL-fO ENERGY FUELS RESOURCES (USA) INC. ‘
, Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
Date: November 13, : Title: 1 le.(2) Bjproduct Disposal
20,1.4.....................j___________________________________
Manifest or BOL #: UJ-&Z-1 7 ^ Z
Are additional settlement monitors required to be placed for this generator?
Page 13 of 13 !
If required, where were settlement markers were placed?
______AS At____________________________
Radiological receipt survey measurements:
l.A ,vxg./U.r.......................................P.Xi>'0_____
Breathing Zone:
1.
2.
Was a Breathing Zone Sample collected? Yes o
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes^r No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Page 1 of__1_Greenfield Logistics. LLC Date 9/13/17
{Name of Carrier)(SCAC)
on Colled on Delivery shipments, the letters COD must appear before consignee's name or as otherwise provided in Item 430, Sec. 1,
To: Consignee Energy Fuels Resources IUSAV Inc.
Street 6425 S. Hwv 191
From: Shipper Crow Butte Resources. Inc.
Street:______86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
City Blandinq . State UT Zip Code 84511 24 hr. Emergency Contact Tel. No: f308) 665-1393
Route:Vehicle:
Nmber
No of units S
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 UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-1),
!CLASS 7
30 cubic yards
Natural Uranium, Thorium-230 and Radium-226
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H2O
LABELS APPUED: N7A per 49 CFR 172.203 (d)(4)
TRANSPORT INDEX: N/A per 49 CFR 172.203(d)(5)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
EXCLUSIVE USE SHIPMENT
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
INCLUDING EXEMPTION FROM MARKING AND LABELING
REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
CBR SHIPMENT #: W-02-17 CB 2
Note-(l) Where the rate Is dependant on value, shippers are required to state specifically on
wnhng the agreed or declared value of the property, as follows: The agreed or declared
value of the property is hereby spectftcaUy stated by the shipper to be not
exceeding _________________per
(2) Where the applicable tariff provisions specify a limitation of (he carrier’s hebilhy absent a
release or a value declaration by the shipper and the shipper does not release the carrier’s
llaMtty or declare a value, the carrier's GabiDty shall be limited to the ertenl provided by such
provisions. See NMFL Item 172.
(3) Commodities requiring special or additional care or attention In handling or stowing must
be so marked and packaged as to ensure safe transports bon. See Section 2(e) of item 380,
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 of this
consignment ere fully and aocurafeiy described
above by the proper shipping name and are
classified, packaged, marked, and
labeledf/ptacara, and are in all respects in
proper condition forlransport according to
applicable international and national
governmental regulations.
ON BEHALF OF SHIPPER
Signature *
SOifKt to SKtan 7 et tn« comftiem r tM Mpnwt to t* b«
Oftiwrtd io trw eamlgftM wthci-t rscome on trw uretoncr, the
eorvlgnar itoB sign in* (odoring sitocmant
TN cvner •ril no( iu)>* dalhvry erf thto wipmwt wtlviJt ptynwt of ft**#* avj ail other bwrful charga
(Spisajtfc? CwniQ-nr)
C O.D. FEE-
PREPAIDP
COLLECT C %
TOTAL
CHARGES
FREIGHT CHARGES
FRfclGKT PREPAID Crwsk ton If chirp* nc*f*v>hir>t»a1 3 ar*lob#
ilBhibchKXMl cottoerf
RECEIVED, subject to the classifications and tariffs in effect on tee 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 canter (tee wort earner being understood throughout this contract as meaning any person or corporation In possession of this property under the contract) agrees to carry to <ts usual place of delivery at said
destination, if on (Is route, otherwise to deliver to another canter on tee route to aaU destination. It is mutually agreed as to each carter of all or any of, said property over aD or any portion of said route to destination end as to each party at any time
interested in all or any said property, that every service to be performed hereunder shell be subject to all the tell of lading terms and conditions In the governing classification on the date of the shipment
Shipper hereby certifies that he is familiar with ell the lading terms and conditions in the governing classification and tee said terms and condtoons are hereby agreed to by the shipper and accepted for himself and hb assigns.
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics, LLC
PER:
q/»3ln
PER: V-----
DATE:DATE:
R JLQluxd / IjLcLcLt
‘MS
Energy rFuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 53233
Blanding UT 84511
** Reprinted by 4 at 09/15/17 07:55:29 **
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1002
11(e)2 NEB CROWE BUTTE
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Date Time Scale
In: 09/15/2017 07:20 1
Out: 09/15/2017 07:54 1
Gross: 62660 lb (M)
Tare: 43820 lb
Net: 18840 lb
Comments: TRL # CB2
Operator: 4 Charge by Weight
Signature:
Generator of Byproduct material:Crow Butte
Controled Elevation used (Cell 3)
Area Elevation
5613.04
Transit Shot
Initial shot for trench 4.98
Top of trench 5609.88 8.14
Bottom of trench 5601.38 16.64
Initial shot used for material 4.98
Too of material in trench 5607.52 10.5
Top of cell 3 Liner 5608.5
Feet below liner 0.98
U>02-(?
No.: PBL-10
Rev. No.: R-3.3
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 11 of 13
Date: November 13,
2014
Title: 11 e.(2) Byproduct Disposal i
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: _____
Name of employee receiving the load: ______
Generator of the Byproduct Material: ____
Shipper’s Manifest or Bill of Lading number: 7-oi^- Sg-d-opp-j
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(^e$)or
No
Who gave and when was the notification given?
j-Tj/vfc-cduii^ri______________... _____
Description of byproduct material disposal area/activities:
Sg<_ J- t__________________________________
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?_________^ _________
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?
^ fr
Was the material segregated from any Mill material or equipment disposed of in the cell?
.... __YfrD_____________________________________________________ _____________________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
...... .Vei.......................................................-___-___________________________________________ - •
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: 11 e.(2) Byproduct Disposal
Manifest or BOL #: '2£>i?-^(i4.-c&o+
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? {<6
Documentation of approval & uTitoovri 7 ^ ..
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confinn. /V/Y 5. 1U.2.
Was the maximum lift thickness above tailings less than 4 feet thick?
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? ;y S'
Refer to drawings used to confirm Celt 3 Co^k >3'
Is the bottom of each disposal area at least 12 feet from tfie sides or
dikes of the tailings cell? ^ ,
Refer to drawings used to confirm. Ce it 7 C,. ,<J.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
/Te)
How was this confirmed (e.g., survey or review)
£8
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?
.jAfivA. bv cA a ace—fr- f— H—1-»‘ Jc f'—
_____________________
Were void spaces filled with tailings?
_________
Was the shipment properly covered?
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
| Page 13 of 13
i
Manifest or BOL #: ZS>l^-Si2-WPf
Are additional settlement monitors required to be placed for this generator?
Ndt ____
If required, where were settlement markers were placed?
M________________________—
Radiological receipt survey measurements:
Am? ____OOP ?TD _____:
Breathing Zone:
1.
2.
Was a Breathing Zone Sample collected? Yes af*NjP
If yes, what were the results of the sampling?
Was a photograph taken during the unloading actmties?/YWor No
Shipper No. 2017-SR1-0007
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
GREENFIELD LOGISTICS
(NAME OF CARRIER)(SCAC)
Carrier No. N/A
Date
Time
9/21/2017
Collected on Delivery shipments, the letters COD must appear before consignee's name or as otherwise
provided in item 430, See. 1.
To: Consignee Energy Fuels
Street: 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No:[phone]
Route: See attached Vehicle:
Number N/A
No. of units &
container type HM Basic Description
Proper Shipping Name. Hazard ClBsiIdenlificatioo Number (UM or N A), Packing group, per 172 101, 172.2U2, 172 203 Total Quantity
(Woghl, Volume, GaDora, qc)
Weight
(Subject to
Cwrectjon)
Rate Charges
(For Canxr It: Only)
1 Roll Off UN2912, RADIOACTIVE MATERIAL. LOW SPECIFIC ACTIVITY (LSA-1),
CLASS 7 18.9 (24.7 yd*)
RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM-
226
PHYSICAL FORM: SOLID
CHEMICAL FORM; UNAT WITH DAUGHTERS
TOTAL ACTIVITY: 1.25E8 Bq (0.004 Ci)
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, OR BREAK SEAL
PLACARDS TENDERED:YES: X NO:
REMITCOD TO-
ADDRESS N/A
Note-(l) Where the rate is dependent oe value, shippers arc required to rate
specifically ext svntinft the agreed « declared value of the property, as follows. The
agreed or declared value of the property is hereby specifically stated by the shipper to
be not *Trr«-Hifn per
'(2) Where the applicable tonlTprovisions specify a limitation of the earner's habtlitv
absent a itfeatc or a value declaration by the shipper and the shipper does not release
the carrier's liability or declare a value the carrier’s liability ihtll be limited to the
etieni provided by inch provisions Sec NMFL item 172
(3) Commodines requiring special cr additional cue or ottcntian in handling or
stowing must be so marked aad packaged as to ensure tife transportation See
Section 2(e) of item 360, Bills oriadiag, Freight Bills, and Statements of Charge*
and Section 1(a) of the Contraa terms and conditions fora lut of such articles
1 hoeby declare that the contents of this ooruigniBeri are folly and accurately described above
by the proper shipping name and are classified, packaged, marked, and labeledf/placa-d. and ire
all respects m proper condition for transport according to applicable international and
itioosl governmental regulations
ON BEHALF OF SHIPPER
•Subject to secooti 7 oi the axvlitibns if this
shipment is to be delivered to the consignee
without recourse on the consignor, the consignor
shall sign the following statement
The comer shall not make delivery of this
bhiprnait without payment cf freight and all other
lawful charges -
SignaiV-
(Signature ofCDnsianor')
N/AFEE-
PREPAID
TOTAL
CHARGES:
N/A
FREIGHT CHARGES
FREIGHT PREPAID
except Check box if charges
when Ixn
at right is
checked
□ arc to be collected
date of max at bn Bill oi Lsduf. ihe properly described ibuvs la tppvtvm food uder. ctcep m eoud (eonteou and ft»nd»uo« of oonknu of paclafl" ■itiwway ouited. and dt.iiocd a« ix6utsl above utudi said tirmr (lha word camw Wi*
reitan n ^xicuioa jf ibis property under the oortract) tfreer tu any to iu usual pbM o( delivery at xud dooaaiMn. if iti hauc, jii^rwue tu ddiver hi anuther earner wi the rvuu tu tad dettialua h a rmtuitly if reed i> to cadi eamo- ufall «v any of wd
each panvatony UfTKiRlcmud ia all oe say sx> pmpeny. ilui ewy wmcsw be periwnmi herewidar ahal be aubiea tu mil its tall at lading temia and a>»ktioM ii the govtfnmg ekaujljaooa ca the Hilt el thaih<fmn(
Shipper hnhy sillies Aat he .t bmilai mlb si the lading totm aadcuaditliiiB in the finw^ns cUaNficalMi rad the wai temia rad coodanavarehenbyigmd toby ihe shipper aad accepted lurhimaelt sad his sii^m.
RECEIVED, aubjeet k the clsai(ka«M«M linm in eflsci oi
ilia eoiilmct a* mesaiat snv person dr i
properry over all or *ny pcnHjn uf sud rMt tw
SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS
PER PER W
DATE FV DATE 1-71-
Rev 4 June 09, 2016
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
e- rz- n'
AX
RSO:
Operations:
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at 09/22/17 12:17:36 **
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1002
11(e)2 WYO SMITH RANCH / HIGHLAND
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
In:
Out
Comments: TRL # GFLU 00139
Operator: 4 Charge by Weight
Transaction No,
53240
Date Time Scale
09/22/2017 11:48 1
09/22/2017 12:16 1
Gross:60520 lb (M)
Tare:43480 lb
Net:17040 lb
Smith Ranch
Controled Elevation used (Cell 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 4.98
Top of trench 5609.08 8.5
Bottom of trench 5602.27 15.31
Initial shot used for material 4.98
Tod of material in trench 5606.58 11
Top of cell 3 Liner 5608.5
Feet below liner 1.92
No.: PBL-10
Rev. No.: R-3.3
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
i
Page 11 of 13
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
f
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:___
Name of employee receiving the load:____P«v (
Generator of the Byproduct Material: c pu k
Shipper’s Manifest or Bill of Lading number: 'Z.o i"7 - 9AtZ-Ooc€
Was the State of Utah given notice to the receipt/disposal activities associated with this load?/fefy)r
No
Who gave and when was the notification given?
___TbA.»>~A l o'-K- > ^ // h/t 7________
Description of byproduct material disposal area/activities:
Has each dmm 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? £ ^ ______
MA.
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?
cOc-S fLo-ttjk 4 cJiaJ dou>a_ L? JrjUv S&sAjir___
Was the material segregated from any Mill material or equipment disposed of in the cell?
_______________________________________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Y*J
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
Manifest or BOL #: z.a t-? ~ 5AT3 ~Ooo(
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? '{e s
Documentation of approval ft 7 ^ .
Was the ISL material segregated from disposed Mill material and other
ISL material? '/es
Refer to plat(s) used to confinn. £dl ? Hr l
Was the maximum lift thickness above tailings less than 4 feet thick?&
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?9?„
Has 4 foot of tailings sands been maintained under each disposal:
area?
Refer to drawings used to confirm /'<■//J dii-i
Is the bottom of each disposal area at least 12 feet from The sides or
dikes of the tailings cell? W v
Refer to drawings used to confirm. £>// y (Awf ■&?'
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
Jjo
How was this confirmed (e.g., survey or review)\
J& ______
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?
L-XtvX - __loc*J.er_j>dr L^jlf M
._U.tLv____________________________________________________________________________ __________________
Were void spaces filled with tailings?
_________________________________________________________________________ _____________________--_______________-____________________________________________________________
Was the shipment properly covered?
__________________________
i 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 13 of 13
i
Manifest or BOL #: f 1 ~? - SAT1 - poo 6
Are additional settlement monitors required to be placed for this generator?
________________________A/A____________________________________________________________________________________________ ..
If required, where were settlement markers were placed?
A/A_______________________. ___________
Radiological receipt survey measurements:
___Pi:p- -z-c>-3
Breathing Zone:
1.
2.
Was a Breathing Zone Sample collected? Yes o:
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/Yey&r No
Shipper No. 2017-SAT3-00Q6
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE Carrier No. N/A
GREENFIELD LOGISTICS Date 9/18/2017
(NAME OF CARRIER) (SCAC)
________ ____________________'TimeI j ;
before enrutcmee's nurne nr *<4 nlherwisr i . »-i rfCollected on Delivery shipments, the letters COD must appear before consignee's name or as otherwise
provided in item 430, Sec 1
To: Consignee EnergyFue]s
Street: 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper
Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No:[phone]
Route: See attached ;Vehicle:
Number N/A
No.of units &
container type HM Basic Description
Proper Shipping Name, Hazard Cbnldentincarion Number (UM or NA). Packing group, per 172 1U1. 172 2U2, 172.203
Total Quantity
(Woghi. Volume, Gallons, etc.)
Weight
(Subject to
Correction)
Rate Charges
(For CumaUie Only)
Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
CLASS 7 18.9 m1 (24.7 yd*)
RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM-
226
PHYSICAL FORM:SOLID •
CHEMICAL FORM; UNAT WITH DAUGHTERS
TOTAL ACTIVITY:I.25E8 Bq (0.004 Ci)
TRANSPORT INDEX: N/A AS PER 49 CFR 172.203(d)(5)
CATEGORY LABEL: N/A AS PER 49 CFR 172.203(d)(4)
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, OR BREAK SEAL
PLACARDS TENDERED: YES: X NO:
REMIT C O D. TO
ADDRESS N/A
Note-(I) Where the rate it dependent on value: shippen arc required to state
specifically on writing the speed or declared value oTthe prapety, as follows The
I hereby declare that the contents oflhn eotuignmenl are fully and aecuretely described above
by the proper shipping name and are class died, packaged marked and labded/Zplacird and are
C0D.A“tt N/A COD
FEE.
PREPAID
N/A
agreed or declared value of the properly is hereby specifically stated by the shipper to Subject to Seoion / ol the ccmchbcns il tha
be not exceeding _____P«*supment u to be deuvered to the iaorognee TOTAL
(2) Where the applicable tariffprovisiora specify a lunitatnn of the carricr'a liability
absent a release cr a value declaration by the shipper and the shipper does not release
the earner’s liability or declare a value, the earner's liability shall be limited to the
extent provided by such provisions SccNMFL item 172
(3) Commodities requiring special or additional care or aneobor ia handling or
wtumn recourse on me eonstghor. tnc coemcnor
shall stun the folknvmg statcrocot.K/A
ON BEHALF OF SHIPPER
O- ic, ti/o........_
The carrier shall not reals delivery of this
shipment without payment of freight and all other
lawful charges
FREIGlir CHARGES
FREIGHT PREPAID
slowing must be so marhed and packaged bs 10 ensure safe transportatioa. See
Section 2(e) of item 36U, Bills of Lading, Freight Bills, sad Stateotenu of Charges
and Section 1 (a) of the Contract lerms and cardihons for a list of such articles
(/ Signature
N/A when box
Check box. if charges
□ arc to be collected
(Siaoatuic ofConsianori at right is
checked
A —ft*. -» siA lh» /WlA TKm fUTl ilTl CtffuM iKn cumi vn lov qui m umv wn dui m trc pwpetty dcacnUad aKiw m appaiviit aood vnlar, esoepi aa ncrad (contcnu aad cuiditioo of eotnents uf pacEagci uc
»*wl J*.M if. .MI«P i|| I 1 ■ j I 1 1^ P
ikooM). mirfccd, ans>tMd. aad d«Jno'1 u indMicd above «rfaehmjd carpitt (ilit «wd carrMt bemg
iiP ■ t umcoDne ■nvc ■odar omfmcl) ^reas to CAfry ila mual |4Ma al *mi acninajiwi, a ewi l.J Tvutc. vwrvj MVC i* khw *
CMdhauM il riie daenfoatiun •M *L. Amt. _r.k.
agrtad uioea«S cama o/dl or any aaid
pro(«ay uwt ul or sny port too otn
Shipper faeiebv cciultw tast be a Ctnnilisr mth ill lb*t^iTm and candittom in ftw ik. ahippn and accapwd far tumacraad tusaa^na
Ml Uw oak at iha arif
SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS
per r ca PER iSu V V.
22
DATE V IllKm_______________
DATE __________________________________________________________________________________
>vy RSO:
— — o-, 0per“ions:
i/nln?Rev 4 June 09, 2016
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
Smith Ranch
Controied Elevation used (Cell 3)
Area Elevation
5612.6
Transit Shot
Initial shot for trench 4.98
Top of trench 5609.08 8.5
Bottom of trench 5602.27 15.31
Initial shot used for material 4.98
Tod of material in trench 5606.58 n
Top of cell 3 Liner 5608.5
Feet below liner 1.92
Zol7-i’ATS'P<S><36
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 53237
Blanding UT 84511
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
Date Time Scale
In: 09/19/2017 10:29 1
Out: 09/19/2017 10:58 1
Gross:56480 lb (M)
11(e)2 WYO SMITH RANCH Tare:44080 lb
Net:12400 lb
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: GFLU001018
Operator: 4 Charge by Weight
Zofl -
: JU^
Signature
No.: PBL-10 !ENERGY FUELS RESOURCES (USA) INC.1
1
| Rev. No.: R-3.3 .STANDARD OPERATING PROCEDURES Page 11 of 13
Date: November 13, !Title: 1 le.(2) Byproduct Disposal
.2014 !
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ill___
Name of employee receiving the load: I ,^rrv S j a A p
Generator of the Byproduct Material: - l hvj' S U
Shipper’s Manifest or Bill of Lading number:__2LGJL? ' <{_____
Was the State of Utah given notice to the receipt/disposal activities associated with this load^Y^ or
No
Who gave and when was the notification given?
•r-fc aLJll
Description of byproduct material disposal area/activities:
:.L f:--..---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Has each drum been inspected to identify the presence of any void spaces? AJ A______
Have all drums with void spaces been filled with tailings sands or soil?____A1A: _______
Which tailings cell was the material placed in? ( ^ a I?___________
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?
■AWtarL**!. k*.—*—-f-r.«.ck# . f-N<- S&A-A •.
Was the material segregated from any Mill material or equipment disposed of in the cell?
Vej ______________________________________________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Ye/
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: lle.(2) Byproduct Disposal
Manifest or BOL #: T-e t~i - cff- oorrt
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? fa
Documentation of approval A ciT/wo ‘trl 7.&
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm. Cel/ 1 tU-2^ D <^^l
Was the maximum lift thickness above tailings less than 4 feet thick?&
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? Y<<
Refer to drawings used to confirm /£// j A?
Is the bottom of each disposal area at least 12 feet fromihe sides or
dikes of the tailings cell? Ye-t
Refer to drawings used to confirm, j^t/i 3 ^ ,kst >*J.9?
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 (e.g., survey or review)
l___
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?
Ac---Co..juiiritU. (Kotor ______________LiA$ f_____
^f.r ItCi ____________________________________...____________________________________
Were void spaces filled with tailings?
________________________________________
Was the shipment properly covered?
. ,_________ ...
No.: PBL-IO" ’...........' ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
i Date: November 13, . Title: 1 le.(2) B>product Disposal
1 2014 ___________|_______________ , ______________
Manifest or BOL #: '7.oi~7 ~ C p?~coo %
Are additional settlement monitors required to be placed for this generator?
____________t'A__________________________________________________________________ . .
Page 13
If required, where were settlement markers were placed?
AJA__________________............................................................................... ...............................
Radiological receipt survey measurements:
__ ifli. 0_CL .......________\ Lv r-_
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o<No^
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? (Yes qr No
Smith Ranch
Controled Elevation used (Cell 3)
Area Elevation
5612.6
Transit Shot
Initial shot for trench 4.98
Top of trench 5609.08 8.5
Bottom of trench 5602.27 15.31
Initial shot used for material 4.98
Too of material in trench 5606.58 11
Top of cell 3 Liner 5608.5
Feet below liner 1.92
'Zon- cJ?-ooo
Shipper No. 2017-CPP-0008
STRAIGHT BILL OF LADING
ORIGINAL—NOT NEGOTIABLE
GREENFIELD LOGISTICS
(NAME OF CARRIER)(SCAC)
Carrier No. N/A
Date
Time
9/25/2017
Collected on Delivery shipments, the letters COD must appear before consignee’s name or as otherwise
provided in item 430, Sec. 1.
To: Consignee „ .
Energy Fuels
Street: 6425 South H WY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper
Cameco Resources
Street: 762 Ross Road
City: Douglas State: W'Y Zip Code: 82633
24 hr Emergency Contact Tel. No: I [phone]
Route: See attached Vehicle
Number N'A
No.of units &
container type HM Basic Description
Pmpa Shipping Name, nii/ardCfus.Itleniifiaitipti Number fJM or N'A), Packing group, per 172.101, 172 202, 172 203
Total Quantity
(Weight, Volume OiiloM, etc)
Weight
(Subject to
ComxJion)
Rate Charges
(For Coma lira Only) :
i Roil on-X
LTN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
CLASS 7 27.8 m* (36.4 yil>)
RADIONUCLIDE: NATURAL URANIUM, THORTTJM-230 AND RADIUM-
226
PHYSICAL FORM: SOLID
CHEMICAL FORM; UNAT WITH DAUGHTERS
TOTAL ACTIVITY: 4.62E7 Bq (0.001 Ci)
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 REQUIREMENT
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER F.N
ROUTE, OR BREAK SEAL
PLACARDS TENDERED: YES: X NO:
REMIT C O D TO.
ADDRESS N/A
COO to, I N7A COD,
FEE
PREPAID
N/A
Subject to Section 7afthe conditions it tfus
shipmeal is tc be delK-ereri to the consignee
w ilhout recounc on the coiuigaor, the curuigncr
shall stgn the fdlo-^ng statemeoc
TOTAL
CHARGES.
N'A
Fhe comer shall nut make delivery o." (hie
shtpenent wilaooI pw men* of fra^ii and all other
lawful charges.
FREIGHT CHARGES
FREIGHT PREPAID
N'A
except
when box
Check ben if charges
D ait lo be Culleeled
f Siimaturc of Craaimor',ml tight it
dwclcd
NoMj) Where ihc me 11 dependent on value shippers are required to *aie
spepfickli) on utUiax the agreed or declared value of the prupert>. as foUims The
agreed or declared value of the prepern is liereby cpetifiolly stated bv uhe shippo to
be not exceedingper.
(2) Whens the applBablc tariff provisions speedy a limitation of Ac camel's Ubhn
absent a release or a valve decUrcuon tn the sliijpa and the slupper docs not release
the earner's liability or declare a value, the earner’s Liability shall be limited tc die
extent prnvtdrd bv such provisions NMFL item ITL
(3) Coraisodiues requiring special or additional care or attention In handling or
stoning must be so marled and packaged as to ensure safe transportation See
Section 2(c) of item 3titi foils ofl-ading. Freight BUls, arj SlatoriciiH of Charges
and Section 1(a) of the Ccm.Tart term* end conditions for a list of buci uriidea
i licndsy declare (hat (be contents of Ais concignmcnt tire fully ond accurately described above
b> the proper shipping name and ere classified, packaged, marked and bibdcd/Zplaeard. and or
all rcspccti in proper condition for transport according to applicable international and
ruttonal goionmcatal tctLlaitncLe
ON BEHALF OF SHIPPFR
REd-.IV^D, sixyeti u lh* (laaswuswt ind unfa uefftel u- cK< dirt uf inMAflh* Bill ladlst. lF* domM •&>« »»fn»rtal #ooJ cxMpicsrM4*d(auiile-ito wd oxidiL-un »f cunuiti uf urLav^*). evdud cwnu|>B^ and dactiaedu irufKBid sIkm whxfa oi^ (ihomd arno-lc-ai
widenaxd rtinMighoji din Ci-Clna u laeso.i)^ any person or <-<rp>yr.no vi poucttMin oflliu pr<*>tm Ufalri ik< e>j«un«»l a^rt*. la e»fr, k> lixiMux rdiM«fdrliMry«t mdilaiina-v'n. >fen iuraair. niMf»n* w deliver rovteiher umo ua (V rnu^ ic «»d dnunbui h u suyiJy efrad u hi racb u< m i<f«l w wiyui. «i
ty ulti al tw «ny puruun cT uud rvult kjdrtnesunuvi l»U>e*ch party St a.iy line btti«il^ » liluru^r^d pn^erty, dial <\tr\ urvue u be pertorned bowficcr Im biU^lI tuall Ik UUnTiuduia Utrnt im. «untlt<e»a !r (h* ^Mrunf dMilfMOnn ua Ik dweef lbs ^ipniem.
Shijn*' hrrrb) 'jer'i.V-i that h: r> (uai-ur itih ill Sir IuJCtii lams etui ixjadiUwi ■■ tlie jtutrimi rbiu V'alna *xt ik sud lmn> and randVxmer; bertbvifiani t»K (be ckpper and aMemed iut brrnu’i ltd ti
SHIPPER:CAM ECO RESOURCES CARRIER: GREENFIELD LOGISTICS
•'L LlWUPER
DATE DATE
..
^13
Rev 4 June 09, 2016
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
■ J^\AP
RSO:
Operations:
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at 09/26/17 07:52:55 **
In:
Out
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1002
11(e)2 WYO SMITH RANCH / HIGHLAND
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: TRL # TR3
Operator: 4
Signature: ) ,.A ;WJ;
Charge by Weight
1 •:
, 7 - C fp 'COO %
Transaction No.
53242
Date Time Scale
09/26/2017 07:29 1
09/26/2017 07 : 51 1
Gross:57080 lb (M)
Tare:42660 lb
Net:14420 lb