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Home My WebLink AboutDRC-2017-006426 - 0901a06880747bb3State of Utah GARY R HERBERT Governor SPENCERJ COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director -VFC'Ton-M&b DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T Anderson Director MEMORANDUM TO: THROUGH: Project File C-2017-17 Russell J. Topham, PE c. / Phil Goble, Uranium Mill Section Manager FROM: Heather Mickelson, PE DATE: August 17,2017 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 1 This definition amends the language given in Section 1 le.(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 City, UT Mailing Address PO Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T D D (801) 536^284 iuww.deq.utati.gov Printed on 100% recycled paper Third Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report August 17, 2017 Page 2 is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance obligations.” Observations Heather Mickelson, PE of the Utah Division of Waste Management and Radiation Control (the Di vision), in the company of Russell J. Topham, PE, observed disposal of six loads of 1 le.(2) byproduct material on August 10, 2017 at the White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (the Licensee). Notification of the disposal was sent by the Licensee by email on July 15,2017. 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 four generators. One load was received from Energy Fuels Resources - Nichols Ranch in Linch Wyoming; two loads from Cameco Resources - Cameco-Smith Ranch in Douglas Wyoming; two loads from Uranium One Americas - Irigaray/Christensen Projects in Linch Wyoming; one load came from South Texas Mining Venture LLP - UEC/La Palanga in Benavides, Texas. 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. This map was reviewed with the Licensee in the mill office. The generator disposal areas are marked within the tailing cell. A photo log is attached and shows disposal activities for each of the waste 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. Once the 1 le.(2) byproduct material was placed in the excavation and compressed, the top of the material was surveyed (Photos 2, 5, and 11). Clean cover was then placed and compacted (Photos 2, 3, 6, 8, 9, and 12). The lateral extent of the burial is below the top line and above the bottom liner. The Nichols Ranch 1 le.(2) byproduct material consisted of trash and pipe (Photo 1). The burial pit liquids splashed to the surface of the cell as the loader and bull dozer were filling and compacting the burial hole (Photo 3). These liquids made it difficult to completely compact and cover the burial cell while DWMRC was onsite. The Licensee completely compacted with the cover after it had dried. Confirmation of this compaction was received on August 16, 2017 in the Nichols Ranch data packet (See attachment). The Uranium One 1 le.(2) byproduct material consisted of trash and hoses (Photo 4). The Cameco-Smith Ranch 1 le.(2) byproduct material was trash and pipe that was received in barrels (Photo 7). Prior to August 10, 2017, the barrels were opened and the material was removed from the barrels. Both the barrels and the material contained in the barrels were crushed to allow the clean cover material to fill the void spaces of the compacted waste (Photo 7). Third Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report August 17, 2017 Page 3 The La Palanga 1 le.(2) byproduct material consisted of pipe, barrels, and trash (Photo 10). Prior to August 10, 2017, the barrels were crushed to allow the clean cover material to fill the void spaces of the compacted waste (Photo 11). Present during a close out meeting to discuss observations during the inspection included Heather Mickelson and Russ Topham (Division), Logan Shumway (Plant Manager), David Turk (Radiation Safety Officer), 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. 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 Cameco-Smith Ranch and La Palanga load barrels contained trash and pipes and was crushed to minimize void spaces. 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:” Third Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report August 17, 2017 Page 4 (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) 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; (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. 0An 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 a conclusion that the Licensee is complying with this license condition. The Division received notice of the disposal on July 18, 2017, which is greater than 7 days in advance of burial on August 10, 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. Third Quarter, 2017 1ST Decommissioning Debris Disposal Inspection Report August 17, 2017 Page 5 Attachments: 1 le.(2) Byproduct Receipt Notifications dated July 15, 2017 Document packet for Nichols Ranch byproduct material bearing Bill of Lading Number NR-010-CPP Document packet for Cameco- Smith Ranch byproduct material bearing Bill of Lading number 2017- SAT2-004 Document packet for Cameco- Smith Ranch byproduct material bearing Bill of Lading number 2017- SAT2-005 Document packet for Uranium One byproduct material bearing Bill of Lading number 02/17- Container#! Document packet for Uranium One byproduct material bearing Bill of Lading number 02/17- Container #2 Document packet for UEC La Palangana byproduct material bearing Bill of Lading number LP-025 r St* ' 3 I Vk., ,^i rr^fs r F ■ S*U J - .^sr-r^ Photo 1. Nichols Ranch 1 le.(2) byproduct material to be buried. Photo taken on August 10, 2017. Photo 3. Compacting clean cover and Nichols Ranch 1 le.(2) byproduct material. Notice burial hole liquids in front of the bulldozer that prevented workers from fully compacting this site. Photo taken on August 10, 2017. Photo 2. Covering Nichols Ranch 1 le.(2) byproduct material with clean cover. The surveyor had just completed measuring the top of the waste. Photo taken on August 10, 7.017 Photo 4. Uranium One 11 e.(2) byproduct material to be buried. Photo taken on August 10, 2017. Photo 5. Surveying the top of the Uranium One 1 le.(2) byproduct material prior to covering with clean cover. Photo taken on August 10, 2017. Photo 7. Cameco-Smith Ranch 11 e.(2) byproduct material to be buried. Prior to DWMRC arrival, the material had been cut up to an appropriate size and placed in the burial hole. Photo taken on August 10, 2017. Photo 6. Compacting the Uranium One 1 le.(2) byproduct material and clean cover with a bull dozer. Photo taken on August 10, 2017. /•r'- - :-.v;-A Photo 8. Covering Cameco-Smith Ranch 1 le.(2) byproduct material with clean cover. Photo taken on August 10, 2017. Photo 9. Compacting Cameco-Smith Ranch 11 ,e(2) byproduct material and clean cover with a bulldozer. Photo taken on August 10, 2017. Photo 11. Surveying the top of La Palanga 11 e.(2) byproduct material prior to covering with clean cover. Photo taken on August 10, 2017. ^ .-o - ~>.r- tt-Photo 10. Pushing of La Palanga 1 le.(2) byproduct material into burial hole. Photo taken on August 10, 2017. Photo 12. Compacting La Palanga 1 le.(2) byproduct material and clean cover. Photo taken on August 10, 2017. i No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. ! Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 j Date; November 13,Title: lle.(2) Byproduct Disposal i 2014 ATTACHMENT 2 1 le.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: ______ Name of employee receiving the load:___________________ _ Generator of the Byproduct Material: A/ >^Uo U (2. Shipper’s Manifest or Bill of Lading number: aj\L- 0\0- £.9? Was the State of Utah given notice to the receipt/disposal activities associated with this load?^Yes^pr No Who gave and when was the notification given? .ljA,!. jirJL.~7 / is/ i “T- Description of byproduct material disposal area/activities: — T...fUf?e.^ .-Sc-jc..__ Has each dram been inspected to identify the presence of any void spaces? Have all drams with void spaces been filled with tailings sands or soil?__ Which tailings cell was the material placed in? C~t* 11 _______ JIA. AJk 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? tisL-L.^A-£_ 'J&sttjs.SiS^fhL.*__ 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 #: yl/fe - OlO ~C-Pf 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 -$ Documentation of approval L-ct«jc & UT; ? ^ y 7 7 A»>r> 7 JK Was the ISL material segregated from disposed Mill material and other ISL material? i-ef Refer to plat(s) used to confirm. C<H 3 Hc-z* Arreti --------- 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 Cell 3 & Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Ye 1 Refer to drawings used to confirm. Cell 3 Ce^h Pett^'hns <%> 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) C>ur</tv &7* 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? _a r^-n &xi_JH__.far.. Were void spaces filled with tailings? ____¥*JL____________________ Was the shipment properly covered? _____Y^i( S'C CL _______ No.: PrlL-10 " ! ENERGY FUELS RESOURCES (USA) INC. r'“ , Rev. No.: R-3.3 ' STANDARD OPERATING PROCEDURES , Page 13 of 13 Date: November 13, ' Title: 1 le.(2) Bjproduct Disposal I2014 ! Manifest or BOL #: /j/ (2 " C7 *Q “ Are additional settlement monitors required to be placed for this generator? MX _____________________________________________ If required, where were settlement markers were placed? Radiological receipt survey measurements: PXD' P.P/A t .. ^P-lUr- Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes oj 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?ir No 9 re? Uranerz enfrgv corporation STRAIGHT BILL OF LADING ORIGINAL-NOT NEGOTIABLE GREENFIELD LOGISTICS (Name of Carrier) Shipment No.: NR-010-CPP Date: July 19, 2017 24 HR. EMERGENCY CONTACT NUMBER: (307)232-6676 Ship to : Energy Fuels Resources, White Mesa Mill Ship From: Energy Fuels Resources, Nichols Ranch Street: 6425 South Highway 191 Street: 485 Red Springs Rd. City: Blanding ■ City: Linch State: UT ZIP: 84511 State: WY ZIP: 82640 Route: Nichols Ranch to White Mesa Mill, Blanding, UT. Vehicle: Number —T-3------feSfM • 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) 1 Roll off X RQ,UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), NON-FISSILE, CLASS 7 RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER PRODUCTS PHYSICAL FORM: SOLID CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H20 TOTAL ACTIVITY: 3.74x1010 Bq TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5) PLACARDS: RADIOACTIVE 7 EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF URANERZ ENERGY CORP. 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 This is to certify that the above-named materials are properly classified, desenbed, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulatjoHSrtfftKFDepartmeBt-ofXransportation. Name: l Date: 7* SHIPPER: Uranerz Energy Corp., an Energy Fuels Company CARRIER: (Q & pr/f.C_A L/ya? 1 <i~n CS PER tMKl DATE V/ Jkcjy* 'ij-zolty Uranez Controled Elevation used (Cell 3) 5612.6 Area Elevation Transit Shot Initial shot for trench 5.18 Top of trench 5608.69 9.09 Bottom of trench 5603.08 14.7 Initial shot used for material 5.18 Too of material in trench 5607.08 10.7 Top of cell 3 Liner___________________________5608.5 Feet below liner 1.42 'Ener'gy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 *+ Reprinted by 4 at 07/20/17 13:43:06 ** Transaction No, 53176 Date Time Scale In: 07/20/2017 13:14 1 Out: 07/20/2017 13:42 1 Vehicle ID T4 Trailer ID:Gross:48720 lb Account ID:11(e)2 WYO NICHOLS RANCH Tare:43800 lb Order ID:Net:4920 lb Owner ID: Material ID: Destin. ID: 11(e)2 Mat 11(e)2 Material Receipt BLANDING Comments: GFLU002068 Operator: 4 Signature: Charge by Weight jyQ.-O\0 - t-K ^-oio-^pp /o%~oio-c.?e 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: 1 le.(2) Byproduct Disposal f } ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: / >1 Name of employee receiving the load: _____ Te-rt-y ^1 Generator of the Byproduct Material: £tx.t^.cco - 5'^vMfU. 12- ^ Shipper’s Manifest or Bill of Lading number: 7 o I 7 ~ S AT 2. ^ OOP H Was the State of Utah given notice to the receipt/disposal activities associated with this load? ^eijor No Who gave and when was the notification given? JI2ic2,_____________________________________________________ Description of byproduct material disposal area/activities: Pi , t r--. c U 'n p U-o f n__p/a. If cl. 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? /j/A Which tailings cell was the material placed in?____f/La-\\ 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? —y^-fcrLiirCt^l__UXA.L. ______A----fcDte-«u>las_. __Aovo/v Lt> ■f-L.-c SovijLS. Was the material segregated from any Mill material or equipment disposed of in the cell? Yej ________________________________________________ ____ Was the material segregated from byproduct material from other 1SL 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 #: zor7 - SAT2.-0O0 M 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? ^5 Documentation of approval $ vT & Was the ISL material segregated from disposed Mill material and other ISL material? Yei Refer to plat(s) used to confmn. Cell 3 He-'l fosaesa! 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 fell 3 So.*, f . Is the bottom of each disposal area at least 12 feet from thd'sides or dikes of the tailings cell? Refer to drawings used to confirm. c,.j{ 3 Ctrs? Ontr.*#*& 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) ^ t u t ^ ..........................& 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? A __**•> __I caftj&l*-*- __ft-____________pdj-;__ ___________________________________ Were void spaces filled with tailings? _______________________________________________....____________________________^ Was the shipment properly covered? ___ V cjTy-ijtA_^lgt» ---------- "h/o.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.1 Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 ; Date: November 13,! 2014 .. .. i Title: lle.(2)B>'product Disposal i Manifest or BOL #: 'ZoH ' SAT? Are additional settlement monitors required to be placed for this generator? AJ*_______________________ If required, where were settlement markers were placed? A/A-_____________ Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes 2. If yes, what were the results of the sampling? No> Was a photograph taken during the unloading activities?( Yes qj No Shipper No. 2017-SAT2-0004 STRAIGHT BILL OF LADING ORIGINAL-NOT NEGOTIABLE Carrier No. N/A GREENFIELD LOGISTICS (NAME OF CARRIER)(SCAC) Collected on Delivery shipments, the Idlers COD must appear before consignee's name or as otherwise provided in item 430, Sec. 1. Date Time 6/29/2017 To: Consignee Energy Fuels Street: 6425 South HWY 191 City: Blanding Stale: 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:(905) 885-8745 Route: See attached Vehicle: Number N/A No of units & container type HM Basic Description Propr Shipping Nome. HazinlClauJdentincatjon Number (L'Mor NA) Packing group, per S 72.101, 172.202. 172 203 Total Quantity (Weigh!, Volume, Gallons, etc) Weight (Subject to Correction) Rate Charges (Fw Cimcr U*e Only) Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM- 226 18.9 m* (24.7 yd*) PHYSICAL FORM: SOLID CHEMICAL FORM; UNAT WITH DAUGHTERS TOTAL ACTIVITY: 1.25E8 Bq (0.00337 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 N(Jte-< 1) Where the rate is dependent on value, shippers arc required tn state speafically on vmung the agreed or declared value of the property, as follow* The agreed or declared value of the property is hereby specifically stated by the shipper 10 be act exceeding ■ per _ _ _ (2) Where the applicable tariff provisions specif)'a limitation of the comer's liabiht) absent a release or a value declaration by the shipper and the ihippex doe* not release the earner's liability or declare a value, the carrier's liability shall be limited to the extent provided by such provisions See NMFL item 172 (3) Commodities requiring special or additional core or attention in handling or slowing must be so marked end packaged as to ensure safe traoipcrution Sec Section 2(e) of item 360, Bill* of Lading, Freight Bills and Statements of Charges and Section Kb) of the Contract terms and conditions for a hsi of such articles 1 herein declare that the contents of this consignment are ftilly and accurately described above • by the proper shipping name and are classified, packaged, marked and labdcdi'/placard, and are in all respects in proper condioon for transport according to applicable international and national govcmmeola] regulations ON BEHALF OF SHIPPER Subject ro Section 7 of the conditions if Ous shipment is to be delivered to the consignee without recourse on the consignor, ihc consignor shall sign the following Etatemau. The carrier shall not make delivery of this shipment without payment of freight and all other lawful charges. N/A (Signature of Consignor) C.O.D, FEE PREPAID N/A TOTAL CHARGES N/A FREIGHT CHARGES FREIGHT PREPAID except when box at right is checked Check box if charge* o are to be collected uflbu Billol Loding, ibe prupem Uncnbed ibiivt i> apfu/tiil |i.wl onkr.rccpi u noted (wmesU condioun uf <onMna of iMkaacs unknown)- nuAed. eonnsrat tad datmod u indiala) ebon which uid earner [Ux mronl cama benj xuon of Ihur fwptrry under lie eoairtcl) t|rc« J k> carry to hi miul place of delivery H raid dcMm>eH>n.tf on It! nutc, iXEcrwDt lu deliver to trtulba amcr rathe roul* lu said deriiMlun. ft s mutually agreed ax to «cS cams of til <v«sye( md any portion of sskS route to dcsimalM and as to each party al any lime istereend in all or «ny wid iha: ewy service to be perfijrmed hereunder mhtl be sibjecl to all iht tat; ofladm* terns and cond; Irons in *e |uwnln| ctaasirieaUea on Hie date of the ahipmenr. Shipper hereby ceraOcs lhat he n famhar »nb all the fad™ tonrx and eoeditions in the govenuD* riaaificalui and rhe amd lenca asd condrtK»& aie haeby igrad to by the shqipa ud aeeepled for himadf and hei assigas RECEIVED, tub]eel to the clasideobons and UriOs .n cffcxl oi understood throughout this contrail os moeniag say penoa or urparaliun in property o' SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS PER PER (Un f-<^--/ DATE / 'DATE Js.irU Rjiauxkcl l <maju JJUlJLz.. (c RSO: Operations: Rev 4 June 09, 2016 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading.xlsx •9 Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 53160 Blanding UT 84511 ** Reprinted by 4 at 06/30/17 07:53:53 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: T3 11(e)2 WYO SMITH RANCH / HIGHLAND 11(e)2 Mat 11(e)2 Material Receipt BLANDING In: Out: Date Time Scale 06/30/2017 07:22 1 06/30/2017 07:53 1 1 Gross: 50060 lb (M) Tare: 44240 lb Net: 5820 lb 4 T '2a\1-$AT'1-Ooo1\ Comments: TRL # GFLU 2030 Operator: 4 Charge by Weight Signature: •M jss Smith Ranch Controled Elevation used (Cell 3) Area Elevation 5612.6 Transit Shot Initial shot for trench 5.18 Top of trench 5609.29 8.49 Bottom of trench 5604.38 13.4 Initial shot used for material 5.18 Too of material in trench 5606.97 10.81 Top of cell 3 Liner 5608.5 Feet below liner 1.53 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: ] le.(2) Byproduct Disposal No.: PB*L-10 \ Rev. No.: R-3.3 Date: November 13, 2014 Page 11 of 13 1 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:__711x1)2___ Name of employee receiving the load: Generator of the Byproduct Material: /Lcu^t-t-o - Shipper’s Manifest or Bill of Lading number: 2 o >7 - S AT? — CXX>£ Was the State of Utah given notice to the receipt/disposal activities associated with this load? (^d^or No Who gave and when was the notification given? bfcuiA TVrH ,....-thsin________________________________________________________ Description of byproduct material disposal area/activities: Prp&c, fro^U. ^ Se^- fU.0 fa cxa-A Has each dmm been inspected to identify the presence of any void spaces? A/A Have all drums with void spaces been filled with tailings sands or soil?_____AjJk Which tailings cell was the material placed in? L.C.W 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? ^ _fo s>______________________________________________________, 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 #: Zoil - SAVZ'-COOf 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? Kr 5 Documentation of approval Uctr,<-L ut !70eH7<( At**** 7 # Was the ISL material segregated from disposed Mill material and other ISL material? . Yr< Refer to plat(s) used to confirm. Ceil 3 /A. z Was the maximum lift thickness above tailings less than 4 feet thick?A? 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? Ye < Refer to drawings used to confirm Cell 1 a? Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Y<3 Refer to drawings used to confirm. CeU 1 ^<?.5 & Will the elevation of the material exceed the plane or grade'of the elevation of the uppermost flexible membrane liner of the cell? ASc) 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? A ucrtvS ___uLilirJU._______cAo.'ZJUZ________ier.fiv.X-t:___H____ __fLc*,i JlSi jt _______________ Were void spaces filled with tailings? _________VcS ___________________________________________________________________________________________ Was the shipment properly covered? Vg t _£>. c, /u-ba <sc- - “No.: PBjL-10 " | Rev. No.: R-3.3 : Date: November 13, i 2014 _____ ENERGY FUELS RESOURCES (USA) INC. ' ! STANDARD OPERATING PROCEDURES j Page 13 of 13 Title: 1 le.(2) Byproduct Disposal | Manifest or BOL #: Z.p\l ' SA'^^aoc>S Are additional settlement monitors required to be placed for this generator? /(/A_____________________________ If required, where were settlement markers were placed? aJ.A___________________________________________ Radiological receipt survey measurements: 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? Ye^pr No Shipper No. 2017-SAT2-0005 STRAIGHT BILL OF LADING ORIGINAL-NOT NEGOTIABLE GREENFIELD LOGISTICS Carrier No. N/A (NAME OF CARRIER)(SCAC) Collected on Delivery shipments, the letters COD must appear before consignee's name or as oiherwise provided in item 430, Sec. I. Date Time 7/17/2017 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:(905) 885-8745 Route: See attached No of units & container type HM Basic Description Proper Shipping Name. HaaardClass.ldentification Number (UM or NA). Packing group, per 172 101, 172 202. 172 203 Total Quantity (Weight, Volume, Gallons, etc.) Weight (Subject to Coneciwin) Rate Charges (For Camcr Use Only) Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 9.9 m* (13 yd*) { RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM- 226 PHYSICAL FORM: SOLID CHEMICAL FORM; UNAT WITH DAUGHTERS TOTAL ACTIVITY: 2.27E7 Bq (0.00061 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)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 Nmc-{ 1) Where Ihe rale n dqxndcnt on vrtluc, ahipperx ire requiTEd to SU(C specifically on wnlmg the agreed or declared value of the property, as fblkn’n: The agreed or declared value of the property is hcrobj specifically stated by the shipper to be not exceediriE t>er (2) Where the applicable tariff provisims specify a iumution of the earner's liability absent a release or a value declaration by the shipper and the shipper docs not release the earner's liability or declare a value, the carrier'i liability shall be bimted to the extent provided by such provisions See NMFL item 172. (3) Commodities requiring special or additional care or a lien lion in handling or slowing must be to marked and packaged as to ensure ufe transportation. See Section 2(c) of item 360. Bills of Lading. Freight Bills, and Statements of Charges and Section 1 (a) of the Contract lemu and conditions for a list ol such ankles. ] hereby declare that (he contents of this consignment are fully and accurately described above b) the proper shipping name and ore classified, packaged, marked, and labdediTplacaid, and are in all respects in proper condition for transport according io applicable micmauonaJ and national governmental regulations ON BEHALF OF SHIPPER C°D Ann* WA - - FEE PREPAID liubjeei to Seen on 7 d the conditions u Uui shipment 15 to be delivered to the consignee without recourse on ths consignor, tbe consignor shall sign the following statement- The earner shall not make detivoy of (his shipment without payment of freight and all othtr lawful charges. N/A 103 AL CHARGES. ^ < N/A FREIGHT CHARGES FREIGHT PREPAID except Chock box If charges when box □ are to be collected ot right is checked PiWWrfCM—1 Vehicle: Number N/A RECEIVED *ubjcc! ip tht cla4u0e»iii.'.r>> innfL m <ffoct on tha tbit of mae of (hi. Bill trt Ltvliop, itte properr. 4eitnhe4 ab>)t« inappateni good order, dxsrpi at noted (oonlcnis 4nd coat! Ironol ccnttrK vifpeckagen on Imran), inerLed. cgrrgncd. and dBiirtod at vdicMed abon whtch Mid uiner(lHe uurdc; Lpdcrtufcjd tbiVBjhooi ifitv cooirscl ti meaniag my or eorpmuott t.-ipoyssauenul' ib:i properry wnecr Ox coilrstt) afreet lu carry 1u iti utual pbee ol delivery r: a'd dexnr.ii.un, it oo tu rtule, crhenmcWi deliver loanoUxr earner os Dm route (o wid dwtineUun H n nnUiallyafrad estuiach caoxr of ad or asvoC uld ptopem'over all uf any ponirn ol votd Mile to daunatBin »rtl«tlue*<hpaTy*t»ri,r time iiuneited in all uranywud ptoperty, lhal every icrvie* to ba petfamrd hncurvlei vhdi be subject lo all the tall oHujing 'eiTri and tondilionx loihegowmng tlatvdtcathin on the date <HiKc ihiptnem Shipper hereto, ccrlilics that he iv Cinltar with afl the lading terms and ccnditns/u in the pjvemin* dflaMlkaliun and the said toms and ccvhiioea ate hereby agreed to by the shipper and accepted lor hicnjrtt and ha aiMgns SHIPPER:CAMECO RESOURCES CARRIER:D LOGISTICS PER DATE "s PER ^ DATE -7//V/7 i. KSO: Operations: — Rev 4 June 09, 2016 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading.xlsx ~?ll tlt7 Smith Ranch Controled Elevation used (Cell 3)5612.6 Area Elevation Transit Shot Initial shot for trench 5.18 Top of trench 5609.29 8.49 Bottom of trench 5604.38 13.4 Initial shot used for material 5.18 Tod of material in trench 5606.97 10.81 Top of cell 3 Liner 5608.5 Feet below liner 1.53 5=,..,,, = - S/^'ooo£ "Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 53173 Blanding UT 84511 Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: Date Time Scale In: 07/18/2017 07:15 1 Out: 07/18/2017 07:46 1 11(e)2 WYO SMITH RANCH Gross: 56300 lb (M) Tare: 43540 lb Net: 12760 lb 11(e)2 Mat 11(e)2 Material Receipt BLANDING Comments: TRL # GFLU2003 Operator: 4 Charge by Weight Signature: < t^ Jir ' No.: TBL-IO ENERGY FUELS RESOURCES (USA) INC. 1 Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: November 13,Title: 1 le.(2) Byproduct Disposal I 2014 ATTACHMENT 2 lie.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:___ffMl?____ Name of employee receiving the load: __ Tcr^y _______ Generator of the Byproduct Material:__ Shipper’s Manifest or Bill of Lading number: (yzhl - i> l Who gave and when was the notification given? D a-v' .^ Vis r k'-j__^2-1 AS i l~J Description of byproduct material disposal area/activities: C- I TWnjy ^ ^ Uj» ho $ La Has each dmm been inspected to identify the presence of any void spaces? jUJK Have all drums with void spaces been filled with tailings sands or soil?/JA____________ Which tailings cell was the material placed in? C-zW 7? _________ 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? Aa. Cr-j^ l__U> iW Av_ oloqjA- 4t> J> CK«rCA-S. Was the material segregated from any Mill material or equipment disposed of in the cell? VcJ-........................................................................................................................................................................ 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 #: Ozhl O 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? Documentation of approval P}uT 4^^ 7 Was the ISL material segregated from disposed Mill material and other ISL material? /e ^ Refer to plat(s) used to confirm. ,/>// % lie- Z &\s*za/ Ar** 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? fo- Refer to drawings used to confirm Cell j Cc/a/'. Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Ytj Refer to drawings used to confirm. cell 5 e',,*sk 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) Sun/t*./, 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? Corfu, fly \ a-ft. J lb M. __— If P-4-___________________________________________________________________________________ Were void spaces filled with tailings? Vcr_________________________________________ ..._____________________ Was the shipment properly covered? St-Cr ih,ho ^ ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 13 of 13 “No.: PBL-10 : Rev. No.: R-3.3 j Date: November 13, i 2014 ________ Manifest or BQL #: P Z,/r74-*s\ Are additional settlement monitors required to be placed for this generator? AS.A^:■ If required, where were settlement markers were placed? ------------A/. A_________________—........................................................ Radiological receipt survey measurements: .. Breathing Zone: 1. 2. Was a Breathing Zone Sample collected? Yes ojff^ If yes, what were the results of the sampling? r NoWas a photograph taken during the unloading activities?- uranium one BILL-OF-LADING & LICENSED MATERIAL SHIPPING FORM EMERGENCY CONTACT: (307) 267-4623 BYPRODUCT SHIPMENT ID# 02/17 SHIPMENT DATE 8/3/2017 SHIPPER (From) Uranium One Americas Irigaray/Christensen Projects, NE of.Linch, Wyoming CONSIGNEE (To) : White Mesa Mill ADDRESS 907 N. Poplar St Suite 260 Casper, WY. 82601 ADDRESS 6425 South HWY. 191 Blanding UT, 84511 SHIPPER LICENSE NO. SUA-1341 Uranium One SHIPPER USDOT NO. USDOT 1698297 CONSIGNEE LICENSE NO. UT 1900479 CONSIGNEE TELEPHONE NO. (435)-678-2221 SHIPPER HAZMAT REG. NO. 071116 550 049Y SHIPPER TELEPHONE NO. (307) 696-8140 CARRIER NAME AND ADDRESS Greenfield Logistics LLC PO Box910332 ST George, UT 84791 CARRIER USDOT NO. 919061 CARRIER HAZMAT REG. NO. 062916 552 046Y HM DESCRIPTION OF MATERIAL AND PACKAGING (USE PROPER CLASSIFICATION) VOLUME cubic feet CLASSIFICATION X UN 2912, Radioactive Material, Low Specific Activity-1, solid waste, scrap material and soil containing residues of uranium- natural. Container #U1 0001=764.1 CF Container #U10002 = 764.1 CF Low specific activity (LSA) Activitv: 370 MBa l .01 Cl)Total 1528 CF Curie (Ci) = 7.1 E-7 x grams of uranium (natural) Megabecquerel (Mbq) = Ci x 3.7 E4 Exclusive use shipment CERTIFICATION: These is to certify that the above named articles are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation, according Ip the applicable regulations of the Department of Transportation and the U.S. Nuclear Regulatory Commission Shipper's Signature:^ Driver's Signature: Date: ate: ^ViTt DESTINATION ONLY Received by: Indication of leakage^NO^ YES ./&.VT.U i M.AsxL If yes, give^planation: Date: -g H Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 ** Reprinted by '4 at 08/04/17 15:13:40 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: T3 URANIUM ON URANIUM ONE lle2 URANIUM ON URANIUM ONE lle2 BLANDING Transaction No. 53192 Date Time Scale In: 08/04/2017 14:15 1 Out: 08/04/2017 15:12 1 Gross: 61780 lb (M) Tare: 46960 lb Net: 14820 lb 4- u \ Comments: TRL 3 Ul-001, Ul-002 Operator: 4 Charge by Weight l r\ * 1 Signature: ' ^ ^ 1 r- QOL' Uranium One Controled Elevation us 5612.6 / ^ ± -OZl \7 - C'C>^+o.,^cr-j&.o\ Area Elevation Transit Shot Initial shot for trench 5.18 Top of trench 5608.69 9.09 Bottom of trench 5603.08 14.7 Initial shot used for material 5.18 Tod of material in trench 5607.08 10.7 Top of cell 3 Liner 5608.5 Feet below liner 1.42 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 Page 11 of 13 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:____ Name of employee receiving the load: ^rvy SI a-tl C____ Generator of the Byproduct Material: ___ Shipper’s Manifest or Bill of Lading number: z. It?-^ tt. Lh U Was the State of Utah given notice to the receipt/disposal activities associated with this load?/^ei or No Who gave and when was the notification given? tWIA , 7| ........................... Description of byproduct material disposal area/activities: t <_____________..............fi*. f-fg- . 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? A/A- Which tailings cell was the material placed in?____/.r:\ \ 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? . fyMk cvLt-rrl' tvi.—Luifo-Ji_pImC j-A. . i -v—jh---Tot ___T-L? ?-v E ..................................jr.e_ t . 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? Vcf 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 #: ^ 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 $ uT tyotVy1! 7 £ Was the ISL material segregated from disposed Mill material and other ISL material? ^ Refer to plat(s) used to confinn. £<*// 3 //<?.& 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? K-y Refer to drawings used to confirm C< it 3 O'* —-& Is the bottom of each disposal area at least 12 feet from the sicies or dikes of the tailings cell? .&< Refer to drawings used to confirm. Cell 3 f & 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) r v € if & 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? -JL _Jr___________4__ Were void spaces filled with tailings? ____________________ Was the shipment properly covered? ______________________________ No.:' PBL-10 Rev. No.: R-3.3 ; ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES i Page 13 of 13 Date: November 13, 2014 Title: lle.(2)B>product Disposal Manifest or BOL #: £.1 il 0~Cr^& 07^ Are additional settlement monitors required to be placed for this generator? ______AlJz—----------------------------------------------------------------------- If required, where were settlement markers were placed? _______MJs_________ Radiological receipt survey measurements: . 5 <Kld Lr t RXD -O_________ Breathing Zone: 1. 2. Was a Breathing Zone Sample collected? Yes oi If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?/1?eshr No uranium BILL-OF-LADING & LICENSED MATERIAL SHIPPING FORM EMERGENCY CONTACT: (307) 267-4623 BYPRODUCT SHIPMENT ID# 02/17 SHIPMENT DATE 6/3/2017 SHIPPER (From) Uranium One Americas Irigaray/Christensen Projects, NE of Linch, Wyoming CONSIGNEE (To) : White Mesa Mill ADDRESS 907 N. Poplar St. Suite 260 Casper, WY. 82601 ADDRESS 6425 South HWY. 191 Blanding UT, 84511 SHIPPER LICENSE NO. SUA-1341 Uranium One SHIPPER USDOT NO. USDOT 1698297 CONSIGNEE LICENSE NO UT 1900479 CONSIGNEE TELEPHONE NO. (435)-678-2221 SHIPPER HA2MAT REG. NO. 071116 550 049Y SHIPPER TELEPHONE NO. (307) 696-8140 CARRIER NAME AND ADDRESS Greenfield Logistics LLC PO Box 910332 ST George, UT 84791 CARRIER USDOT NO. 919061 CARRIER HAZMAT REG. NO. 062916 552 046Y HM DESCRIPTION OF MATERIAL AND PACKAGING (USE PROPER CLASSIFICATION) VOLUME cubic feet CLASSIFICATION X UN 2912, Radioactive Material, Low Specific Activity-1, solid waste, scrap material and soil containing residues of uranium- natural. Container #U1 0001= 764.1 CF Container #U 10002 = 764.1 CF Low specific activity (LSA) Activity: 370 MBa f .01 Ci)Total 1528 CF Curie (Ci) = 7.1 E-7 x grams of uranium (natural) Megabecquerel (Mbq) = Ci x 3.7 E4 Exclusive use shipment CERTIFICATION: These is to certify that the above named articles are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation, according tp the applicable regulations of the Department of Transportation and the U.S. Nuclear Regulatory Commissic Shipper's Signature: :ommissioi> / Date: Driver's Signature: [ *%— l <'yL DESTINATION ONLY ^Received by: Indication of leakagqr!NO] YES If yes, give^iplanation: Date: % -A-\l Uranium One V x Controled Elevation us 5612.6 Area Elevation Transit Shot Initial shot for trench 5.18 Top of trench 5608.69 9.09 Bottom of trench 5603.08 14.7 tial shot used for material 5.18 Too of material in trench 5607.08 10.7 Top of cell 3 Liner 5608.5 Feet below liner 1.42 C?Z 1 4- oz. Transaction No. 53192 Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blending UT 84511 ** Reprinted by 4 at 08/04/1,7 15:13:40 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: T3 URANIUM ON URANIUM ONE lle2 URANIUM ON URANIUM ONE lle2 BLANDING Date Time Scale In: 08/04/2017 14:15 1 Out: 08/04/2017 15:12 1 Gross: 61780 lb (M) Tare: 46960 lb Net: 14820 lb Comments: TRL 3 Ul-001, Ul-002 Operator: 4 Charge by Weight Signature:JnAU'wv /I ’No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.i Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 | Date: November 13.Title: Ile.(2) Byproduct Disposal | 2014 | ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: ^/|Q/>7____ Name of employee receiving the load: _ TV y AT a Ac. Generator of the Byproduct Material: u£c_ Shipper’s Manifest or Bill of Lading number: 4- P - O ZS ______ Was the State of Utah given notice to the reccipt/disposal activities associated with this load? (ycsY>r No Who gave and when was the notification given? . ..... llislt 7_____________________________________.. . Description of byproduct material disposal area/activities: Has each drum been inspected to identify the presence of any void spaces? Ye.5 ___ Have all drums with void spaces been filled with tailings sands or soil? coc-rt, Ucek u>f W l WTiich tailings cell was the material placed in?___£e-li _______________ 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? - I A________________4-Ufc-T_______fo TL.iL . Was the material segregated from any Mill material or equipment disposed of in the cell? _.... ics: Was the material segregated from byproduct material from other 1SL 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 #: L P- O 7 y 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 mT itjodHT*} /W»» 7 Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. ctU 3 /Je-.z & 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? fry Refer to drawings used to confirm Ceti 3 Co.nfr T Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? < Refer to drawings used to confirm. Cth 3 c'o/i^h e & Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? Jld How was this confirmed (e.g., survey or review) —----------------- ^___________ 7 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? /Ar-c-e- _A.__lP Cc Acr__tfcir__(f__hi__________fjCrc:__l■ ^^ _____ Were void spaces filled with tailings? Was the shipment properly covered? _____Vg-St oJsxyy c No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 iDate: November 13, 2014 Title: 1 le.(2) Byproduct Disposal i 11 Manifest or BOL #: L P-O 2.6 Are additional settlement monitors required to be placed for this generator? ______xtA_______________________________ If required, where were settlement markers were placed? AlA_____________________:_________ Radiological receipt survey measurements: __pr P' 0________^ Breathing Zone: 1. Was a Breathing Zone Sample collected? Yesor^f^ 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?/! es)>r No Shipment Number t-l ~~ I'ok BILL OF LADING - LICENSED MATERIAL SHIPPING FORM 24-HOUR EMERGENCY CONTACT NUMBER/PROVIDER & CONTRACT NAME OR No. (830j 583-4222 Kevin Dziuk (Radiation Safety Officer) CONSIGNOR (Shipper/From): Company Name and Site CONSIGNEE (Receiver/To): Company Name and Site South Texas Mining Venture LLP - Benavides, Texas Energy Fuels - Blanding, Utah ADDRESS: 5781 FM 3196 Benavides, TX 78341 ADDRESS: 6425 S Highway 19 Blanding, UT 84511 SHIPPER TELEPHONE No.: (361)256-3995 CONSIGNEE TELEPHONE No.: (435)678-2221 SHIPPER/TRANSPORTER INFORMATION SHIPPER NR C/STATE LICENSE No.: R06062 SHIPPER USDOT No.: 148604 CARRIER NAME: Cosby Trucking CARRIER USDOT No.: 298957 CONSIGNEE NRC/STATE LICENSE No.: UT 1900479 SHIPPER PHMSA REGISTRATION No.: 071111550027TV CARRIER ADDRESS: 601 S 200 E Blanding, UT 84511 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 i UN 2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1) (Solid Byproduct Material) Activity 37 Mbd ( Ci) Curie x 3.7E4 = 1 Megabecquerel Volume 11 cubic-feet 7 Estimated TH39- (asreeer ♦♦♦♦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, and are in proper condition for transportation accopdfng to the applicable regulations of the Department of Transportation. 17 SHIPPER'S SIGNATURE DATE date ‘S^8r-/r7 DATE 10-17 Controled Elevation used (Cell 3) UEC La-Palangana 5612.6 Area Elevation Transit Shot Initial shot for trench 5.18 Top of trench 5608.58 9.20 Bottom of trench 5602.29 15.49 Initial shot used for material 5.18 Too of material in trench 5606.55 11.23 OZ-5' Top of cell 3 Liner5608.5 Feet below liner 1.95 , ,1,1,1, ;............................ Enefgy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 53197 Blanding UT 84511 ** Reprinted by 4 at 08/10/17 07:32:41 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: 875 UEC MNT LU US ECOLOGY 11(e)2 Mat 11(e)2 Material Receipt BLANDING In: Out: Date Time Scale 08/10/2017 07:02 1 08/10/2017 07:32 1 Gross: 62520 lb (M) Tare: 33060 lb Net: 29460 lb Comments: TRL # 5 Operator: 4 Charge by Weight Signature: d U,Jt. / p~ozr